Detailed Environmental Impact Assessment

Environmental Impact Assessment on Proposed Development of a New Plasticizer Plant on Part of Lot 140 and a Tank Farm on Part of Lot 1863 at Gebeng Industrial Estate, Mukim Sg. Karang, Kuantan District, Pahang Executive Summary

EXECUTIVE SUMMARY

1 Introduction

The title of this study is the “Environmental Impact Assessment on Proposed Development of a New Plasticizer Plant on Part of Lot 140 and a Tank Farm on Part of Lot 1863 at Gebeng Industrial Estate, Mukim Sg. Karang, Kuantan District, Pahang”.

2 Project Proponent and Consultants

2.1 Details of the Project Proponent

Project Proponent : UPC Chemical (Malaysia) Sdn Bhd Address : B-08-07, Capital 2, Oasis Square, No.2, Jalan PJU 1A/7A, Ara Damansara, 47301 Petaling Jaya, Selangor, Malaysia Contact Person : Mr. Wu Wei Ting (Senior Manager) Telephone : +603 7859 7668 Fax : +603 7859 7669 Email : [email protected] 2.2 Details of the EIA Consultant

EIA Consultant : Chemsain Konsultant Sdn Bhd

Address : No. 41, 1st Floor, Jalan USJ 10/1D, 47620 Subang Jaya, Selangor Darul Ehsan, Malaysia

Contact person : Ms. Lina Chan (EIA Team Leader)

Telephone : +603 5637 0163

Fax : +603 5637 0385

Email : [email protected]

3 Legal Requirement

Under the Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order 2015, the above Project is a prescribed activity under Second Schedule:

Item 6: INDUSTRY

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Sub-item (d) Petrochemicals: Production capacity of each product or combined product of 50 tonnes or more per day.

Previously under the Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987, the above Project was a prescribed activity under:

Item 8: INDUSTRY

Sub-item (b) Petrochemicals: All sizes

In compliance with Section 34A of the Environmental Quality Act, 1974, an EIA report on the impacts of the proposed Project on the environment is to be prepared and submitted to the Department of Environment (DOE) Putrajaya, for approval prior to commencement of the Project.

This is requirement is confirmed by DOE Pahang via its letter referenced AS.C35/400/000/019 (02)] dated 25 March 2014 in its feedback to the submitted Penilaian Awal Tapak (PAT).

As part of DOE’s requirement, a Terms of Reference (TOR) for the proposed EIA study was submitted to DOE Putrajaya and endorsed on 17 September 2015

4 Statement of Need

The Plasticizer Plant is proposing to produce various types of plasticizer, namely Dioctyl Phthalate (DOP), Diisononyl Phthalate (DINP) and Dioctyl Teraphthalate (DOTP).

These plasticizers are used for different field of application. The demands in Malaysia and other ASEAN countries are increasing yearly. Statistically, ASEAN+6 regions are the most promising market for plasticizers and are anticipated to be the same in the near future. ASEAN is on track as a fast increasing market of plasticizers, with total demand is about 300,000MTA in 2014. The demand for plasticizers in the region is projected to grow at a CAGR of about 6.41% from 2014 to 2019. Due to its plasticising performance, and cost- effectiveness DOP is widely employed as a general purpose plasticizer especially with PVC. DINP, with higher permanency and lower volatility and improved resistance for cold outdoor conditions, is currently produced in Thailand in small quantity. Meanwhile DOTP is a non- toxic, eco-friendly plasticizer, which is widely used in physical contact product, e.g. gloves, toys, diaper. DOTP is the fastest growing non-phthalate plasticizers, with projected growth at a CAGR of about 10.18% between 2014 and 2019. In the ASEAN countries, all DOTP is imported, mostly from China and Korea.

Malaysia and specifically Gebeng Industrial Estate in Kuantan is selected for this proposed project due to its strategic presence in the ASEAN region. The proposed project is expected to make the best use of local and readily available raw materials by adding its value, and the proximity to the PVC downstream industries is expected to enhance the development of such industries in Malaysia.

This proposed project will create new career and business opportunities to the locals during both construction and operation stages. During construction stage, about 300 workers are expected to be involved during the peak time while about 100 skilled and semi-skilled workers are anticipated during the operational stage. Maintenance work will be outsourced from local engineering companies and local suppliers for consumable parts, tools, piping

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materials are required. There are likely more indirect opportunities being created in order to service the project and as such the proposed project is deemed to contribute to the economic growth of the region. In addition, about 150,000 tonne of chemicals will be imported and exported through Kuantan Port annually. These will not only increase the berth usage and efficiency, but the project will also contribute to the revenue of the local authorities and agencies, through various taxes and handling fees.

5 Project Location

The proposed Plasticizer Plant is located within part of Lot 140 of the Gebeng Industrial Estate, Kuantan, Pahang and a tank farm is located on part of Lot 1863 of Kuantan Port (see Figure ES 1). The coordinates of the project sites are as tabulated in Table ES 1. Table ES 1: Coordinates of the Project Sites

Project Site (Area size) Location Latitude Longitude Plasticizer Plant North corner 3° 58’ 46.63” N 103° 21’ 52.02” E (10 acres) East corner 3° 58’ 44.52” N 103° 21’ 56.08” E West corner 3° 58’ 38.15” N 103° 21’ 44.59” E South corner 3° 58’ 35.27” N 103° 21’ 48.17” E Tank Farm North corner 3° 58’ 41.19” N 103° 25’ 27.31” E (5 acres) East corner 3° 58’ 37.62” N 103° 25’ 29.68” E West corner 3° 58’ 38.37” N 103° 25’ 22.57” E South corner 3° 58’ 34.69” N 103° 25’ 25.03” E

The project site and the wider Gebeng Industrial Estate (GIE) are accessed via the East Coast Highway which links Kuantan and Kuala Lumpur. The Gebeng Industrial Estate is zoned for chemical and petrochemical industries.

6 Project Concept

The Plasticizer project consists of one Plasticizer Production Plant and one Port Tank Farm. The plasticizer plant consists of production lines and associated facilities and utilities, packaging, loading and storage areas and administrative office; while the port tank farm is for import and export activities as well as for storage for raw materials and products.

The Plasticizer Plant will produce three types of plasticizer which namely Dioctyl Phthalate (DOP), Diisononyl Phthalate (DINP) and Dioctyl Teraphthalate (DOTP). The Plant is designed for a production capacity of 120,000 tons / year of plasticizer. Depending on market requirement, the anticipated production ratio can be as presented in Table ES 2.

Table ES 2: Production Scenario (Source: UPC)

Type of Product Production Scenario (tons / year) A B C D DOP 120,000 0 0 30,000 DINP 0 120,000 0 30,000 DOTP 0 0 60,000 30,000 Total 120,000 120,000 60,000 90,000

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SOURCE: PENGUBAHAN RANCANGAN TEMPATAN DAERAH KUANTAN 2010-2015 (+)74''5Ä Environmental Impact Assessment on Proposed Development of a New Plasticizer Plant on Part of Lot 140 and a Tank Farm on Part of Lot 1863 at Gebeng Industrial Estate, Mukim Sg. Karang, Kuantan District, Pahang Executive Summary

The scope of this EIA will cover the construction and operation of:

. All production lines and associated facilities and utilities, packaging, loading and storage areas and activities within the proposed Plasticizer Plant on Lot 140; . The proposed Port Tank Farm and activities on Lot 1836; and . A new pipe-rack connecting the sources in BPC to the proposed Plasticizer Plant site.

7 Project Components and Layout

The estimated amounts of raw material usage and production quantity are shown in Table ES 3, while the plasticizer plant and port tank farm layout are presented as Figure ES 2 and Figure ES 3 respectively. Table ES 3: Estimated Raw Materials and Production Capacity

Materials Chemical Formula Estimate Quantity Supplier / Mode of (tons/year) Transport Raw Materials

Phthalic Anhydride (PA) C6H4(CO)2O 48,000 PA Plant located at BPC Site / via pipeline

Terephthalic Acid (PTA) C6H4(CO2H2)2 25,800 PA Plant located at BPC Site / via pipeline

2-Ethylhexanol (2EH) C8H18O 84,000 PA Plant located at BPC Site / via pipeline

Isononanol (INA) C9H20O 84,000 Imported via Kuantan Port and by tanker / truck to Plasticizer Plant Main Chemical Used

Tetraisopropyl Titanate C12H28O4Ti 60 Local supplier and by truck (TPT) / Titanium to Plasticizer Plant isopropoxide

Sodium Carbonate Na2CO3 45 Local supplier and by truck to Plasticizer Plant Products

DOP C6H4(C8H17COO)2 30,000 – 120,000 By tanker or truck to customer / Port Tank Farm

DINP C26H42O4 30,000 – 120,000 By tanker or truck to customer / Port Tank Farm

DOTP C6H4(C8H17COO)2 30,000 – 60,000 By tanker or truck to customer / Port Tank Farm Source: UPC

Raw materials will be supplied to plasticizer plant via pipelines and also trucks from tank farm. Material transported via pipeline is illustrated in the following Table ES 4.

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CHEMSAIN KONSULTANT SDN. BHD.

FUTURE

PARKING AREA

LAND AREA: 10Acres

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SUB 2500mƳ K-06 DOP tank T-C03 K-02 FIRE UT K-04 K-05 K-07 DOTP tank T-C04 K-01OFFICE REST ROOM WATER CTL

MCC WW PIT GUARD DINP tank ROOM TANK T-C05 FW PUMPS Staff Gate DINP tank T-C06 Raw Material Otho-xylene tank T-B01 2000m3x6, dia.16.5x13.0 Otho-xylene tank T-B02 K-03 2500mƳ 2500mƳ Otho-xylene tank T-B03 Loading Pumps OX INA Station Isononanol tank T-B04 T-B06 T-B03 Isononanol tank T-B05 Isooctanol tank T-B06 Pumps 2500m 2500m 1500m3x6, dia.13.7x12 Ƴ Ƴ OX OX MCC K-04 1500mƳ 1500mƳ 1500mƳ T-B05 T-B02 Fire pump K-05 DINP DOP DOP T-C06 T-C04 T-C02 Fire water tank K-06 Fire accident pool K-07 2500mƳ 2500mƳ Weighbridge K-09 1500mƳ 1500mƳ 1500mƳ INA INA DOTP DINP DOP T-B04 T-B01 Pipe network(factory) K-10 T-C05 T-C03 T-C01 Pipe network K-11 (Outside Plant)

/ TO Berth

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(+)74''5Ä Environmental Impact Assessment on Proposed Development of a New Plasticizer Plant on Part of Lot 140 and a Tank Farm on Part of Lot 1863 at Gebeng Industrial Estate, Mukim Sg. Karang, Kuantan District, Pahang Executive Summary

Table ES 4: Proposed Material Conveying Pipelines

Materials Specification of Pipeline Flow Direction Otho-xylene 3” UPC to BPC site as raw material to PA Plant 2-Ethylhexanol 3” BPC to UPC site as raw material Phthalic Anhydride 3” / 5” (jacket pipe) BPC to UPC site as raw material Plasticizer 3” BPC to UPC site for sale Waste Water 3” BPC to UPC site for treatment Steam 6” BPC to UPC site as energy Condensate 3” UPC to BPC site for treatment

Na2CO3 1.5” UPC to BPC site Source: UPC 8 Project Activities

8.1 Construction and Installation Stage

The development of the proposed project is estimated to take about 12 months. It is anticipated that upon the completion and approval of the EIA, and after other necessary permissions for development are granted, full scale construction works on-site will commence immediately. The construction and installation stage is expected to have the following activities.

Table ES 5: List of Activities during Construction and Installation Stage

Activity Description Mobilisation of Workers Include setting up of site office, sanitary facilities and other temporary and Machineries facilities required for the construction works. About 300 personnel are expected to be involved during the peak of construction stage. These

construction workers will be accommodated offsite or onsite and at appropriate quarters with proper hygiene and sanitation services. Transportation of The project site is easily accessible and about 3km from an existing Construction Material and expressway. The main entrance to the Project site is from Jalan Gebeng Equipment 2/1. Transportation of materials and equipment shall be planned to avoid the peak hours. Proper traffic and parking management will be implemented to prevent interference to other road users and to ensure safe movements around the work areas. Vegetation Clearing Minor removal of vegetation within the project site, mainly shrubs, will be carried out manually or by machinery. Vegetation waste will be disposed at approved site or reuse at site for soil erosion control purposes. Foundation Works Some soil and foundation improvement works are anticipated especially at areas to be loaded with Plant’s component. Earthwork will be very

minimal since the sites are prepared sites. Typical foundation work includes piling. Civil and Structure Works Civil and structural works involve frame work, casting, and building

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Activity Description components of the proposed Project. These works will include

construction of access entrance and internal access roads, and storm water drainage system. Structural steel work may include fabrication, erection, painting, sheeting and cladding works. Mechanical and Electrical Mechanical works, equipment installations and electrical works will Works include the necessary piping, electricity, material and water supply connection with external sources. Testing and Project’s components will be commissioned as they are completed. Commissioning Various load tests and performance tests will be conducted once all the associated plant’s components are commissioned. During this testing

and commissioning period, the operation mode will be fine-tuned and optimised where necessary Demobilisation of workers On completion of the development of the Project, all temporary facilities and temporary facilities. will be removed from site and these shall include any excess of construction materials and wastes.

8.2 Operational Stage

Principle of plasticizer production is by synthesis of specific type of phthalic anhydride and alcohol by non-acidic esterification catalyst. Different plasticizer is determined by the differences in alcohol used, proportion of different recipe and reaction time.

Generally, the production of DOP, DINP and DOTP are similar, which involve the following steps, and Figure ES-4 illustrates the typical plasticizer process flow.

. Monoesterification . Diesterification . Purification . Filtration

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Figure ES-4: Typical Plasticizer Process Flow Diagram

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8.3 Waste Management and Pollution Control System

Table ES 6 lists the potential sources of pollutants and the proposed control measures. Table ES 6: List of Potential Sources of Pollutants and Proposed Control Measures

Category Source Type of Pollutants Proposed Compliance Control Requirement Measures Air Reactor, vacuum, Off gases with Wet scrubber VOC ≤ 150 mg/m3 Emission washing process alcohol residue and de-alcohol

Wastewater Process wastewater, Average COD 10,000 WWTP with Standard B of scrubber mg/L capacity of Environmental Quality wastewater, 180 m3/day (Industrial Effluent) sewage, Regulations 2009 contaminated water from first flush pit Noise Motorised Elevated noise Enclosure Recommended equipment, pumps boundary limit: 70 and compressors dB(A) day time and 70 dB(A) night time Solid Office Domestic waste Approved - Waste landfill Process Packaging materials Construction Construction material Scheduled Filter cake Residue of Reutilise at Environmental Quality waste plasticizer, organic approved (Scheduled Waste) impurities facility Regulation 2005 Dispose at licensed facility Maintenance Used oils Recover or dispose at Materials licensed contaminated with facility scheduled waste WWTP Sludge

9 Project Options

9.1 Project Siting

The activities of a plasticizer plant do not emit much pollutant and can typically fit in any chemical industrial park. However, the proposed site was initially identified due to its proximity to the sources of feedstock and availability of required infrastructures. The followings further elaborate the site selection criteria and justification why the proposed sites at GIE were chosen.

Availability of Materials

Among the key feedstock and requirement for the plasticizer plant are 2-Etheyhexanol, phthalic anhydride (PA) and steam. UPC has an opportunity to source these key materials

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from existing production plants located within BASF PETRONAS Chemicals Sdn Bhd (BPC) site. As the proposed plasticizer plant is just across the road of BPC’s facility, these materials will be conveyed from BPC site via a new pipe rack. The vicinity of the sources of materials, reduces the development and operation costs and risks associated with materials handling, and ensure the efficiency of material supply to the proposed plasticizer plant.

Availability of Land and Land Use Zoning

The proposed sites, both for the proposed plasticizer plant (10 acres) and the port tank farm (5 acres) are prepared sites. They are both zoned for industrial use and readily available. Strategic Location

The readily available infrastructure and utilities are being described in Chapter 4 of this EIA report. GIE is well equipped with networks of roads and port facility. These provide the proposed Project a direct access to its markets within Malaysia as well as the ASEAN region, thus making the selected sites within GIE a strategic location. The Proponent intends to use the Kuantan Port’s liquid terminal to import and export its raw materials and products.

9.2 Technology Options

UPC uses non-acid catalysis esterification as their process option to produce the desired plasticizers. The process was chosen because it is safer, cleaner and higher quality compared to acid catalysis esterification.

A non-acid catalyst, tetraisopropyl titanate (TPT or titanium isopropoxide is preferred as it allows high quality production, low feedstock loss and less complex catalyst removal process.

The Proponent intends to apply the following Best Available Techniques for the control of emissions for the proposed Project.

. Condensation will be used to recover alcohols and the recovered alcohol will be reused in the plasticizer production. This will also reduce the mass flow to downstream abatement; and

. Wet Scrubbing with water is selected as it has performance up to 99% of reduction for inorganic compounds and highly water soluble VOCs (e.g. alcohols) and the wastewater generated is not difficult to be treated.

9.3 No Project Option

The benefits of considering the “No Project Option” will be the absence of all environmental impacts and its associated costs as a result of the proposed Project. However, some potential social, economic and environmental benefits will be lost as a result of the “No Project Option”.

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10 Existing Environment

The existing environment of the surrounding area of the Project site is summarised in the following Table ES 7. The baseline monitoring stations are illustrated on Figure ES-5. Table ES-7: Summary of the Existing Environment

Parameters Description Physical Environment Topography Both proposed plasticizer site and port tank farm are prepared lands which relatively flat. The plasticizer site is currently unused and habituated with shrubs while the proposed port tank farm was used for open storage. Soil and Geology Site is mainly located on organic soils, principally peats with some muck, developed over mineral alluvial soils in poorly drained situations, of limited suitability for agricultural development. The bedrock is underlain with marine and continental deposits of clay, silt, sand and peat with minor gravel of Basalt of early Pleistocene age in the Kuantan area. Hydrology and GIE has network of a purpose designed drainage system and these drainage Drainage system discharges into both Sg. Tunggak and Sg. Balok. The Project site discharges into PKNP’s storm water drain and ultimately into Sg. Balok. Meteorology Kuantan experiences the Northeast monsoon occurring from November to March and the Southwest monsoon occurring from May to September. The 24-hr mean temperature fluctuates in a small range around 26.4 °C. The average annual 24- hour relative humidity is 85.1%. Average annual rainfall recorded at Kuantan Airport over the period 1968 to 2014 is approximately 2,986.1 mm with an average of 185 rainy days per year River Water Water quality at monitoring locations range between Class II and Class III Quality requirements of the NWQSM. COD for most water samples did not comply with Class III requirement of 50 mg/L. Organic matter in the water at these monitoring locations could be contributed by the surrounding natural peat swamp as well as the discharges from the industrial activities in the Gebeng area. High COD at the monitoring locations were also observed in other reported studies. Air Quality Ambient air quality at the four monitoring locations complied with the recommended ambient air quality guideline limits. Noise Level Measured noise levels at N1 (Project site) complied with DOE stipulated limits for industrial setting but the existing noise levels at N2 (at Taman Balok Makmur,) were higher than the respective stipulated limits for suburban residential setting. Biological Environment Flora and Fauna Both the proposed Plasticizer Plant and Port Tank Farm sites are prepared areas and have no ecological importance. Land Use and Human Environment Land Use The proposed Project site is located on prepared land southeast of an existing warehouse facility managed by Pacific Selatan Agency Sdn Bhd at GIE and a port tank farm on a prepared land within the Kuantan port. The GIE is primarily intended for chemical and petrochemical industries. The Pahang State Development Corporation (PKNP) is the authority responsible for the development and management of the industrial estate. The land uses within the zone of study are mostly industrial (Figure ES-6). Based on the Rancangan Tempatan Kuantan 2010 - 2015, the Project site and its immediate surrounding areas are zoned for industrial (Figure ES-1). Human Nearest residential area is Taman Balok Perdana and is approximately 2.4 km Settlement away from the plasticizer site.

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Parameters Description Public Socioeconomic Survey Participations Most of the respondents are unaware of the proposed Project but they are fully aware of GIE. The survey showed that majority of the respondents thought that the proposed Project would benefit the State (42%) and the local community (38%), the others expressed uncertainty as they had no knowledge of the Project. 72% expressed that there might be some environmental concerns while 23% of the respondents were not sure. Majority of the respondents viewed that changes to air and water would be of concern, followed by health and safety risks.

Dialogue the Communities and Stakeholders A dialogue session was carried out in the presence of the Project Proponent, Environmental Consultant, industrial stakeholders, and representative from Balok residential areas on the 11 September 2015, at De Rhu Beach Resort. The dialogue aimed to brief the stakeholders on the Project scope and dissemination of information. Public Health Survey conducted showed that the local community had very good basic amenities which include safe water supply, appropriate sewage and solid waste management system. The period prevalence rates of non-communicable diseases in this local community were lower than those reported in the National Health and Morbidity Survey Information System III (NHMIS III, 2006). In general, the incidences of diseases which could be direct or indirect results from the exposure to the putative source of hazardous effluent, and poorer air quality were apparently low. From the secondary data review, for outpatient visits at the health clinics, the URTI made up a large proportion of all cases seen in the health clinics, KK Balok and KK Beserah in Kuantan. For hospital admission, respiratory diseases were the main cause of admissions in the medical wards, followed by cardiovascular diseases. Highest case fatality rate was due to cardiovascular diseases.

Chemsain Konsultant Sdn Bhd P a g e | ES-11 CK/EV703/7008/15

11 Impacts Assessment and Mitigation Measures

The findings from the environmental impact assessment and the recommended mitigation measures are summarised in Table ES 8.

Table ES 8: Summary of Impacts and Recommended Mitigating Measures

Aspect Impacts Mitigation Measures Monitoring 1. Air quality Construction stage . Exposed soil areas, excavated materials and Ambient air stockpiles must be damped or covered during dry monitoring. . Fugitive dust emissions from construction activities and windy days to reduce fugitive dusts. have the potential to result in localised impacts on Stacks emission air quality unless controlled. . Exposed site areas should be kept to the minimum monitoring during the required and completed areas should be hard operation stage. Operation stage surfaced/re-vegetated as soon as practicable. . Off gases generated by processes in the proposed . Speed limit to be imposed on vehicles entering the plasticizer plant will mostly be alcohol as volatile Project site to reduce dusts. organic compounds (VOCs). It was assumed mostly is xylene. There will be no combustion off . Fuel burning equipment to be regularly maintained gases. and serviced to prevent the emergence of dark smoke. . Modelling of the maximum 1-hour, 8-hour, 24-hour and annually average VOC concentrations in . Prohibit open burning. ambient air were conducted. As there is no specific . Emission limit for VOC at scrubber stack to comply ambient air guideline level for VOC in Malaysia, 3 Arizona Ambient Air Quality Guideline is used as with 150 mg/m . reference. In both scenarios, with and without . Ensure scrubber is well maintained and be able to control, the predicted VOC levels in ambient air safely remove VOC from the plasticizer processes. were well below the guideline level. Wastewater from the scrubber shall be treated at the proposed WWTP. . Provision of spare parts to facilitate immediate repair requirement. . Minimise fugitive leaks by proper engineering measures.

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Aspect Impacts Mitigation Measures Monitoring 2. Water quality Construction stage . Execute erosion and sediment control plan during Water quality earthwork and civil and structural work. monitoring at . Both plasticizer plant and port tank farm are already receiving waterways prepared areas, therefore minimal earthwork is . Provision of adequate numbers of sanitation expected during construction stage. facilities (portable toilets and/or toilets with septic Effluent monitoring tank) for the construction workers. during the operation . As the number of workers will increase gradually stage. and duration of work for each group of workers at . Portable toilets and/or toilets with septic tank shall site is short term, it is proposed that temporary be regularly de-sludged. holding tanks are to be used to contain sewage generated during construction stage. Likeliness for . Provision of containment trays/ drip collection sewage to enter nearby water bodies is considered devices shall be made available for vibrating to be negligible. machines such as generator sets, bar cutting and bending machines. . A major spillage or leakage of oil and grease or chemicals is considered to be remote and unlikely . All temporary fuel tanks and storage areas should to happen if proper house-keeping is practised and be provided with drip collection devices and be stringent handling and containment facility are sited on sealed areas with a bund enclosure implemented on site. capable of containing 110% of the inventory of the largest tank; the provision of a weather shelter over Operation stage the storage tank is an appropriate measure to prevent the accumulation of rainwater within the . Dedicated containment facilities will be provided for bund. storage areas. First flush pit (FFP) will be installed at both plasticizer plant and port tank farm to . Temporary fuel storage facilities and refuelling activities should be located away from on-site isolate potential contaminated water during rain events. Hence, the likelihood of contaminated drainage channels. storm water to enter nearby water bodies is . Heavy machinery and vehicles need to be considered to be not significant. maintained regularly and checked for leaks. Maintenance of equipment on site involving the . Process wastewater and sewage will be treated at 3 handling of oil and grease is to be carried out at an a centralized WWTP with capability of 180 m /day, appropriate workshop which is to be appropriately using biological treatment. The WWTP treated bund and equipped with oil and grease trap that is effluent shall comply with Standard B requirement of the Environmental Quality (Industrial Effluent) regularly inspected and maintained. Regulations 2009. . Spill cleaning kits are to be located at strategic locations in the plant area to be used in the unlikely . The storage tank farms will be located within

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Aspect Impacts Mitigation Measures Monitoring product-resistant concrete bund enclosures event of a spillage of chemical or oil related capable of containing 110% of the contents of the material. largest tank within the enclosure. . All site workers are to be trained regarding the appropriate use, handling and disposal of site based chemicals and lubricants, as well as emergency spill response. . Provision and maintenance of all control devices (sump pit, containment facilities) to ensure its effective at all time. . Water accumulated within the containment facilities and sump pits will be checked for contamination. If contamination is detected in accumulated water, it will be pumped to the WWTP for treatment. . Periodical inspection and maintenance of the sewer system is important to ensure that it is effective at all time. . Production area shall be provided with concrete catchment systems and to route surface runoff/spillages to purpose designed drainage collection with FFP. Contaminated water with COD >200 ppm will be treated at the WWTP prior to discharge. . All truck drivers need to be provided with appropriate training on handling the chemical that will be transported . Provide PPE and ERP tools in each transportation truck to facilitate emergency response should there be any accidental spill during transportation. . Should the WWTP fails or shuts down, the overall process activity at the Plasticizer Plant will be shut down until the WWTP resumes its operation.

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Aspect Impacts Mitigation Measures Monitoring . Performance monitoring at the wastewater treatment system shall be implemented as per requirement of the Environmental Quality (Industrial Effluent) Regulations 2009 to ensure effective wastewater treatment. 3. Noise Construction stage . Establish periodical maintenance schedule for all Boundary noise motorised machineries and equipment as monitoring . Noise impacts from construction activities are preventive measure to minimise emission of loud temporary in duration and can generally be noise. controlled to within acceptable levels. . Enclosure or other type of acoustic measures shall Operation stage be applied on equipment which contribute to noise . Noise levels during normal plant operation are levels higher than 85 dB(A). expected to be below 70 dBA at the boundaries of . Safety signage shall be installed to inform workers the proposed site. No noise impact at community of areas with high noise level. areas is expected. . Provision to workers who work in high noise level areas with adequate protective devices such as earmuffs or earplugs. 4. Health . Both carcinogenic and non-carcinogenic chronic . Provision of medical checks and vaccination for Ambient air health risk assessment for xylene at identified workers, especially foreign workers, to prevent monitoring. receptor locations indicated that the calculated HI transmission of communicable and vector borne Stacks emission values of emission pollutant concentrations were diseases. monitoring during the below 1. . Removal of areas of stagnant water and having operational phase. . This suggests an unlikely chronic health impact proper waste and sanitation management plan to from the operation of the proposed plasticizer plant, prevent breeding of vectors. during both normal operation scenarios and the projected worst case emission scenario. . Provision of adequate and suitable PPE to workers and visitors at the site for protection. . Periodical education of workers on risks present at the site, including proper safety procedure and correct hygienic practices. . All emission control equipment shall be operated

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Aspect Impacts Mitigation Measures Monitoring and maintained to ensure consistent compliance with recommended emission limits. . Any changes involving the increase of emissions to the atmosphere are to be further assessed in the context of human health impacts to surrounding areas. . Chemical health risk assessment (CHRA) shall be conducted during operational stage to identify the workers’ exposure risks and the type of exposure monitoring, if required. 5. Risk . Consequence analysis of the identified hazards . Prepare an emergency response plan (ERP) to - Assessment related to the Project operation showed that the include possible emergency scenarios. potential outcome due to release of hazardous materials on site are pool fire, jet fire, flash fire and . Engineering design for the process equipment and tank shall ensure that sufficient reliability, explosion. redundancy and basic process control system . 1 x 10-5 per year IR contour remains within the along with the independent Emergency Shutdown industrial developments i.e. Gebeng Industrial System (ESD) is accounted for, to prevent tank Estate. overfilling, potential loss of containment which may -6 eventually lead to a vapor cloud explosion . 1 x 10 per year IR does not encompass the scenario. nearest sensitive receptor area. . Both proposed tank farm and plasticizer plant have . Depending on the composition of the Otho-xylene, the need for draining water from the bottom of the tolerable risk in term of societal risk. storage tank to prevent potential boil over scenario shall also be assessed. . During the design phase, scenarios of tank rim seal fire and full tank surface fire should be assessed along with the identification of neighboring tanks potentially impacted by thermal radiation from the tank on fire. Radiation shields can be recommended to fight fire if deemed necessary based on the outcome of consequence analysis. The firewater demand calculations in the design phase must account for sufficient supplementary

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Aspect Impacts Mitigation Measures Monitoring firewater and its application rates for cooling the tanks in the above-mentioned scenario. . The capacity of the bunds shall be designed to comply with NFPA 30 standard and the bunds should be leak-tight and fire-resistant. . All emergency shutdown valves provided shall be fire-proofed for adequate time duration and the remotely operated shut down valves can be considered to prevent escalation of fire. . Ensure only fully trained and competent personnel are employed for the proposed process and storage area. . Enforce safety procedures to ensure authorized access only to the proposed project site and further restrictions are in place for limiting process and tank area access to approved persons only. . Ensure tanks in operation have enough headspace margins for the intake to be closed off in time. . Ensure protection systems are thoroughly inspected, maintained and tested periodically. . Perform regular emergency response drills (including desktop exercises) as well as feedback and review sessions with the local fire and rescue services for handling and controlling the worst case scenario. . Undertake regular maintenance of the process equipment i.e. tanks, piping, pumps and process vessels in accordance with manufacturers guidance.

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Aspect Impacts Mitigation Measures Monitoring 6. Waste Construction stage . Establish a waste management plan which includes - generation allocation of a dedicated construction waste . Various construction wastes will be generated storage area on site, frequency of waste collection including construction waste, scheduled waste and and disposal and periodical inspection on site. domestic waste. . Minimise generation of solid waste by sound Operation stage planning of material usage, using reusable items . Two major types of waste are domestic wastes and and encourage 3Rs. scheduled wastes. Domestic wastes are from the . Scheduled wastes shall be managed and handled offices while the scheduled wastes are largely in accordance with the Environmental Quality industrial wastes including filter cake, used oil and (Scheduled Waste) Regulation 2005. WWTP sludge. . Provide adequate number of waste bins at strategic locations around the site office and work areas. . Temporary storage areas for scheduled wastes where floor should be concreted, roofed, provision of concrete dyke and sump for spillage containment. Incompatible scheduled wastes shall be segregated accordingly. . Spill kits are to be made available for the containment or clean-up of spills. . Collection, recovery or disposal of scheduled wastes shall be by DOE licensed transporters to approved and licensed premises. . No open burning. . Good housekeeping 7. Traffic and Construction stage . All appointed contractors and sub-contractors - transport (including transporters) shall comply with safety . GIE has good road network. procedures and regulations stipulated by the Road Transport Department. . It is anticipated that increase of traffic volume due . Speed limit and other traffic laws should be strictly to proposed project is limited during peaks hours observed. Only qualified and competent drivers or

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Aspect Impacts Mitigation Measures Monitoring due to movement of workers. Transportation of personnel should be allowed to operate the construction materials and equipment shall be equipment and machinery on site. planned to avoid these peak hours. Proper parking . Vehicular movements for transportation purposes area and waiting bay shall be allocated. and other associated activities, particularly heavy, slow-moving vehicles, should be avoided during . Under normal circumstances, the anticipated traffic peak traffic hours. due to the development of the proposed port tank farm at Kuantan Port is not expected to be . Provision of flag man or traffic management team significant. However, based on recent site to control movement of traffic during peak hours observation (in October 2015), the existing traffic to and during mobilization and demobilization of the Kuantan Port area was experiencing delays heavy machineries. due to poor coordination of bauxite transportation . Provision of adequate warning signage on existing in the area. This may pose a concern to the of heavy vehicles along the approaching road to the proposed project as transportation and movement designated entrance. to the proposed port tank farm may suffer the same delays. . Designate a parking space and large enough Operation stage parking space for cranes and heavy trucks. . Transportation trips to be generated by the . Regular maintenance of vehicles and use of proposed Project are estimated to be 21 trips per manufacturer approved parts to minimise day and these are not expected to have any potentially serious accidents caused by equipment significant impact on the existing road service in malfunction or premature failure. the GIE. . Collaboration with local communities and . As the main transportation points are between the responsible authorities to improve signage, visibility proposed plasticizer plant and the port tank farm, and overall road safety. and that both of these locations and the access roads are located within industrial areas, the potential impacts to sensitive community are not expected to be significant. 8. Socio- . Beneficial impacts will include job and business . Provide information and involve the communities - economic opportunities, technology and knowledge transfer, within the zone of influence in emergency and socioeconomic development in the area. preparedness and response plans and relevant drills. . Proponent will have the capacity to bring in much of their development and experiences in the . Establish a mechanism to deal with grievances and

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Aspect Impacts Mitigation Measures Monitoring production of plasticizer to Malaysia. expectations from local stakeholders. . Main concerns of local community are related to deterioration of air and water quality. These aspects are addressed in EIA. 9. Project . Although unlikely, abandonment could occur during . Detailed abandonment plan shall be prepared and - abandonment construction stage or when facility is in operation submitted to DOE, which shall include scheduled due to unforeseen circumstances like economic programme of its implementation and the recession, natural disasters or political reasons. associated management plans.

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12 Conclusion

Perceived residual impacts are associated with air, water and safety risk during operational stage. It is suggested that while residual impacts will remain, the impacts will be within Malaysian planning and environmental standards and regulations, and will not cause significant adverse effects on the surrounding environment. In order to ensure that the measures implemented are effective at all times and residue impacts remain insignificant, an Environmental Management Plan with associated environmental monitoring and auditing as well as Emergency Response Plan are recommended to the Proponent.

This EIA has demonstrated that with proper incorporation of the recommended mitigating measures, the proposed Project can be implemented with acceptable environmental risk and impacts.

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