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ASIAN PRECIOUS MINERALS LIMITED – EIA REPORT CEMENT PROJECT

Chapter – 5, Evaluation of Impacts & Mitigation Measures Page – 5.1

5.0 EVALUATION OF IMPACTS AND MITIGATION MEASURES

Evaluation of the likely adverse impacts of pollution from the project duringconstruction and regular operation and mitigation measures to be adopted are detailedbelow.

5.1 Assessment of Any Environmental Impact on Local Population and the Environmentduring Construction and Operational Phase.The proposed project site is situated in rain fed agriculture area with mining arealocated in perennial grazing, short grasses, bushes/shrubs and scrubs.

Details about the human settlements in the area are given in the Chapter - 4, Section4.4. Nearest town is Choa Saidan Shah, which also Tehsil headquarter.

Three cement plants are location in the Project area. In view of the strict environmentalmanagement measures to be adopted during construction and operation of the plant,there will not be any adverse impacts on the population and environment around. Asystematic account of the environmental issues and their solutions is providedhereunder.

During construction and operation phases of the project pollutants like effluent,gaseous emissions, particulate matter, solid wastes and noise will be generated. Thelikely impacts of pollutants, in case environmental controls are not put in place for theirmitigation, are discussed here. Details are also given as how environmentalmanagement practices to be adopted will help to undo adverse environmental impactson all segments of the environment.

5.1.1 Environmental Adverse Impacts and Remedies -During ConstructionThe likely adverse environmental impacts to occur due to the project activity duringconstruction phase are described as below



Excavation, construction activities, moving vehicles, machinery & materials transportactivity and plant installation are the likely main sources of pollution during constructionphase.

The pollutants during construction will be emissions including sulphur dioxide (SO2),nitrogen oxides (NOx), carbon monoxide (CO); particulate matter (PM); noise frommachinery and vehicles and sewage from the work force. Dust (PM) will also begenerated especially during leveling, excavations of the land for civil construction,moving machines and transport.

Construction activities will be carried out according to a well-planned action plan basedon sound environmental management and controls principles. The construction plan willbe prepared also keeping in view avoiding maximum use of machinery at the same time.Rather, the minimum number of machines and execution of minimum number ofoperations/construction/plant installations jobs at a time will be followed. Under allthese construction and other operations gaseous emissions, particulate matter andnoise from the machinery and vehicles will be minimized and curtailed within limitedarea of the project. Therefore, pollution factor will be further reduced at source. As faras possible construction work will be carried out during day time.

Frequency of the vehicles to visit the site, carrying plant machinery and other materialswill be regulated to avoid rush on the public roads and at the project site. Rather theirvisit will be regulated under a well considered plan. They will approach the project siteat different intervals of time and in limited number. As far as possible, well maintainedvehicles will be engaged for the project work. Therefore, all type of pollutants includinggaseous, PM, noise levels and so on will be curtailed through these programming andmanagement mechanisms of number and time of visits of the vehicles.

Domestic sewage to be generated will be treated according to standard method. Thetreated sewage will be used within the four walls of the project site for irrigation ofvegetation and plants and sprinkling on the dusty roads to suppress dust and thusminimize PM pollution from the roads also. If some volume were left unused it will bedischarged in proper way.



The project area will be declared “No Horn Zone”. This will drastically further reduceunnecessary noise levels.

Even during plant machinery installation period the best environmental managementpractices are to be strictly followed according to a plan encompassing environmentalelement.

Blasting is not predicted during construction phase however if required legal permissionwill be obtained. No hazardous chemicals will be used during construction without therequired health safety and environmental plan in place. All construction machinery willbe kept clean to avoid any oil and grease.

To keep noise levels within the prescribed limits of the NEQS Pakistan, powermechanical equipment will be used with low sound power, whenever possible.Construction machinery will be well maintained & regularly serviced. Constructionactivities will be scheduled in such a way that noise intensive operations side by sidewith an increased net noise levels are avoided. Workers will be required to use earplugs or ear muffs to avoid damage to hearing besides ensuring adoption of safe workpractices.

Further, the area subject to excavation or construction is devoid of any fauna life. Assuch there is no sensitivity of environment within the area of influence of the projectactivity. Construction activities will be carried under controlled measures to avoid anydamage to nearby waters or any element of environment in the area of influence of theproject during construction. And last but not the least, the entire phase of constructionis short lived, accordingly the likely minor addition of sediments to nearby waters havingextremely large dilution capacity will hardly matter from environmental point of view.

The main direct ecological impact resulting from the construction phase of the projectwill be the loss of vegetation associated with the “clearance” at the quarry areas, andthe access road alignments. At the quarry about 1 - 3 meters of topsoil at surface,including vegetation will be removed. These will be store in a designated area for futurere-vegetation purposes. Any trees in the plant & quarry area will be cut and supplied tothe local community as firewood.



However, APML shall establish forest nurseries in association with this project. Treeseedlings are used (i) to provide physical screening of quarries and cement plant sitesand (ii) for subsequent site restoration. The establishment of nursery should assist withshort-term mitigation and longer term on and off-site restoration of damaged habitat.

5.1.2 Environmental Adverse Impacts, During Operation Stage and Their UltimateCompliance Status:

The potential effects of the proposed development during operation can be divided asfollows:

• Impacts on air quality as a result of emissions from the cement productionprocess and dust from the quarry activities and crushing and grinding processes.Also, international scale impacts as a result of the emissions of greenhouse gasesfrom the production process.

• Impacts associated with noise, particularly the impact of noise on nearby humanreceptors.

• Impacts of the plant and quarries by changes to the landscape and visualimpacts.

• Impacts on the local ecology by the loss of habitat taken by the development andimpacts associated with the operations on the surrounding ecology.

• Impact on the surface water regime (hydrology) by changes to the naturaldrainage of the landscape within the development area and potential emissionsof fine particles (suspended solids) into the water as a result of the industrialactivities. Potential release of contaminated effluents into the surface waterdrainage. Also, impact on the underground water, called groundwater(hydrogeology) as a result of extraction of raw materials for use in the industrialprocess.

• Use of significant volumes of raw materials and the production of waste on anindustrial scale.

• Impacts of transport.

Each of these potential issues is addressed in the following sections.



5.1.2.1 Pollutants and Wastes:During regular plant operations the following pollutants/wastes will accrue:

i- Stack: If not controlled, they may cause various diseases among human beings,pollute nearby waters, damage aquatic life, change pH of soil and thus maydamage it. It may damage trees, plants, vegetation, structures and anything thatcomes under its influence.

The levels of their emissions into the air will be controlled well within the limitingvalues of the environmental standards of the NEQs Pakistan by employing/using:

ii- Combustion controls to minimize the formation of CO.

iii- The use of low NOx burners technologyto reduce NOx, a Greenhouse Gas (GHG),will also be in the spirit of Kyoto Protocol and practical demonsration ofadoption of Cleaner Development Mechanism (CDM).

iv- A bag filters and ESP’s for control of PM emissions..

The stack emissions concentrations of these gases and the PM will correspond to therequired limits of the NEQs Pakistan:

5.1.2.2 Air Dispersion Modeling (ADM):The design and operational criteria for the facility have been based upon guidelinesprovided the World Bank/IFC. The European Union standard relates to the main aspectsof industrial design and operation and sets out the Best Available Techniques (BAT) forprevention and control of pollution. The BAT is detailed for each major industrialactivity in a series of documents called the EU BAT Reference (BREF) notes. There is aspecific BREF note for the production of cement, which details the suitable design andoperational standard for this industrial sector. Similarly, the World Bank Group throughthe IFC have issued the EHS Guidelines which detail the requirements for the design andoperation of industrial facilities. Within these guidelines are guidelines for the cementindustry. This is the main standard adopted by the IFC investment partner. The two setsof guidance are complementary.



Of particular importance to this project are emissions to air and assurance that the plantwill comply with the appropriate benchmarks for emissions to air. Oxides of nitrogen areof particular importance when controlling emissions from cement plants. APML hasstated that the plant will be designed and operated to meet World Bank/IFC emissionfrom stack limit standards as stated in the EHS Guidelines for Cement & LimeManufacturing, April 30, 2007. Table-1 of the guideline is reproduced below as areference:

Table – 5.1



These levels should be achieved, without dilution, at least 95 percent of the time thatthe plant or unit is operating, to be calculated as a proportion of annual operatinghours.

These emission limits are comparable with the emission limits required in the EU BREFwith the exception of Oxides of Nitrogen. The BAT emission limit for Oxides of Nitrogenas stated in the EU BREF is stated as 500 – 800 mg/Nm3, dependent on the controlsused.

Controls on all other pollutants also have to adhere to the guidelines laid out in the forementioned standard. For all pollutants the maximum concentrations have to beachieved without dilution (i.e. main stack to contain only process gases), at least 95% ofthe time that the plant or unit is operating, to be calculated as a proportion of annualoperating hours.

In contrast to the cement plant, there are no official standards published by the EU orWorld Bank for quarrying activities. A key document useful in this respect is entitledGood Environmental Practice in “The European Extractive Industry: A Reference Guide”.

In addition to the use of international design standards for the cement plant, APML willoperate the quarries to the same standards as its parent company does with its quarriesin other countries, taking into account local sensitivities in its operational activities.

The proposed design and operation provided by the APML indicates that the plant,quarries and associated infrastructure developments will comply with the appropriateWorld Bank/IFC design and operational standards. With regards to emissions of oxidesof nitrogen the plant will operate in line with the requirements of Pakistan NEQS and IFCStandards. It is expected that APML will operate within the World Bank/IFC limitswithout the need for NO abatement technologies.



Air Dispersion Modeling of Proposed Cement Plant:

i. IntroductionThe air dispersion of the emissions from the power plant have been estimated withthe help of widely used Air Dispersion Model “Screen – 3”.

ii. Air EmissionsThe main emissions from chimney/stack include sulfur dioxide, oxides of nitrogen,carbon monoxide, and particulate matter.

iii. Methodology:USA Clean Air Act allows the use of air dispersion modeling to determine or predictground level concentration of pollutants from point, area, volume and open pitsources as well as from line sources. The adoption of air dispersion models in thelocal scenario is most suitable to determine CO, SO2. NOx, and Particulate matter andtheir ambient concentrations from source emissions. ADM has been carried out onkiln stack located at a height of 115 meters.

iv. Modeling Scenarios:

a) Hourlyb) 24 hourly Dispersions of emissionsc) Yearly dispersion of emissions

Air dispersion modeling of NOx, SO2, CO and PM10 based hourly, 24-Hourly, andAnnual Averages of meteorological parameters for the proposed Cement Plant hasbeen carried out and the modeling output tabulated in the form of air quality tablesbelow. Appendices 5.2, 5.3, 5.4, and 5.5 present model run data for NOx, SO2, COand PM10 respectively.

v - Conclusions

The following tables based on the Air Dispersion Modeling data (show thatestablishment of the proposed Cement Plant; would have minimum environmental



adverse impact on the air shed from the emissions of pollutants from the Kiln Stackas they remain within the prescribed limiting values set by the NEQS Pakistan andIFC Standards. Results of Air Dispersion Model run are presented below:

Table – 5.2APML - Air Dispersion Model - Data

Exhaust Gases Characteristics Emissions

CO, mg/Nm3 29

SO2, mg/Nm3 200NOx, mg/Nm3 400

PM10, mg/Nm3 30

Table – 5.3APML - ADM Input

Emission Rate

NOx, g/s 56.58

SO2, g/s 28.29

CO, g/s 4.10

PM, g/s 4.24

Stack Height, meters 115

Exhaust Temp, o C 150

Average Ambient Air Temp, o C 30

Exhaust Velocity, m/s 20.01

Volume Flow Rate, m3/s 141.46

Stack Cross-Section Area, m2 7.07

Stack Inside Diameter, meter 3.00



Table – 5.4APML - AIR DISPERSION MODEL - RESULTS SUMMARY

Kiln StackParameters NOx SO2 CO PMA - Air Dispersion Model - Input Data- Source Type Point Point Point Point- Stack Height, meters 115.00 115.00 115.00 115.00- Stack Diameter, meters 3.00 3.00 3.00 3.00- Volume Flow Rate, Nm3/s 141.46 141.46 141.46 141.46- Emission Rate, gm/s 56.58 28.29 4.10 4.24- Stack Gas Temperature, oK 423.00 423.00 423.00 423.00- Ambient Air Temperature, oK 303.00 303.00 303.00 303.00- Rural/Urban Option Rural Rural Rural RuralB - Air Dispersion Model - Output Data- Final Stable Plume Height, meters 509.59 509.59 509.59 509.59- Stack Velocity, M/S 20.01 20.01 20.01 20.01- Buoyancy Flux, M4/S3 125.25 125.25 125.25 125.25- Momentum Flux, M4/S2 645.33 645.33 645.33 645.33- Terrain Simple Simple Simple Simple

- Maximum 1- Hour Concentration, µg/m3 101.50 50.76 7.36 7.61- Maximum 24- Hours Concentration, µg/m3, See Note(**) 40.60 20.30 2.94 3.04

- Max. Annual Ave. Concentration, µg/m3, See Note (**) 8.12 4.06 0.59 0.61- Distance to Maximum, meters 982.00 982.00 982.00 982.00IFC/WHO, Stack Emissions , mg/Nm3, (*) See Note 600.00 400.00 (***) 100 30Pakistan - NEQS, Concentration in Ambient Air,µg/Nm3

- Annual Average 40.00 80.00 (2) 5.00 120.00

- 24 Hours 80.00 120.00 (3) 10.00 150.00

(*) - Note: IFC - General EHS Guidelines April 2007, Air Emissions & Ambient Air Quality

(**) - Using US EPA conversion factor for Screen3

(***) - WHO Guideline Value for CO is 100 milligram/cubic metre for 15 minutes or 30 mg/m3 for one Hour

(1) - NOx as NO2

(2) - NEQS CO - 8 hours

(3) - NEQS CO - 1 hr



Air impact modelling assessment indicates that there will not be an adverse impact onlocal air quality as a result of the proposed emissions of NOx, SO2, CO & PM.

It is concluded that at all sensitive receptors, the maximum changes in NOx, sulphurdioxide, carbon monoxide, and particulate matter concentrations due to plant operationare a small fraction of the relevant air quality criteria, and future air quality will remainwell within these criteria. The principal emission from the cement kiln is oxides ofnitrogen. Given the likely very good existing background air quality in these largely rurallocations, air quality will remain well within the limit value.

The overall conclusion from the dispersion modelling study is that when the plant is inoperation future air quality will be well within the Pakistan NEQS, World Bank/IFC &WHO guidelines specified for the protection of human health. These limits are set wellbelow the levels at which there are any observable effects on human health orrespiratory function in order to protect vulnerable individuals within the population. Onthat basis, it is concluded that there will be no adverse health effects on the localpopulation due to the operation of the proposed Cement Plant.

5.1.2.2 All Waste WatersThe Cement Plant produced wastewater, sanitary & sewage water and oily waste water,etc., will be treated as: neutralized, flocculated, bio-contact oxidation technologyprocessing and oil-water separators respectively. After treatment the wastewater isexpected to meet Pakistan NEQS effluent standard and will be reused.

5.1.2.3 Equipment NoiseIt will be controlled using conventional noise control measures, such as insulation,lagging, and enclosures as needed to comply with the NEQS Pakistan {85 dB (A)}:



Maximum Allowable Log Equivalent (hourly measurements), in dB(A)Day Night

Receptor (07:00-22:00) (22:00-07:00)Residential,Institutional,Educational 55 45

Industrial,Commercial 70 70

5.1.2.4 Solid Wastes,Main solid wastes anticipated and their disposal methodology are given hereunder:

- Metal/wooden waste: Metal and wooden waste to be sold in the marketfor reuse.

- Empty drums or containers: Empty drums/containers will be returned tothe suppliers for recycling/reuse at their end.

- Cotton rags: Waste cotton rags to be generated after cleaning ofequipment will be incinerated in an incinerator to be installed on theproject site.

- Dispensary wastes: All dispensary wastes will be incinerated inincinerator.

- Miscellaneous waste: Miscellaneous solid waste including redundanttires, tubes, batteries, belts, nylon strips, filters, scrap wood, steel scrap,etc., will be sold in the market through contractors.

Solid wastes to be generated from the project production activities will be sold in themarket for their recycling & reuse. Some of them will be used on site.

However, while disposing any solid waste material, all environmental aspects/impacts ofsuch wastes will be communicated clearly to the concerned contractor. Record of allsuch sales will be maintained for later use if and when required.



Environmental pollution on all accounts from the project activity on regular basis shallbe managed by strict compliance with the Environmental Management Plan (EMP) andEnvironmental Monitoring Plan (EMtP) as recommended in this EIA Report, andfollowing environmentally sustainable practices/cleaner production practices under thefive (5) “R” concept- Reduce, Recycle, Reuse, Retrofit and Refurbish.

5.2 The Relevant Environmental Data and Predictive Methods Used and Any UnderlyingAssumptions Made

5.2.1 Base line Environmental Data:In order to know about the existing status of environment on the project site, baselineenvironmental monitoring was carried out. The ambient monitored data regardingSulphur dioxide (SO2), Nitrogen Oxides (NOx), Carbon monoxide (CO), PM, noise levelsand water quality are exhibited in following sections. These data are necessary for anyfurther reference and for its use by EPA Punjab or the project proponent for a variety oftheir end uses.

5.2.1.1 Ambient Air Quality-AmbientDetails of the status of ambient gaseous pollutants and particulates are reportedhereunder:

Table – 5.5Ambient Air Monitored Data

REFERENCEPOINT DATE

TIMEHOURS

SO2(µg/m3)

NO2(µg/m3)

CO(mg/Nm3)

PM10(μg/m3)

Near Proposed

Plant Site

28.09.2015 06:00 31.2 32.5 1.3 33.9

28.09.2015 09:00 34.1 31.2 2.5 41.7

28.09.2015 12:00 35.8 36.7 2.6 42.5

28.09.2015 15:00 36.1 37.2 0.1 43.1

28.09.2015 18:20 35.7 25.3 1.8 42.8

28.09.2015 21:30 31.1 12.3 2.5 33.8



REFERENCEPOINT DATE

TIMEHOURS

SO2(µg/m3)

NO2(µg/m3)

CO(mg/Nm3)

PM10(μg/m3)

28.09.2015 24:00 31.0 22.2 2.3 33.7

29.09.2015 03:00 30.9 21.9 1.0 42.1

29.09.2015 06:00 31.0 22.1 1.1 43.1

Pak NEQS 80µg/m380

µg/m3 10 mg/m3 150

µg/m3

NEQS = National Environmental Quality Standards for Ambient Air.* High concentration of air pollutants are associated with burring of the post waste from cultivated land, andmovement of Bicycle and Heavy Tractors during the monitoring hours.

5.2.1.2 Noise LevelsNoise levels monitoring was done at the project site to have background environmentaldata. The monitored data are reported in the Table – 5.6.

Table 5.6Noise Levels Monitored Data

REFERENCEPOINT DATE

TIMEHOURS dB(A)

LEQ /AVERAGE

Main RoadNear Katas

28.09.2015 06:00 45 46 46 46 47 45 47 47 45 46.0

28.09.2015 09:00 61 63 63 62 68 70 70 61 66 64.88

28.09.2015 12:00 70 68 68 68 61 59 59 60 61 63.77

28.09.2015 15:00 62 69 72 62 60 61 60 59 60 62.77

28.09.2015 18:20 64 63 63 62 68 73 74 61 63 65.66

28.09.2015 21:30 45 46 49 49 48 45 41 42 42 45.22

28.09.2015 24:00 35 36 36 36 37 35 37 37 35 36.0

29.09.2015 03:00 34 33 31 31 31 32 33 31 32 32.0

29.09.2015 06:00 45 46 46 46 47 45 47 47 45 46.0



5.2.1.3 Water QualityAnalysis of ground water sample collected Tatral Village, Dulmial Village and Near KatasTemple are presented in Tables 5.7, 5.8 and 5.9.

Table – 5.7

SR.NO.

PARAMETERS UNITS NDWQS RESULTS REMARKS

1. pH – 6.5–8.5 7.7

--

2. Taste & Odor – NonObjectionable Objectionable

3. Color TCU



SR.NO.


19. Mercury mg/L 0.001 N.D.

20. Iodine mg/L – 0.08

21. Zinc mg/L 5 0.14

22. Boron mg/L 0.7 N.D.

23. Chromium mg/L ≤0.05 N.D.

24. Selenium mg/L ≤0.5 N.D.

N.D = Not DetectedSampling Source = Hand Pump Water near Tatral

Table – 5.8

SR.NO. PARAMETERS UNITS NDWQS RESULTS REMARKS

1. pH – 6.5–8.5 7.4

--

2. Taste & Odor – NonObjectionable

Objectionable

3. Color TCU



SR.NO.


12. Arsenic mg/L



SR.NO.


5. Total Coliform Number/100 mL 0 Number/100mL

45

6. E–Coli Number /100 mL0 Number /

100 mL +ve

7. Total DissolvedSolids (TDS) mg/L



5.3 Compliance with Relevant Environmental Standards:The plant will operate in compliance with the National Environmental Quality Standards(NEQS) Pakistan.

5.4 Assessed Significance of the Impact Stating the Standards or Criteria used as a Basisfor Judgment:Pollutants of all sorts to be generated due to plant operations have been discussed inthe preceding section. Assessment as to their remaining within the NEQS limiting valueshas also been given therein. The levels of emissions of all kinds will conform to theNEQS.

5.5 Potential socio-economic impactsPotential socio-economic impacts to accrue from the project activity are described asunder:

The proposed Project will provide jobs to about 1500 - 2000 workers at peakconstruction and about 300 - 400 workers during regular operations of theproposed Cement Plant.

Both provincial and Federal Governments will receive taxes and duties onrecurring basis.

Basic infrastructure of the area will improve. Supply of vendors’ services is yet another opportunity of earnings for the people

of the area. Supply of edibles like fruit, milk and other food items will be other source of

income. Price of the land will be appreciated which is another benefit to its owners. Addition to the awareness of the people will set trend in getting education

among the people of the project area. It will improve their social status thusbringing a lot of tangible change in the overall life style of the people.


Chapter – 6, Comparative Evaluation of Alternative Page – 6.1

6.0 COMPARATIVE EVALUATION OF SITE ALTERNATIVES AND IDENTIFICATION OF THEPREFFERED OPTION

6.1 Siting

Site selection requires careful, well thought out and wise decision. Any over sight maylead to major failure. Among various other major factors, the following are the mostimportant ones taken into consideration for site selection regarding the cement plantunder reference:

This Chapter presents a systematic comparison of feasible project alternatives, in termsof both the project (i.e., technology, design, operation, etc.) and site selection. Theassessment of project alternatives and site selection includes environmental and socialfactors and include a no action (i.e., without the project) scenario.

The assessment must clearly state and justify the selected alternative. Alternativesinclude location as well as approach to design, process, and construction technology aswell as the country chosen.

The main alternatives for the establishment of a grass root cement manufacturingfacility can be summarized in following sections.

6.2 Do Nothing Alternative

The ‘Do Nothing’ alternative means as economic development accelerates, due to CPEC,public sector development programmes and various public & private projects (especiallymega dams projects), and the country will have to import cement to meet its futureneeds and will be mostly dependent on world market fluctuations. At the same timeexport of cement (a substantial foreign exchange earner) will end. With shortage ofcement in the country the prices of cement will go up thus increasing construction costs.Pakistan has abundant natural resources and especially high quality and easilyextractable limestone and clay/laterite reserves which make the best location in PunjabProvince for a cement plant. This single source alternative if not utilized will resort todependence on cement imports, but that could also very easily result in the cement



supply shortages. Shortage of building material like cement will cause cement prices torise.According to Market Study of the Project, by Year 2020-21 there will a shortfall indomestic demand of 4.0 million to 7.0 million tonnes of cement, which is likely toincrease further in subsequent years. “Do Nothing” alternative will place Pakistan’sdependency on cement imports or slow down its economic growth.

The ease of availability to basic building materials is needed to further develop country’seconomy. The ‘Do Nothing’ alternative does not seem plausible given the legitimacy ofthe proposed project rationale and the benefits to be derived. Pakistan’s trade deficitwill increase, and the country will remain susceptible to high cement prices.

Though it has minor social and environmental impacts, the proposed cement plant isexpected to provide about 350 job opportunities during its operation phase andadditional job and economic opportunities through development of supply/distributionchain and trucking. In addition, there will be a transfer of technology associated withinstallation, operation of the equipment and maintenance and savings on foreignexchange, hence the alternative of establishing cement plant was chosen.

The investment potential of US Dollar 470 million, as proposed by the ProjectProponents, will not be utilized with “Do Nothing” option.

6.3 Project Site Option

Given that limestone and clay represent over 94% of the raw materials from whichcement is manufactured, the availability of these unexploited raw materials is anotherprimary criterion for determining potential sites for a new cement plant. The proposedplant site in Chakwal District located close to south of large reserve of good qualitylimestone deposit with availability of clay in the vicinity. Shorter distance location of theplant from the limestone and clay deposit will reduce the transportation cost and in turnwill lower the cost of cement production as well as minimize generation of greenhousegases due to transport movement over shorter distance from quarry to plant site.



The proposed plant site is to be located in an area which is devoid of any biodiversityincluding forestry, wildlife, migratory birds, game reserves (flora and fauna), orprotected species of fauna & flora; fishery or aquatic biology; watershed. There is nocultural or any other heritage in the proposed Plant site area.

There is only one very small village namely “Rupper” Village with 32 houses having apopulation of 175 people. Population of this village will be relocated/resettled.

There is no environmental sensitivity in the project area. These factors are also stronglysupportive of the proposed project site.

The limestone deposit is unexploited and is situated along with proposed plant site inarea of environmentally insignificant. Most of the area has vegetation in the form ofvery small bushes, of no value from any angle.

All raw materials, with the exception of gypsum, will be extracted from the proposedmining lease area. This option entails the execution of the proposed project, whichinvolves mining limestone and clay from a dedicated quarry.

The proposed location was determined to be the most convenient location in closeproximity to the limestone and clay reserves. The proposed site has least environmental& social impacts.

The site has proximity to Motorway M-2. A 132 KV High Tension Line passes close to theproposed site. These factors are also very much supportive of the project at theproposed site.

6.4 Mine Options

Two options can be considered for limestone mining, within the proposed site, i.e., sub-surfaced Open Cast Mining and Underground Mining. Sub-surface open cast mining hasbeen considered as most efficient and suitable for mining operation. The method ofmining is considered to be safer and economical.



6.5 Technology Options

The technology being considered to be ‘state of the art’ in terms of being environmentfriendly, energy efficiency and modern plant & process design for similar capacityplants.

Dry process technology has been preferred over wet or semi-dry technologies as moreeconomical in power consumption as well as heat and manpower requirement andbeing less capital intensive.

The new plant will be built according to the applicable Best Available Technologies (BAT)defined for the cement industry, which include the adoption of pre-calcining technologyin the clinker production and de-dusting bag filters for gases.

6.6 Process Options

The grinding efficiency of a ball mill is only half as efficient as a vertical roller mill,therefore, for this project, APML has proposed vertical roller mills for raw materialgrinding, cement finishing grinding and solid fuel (coal) grinding. Ball mills result insignificantly higher specific power consumption. In addition, the noise level of a verticalroller mill is significantly lower than that of a ball mill.

APML has proposed 5-Stage preheater with pre-calciner. The preheater configurationselected offers an optimal solution with respect to heat economy and powerconsumption taking into account the moisture content of the raw materials as well asthe height of the preheater tower.

In comparison with conventional kiln systems (without pre-calciner) the selectedinstallation offers a considerable reduction in kiln dimension and a high degree of pre-calcination. Concerning the operational costs, the uniform operation and low brickconsumption are favorable aspects of the pre-calciner kiln.

The kiln burner is a two-channel burner with low primary air consumption, normally inthe region of 6-8%. The primary air is supplied by a high pressure fan (up to 250 mbar).



Coal mill installations are designed to meet International standards, which will befollowed for factory installations, where the risk of explosion is possible.

Several air pollution control technologies suitable for the proposed project wereconsidered, the main equipment include bag house, ESP and cyclones.

6.7 Construction Technology Options

The proposed project site is not exposed to any natural hazards. The highest structure inthe cement plant is the preheater tower at approximately 110 meters in height. In thisrespect, concrete construction will be applied in the foundation and lower level of thepre-heater tower. The middle and top levels of the pre-heater tower are expected touse structural steel. Alternatives, such as the use of fewer pre-heater stages, to lowerthe height of the structure would compromise, unfortunately, negatively impact the fuelefficiency of the plant and therefore the increase environmental emissions. Therefore,good engineering practices need to be implemented within the context of the preferredtechnology.

A thorough investigation of construction technology options will therefore depend onsound engineering design as well as field investigations (such as weather, climate, soilbearing capacity, the availability of construction materials locally and local labor skills).During the design phase, the EPC Contractor will choose the construction technologywhich best meets the Project schedule, safety, and quality as well as the economicbenefit to the local community.

The proposed project site is located in the “Minor to Moderate Zone of SeismicActivity”.


Chapter – 7, Environmental & Social Management Plan Page – 7.1

7.0 ENVIRONMENTAL MANAGEMENT PLAN, ENVIRONMENTAL MITIGATION MEASURES,MONITORING PLAN, SOCIAL MANAGEMENT PLAN AND PROPOSED TRAINING

As desired by the matrix/mandate of the officially approved EIA Repot guidelinesAppendix – 1.5, the Environmental Management Plan (EMP) presented in this sectionhighlights the followings:

i- Mitigation / Compensation Measures during Construction Phaseii- Mitigation / Compensation Measures during Operation Phaseiii- Environmental Monitoring:

Ambient Air Quality Stack Emissions Noise Assigning responsibility for implementation (by name or position) Reporting and reviewing procedures

iv- Training Needs

7.1 Environmental Management Plan

Environmental Management Plan (EMP) is presented in this section. Mitigation andcompensation measures to address the environmental issues during construction of theproject are discussed in Section-7.2. The mitigation and compensation measures essentialto meet the requirement during operation of the proposed project are described inSection - 7.3 of this Chapter. Section – 7.4 presents the impacts and mitigation measuresduring decommissioning phase.

In Section-7.8, monitoring recommendations are presented for documenting thecompliance of the project to the NEQS Pakistan and the World Bank EnvironmentalGuidelines.

7.2 Mitigation / Compensation Measures during Construction PhaseThese are presented in Table – 7.1 below.



7.3 Mitigation / Compensation Measures during Operation PhaseThese are presented in Table – 7.2 below.

Mitigation Measures during Construction PhaseTable - 7.1

AIR QUALITYEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingAir quality:- dust emissions duringconstruction and groundworks.

Development ofprocedures for:-water spraying roads anddusty materialsstockpiles- covering vehiclescarrying dusty materialson leaving the site toprevent materialsbeing blown from thevehicles-speed limits on unpavedsurfaces on site to limitdust.

Dust propagation will belimited to construction areaand will not influence localcommunity. Workers willbe supplied with dustmasks.

Minor adverse

GROUND & WATEREnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingImportation of pollutantsalready presentwithin the materials to beused for fillingand site levellingoperations

Ensure that pollutants arenot present in materialsimported onto the site byappropriate selection ofsource material by theContractors and chemicalanalysis by APML ifrequired.

Potential for importation ofpollutants in the materialwill be minimized throughAPML’s specifications toContractors and monitoringby APML project team.

Minor adverse

Accidental release of fuels,oils, chemicals, hazardousmaterials, etc., to theground, especially in theconstruction lay-downarea, during delivery to thesite.

Appropriate proceduresand protocols to beestablished and monitoredfor materials delivery andhandling to ensure thereare no spills.

Potential for accidentalrelease during delivery ofmaterials to the site will beminimized via writtenprocedures and protocols.

Minor adverse

Accidental release of fuels,oils, chemicals, liquidwaste, hazardous materials,etc., to the ground,especially in theconstruction lay-downarea, during storage.

All storage areas will haveappropriate environmentalsecurity measures toprevent accidental releaseto ground.

Potential for accidentalrelease of materials duringstorage on the site will beminimized.

Minor adverse



GROUND & WATER [continued]Environmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingAccidental release of fuels,oils, chemicals, hazardousmaterials, etc., to theground, especially in theconstruction lay-downarea, during transport tothe area of use.

Appropriate proceduresand protocols to beestablished and monitoredfor materials transport andhandling whilst on the site.

Potential for accidentalrelease of materials duringtransport within andhandling on the site will beminimized.

Minor adverse

Accidental release of fuels,oils, chemicals, hazardousmaterials, etc., to theground, during use, [forexample, re-fuelling,maintenance, etc.]

Appropriate proceduresand protocols to beestablished and monitoredfor materials handling anduse. Where possible, re-fuelling and maintenanceareas will include someform of secondarycontainment.

Potential for accidentalrelease of materials duringuse will be minimized.

Minor adverse

Accidental release of liquidwastes during removalfrom site.

Appropriate proceduresand protocols to beestablished and monitoredfor waste materialsremoval.

Potential for accidentalrelease of waste duringremoval from the site willbe minimized.

Minor adverse

Accidental discharge ofsanitary wastewater toground and groundwaterfrom the workers camp.

Sanitary waste will not bedischarged to the ground.Contractors will provideappropriate SewageTreatment Facilities.

None Negligible/Nil

Contamination of localwater ways from proposedeffluent plant discharge.

Ensure that the plantcomplies with IFCstandards and otherinternational guidelines.Final effluent should haveno significant negativeimpact on the receivingwater. The plant will bedesigned for the full loadduring construction.

Potential for release ofharmful of effluent if thefacility is underspecified ornot managed correctly.

Minor adverse

Discharge of pollutants inwater used for plant,equipment and vehiclewashing to ground.

Washing activities willtake place on areas withappropriate containmentand procedures andprotocols will beestablished and monitoredto ensure that thepreventative measures aresufficient to meet theeffluent standards.

Potential for accidentalrelease of pollutants to theground during washingactivities will beminimized.

Minor adverse



GROUND & WATER [continued]Environmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingIncrease of sediment loadin natural aquatic receptorsresulting from direct run-off disposal.

Minimization ofexcavations face duringConstruction. Temporarydrainage grooves andsedimentation ponds forsurface run-off collection.The topography is nearlyflat.

None Negligible

Natural aquatic receptorsdegradation due to directdisposal of domestic typewastewater.

Construction of appropriatesewage system andwastewater treatmentfacility by Contractor.Effluent if any will meetthe standards.

None Negligible

Groundwatercontamination fromleakage of pollutingsubstances.

Usage of non-hazardousconstruction materials forhuman health andenvironmental protection.Storage of potentialpolluting materials inappropriate areas,including secondarycontainment.Any contaminated landoccurred duringconstruction will bedirectly removed anddisposed of in accordancewith local regulations forwaste disposal.

None Negligible

MATERIAL USE & WASTE MANAGEMENTEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingWaste generation. Introduction of waste

storage and controlproceduresSegregation and recyclingof waste by EPCContractor into metalcomponents, plastics, glassseparately.

Waste for disposal will bedisposed of at an approvedwaste disposal site.

Negligible



ECOLOGYEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingPlant & Mine SiteLoss of vegetation on site.Clearance.

Vegetation loss cannot beavoided, but clearance withsuccessful restoration,improvement and longterm management of thesurrounding areas forconservation andproductive uses willprovide significantcompensation.

Negligible

Further land take over(habitat loss) for temporaryConstruction Camp.

Build temporaryconstruction camp on landthat in due course be re-used for APML for otheractivities.Contractors/APML willalso restore, whereverpossible to green areassuch as the planting ofgrass, shrubs & trees.

No additional impact sinceis visualized.

Not significant

Destruction of fauna andhabitat (mammals, birds,reptiles, amphibians,invertebrates).

Further ecological/faunasurvey at appropriateseasons and translocationsmonitored by the APMLspecialist.

Moving fauna toneighbouring sites mayhelp short-term survival,but not medium-term ifthese sites are alreadyoccupied. In long termpopulations may recoveron restored sites.

Not significant

Increase in exploitativepressures on habitatsneighbouring the sites.

Conduct and implementfurther “Habitat Surveyand Management Study”,in close consultation withlocal officials &communities.

With co-operation ofofficials & localcommunity and projectproviding alternativesource of income, habitatsshould be improved.

Moderate to substantialbeneficial.

On ecology of surroundingarea by temporaryworkforce as a result ofremoval of vegetation andthe displacement ofwildlife.

Education, monitoring andenforcement program.Adequate wastemanagement and sanitationfacilities. No permits willbe provided to Contractorsfor any burning.

Implementation may bedifficult and some impactcan be expected.

Minor adverse (subject toimplementation andenforcement).

LANDSCAPE AND VISUALEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingDamage to the landscapecharacter and visualamenity due toIntroduction ofincongruous features andactivities.

Sensitive planning of siteworks and worker’scompound. Advancedstructure planning.Minimize lighting andnight time workings.

Some exposure toalteration of the landscapecharacter and loss of visualamenity, predominantlydue to out-of-site activity.

Minor adverse impact.



NOISE & VIBRATION [Incorporating Transport]Environmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingNoise from construction ofnew plant/mine and linkroads.

Good site management;Appropriate choice ofmachinery; Methods ofworking; Hours ofworking; efficient materialhandling.

A baseline noise studyneeds to be carried out. Butfurther study may be Theneed to predict whetherthere may be noiseincreases at nearbyvillages.

Minor adverse

Noise from traffic relatingto construction usingexisting roads throughlocal residential areas &cities

Define access routes to thesite with the smallestnumber of properties inproximity to it. Keepvehicle movements to aminimum. Once link roadsare completed, allconstruction traffic to/fromthe site should only use thelink roads.

There may be noiseincreases at residentialproperties in proximity tothe chosen access route,and then from the link roadonce completed.

Not significant

SOCIALEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingWorker - industrialemergency

Prearranged qualitycurative treatment inHospitals at Choa SaidanShah, Kallar Kahar andChakwal for allemergencies.

Depends on nature ofemergency

Minor adverse

Non-local worker livingconditions and quality oflife. Utility and serviceprovision impacts on localvillages.

Contractors will providedetailed specification ofcamp layout, facilities, andutility provision (anddisposal) in accordancewith identifiedinternational standards.APML to monitor healthand safety and terms andconditions of employment.

Depends on individualworker susceptibility. Ifconditions are poormultitude of issues couldarise in camp and spill intolocal communities.

Minor / Moderate adverse

Disturbance and conflict incamp

In-camp codes of conductand enforcement of keybehaviours shall berequired.

None identified Minor adverse



SOCIAL [continued]Environmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingDisturbance and /orconflict with localpopulation.

Camp code of conductupheld by workers andenforced by camp.Provision of employmentand opportunities to localpopulation to minimizehostility.

Some residual impactexpected but scale limitedby worker free time, andlocal interaction withcamp, especially if“Liaison Committee” isformed early.

Minor / Moderate adverse

Potential for increasedincidence of transferabledisease (TD) in localpopulations and amongstworkers.

Preventative healthawareness campaigns forTDs provided to workersand targeted at key locallocations / groups.Contractors will providehealth checks andimmunizations beforemovement to site.

Difficult to identify causeor source of such disease.However some diseasemay be spread and curativetreatment may be requiredfor the different diseases.

Moderate adverse



MITIGATION MEASURES DURING OPERATION PHASE

Table 7.2AIR QUALITYEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingRelease of combustiongas emissions from thekiln stack

Equipment design andprimary operationalmanagement controltechniques

Local air emissions willbe based on IFCGuidelines for theprotection of humanhealth at all emissionpoint sources. On thatbasis, it is concludedthat there will be noadverse health effects inthe local population dueto the operation of thecement plant.

Not significant

Release of particulateemissions from the kiln,the clinker cooler, thecoal mill and the cementmill.

Bag filters – dustabatement using verystringent 30 mg/Nm3

standard and ESP 100mg/Nm3 standard.

Local air quality will bevirtually unaffected inProject area &surroundings, and willbe based IFC Guidelinesfor the protection ofhuman health.

Negligible

Release of dustemissions from thequarry operations.

Use of best practicemanagement techniquesduring extraction andloading of raw materials.

It is unlikely that therewill be any discernibleadverse effect due todust deposition at anyresidential properties.

Not significant

Release of combustionemissions from transportassociated with transportof materials to and fromthe site.

Use of new, efficientvehicles, driver trainingto minimize emissions(e.g. prevention of overrevving, shut off engineswhen vehicles not inuse), propermaintenance,rationalization of trafficmanagement system tooptimize transportefficiency.

Localized minor effectson air quality at anyproperties very close tocertain roads, butincrements a very smallfraction of air qualitycriteria. Given thevolume of trucks,however, impact isModerately adverse.

Moderate.



Surface Water and Ground WaterEnvironmental Impact Proposed Mitigation Residual ImpactIncrease of sediment content insurface due to fugitive dustdispersion.

For cement plant: Storm watermanagement through ditchesand or gutters and settlementponds.For mines: Mine face will bekept minimal. Gradualrehabilitation (throughlandscaping and planting) oflocations where extractionworks have been completed.Storm water managementthrough peripheral ditches andsettlement pond.

None

Degradation of surface watersquality due to process waterdirect disposal or leakage ofpolluting materials.

For cement plant: Processwater circulation is closedcircuit including settlementtank for treatment. Storage offuels for cement production inenclosed storage area. Tidyingthe plant on regular basis withmechanical sweepersremoving dust collected on thestreets and gutters. Thoroughwashing of surfaces in case ofpolluting materials spillagesand further processing ofcollected washings as specialwaste.For mines specialconsiderations for clay quarry.Preventative maintenance ofquality equipment, protocolsand procedures.

None. Appropriate collection andtransportation of potential pollutingmaterials (e.g. spent oil, lubricants,etc.)

Pollution of surface water dueto release of harmful/untreatedsewage.

The sewage treatment systemwill be sized for peak demandduring operation phase. Nohazardous liquids will bereleased on to the sewagetreatment system. Theprovision of a large balancingtank before industrial use willact as a storage unit in theevent of accidental release intothe sewage system.

None



Soil Erosion. For cement plant: EPContractor to design properdrainage system consistentwith seasonal winds.For mines: Proper Drainagedesign by the Contractor aswell as gradual rehabilitationof location where extractionworks have been completed.

Soil erosion will be limited on-site thequarries.

Ground and Groundwatercontamination.

For cement plant and mines:Secondary containment forpotential polluting materials.Any contaminated landremoval and disposal inaccordance with local andgeneral internationalrequirements.

Potential contamination will be limitedon-site.

LAND QUALITYEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingAccidental release offuels, oils, chemicals,hazardous materials,etc., to the groundduring delivery to thesite.

Appropriate proceduresand protocols to beestablished andmonitored for materialsdelivery and handling.APML will have, at alltimes, clean up kitsavailable.

Potential for accidentalrelease during deliveryof materials to the sitewill be minimized.

Minor adverse.

Accidental release offuels, oils, chemicals,liquid waste, hazardousmaterials, etc., to theground during storage.

All storage areas willhave appropriateenvironmental securitymeasures to preventaccidental release toground. EP Contractorto design the plant forberms/detrimentalretainer walls that aredesigned for 1.5 timesthe capacity of any suchstorage tank.

Potential for accidentalrelease of materialsduring storage on thesite will be minimized.

Minor adverse.

Accidental release offuels, oils, chemicals,liquid waste, hazardousmaterials, etc., to theground during transportto the area of use.

Appropriate proceduresand protocols to beestablished andmonitored for materialstransport and handlingwhilst on the site.

Potential for accidentalrelease of materialsduring transport withinand handling on the sitewill be minimized.

Minor adverse.

Accidental release offuels, oils, chemicals,liquid waste, hazardousmaterials, etc., to theground during use, for

Appropriate proceduresand protocols to beestablished andmonitored for materialshandling and use. Wherepossible, re-fuelling and

Potential for accidentalrelease of materialsduring use will beminimized.

Minor adverse.



example, re-fueling,maintenance, etc.

maintenance areas willinclude some form ofsecondary containment.

Accidental release ofliquid wastes duringremoval from site.

Appropriate proceduresand protocols to beestablished andmonitored for liquidwaste materials removal.

Potential for accidentalrelease of waste duringremoval from the sitewill be minimized.

Minor adverse.

Accidental discharge ofsanitary wastewater andwastewater to ground.

Sanitary wastewater willnot be discharged to theground. Wastewatersumps and pits will beproperly designed. Pipe-work will be inspectedperiodically by APMLand recycle waterwherever possible.

None Negligible/Nil.

Discharge of pollutantsin water used for plant,equipment and vehiclewashing to ground.

Washing activities willtake place on areas withproper drainage systemswith containment andtreatment. Effluent, ifany, will meet thestandards.

Potential for accidentrelease of pollutants tothe ground duringwashing activities willbe minimized by properdesign and use byAPML.

Minor adverse.

ENERGY AND GREENHOUSE GAS BALANCEEnvironmental Impact Proposed Mitigation Residual ImpactUse of solid fuels and direct andindirect greenhouse gasemissions.

Ensure that combustion andprocessing is as efficient and infull compliance with IFCrequirements for cement plantand maintenance and monitoringby APML.

Emissions of greenhouse gases.[Refer to separate note, in latersection of this Chapter-7.]

MATERIAL USE AND WASTEWATER MANAGEMENTEnvironmental Impact Proposed Mitigation Residual ImpactStorage of solid and liquidwastes.

Inspection of all waste storageareas to ensure appropriateidentification, segregation andcontainment.

Potential release into theenvironment.

Waste management Establishment of wastemanagement disposal/recyclingtechniques and appropriatechoice/negotiation of EPCcontractor by APML.Establishment of filter dusthandling procedures and choiceof the contractors. Hazardouswaste disposal techniques to beestablished. Review of wasteminimization and recyclingoptions for all waste will beexhaustive

Waste management will becovered by internal proceduresand will be regulated throughlocal regulations. Increasedquantity of waste will be disposedof off-site. APML will monitor itsprocedures to increase ormaximize recycling/reuse of anywaste generated, including firingin the cement manufacturingprocess and composting.



ECOLOGY, Cement Plant and Mine Sites.Environmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingDust deposition onleaves leading to loss ofvegetation productivityand health.

The planting of tree linesby Contractors duringthe construction phase toprovide local screeningin accordance withecology expert’srecommendation as amean to reduce dustemissions at the sourceduring operation. APMLwill ensure that the treesare planted to aid in theprevention of dustaccumulation on foliageoutside the plant.

Some dust emissions atthe quarry sites,associated withexcavation, etc., areinevitable, but emissionsand impacts can be keptto an acceptable level byuse of latesttechnologies and bestworking practices.Mining plan andprocedures to beimplemented per therecommendations andapproval by ecologyexpert.

Minor Adverse.

Productivity and qualityof vegetation forherbivores reduced.

In-plant road will bepaved. Mine accessroads will be clay andwill be periodicallywetted to minimize anyimpact.

Some impact isinevitable, but APMLwill make it a priority.

Minor Adverse.

Disturbance of wildlifeby noise.

Reduced at source andless than 60 dB at theplant fence.

The project site does nothave any sensitivespecies.

Not significant

Disturbance of wildlifeby human presence andactivities.

Environmentaleducational program.On-site ecologist byAPML.

There should be somehabituation to humanpresence by some non-sensitive wildlife.

Not significant



LANDSCAPE AND VISUALEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingDamage to the landscapecharacter and visualamenity due tointroduction ofincongruous features andactivities

Proper design of lightsources by establishingand effective balancebetween safety/securityand environmentalsensitivity. Sensitive anduniform (paintspecifications)coloration of cementplant and vehicles.Minimize the timebetween working andrestoration phase ofquarry

Some exposure toalternation of thelandscape character andloss of visual amenity,predominantly due tooff-site quarry activities.

Minor to moderateadverse impact

TRAFFIC AND TRANSPORTEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingIncreased heavy vehiclestraffic both locally andnationally.

Maximize the use of therail network, whenavailable, for bulkdeliveries and abnormalloads. Restrictingdelivery hours to reducenoise nuisance; avoidheavy truck movementsin the night hours willbe considered whetherdeliveries should bescheduled to avoid peaktimes to reducecongestion; heavyconstruction traffic willbe subject to a trafficmanagement plan, asnecessary.

The traffic has thepotential to contribute tocongestion and lead tocomplaints due tonoise/vibration nuisanceon a local basis.However, the studyindicates that there willnot be a significantimpact.

Minor Adverse.

NOISE AND VIBRATIONEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingNoise from cement plant None recommended

unless the plant andvarious installationdiffer significantly fromsimilar establishedcement plants used as areference. IFCguidelines for noise willbe followed by APML.

None expected Nil. Less than 60 dBA.



Noise from miningactivities

Good site management;appropriate choice ofmachinery; methods ofworking; hours ofworking; efficientmaterial handling.

None expected Minor Adverse.

SOCIALEnvironmental Impact Proposed Mitigation Residual Impact Residual Impact

RatingIncreased Employment.(Positive Change)

Measures to maximizelocal employment.Recommended:

Local recruitmentand training.

Prioritization ofemployment ofProject AffectedPeople (PAP’s)

Identification oftargets of localpeople to beemployed by skilllevels.

This depends on skillsof the people. Enhancedapprenticeship/trainingfor some local peoplewhose skills could beimproved includingRecruitment Policy toextend in future tolimited sponsorship forworkers / local peoplechildren.

Major beneficial.

Increased National taxand budget (PositiveChange).

Assistance to villagersto formulate projectsand strengthenadvocacy. Money fromimproved budget can beused to realize theseobjectives. APML mayoffer skills training forimproved planning &project formulation.

Increased Regional &National Budget andsecondary impact onlocal Communities.Residual impact willdepend on effectivenessof allocation process infavour of affectedvillages. An ineffectiveprocess would causeconflict / discontent.

Major beneficial.

Electrical and otherinfrastructureimprovements (neutralor positive if realized).

APML will be self-sufficient from theNational Grid so there isno mitigation.

Potential positive impacton visual impacts due toinfrastructureimprovement.

Neutral/Minorbeneficial.

Extended and improvedroad and implicationsfor local economy(minor/moderatebeneficial).

Regulations relating toroadside andcommercial activities tobe adhered to bybusiness persons andenforced byCommunity. Monitoringof health, road safetyissue. Curative andpreventive action to betaken if issues identifiedby monitoring.

Improved opportunitiesshould be seen inincreased opportunitiesand wealth of villages. Itmay be difficult toapportion this only tothe new road or cementworks given the currentincreasingly dynamiceconomic environment.

Minor beneficial.



Loss of Land andproperty “RUPPER”Village household andcompensation (minorbenefit/minor adverse)

An appropriatecompensation plan willbe developed and agreedupon. CompensationPlan & FrameworkDocuments will beprepared.

No negative residualimpact should beincurred by PAP’s. Theassessment shouldinclude all applicableentitlements. Monitoringprocess to review andreport.

Negligible / minorbeneficial.

Hazards associated withdevelopment of newroads from mainHighway to the cementplant and from thequarry to the cementplant.

With regards toidentified ‘high’ risks: Design measures to

ensurelandslips/falling rocksdo not cause accidents

Inclusions ofpedestrian walkwaysand crossings

Lighting, particularlyat intersections.

Planned access andparking. Risk ofaccident shall bereduced byimplementation ofeducation (road safetyawareness) programsand liaison with thelocal communities aswell as driver trainingprograms andimplementation ofnear-miss/accidentreporting procedures.Communities toconsider the need foradditional safetybylaws.

Some residual impact isexpected, but should belimited byimplementation ofaforementionedmitigation measures.

Moderate adverse –possibility severeadverse if there isdisregard for safetyissues by the road users.

7.4 Impacts during Decommissioning Phase:

Detailed assessment of environmental impacts associated with decommissioning cannotbe made at present. The plant has an expected lifespan of over 50 years and so onlygeneral principles can be established at the present time.

7.4.1 Broad the process of decommissioning is likely to give rise to impacts similar to thoseexperienced during construction phase. The methods and techniques selected are



expected to be in accordance with national and international standards prevailing at thetime of decommissioning.

7.4.2 Decommissioning will involve following activities: Removal of all surface equipment and units; Potential removal of hard standing and surface cover; Abandonment of sub-surface utilities or filling and abandonment as appropriate; Reinstatement of the site and all project areas to pre-construction conditions. With

regards to the rehabilitation of the quarries during operation, the works shall beconducted on an on-going basis in accordance with the accepted timetable set out inthe planning proposals to the Jamaican authorities.

For the cement plant, APML will develop a site closure plan during the later stages ofproject design and maintain the plan throughout the life of the development. The planshould include arrangements for decommissioning the plant in a manner which avoidsany pollution and return the site to an acceptable state. In addition anydecommissioning plan should take into account the social and economic impacts andinclude mitigation measures where necessary.

The opportunities the site provides for long term biodiversity conservation purposesshould be investigated as part of the site closure plan. There are no identified sites ofecological significance outside the main development areas that should be affectedby decommissioning activities, though consideration will need to be given as to thelong term use of the access roads to the mines. This will depend on their future use.It may be necessary to remove the roads and “re-instate” the ground and vegetation,but maintaining vehicle access or foot access only are also possibilities.

The site closure plan and preceding rehabilitation plans will need to be reviewed andupdated in the light of experience with implementing the ecological mitigation andcompensation measures – especially the “Habitat Restoration” proposals. Thesehabitat restoration activities will need to be monitored, during the course of theproject, so that lessons can be learned and applied prior to and at the time of finalsite closure.

Overall, decommissioning activities are transitory, and are likely to be similar inmagnitude to construction impacts.



Rehabilitation of the mine area will take place in stages during the development ofthe mine. When an area of the mine has been exploited, rehabilitation works willfollow and the success of the rehabilitation/restoration monitored so that the besttechniques can be adopted for future stages of restoration.

The decommission activities relating to the mine sites will be significantly lessintensive that those of the cement plant due to the lack of onsite plant and permanentstructures and hard-standing to be removed. It is anticipated that thedecommissioning activities will have no noticeable effect beyond that which theoperational phases experienced. Giving consideration to the effect of noise from theoperation of the mine on the landscape character, the ceasing of excavation activitiesin itself will abate the negative effects of the quarries. As such the decommissioningof the mines is anticipated to have a minor adverse effect on the landscape resources.

The restoration programmes for the mine sites, as with the cement plant, has thepotential to contribute to landscape enhancements to the baseline landscapecondition. This may involve the reforestation of the area, ground re-modelling, andpotentially the addition of landscape amenities such as the conversion of the mineinto a water body. As such, the restoration phase of the mines will have a minorbeneficial effect of the landscape resources.

Environmental Impact Proposed Mitigation Residual Impact Residual ImpactRating

Emission Prevention Development of siteclosure plan.

Undated information onrisks and requirements isavailable at site closure.

Minor beneficial

Dust emission duringground works

Water spraying of roads.Covering of vehiclescarrying dusty materials.Speed limits of vehiclesmovement.Dust emission monitoringat selected points

Dust propagation will belimited to demolition areaand not influence the localcommunity.However, workers shouldbe supplied with dustmasks.

Minor adverse

Discharge of silty orcontaminated water tosurface water.Ground contamination ofleakages from machines.

Potentially pollutingmaterials will be stored indedicated storage areas.Machines & equipmentcondition to be reviewedperiodically.Machines & equipmentwill be sited on hardsurfaces.

Ground and storm watercontamination will belimited on site by properhandling and storage ofmaterials and equipment.Storm water will be treatedin sedimentation ponds, theimpact on overall qualityof wastewater will beminor.

Minor adverse



All storm water will go viasedimentation ponds & oilseparation.Procedures for locatingcontaminated materialduring evacuation will beestablished.Covering and damping ofexcavated materials.Appropriate storage ofcontamination material iffound

Some loss of flora & faunathat are re-colonizing themine area.

Mine Restoration Planincorporating habitatcreation and use of nativespecies

Depending on proposedfuture use of mine habitatcreation could lead tosignificant improvementfor biodiversity over valuewhen used as an activequarry.

Moderate to substantialbeneficial

Damage to the landscapecharacter and visualamenity due to introductionof incongruous featuresand activities

Restoration of the plantand mine sites including areforestation programme

Return of sites to existingto better than existingcondition

Minor beneficial

Solid waste generation Segregation and recyclingof waste and proper storagein isolation from theground

Solid waste will be passedto contractors and disposedaccording to their permits.

Minor adverse

Noise and emissiongenerated by vehicles

Traffic management plan. Local traffic congestionproblems avoided

Moderate adverse

Noise fromdecommissioning of plantand mines

Good site management;Good choice of machinery;Methods of working,including sequentialblasting;Hours of working;Efficient material handling;Construction of noisebarriers or baffle mound;Maximizing separationdistances

Until further details areknown, it is not possible topredict whether there maybe noise increase at nearbyresidential properties

N/A

Emergency situationsduring decommissioningworks

Local fire and emergencysquads available on-site.Availability of APML andcontractors inspectors onsite.

Plans to re-deploy workerswill be developed

Moderate adverse

Social Impacts – There willbe no job losses

An exit strategy should bedevised to minimize lossesand assist deployment. Itshould include options forretraining / early retirement/ assistance to job searchesand positioning /identification of jobswithin the group andpossible relocationassistance.

Plans to re-deploy workerswill be developed

Moderate adverse



7.5 Other Mitigation Measures

7.5.1 Waste Minimization and Treatment & Disposal MeasuresThese have been discussed in Sections 7.1 and 7.2, above.

7.5.2 Natural Resource ManagementThese have been discussed in Sections 7.1 and 7.2, above.

7.5.3 Mitigation of Human Impacts

A) Economic Environment

The Project could have both positive and negative impacts on theeconomic environment.

Whilst there is significant potential for positive economic benefits of theProject, the extent to which it is likely to lead to economic developmentand or inflation depends on the Project approach to providing services toits workers (e.g. transport, canteen services, and in-house medical care).

Mitigation: The Company needs to consider the Socio-economic baselinecontext and consult community leaders and civil society when makingeconomic development agreements.

B) Employment, Livelihoods and Income Generating ActivitiesAccess to Project Employment is a key priority for local stakeholders.

In both construction and operational phases there is an opportunity formaximizing positive impacts of the Company on local employment throughinvolving unskilled (and where possible skilled) labour from all Projectcommunities. However, although the generation of employmentopportunities resulting from Project activities is expected as a positiveimpact, there is a risk that conflicts could arise between local inhabitantsand new comers or outsiders over such employment opportunities.Furthermore there is high risk that, unless Project employment by theCompany and contractors is managed appropriately, nepotism wouldinfluence the recruitment procedure, meaning that people without



connections would not get access to Project opportunities – namelyemployment and other livelihood benefits. This could lead to a moderaterisk of social conflict.

Mitigation Measures:The Company should work actively to promote local access to Projectemployment in both the construction and the operations phases.

The Company needs to identify the skills that it needs for its constructionand operations phases that could be provided as part of a community skillsdevelopment program providing basic vocational training in thecommunities.

7.5.4 Occupational Safety & Health Measures

Construction and operational activities could expose workers to health andsafety risks. In particular, the following activities could have negativehealth impacts: noise and dust; working with heavy equipment (strains andaccidents); working in confined spaces (fumes could mean respiratoryimpacts), heavy lifting, storage, handling and use of dangerous substancesand waste (strains and accident risks), and working under noisy conditions(hearing and stress/psychological impacts). Excavations andtransportation of materials may cause further health and safety negativeimpacts.

Occupational health and emergency health services for both theconstruction labour force and operations employees will be at risk ofnegative health impacts which cannot be quantified, until clear plansemerge. The need for an ongoing, proactive workers health and safety planapplies for the full Life Cycle of the Project, particularly with regard to theoperational phase for the employees.

Without an operational/fully functional Health and Safety plan and healthtraining for workers the risks for worker health and safety are high.



Mitigation Measures:The Company needs to demonstrate a best practice occupational healthscheme, and share plans for the health maintenance and emergencyservices for their employees so that local health infrastructure capacity isnot put under greater strain. An important mitigation is the forming ofpartnerships of understanding and relationship building with local healthcare providers.

Company’s contractors should adopt strict construction and operationpractices with best technology and health and safety training to ensure thesafety of its workers.

7.6 Mitigation Measures for Green House Gases

The Carbon dioxide (CO2) emissions from Portland cement manufacturing are generatedby two mechanisms. As with most high-temperature, energy-intensive industrialprocesses, combustion of fuels to generate process energy releases substantial quantitiesof CO2. Substantial quantities of CO2 also are generated through calcining of limestone orother calcareous material. This calcining process thermally decomposes CaCO3 to CaO andCO2. Typically, Portland cement contains the equivalent of about 63.5 percent CaO.

Consequently about 1.135 units of CaCO3 are required to produce 1 unit of cement, andthe amount of CO2 released in the calcining process is about 500 kilograms (kg) per tonneof Portland cement produced. Total CO2 emissions from the pyro-process depend onenergy consumption and generally fall in the range of 0.85 to 1.35 tonnes of CO2 per tonneof clinker. IFC EHS Guidelines for Cement and Lime Manufacturing (April 30, 2007), inTable-7.3 (presented below) indicates the range of CO2 output from cement plant.



Table – 7.3

The other sources of CO2 emissions stemming from cement manufacturing operationsinclude transportation equipment used in the mining and transport of raw and finishedmaterials. The direct CO2 emission intensity of fuels depends on the carbon content ofthe fuel which varies by type of fuel and further may vary within a given fuel type. Theemission intensity of coals, for example, will vary depending on its geologic source.

In general, emissions of CO2 from the cement manufacturing sector can be reduced by:

• Improving the energy efficiency of the process,• Shifting to a more energy efficient process (e.g. from wet to dry process and use

of preheater/precalciner process),• Replacing high carbon fuels with low carbon fuels,• Applying lower clinker/cement ratio (increasing the ratio additives/cement):

blended cements, etc.

The technology to be used by APML is efficient, for the plant capacity, using dry processand preheater/precalciner process. Coal will be used as fuel.



Forests are both a part of the global warming problem and part of the solution. Unlikeother emission sectors, forests have the unique capacity to remove carbon dioxide (CO2)from the atmosphere and store this gas as carbon for long periods of time in their biomass(e.g., trunks, branches, leaves, roots, etc.).

While forests are a natural CO2 reservoir, or “sink”, they are also a source of CO2emissions. On a global level, forests are responsible for roughly 20 – 25% of overall CO2emissions, largely due to conversion of forestland and the associated depletion of carbonstocks. When forests are disturbed through events such as conversion to development oragriculture, fire or harvest, the carbon that is stored in tree biomass is emitted to theatmosphere. When harvested for timber, a percentage of forest carbon is stored in woodproducts for periods of time. These wood products decay over time, releasing CO2 at anaverage decay rate of 2% annually.

The Project can reduce greenhouse gas emission through activities that increase forestcarbon stocks on the landscape in concession area.

In order to mitigation GHG generation, APML can support afforestation project inconcession area through the Divisional Forest Department, by developing nurseries andprovision of samplings.

7.7 Coal Transportation

Coal unloading at Port Qasim and transportation to cement plant site has the potential togenerate fugitive dust. The fugitive dust can be reduced by:

Importing coal without fines and in larger sizes. Importing coal with moisture content ranging at 7% to 8%. This will also

lessen fire hazard. Using tarpaulin or other covers during transportation.



7.8 Environmental Monitoring

7.8.1 Ambient Air QualityA continuous ambient air quality monitoring system and program should be installed atleast 2-3 months prior to the start of main construction activities.

It is recommended that the monitoring program should cover as a minimum, the chemicalparameters under the environmental legal requirement.

Meteorological data should be recorded in parallel to air quality monitoring at the samereference location.

Monitoring parameters and frequency are to be carried out according to the requirementof Pakistan Environment Protection Act, 1997, under Category-A “Guidelines for Self-Monitoring and Reporting by Industry (SMART), [Copy attached as Appendix – 7.1].Ambient air quality monitoring should be carried out biannually, at least.

Monitoring methods are presented in Appendix – 7.1. Recommended monitoringequipment and instruments (including costs) and recommended monitoring methods arepresented in Appendix – 7.1.

7.8.2 Stack EmissionsArrangement for regular stack monitoring of NOx, SO2, CO and PM should be in place

7.8.3 NoiseAn ambient noise measurement program should be instituted upon commissioning of theproject. The monitoring program should consider the noise limits during day-time andnight-time at the closest point of public contact.

7.8.4 Wastewater/Thermal DischargeTreated wastewater and cooling water will be monitored as required by applicableenvironmental regulations.



7.8.5 Assigning responsibility for implementation (by name or position)In order to ensure implementation and effective operation of the EnvironmentalManagement Plan (EMP), it is of utmost importance that responsibilities be fixed tospecific persons so that each one of them should be answerable in case of lapse ormishap. Accordingly, hereunder the same responsibilities have been described:

Official Concerned Responsibility

1- Works Manager

i- Ultimate in-charge and responsible for all the

operations of Environmental Management Plan

(E.M.P) set up.

ii- He will be responsible to ensure smooth

functioning of the E.M.P system.

iii- Daily progress on the state of the

environmental status will be reported to him in

writing by the Shift Production Foremen.

iv- All other E.M.P matters, issues and problems

will be reported to him (for rectification) by the

Shift Production Foremen.

v- He will work as bridge between the

Government concerned authorities and the

senior most management of the project.

vi- He will be answerable to the higher

management in all matters relating to E.M.P.

and report at least monthly about the state of

the E.M.P. operations.

2- Shift Production Foremen

i- During his shift timings, he will be responsible to

ensure smooth functioning of the entire E.M.P.

ii- He will be responsible to rectify any problem

regarding environmental matter.

iii- He will directly report to the Plant Manager. Allmatters relating to E.M.P. on daily basis.



3- Plant Operator

i- He will be responsible to operate effluent

treatment plant and look after gaseous,

Production Manager and sound levels monitoring

systems.

ii- He will maintain all records of monitoring of the

entire elements of the E.M.P.

iii- He will report to the Shift Production Foremen

about matters relating to EM.P. Operations on

daily basis and earlier if so required.

4- Laboratory Chemist

i- He will be responsible to carry out all laboratory

testing of waste water at all levels.

ii- He will perform all other lab. testing as may be

required from time to time in