ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN LIBAN …
Transcript of ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN LIBAN …
ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
LIBAN LAIT INDUSTRIAL FACILITY
ESMP REPORT
22 February 2019
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ABBREVIATIONS AND ACRONYMS
ASL Above Sea Level CIP Cleaning In Place EIA Environmental Impact Assessment EA Environmental Audit EHS Environmental, Health and Safety ESA Environmental and Social Assessment ESMP Environmental and Social Management Plan GRM Grievance Redress Mechanism HR Human Resources L Liters LEPAP Lebanon Environmental Pollution Abatement Project m2 Square meters m3 Cubic meters MoE Ministry of Environment MoEW Ministry of Energy and Water MSDS Material safety Data Sheets NOx Nitrogen Oxide O&M Operation and Maintenance PPE Personal Protective Equipment PVPP Polyvinylpolypyrrolidone SES Social and Environmental Standards
SESP Social and Environmental Screening Procedure WB World Bank WWTP Wastewater Treatment Plant
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TABLE OF CONTENTS
ABBREVIATIONS AND ACRONYMS .................................................................................... i
TABLE OF CONTENTS .........................................................................................................ii
1 INTRODUCTION ....................................................................................................... 4
1.1 OVERVIEW ................................................................................................... 4
1.2 THE OBJECTIVE OF ESMP .......................................................................... 4
1.3 BRIEF DESCRIPTION OF THE INDUSTRY .................................................. 4
1.4 DESCRIPTION OF THE WORKFORCE ...................................................... 10
1.5 GRIEVANCE REDRESS MECHANISM FOR WORKERS ........................... 11
1.6 GRIEVANCE REDRESS MECHANISM FOR AFFECTED COMMUNITIES . 12
1.7 Social Impacts ............................................................................................. 12
1.7.1. LEBANON LABOR LAW .............................................................................. 12
1.7.2. HEALTH AND SAFETY PROCEDURES ...................................................... 12
1.8 MAIN ENVIRONMENTAL IMPACTS ............................................................ 14
2 SUB-PROJECT DESCRIPTION .............................................................................. 16
2.1 WASTEWATER QUANTITIES AND SOURCES .......................................... 16
2.2 PROJECT COMPONENTS AND DESIGN FEATURES ............................... 20
2.2.1 Existing Infrastructure ...................................................................................... 20
2.2.2 Foreseen Treatment ........................................................................................ 21
2.3 SUMMARY OF ENVIRONMENTAL AND SOCIAL LEGISLATIONS
RELEVANT TO WASTEWATER TREATMENT ........................................... 24
2.4 SCREENING OF THE PROJECT AND APPLICABLE WORLD BANK (WB)
SAFEGUARD POLICIES ............................................................................. 27
3 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ....................................... 31
4 ENVIRONMENTAL AND SOCIAL MONITORING PLAN ......................................... 44
5 EMERGENCY PREPAREDNESS AND RESPONSE PLAN .................................... 50
6 STAKEHOLDERS MEETING .................................................................................. 52
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Table of Figures
Figure 1 : Liban Lait - Location of Plot No. 762 (1/20,000) .................................................... 5 Figure 2 : Liban Lait – Haouch Snaid (Google Earth Satellite Image) .................................... 5
Figure 3 : Liban Lait – Boundaries of Plot No. 762 (Google Earth Satellite Image) ................ 6
Figure 4 : Liban Lait - Location and Surroundings of the Dairy Processing Plant ................... 6
Figure 5: Liban Lait - Location and Surroundings of the farm ................................................ 7
Figure 6: Process Area at Liban Lait ..................................................................................... 9
Figure 7: Portable Fire Extinguishers and Fire Hose Reels at Liban Lait ............................. 14
Figure 8: PPE worn by workers at Liban Lait ....................................................................... 14
Figure 9: Silage Moisture Drained in Open Trenches ......................................................... 17
Figure 10 : Existing wastewater treatment infrastructure (in yellow the location of the existing
ponds, in red the location of the planned WWTP) ............................................................... 21
Figure 11: Flowchart of the treatment steps ........................................................................ 22
Figure 12: Consultation meeting for the ESMP of the WWTP, Liban Lait, 13 June 2018 ..... 53
List of Tables
Table 1: Liban Lait Employees and working shifts ............................................................... 10
Table 2: Wastewater Sources per production line in Liban Lait ........................................... 16
Table 3 : Wastewater Quantities and Sources at Liban Lait ................................................ 17
Table 4 : Maximum Allowable Limits for Wastewater Discharge into Surface Water ........... 18
Table 5 : Available Wastewater Measurements results during the auditing process ............ 19
Table 6: List of legislation relevant to the sub-project .......................................................... 25
Table 7: List of Attendees of the Consultation meeting held at the Liban Lait ...................... 52
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1 INTRODUCTION
1.1 OVERVIEW
An Environmental Audit (EA) of the Liban Lait industrial facility was financed through a fund
granted to the Ministry of Environment (MoE) from the IDF/Improve Capacity for
Environmental Compliance Project under the activity “Supporting Industrial Pollution
Abatement in Lebanon III” (Contract No. FC002).
The EA report was submitted to the Ministry of Environment for review and was approved
through the letter No. 1544/B Dated 19 March 2018.
Wastewater resulting from the Liban Lait plant located in Hosh Sneid Cadastral District
(Baalbeck, Bekaa) is currently directly discharged into a nearby water stream which
eventually discharges into the Litani River after a preliminary separation of the solids from
the liquid stream. As part of its obligations towards the national legislations, Liban Lait is
required to treat its effluent prior to its discharge into the nearby water stream.
In order to achieve environmental compliance in terms of wastewater discharge, Liban Lait is
currently keen to implement an industrial wastewater treatment plant (WWTP) and is seeking
financing under the Lebanon Environmental Pollution Abatement Project (LEPAP).
This document is an Environmental and Social Management Plan (ESMP) submitted to the
LEPAP, which pertains to the WWTP to be implemented at Liban Lait industry.
1.2 THE OBJECTIVE OF ESMP
The WWTP foreseen to be implemented at “Liban Lait” is a category II subproject according
to the ESA of LEPAP and the World Bank OP 4.01., hence an ESMP is required.
In fact, the overall objective of the ESMP is to assist in minimizing the impacts to the
environment and surrounding communities and reach a set of environmental and social
objectives. The ESMP ensures that the environmental and social objectives of the projects
are met through monitoring in order to avoid or mitigate adverse effects on the environment
and the population.
The ESMP is compiled based on the environmental audit report prepared in accordance with
Lebanese environmental laws and guidelines, the World Bank Safeguard Policies and
similar projects best practice.
1.3 BRIEF DESCRIPTION OF THE INDUSTRY
Liban Lait Plant is located on plot No. 762 of Hosh Sneid Cadastral District (Caza of
Baalbeck, Mohafaza of the Bekaa) in an industrial zone, at an altitude of 1,015 m above Sea
Level (ASL). The industrial facility is surrounded by adjacent agricultural lands, few
residential units and a military compound.
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The total allocated site area amounts to 30,000 m2 for the processing Plant and 60,000 m2
for the farm. The Main Products are dairy products (Fresh and pasteurized Milk, Skimmed
Milk, Yogurt, Ayran, Labneh, different types of cheese), Juices, Plastics (HDPE containers
for yogurt and PET bottles for Ayran) and Fertilizers from manure.
Figure 1 : Liban Lait - Location of Plot No. 762 (1/20,000)
Figure 2 : Liban Lait – Haouch Snaid (Google Earth Satellite Image)
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Figure 3 : Liban Lait – Boundaries of Plot No. 762 (Google Earth Satellite Image)
Figure 4 : Liban Lait - Location and Surroundings of the Dairy Processing Plant
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Figure 5: Liban Lait - Location and Surroundings of the farm
The main production processes of Liban Lait can be summarized as follows:
Farm Process (Raw Milk and Manure) and skimmed Milk, with a total annual capacity
of 750,000 L
The farm has 1,256 dairy cows, 1,065 heifers (1-22 months) and between 50 to 100 calves
(3 months), which are distributed into 4 hangars. The dairy cows are milked mechanically.
The milk is transported in stainless steel pipes and stored in stainless steel tanks. The milk is
also refrigerated (4-50C) during the storage time for 72 hours maximum. As the milk reaches
the production facility, it is tested to check the microbial and chemical parameters on a daily
basis upon every delivery, then it is cooled to 4~5 ºC. Washing and cleaning of cows takes
place by using the reject reverse osmosis water and untreated water.
The skimmed milk is produced in the same way as the UHT milk but it is fat free,
wherein, in a first stage prior to the pasteurization stage, the raw milk is entered into a
separator that skims the fat. This fat that is collected goes to the cream processing unit
(located in the process area) where centrifugation occurs and the skimmed milk is then
pasteurized with UHT technique by heating it at 140 °C (275 °F) (the temperature
required to kill spores in milk) for 3 to 5s. The last stage includes steam sterilization of
the milk to extend its lifetime before bottling (multilayer cartoon bottles). The fat is re-
injected in other production lines (i.e. fresh and pasteurized milk).
Yogurt, with a total annual capacity of 330,000 L
The cooled milk is pasteurized under 95 ºC for 5 minutes and then taken to the cream
separator where the cream is separated from the milk. The collected cream is taken to
the cream processing unit and the remaining milk goes to the homogenization unit and
then cooled to 45ºC. After cooling, bacterial cultures are added to the milk to initiate the
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fermentation process, then it is directly filled in plastic containers (5 Kg, 1 Kg, and 2 Kg).
The containers are transferred to the storage rooms while a temperature of 45˚C is
maintained till the pH reaches 4.85. At this stage, the product inside the containers
becomes harder and it is moved to the refrigerator at 3˚C. Two hours later, the yogurt is
ready and stored.
Ayran, with a total annual capacity of 560,000 L
After the process of producing yogurt as per the above, water, salt and whey are added to
yogurt and stirred. The liquid mixture is then filled in plastic bottles and refrigerated when
stored. Out of specifications products are used to produce Chanklish. There is not a
standalone production line for Chanklish. The Chanklish production is done manually where
salt, pepper and spices are added to the out of specifications products. The output is left for
fermentation for about 8 hours before being packed.
Labneh, with a total annual capacity of 200,000 Kg
The cooled raw milk is pasteurized under a temperature of 95˚C for 5 min and then cooled to
45˚C, further to which yogurt starter culture is added to initiate and enhance fermentation.
About 2h30min later, the pH reaches 4.85. The content is then cooled to 37˚C with shaking.
After this, the content is cooled to 5˚C till the next day (20 hours). Water and salt solution
(2%) are added to the cooled yogurt and transferred to strained bags to begin mechanical
dripping to finally produce and pack Labneh. The left over whey is then taken as it is and
used for Ayran, calves fodder and cheese process.
Several kinds of cheese, with a total annual capacity of 224,000 Kg
- Feta (60,000 Kg)
- Double Crème (26,000 Kg)
- Accaoui and Accaoui Chiki (30,000 Kg each)
- Halloum (78,000 Kg)
The cooled raw milk is pasteurized, further to which cheese starter culture (yeast or mold) is
added to initiate the coagulation of milk. About 1 hour later, the obtained coagulated mixture
is strained in permeable bags. The coagulated mixture is pressed to separate the whey from
the cheese. The cheese is cut into pieces . Then, production steps differ according to the
desired type of cheese.
Fruit Juices, with a total annual capacity of 34,320 L
Fruits concentrates (pineapple and orange) are mixed together with water and sugar. The
100% concentrated fruit juice is then filled, packed and labeled.
Fruit Nectars, with a total annual capacity of 936,000 L
The fruit nectars are produced by the same process of concentrated juices as described
above. However they are 45% concentrated juices.
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Plastics (HDPE Containers for Yogurt/ PET Bottles for Liquid Ayran), with a total
annual capacity of 4,576,000 pieces.
High density polyethylene pellets are added to the molding machines, where they are heated
to the elastic point. By injecting the melted pellets in a container shape mold, the plastic
takes the shape of the yogurt tanks. The mold is cooled in a closed system and then ready
for use.
PET Bottles are made from small pre-form polyethylene bottles. The pre-form bottles are
added to the molding machine, where they are heated to reach the elastic point, then air is
blown in the pre-form bottles to take the last shape. The hot bottles are then cooled in a
closed system and packed to be used.
Fertilizers, with a total annual capacity of 370,000 Kg
The farm produces fertilizers from manure. The manure is collected inside the stables and
outside in the external yards next to stables. The manure inside the stables is collected
mechanically. Each stable is equipped with a long scraper that collects the manure produce
from the cows and push it all into a central canal then to the collecting underground tanks
equipped with mixer and pump. Each pool has a capacity of 27 m3 and is continuously mixed
to homogenize the manure. The mix is then pumped to the separation tank (250 m3). This
manure is pumped through centrifugal pumps to separate the solid from the liquid. The solid
part is then dried in the open air for organic fertilization while the liquid part is discharged into
the nearby water stream and is expected to be further treated once the nutrient recovery and
water recycling unit is implemented. The manure produced in the external yards is kept
outside to dry and then collected to be sold later. This process happens only in good
weathering conditions, especially from May to October. In the winter, the manure is collected
and left in the external yard. When the compost is finished, it is screened. The screening is
needed to sort into different sizes. The smaller sizes are filled in bags and sold to the florists
and gardens. The large ones are sold to farmers.
Figure 6: Process Area at Liban Lait
The main environmental issue faced at Liban Lait is the generation of wastewater (described
in Section 2.1 below) in addition to the following:
The generation of air emissions mainly from the generators and boilers;
The generation of manure from the cattles’ farm;
The generation of odors, ammonia and methane from the farm;
The generation of solid wastes mainly recyclables (cartons, plastics, nylon and wooden
pallets).
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A minor generation of hazardous waste inlcuding used oils and lubricants.
The carbon monoxide and sulfur dioxide emissions of all generators and boilers are below
the regulatory limits. Nitrogen oxides levels are also below the limit values except for one of
the generators. Liban Lait is required to follow a regular maintenance program in order to
ensure the sufficient operation of the generators and the boilers. Furthermore, a catalytic
converter for nitrogen oxide reduction should be installed for the non-compliant generator in
order to further minimize the emissions.
The manure generated at the farm is currently composted on-site and sold for farmers. The
farm cleaning activities are a source of odors and ammonia and methane emissions in the
area. Once the wastewater is treated properly, the odours issue will be resolved.
Used oils and lubricants currently sold to third parties shall be sold for recycling. The solid
wastes generated are mainly the following:
Plastic pallets are reused on-site;
Salt, sugar, culture starter, bacterial cultural bags currently sold to third parties shall be
reused or sent for recycling;
Caps, cartons, nylon and wooden pallets are currently sold to third parties; Liban Lait is
advised to send them back for recycling.
As the production lines systems is fully automated, the interventions from labors is limited to
minor regular check ups and to scheduled maintenance. The number of labors involved
depends on the type of interventions.
1.4 DESCRIPTION OF THE WORKFORCE
Liban Lait currently engages 25 managerial employees and 153 production employees.
Table 1: Liban Lait Employees and working shifts
Type Number
Total number of employees 488
Number of Full Time Employee 487
Number of Part Time Employee 1
Number of Managerial Employees 25
Number of Production Employees 153
Number of Female Employees 41
Nationality of Employees Lebanese and Bengali
Employees Residence Close – by villages
Work Schedule 13 hrs./day
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Days per week: 6
Shifts per day: 2
Days per year: 288
The only part-time employee at Liban Lait is the representative of the National Social
Security Fund. Women are mostly working in the administrative positions in the plant in Hosh
Sneid and the offices in Beirut (human resources, accounting, purchasing..etc.) but also in
the laboratory and the quality department.
All employees are ensured under workmen compensation plan. The Bengali employees are
considered as daily labours and they are all covered under workmen compensation plan as
well.
Syrian workers are recruited as daily workers on a need basis (i.e. trucks loading and
unloading).
Liban Lait follows the stipulations of the Lebanese Labor Law dated 23rd September 1946,
with Amendment Law 207 issued on 26th May 2000, however there is no written policy in this
regard.
Liban Lait doesn’t have a workers’ association but has a written code of conduct that
includes the industry’s internal policies mainly with regards to the grievance, the health and
safety instructions and the fire and electrical shutdown risk prevention systems.
1.5 GRIEVANCE REDRESS MECHANISM FOR WORKERS
There is a grievance mechanism available at Liban Lait. The purpose of grievance handling
is to establish a procedure for the fair, orderly, and speedy resolution of disputes that
sometimes arises between supervisors and employees. This shall serve as the exclusive
company procedure for the resolution of job-related concerns/complaints and grievances.
An employee may utilize this procedure to review an alleged violation or misapplication of
company policies or rules pertaining to employment in the department involved, or applicable
laws and regulations that directly and adversely affected the employee. Complaints can be
resolved informally or through the assistance of the HR department if informal attempts
failed. It is processed through the direct manager/supervisor who prepares the non-
conformity report and send it to the HR department for making the proper assessment and
taking the needed actions accordingly(verbal and written notifications and warnings).
Moreover, The HR Manager may be contacted for informal counselling, if the employee
believes he cannot approach the department Manager/Supervisor with the problem. The HR
Manager will meet with the employee, the supervisor, or both as may be appropriate, to
assist in amicably resolving their differences.
It should be noted that the existing grievance redress mechanism for workers is also
applicable to all those who would undertake any construction and/or operation activities on
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Liban Lait’s site. Therefore, this grievance mechanism shall be applied to all contractors’
workers operating onsite.
1.6 GRIEVANCE REDRESS MECHANISM FOR AFFECTED COMMUNITIES
External complaints are currently reported through phone calls and through emails. All the
complaints are directly handled by the quality department, and the customers are
compensated accordingly.
It is also worth mentioning that a grievance redress mechanism is available at the LEPAP
level and it allows all those who believe they are being affected by a LEPAP financed sub-
project to raise their concerns and have them resolved. It is a complaints mechanism
addressing the mitigation and monitoring of any potential negative impacts in a timely
manner.
It should be noted that the existing grievance mechanism for affected communities shall be
further detailed and improved to include the following information: precise timeline,
departments involved and responsibilities as per Section 3 below.
1.7 SOCIAL IMPACTS
1.7.1. LEBANON LABOR LAW
As per the applicable social legislations mentioned in Section 2.3 below and according to
Article 22 of the Lebanese Labor Law, it is forbidden to employ employees aged less than 14
years. Hence, exposing young employees (14 years of age) to risks affecting their life,
health, physical, mental, spiritual, moral or social development is not possible within Liban
Lait.
1.7.2. HEALTH AND SAFETY PROCEDURES
The Health and Safety Procedures implemented in Liban Lait can be summarized as follows:
- Medical tests for the production staff are carried out periodically.
- Personal Protective Equipment (PPE) such as protective clothing, hairnet, eye
protection, and ear protection are worn in the different production areas.
Impervious boots of chemically resistant material are worn when necessary (i.e. while
handling chemicals such as medicine for cows)
Body suits, aprons, and gloves of chemical resistant material should be worn at all
times. Contaminated clothing are cleaned and dry thoroughly before reuse.
Eye protection and protective clothing are worn during handling of Chemicals.
Respiratory masks are worn during handling of Formalin.
Safety glasses, lab coat, gloves (impervious), and dust respirator are worn while
handling Citric Acid.
Face protection masks and gloves are worn when in contact with Copper Sulphate.
Hairnets are worn all the time.
- An eye wash station and drench shower are present within the Plant.
- There are policies and procedures related to hygiene. Good housekeeping rules are
practiced; Dust dispersal during cleanup operation is avoided.
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- The milking machine and milk storage equipment are kept clean and in good condition.
- All equipment, machines and tanks are sanitized after use. Safety instructions for using
all the machines are given on a weekly basis.
- Every container in the plant is well labeled with material identification, supplier name,
manufacture date and expiry date.
- The Plant is well ventilated. A general mechanical ventilation system is available within
the plant.
- Pest management strategy is applied within the farm area; and
- Fire protection system is installed in the different production lines. The fire alarm system
is equipped with the following:
Smoke and heat detectors, installed in each area of the plant;
Beam Detectors, installed in the large areas (process area, filling area, overfilling area
and warehouse);
Horns: 7 horns are distributed in and around the plant to alert the people in case of
fire
A main control panel installed (to show the place of the fire or alarm in case).
12 Pull stations to manually alert people in case of fire.
Liban Lait is equipped with portable fire extinguishers and fire hoses. In fact, the fire
suppression system is equipped with the following:
Fire Sprinkler systems, installed in the warehouse, and in the top of all the
refrigerators;
CO2 fire Suppression, installed in the process MCC electrical room;
Fire trace System, installed for all the UPS and closed panels;
Extinguishers, distributed throughout the plant (CO2, Powder or Foam);
Hoses: 14 hoses are installed throughout the plant.
Moreover, an Evacuation Plan is implemented in Liban Lait. The factory is divided into three
evacuation zones:
1. Zone 1: Utility, Process, Filling and Offices Employees
2. Zone 2: Offices, Filling and Over filling Employees
3. Zone 3: Warehouse Employees.
It should be noted that the WWTP will be equipped as part of Zone 1.
With respect to spills, no emergency response plan is implemented.
On the Job trainings are obligatory for new employees and minimum once a year for existing
employees.
The facility has reported a fire incident that occurred in 2005 in the storage area which lead
to air emissions to the environment. During July 2006, the milk production process suffered
from bombardment which ultimately led to negative environmental impacts and pollution
risks to the surrounding area.
The facility reported about complaints from the near residential/ neighboring buildings due to
the odor emissions produced from the activities of the dairy farm, mainly from the animal
manure and possible dead cows.
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Photos representing some of the existing health and safety measures implemented at Liban
Lait are presented in the photos below:
Figure 7: Portable Fire Extinguishers and Fire Hose Reels at Liban Lait
Figure 8: PPE worn by workers at Liban Lait
Liban Lait Management is keen to provide continuous trainings to all employees and
workers. The trainings are mostly technical and related to the different departments’
responsibilities; no training on social aspects are currently delivered at Liban Lait.
The trainings addressed to workers are mainly related to personal hygiene and food safety.
On another hand, the training addressed to the employees usually cover the following
subjects: new software, new processes and procedures, specific engineering matters.
1.8 MAIN ENVIRONMENTAL IMPACTS
Liban Lait conducted an Environmental Audit (EA) in order to assess the impacts of its
activities and to allow a better planning of the actions needed to avoid or reduce undesirable
effects and/or impacts.
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The EA report was approved by the Minister of Environment through its Letter No. 1544/B
dated 19 March 2018.
As highlighted in the EA report, the main environmental issues associated with Liban Lait are
summarized here below:
The process and domestic wastewaters are not treated properly. Process and domestic
wastewaters from the dairies production building (i.e. Cleaning in Place (CIP) system,
cleaning of production areas and equipment) and from the cow farms is collected by
separate drainage system to a main collection / separation tank where the solids are
separated from the liquid wastewater stream via a screw press as a first step of
treatment. After that, the liquid is discharged without any further treatment to the
adjacent land, owned by the facility, where the settling tanks are constructed. The solids
from the main tank are collected and are either composted or sold to third parties as
fertilizer. Process wastewater from the CIP system of the milking parlor along with the
wastewater from the moisture drainage of the silage are also drained directly to the
adjacent land without any further treatment, via open unpaved trenches; this would result
in polluting the Litani River
High NOx concentrations have been detected at one of the generators (500 KVA CAT
Generator, dated 2005), which is located on a concrete slab, in a partly enclosed area,
open from one side with two big doors. Regular maintenance and emissions monitoring
shall be conducted along with the installation of a catalytic converter for NOx
concentration minimization.
The used oils, oil containers, hydraulic oil containers, used lubricants containers, NaOH
bags and HNO3 containers are currently sold to a third party. These hazardous wastes
shall be returned to the supplier for reuse or sent for recycling.
Medical waste generated at the farm is currently sent to third party for disposal. These
wastes shall be disposed of according to the best environmental management practices.
Noise was measured 1 m next to the generators. The noise measurement required at the
proximity of the nearby residential units surrounding the plant was not conducted
because it is a military area and the team was not allowed to approach it. Sound proofing
doors are suggested to be installed in front of the generators. Although generators are
located indoors, the doors are not appropriate for keeping noise at low levels.
The bags and containers of the following raw materials are currently being disposed of
with municipal waste: salt, sugar, culture starter, NaOH and HNO3. It is suggested that
they are returned to the corresponding suppliers as per the requirements of the materials
safety data sheets.
The used oils and lubricants are currently being sold to third parties. Liban Lait is
requested to send them back for recycling.
The Action Plan and Compliance Strategy for Liban Lait has been divided into 12 sub-
projects as per section 7.3 of the Environmental Audit (EA) of Liban Lait.
Sub-project No. 1 consists of the installation of a WWTP. The following ESMP will include all
the necessary actions, mitigation measures, management and monitoring plan set forth in
view of not compromising the potential of the sub-project and hence ensuring its
sustainability.
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2 SUB-PROJECT DESCRIPTION
As stated above, sub-project No. 1 consists of the installation of a WWTP for the domestic
and process wastewater in order to comply with the national ELVs for WW discharge and the
Wrold Bank environmental health and safety guidelines and to alleviate the impacts of odors
on the surrounding areas.
2.1 WASTEWATER QUANTITIES AND SOURCES
Industrial wastewater is mainly generated from CIP and cleaning activities of the farm and
the manufacturing plants. A summary of the wastewater sources per production line is
presented in the table below:
Table 2: Wastewater Sources per production line in Liban Lait
Production line
Wastewater sources
CIP
Whey Cleaning of Floors
Pasteurization
Bottles Rinsing
Cleaning of Equipment
Other
Farm
X
X
X
Spraying of
cows
- Silage
moistening Fresh, Pasteurized/
UHT and skimmed
milk
X
X
X
X
Yogurt and Ayran
X
X
X
X
X
Labneh X X X X
Cheese X X X X Preparation
of brine
solution
100% Concentrated
Fruit Juices and
Fruit Nectars
X
X
X
HDPE containers for
Yogurt X
PET bottles for Ayran
X
Fertilizers X X
Whey from the dairies production activities is collected to a designated tank and is either
mixed with silage in order to be used as fodder in the farms or reused in the processing of
some cheeses.
Process and domestic wastewater from the dairies production building (i.e. CIP system,
cleaning of floors, etc.) and from the cow farms is collected through a separate drainage
system to a main collection/separation tank where the solids are separated as a first step of
treatment from the liquid stream of the wastewater via a screw press. Resulting liquid is
discharged to the adjacent land without any further treatment. The solids from the main tank
are collected and are either composted or sold to third parties as fertilizer.
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Process wastewater from the CIP system of the milking parlor along with the wastewater
from the moisture drainage of the silage are drained directly to the adjacent land without any
further treatment, via open unpaved trenches.
The rejected water from the RO treatment is estimated to be 70.800 m3/yr and is gathered in
an underground tank and mainly reused in the cow farms for cleaning purposes. When the
usage decreases, the overflown water is discharged to the wastewater sewage drainage,
which ends up into the main collection/separation tank.
Figure 9: Silage Moisture Drained in Open Trenches
Finally, the moisture of the silage, which is stored as fodder in open spaces, is drained under
the silage’s own weight onto the ground, wherefrom it is discharged via open unsealed
trenches to the adjacent plot. The estimated quantities of the generated wastewater per
source are presented in the table here below:
Table 3 : Wastewater Quantities and Sources at Liban Lait
Sources of wastewater Annual
production
(m3/year)
Daily flows
(m3/day)
Final Discharge
System
Whey from dairy production process 1,080 3.75 Collected and reused as calves
fodder
CIP in dairy production lines 69,400 241.0 Collected to a main
collection / separation tank
(solids separation) and the
liquid effluent is discharged
to the adjacent empty plot
without further treatment.
Cleaning of production areas and equipment 4,032 14
Bottles’ rinsing 1,500 5.2
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Wastewater from the cow farms 80,000 277.8
Domestic uses 3,665 12.7
Pasteurization 500 1.8
CIP in milking area 4,400 15.3
Discharged untreated to the
adjacent empty plot via open
trenches
Silage moisture drain: Liban Lait uses 130
tons of corn per year; it is fermented onsite,
resulting of a considerable amount of
wastewater, but it is difficult to quantify
Unable
to
quantify
-
RO reject
70,800
(Included in the
volume from
cleaning the cow
farms)
-
Reused for cleaning the cow
farms and the excess reject
water is collected to the main
collection/separation tank
(solids separation) and the
liquid effluent is discharged
to the adjacent empty plot
without further treatment.
TOTAL 235,377 571.44
Daily flows are based on 288 days of annual operation as reported by Liban Lait. At present,
the total quantity of wastewater discharged is estimated at 572 m3/day; however, wastewater
quantities are expected to reach 1,000 m3/d in the coming years due to the expected
increase in production within the facility.
The wastewater quantities generated per production line has been estimated since flow
meters have not been installed at the industry.
The WWTP shall allow Liban Lait to move towards environmental compliance by discharging
treated wastewater with the following characteristics:
Table 4 : Maximum Allowable Limits for Wastewater Discharge into Surface Water
Substance
Max. Allowable limits for WW
Discharge into Surface Water
according to Decision 8/1
Max. Allowable limits for WW
Discharge according to the
WB EHS Guidelines for the
wastewater and ambient
water quality
pH 6-9 6-9
Temperature (ºC) 30 -
BOD (5 day, 20ºC) (mg/l) 25 30
COD (dichromate) (mg/l) 125 125
Total Phosphorus (mg/l) 10 2
Total Nitrogen (mg/l) 30 10
Suspended solids (mg/l) 60 50
Oil and grease (mg/l) 30 10
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Sulphates (mg/l) 1,000 -
Coliform bacteria (37ºC in
100ml)
2,000 400
The limits values for BOD, COD and suspended solids are almost the same according to the
requirements of the WB and the MoE. The allowable limits for total phosphorus, total
nitrogen and oil and grease are more stringent according to the WB requirements. However,
the water recycling and nutrient recovery is expected to allow LIban LAit to comply with the
national wastewater environmental standards and the World Bank allowable limits.
Three (3) wastewater samples were taken at Liban Lait during the Environmental Auditing
Process: one sample from the discharge point of the production building, another sample
from the farm, and a third from the main collection/separation tank.
Wastewater contains high concentrations of organic compounds, measured as COD and
BOD5, due to the organic loads and the chemicals uses in the central CIP system for the
cleaning of the process equipment. The TSS content is low because the whey is separated
at an early stage and does not end up to the main collection tank.
Table 5 : Available Wastewater Measurements results during the auditing process
Substances
Measurements at the
Outflow of the
production building
Measurements at the
Farm
Measurements at
the Main Collection
Tank
June
2016
August
2016
March
2017
Substan
ce
June
2016
August
2016
March
2017
Substan
ce
June
2016
March
2017
pH 11 11.7 8 7 7.47 7 7.5 7
BOD (5 day, 20ºC)
(mg/l) 580 219 2,960 3,780 9,190 19,800 4,180 13,300
COD (dichromate)
(mg/l) 960 5,630 6,560 5,470 25,600 26,400 6,430 20,300
Total Phosphorus
(mg/l) 2.3 - 5 4.5 - 9 6.1 7
Total Nitrogen
(mg/l) - <0.03 % 508 4,760 <0.03 % 2,520 7,060 1,920
Suspended solids
(mg/l) 80 - 97 85,000 - 39,800 112,000 24,000
Oil and grease
(mg/l) 26 456 118 74 1,100 211 118 178
Sulfates (mg/l) - - 75 - - 5 - 5
Total coliform
(CFU/mL) - - - 1.1 x 10
4 - - 5.5 x 10
4 -
The “farm” sample was collected from one of the three farms within the facility. The
differences shown in the results above are mainly due to the sampling process adopted.
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Wastewater from the farms contains very high loads of COD, BOD, TSS and Total Kjeldahl
Nitrogen, which is expected from such wastewater as that resulting from farms which mostly
consists of animal feces.
In fact, the values measured in the main collection / separation tank which constitutes the
only type of treatment currently applied by the facility before the wastewater is discharged
onto the adjacent land, are all incompliant with the discharge limits (except from Total
Phosphorus), hence the crucial need for the WWTP.
2.2 PROJECT COMPONENTS AND DESIGN FEATURES
2.2.1 EXISTING INFRASTRUCTURE
The industrial plant had previously installed a WWTP, which is no longer operational;
however, the corresponding infrastructure is still present on site.
Liban Lait has constructed two open cylindrical tanks having respectively 13 and 14 meters
in diameters, which were supposed to be operated as anaerobic reactors for the treatment of
the liquid wastewater from the main collection/separation tank. It is however important to
note that the mentioned tanks are uncovered and are not equipped with any devices for
mixing the wastewater or collecting/utilizing the biogas.
Furthermore, the facility has constructed a set of 3 settling/stabilizing tanks for wastewater
treatment: two of them have a depth of 4.5 m and the third 6.0 m, with a total volume of
17,460 m3 and a total surface of 3,480 m2.
As per the existing design, the wastewater collected in the main collection/separation tank,
will be treated first in the two anaerobic reactors and then it would flow to the set of the three
settling/stabilization tanks for further treatment before it is discharged either to the adjacent
plot or to Litani River.
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Figure 10 : Existing wastewater treatment infrastructure (in yellow the location of the existing ponds, in red the location of the planned WWTP)
2.2.2 FORESEEN TREATMENT
Liban Lait decided to adopt a nutrient recovery and water recycling system with a total
design capacity of 1,000 m3/day taking into consideration the current wastewater flow and
the quantity of wastewater which is expected to be reached within the coming years due to
the increase of production.
With this type of treatment, the majority of the currently produced liquids are recovered as
clean water while the crop nutrients are segregated and concentrated.
The treatment process consists of the following steps:
- Dairy and farm wastewaters are mixed in the main collection tank;
- The wastewater is passed through two screw presses in a row in order to collect the
solids;
- Solids are transferred to the composting section at Liban Lait for further treatment
while the resulting liquid is transferred to the main feed tank;
- The resulting liquid goes through the first wave system to further separate the solids
which are also transferred to the composting unit for treatment;
- The resulting liquid goes through the second wave system which results in the
production of a liquid fertilizer on one hand and clean water on another hand.
Below is a flowchart representing the treatment process.
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The liquid fertilizer produced will be stored on-site in the existing 15.000 m3 concrete ponds
in addition to a 30.000 m3 storage tank which will be constructed by Liban Lait.
Liban Lait will be using the liquid fertilizer produced for the cultivation of 10.000 tons of corn
needed for animal feeding. The liquid fertilizers will also be used by the neighboring farmers
for growing fruit trees, vineyards and forage crops.
It should be noted that the treatment process does not generate any odors since there will
be no ammonium in the liquid fertilizer.
The main components of the treatment plant are the following:
- Control and Information Package
It includes the information and controls system design. The controls and instrumentation are
driven remotely by local iPad or from the control panel touch screen. The operator can
control and monitor the entire system for total and instantaneous measurements of liquids,
water, chemical consumption and electrical consumption. Shutdown conditions notify the site
operator and/or any of the dairy management.
The customized iPad allows the operator to control and monitor the operation while working
in the immediate vicinity of the equipment or remotely from home, office or anywhere there is
Wi-Fi internet access.
- Inlet Suspended Solids Separation
It consists of a screen system including a manure feed pump, automated feed polymer
system, high performance coagulation/flocculation chamber (patent pending), and patented
separation screen with cover. This system is expected to achieve a 99.99% removal of
phosphorus and suspended solids.
- Fine Solids Separation System
It consists of a very efficient removal of entrained fine solids due to a settlement approach
requiring little energy. The fine solids are controlled with is a single pump in addition to a
stainless-steel cartridge filter which is flexible across a range of particle size for an increased
membrane protection.
Figure 11: Flowchart of the treatment steps
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- Nutrient RO Membrane System
The Reverse Osmosis (RO) Membrane System is an established technology functional for
nutrient liquids. This RO features include:
A high surface area membrane configuration which assures consistent operation;
A built-in anti-fouling capacity so that water recovery is optimal and stable;
An automated cleaning system which works in conjunction with the cleaning solution for
a daily removal of impurities;
A nutrient recovery capacity of up to 80%;
A membrane designed to minimize the feed pressures to save electricity, to reduce
pump capacity and to maximize motor and pump life for the RO pumps.
The main civil works required are the following:
- A 5.000 m3 tank used as a feed tank;
- A 30.000 m3 pond for the storage of liquid fertilizers;
- A treatment building to host all the equipment.
The civil works are expected to require the following equipment:
a. Excavator (1);
b. Chain Loader (1);
c. Trucks (2);
d. Concrete mixer trucks.
Labor force required for sub-project
The above mentioned works are expected to be completed within a period of six months
through a private contractor who will need to hire around 20 labors intermittently. The
mentioned labors will be mobilized specifically for the construction of the WWTP; thus, they
won’t reside on the sub-project’s premises and will be transported onsite on a daily basis as
needed. This means that there won’t be any labor camp on-site throughout the sub-project
construction period.
However, the contractors’ workers will have to abide by the environmental, health and safety
regulations of Liban Lait in addition to the construction’s mitigation measures mentioned in
Section 3 below during their interventions on the site.
It should also be mentioned that the contractor’s labors shall undergo trainings on major
health and safety matters and applicable code of conduct. In addition, they are entitled to a
full insurance coverage complying with the occupational health and safety requirements.
The contractors’ workers will also have access to Liban Lait grievance redress mechanism in
case of complaints.
It is the responsibility of Liban Lait and the contractor to ensure the minimum health and
safety requirements are applied and the Lebanese Labor Law and the World Bank
Standards are met. For this matter, the below Day Laborers Policy requirements shall be
applied.
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Day Laborers Procedure:
a. Recruitment :
Name, address and copy of ID to be kept in a registry by the contractor and to be
provided to Liban Lait;
Ensure that the age of the workers are compliant to the national labor law;
Ensure that the workers do not pay a mediator fee for the employment to any third
parties.
b. Inductions and conditions :
Day laborers shall be given a training on the following topics:
. Health and safety guidelines;
. Emergency preparedness and response plan;
Day laborers shall be informed about their duties and rights, working hours, rates and
schedule of payments, work schedule…etc.;
A record of the wage payments and hours worked shall be kept;
The workers shall be provided with protective equipment as described in Section 3
below.
c. Responsibility of Liban Lait and Contractor :
Liban Lait is responsible to enforce the contractor to implement the labor and health and
safety conditions onsite. This could be followed upon by appointing someone to regularly
inspect the construction site, to undertake frequent conversations with the workers onsite
and to check the employment records. The contractor is therefore requested to:
Keep a record of the names and information of the laborers onsite;
Ensure that the workers’ age is compliant with the national labor law;
Ensure that the workers have received the trainings mentioned above;
Ensure that the workers are using the needed protective equipment and are following the
applicable safety procedures;
Ensure that the workers are receiving their wages and that a record of their payments is
being kept;
Ensure that the workers have access to water and proper sanitation facilities.
2.3 SUMMARY OF ENVIRONMENTAL AND SOCIAL LEGISLATIONS RELEVANT TO
WASTEWATER TREATMENT
The main Lebanese environmental and social legislations addressing wastewater
management is presented in the table below:
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Table 6: List of legislation relevant to the sub-project
Reference Date Description
Decree No.
8471/2012
12/07/2012 Environmental Compliance for Establishments Decree
According to this decree, industrial enterprises are required to carry
out an environmental audit (EA) including an Environmental
Management Plan (EMP) at the facility level and to execute the
required mitigation measures in order to be eligible to apply for the
Environmental Compliance Certificate (ECC).
The ECC is a three-year renewable certificate proving the
adherence of the industry to environmental standards and
application of an environmental management system.
Decision No.
52/1
29/07/1996 Environmental Quality standards for air, water and soil
The Decision sets the National Standards for Environmental
Quality (NSEQ) and the Environmental Limit Values (ELVs) for Air
and Water, as well as Maximum Permissible noise levels (Annex
10 of MOE Decision 1/52). It can be noted that the document
encompasses a wide scope of Standards set forth by MoE. The
following sections and tables relate most closely to the project at
hand:
- Annex 10: Maximum Permissible noise levels,
- Annex 14: Permissible Air Pollutant Content and Time of
Exposure.
Decision No.
8/1
01/03/2001 Air emission standards and wastewater discharge
The decision provides environmental limit values (ELVs) for
wastewater discharge into different receiving media (sewerage
system, surface water and sea).
It should be noted that the decision No. 8/1 presents an update of
some of the standards included in the previous decision No. 52/1.
The following sections and tables relate most closely to the WWTP
project :
- Table 2: New standards of Environmental Limit Values
(ELV) for wastewater discharge (into the sea, into surface
water, into the sewerage system) have been set.
Decision 29/1 2018 Work regulations for foreigners
Restricts a substantive number of jobs to Lebanese citizens in
order to protect the workforce and reduce unemployment. These
consist of all jobs practiced by Lebanese citizens include tiling,
plastering, gypsum board, iron, wood and aluminum profile
installation and other decorative tasks. Engineering is also
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restricted to Lebanese citizens.
On March 21, 2018, a clarification letter was issued by MoL
regarding Decision 29/1, which states that Syrians are allowed to
occupy jobs in the construction sector that are not restricted to the
Lebanese as per Decision 29/1 of 2018.
Abolishment of
article 522
2017 The Committee for Administration and Justice of the
Lebanese Parliament declares the abolition of Article 522 on
15 February 2017
Abolishment of article 522 of the Penal Code that exempts a rapist
from punishment if he marries his victim.
Decree 3791
(amending
Decree 7426 of
2012)
2016 Set and apply the official minimum wage for employees and
workers subject to the labor law and the cost of living ratio
Raises the minimum daily wage to US$20
Law 293 2014 Law on Protection of Women and Family Members from
Domestic Violence –
Advances women’s rights and safety. Establishes important
protection measures and related policing and court reforms, but
leaves women at risk of marital rape and other abuse
Decree 8987 2012 Forbids the employment of adolescents and children under 18
years of age in jobs that pose a risk to their health, safety and
behaviour
Decree 11802 2004 Organizing occupational safety, safety and health in all
institutions subject to labor law
Provides the general regulations for the prevention of occupational
hazards and accidents, and the promotion of health and safety in
all industrial establishments subject to the Labor Law. These cover
prevention and safety, occupational health, the safe use of
chemicals at work, as well as occupational noise standards
MoL Decision
49/1
1997 Abolition of child labour
Forbids the employment of adolescents and children under 18
years of age in non-industrial settings, unless a medical
examination proves them apt to perform such work.
Labor Law and
its updates
Amendment
Law 207
issued on 26th
May 2000
23/09/1946
Amendment
Law 207
passed in
26/05/2000
Sets the framework and rules governing the relationship between
employers and employees, including:
Minimum age of employment: 13 years (if the candidate is in
good health); subject to yearly medical examinations until the
age of 18.
Minimum age for employment in industrial workplaces and
tedious tasks and works requiring substantial physical effort, or
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those posing health risks: 15 years
Minimum age for employment on tasks and works that pose
risks or hazards to health and safety: 16 years
Employment record issued by the Ministry of Labor specific to
every employee, comprising name, nationality, employer name,
photograph, specialty, health consultations, and dates of
joining and leaving each establishment.
Working hours for employees under the age of 18 years: ≤6
hours, including a one-hour break following 4 continuous
working hours. Working hours must exclude the period
between 7:00 pm and 7:00 am.
Adolescent employees must be given a resting period of at
least 13 consecutive hours between two working shifts.
Overtime work and work during breaks, on weekends and
holidays are forbidden for adolescents.
Minimum vacation days for adolescents: 21 days following
employment for a complete year; 2/3 of which must be taken
continuously.
No gender discrimination is allowed in the workplace regarding
work type, remuneration, employment, promotion, training and
clothing. Employment of women in industrial settings and other
tedious and risky works is forbidden
The right of women for a paid maternity leave (10 weeks
according to the latest legislation)
It is forbidden to fire women during their maternity leave
Maximum weekly working hours: 48 hours with a 1-hour break
(mid-day)
Working hours can be reduced based on the level of physical
effort required by the job
Right of employees to a continuous 9-hour resting period
during a working day
The right of employees for a continuous 36-hour break every
week
The right of employees hired since at least 1 year to 15 days of
vacation per year, without the right of employers to fire
employees during their leave.
The right of employees to a paid occupational sick leave in case of
occupational accident, the duration of which varies based on the
case.
2.4 SCREENING OF THE PROJECT AND APPLICABLE WORLD BANK (WB)
SAFEGUARD POLICIES
The Environmental and Social Assessment Report (ESA) of the LEPAP includes specific
procedures for environmental assessment to be applied to activities and sub projects
planned, according to the importance of their environmental impacts and in accordance with
the safeguard policies of the World Bank mainly OP 4.01 on “Environmental Assessment”,
taking also into consideration the national EIA Decree No. 8633 of 2012.
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According to the LEPAP ESMF, an industrial WWTP containing non-hazardous materials is
considered as a category II sub-project and thus requires the preparation of an ESMP.
OP 4.01 is solely triggered among the World Bank’s Environmental and Social safeguards.
The implementation of the WWTP at Liban Lait is not expected to cause any physical or
economical displacement or lack of access to designated parks, therefore the Involuntary
Resettlement Policy OP 4.12 would not be triggered in this sub-project.
It is to be noted that the World Bank issued the World Bank Group Environmental, Health,
and Safety Guidelines (known as the "EHS Guidelines"). General EHS Guidelines contain
information on crosscutting environmental, health, and safety issues potentially applicable to
all industry sectors. General EHS guidelines related to wastewater and ambient water quality
along with the specific EHS for Dairy processing and for Metal, Plastic, and Rubber Products
Manufacturing.
The present ESMP is prepared in line with the relevant guidelines summarized here below:
In the context of their overall ESHS management system, facilities shall be implemented with
a vision to:
- Understand the quality, quantity, frequency and sources of liquid effluents in its
installations;
- Plan and implement the segregation of liquid effluents principally along industrial, utility,
sanitary, and stormwater categories, in order to limit the volume of water requiring
specialized treatment;
- Identify opportunities to prevent or reduce wastewater pollution through such measures
as input substitution, or process modification (e.g. change of technology or operating
conditions/modes);
- Assess compliance of their wastewater discharges with the applicable discharge
standards.
Process wastewater treatment standards shall also be consistent with applicable Industry
Sector EHS Guidelines, i.e., in this case, specific EHS for Dairy processing, and for Plastic
and Rubber Products Manufacturing.
The pollutant load of dairy effluent is primarily composed of significant organic content,
biochemical oxygen demand (BOD) and chemical oxygen demand (COD). Whey may also
contribute to high organic loads in wastewater. Salting activities during cheese production
may result in high salinity levels in wastewater. Wastewater may also contain acids, alkali,
and detergents with a number of active ingredients and disinfectants, including chlorine
compounds, hydrogen peroxide, and quaternary ammonia compounds. The wastewater may
have a significant microbiological load and may also contain pathogenic viruses and
bacteria. The following preventive management measures can be used to prevent the
contamination of the WW stream:
- Avoid milk, product, and by-product losses (e.g. from spills, leaks, excessive
changeovers, and shut downs) through the adoption of good manufacturing procedures
and facility maintenance;
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- Separate and collect product waste, including rinse waters and by-products, to facilitate
recycling or further processing for subsequent use, sale, or disposal (e.g. whey and
casein);
- Install grids to reduce or avoid the introduction of solid materials into the wastewater
drainage system;
- Process and foul drains should be separate in process areas and should discharge
directly to a treatment plant and/or municipal sewerage system;
- Pipes and tanks should be self–draining, with appropriate procedures for product
discharge prior to, or integral with, cleaning procedures;
- Subject to sanitary requirements, recycle process water including condensate from
evaporation processes, for preheating and heat-recovery systems for heating and
cooling processes, to minimize water and energy consumption;
- Adopt best-practice methods for facility cleaning, which may involve manual or
automated CIP systems, using approved chemicals and/or detergents with minimal
environmental impact and compatibility with subsequent wastewater treatment
processes.
Techniques for treating industrial process wastewater of the dairy sectors include flow and
load equalization; sedimentation for suspended solids reduction using clarifiers; biological
treatment, typically for the dairy WW : anaerobic followed by aerobic treatment, for reduction
of soluble organic matter (BOD); biological nutrient removal for reduction in nitrogen and
phosphorus; chlorination of effluent when disinfection is required; dewatering and disposal of
residuals;. Additional engineering controls may be required to contain and neutralize
nuisance odors. Grease traps, skimmers or oil water separators for separation of floatable
solids are specially adopted for the treatment of the food and beverages and dairy
processing wastewater; Source segregation and alternate treatment methods are typically
used for high salinity streams that contribute to elevated TDS levels in the wastewater,
specifically for the dairy effluents.
Process wastewater used in the plastic molding and forming processes can be subdivided
into three main categories: (1) cooling (or heating) water for plastics production; (2) surface
cleaning and wash water used both for plastics product surface cleaning and equipment
washing; and (3) finishing operation water to remove waste plastic material or to lubricate
the product. Cooling (and heating) water may be a source of thermal pollution if discharged.
Toxic pollutants potentially detectable in process wastewater discharged by contact cooling
and heating processes include phthalates (e.g. bis [2-ethylhexyl] phthalate [DEHP]).
Cleaning water may be characterized by significant levels of biochemical oxygen demand
(BOD5) and chemical oxygen demand (COD), total suspended solids (TSS), total organic
carbon (TOC), oil and grease, total phenols, and zinc. Finishing water may contain
significant levels of TSS and water soluble additives (e.g. phthalates).
Techniques for treating industrial process wastewater of the Plastic manufacturing sectors
include the installation of activated carbon process to remove soluble organics, including
phthalates (particularly important in manufacturing of plasticized PVC) and the recycling of
the process water through sedimentation / settling units and removal of the suspended
solids, oils and grease.
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Occupational health and safety hazards associated with dairy operations include:
Exposure to biological and microbiological agents may be associated with inhalation
and ingestion of dust and aerosols, particularly in milk powder operations. Dust from
the ingredients used in dairy processing and high levels of humidity may cause skin
irritation or other allergic reactions.
Exposure to chemicals (including gases and vapors) typically involves chemical-
handling activities related to cleaning operations and disinfection of process areas, in
addition to the maintenance of heating (thermal oils) and cooling systems (ammonia).
Workers at dairy processing facilities are exposed to heat from process activities and to
cold in refrigeration areas and rooms.
The main sources of noise in a dairy processing facility are centrifuges, homogenizers,
spray towers, and filling and packing machinery which are all typically located in
enclosed buildings.
The following are recommendations for the prevention and control of exposures to biological
hazards:
- Avoid dust- and aerosol-generating activities (e.g. use of compressed air or high-pressure
water for cleaning) and, where they cannot be avoided, provide proper ventilation of
enclosed or semi-enclosed areas to reduce or eliminate exposure to dust and aerosols;
- Install exhaust ventilation equipped with filters and / or cyclones, at sources of dust;
- Provide workers with PPE that is appropriate for the process activity;
- Ensure physical segregation of work and welfare facilities to maintain worker personal
hygiene;
- Avoid direct contact with non-conforming dairy products.
As for the physical hazards, the following additional industry specific recommendations are
presented here below:
- Provide workers with training in the proper use of equipment (including the proper use of
machine safety devices) and personal protective equipment (PPE), such as hearing
protection;
- Demarcate transport corridors and working areas and ensure the proper placement of
handrails on platforms, ladders, and stairs;
- Projects should try to reduce the number of accidents among project workers to a rate of
zero, especially accidents that could result in lost work time, different levels of disability,
or even fatalities. Facilities should also maintain a record of occupational accidents,
diseases, and dangerous occurrences and accidents.
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3 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN
Activity
Expected
Environmental and
social Impacts
Proposed Mitigation Measures
Cost associated
with
implementing
mitigation
measures
Period of
implementing
mitigation
measures
Responsibility for
implementing mitigation
measures
Construction / installation phase
Emissions from construction
equipment and vehicles
Air pollution Equipment and vehicles shall be regularly
maintained in line with manufacturers’
recommendations to minimize polluting
exhaust emissions.
All new equipment and vehicles shall meet
the relevant national regulations and WB
directives for emissions standards.
Vehicles and equipment shall be turned off
when not in use.
Construction equipment and vehicles shall be
monitored periodically to ensure they meet
the agreed standards.
Regular checkups and preventive
maintenance
Corrective maintenance
Minor / included in
construction costs
Weekly Construction contractor and
supervision consultant
Noise and vibration from
construction works and
equipment
Noise pollution and
vibration
Construction activities shall be limited to
normal daylight working hours. A works
schedule shall be followed and/or other
specific restrictions on works shall be
established.
Construction activities shall be limited to
Minor / included in
construction costs
Ongoing Construction contractor and
supervision consultant
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Activity
Expected
Environmental and
social Impacts
Proposed Mitigation Measures
Cost associated
with
implementing
mitigation
measures
Period of
implementing
mitigation
measures
Responsibility for
implementing mitigation
measures
permissible work hours in rural, residential
areas as per Annex 10 of MoE’s Decision No.
52/1
All construction equipment and vehicles shall
be in good working order and maintained in
line with manufacturers’ recommendations.
Noise control engineering techniques shall be
in use where practical i.e. the use of mufflers,
silencers, enclosures etc. Noise emissions
shall be monitored against set control targets
to meet required standards.
Spills from construction
vehicles and equipment
Soil and water
pollution
Stringent onsite pollution control measures
shall be applied to prevent soil and water
contamination from oil and fuel. Condition of
vehicles and equipment shall be periodically
checked. Equipment and vehicles shall be
regularly maintained in line with
manufacturers’ recommendations.
Any spills shall be contained and cleaned up.
All vehicles shall carry absorbing pads.
Protective equipment and trays shall be used
when refueling or changing oil on vehicles
and equipment.
Designated areas shall be defined for the
storage of fuel, lubricants, coolants, paint,
solvents etc.
Leakage detection system where needed;
Regular checkups and preventive
maintenance
Minor/ included in
construction costs
Ongoing Construction contractor and
supervision consultant
LEPAP Environmental and Social Management Plan
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33
February 2019
Activity
Expected
Environmental and
social Impacts
Proposed Mitigation Measures
Cost associated
with
implementing
mitigation
measures
Period of
implementing
mitigation
measures
Responsibility for
implementing mitigation
measures
Corrective maintenance;
Assigned personnel for emergency
situations
Waste generation from
construction activities
(including hazardous waste)
Soil and water
pollution
Proper waste collection and subsequent
disposal shall take place at Baalbeck landfill.
Hazardous wastes (oils and grease from
grease trap) shall be collected in closed
tanks, temporarily stored in the recycling area
and handed over to an authorized company
for final treatment/disposal.
Excavated materials will be transported for
disposal at Baalbeck Landfill
Minor/ included in
construction costs
Weekly Construction contractor and
supervision consultant
Disruption of existing
services from
implementation of drainage
and connection works
Interruption of
existing plant
operation
Contractors shall protect existing installations
and buildings from potential damage during
the execution of works. In the event of
damage, the contractor shall undertake
repairs
Minor/ included in
construction costs
Ongoing upon
occurrence
Construction contractor and
supervision consultant
Traffic Congestion Disruption, health
and safety impacts
as well as social and
economic impacts
Develop and implement a traffic management
plan
Erect road safety features
Included in
construction costs
Quarterly Construction contractor and
supervision consultant
Accidents from construction
activities
Construction health
and Safety
Health, safety and environmental regulations
shall be imposed on all employees and
workers of Liban Lait in addition to the
contractors workers
Minor/ included in
construction costs
Daily Libany Lait Management,
construction contractor and
supervision consultant
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
Activity
Expected
Environmental and
social Impacts
Proposed Mitigation Measures
Cost associated
with
implementing
mitigation
measures
Period of
implementing
mitigation
measures
Responsibility for
implementing mitigation
measures
Signature of an agreement between Liban
Lait and the contractor shall include the
enforcement of the environmental, health and
safety measures applied by the industry on
the contractors’ workers during the whole
construction works period
Provision of all necessary safety equipment,
fire protection measures and monitoring
instruments
Provision of PPE (helmets, boots, earplugs)
Provision of construction barriers and proper
warning signs
Properly labelling and storing chemicals
Properly rating electrical installations and
equipment
Emergency response plan shall be prepared
and implemented by Liban Lait
Absence of sanitation, social
and medical facilities and
services;
Construction
workers welfare /
workforce social
issues
Provision of good sanitation, social and
medical facilities and services including good
water and sanitation facilities;
Develop, implement and disseminate
occupational health and safety guidelines
Employ qualified fist aider and safety officer
First aid kits to be available on site for use by
the workers.
The GRM implemented by Liban Lait shall be
applicable to the contractor to help identify
and address potential problems during
Included in
construction costs
Continuous Construction contractor and
supervision consultant
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
Activity
Expected
Environmental and
social Impacts
Proposed Mitigation Measures
Cost associated
with
implementing
mitigation
measures
Period of
implementing
mitigation
measures
Responsibility for
implementing mitigation
measures
construction.
Employment Opportunities Implementing clear and transparent
procedures for recruitment of labor and
sourcing of goods and services will enhance
the positive impact.
Preference will be given to residents of local
communities, in the case of unskilled labor,
and preference given to local suppliers in the
case of goods and services.
Included in
construction costs
Quarterly Construction contractor and
supervision consultant
Social impacts Construction
workers welfare /
workforce social
issues
Keep an employment record by registering all
labors and workers involved in the
construction works on a daily basis by the site
operator. The following minimum information
shall be registered: Name, address, copy of
ID, …etc. in addition to keeping a record of
all the wage payments and hours worked for
each worker
Keep a record of all the injuries and accidents
on-site ;
Enforcement of the health and safety
measures
Application of the code of conduct for
contractors’ workers
Included in
construction costs
Daily Construction contractor and
Liban Lait
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
Operation phase
Treatment Efficiency and Effluent Quality
Wastewater collection
system
Soil and water
pollution
All sewers, collection channels and manholes
shall be kept watertight.
Ongoing inspection and maintenance of the
WCS shall be performed to monitor leaks,
pipe corrosion etc.
Included in O&M
costs
Weekly WWTP Operator
Discharge of effluent to
recipient water stream/ Litani
river and/or inefficient
WWTP operation
Water quality
degradation
WWTP will operate at optimum efficiency levels
commensurate with the design criteria and
required compliance. In case of emergency
conditions, special emergency actions shall be
taken as per the Emergency Response Plan in
Section 5 below in order to avoid release of
untreated effluent into natural recipients and
public sewer systems.
As addressed in the monitoring plan, effluent shall
be regularly monitored to ensure water quality
standards as prescribed by the Decree on
Conditions for Discharge of Wastewater into
Natural Recipients and Public Sewer Systems
(Decision No. 8/1).
An operation and maintenance manual and
related procedure shall be set and made available
by the supplier. The document shall target, at a
minimum, the following:
Operator and staff responsibilities;
Staff guidance for emergency situations;
Identification of MoE requirements and
the obligation to meet these
500,000 USD/year
200 USD/sample
Cost of trainings
and
documentation
included in the
supplier’s offer
Continuous
Monthly
Sampling: Regularly
as required by the
supplier and Bi-
annually by third
party
Training: Yearly
WWTP Operator, third party
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
requirements;
Operating procedures including a detailed
description of each major treatment
unit/process with relationship to related
units, safe operating procedure for normal
operation, including common operating
problems, safe operating procedures for
operating during emergency conditions,
and any fail-safe features;
A program of regularly scheduled
inspection and maintenance; and
An emergency plan
Filter backwashing Water pollution Backwash wastewater shall be recycled into the
system and treated
Included in
operation and
maintenance
costs
According to the
supplier’s
requirements
WWTP operator
Polymers Environmental
pollution
The polymers used during the treatment phase
shall be used in appropriate optimal dosage
commensurate with influent and effluent quality as
per supplier’s recommendations. The storage,
handling and disposal of waste shall be conducted
in line with the MSDS obligations.
Included in
operation and
maintenance
costs
Continuous WWTP Operator
Pump failure Outflow of
wastewater
To prevent the accidental flow of water from the
pumping station due to pump failure, spare pumps
shall be provided and installed
Spare parts costs
are included in the
supplier’s offer for
the first year.
3% annually
thereafter
During planning of
the project and
contract negotiations
with supplier
Liban Lait Management/
Maintenance team
Power outage Malfunctioning of
plant
In order to ensure that power is available to the
plant at all times, a UPS shall be put in place to
cater for the transitionary period between the
20,000 USD Continuous Liban Lait Management
/maintenance team
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
electrical outage and the operation of the
generator set.
Incident discharge of
operational wastewater to
surrounding area
Water quality
degradation
Implementation of a second feed tank of 5 m3
capacity to be used for storage in case of
spills / bad product production, etc.
Continuous analysis of the influent and
effluent quality in the on-site laboratory, as
addressed in the monitoring plan
Regular monitoring of sewer line and
manholes for visible leakages/ overflows
Immediate repair operation for the damaged
portion of sewer line
De-siltation of blocked sewers/ manholes with
sewage pumping machines storing and
disposal at appropriate refusal area after
treatment
Ensure proper covering of manhole and avoid
dumping of solid waste to prevent chocking of
sewer line
Included in the
supplier’s offer.
Continuous
As per the
monitoring plan
WWTP Operator
Solids Generation
Disposal of solids generated
at the screw presses and the
first wave steps
Soil and water
pollution (problems
arising due to bad
odour, insects,
polluted air, etc.)
The solids will be used for composting, which will
be undertaken on site. Safety procedures for
internal transportation and disposal shall be
established.
Included in
Operation and
maintenance
costs
Continuous WWTP Operator
Health and safety
Acute intoxication caused by
erroneous drinking of
untreated wastewater
Health and safety
hazard of WWTP
personnel
Take extreme care when handling the
polymers
Training and education programs shall be
organized for employees.
Included in O&M
costs
Training cost
Continuous WWTP Operator, Liban Lait
Management
LEPAP Environmental and Social Management Plan
Liban Lait
39
February 2019
Personnel of the WWTP shall undergo
periodical medical checks to ensure no
negative impacts arise from their employment
at the WWTP.
included as part of
supplier’s offer
Slips and falls on floors
made slippery by water, as
well as falls into ponds, pits,
or tanks causing injuries or
drowning
Health and safety
hazard of facility
personnel
Use safety shoes or boots with non-slip soles.
Training and education programs shall be
organized for employees.
60 USD /
Personnel Safety
shoes
Training cost
included as part of
supplier’s offer
Continuous WWTP Operator, Liban Lait
Management
Fire and explosions due to
the potential formation and
release of flammable gases
during processing (e.g., ,
hydrogen)
Health and safety
hazard for WWTP
personnel
Fire extinguishers of the “dry” type will be
provided in all buildings containing electro-
mechanical equipment and electrical
installations, which are in-line with applicable
standards.
Fire extinguishers and hoses shall be
regularly inspected by the fire department
An outdoor hydrant network will be
constructed at the plant, in accordance with
the appropriate regulations
5,000 USD During construction
and operation
Construction contractor /
maintenance team
Health and safety hazard:
airborne hazards not only
create unpleasant odors but
may also pose the risk
of respiratory and
gastrointestinal infections for
the operators
Social Impact
(Human Health
Cost)
Personnel of the WWTP shall undergo
periodical medical checks to ensure no
negative impacts arise from their employment
at the WWTP.
Training and education programs shall be
organized for employees.
Assigned personnel for emergency situations
Organization chart providing a list of relevant
personnel/people to contact in case of
emergencies with their respective phone
numbers. The chart should be easily
Included in O&M
costs
Continuous Liban Lait Management /
WWTP Operator
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
accessed by all staff/workers and available in
Arabic.
Social
Health benefits for the
general public from the
implementation of the
WWTP
Social Impact
Ensuring WWTP operation commensurate
with design criteria and required compliance
levels, ensures the targeted higher quality of
effluent discharged into receiving water
bodies, and thus increases health conditions
and improves quality of life to local residents.
Included in O&M
costs
Training cost
included as part of
supplier’s offer
Continuous Liban Lait Maintenance
Team / WWTP Operators
Socio-economic benefits Socio-economic
benefits
Support the project with awareness
campaigns and trainings on benefits of
composts and liquid fertilizers
Included in O&M
costs
Continuous Liban Lait Maintenance
Team
Complaints of people
affected by the WWTP
activities and operation
Social impact The internal GRM already available at Liban
Lait shall be enforced to ensure that the
workers’ rights are being protected.
Monthly follow-up, documentation and
monitoring of the internal GRM
The external GRM shall be further detailed to
include the following information:
departments and responsible entities,
timeline for each step of processing the
complaints, contact information
The external GRM shall be amended to allow
anonymous and oral complainants to be
submitted
The external GRM shall enforce the
documentation of all complaints submitted on
a monthly basis
Continuous Liban Lait Maintenance
Team
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
Post - Operation / Decommissioning phase
Transport, installation and
decommissioning of the
WWTP may pose potential
safety risks to local
communities and workers.
Technical and
Operational Impacts
/ Health and Safety
The responsible contractor(s) and sub-
contractor(s) shall submit closure plans for
approval before starting the decommissioning
works. In the closure and demolition of
abandoned facilities, any residual wastewater
or solids must be properly disposed.
Clear warning / danger signs shall be
installed to alert employees of Liban Lait of
decommissioning works.
Personal protective equipment shall be
provided to workers.
Safety management plan required to be
submitted by the contractor(s) and sub-
contractor(s), shall be implemented and
monitored for compliance during
decommissioning.
Workers shall undergo specific orientation
and regular training on safety during
decommissioning.
Included in
decommissioning
costs
Ongoing Decommissioning contractor
and supervision consultant
WWTP that is removed from
use may contain residual
wastewater. Abandoned
equipment from the WWTP
may pose physical risks to
humans who may come into
contact with them, along
with any number of long
term environmental risks,
risks to wildlife, regulatory
issues, and liabilities to the
owner.
Environmental /
Health and safety /
Social Impacts
Residual wastewater may often be
discharged to a nearby sanitary sewer, when
available; Alternatively, the responsible party
may hire a licensed wastewater hauler to
remove residual liquid wastes.
Solids shall be adequately collected and
disposed of in the solid waste management
facility operational and licensed for such
purposes at the time of decommissioning.
Tanks cannot be abandoned and shall be
either removed from site or filled in place
using an inert solid or other such approved fill
Included in
decommissioning
costs
Ongoing Decommissioning contractor
and supervision consultant
LEPAP Environmental and Social Management Plan
Liban Lait
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February 2019
material.
Left over polymers Environmental
Pollution
Left over polymers shall be removed from the
site. If possible, the responsible party could
arrange to return the polymers to the
manufacturer, or alternatively sell or give
them to a different WWTP to be used for their
intended purpose, or have them disposed of
properly.
Minor / Included in
Decommissioning
costs
Ongoing Decommissioning Contractor
and Supervision consultant
Noise and vibration from
demolition works and
equipment
Noise pollution and
vibration
Decommissioning activities shall be limited to
normal daylight working hours. A works
schedule shall be followed and/or other
specific restrictions on works shall be
established.
All construction equipment and vehicles shall
be in good working order and maintained in
line with manufacturers’ recommendations.
Noise control engineering techniques shall be
in use where practical i.e. the use of mufflers,
silencers, enclosures etc. Noise emissions
shall be monitored against set control targets
to meet required standards.
Minor / Included in
decommissioning
costs
Ongoing Decommissioning contractor
and supervision consultant
Introduced flora and weed
species
Environmental
Impact
Top-soiling and planting of the site with
native, locally sourced plants or grasses; and
/ or
Grading, levelling and re-contouring to ensure
no voids or uneven surfaces; and
Rendering the site safe for future land use.
Included in
Decommissioning
costs
Ongoing Decommissioning contractor
and supervision consultant
Emissions from
decommissioning equipment
Air pollution Equipment and vehicles shall be regularly
maintained in line with manufacturers’
Included in
Decommissioning
Ongoing Decommissioning Contractor
and supervision consultant
LEPAP Environmental and Social Management Plan
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February 2019
and vehicles recommendations to minimize polluting
exhaust emissions.
All new equipment and vehicles shall meet
the relevant national regulations and WB
directives for emissions standards.
Vehicles and equipment shall be turned off
when not in use.
Decommissioning equipment and vehicles
shall be monitored periodically to ensure they
meet the agreed standards.
costs
Waste generation from
decommissioning activities
(including hazardous waste)
Soil and water
pollution
Proper waste collection and subsequent
disposal shall take place at the solid waste
management facility operational and licensed
for such purposes at the time of
decommissioning.
Hazardous wastes (oils and grease from
grease trap) shall be collected in closed
tanks, temporarily stored in the recycling area
and handed over to an authorized company
for final treatment/disposal.
Minor/ Included in
decommissioning
costs
Weekly Decommissioning contractor
and supervision consultant
Disruption of existing
services from
implementation of drainage
and connection works
Interruption of
existing plant
operation
Contractors shall protect existing installations
and buildings from potential damage during
the execution of works. In the event of
damage, the contractor shall undertake
repairs
Minor/ Included in
decommissioning
costs
Ongoing upon
occurrence
Decommissioning contractor
and supervision consultant
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February 2019
4 ENVIRONMENTAL AND SOCIAL MONITORING PLAN
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
Construction / Installation phase
Air quality
Exhaust emissions from vehicles and
equipment
Level of dust (amounts of sediment
particles and airborne particles)
Working area Visual inspection,
Measurement
devices (if
needed)
Check vehicle and
equipment service
history
Once a week in the dry season
during construction, and after
complaints
300 USD/
Measurement
event
Construction contractor
Noise level Sensitive receptors in
the plant vicinity
Monitoring
through site
inspection and
measurement
devices
Regularly during construction,
as appropriate, or upon
complaints from citizens
300 USD/
Measurement
event
Construction contractor
Waste generation and management Working area Visual inspection,
disposal records
Regularly during construction,
as appropriate. Internal reports
on amounts and disposal
records to be prepared daily
and monthly
Included in
construction costs
Construction contractor
Water tightness Collectors, pipes and
WWTP facilities
Test certificate;
visual inspections
During construction Included in
construction costs
Construction contractor
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February 2019
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
Health and safety Working area Visual observation
and photographic
documentation.
Maintaining a
record
(documentation
and log) of injuries
and accidents
specifying cause
and location
description.
Maintaining a
record of all the
training activities
(and their
frequency) related
to health and
safety
Maintaining a
monthly record of
all the grievances
submitted by the
workers or the
affected
communities
Continuous, during
construction
Included in
construction costs
Construction contractor
Operation phase
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Liban Lait
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February 2019
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
Two types of wastewater monitoring are to
be implemented: (1) Internal, to ensure
good WWTP operation, as per supplier's
requirements, an (2) By third party, as
required for the MoE in order to confirm
compliance in terms of wastewater
discharge.
Wastewater chemical and physical
parameters:
Flow
Temperature
pH,
total suspended solids (TSS) (mg/l)
BOD5 (mg O2/L)
COD (mg O2/L)
total phosphorus concentration (mg
P/L)
total nitrogen concentration
total oil and grease concentration
(mg/L)
WWTP inlet and outlet Laboratory testing Regularly as required by the
supplier
Bi-annually by third party
Included in plant
operation
200 USD/sample
Liban Lait Management
and WWTP operator
and third party (needed
when reporting to MoE)
Liquid fertilizers quality:
regular quantity (m3 /d)
Total nitrogen concentration (mg N/kg
D.S.)
Total phosphorus concentration (mg
P/kg D.S.)
Total potassium concentration (mg
Second wave line Tests of quality of
the liquid
fertilizers
Visual observation
and photographic
documentation
Once per semester for all
analyses, except for total
heavy metals to be carried out
once per year
500 USD /
measurement
event
WWTP operator for
sampling/documentation
Third party for analysis
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Liban Lait
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February 2019
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
K/kg D.S.)
Maintaining a
record of type,
quantity, and
disposal location
of generated
liquid fertilizers
Once per month
Noise levels WWTP Boundary
sensitive receptors
Measurement
devices
Site inspection: once a month
Ad hoc monitoring to be
undertaken as appropriate
Testing: Once a year during
operation, baseline analysis
needed
300 USD /
Measurement
event
Liban Lait Management
WWTP operators
Compliance with legal regulations and
internal procedures for safe material
handling
On site Visual observation
and photographic
documentation
Maintaining a
record of injuries
and accidents
specifying cause
and location
description
Periodic Included in
operation costs
Liban Lait Management
and Maintenance /
WWTP operators
Health and safety Working area Maintaining a
monthly record of
all the grievances
submitted by the
Continuous, during operation Included in
operation costs
WWTP Operator
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February 2019
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
workers or the
affected
communities
Post Operation / Decommissioning phase
Air quality
Exhaust emissions from vehicles and
equipment
Level of dust (amounts of sediment
particles and airborne particles)
Working area Visual inspection,
Measurement
devices (if
needed)
Check vehicle and
equipment service
history
Once a week in the dry
season, and upon complaints
300 USD/
Measurement
event
Decommissioning
contractor
Noise level Sensitive receptors in
the plant vicinity
Monitoring
through site
inspection and
measurement
devices
Regularly, as appropriate, or
upon complaints from citizens
300 USD/
Measurement
event
Decommissioning
contractor
Waste generation and management Working area Visual inspection,
disposal records
Regularly, as appropriate.
Internal reports on amounts
and disposal records to be
prepared daily and monthly
Included in
decommissioning
costs
Decommissioning
contractor
Health and safety Working area Visual observation
and photographic
documentation.
Continuous, Included in
decommissioning
costs
Decommissioning
contractor
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February 2019
Monitoring Parameters Sampling Location
Type of
Monitoring
Equipment
Monitoring Frequency Estimated Cost Responsibility
Maintaining a
record of injuries
and accidents
specifying cause
and location
description.
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February 2019
5 EMERGENCY PREPAREDNESS AND RESPONSE PLAN
Monitoring efforts would be in vain in the absence of an organized record keeping practice. It
is normally the responsibility of the project administration (Liban Lait Management through
its Operation and Maintenance teams) to ensure development of a database that includes a
systematic tabulation of process indicators, performed computations, maintenance
schedules and logbook and process control/performance monitoring outcomes. Such a
historical database benefits both the project administrator and surrounding communities.
The project administrator should submit a semi-annual report to the assigned regional
authority, namely the Ministry of Environment (MoE) according to its requirements.
Contingency measures and plans in case of emergency have been addressed briefly
throughout this report, including namely:
- Stand-by equipment (pumps, dewatering equipment, etc.);
- Back-up power supply (electrical generators) maintaining the operation of the WWTP
in case of any local power failure;
- Overflows for WWTP in case of plant failure (at the various stages of treatment);
- Regular checkups and preventive maintenance;
- Corrective maintenance;
- Process operational procedures;
- Leakage detection system where needed;
- Firefighting system;
- Signs as needed;
- Ladders as needed;
- Personal Protective Equipment (PPE);
- Training of Personnel;
- Assigned personnel for emergency situations;
- Organization chart providing a list of relevant personnel/people to contact in case of
emergencies with their respective phone numbers. The chart should be easily
accessed by all staff/workers and available in Arabic.
Throughout the construction and operation of the project, the workforce is to be continuously
informed of any hazardous issue that may materialize during these periods. Moreover,
residents in the project area and relevant municipalities and authorities should in turn be
informed accordingly should a hazard persist during the operational period.
Stringent emergency procedures are to be assigned in the aim of intercepting any pollution
that may occur as a result of structural damage due to any natural disaster occurrences.
. As noted in the Environmental and Social Management Plan here above, an emergency
plan shall be included as part of the Operation and Maintenance Manual provided by the
supplier upon commissioning of the sub-project.
The emergency plan shall be designed to ensure effective operation of the treatment works
under emergency conditions, and shall consist, at a minimum, of the following elements:
LEPAP Environmental and Social Management Plan
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February 2019
- A vulnerability analysis which shall estimate the degree to which the treatment works
would be adversely affected by each type of emergency situation which could reasonably
be expected to occur, including but not limited to those emergencies caused by natural
disaster, civil disorder, strike, sabotage, faulty maintenance, negligent operation or
accident;
- The vulnerability analysis shall include, but is not limited to, an estimate of the effects of
such an emergency upon the following: (1) Power supply; (2) Communication; (3)
Equipment; (4) Supplies; (5) Personnel; (6) Security; and (7) Emergency procedures to be
followed.
- An evaluation of the possible adverse effects on public health and the environment due to
such an emergency; and
- An emergency operation plan for ensuring, to the maximum extent possible, uninterrupted
operation of the treatment works and a manual of procedures for the implementation of
such plan, including procedures for the notification of the MoE and municipal authority.
The plan and manual shall address each of the emergency situations described in the
vulnerability analysis.
A requirement should be set in the contract signed between Liban Lait and the supplier,
which requires the awarded contractor to perform regular and frequent maintenance
checkups of the facility.
These preventive measures and design considerations will ensure a continuous and
uninterrupted operation of the facility while catering for any potential environmental or social
adverse impact.
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February 2019
6 STAKEHOLDERS MEETING
A Consultation meeting for the Environmental and Social Management Plan of the WWTP
was held at Liban Lait, Hosh Sneid, on Wednesday 13 June 2018 in the presence of the
following attendees:
Table 7: List of Attendees of the Consultation meeting held at the Liban Lait
No. Institution Representative Mobile/Tel Email
1 Ministry of Industry Soha Yazbek 71-325002 [email protected]
2 Ministry of Environment Ebtihaj Abou Chakra 70-827011 [email protected]
3 American University of Beirut – Faculty of Agriculture
Mustapha Haidar 03-334319 [email protected]
4 Mayor of the Municipality of Brital
Ahmad Ismail 70-770999 [email protected]
5 Vice Mayor of the Municipality of Brital
Ali Abbas Younes 79-134692 -
6 Vice Mayor of the Municipality of Talia
Phillipe Abou Haidar 71-384837 -
7 Mayor of the Municipality of Hosh En Nabi
Fouad Saeed El Haj Hassan
70-147735 -
8 Owner of a nearby land Hassan Audi 71-642022 -
9 MOE/LEPAP Cynthia Kayem 76-301060 [email protected]
10 Liban Lait – General Manager Marc Waked 05-959444 [email protected]
111 Liban Lait – Plant Manager Anis El-Khatib 08-345230 [email protected]
12 Liban Lait – Agriculture Department Manager
Adnan Haj Hassan 03-203473 [email protected]
13 Liban Lait – Technical Manager
Hassan Jadel Aoun 03-961698 [email protected]
14 Local community representative
Rachid Al Halabi 71-379150 [email protected]
15 Local community representative
Obeida Seifeddine 03-021231 [email protected]
16 Liban Lait - Quality Assurance Ghenwa Haj Hassan 03-795907 [email protected]
17 Local community representative
Dominique Dandan 71-794104 [email protected]
18 Liban Lait – Senior HR Fatima Ghosn 70-988772 [email protected]
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Figure 12: Consultation meeting for the ESMP of the WWTP, Liban Lait, 13 June 2018
The meeting involved mainly the potential impacted stakeholders, whom are the mayors of
the Municipalities of the surrounding villages and an owner of nearby land, a representative
from the Ministry of Environment, the Ministry of Industry and the American University of
Beirut.
An invitation was sent to the Mayor of Hosh Sneid, the Ministry of Public Health, the Ministry
of Agriculture, the Governor of Baalbeck/Ministry of Interior and Municipalities, and the
neighboring military unit, however, they were not able to attend the meeting. The General
Manager of Liban Lait commited to share with them the PowerPoint presented during
meeting.
The ESMP of the WWTP planned for execution at Liban Lait was presented by Mrs. Cynthia
Kayem, the monitoring and evaluation officer at the LEPAP project, with specific emphasis
on the potential negative impacts of the WWTP and the planned mitigation measures during
the phases of construction, operation, and decommissioning.
The main concern of the attendees – especially of the Mayor of the Municipality of Hosh En
Nabi and the owner of the nearby land who seemed to be the most affected – was the odors
generated from the accumulation of untreated wastewater at Liban Lait, its negative impact
on the Litani River and on the health of the residents of the surrounding villages.
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In addition, Mr. Hassan Audi expressed his concern regarding the location of the current
screw press and the planned WWTP. He was specifically complaining about the odors and
the unpleasant view caused by the mentioned equipment.
Mrs. Kayem explained that the WWTP is not expected to generate any odors. Mrs. Ebtihaj
Abou Chacra, the representative of the MoE, explained that nor the MoE neither any other
institution can force Liban Lait to change the location of the sub-project. However, it is
obligatory for Liban Lait to ensure that no adverse impacts are caused to the neighboring
area. For that matter, it is mandatory for Liban Lait to undertake all needed measures to
reduce the impacts of the screw press and the WWTP on the landscape in the area. One of
the proposed actions was to request the industry to plant trees in a row next to Mr. Audi’s
land in a way that the screw press and the WWTP will be unseen. By the end of the
discussion, Mr. Audi was convinced of the proposed measures and asked Mr. Marc Waked,
the General Manager of Liban Lait, to commit to execute the actions agreed upon.
Mr. Waked reiterated on the importance of the WWTP implementation and pledged that
Liban Lait will execute and operate the sub-project taking all the concerns into consideration
and executing all mitigation measures as needed. The attendees were happy to know about
the plan of Liban Lait to implement a WWTP which will reduce the odors and have a positive
impact on the close by Litani River. They were very cooperative and understanding of the
period needed for the WWTP to start operating, and hence improve the surrounding air and
water quality. They also expressed their wish that other industries in the region would follow
the lead of Liban Lait and manage their wastewater properly.
The attendees expressed their content that mitigation measures were taken into
consideration and they were informed about the exact location of the WWTP within the
premises of Liban Lait.
Finally, Mrs. Cynthia Kayem highlighted that monitoring reports will be submitted regularly to
the MoE and accordingly the MoE and LEPAP team will be closely following up on the
construction and operation of the WWTP. Thus, the attendees can communicate any
concerns they have in the future by contacting Liban Lait directly or by referring to the
grievance mechanism of LEPAP.