PLAN

4800000206/004–Waste Management Plan for logistic

hub – back of house

Contents
1. Introduction ................................................................................................................................................... 6
2. Project Description ..................................................................................................................................... 6
3. Purposeandscope ........................................................................................................................................ 7
4. Waste Management System..................................................................................................................... 7
4.1. Waste Management Approach ....................................................................................................... 8
5. Legal Standards ......................................................................................................................................... 11
5.1. NEOM Standards and Reference ................................................................................................. 11
5.2. License Requirements .................................................................................................................... 11
6. RolesandResponsibilities ...................................................................................................................... 11
6.1. Project Manager ................................................................................................................................ 12
6.2. Construction Manager .................................................................................................................... 12
6.3. Environmental Manager(AlsoActasWasteManagement Manager)............................... 12
6.4. Environmental Coordinator ......................................................................................................... 13
6.5. Environmental Engineer(Sindalah Island) ............................................................................. 13
6.6. Environmental Inspector............................................................................................................... 13
6.7. Environmental Engineer(UAH Area) ........................................................................................ 14
6.8. Environmental Officer(Marine) .................................................................................................. 14
6.9. ProtectedSpeciesobserver ............................................................................................................ 14
6.10. Waste Management Foreman.................................................................................................. 15
6.11. Waste Management Operatives .............................................................................................. 15
6.12. AllPersonson site .......................................................................................................................... 15
6.13. Organization Chart....................................................................................................................... 16
7. Waste Management Program .............................................................................................................. 16
7.1. Waste Management Resources ................................................................................................... 16
7.2. Program Monitoring ........................................................................................................................ 16
7.3. Waste Management Awareness & Training ........................................................................... 16
7.1.1. Site Induction ...................................................................................................................................... 17
7.1.2. Environmental and Social Training for MHC Leadership Team...................................... 18
7.1.3. Environmental Training for Construction Supervisors ...................................................... 18
7.1.4. Toolbox Talks ...................................................................................................................................... 18
7.2. Trainingprogramme ........................................................................................................................ 19
8. Environmental Impacts .......................................................................................................................... 20
 9. Waste Types /Classification and Projected Quantities........................................................ 20
9.1. Non-hazardous Waste .................................................................................................................... 20
9.2. Hazardous Waste .............................................................................................................................. 21
10. Waste Management Measures ......................................................................................................... 25
10.1. General Refuse and Other Wastes ......................................................................................... 26
10.2. Recycling .......................................................................................................................................... 27
10.3. On-site Sorting, Storage and Disposal of CONSTRUCTION Materials ...................... 27
10.3.1. Excavated Materials ....................................................................................................................... 27
10.3.2. Construction and Demolition Materials ................................................................................. 27
10.3.3. Chemical Waste ............................................................................................................................... 28
10.3.4. General Refuse ................................................................................................................................. 29
10.3.5. Waste Containers ............................................................................................................................ 30
10.3.6. Sewage storage, collection and disposal ................................................................................ 30
10.3.7. Medical Waste .................................................................................................................................. 31
10.4. Central Waste Storage Location ............................................................................................. 31
10.5. Hazardous Waste Storage Location ...................................................................................... 32
10.6. Waste Management Resources ............................................................................................... 33
10.7. Waste Management Service Provider .................................................................................. 33
10.8. Waste Spill Prevention and Response .................................................................................. 43
10.8.1. Spill Prevention .......................................................................................................................... 43
10.8.2. Spill Response ............................................................................................................................. 45
11. Records Management .......................................................................................................................... 46
12. Monitoring ............................................................................................................................................... 46
13. Reporting ................................................................................................................................................. 47
14. Performance Monitoring .................................................................................................................... 48
Appendix ........................................................................................................................................................... 50
15.1. Site Mobilization Plan –Showing Waste Management Facility ................................... 50
15.2. Waste Manifest .............................................................................................................................. 51
15.3. Waste Management Logbook .................................................................................................. 52
15.4. Waste Management Inspection Checklist ........................................................................... 53
15.5. Environmental Incident Notification .................................................................................... 54
15.6. Hazardous Material Compatibility Storage Matrix.......................................................... 56
15.7. Hazardous Material Incompatibility Matrix ...................................................................... 57
15.8. Proposed Waste Storage Bins, Skips, Containers ............................................................ 58
15.9. Sample Slogans for Environmental Awareness ................................................................ 59
1. Introduction
Sindalah Island represents one of the icons of NEOM with exceptional marine characteristics and
beauty. At an overall distance of 2.0 km in east-west direction and an overall distance of 0.7 km
in the north-south direction, the island amounts to a total land area of approximately 840,000.00
m2. The island is located approximately 5.0 km fromthe mainland of Saudi-Arabia and can be
accessed with ease via water transportation, refer to Figure 1.

Sindalah Island is located approximately 3 km from the land and sits at an average of 4m above
sea level, with a maximum elevation of 23m. Travel time between the mainland and Sindalah
Island is approximately 15 minutes by boat.

Figure1– Location of Islands

Figure2–Sindalah Island Location

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This Scope of Work covers for the Sindalah Island Back of House Logistics Hub and other associated works, located in
Cluster 6.

Scope of work
The Contractor shall provide the following, but is not limited to:
a. The Contractor shall immediately commence Procurement of all components required for the Works and
adhere to the interim milestones in Part 6 of this Scope of Works for placing Purchase Orders and Long
Lead Item Purchase Orders.
b. The Contractor shall prepare a grass nursery to receive the stripped Bermuda golf course grass off Hole
#4 of the Sindalah Golf Course where the Back of House Logistics Hub is located.
c. The Contractor shall strip, collect, transport, place at nursery and maintain all Bermuda fairway grass
required to be removed for the Construction of the Back of House Hub.
d. The stripped Bermuda grass will be reused in the future to recover the stripped area at Hole #4 of the
Sindalah Island Golf Course.
e. The Contractor shall remove, transport, store and return all capping sands required to be removed during
the Works.
f. The Contractor shall return all existing dun escapes and landscaping to its original condition if during the
Works such dun escapes or landscaping it altered for enabling of the Works such as access and crane age.
g. The Contractor shall execute all required utility diversions, inclusive of but not limited to irrigation lines,
main water lines, manholes, utility corridor utility network and all other existing services required to be
diverted to enable the Construction of the Back of House Logistics Hub.
h. The Contractor shall ensure that the Golf Course irrigation and drainage systems are fully functional and
uninterrupted 24/7 during the Works.
i. The Contractor shall set out the Back of House Logistics Hub, pins or similar are to be used with flags
indicating cut levels and existing ground levels.
j. The Contractor shall execute all Earthworks required for the construction of the Back of House Logistics Hub.
k. The Contractor will be responsible for and shall execute all required Geotechnical, Topographical and
Bathymetrical site studies.

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m. The Contractor shall ensure that all excavations and slopes are suitably protected, benched or
supported with shoring systems to control any risk of earthwork collapse and to protect the
integrity of the road adjacent to the Back of House excavation and all existing utilities lines and
manholes.
n. The Contractor must ensure that there shall be no discharge or run-off of water or solids to the
ocean ecosystems at any time during the execution of the Works.
o. The Contractor shall execute all Structural, Mechanical, Electrical, Plumbing, Heating, Ventilation
and Air Conditioning (HVAC) Works.
p. The Contractor shall construct all MEP shafts, stairways, pavements, ramps and tie in of ramps to
the Utility Corridor roadway.
q. The Contractor shall construct all necessary retaining walls and ensure timely mobilization of all
temporary works and temporary works design certificates and check certificates.
r. The Contractor shall execute all pavement works associated with the Back of House Logistics Hub.
s. The Contractor shall execute all tunnel/underpass works associated with the Back of House Logistics Hub.
t. The Contractor shall execute all Landscaping and hardscaping Works for the Back of House Logistics Hub.
u. The Contractor shall execute the Works in accordance with the Stage 3D IFC Design Package for
the Back of House Logistics Hub.
v. The Contractor shall prepare equipped site offices at UAH for the works if required by Employer.
w. The Contractor shall provide the material submittals based on the project specification/contract
drawings, shop drawings and a detailed construction schedule along with PQD, PQP, PSP, PEP, HSE,
for approval prior of commence construction works at site.
x. The Contractor shall construct all structural steelworks elements including but not limited to
vertical structural steel work elements & horizontal structural steelwork elements with all
accessories based on Project specifications / Contract drawings and International agreed codes.
y. The contractor shall carry out the steel work protection coating application to cover the fire
protection as well as the corrosion resistance throughout the horizontal and vertical structure
elements based on Project specifications and International agreed codes.
z. The contractor shall construct the precast structural concrete elements, cementitious grouting
and Cast-In-Place concrete structural elements based on project specification, Contract drawings
and codes.
aa. The Contractor should present the mix design submittal for approval prior to cast both Precast and
Cast in-situ concrete elements The Contractor shall ensure upon approval of the mix design for
every concrete mix that trial mixes are immediately arranged within 24 hours to be attended by
the Project Management Consultant and NEOM ETSD.
bb. The Contractor is responsible for all the lifting and transporting arrangement of the precast
concrete elements and to ensure all materials are installed in site in good condition.
cc. Contractor shall make coordination between all the disciplines to prepare the coordinated
drawings in prior to construction.
dd. The Contractor has no exclusive rights to any part of the Sindalah Island Project and must
safeguard their own works with suitable levels of supervision and security.
ee. The Contract shall liaise with all past, current, and future Contractors during the execution of the
Works in order to avoid any delays and co-ordinate and agree sequence of the Works to avoid
any delays.
 Figure 1.3 Sindalah Island–Indicative Renders for the Back of House Logistics Hub
The Construction waste generated during Construction activities on Sindalah Island has been
identified as one of the major environmental issues. During the project Construction,
development, and restoration activities, most of the Construction waste generated will be
unused building materials. The Construction waste consists of materials damaged during
Construction or left unused, such as bricks, concrete, and wood.

Construction waste impacts the environment in many different ways, including soil
contamination, water pollution, and damage to the landscape. Moreover, Construction waste
contributes to increased Construction costs due to the need to replace waste materials.
2. Purpose and scope
MHC is legally and socially responsible for the reduction and management of waste
generated during Construction of Logistic Hub Project. The WMP plan has been
developed to meet these obligations and complement the overarching NEOM
Environmental Standards.

The Objective of WMP is to

• Facilitate compliance with relevant Saudi government waste management

regulations and NEOM and international Standards
• Provide framework to properly manage waste generated from Sindalah Island
Development activities
• Implement waste management hierarch to avoid, reduce, recycle, treat and
dispose the waste
• Minimize risk of causing impact on environment that may arise due to improper
waste management
• Engages take holder subtilize appropriate waste management and disposal
services
• Develop site specific and activity specific waste management procedures during
project timeline

The WMP provides an overview of strategy, method sand control supplemented by MHC to
manage the waste generated from Sindalah Construction site, this WMP shall

• Identify types waste generated at Construction site

• Describe waste management framework

3. Waste Management System

The NEOM Waste Management Procedure adapted by MHC outlines the following waste
management objective sand guiding principles which has been considered throughout
this WMP
 Waste Minimization:

 To assists contractors in planning for suitable waste management by developing

Waste Management Plan
 To minimize resource requirements and Construction waste through reuse,
recycle and efficient selection and use of resources.
 To maximize reuse and recycling of waste

Waste Management:

 To develop systems of waste management that ensures waste is transported and

disposed in law full manner
 To provide guidance in regards to space, storage all torments, amenity and
management of waste storage facility.
 To ensure waste management systems are compatible with collection services.
 To minimize risks associated with waste management at all stages

4.1. Waste Management Approach

The waste management approach follows Deming’s cycle of Plan-Do-Check-Act(PDCA)

1. Plan: Prepare how to implement program – Clarify the objectives and decide on the
control items – set measurable target and decide on the methods to be used to achieve
targets.
2. Do: Study and train in the methods to be used, utilize the method and collect the
measurable data for decision making
3. Check: Review the results of activities and achievements – check whether the results
of the implementation have been performed according to the plan, if the results are
promising standardize the plan and continue implementation, if results are poor re-
plan and develop the action plan and repeat the cycle
4. Act: Take counter measures based on the review and check-If the result so
implementation deviate from the plan or standard, take action to correct this - If an
abnormal result has been obtained, investigate the reason for it and take action to
prevent it recurring - Improve working system and methods. The below diagram
explains the PDCA cycle.
MHC’s Environmental Policy
5. Legal Standards

The following legislation, policies and guidelines are applicable to the appropriate
function in gand management of waste generated at Sindalah development site.
These documents have been referred in preparation of WMP.
 Code of Construction Safety Practice, KSA local Municipality.
 ISO14001:2015 Environmental Management System
 Ministry of Municipal and Rural Affairs(MOMRA)
 IFC General EHS guidelines–1.6waste management
 National Legislation - General Environmental Regulations (GER) and the
Rules for Implementation (Presidency of Meteorology and Environment,
2001) as per Article13
 Environmental standards in support of the aims of the GER(published2012-2014)
 Saudi Arabia International and Regional Commitments
 International Good Practice standards and guidelines

5.1. NEOM Standards and Reference

 NEOM-NEV-PRC-706-WasteManagementProcedure
 2021-01-18_BDC_NEOM_TREP_SindalahIsland_EarlyWorks_ESMP_Rev06
 NEOM-NEV-STD-304-
01.01_InterimRestrictedMaterialsStandard_Rev01.01_issued27Aug2020
 NEOM-NEV-TGD-702-EnvironmentalandSocialCodesOfPracticeForConstruction

5.2. License Requirements

 MHC Shall contract with waste management contractor registered with
GAMEP and approved by NEOM and Local municipality
 MHC shall contract with a hazardous waste management & transport
company that has permit to transport hazardous waste and have
access to a licensed hazardous waste management facility
 MHC Shall contract with medical waste management company to
treat and dispose infectious waste generated from UAH camp.
6. Roles and Responsibilities
This WMP must be implemented by the MHC with oversight from NEOM and
AECOM as follows:

 Site waste management need saread equately identified.

 Suitable waste management facilities approved by NEOM /PMC are
established at site.
  Adequate number of equipment is available for waste collection and storage
 Waste management plan is effectively implemented at site.
 Any waste removed from site quantified, recorded and reported to Proponent
Environmental Consultant (PEC)/ Project Management Consultant (PMC).

MHC will carry out Construction activities, under the supervision of NEOM & consultant
AECOM. The MHC have obligations under KSA’s environmental laws and under its contract
with NEOM. The responsibility for implementation of this WMP rests with the MHC and its
subcontractors.

MHC will:
• Assign responsibilities to individuals within their project teams to facilitate the
implementation of the WMP and allow for effective communication between
NEOM/AECOM project management and the environmental management roles
within their project teams;
• Develop a site specific WMP compliant with NEOM Waste Management Guidelines;
• Have their WMP as well as their quality assurance processes approved by NEOM prior
to commencement of Construction; and
• Provide project personnel and workers with appropriate training to implement and
monitor implementation of the site-specific WMP
6.2. Project Manager
• Reviews and approves the present procedure and provides support and leadership
in promoting its implementation;
• Ensures sufficient resources (human, financial, equipment) are made available for
the proper implementation of and abidance to the measures contained therein.

6.3. Construction Manager

• Has the primary responsibility for ensuring the requirements of this plan are properly
implemented in all project areas;
• Ensures the Construction staff is adequately aware of the measures of the waste
management procedure, all work force passed induction and everyone work
according to statutory requirements;
• Participates directly in the review of Risk Assessment and Method Statement, and of
the documentation submitted by Subcontractors.

6.4. Environmental Manager (Also Acts Waste Management Manager)

• Drafts and reviews the present document before its submittal for approval, and
ensures its proper distribution to all concerned parties after PM approval;
• Holds a briefing (directly or through personnel on his behalf) with all interested
management and staff, to ensure they are properly aware of the measures therein,
 and ensures that measures of this document are included in relevant training and
awareness programs;
• Verifies compliance with this plan through regular inspections and audits carried out
by Environment Manager, AECOM / NEOM, and refers to PM any deviation to take
appropriate corrective/disciplinary measures; Facilitates the arrangement of third-
party qualification training and required inspections;
• Provides his assistance in the implementation of the plan, acting as an advisor as
needed and required, to ensure workplaces meet the requirements set forth in the
document;
• Promotes campaigns and/or similar activities to promote and spread awareness
concerning waste management requirements in the Project.
• Prepare Environmental risk assessment and review the Safe Work Method
Statements prepared by the Construction.
• Ensure that waste management service providers have appropriate licenses.
• Ensure all people working for waste management at site have appropriate training as
per WMP.
• Maintain waste register with type of waste and quantity generated and disposed,
treated and reused at a site.

6.5. Environmental Supervisor

• Assist Environmental Manager waste management program implementation.
• Regularly perform environmental compliance site visits and record in
environmental registry and follow-up with field staff to close the observations
• Assist Environmental Manager in preparing daily, weekly and monthly reports
• Compilation and field data for reports.
• Coordinate with field staff to implement scheduled field activities
• Coordinate with environmental manager and consultant to close observations and
incidents
• Organize training programs, toolbox talks, Environmental Drills, and Environmental
campaign.
• Daily work site inspections and close observations in coordination with
Construction team.
• Monitor to segregate waste at source and check proper housekeeping is maintained
at worksite.
• Collect daily waste data and filed observation related to waste management and
submit to environmental manager for records and reporting.
  Monitor the waste storage are as in coordination with Construction team.
 Daily checks at working sites and shorelines and waste storage areas for proper
storage, avoid leakages at site.
 Monitor any hazardous waste generated due emergency maintenance activities at site
to transport and dispose at designated location at UAH. 
Coordinate to keep all required resources to execute waste management activities at
Sindalah.

Waste Management Foreman

• Foreman will report directly to Environmental Supervisor, coordinate waste
management activities at Sindalah Island.
• Implement daily waste management activities with allotted team of operatives
• Assist environmental supervisor in closing observations and in any emergency
situations.
• Implement waste collection operations as per designed schedule.

6.6. Waste Management Operatives

• Collect and empty waste bins outside residential cabins, offices, messhall, recreation
area and other designated areas.
• Replace the bin liners with 120 gallon bags in each of the240 litterbins.
• Follow safety procedure on handling of waste by proper segregation of waste,
wearing appropriate Personal Protective Equipment.
• Inform foreman of any suspicious site and environmental heritage items
immediately.
• Attend all tool box and training programs conducted by the MHC.
• Perform any other duties assigned by waste management foreman.

6.7. All Persons on site

All persons on site are responsible for:

• Understand fully and apply correctly this plan in the course of their work.
• Strictly abiding to the instructions described in this document and those provided by
their direct site managers/supervisors;
• Every worker will report to his supervisor any possible anomaly regarding working
procedures;
• All employees are expected to study, understand and comply with these rules and
regulations regarding waste management/handling. No one can plead ignorance of
the same.
• Everyone is required to read all notices appearing on the bulletin boards and to attend
toolbox talks and safety awareness course, and will be responsible for any matter
appearing in such notices, which may concern them.
6.8. Organization Chart
 7. Waste Management Program
7.1. Waste Management Resources
MHC have allotted different types of waste collection bins in sizes and quantity,
transport within site and manpower required for environmental activities at site.

7.2. Program Monitoring

The MHC Environmental Supervisor periodically monitors site and Construction activities
through data collection and plans to forecast for future requirements.

7.3. Waste Management Awareness & Training

The main objective of the environmental awareness and training program is to ensure that
all personnel involved in Construction site at Sindalah Island development works are aware
of their individual responsibilities. Additional to MHC specific HSE training and induction
programs for all staff will be provided as needed. Specific training components will focus on
receptor awareness and sensitivities. The need for follow-up training will be based on the
incidences of NCRs documented in the environmental monitoring reports.

Training and competence are essential to the effective implementation of WMP. Training and
competencies must be split to reflect competency requirements for designers, managers,
engineers and workers. Training materials will be submitted to NEOM for review and
approval to ensure its adequacy.

The Environmental Manager will establish the Environmental/Social training schedule, and must be
responsible for:
 • The development of training materials or the oversight of the preparation of such
material by a competent person in order to effectively conduct environmental and
social training;
• Development of an environmental and social training program;
• Thepreparationandupdatingofthescheduleforenvironmentalandsocialtraining;
• Carrying out environmental and social training for site personnel in
accordance with this procedure;
• Training the sub-contractor’s nominated trainers; and
• The collation and retention of training records.

All site personnel must attend and participate in the scheduled training sessions, as
applicable. Arrangements will be made which allows the MHC to identify each individual who
has successfully completed the required training. Those who cannot be identified must not
be allowed to work on site.

Arrangements will also be made to ensure that, at the start of each week’s work, all workers
participate in a toolbox talk with their supervisor. Records will be kept for auditing purposes.
Guidance on how to present the talks will be prepared by the Environmental Manager and
issued to those giving the talk.

7.1.1. Site Induction

All MHC employees and sub-contractors must be inducted prior to commencing work on the
site. The environmental and social component of the induction will be conducted by
Environmental Manager / Environmental Supervisor and will focus on the role of the CESMP
in achieving good environmental performance. As a minimum, this training will include the
following topics:

• MHC Environmental and Social Policy and Environmental Management System;

• Legal requirements and other site-specific obligations as they apply to emissions,
discharges and wastes handling;
• The key environmental aspects identified for the works such as air emissions, dust,
hazardous materials handling, waste management, housekeeping, spill prevention
and incident management, energy and resource usage and excessive noise generation
and their associated impacts;
• Addressinggrievancesfromworkersandotherapplicablestakeholderinaccordancewit
hthe MHC approved grievance redress mechanism;
• Summary of the measures and practices to be followed to minimize environmental
and social impacts;
• Roles and responsibilities of key personnel for environmental and social matters; and
Potential emergencies and how to respond to them.

The induction training will be conducted by Environmental Manager & Environmental

Supervisor. The training will have visual presentations, discussions and will be conducted in
English, Arabic, and Hindi as required. Assigned record of each induction must be maintained
on site.
7.1.2. Environmental and Social Training or MHC Leadership Team
Waste Management programs objectives and expectations training must be provided for
MHC leadership team involved in project activities. This training will include topics related
to overall project waste management and sustainability goals, site environmental controls
measures that will be implemented and reporting program in addition to general site and
project environmental requirements.

7.1.3. Environmental Training for Construction Supervisors

All site supervisors who oversee Construction activities and activities with relatively
higherpotentialforenvironmentalimpactsduetoimproperhandlingofwasteorincidentsmustb
eprovidedwithspecifictrainingtounderstandthewastemanagementprocedurerequirementsa
ndgood site practices. As a minimum, the training must include:

• Chemicals/Fuel/Hazardous materials storage and handling, and spill response;

• Waste Management (including sewage and other wastewater); and
• Housekeeping at work sites
• Proper segregation and waste storage

7.1.4. Toolbox Talks

Toolbox Talks (TBTs) or environmental briefings related to project task-specific
environmental aspects will be given to concerned employees undertaking such tasks where
required to assist personnel to carry out their required tasks. This training will be carried
out by the HSE (Health, Safety and Environment) team.

TBTs will be conducted with the employees carrying out the work during the project on
various aspects of the Waste Management Program and control measures that may be
required for particular Construction activities. They will be carried out on a daily basis,
before the commencement of site activities.

Additional TBTs will be given where a particular environmental issue has been identified as
a problem during site inspections or audits. The following topics will be covered for TBTs.
• Hazardous substances handling;
• Waste management;
• Spill control and emergency response;
• Refueling;
• Waste water handling;
• Incident reporting;
• Effect of Waste Spills on Island and Marine Fauna
7.2. Training program

Table7-1TrainingProgram

SNO Item Description Who will Proposed

Attend timeoftraining
1 Waste 1. Logistic Hub proposed Site Managers January
Management waste management Line Managers 08/01/ 24
program program overview Engineers
objectives & 2. Program objectives3.
implementation Waste management
program requirements
5.Responsibilities
6.Monitoring & Reporting
2 Waste 1. WMP implementation Site January
Management process Supervisors 08/01/ 24
Program 2. individual Foreman
Activities responsibilities at site
3. Program
expectations
4. Emergency response
5. Spill Control
6.Supervision and
reporting
3 Expectations from 1.Logistic Hub project Contractor Site Induction
Contractor rules and regulations employees
2. Expectations from
contractor
3. Waste Manifest
4. Health and Safety
4 Waste 1. Waste Segregation Waste Weekly
Management 2. Waste types and Management
Toolbox Talk disposal Operatives
3. Only place waste in
designated Container Skilled and
4. Never mix general waste Unskilled
and hazardous waste Operatives
5. Spill Response
procedures
6. Material Storage
7. Clean and Tidy
8. Housekeeping at
working site
9. Health and Safety
8. Environmental Impacts
Sindalah Island Development Construction activities have created significant environmental
impacts as a result of waste spills. Here is a list of impacts that have been found in the
ESIAstudy.

Impact ID Description Impact

Significance
SG003 Impacts upon soil and ground water resources from Low
The storage of hazardous materials (including
the CSD refueling station)
SG004 Removal of existing sewage system, causing Low
discharge of raw or partially treated sewage into
soil and ground water resources
WM001 Wind-blown litter entering the wider general Medium
environment.
WM002 Poor waste management and housekeeping Medium
Practices leading to impacts on ecology,
contamination, visual appearance.
WM003 Unregulated dumping of waste due to lack of Medium
licensed facilities within project area
WM004 Reduction of landfill life span at municipal dumps Medium
due to addition of Early Works Phase waste load.
WM005 Poor waste management upon vessels causing Medium
Damage to multiple receptors

A total of five impacts were identified in the ESIA study at medium significance, and if the
appropriate waste management measures were applied, these impacts would below-level.

9. Waste Types/ Classification and Projected Quantities

9.1. Non-hazardous Waste
Kitchen waste:

The Organic waste is generated from the kitchen and mess hall located in UAH camp, this
waste from kitchen and mess hall collected in skip and transferred to central waste storage
area for disposal by registered contractor.

Camp management operatives collect general waste along with food waste from the cabins
in UAH camp, as well as from transport ships, the dredger and Sindalah Island, which is
temporarily stored in CWS area.
Mixed waste from Construction site:

There may be rocks during excavation due to the rocky earth profile of the island, which will
be pile data designated location and reused within the site or exported to camp.

During the Construction phase there may be a surplus of materials, such as timber off-cuts,
broken concrete blocks, plastics, HDPE pipe off cuts, metals generated. There may also be
excess concrete during Construction which will need to be disposed of. Plastic and cardboard
waste from packaging and over supply of materials will also be generated. Waste will also be
generated from Construction workers e.g. organic/food waste, dry mixed recyclables
(wastepaper, newspaper, plastic bottles, packaging, aluminum cans, tins and cartons), mixed
non-recyclables and potentially sewage sludge from temporary welfare facilities (UAH
Camp) provided on site during the Construction phase. Waste printer/toner cartridges,
waste electrical and electronic equipment (WEEE) and waste batteries may also be
generated in frequently from site offices.

9.2. Hazardous Waste

Contaminated soil

 Construction operations or oil spills will result in a negligible amount of contaminated soil

Fuel sand Oil

 Fuel/oil storage, storage tanks and oil draw-offs will be bunded (or stored in
double-skinned tanks) and in a dedicated, secure area on site. If the protocols are
adhered to and crew members are trained in proper refueling techniques, there
should be no fuel or oil waste at the site.

Other Hazardous Waste

 Paints, glues, adhesives will generally be present in small volumes only and
associated waste volumes generated will be kept to a minimum.
 WEEE (containing hazardous components), printer toner/cartridges, batteries
(Lead, Ni-Cd or Mercury) and/or fluorescent tubes and other mercury containing
waste may be generated during Construction activities.
 Following Table give details of waste types expected from Sindalah Logistic
Hub Construction Activities
Table9-1ExpectedwastetypesfromSindalahGolfCourseConstructionactivities

Waste Category Waste Sub-Category Classification

Construction Waste
Concrete, bricks, tiles Concrete, bricks, tiles Non -
and ceramics and ceramics Hazardous
Concrete
Mixtures of, or separate fractions Hazardous
of concrete, bricks, tiles and
ceramics containing hazardous
substances (e.g.
hydraulic fluids, used oil, chemical
materials, bitumen, etc.)
Mixtures of concrete, bricks, tiles Non –
and Hazardous
Ceramics not containing
hazardous materials
Wood, glass and plastic Wood, glass and plastics Non–
Hazardous
Glass, plastic and wood containing Hazardous
or
Contaminated with
hazardous substances
Bituminous mixtures, Bituminous mixtures containing Hazardous
coal tar and tarred coal tar
products Bituminous mixtures not Non-Hazardous
containing coal tar
Coal tar and tarred products Hazardous
Metals (including their Copper, bronze, brass, aluminum, Non-Hazardous
alloys) lead,
zinc, iron, steel and tin
Mixed metals Non-Hazardous
Metal waste contaminated with Non-Hazardous
hazardous substances
Cables containing oil, coal tar and Non-Hazardous
other hazardous substances
Cables other than those containing Hazardous
hazardous substances
Soil (including Soil and stones containing
hazardous
excavated soil from contaminated Substances
sites),
Soil and stones not containing Non-Hazardous
stones and dredging
hazardous
spoil
Substances
Gypsum-based Gypsum-based Hazardous
Construction Construction materials
material Contaminated with
hazardous substances
Gypsum-based Construction Non-Hazardous
materials not contaminated with
hazardous waste
Used Oil, Hydraulic Fluids and Fuel Wastes
Used oils Waste hydraulic oils Hazardous
Waste engine, gear and lubricating Hazardous
oils
Wastes of liquid fuels Hazardous
Absorbents, Filter Material, Wiping Clothes and Protective Clothing Wastes
Absorbents, filter Absorbents, filter materials Hazardous
materials, wiping (including oil filters not otherwise
cloths and protective specified), wiping cloths,
clothing (e.g. used protective clothing contaminated
spill kits and cleaning by
materials) Hazardous substances
Absorbents, filter materials, Non-Hazardous
wiping cloths and protective
clothing not contaminated by
Hazardous substances
Vehicle and Equipment Maintenance Wastes
Wastes from vehicle Waste tyres Non-Hazardous
and equipment
Oil filters Hazardous
maintenance
Components containing mercury Hazardous
Components containing PCBs Hazardous
 Explosive components (for Hazardous
example air
bags)
Brake pads containing hazardous Hazardous
substances(e.g. asbestos)
Brake pads other than those Hazardous
mentioned Above

Brake fluids Hazardous

Hazardous components other than Hazardous
those Mentioned above

Components not otherwise Non-Hazardous

specified
Wastes no to otherwise specified
Waste Electric and Electronic Equipment
Waste electrical and Transformers and capacitors Hazardous
electronic containing
equipment(WEEE) PCBs
Discarded equipment containing Hazardous
or contaminated by PCBs other
than those mentioned above

Discarded equipment containing Hazardous

chlorofluoro carbons, HCFC, HFC
Waste Batteries
Batteries Lead batteries Hazardous
Ni-Cd batteries Hazardous
Mercury containing batteries Hazardous
Alkaline batteries Hazardous
Municipal wastes arising from Offices, Canteens and Labor Camps
Separately collected Paper, cardboard, glass, Non-Hazardous
Fractions biodegradable kitchen
and canteen waste,
clothes and textile

Solvents, acids and alkalines Hazardous

Pesticides Hazardous
 Fluorescent tubes and other Hazardous
mercury
Containing waste
Discarded equipment containing Hazardous
Chlorofluorocarbons
Edible oil and fat Hazardous
Paint, inks, adhesives and resins Hazardous
containing Hazardous
substances
Detergents containing hazardous Hazardous
Substances
Plastics and metals Non-Hazardous
Biodegradable waste Non-Hazardous
Septic tank contents Septic tank effluent and sludge
Waste from sewage cleaning

Estimated Construction Waste Quantities

Table9-2EstimatedConstructionWasteQuantities

Waste Type Percentage

Mixed C & D Waste 33%
Timer 28%
Plater Boards 10%
Metals 8%
Concrete 6%
Others 15%

Note: Construction waste generation from proposed work is difficult to predict until the
exact materials and quantity of Construction waste is known, since the exact materials and
quantities are subject to some degree of change or variation during the Construction process.

10. Waste Management Measures

During Logistic Hub Development activities, MHC shall identify the processes and activities
that are likely to produce CONSTRUCTION materials and identify ways to reduce or minimize
their generation in particular, metallic waste, timber, paper and chemical waste. Additionally,
MHC will ensure
 Proper planning for works,
  Good management such as minimizing over-ordering
 Avoiding cross contamination to reusable and/or recyclable materials collected,
 Optimizing the use of metal form work or other work process to reduce or minimize
the use of timber in temporary works Construction and
 Maximizing the reuse of excavated inert CONSTRUCTION materials within the site etc.
To demonstrate MHC’s commitment on good waste management, the following
performance targets should be adopted:

 All excavated materials should be sorted to recover the inert portions (e.g. soil and
broken rock) for reuse on site or disposal to designated places as directed by
NEOM or Landfill.
 All metal should be recovered onsite or collection by recycling contractors;
 All cardboard and paper packaging (for plant, equipment and materials) should
be recovered on site, properly stockpiled in dry condition and covered to prevent
cross contamination by other CONSTRUCTION materials;
 All demolition debris from demolition works should be sorted to recover on site
broken concrete, reinforcement bars, mechanical and electrical fittings as well as
other building services fittings/materials that have established recycling outlets.

10.2. General Refuse and Other Wastes

Paper wastes from site offices are expected to be the predominant waste type. MHC
will take every attempt to minimize waste generation by:

 Reducing the number of photocopies to a minimum;

 Utilizing noticeboard to deliver message to site staff and minimizing printing hard
copies of correspondence where possible;
 Copying documents on both sides of paper for both internal and external
documents where possible; and
 Providing electronic communication facilities (e.g. email) to further reducing
printing of hardcopies for daily correspondence where possible.
Briefing to workers about the concepts of site cleanliness and appropriate use of
materials, including reduction, reuse and recycling shall be prepared by PEE to ensure
initiation measures are properly implemented.

Staff at the site shall be encouraged to use reusable rather than disposable dishware.
Food waste should be disposed of in the provided garbage bin around the site for proper
collection by appointed collectors. The Environmental Supervisor is responsible for
making sure all garbage bins are covered. In order to prevent the breeding of mosquitoes
or other diseases, garbage bins must be covered properly, and this can be verified through
routine environmental inspections.
10.3. Recycling
MHC will encourage segregation of steel reinforcing bars or off-cuts will be collected as
appropriate and sold to scrap steel mills for recycling by sub-contractors of MHC.

Construction waste including brick, concrete, reinforcing bars arising from site
clearancewillbesortedforreuseandrecyclingifpossibleandpracticableon-site. Useful
materials such as steel pipes, reinforcement, will be collected for recycling as scrap metal
by MHC’s sub-contractor. The scrap metal generated will be delivered to local metal mills
for recycling. All hoardings and formworks will be reused in our other sites prior to be
sold to recyclers for beneficial reuse.

10.4. On-site Sorting, Storage and Disposal of CONSTRUCTION Materials

All CONSTRUCTION materials arising from or in connection with the Project shall be
sorted on-site to recover the inert CONSTRUCTION materials and reusable and/or
recyclable materials prior to disposal of the waste portions off-site.

10.3.1. Excavated Materials

MHC's Environmental Engineer ensures all excavated materials are properly stored
onsite and used for back filling where necessary.

10.3.2. Construction Materials

Construction materials including brick, concrete and reinforcing bars arising from site
clearance will be sorted for reuse and recycling if possible. Selective sequential
demolition will be adopted to enhance reuse of waste.

Designated areas are located to carry out the on-site sorting, storage and disposal
processes. The sorting and storage areas will be arranged where near the front entrance
of Construction site, thus the appointed collectors are enabling to transport these wastes
easily and without any interruption to the works. The sorting and temporarily storage
areas (reusable and recyclable scrap material) for the scrap steel and CONSTRUCTION
materials are shown in the separate layout plan of temporary storage area for
CONSTRUCTION materials. (Refer to site layout plan at the end of this WMP) MHC shall
make arrangements with licensed recycling contractors to facilitate that recyclable
materials sorted from the Construction site are collected with reasonable care. In
addition, MHC shall record the quantities of all the recyclable materials before removal
off sites by the recycling contractors and include the details in the Manifest.
10.3.3. Chemical Waste
Any chemical wastes to be generated will be sorted and handled in accordance with
the NEOM Environmental Social Code of Practice on the Packaging, Handling and
Storage of Chemical Wastes.

Packaging:

 Chemical waste will be packed and held in containers so as to prevent leakage,

spillage or escape of the contents under normal conditions of handling, storage
and transport;
 The containers for chemical waste will be securely closed or sealed, correctly
stored and kept clean;
 Separate containers will be used to hold different types or different sources of
chemical wastes;
 Appropriate labels will be affixed on the sides of each of the containers of chemical
waste
 Drums and jerry cans will be used as chemical waste containers
 The information contained on the label will be accurate and sufficient so as to
enable proper and safe handling, storage and transportation of the chemical
waste.
Storage:

 A storage area located close to the source of waste generation will be designated
for temporary storage of chemical waste;
 The main storage area will be covered and rigidly enclosed.
 Adequate ventilation will be allowed and adequate space will be allowed within
the storage area for chemical waste container handling;
 The chemical waste storage will be bunded to retain potential leakage of the
capacity to110% of the largest container.
Disposal:

 Disposal of chemical waste will be regular and via licensed waste collector;
 A hazardous waste manifest will be maintained for the removal of chemical
wastes from site. Manifests will be issued by the storekeeper for the disposal of
material. This will record vehicle licenses; loads and types of chemical waste
carried and time on and off site for each trip leaving the work site. The records
will be kept properly by MHC.
 Emergency response:

A Spill Response Plan has been established and will be implemented to deal with
any accidental spillage of chemical on site. The spill response plan contains the
following procedures.

 Spill prevention and precaution;

 Response actions; and
 Spill clean-up and disposal.
 Sindalah Island is a prohibited storage location for hazardous waste, so any
hazardous waste generated there will be handled in a manner consistent with
emergency response procedures, and collected hazardous waste will be
transported securely to the UAH hazardous storage area, as follows:
o Hazardous liquid waste will be packaged in sealed drums and transported in
dyna with secondary containment.
o The solid hazardous wastes will be placed in leak proof bags and transported
to the UAH hazardous waste collection area in dyna.

10.3.4. General Refuse

Camp

 Food waste will be collected and stored in enclosed bins and plastic bags in the
refuse storage yards. A waste operative will be employed to remove the refuse
from the site on daily basis.
 Office waste paper will be reduced through recycling of paper if volumes are large
enough to warrant collection. MHC will consider participating in a local waste
recycling collection scheme if one is available.
 Labelled recyclable waste collection bins will be provided on site for other
recyclable wastes with insignificant amount including aluminum cans, glass and
plastic bottles to facilitate subsequent waste recycling;
 General refuse generated on-site will be stored in movable skips at work places.
Licensed waste collector will be employed to remove general refuse from the site
every day or as appropriate to the quantities of waste produced.
Sindalah Island

 MHC will designate one Dyna to collect waste from various worksites locations
in island.
 There will be dedicated staff to collect waste on daily basis, will be available on site
during site working hours.
 The collected waste will be stored in a temporary waste to rage area, and it will be
hauled to CWSL within 24 hours of accumulation. It is necessary to maintain proper
 housekeeping.
 On-site Maintenance shall be provided at Sindalah Island for any emergency repairs
and hazardous waste generated will be stored in leak proof container located in the
maintenance vehicle and transported to Hazardous Waste Storage area at UAH camp.
 An empty drum with lid will be provided to store any collected used oil.
 The area will have spill kits and protected with secondary containment.

10.3.5. Waste Containers

 Sufficient waste skips/bins/containers will be in place at all time, and all waste
stored in designated places at all times
 All food waste containers will have fitted lids
 All time waste bins/containers and skips will be maintained in good condition
 All Waste Shall Be Containerized all times
 Light weight waste will be covered with net to prevent the waste from becoming
airborne and escaping the skip.
 All bins shall be clearly labelled, identifying their intended contents.
 Inspections should be conducted regularly by an environmental Manger, who
will ensure the condition of the skips.

Table10-1WasteContainertypes

Type o0f Waste Number of Skips Waste Type

Container and Size

Skip 5 Plastic
Small Builder skip Metals
(10 x 4 x 4 feet)
Mixed Construction (2 Skips)
Wood
Container
Large Builders' Skip
(12 x 6 x 4 feet) 2 Organic Waste
Hazardous Waste 1 Contaminated Soil, Hazardous
Skips Waste

10.3.6. Sewage storage, collection and disposal

 All waste water will be stored in designated holding tanks inside second
contentment and transported to NEOM Sewage Treatments Plants (STP) Al bada by
specialized contractor on routine basis. 
 Routine inspection will be carried out by waste management team to check levels
and avoid overflow.
 Always holding tanks will be maintained well and checked on routine basis.
  All personals involved in sanitary activities will be trained in spill prevention and
training records submitted to NEOM.

10.3.7. Medical Waste

The Medical Waste from Sindalah Development Site shall comprise the following

 Soiled dressings: These include soil crepe or cotton, bandages, cotton swabs,
plasters, etc. They shall be handled carefully to avoid the spread of pathogens. These
wastes shall be disposed of by incineration.
 Used needles and syringes: These are the materials used for injections and sample
collection. The needles and syringes shall be put into a plastic, rigid and dedicated box
labelled by Biohazard International Symbol, and then sent for incineration.
 Expired drugs: These are the drugs that are beyond the manufacturer’s prescribed
life span. They included syrup, tablets, capsules, etc. These drugs shall be packed in
carton sand incinerated by designated medical waste disposal sub-contractor
approved by government authorities / MOH. The possibility of having this waste
onsite is very low as drugs will be inspected regularly and only those well within their
prescribed life span shall be taken onsite.
 MHC will sign contract with SEPCO Company dealing with medical waste
management to remove the waste generated from clinic.
 SEPCO Environment will collect the accumulated medical waste in clinic every week
and treat with Auto clave facility and dispose the treated waste in designated area of
the landfill.

10.5. Central Waste Storage Location

 All the waste from Construction activities will be stored in central waste storage
location (CWSL) and temporary satellite storage location will be identified as per
the need at designated locations in project site.
 Designated CWSL will be easily accessible and away from sensitive locations,
constructed with hard standing base with adequate space, skips and sign ages
estimated waste quantity and type.
 All necessary safety measures will be taken at storage facility.
 The Frequency of waste collection should be sufficient to avoid any waste
accumulation in the CWSL.
 All waste skips are to be closed securely except while adding waste
 CWSL will have space allotted for daily general waste collected from site and
temporary Construction waste storage location–refer to UAH layout for
details.
10.6. Hazardous Waste Storage Location
 There will be dedicated area to store all hazardous waste material with
impermeable base and concrete bund of at least 110 % of maximum capacity.
 Proper labeling will be followed for easy identification and access.
 Containers used for hazardous waste will not be used for other purposes
 Safety requirements like firefighting equipment, spill kits will be provided
 Storage/collection centers to be located away from main Construction Activities to
prevent ignition /fire;
 Hazardous waste storage areas will have spill containment system sand be
protected to avoid run-off to and from the storage area;
 Perimeter cut off drainage may be constructed to contain leaks, spill sand runoff;
 Firefighting equipment will be provided in close proximity to the storage/collection
center;
 Chemical and hydrocarbon absorbent materials will be provided to clean up spills
and leaks;
 Sufficient number of skips or other adequate containers will be provided for the
collection of the different types of waste identified;
 Containment curbs will be maintained around the loading and unloading area;
 Containers and storage tanks to be constructed from a suitable/compatible material,
to permanently contain the hazardous waste, and will have an identification label;
 Storage facilities to be inspected regularly for leakage;
 Storage facilities for volatile substances will be enclosed;
 At the expiry of the storage time limit, the material will be transported/removed to
a suitable hazardous waste management facility;
 Hazardous waste containers for transport will be appropriately marked and labelled;
 Handling, storage, and transport of hazardous waste will be tracked.
 Different types of hazardous waste shall be stored separately to avoid adverse
chemical reactions and facilitate eventual treatment.
 Hazardous waste shall be stored in tightly closed, leak-proof containers made of or
lined with, materials that are compatible with the hazardous waste to be stored.
 Liquid hazardous waste shall be stored in closed-top/lidded containers that are
compatible to the materials stored therein and compatible with hazardous waste
packaging and transport requirements.
 Containers intended for hazardous waste disposal shall NOT be used for other
purposes. Rusty, dented or defective containers for waste storage must not be used.
 Used batteries shall be stored within a concrete bund or rigid plastic spill tray. Used
batteries shall be sent for recycling.
10.7. Waste Management Resources

The following are the resources required in the waste collection operations in Sindalah
Construction Site;
 Vehicle to pick-up the collected waste bags and waste from bins around the site.
 Suitable Waste bins distributed at designated areas in residential, offices and
Construction areas
 Waste management and cleaning tools and equipment’s
 Black Plastic waste bags for general waste and yellow plastic waste bags for
clinical waste.
 Personal Protective Equipment of the waste collect or operatives such as gloves,
clear eye glass protection, Cover all and face mask, and steel to ecapped boots.
 Contract agreement with a qualified waste management contractor to haul the
stored waste to appropriate landfill or facility following KSA rules and
regulations.

10.8. Waste Management Service Provider

To ensure best practice management, appropriate contractors and facilities will be selected
by MHC, selected contractor and facilities will have approved licenses to haul and for
disposal.
Table10-2WasteManagementContractordetails

Recommended Waste Management Contractors

Organic & General Waste AFRAS TRADING & CONTRACTING COMPANY

Demolition Waste Al Qurany

Hazardous Waste GEMS
Used Lubricant Oil
Used cooking oil
MedicalWaste Afras treatment Facility
Disposal Facility
1. Organic & General Waste NEOM Landfill, Tabuk Road
2. Hazardous Waste GEMS Class I or II landfill
3. Used cooking oil for recycling Contractors Facility
4. Used lubricant oil Contractors approved Facility
5. Medical Waste Afras treatment Facility
GAMEP Environmental permit to operate
GAMEP Waste Transport Certificate-GEMS
Demolition Waste Company Transport Certificate
10.9. Waste Spill Prevention and Response

This Spill Response Plan identifies the potential risks associated with the storage of
hazardous substances at site and briefly describes the control measures. Detailed mitigation
planning and actions that will be taken in response to spill incidents are discussed in this
section below.

10.8.1. Spill Prevention

The following procedures shall be carried out to reduce the possibility of a spill that may be
harmful to the environment or to the health and safety of the workforce.

General Precautions:

 Avoid disorder and storage of unnecessary materials in working areas

 Prevent obstructions and tripping hazards
 Prepare all required equipment prior to commencement of work
 Prohibit smoking at or near the dangerous goods stores

Storage Precautions:

 Use solid and impermeable enclosure walls or storage containers

 Reduce the danger of falling of stacked containers
 Provide tightly closed lips to avoid leakage of chemical wastes to further reduce the
danger of container falling
 Store compatible chemical wastes in the same storage area
 Inspect the storage area to detect if any leakage of defective containers on a regular
basis
 Use suitable containers, which are resistant to the stored chemical wastes, to avoid
leakage or spillage
 Checktheconditionsofthestoragecontainersregularly
 Identify and provide suitable notice sin storage area
 Provide adequate eventuation in these to rage area
 Prohibit to pen flame and smoking near the chemical waste storage area
 Prevent mixing of in compatible chemical wastes
 Carry out mixing of compatible chemical waste outside the storage area
 Store large and heavy containers on the floor as far as possible or avoid storage of
these containers high earthen 2 feet from the floor
 Keep chemical waste containers below eye level
 Provide adequate space for handling 0f the containers
 Maintain along of chemical wastes
 Separate in compatible chemical from each other
Transfer and Transport Precautions:

 Consider the size of the container to avoid over filling

 Use pumps to transfer chemical wastes instead of simple pouring
 Provide containment structure to hold the chemical wastes when leakage or spillage
of chemical waste occurs
 Use safety and suitable labelled containers
 Use suitable carriers to transfer the chemical waste containers from one location to
another
 Employ licensed waste collectors to be responsible for chemical; waste
transportation

10.8.2. Spill Response

In case of are lease of petroleum or other chemical product, the following actions will be
taken in conjunction with the requirements of the Environmental Incident Response:

 Workers shall be aware of emergency telephone numbers, locations of spill kits,

emergency exit and evacuation routes
 Medical emergency response shall be under taken whenever necessary.
 The response actions to an accident would include the following steps

 Keepuntrainedpersonnelawayfromthespillageareaorevacuateallpersonnelandcal
ltheemergencyserviceifthespills are highly toxic and volatile
 Provide forced ventilation in the spillage area
 Allow only trained persons who have equipped with protective clothing and
equipment to enter the spillage area for clean up
 Transfer the spills back into containers using suitable equipment whenever
practicable
 Use suitable absorbing materials to clean up the spills and dispose of the
absorbing materials as chemical waste
 Use suitable solvent to clean the spillage after removing the spills
 Prepare necessary protective devices, safety equipment, containers and cleanup
materials for emergency use
 Train staff to handle the spillage of chemical
 Evaluate the potential hazard of the chemical waste
 Notify the NEOM immediately about the spillage through the form
Environmental Incident Notification Form.
 Any spill shall be documented and reported using the Environmental Incident
Report.
The Incident Report Matrix shall follow
 Type UrgencyofNotice Notification Remarks
ofincide (byorderofsequence)
nt
Major 1. Verbal notice within 1- hour of 1. Project Manager The report shall be
Environm discovery/incident 2. Safety Personnel initiated by person who
ental 2. Preliminary written report 3. MHC Environmental witnesses or discovers
Incident within 24 hours to be submitted Incident Control Team the incident with the
to Client and MHC Management 4. NEOM Representative assistance of a
3. Final investigation competent officer
report within 72hrs
4. To be recorded in incident log.

Minor Oil 1. To be recorded in incident log 1. Safety Personnel The verbal report shall be
spills, 2. Investigation report as per 2. Project Manager initiated by person who
Oil/Gas nature of high potential or injury 3. NEOM Representative witnesses or discovers
Leaks frequency the incident. Report by or
With the assistance of
a competent officer

Spill Response Team Member Contact

Zeeshan Khan 0536100772
Akif Ullah 0507874843
Abdullah 0553068039

11. Records Management

A Waste Documentation System will be prepared by MHC. The documentation to be maintained, as

a minimum, shall be the following:

• The names of the agent(s) and transporter(s) of the wastes;

• The name(s) of the person(s)responsible for the ultimate recycling, recovery or
disposal of the wastes;
• The ultimate estimation(s) of the wastes;
• Written confirmation of the acceptance and recovery, recycling or disposal of any
waste consignments;
• The tonnages all waste materials;
• Wastemanifestforhazardouswastestransferredfromsiteandassociatedappendices;
• Certificates of Recycling, Recovery, Re-Use or Disposal for all wastes transferred from
the site. All waste records will be maintained until the end of the project.
• All waste documentation will be maintained in a safe place, preferably onsite, during
the project implementation phase. Electronic records will be placed on a secure
server that is backed up regularly.

12. Monitoring
Waste inspection will be incorporated in the general environmental inspection. The general
environmental inspection will be undertaken weekly to check all Construction activities for
compliance, following will be

 Inert Construction materials suitable for recycling into aggregates are recovered
and delivered to designated areas.
 A disposal recording system that is operating satisfactory for recording
construction material removed from the Project;
 Paper/cardboard packaging, and metals including aluminum cans are recovered
and collected by Waste collection team;
 Plasticbottles/containersorplasticsheets/foamarecollectedandstoredin
designated container.
Environmental Manager is responsible for the formulation of the environmental inspection,
deficiency and action reporting system, and a comprehensive inspection checklist for
carrying out the waste monitoring site inspection works. The areas of inspection will not
only cover the current environmental situation, pollution control and mitigation measures
within the site, but also include the environmental situation outside the site area that is likely
to be affected, directly or indirectly, by site activities

After the weekly inspection, Environmental Manager shall prepare the summary table of
follow-up actions that should be agreed and signed by the responsible staff. Thus, PM shall
take prompt action to rectify the deficiencies identified and shall report the status of action
taken before the forth coming weekly inspection.

13. Reporting

• Daily Environmental Observations Checklist: Contains the Observations

recorded at site during daily site walkover
• Weekly Report: Weekly report will be submitted in suitable format with
compilation of observations conducted during the period with collected data and
evidences, will include information related waste shipment records, Water
consumption, fuel consumption, nonconformance recorded and their response
status, trainings, any environmental issues identified.
• Monthly Report: This report will include brief description of completed and
planned Construction activities, summary findings and their response status,
fuel and water consumption quantities etc.
• MHC will maintain below reporting forms for waste management
o Waste Manifest
o Waste Management Logbook
o Waste Management checklist
• Waste logs shall keep information related to movements of all types of waste, the
 logs shall contain information of waste source, date of removal, waste type and
description, quantity removed, destination of waste and sub-contractor name,
vehicle details and driver signature.

14. Performance Monitoring

A review of the WMP will be conducted by the MHC (NP) Environmental Team (ET) and
Contractor Environmental Manager (CEM), which will assess the quantity and type of
construction materials generated, reused, and disposed off-site. The amount of fill materials
imported to the Sindalah Island Development site and the amount of wood used in
temporary works at each Construction stage shall be monitored. Additionally, ET and CEM
of NP are responsible for monitoring the outcomes of the WMP.

As part of the WMP, corrective and preventive measures need to be taken if there are any
non-conformities (e.g. nonconformity on the part of environmental inspectors, etc). NP's
ET and CEM will also need to monitor the follow-up action on these defects and
deficiencies.

Note:

If any violations of the waste control measures are detected during an environmental
inspection by the ET/Project Environmental Supervisor, NP will formulate and
implement corrective measures promptly to resolve the problem. Alternate methods of
compliance and additional control measures may be recommended If non-compliance
persists.

An Event Contingency Plan in relation to non-compliance revealed or compliant received is

given in Table 4.

Table4–An Event Contingency Plan

Event Actionby
Construction Manager Environmental Foreman
/Project Engineer Supervisor
/Officer
Non- Discuss with Construction Log Non- Undertake mitigation
Compliance Manager to formulate Compliance into measures.
Mitigation measure. NCR and NCR
Report to Environmental
Logbook.
Delegate foreman to Engineer on completion of
Undertake mitigation Conduct follow- Mitigation measures.
measures. Up inspection.
Undertake further
Propose further mitigation Close out NC and Mitigation measures if
Measures if necessary. Report to necessary.
 Assistant Project
Manager.

Keep record of
NCR.

Complaint Discuss with Construction Inform Assistant Undertake mitigation

Manager to formulate Project Manager measures.
mitigation measure. upon receipt of
Report to Environmental
complaint.
Delegate foreman to Engineer on completion of
undertake mitigation Investigate mitigation measures.
measures. validity of
Undertake further
complaint.
Propose further mitigation mitigation measures if
measures if necessary. Log complaint necessary.
into
Environmental
Complaint
Record if
complaint is
valid.

Conduct follow-
up inspection.

Close out
complaint and
report to
Assistant Project
Manager.

Communicate
with complainant
if necessary.

Keep record of
Environmental
Complaint
Record.
 Appendix:

15.1. Site Mobilization Plan–Showing Waste Management Facility

Central
wastestorage
Area

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 15.2. WasteManifest

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 15.3. Waste Management Logbook

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 15.4. Waste Management Inspection Checklist

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 15.5. Environmental Incident Notification

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 15.6. Hazardous Material Compatibility Storage Matrix

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 15.7. Hazardous Material Incompatibility Matrix

Take
safetpreca
ution

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 15.8. Proposed Waste Storage Bins, Skips, Containers

Storage Bin examples:

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 15.9. Sample Slogans for Environmental Awareness

1. Just think before you bin it, there could be some use in it!

2. Make Our Sindalah Island cleaner place work and live Recycle

3. Once is not enough, recycle

4. Paper, Bottles, Plastic, Cans. Recycle the mall, take a stand!

5. Recycling takes little effort to your part, for a big difference to our world

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