Ems Manual Wo 009

Contract: NEOM Mountain Military Road Upgrade Contract No.
100322-009
ENVIRONMENTAL MANAGEMENT SYSTEM

MANUAL
For
NEOM MOUNTAIN MILITARY ROAD UPGRADE
Work order No : 100322/009
Project : 1000322/009 Doc. No: 100322-SPC-ENV-PLN-00000

Client : NEOM Revision : 01
Consultant : AECOM
Signature:
Issue for Ahmed Alnaima

Ali Dwairi Ali Soultan
09/03/2022 01 Review and Environmental
QHSE Manager Project Director
Approval Manager
Date: Rev. Description Prepared By: Reviewed By: Approved B:
Contract: NEOM Mountain Military Road Upgrade Contract No. 100322-009
Contents
1. Introduction .......................................................................................................................................... 4
1.1 Company Overview ................................................................................................................................. 4
1.2 Building Project ...................................................................................................................................... 4
1.3 Location ................................................................................................................................................. 4
1.4 Current Scope of Work ........................................................................................................................... 6
2. Construction Activities ........................................................................................................................... 7
3. Environmental Permits ........................................................................................................................ 11
4. Environmental Management ............................................................................................................... 11
4.1.2 Environmental Manager .................................................................................................................. 12
4.1.3 Emergency Response Coordinator .................................................................................................. 12
4.1.4 Spill Control Team ............................................................................................................................ 12
4.1.5 Security Team .................................................................................................................................. 13
5. Company EMS ..................................................................................................................................... 11
6. Determining the scope of the Environmental Management System (EMS) ........................................... 14
7. Environmental Management System ................................................................................................... 14
8. Environmental Aspects .......................................................................................................................... 16
8.1 Air emission impacts ............................................................................................................................. 16
8.2 Dust & Odour ....................................................................................................................................... 17
8.3 Surface Water Impacts .......................................................................................................................... 18
8.4 Land Clearing and Soil Waste ................................................................................................................ 19
8.5 Flora and Fauna .................................................................................................................................... 19
8.5.1 Spiny Tail Lizard Prevention and Mitigation Measures .................................................................... 20
8.5.2 Potential Impacts ............................................................................................................................... 20
8.5.3Ecological Procedure .............................................................................................................................. 21
8.5.4 Marine Ecology Impacts SAPAC adhere ESIA ....................................................................... 23
8.6 Noise and Vibration Impacts ............................................................................................................... 23
8.7 Traffic Impacts .................................................................................................................................... 23
8.8 Waste Management Impacts .............................................................................................................. 23
8.8.1 Waste Classification ......................................................................................................................... 23
9. Compliance Obligations ....................................................................................................................... 33
10. Legal and other requirements ............................................................................................................ 33
11. NEOM Environmental Code of Practice for Construction ............................................... 34_Toc96854968
12. Implementation & Operation ............................................................................................................. 37
12.1 Competence, Training and Awareness .............................................................................................. 37

12.2 Communication ................................................................................................................................. 38
12.3 Documentation & Control of Documents.......................................................................................... 39
12.5 Emergency Preparedness and Response........................................................................................... 40
12.7 Non Conformity, Corrective Action and Preventive action ................................................................... 42
13. ENV Training Matrix .......................................................................................................................... 44
14. Environmental Management of Change……………………………………………….………………………………………….…43
1. INTRODUCTION
1.1 Company Overview
SAPAC started more than 30 years ago with clear vision and objectives. At start, the focus was on infrastructure only,
then SAPAC went through progressive development according to well-established Business and Strategic Plans.
Since SAPAC been founded; we believed in success factors; namely: humans, tools, and processes. SAPAC invested
extensively in these factors, today; we can see that such investment is paying off as it’s clear now that SAPAC has
been founded on very strong pillars. SAPAC now can mobilize to any site in Saudi Arabia within 72 hours. A
distinctive capability.
SAPAC has its presence all over the Kingdom, with a national spread of offices. A thrust on international business
has seen overseas in manufacturing business significantly. It has the urge to continue to grow its global footprint,
with manufacturing facilities in multiple countries.
• Construction of more than 1546 km idealizations of the main roads nationwide

• Rehabilitation of more than 450 km of existing roads
• More than 1396 km of road maintenance including asphalt milling and relaying of asphalt and street lighting
1.2 Building Projects

• Construction of medical building projects some of which are: Mina Medical Center, hospitals with a 100 and 50 beds
capacity, casual treatment and emergency centers
• Construction of educational projects, one of which is the infrastructure of Najran University
• Construction of the technical colleges of General Organization of Technical Education and Vocational Training in
Arar and Al Jawf
• Construction of lab projects, one of which is Laboratory for Measurement and Standardization of Saudi Arabia
Standards Organization (SASO)
• Construction of administration buildings of The Ministry of Interior, located nationwide
• Construction of housing projects, one of which is Ofﬁcers Housing project in King Khaled Military City in Hafer Al
Batten
• Construction of mosques under the Ministry of Islamic Affairs, Endowments, Da’wah and Guidance
• Construction of numbers of hotels
• Construction of more than 3668 m long pre-stress bridges
• Construction of several tunnel projects nationwide
• Construction of storm drainage networks in different locations in the kingdom
1.3 Location
Construction activities in NEOM mountain region, NEOM is intending to upgrade the military road which is required
to support future works for the mountain projects. The project sites are presented in the overleaf figures (Figure 1 and
Figure 2).
Figure 1: Location and authorized extent of the proposal

Figure 2: Location of the new Laydown area
1.4 Current Scope of Work
NEOM is targeting to upgrades the existing military road (25km long section) with exception of two detours (1.3
and 1.7km long) and will include installation of passing and overtaking lanes, paved shoulders, signage, improving
pavements, new jerseys, slope protection from the fall and ground rails for heavy vehicles. A working width of
between 16 m and 30 m will be required during construction. The width of the upgraded road will be up to 10.3m
wide.
New laydown area located near the station at 00+800 km.
The works shall be carried out in an effective, environmentally friendly, safe, and risk-free manner and in
accordance with the Environmental Mitigation Plan.
1.4.1 Scope of Works includes but not limited to:
• Limited clearing, grubbing, stripping

• Shoulder paving
• Installation of guard rails, road marking, signage, pavement improvement
• Cut and fill (Detour 1 fill = 42,000 m2, Detour 2 fill = 51,000 m2)
• Slope soil stabilization for vehicle safety
• Sub-grade preparation
• Stockpile management
• Reinstatement of temporary use areas
During works, assets will be re-used where possible as part of the circular economy, such as guard rails, signage,
pavement, slope stabilization materials.
A temporary laydown area will be established within the Mountain Early Works laydown yard incorporating the
following facilities:
• Site offices
• Ablution facilities with sewage holding tanks
• HAZMAT storage
• Fuel storage (mobile double skinned tanks)
• Waste management
• Vehicle parking
The location of temporary site offices, ablution facilities and laydown areas in the vicinity of the works area will
be subject to NEV approval prior to Contractor mobilisation. On completion of construction all temporary use
areas will be reinstated and Contractor shall propose a de- commissioning management plan for temporary
workers rest areas, welfare facilities and temporary storage areas.
The workforce (approximately 100 persons) will be accommodated off site in local accommodation and will be
transported to site by bus via the Military Road.
Services during construction
Where needed, diesel generators will used for power generation at Contractor’s and NEOM’s temporary offices
and welfare/ablution facilities and the laydown area. Fuel for diesel generators will be stored in bunded double
skinned tanks and fuel will be supplied by road tankers.
Potable water and water for dust suppression, compaction, construction works will be fresh water which will be
supplied by water tankers from approved licensed sources.
Crushed rock or other aggregate material (if required) shall be sourced from quarries/borrow pits that have an
Environmental Accord issued by NEOM Environment Department.
Wastewater from site offices and ablution facilities will be collected into holding tanks and these shall be removal
regularly by tankers to offsite licensed treatment works.
Solid waste from site shall be collected in skips located on site and will be removed regularly once full to approved
waste management facilities.
2. Construction Activities
With reference to the project contract (WO-100322.009), a baseline schedule was compiled to provide planed and
actual activities. This populated schedule will enable the involved parties with an opportunity to ascertain any data
gaps as the site activities progress overtime. The below Tables provide an overview of the project and this was
presented to PMC and Neom projects. The timeline progress in presented in Table 2 below.
Table 2: Project schedule overtime

3. Environmental Permits
NEOM updated permit is received on 02th Feb 2022 for WO-009 NEOM Mountain Military Road Upgrade Accord
No is 2021/11 as per accord the SAPAC will follow the accord conditions.
• SAPAC will upgrade the approval locations by using cut and fill and imported material from approved
borrow pits/quarries only. SAPAC will disposed of unsuitable material to approved location only.
• SAPAC shall implement the Proposal as described in the Approved Mountain Military Road Upgrade
Environmental and Social Management Plan (CESMP) attached to the Environmental Accord, and in
compliance with the conditions of the Accord.
• SAPAC shall ensure that contractors do not exceed the authorised extent of the Proposal as defined in the
Environmental Accord unless amendments to the Proposal and the authorised extent of the Proposal have
been approved by the NEOM Environment Department.
• All commitments and management controls detailed in the CESMP attached to the Environmental Accord,
shall be implemented in full and according to their naturally understood intent.
• SAPAC shall ensure that all contractors comply with NEOM Employer Requirements and all relevant
requirements of NEOM’s Regenerative Development Management System.
• SAPAC must ensure they comply with any permits issued for the Proposal by the Ministry of Environment,
Water and Agriculture.
• SAPAC shall comply with all relevant requirements under Kingdom of Saudi Arabia Law until such time as
it is replaced by NEOM Founding Law.
4. Environmental Management
Environmental management is a corporate strategy that monitors, develops and implements environmental
policies of an organization. It is a systematic approach that is gaining due prominence as consumers are
looking for products and services that are eco-friendly and eco-aware
4.1 Leadership and Commitment
SAPAC Senior Management are committed to achieving, not only acceptable minimum standards of
environmental performance on their construction project but aspire to exceed minimum standards by
delivering exceptional standard of environmental performance. SAPAC Senior Management promote a
culture of positive environmental management amongst their staff.
SAPAC provide sufficient and adequate resources to their construction project, to ensure that acceptable
standards of environmental performance are achieved and maintained over the project life-cycle from
contract award, to handover and demobilization.
Below are detailed the roles and responsibilities of persons within SAPAC that may influence the success
of the environmental management system, including a description of the position and authority of the
SAPAC Environmental Manager who is assigned to the project.
4.1.1 Project Manager (PM)

• The Project Manager shall be designated as the responsible person, and have overall responsibility for
the implementation of the on-site Environmental Management System;
• Ensuring the requirement of this plan are communicated to all concerned, including all sub-
contractors.
• Ensures the project team is aware of their responsibilities, and that these are enacted on site.
• Provide appropriate resources for effective implementation of this EMS including the resources
required for procurement, and emergency response equipment.
• Constitute an Emergency Response Team for this project and define the specific responsibilities.
4.1.2 Environmental Manager
• Environmental Managers manage the development and implementation of environmental

management systems within organizations by identifying.
• Solving and alleviating environmental issues, such as pollution and waste treatment, in compliance
with environmental legislation and to ensure corporate sustainable development.
• Environmental managers are responsible for overseeing the environmental performance of private
and public sector organizations and for developing, implementing, and monitoring environmental
strategies that promote sustainable development.
• Respond to inquiries and concerns related to EMS.
• Perform regular environmental audits to monitor emissions, contaminations, and incidents
• Work with team to develop effective environmental strategies to reduce contaminations
• Investigate environmental incidents and develop action plans.
• Develop budget and timelines for environmental operations and develop cost reduction initiatives
while still maintaining quality.
• Provide job trainings and assistance to team members when needed.
4.1.3 Emergency Response Coordinator

• Assessing the severity and consequences of an emergency event and deciding on the levelof
response required.
• Contacting the external emergency service, if required.
• Acting as the Commander in control in the event of an emergency and coordinateemergency
response actions and communication to the emergency control room.
• Arranging rescue of any person affected by the emergency event, without compromising the
safety team members.
• Conducting debriefing after the completion of emergency evacuation exercise.
• Inspecting and maintain the emergency response kit.
4.1.4 Spill Control Team

• Attending spillage spots immediately and taking all possible initiatives to stop spillage if it is safe
to do so.
• Containing spillage by constructing bunding around the spill or spreading inert absorbentto
prevent further spread.
• Recovering spilled oils and chemicals where practicable.
• Cleaning of spillage at site as soon as practicable and storing contaminated soil in an
appropriate manner.
• Assisting external agencies, as required, or requested.
4.1.5 Security Team

• Cordoning off the emergency area to prevent access of any unauthorized person.
• Assisting the Emergency Response Coordinator, and external agencies, as requested.
4.1.6 All Personnel
Every person employed on the project has a statutory duty to take reasonable care for the health
safety and environment of themselves and others who may be affected by their actions or
omissions at work.
• Regarding the statutory duties imposed on the project manager, they must cooperate with the
environmental manager to enable him to comply with the relevant statutory requirements.
• Keep all the project premises tidy and clean.
• All persons should put the waste in trash bin according to the classification. no body allowed to
interfere with hazardous waste without authorization.
• All personnel shall wear or use the appropriate safety equipment or clothing. all personnel will report
any unsafe practice regarding the environment.
• All personnel are encouraged to make suggestions to improve environmental performance.
Figure 3: Company Structure in NEOM and in the project

5. Company EMS
The main advantage of any international certification is the sustainability of the “Plan-Do-Check-Adjust” cycle. ISO
14001:2015 goes beyond this minimum tangible benefit to include:
• Development of a best-in-class EMS to align with the requirements of international standards

• Development of sustainable environmental initiatives based on the full life cycle of all input feedstock’s and output
products, services, and waste streams to minimize the environmental impact of hydrocarbon operations
• Optimization of EMS performance to conserve air, land, and water resources, and an inventory of pollutants leading
to financial benefits to the company
• Ensuring management’s commitment and visibility to employees and contractors for the significance of
environmental initiatives leading to a greener future
• Building a respectable image for SAPAC facilities as the company and the Kingdom looks to expand its economic
portfolio.
The new EMS includes a full life cycle impact assessment of all input and output streams, risk management and
treatment plans, and the implementation and closure of some continuing environmental concerns.
SAPAC environmental protection department took a comprehensive look at the entire process to search for best
practices and guidelines that may be used for future SAPAC departments opting to certify their facilities according to
the international standard.
6. Determining the scope of the Environmental Management System (EMS)

The following paragraph defines the scope of SAPAC Environmental management system. The scope is a
factual and representative statement of SAPAC operation which are include within the determined boundaries
its environmental management system.
SAPAC has defined organization environmental policy for all site-based projects and ensure that within the
defined scope of its environmental management system.
• Is appropriate to the nature, scale and environmental impacts of site construction activities.
• Includes a commitment to continuous improvement, and prevention of pollution.
• Includes a commitment to comply with applicable legal compliance, and with other requirements to which
the SAPAC subscribes, which relate to its environmental aspects.
• Includes waste management General, Hazardous waste properly dumped through NEOM Waste
management procedure.
• Provides the framework for setting, and reviewing environmental objectives, and targets.
• Is documented, implemented, and maintained.
• Is communicated to all staff, labors, and sub-contractors working for or on behalf of the SAPAC; and,
• Is available to the NEV, AECOM, government agencies, interested parties, etc.
SAPAC have established, implemented, and will maintain and continually improve their Environmental
Management System (EMS). The EMS described in this document will enhance SAPAC environmental
performance and deliver its intended outcomes.
7. Environmental Management System

SAPAC have established, implemented, and will maintain and continually improve their Environmental
Management System (EMS). The EMS described in this document will enhance SAPAC environmental
performance and deliver its intended outcomes.
The framework constitutes plan-do-check-act improvement cycle and five layers namely:
1) environmental policy,
2) planning,
3) implementation,
4) checking,
5) review.
Environmental management system framework basically provides a tool which leads higher education
institutes towards sustainability. The proposed EMS framework presented in Figure
7.1 Environmental policy
In the first step, principles and aims for the protection of environment are set in formally documented form.
Environmental policy is basically a guiding document and following it is essential for the reliability and the
success of EMS.
Following are the commitments that should be included in policy:
1) pollution prevention,
2) related legislations of environment and other requirements,
3) continual improvement.
7.2 Planning
The second most important step is planning. According to the above given three commitments of policy,
HEIs should set their targets and objectives and develop a plan for their fulfilment. Planning includes
aspects, legal and other requirements, targets and objectives, and environmental management programs.
7.2.1 Actions to address risks and opportunities

The company is committed to identifying and addressing relevant risks and opportunities as a
means for:
• Increasing the effectiveness of the EMS.
• Improving performance.
• Preventing or mitigating negative effects.
When undertaking risk management activities, the company must give consideration to the:
• Positive and negative factors or conditions.
• External context and issues, such as legal, regulatory, technological, competitive, cultural,
social, political and economic environments.
• Internal context and issues, such as values, culture, organization structure, knowledge and
performance of the business.
• Determination of the requirements and needs and expectations of interested parties relevant
to the EMS.
• Authority and ability to exercise control and influence.
• Activities, products and services relevant to the business.
The company may adopt any or a combination of the following risk options:
• Avoid the risk.
• Eliminate the risk source.
• Take the risk to pursue an opportunity.
• Change the likelihood or consequences of the risk.
• Share the risk.
• Retain the risk by informed decision.
Opportunities identified by the company may lead to:

• Adoption of new and improved processes.
• Pursuing new markets.
• Utilizing new technology.
• Improved ways of addressing client need.
The company will manage risk and opportunities as follows:

• Through ongoing effective leadership and commitment to the EMS.
• Manage business and quality risks and opportunities in the Board meeting and the
Management meetings.
• Through the effective management and control of suppliers and contractors.
• Through the effective training of personnel to ensure they are competent to perform relevant
tasks safely.
• By monitoring, measurement and review of relevant processes and outputs.
7.3 Implementation
After the development of plan, HEIs should then establish the necessary elements for the implementation
and operation of their plan successfully. Implementation layer further comprises on structure and
responsibilities, operational control and emergency preparedness and response, training and awareness,
competence, communication, documentation and documentation control.

7.4 Checking
By successful implementation of plan, it is required to monitor that the targets and objectives are meeting
according to the plan or not. If any objective is not met according to the plan, then corrective actions need to
be taken. The whole environmental management system should be audited periodically to monitor that the
standard requirements are satisfied. It includes monitoring and measurement, corrective and preventive
action and EMS audit.
8. Environmental Aspects
8.1 Air emission impacts
Construction activities will result in increased air emissions from fugitive dust, particulates, and gaseous pollutants.
Air emission contains, Dust generation Emission of Gases and Volatil
8.2 Dust & Odour
It is expected that the main activities, which will impact air quality through the generation of fugitive dust, include:
Excavation, stockpiling and other earthworks Dismantling of temporary platforms Transportation of materials
and personnel; Heavy equipment movement on site. Stock piling of spoil material from excavation will generate
airborne particulates that may be dispersed under windy conditions. SAPAC will follow the dust control procedure.
However, construction activities are temporary, and impacts are considered reversible once construction works have
been completed. In addition, dust impacts are also reduced with distance from activities thus the nearby sensitive
receptors are not likely to be affected. Dust generation impacts will be small provided that dust control measures are
undertaken.
Mitigation
The following control mitigation will apply to control the dust on site
• All site activities with a potential to generate dust will be identified and subject to an Environmental
Risk Assessment.
• Excavation and Backfill activities shall be conducted in accordance with NEOM.
• Water spray, will be used for dust suppression on roads where required
• Site inspections will assess the effectiveness of dust control measures used onsite.
• Loading and unloading of material that could generate dust will be done without throwing into the
air.
• Loads on the hauling vehicles will be covered properly to avoid the dust from spreading.
• Before to dismantling the temporary platform should be check for dust and clean them.
• All stock piling will occur in designated areas.
• Stockpiles will not exceed a peak height and should be according to NEOM.
• Materials deposited on stockpiles on site will be closely monitored for any emission of dust and if
required they will be damped down, covered, or treated with a dust suppressant.
• The drivers will train to reduce their speed while moving around the site during dry weather to
minimize disturbance.
• Ensure dust/ sand on roads leading to the sites is periodically and adequately cleared. Housekeeping
will conduct to clean the site.
• All employees will be provided with PPE (dust masks etc.) for when they will be working in dusty
conditions.
• No significant production of odorous materials is expected during the construction. In the event that
any odorous materials are excavated, mitigation measures such as the use of odor suppressants will
be implemented where practicable. In addition, the following measures will be taken onsite.
8.3 Surface Water Impacts
Spillage and leakage

Waste generation from construction activity Contamination of surface water.
Waste water generation from camp area.
Waste water generation from site construction activities Soil and Ground water Impacts.
Soil and groundwater will be susceptible to contamination from various sources
during the construction phase of the project. The main sources of contamination are typically those places along the
handling and processing of products where liquid waste and hazardous material can escape into the soil
and groundwater. These are commonly associated with the transport, handling and storage of such
materials and the potential threat of releases and spills into the ground. The following materials is
expected that may be cause of contamination.
• Diesel fuel,
• Control oils
• Lubricants,
• Solvents and chemicals,
• Cement additives,
• Paints and coating materials
• Testing fluids.
Impacts may also occur from accidental discharges of hazardous and non- hazardous materials and
wastes handled onsite however the impacts are considered negligible when mitigation measures
contained are implemented. Construction activities may pose a potential for release of diesel fuel-based
products, such as lubricants, hydraulic fluids, or fuels during their storage, transfer, or use in equipment.
Control Measures
• Construction machinery will be checked regularly.

• Refueling will be limited to a designated area. Spill kits, absorbent pads and other required absorbent
will always be available on site.
• Parking of staff vehicles will only be permitted in designated areas.
• Any spills will be cleaned up as soon as possible with any contaminated sands bagged up and
disposed of according to procedure and standards.
• Pollution prevention measures will be included to ensure the correct storage of hazardous chemicals.
• Fuel storage areas will be segregated from dewatering water to avoid contamination of settlement
water resource
• Waste oil and grease from the construction site will be collected in suitable drums and sent out for
proper disposal. Records of such material will be maintained.
• Part of the site inspection will include an integrity inspection of all site and camp pipe work, hoses,
watering units etc. to check for leaks/losses.
• Specific wastewater collection facilities will be provided onsite according to the contractual
requirements and standards. These will be installed and maintained to facilitate wastewater/wash
water collection.
• All chemical storage shall be conducted within a secondary containment impermeable and reinforced
with epoxy paint.
• Wastewater discharge to open land or drains shall not be permitted. Records of all disposals will be
maintained by the sub-contractors and provided to SAPAC if required.
• The use of any piles or excavations will be supported by a risk assessment to ensure that appropriate
mitigation is identified to avoid the contamination of groundwater through the creation of new
migration pathways through these works.
• Onsite vehicle washing will not allow.

• Emergency Response Plan will be enforced and audited. Staff will be appropriately trained and
monitored in spill prevention and clean-up procedures.
• Spill kits will be provided at all significant locations, if required. Their disposal upon use will be in
accordance with NEOM
8.4 Land Clearing and Soil Waste

Unwanted Soils waste constraints may be physical such as dryness, wetness, steepness, and extreme
textures. Reversing the degradation of soil, water and biological resources and enhancing through
appropriate management and remediation are essential components in achieving waste control.
Mitigation measures
• Maintain speed limit on site for equipment and especially machinery on windy days.
• It shall be checked that fine materials are not heaped up in places exposed to the wind.
• Earthworks shall be restricted to the strictly necessary in windy or very windy condition
• Establishment of feeding systems that provide material stockpiles since shortly height
• Moistening of material liable to produced dust.
• Site access roads must be cleaned in order to prevent accumulation of mud. Terrestrial Ecology
Impacts
8.5 Flora and Fauna

• For the general protection of flora and fauna in the project area, the ESIA mitigation measures shall
be implemented during project activities: Overall habitat loss shall be minimized to the maximum
extent. project site shall be protected from disturbance during construction through fencing off
unused areas, use of warning signage, and training of workforce.
• Any sightings of wild animals (i.e. snake, camels, dogs etc.) and any incidents involving hunting on
around the site area shall be recorded in Monthly Environmental Compliance forms.
• Vehicle speed will be controlled to minimize noise and dust
• Materials movement outside the Project boundary will be controlled, and entry limited to authorized
personnel
• Wastes and hazardous materials will be stored within a designated area or i n containers to prevent
animal scavenging
• Excavations will be barricaded to prevent entry of wildlife.
• The spill or leak of hazardous substances also can affect the Flora and fauna, so the Leaks or spills
of Control measures include, but are not limited to, the following:
• Fuel Storage Tanks will be installed above-ground, underground fuel storage tanks are prohibited
• Fuel Storage tanks will have a containment 110% of the storage volume and all storage tanks will
be placed inside an impermeable and bounded according to the applicable NEOM rules and
regulations.
• Diesel generators will be placed in site according to the NEOM procedure.
• Spill containment spill trays or comparable spill prevention methods will be implemented for diesel
engine driven equipment, such as compressors or welding machines.
• Chemicals, including but not limited to, paints, solvents, cleaning solutions, etc., will be stored inside
impermeable bounded areas, and/or transport containers or comparable arrangement which prevents
releases/spills.
8.5.1 Spiny Tail Lizard Prevention and Mitigation Measures
Spiny tail lizard Burrows Protect Burrows are typically characterized by a perimeter around the burrow
entrance, which consists of soil excavated by the animal occupying the burrow. These perimeter walls
alter the thermal environment in the immediate vicinity of the burrow entrance.
Mitigation Protection Measures

• Cordon the burrow area
• Arrange Sign protected area
• Adhere to EIA recommend mitigation protection measures
• ESIA recommend mitigation protection measures mention below
The occurrence of terrestrial ecology receptors, such as the IUCN Vulnerable species, Spiny
Tailed Lizard (Uromastyx aegyptia), within the project site cannot be excluded.
8.5.2 Potential Impacts

Potential impacts during the project construction phase include the loss of habitat, and conflicts from the
construction activities with the local terrestrial fauna (e.g., road kill, hunting, etc.).
The increase in presence of humans and associated issues such as litter, waste, noise, and general
disturbance is likely to influence the local fauna, introduce exotic species, attracting human commensal
species and displacing existing native species.
The potential impact of vibration of extant species within the site is not expected to be significant.
Ground borne vibration is created chiefly by construction activities such as piling and excavation.
Ground borne vibration does not propagate significant distances from the source and is therefore not
considered to be a potential significant impact on ecological resources.
8.5.3 Ecological Procedure

Explicitly identified PME requirements with regard to the impact of the
proposed Project on flora and fauna of the area. However, GAMEP is responsible for marine
conservation and environmental protection in the Kingdom. Working closely with the PME on
terrestrial ecology is the Saudi Wildlife Authority (SWA), which is tasked with developing and
implementing the national policy for conservation and protection of species and reserve areas.
GAMEP with SWA has identified protected and conservation areas and works with the industry
and other ministries for establishing regulations and standards to prevent any damage to these
areas.
Saudi Arabia in its commitments to the United Nations Convention on Biological Diversity
(UNCBD), (United Nations, 1992) produced a listing of species considered to be of Higher
Conservation Priority (HCP), these are commonly used as a de facto protected species list for the
purposes of ESIA.
Saudi Arabia has also produced a National Biodiversity Strategy and Action Plan (NCWCD,
2005) the provisions of which have legal binding through the Kingdom’s commitments to the
UNCBD.
Ascribing Species and Habitat Status
In the absence of any national protected species list this ESIA has utilized two approaches for
establishing species status. These are described below.
In order to classify species conservation concern, two approaches have been used.
Firstly, the global Red List developed by the International Union for Conservation of Nature and
Natural Resources (IUCN) which classifies species in accordance with their risk of extinction on
a global basis is used. The IUCN version 3.1 Categories
Source: IUCN Website: accessed June 2018
The second approach for determining the importance of species uses a National basis. As noted,
Saudi Arabia is a signatory to the UNCBD and as such has obligations to protect
species within the Kingdom. There is no national legislation covering general species protection
with Saudi Arabia but in response to the UNCBD requirements the former NCWDC
produced a list of HCP species. These were set out in the Kingdom’s first letter to the UNCBD
(NCWDC, u/d) and utilize a range of criterion, some of which relate to cultural importance of
species as much as conservation status. However, this is the only de facto protected list and so is
used within this ESIA to provide a national context. Species with HCP status are referred to as
HCP species. The criteria used for HCP species is set out below.
• Criterion 1 - Genera, species, or subspecies that are critically endangered, endangered, or

vulnerable (globally, regionally, or nationally); taxa which are locally extinct in the wild
may be included, provided that there is an NCWCD policy to reintroduce them.
• Criterion 2 - Genera, species, or subspecies that are endemic to the Arabian Peninsula, the
Red Sea, or the Gulf.
• Criterion 3 - Genera, species, or subspecies of which the conservation of populations within
Saudi Arabia is essential to the conservation of the taxon (e.g. near-endemics and migrants
for which Saudi Arabia represents a critical range).
• Criterion 4 - Relict genera, species, or subspecies that are of global, regional, or national
significance.
• Criterion 5 - Genera or species of special ecological importance (i.e., fulfilling a vitally
important function in an ecosystem such as providing a key habitat for other species, serving
as indicator species, etc.).
• Criterion 6 - Genera of species of significant economic importance.
• Criterion 7 - Genera or species that serve a “flagship” function (i.e. high-profile species of
cultural value, the protection of which will also protect large numbers of other species that
share their habitats).
More recently, the IUCN has commenced developing a system for evaluating ecosystems of the
world and utilizing a similar approach to the Red List. This is referred to as the Red list of
Ecosystems (RLE) and assesses the risk of complete collapse of the ecosystem. To date no
ecosystems within the Middle East have been evaluated
Archaeology and Cultural Heritage Interests
To safeguard archaeological remains within the project area and to ensure the well- being of the
local population is maintained throughout the construction.
• SAPAC will include contingencies in risk planning to deal with the discovery of important
archaeological finds. Should any archaeological remains be discovered, works will stop
immediately, and the findings will be reported to the Site Manager and HS Manager,
Environmental Manager immediately.
• Part of the induction training will be used to make all staff aware of the procedures to be
followed upon the discovery of archaeological remains in addition to the type and potential
range of artefacts (if any) that could be located within the site.
• The possible or confirmed existence of heritage objects or places, and the responsibility to
report any suspected heritage discoveries, will be communicated to all staff including
machinery operators.
• When the work is conducted near identified heritage items, the items will be clearly marked
with temporary flagging or fencing prior to the commencement of works.
• When work is conducted near identified heritage items, an exclusion zone will be created
around the items to prevent damage by excavation, vehicle movement and vibration,
resulting from vehicles and equipment.
• It is noted that potential heritage items or relics can include:
• Evidence of historical occupation (such as aged building remains), fishing or pearling
artefacts, shipwrecks, pottery, and other tools. Evidence of early industrial heritage; Articles
of religious heritage value; and Items or places of importance to the early Bedouin peoples.
8.5.4 Marine Ecology Impacts SAPAC adhere ESIA
8.6 Noise and Vibration Impacts

SAPAC to adhere all the standards set by NEOM as per site requirements.
8.7 Traffic Impacts

Traffic impact is considered as a tool to obtain the impacts may be caused by the project, and to
identify any roadway improvements that can alleviate
Analyze the internal traffic elements including the access/egress points and car parking
availability. Accordingly, the objectives are as follows: To identify the existing traffic and road
conditions within the area of influence site area.
• To estimate the additional traffic that will be generated by the project and to determine how
this additional traffic would affect the existing road network.
• To estimate the amount of parking demand and determine whether the available supply would
be sufficient or not.
• To identify the types of improvements required in order to minimize the traffic impact of the
proposed project and improve traffic circulation within the area of influence
8.8 Waste Management Impacts

Waste Management Impacts consist the following waste management principals. Waste
Classification Waste Minimization Waste Identification Waste Segregation Waste Storage Waste
Handling Waste Transportation Waste Disposal SAPAC prepared these documents according to
NEOM, and Presidency of Meteorology and Environment PME standards
8.8.1 Waste Classification

A waste is any material or substance (Solid/Semi-Solid/Liquid/Gaseous) that has discarded or
intended to be discarded. A waste is generally defined by its physical, biological, and chemical
characteristics. There are five generic waste types:
• Municipal Waste
• Non-Hazardous Industrial Waste
• Hazardous Waste
• Radioactive (A special category of hazardous waste)
• Medical Waste (A special category of hazardous waste)
• E-Waste (Waste electrical and electronic equipment)
Municipal Waste - Inert or non-hazardous waste produced through everyday non- industrial
operations and living. Examples are paper, cardboard, plastic bottles, tins/containers, kitchen
wastes etc.
Non-Hazardous Industrial Waste - Any waste generated by industrial processes or civil

activities that is not classified as hazardous. Examples are masonry and brick rubble, plastic, wood
and metal ferrous and non-ferrous etc.
Hazardous Waste - Substances that pose a present or future threat to man and/or the environment which are
unwanted and economically unusable and that are ignitable, corrosive, chemically reactive or
toxic. Examples used oil
Radioactive Waste - Any waste containing a radionuclide. (i.e. a nuclide that is radioactive)
Medical Waste - Any waste which is generated in the diagnosis, treatment, or immunization of human
beings, or in related research, biological productions, or testing.
Unidentified Waste
A material/substance to be discarded that is to be classified as hazardous waste if it exhibits one or more of
the following characteristics:
• Ignitability
• Corrosives
• Chemical reactivity
• Toxicity
• Radioactivity
• Medical/Bio-hazardous
• Ignitability - A waste is ignitable if: It is a liquid and has a flash point less than 21°C.It is not a
liquid and is capable of causing fire through friction, absorption of moisture, or Spontaneous
chemical changes; and, when ignited burns so vigorously and persistently that creates a
hazard. It is an ignitable compressed gas, or It is an oxidizer.
Corrosives
A waste is corrosive if it is aqueous and has a pH less than or equal to 2 (≤2), or greater than or
equal to 12.5 (≥12.5)
Chemical Reactivity
A waste is reactive if:
• It reacts violently with water.
• It forms potentially explosive mixtures with water.
• It is normally unstable and readily undergoes violent change without detonation
• When mixed with water, it generates toxic gases, vapors, or fumes in a quantity
sufficient to present a danger to human health or the environment.
• It is readily capable of detonation or explosive decomposition under normal conditions
(Standard temperature and pressure).
Toxicity
A waste is toxic if laboratory testing indicates that it contains a contaminant at a concentration
equal to or greater than (≥) the maximum acceptable concentration level given.
Medical / Biohazard - Medical waste classification and disposal requirements are defined by MOH
Regarding Medical Waste Disposal. The following groups of medical waste:
Group A – Bandages, dirty linen etc.
Group B – Used syringes and needles, surgical tools, broken glass etc. Group C
– Blood, tissue, and biological wastes.
Group D – Pharmaceutical waste and chemical wastes used for medical purpose. Group E – Human urine or
feces contaminated material wastes.
Group F – Radioactive medical waste.
Waste Electrical and Electronic Equipment (E-Waste) - Any electrical or electronic waste such as
fused light bulbs, fluorescent lights, discharged batteries or equipment which contain hazardous
chemicals will be classified as hazardous waste. Disposal will be as per specific waste
management plan for hazardous waste. All other E-Waste, such as computers that have been
replaced, will be recycled, if possible.
Concrete wash out

Management of concrete wash out into a lined pit with recovery and disposal of liquid, and
disposal/ reuse of residual concrete. The pit should be well maintained, free of damage and leaks.
Specific Wastes
Containers/Drums/Compressed Gas Cylinders
Any drums or containers that held a hazardous substance will be considered hazardous regardless
of the quantity of substance remaining in the drum or container. Any container or cylinder
awaiting disposal or being discarded that contains a hazardous compressed gas with a pressure
greater than atmospheric pressure, will be classified as hazardous waste. The contractor should
store used oils in secure bulk containers which are double skinned or have bunds of 110% capacity
Exceptions:
A container that has held any identified hazardous material, or any hazardous waste, spillage, or
residue, with the exception of acutely toxic substances, may be considered “empty” and therefore
non-hazardous if:
All contents have been removed using practices commonly employed (e.g. Pouring, pumping and
aspiration); and No more than 2.5 centimeters of residues remain on the bottom of the container;
or The residues comprise no more than 3 % by weight of the total capacity of the container, if the
container is less than 110 gallons in size; or The residues comprise no more than 0.3 % by weight
of the total capacity of the container, if the container is more than or equal to 110 gallons in size.
Note: Drum reinstates will be handled by means of the best practical environmental option.
Containers of unknown substances or residues require approval from the OSHE Practitioner or
their authorized representative before disposal.
Grit Blasting Material

Grit blasting may produce hazardous waste depending on the type, concentration, and quantity of
toxic or polluting substance in the waste material. Paint wastes containing heavy metals (i.e. Lead,
Zinc, Chromate, Organometallic Compounds, and/or Tri-Butyl Tin and Mercury) and some types
of abrasive blasting media used in grit blasting may generate hazardous waste. Any grit blasting
waste that contains any substance with exceeding concentration levels will be considered as
hazardous wastes and will be handled accordingly. Insulation
All insulations (i.e. pipe lagging, thermal insulation for boilers and heaters, etc.) will be monitored
by the OSHE Department or their authorized representative to confirm that the proper disposal
procedures are being followed. Any insulation that is found to contain asbestos or other hazardous
materials shall be removed and disposed of by a specialist contractor.
Spill Waste
Any spilled material that is, or contains, any substance that is classified as hazardous or that
cannot be identified will be defined as hazardous waste. This is inclusive of any containers used
for spill collection and all materials/substances that come into contact with the spilled hazardous
material (e.g. cloth, personal protective equipment [PPE], absorbent, plastic, soil, etc.) unless the
hazardous waste spillage and/or residue meets appropriate exemption criteria.
Plastic Waste
All plastic waste will be collected and stored in large sealable containers. This will help to prevent
windblown debris from polluting NEOM.
Waste (Hazardous Waste)

Wastes that are hazardous to public health and detrimental to the environment. These I include
materials that are flammable, corrosive, reactive, toxic, radioactive, infectious, or carcinogenic
(cancer causing).
• Explosive: substances and preparations which may explode under the effect of flame or
which are more sensitive to shocks or friction like dinitrobenzene.
• Oxidizing: Substances and preparations which exhibit highly exothermic reactions when in
contact with other substances, particularly flammable substances.
• Highly flammable liquid: Substances and preparations having a flash point below 21°C
(including extremely flammable liquids), or substances and preparations which may become
hot and finally catch fire in contact with air at ambient temperature without any application
of energy, or solid substances and preparations which may readily catch fire after brief
contact with a source of ignition and which continue to burn or to be consumed after
removal of the source of ignition, or gaseous substances and preparations which are
flammable in air at normal pressure, or substances and preparations which, in contact with
water or damp air, evolve highly flammable gases in dangerous quantities.
• Flammable liquid substances and preparations having a flash point equal to or greater than
21°C and less than or equal to 55°C.
• Irritant: non-corrosive substances and preparations which, through immediate, prolonged, or
repeated contact with the skin or mucous membrane, can cause inflammation.
• Harmful substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may involve limited health risks
• Toxic substances and preparations (including very toxic substances and preparations) which,
if they are inhaled or ingested or if they penetrate the skin, may involve serious, acute, or
chronic health risks and even death.
• Carcinogenic substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may induce cancer, or increase its incidence.
• Corrosive substances and preparations which may destroy living tissue on contacts
• Infectious substances containing viable micro-organisms or their toxins which are known or
reliably believed to cause disease in man or other living organisms.
• Teratogenic substances and preparations which, if they are inhaled or ingested or if they
penetrate the skin, may induce non-hereditary congenital malformations, or increase their
incidence.
• Mutagenic substances and preparations which if they are inhaled or ingested or if they
penetrate the skin, may induce hereditary genetic defects or increase their incidence
• Substances and preparations which release toxic or very toxic gases in contact with water,
air, or an acid.
• Substances and preparations capable by any means, after disposal, of yielding another
substance, e.g. a leachate, which possesses any of the characteristics listed above.
• Eco-toxic substances and preparations which present or may present immediate or delayed
risks for one or more sectors of the environment.
• Special Waste Special wastes are potentially dangerous industrial wastes that are not
categorized and regulated as hazardous waste. There are six categories of special waste
Cement kiln dust Mining waste
• Crude oil, natural gas and geothermal exploration and production wastes
• Phosphate mining and processing waste
• Fossil fuel combustion waste
Medical Waste
Waste generated by health care activities includes a broad range of materials, from used needles
and syringes to soiled dressings, body parts, diagnostic samples, blood, chemicals,
pharmaceuticals, medical devices, and radioactive materials. Medical wastes potentially expose
health care workers, waste handlers, patients, and the community at large to infection, toxic effects
and injuries, and risks polluting the environment. It is essential that all medical waste materials are
segregated at the point of generation, appropriately treated, and disposed of safely.
The medical waste shall comprise as below.
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 materials: These consist which are used for injections and sample collection. The needles
and syringes shall be put into a plastic, rigid and dedicated box labeled, 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 cartons and incinerated by
designated medical waste disposal subcontractor approved by government authorities.
The medical facilities should be inspected regularly to avoid these types of waste.
Sewage / Septic Tank / Waste Water

Sewage shall collect in septic tanks. The septic tank waste shall be disposed at the designated
approved disposal site.
Subcontractor Hazardous Waste Disposal Responsible.
Lead acid batteries, wet type Lithium and cadmium batteries shall be fully discharged. The
batteries shall be segregated, labeled, and transported for disposal by an accredited waste disposal
subcontractor.
Mitigation measures
• Maintain speed limit on site for equipment and especially machinery on windy days.
• It shall be checked that fine materials are not heaped up in places exposed to the wind.
• Earthworks shall be restricted to the strictly necessary in windy or very windy condition
• Establishment of feeding systems that provide material stockpiles since shortly height
• Moistening of material liable to produced dust.
• Site access roads must be cleaned in order to prevent accumulation of mud
• No spoil/overburden storage outside project boundaries Contaminated soil/sand
SAPAC will avoid the soil contamination. For disposal, the contaminated soil should be fill in
the plastic sacks and transported by authorized disposal subcontractor. NON hazardous waste
Domestic Waste are related to the residential and working area. This type of wastes contains.
Food waste Kitchen refuse Papers Plastic
Sewages i.e. sludge Disposal drink cans Aluminum cans Plastic glass Metal Scrap
Printer toner cartridges
Woods (Fly wood) using during foundations and carpentry work Pepsi and other cold drink cones
using during food in camp area
• Food waste
• Kitchen refuse
• Papers Plastics
• Disposal drink cans
• Aluminum cans
• Plastic glass
• Metal Scrap
• Woods (Fly wood) using during foundations and carpentry work cold drink cans using during
food in camp area
Waste Segregation
Waste Collection Skip
SAPAC will provide Waste collection skips according to the requirements. Waste Collection Skip
generally large in volume and metallic bins. These bins loaded and unloaded from the backside of
the waste collection vehicle.
This waste collection skips mostly use for: Class-II waste
Class-II waste
Waste collection skip should be clearly labeled for communication according to the classification
and in all the languages which can understand by the workforce like English, Arabic, and other
languages.
Waste Collection Bin

Waste collection bins are smaller in size. The plastic bin have light weight so easily can transfer
and easy for loading and unloading. SAPAC will provide these bins insufficient numbers in the
following locations.
Site offices Medical Centre Workshops Kitchen Camps
Biodegradable Kitchen waste, vegetables, fruits, flowers, leaves from the garden.
Class-III waste
Waste collection skip should be clearly labeled for communication according to the classification
and in all the languages which can understand by the workforce like English, Arabic, and other languages.
Waste Collection Bin
Waste collection bins are smaller in size. The plastic bin have light weight so easily can transfer and easy for
loading and unloading. SAPAC will provide these bins insufficient numbers in the following
locations.
Site offices Medical Centre Workshops Kitchen Camps
Biodegradable Kitchen waste, vegetables, fruits, flowers, leaves from the garden.
Non-biodegradable
Recyclable waste - Plastics, paper, glass, metal
Hazardous Waste
Condemned oil, waste from NDT operations (solid & liquid), hydro testing water (with inhibitors), paints,
chemicals, oil filters, pesticide containers, batteries, old med
None-Hazardous
Combustible Waste- Contaminated paper, packaging materials, garbage, trash etc. Do not mix different waste
Segregate the waste according to the classification and hazards Follow NEOM, and Saudi Government rules
and regulation during waste disposal. Waste Storage
Waste storage area should be designed to handle all waste types as Hazardous wastes,
non-hazardous wastes, infected medical waste, and special waste. All wastes must be stored in approved
containers to prevent.
• Accidental spillage or leakage
• Contamination of soils and groundwater
• Corrosion or wear of containers.
• Loss of integrity from accidental collisions or weathering.
• Waste containers should be recognized according to contents and different wastes should not
be mixed and waste containers should be in good condition. Therefore, the following
precautions shall be taken.
• Old and wrong labels shall be replaced with right and new ones.
• Containers shall be labelled in accordance with to waste type
• All labels shall be checked periodically and updated
• Containers are in good condition and are not leaking.
• Containers are appropriate and enough to the waste they contain; Appropriately sealed (e.g.
with a lid or bung) if required
• Containers are not emitting any harmful gases or generating heat.
• Non-Hazardous Waste Storage Area
SAPAC will use this dumping area as a waste’s storage area. Other non- hazardous wastes may be
as below, and these wastes are recyclable materials.
Ferrous metals (cans and scrap)
• Non-ferrous metals (aluminum, cables etc.)
• Plastic bales
• Wood
• Unrecyclable materials may be stored in a different zone in non-hazardous waste storage area
and Incineration of waste on site is not allowed. Non-hazardous wastes shall be reported
monthly with “Monthly Waste Report Form”.
• The waste storage area should be clearly marked with label or Signage. Temporary storage
area will also provide but these areas should have safe distance from the construction area.
• Fire extinguisher will arrange according to the fire type for storage area.
• Sufficient number of skips and barricaded areas will be provided at Places of waste generation
to facilitate safe and environmentally sound Temporary storage prior to collection and transfer
to waste storage Areas. All containers and barricaded areas to be clearly marked, according to
contents
• Exit and Entry access will provide for authorized personnel.
• The storage area will be readily accessible to collection vehicles Containers and storage areas
will be cleaned on a regular basis
• Waste m a t e r i a l will be removed to the disposal site at the earliest Opportunity to prevent
inventory build-up
Hazardous Waste Storage Area

All hazardous waste shall be stored in hazardous waste storage area. Any kind of hazardous waste
Incineration of waste on site is not allowed. All kind of waste identify keen fully comply
with NEOM standards. Hazardous wastes shall be reported with “Monthly Waste Report Form”.
• Hazardous storage area should be clearly marked with label and sign board Should be clearly
accessible for collection vehicles
• Fire extinguisher and other firefighting equipment’s should be provided if required.
• Have a safe distance from the site office and main construction area. Storage facilities to be
inspected regularly for leakage
• Exit entry should be controlled only authorized person can enter. Containers and storage tanks
to be constructed from a suitable/compatible material, to permanently contain the hazardous
waste, and will have an identification label.
• Spill kits and Spill absorber will provide when required drip tray and other spill control
equipment’s will also provide
• Containment curbs will be maintained around the loading and unloading area
• At the expiry of the storage time limit, the material will be transported/removed to a suitable
hazardous waste management facility
• Hazardous Solids All hazardous solid wastes shall be stored in hazardous waste area in an
appropriate container. These materials may be as below.
• Lead acid batteries
• Batteries
• Toner, PC etc.
The large vehicle batteries will be stored in suitable containers to prevent the leaking of acids. The
small batteries, toner, pc etc. will be stored in containers. These wastes will be stored while
alternative options for recycling are considered.
Hazardous Liquids
The following liquids will be stored at the Hazardous Waste Storage Area.
• Waste oils and lubricants
• Various types of chemical wastes
• Cleaning chemicals
• Fuels
Liquid wastes shall be transferred and bulked in the containers which are located in the
Hazardous Waste Area.
Contaminated Soils and Sludge

All contaminated soils and other solids shall be stored in designated area in hazardous waste
storage area. Sludges and tank bottoms contaminated with hydrocarbons will also be stored in
designated storage area which can prevent farther contamination to soil or ground.
Waste handling and transportation

SAPAC should make sure the safe handling and safe transportation of all types of waste. The
following are the minimum requirements for safe handling of the waste from construction
activities of the Project Site Development.
Non-Hazardous Waste handling

• Identify the waste and classified
• Mark the storage area and collection skips and collection bins
• Waste shall be segregated at the source,
• Start the collection on daily basis
• First collect in the designated bins and after transport to the waste designated area.
• Provide written communication by signage in English and other required language.
• Food waste to be removed to approved landfill within a period of not more than 3 days
from last collection day
• The waste should be transported outside by the approved sub-contractor. This removal
should be done on regular basis
• The waste shall not come outside from the collection vehicle or during transportation
Hazardous Waste handling

• Safety Data Sheet should be provided with all a hazardous waste.
• Clearly write the name and the hazardous nature of the hazardous waste on the container.
• All containers containing hazardous waste shall be marked and provide warning signage.
• Medical waste will be sterile and collected in proper containers.
• Waste oil to be properly collected and disposed of through an authorized waste operator.
• The hazardous waste removal record should be maintained. The workers which are
handling the waste should be trained
• Hazardous waste, such as waste oil and chemicals, will be removed and collected from the
construction site within a period of not more than 90 days from the last collection day.
• The waste collectors should wear appropriate personal protective equipment’s according to
the properties of the hazardous waste.
Waste Disposal
Waste treatment and disposal shall execute by SAPAC according to the following standards.
• The Environmental Representative is overall responsible for monitoring the disposal of
waste.
• The Environmental Representative should confirm that the waste disposal company is Saudi
Government approved and have valid licensed for waste transportation and waste disposal
process.
• The Environmental Representative should make sure that the Waste Manifest Form has
signed and completed by the related parties.
• The Waste Manifest Form should keep with waste company during the transport and this
need three copies
• One Copy with waste generator
• One Copy with environment representative
• One Copy with the waste transporter to the waste disposal facilities
• The Environmental Representative should confirm prior to transport that the waste Name
the quantity and other description should completely mentioned in the Waste Manifest
Form.
• All the related parties should Sign on the Waste Manifest Form.
• The copy of the Waste Manifest Form with transporter must return to the disposal facility
countersigned to ensure the safe disposal of the waste.
• The Environmental Representative should inspect the site for waste management.
• In t h e event that any hazardous waste is required to be exported, permission shall be
obtained from local authority
• Report all the incidents related to the waste.
• The Environmental Representative will not release the waste if there is concern about the
standard of segregation, transport, or destination of the waste.
• No waste will be disposed of or removed from the construction site without the knowledge
and approval of the Environmental Representative.
• The Environment Representative should also establish recommendation for the
management for good practices according to the NEOM procedures.
• Record all the waste transport from the Project Site Development.
• SAPAC will prepare monthly summary report for hazardous waste transfer and will submit
to NEOM environmental department.
Waste water management

SAPAC will comply all waste water generated on site during the construction.
All the Sanitary wastewater from the temporary SAPAC labor camp and offices and also during
the site activities will be collected to the holding or other required tank and then will transfer to
the waste water treatment plant.
The sanitary waste water shall not be mixed with industrial water or storm water collection
system.
All sanitary water from the offices, temporary camp and from the site areas of the Project Site
Development should be transferred to the waste water treatment plant for disposal. Should be
conduct inspections for the transfer pipes and sewerage to avoid the sanitary water leakage.
Maintain good housekeeping. Train and acknowledge the people to a report about the waste and
waste water leakage in their accommodation in the temporary camp.
9. Compliance Obligations
• Saudi Government Laws PME-Presidency of Meteorology and Environment (PME
- 2012) Regulations.
• International Body
• ISO14001:2015 -Environmental Management System Requirements with guidance for use.
• EPA-Environmental Protection Agency Rules and Regulations
• Environmental Impact Assessment (EIA)
• Preliminary Environmental Review (PER)
• Construction Environmental Management Plan (EMP)
Contractor Documents
• Contractor Environmental Management Plan Contractor Waste and Wastewater
Management
• Plan Contractor Site Safety Plan (CSSP)
• Construction Environmental Management Plan (EMP) SAPAC
Objectives, Targets and Plans

The company will establish measurable objectives and targets in relation to its EMS
performance.
• The established objectives and targets must be:
Consistent with the applicable policies.
Measurable.
Monitored and updated.
Effectively communicated to relevant parties.
• When establishing, reviewing and updating measurable objectives and targets, consideration
is to be given to:
Health and safety hazards/risks.
Significant environmental aspects and risks/opportunities.
Significant business or quality risks/opportunities.
Technological, financial and Operational and business requirements.
Products and services provided to customers.
The enhancement of customer satisfaction.
Views of stakeholders.
Legal and other requirements.
• Once measurable objectives and targets have been established, plans for achieving those
measurable objectives and targets are to be established.
• Performance in achieving each measurable objective and target is to be periodically
monitored during Management Review meetings
10. Legal and other requirements

SAPAC has identified and has access to legal, regulatory, and other requirements to which the
company subscribes. Procedure for identifying the requirements and the requirements themselves
are in place.
Applicable Documents
Activities related to this section are documented in legal and regulatory requirements procedure.
Summary of Procedure
The process of identifying the legal, regulatory and other requirements is developed in the following
phases:
• Identification of compliance programs, and preliminary research of activities that could potentiallybe
subject to environmental regulations.
• Management review to determine whether in-house expertise, and resources are sufficient to identifyall
applicable requirements by.
• Initial identification and documentation of specific laws, regulations and other requirements that apply
to site projects.
• Legal, regulatory and other requirements are documented in the legal compliance register, which will
be maintained by Environmental Manager.
11. NEOM Environmental Code of Practice for Construction

The following listed sources have been used to inform NEOM’s approach to developing this
environmentalcode of practice for construction.
• Saudi Vision 2030 Objectives (KSA Plan 2030);
• All relevant and applicable Saudi Arabian Laws;
• ISO 14001:2015 Environmental management systems — Requirements with guidance for use;
• International Finance Corporations (IFC) Environmental & Social Sustainability Performance
Standards (EPS);
o IFC Performance Standard 1: Assessment and Management of Environmental and Social
Risks and Impacts
o IFC Performance Standard 2: Labor and Working Conditions
o IFC Performance Standard 3: Resource Efficiency and Pollution Prevention
o IFC Performance Standard 4: Community Health, Safety, and Security
o IFC Performance Standard 6: Biodiversity Conservation and Sustainable Management of
Living Natural Resources
o IFC Performance Standard 8: Cultural Heritage
o IFC Environmental, Health, and Safety Guidelines: Environmental Air Emissions and
Ambient Air Quality
o IFC Workers’ Accommodation: Processes and Standards
• International best practice in construction environmental management; and,

• The "Saudi Aramco Sanitary Code - RT-Gl-151.006" document, Section SASCS-04: Food
Establishments and Section SASC-S-07: Camps and Communal Living Facilities.
Objective, targets and program
• SAPAC has establishes objectives, and targets to fulfil the policy, and improve the environmental
performance in areas related to significant environmental aspects, legal and other requirements, and
views of interested parties. Objectives are always maintained in areas pertaining to prevention of
pollution, and accidents
Summary of Procedures
The top management in accordance with site personnel recommends the selection of initial environmental
objectives, and targets for the project.
• On an ongoing basis, the Environmental Manger identify the need for new objectives, and targets, and
recommend the new objectives to the top management.
• Initial and new objectives and targets, and associated programs, are formally reviewed, and approved by
SAPAC’s top management before they are authorized for implementation on-site.
• Objectives and targets are documented in the associated objective & target management program
Objectives, targets and Management Program Form

Aspect Key Performance
Aspect Identification Objective Target Improvement Program
No. Indicator (KPI)
Compliance and
Environmental CESMP compliance on-site, daily
To achieve environmental close out rate
compliance on on-site, NEOM environmental
1. inspection score of at least 70% 01/2022 weekly score, near
environmental construction checklist, weekly
every week. miss, incident &
inspection. environmental performance report.
accident.
Environmental Manager /
Staff and workers should CESMP compliance on-site, TBT /
Environmental Coordinator to TBT / Training
have clear understanding Training with reference to scope of
2. deliver at least one (1) toolbox records with
on site specific 01/2022 works, site specific environmental
per week and one (1) training attendance sheet.
environmental issues. aspect & impact.
per month.
Zero spillage onto the bare Implementation & compliance of

No of incidents,
ground at active site / Zero spill onto the emergency spill response plan.
3. 01/2022 volume of spilled
maintenance area / equipment ground. Availability of spill kit. Provision
onto the ground.
parking area. of drip trays for containment.
Waste Transfer
Implementation & compliance of Notes (WTN’s)
Effective monitoring of waste Zero waste discharge / waste management plan, maintain record of removal
compliance for waste 01/2022 of waste transfer notes (WTN’s).
4. overflow on the ground. of all types of
collection, segregation, and Increase staffs, and worker’s waste.
disposal. awareness on waste minimization,
and disposal. TBT / Training
records.
12. Implementation & Operation

Resources, Roles, Responsibility and Authority
The top management in SAPAC is ultimately responsible for the implementation of EMS
system on-site, and for providing resources necessary to establish, implement and maintain the
system.
Top Management
For the purpose of the EMS system, the top management shall provide full responsibility to
implement, and maintain the EMS, and to show full commitment in implementing the EMS
system.
Organization – Responsibility
All departments within project site office are responsible for implementing, maintaining, and
supporting the EMS system.
List of personnel, who are responsible for providing resources for the project, and have overall
authority on-site.
Contact Details of Key Personnel

Role Name Contact Number
Project Manager Ali Soultan 059 471 9574
Admin Manager Walid Ghazi Alharbi 056 000 6311
12.1 Competence, Training and Awareness

SAPAC identifies training needs for the proposed road works, and provides awareness, and
environmental training to all levels. Training is provided to personnel whose work may create a
significant impact or risks. All training is recorded.
• Environmental induction, toolbox & training record
The environmental training and awareness program comprises the following topics
• Environmental training & general awareness;
• Communication of SAPAC’s policy to all levels;
• Distribution of procedures and work instructions; and,
• Training on emergency response plan.
• Environmental training is provided for those groups of personnel (specially servicing and
maintenance team) is associated with higher impact on environment or other present while or
after their work is done.
• Training programs are reviewed, and amended to address new design changes, and activities,
and in response to non-conformances identified through the system of corrective, and
preventive actions, and internal audit of the EMS.
T
o
p
Department Position
i
c
s
Scope of Spill Air Waste Terrestrial Chemical Noise & vibration
Works prevention & quality & management Ecology handling
- Env aspect & use of spill kit dust
impact emission
Jan, 2022 Feb, 2022 Jan, 2022 Feb 2022 Mar, 2022 Mar, 2022 Feb, 2022
Project Management Project Manager X X X X X X X
Storekeeper X X X X X
OHS Manager X X X X X X
Environmental Manager X X X X X X
Construction Engineers X
Foreman X X X X X
Laborers X X X X
Surveyors
Logistics Drivers / Operators X X X X X X
HS Male Nurse
E HSE l Safety Officers X X X X X X X
HSE Helpers X X X C X X
12.2 Communication
SAPAC site office maintains systems for communicating within the organization information
about the environmental issues, and maintains a procedure for communicating with external
interested parties. The procedure instructs in receiving, documenting and responding to relevant
communication.
Applicable documents
• Environmental induction, tool box talks and meeting
Internal communication is flows through:
• Weekly HSE / Environmental meeting is held to provide instructions and receive feedback of
environmental performance on site.
• Communication is undertaken in a number of ways, and will include, and not limited to the
following:
o Weekly team meeting;
o Internal letters;
o Email, and reports;
o Consultation with the workforce at TBT; and,
o WhatsApp communication among all departmental staff.
For external communication the following stakeholders are relevant through email, external
letters, and weekly progress meeting:

o NEOM (client);
o Ministry of defense;
o Suppliers; and,
o Baladiya (municipality).
• All incoming external communication regarding environmental issues are forwarded to the
Project Manager, and will be maintained.
12.3 Documentation & Control of Documents
Document Controller (DC) controls all documents related to the EMS to ensure that they are
reviewed, and approved by the project manager, and ensure that the current versions of
documents are available where they are required, to ensure that obsolete documents are
promptly removed, and otherwise to ensure integrity of documents.
• Control of Documents (through Aconex)
• Control of Records (through Aconex)
• Documents pertaining to the EMS management system comprise the following:
o Site specific EMS plan, CESMP, work instructions.
o Aspect / impact register.
o Training program and material.
o Environmental emergency and spill response plan.
• As applicable, documents are identified by their title, code number, date of issue, revision
level, and the issuing, and approval authority.
• Documents are reviewed for adequacy, correctness, and conformity with SAPAC’s policy
prior to issue and release. Changes to documents are reviewed, and approved by the same
function or department that approved the initial document, unless designated otherwise.
• Recipient of revised documents are instructed to remove, and destroy the old superseded
version of the document. Maintaining unauthorized files with superseded revisions of
controlled documents is prohibited.
12.4 Operational Control
SAPAC implement control measures to control activities associated with significant
environmental aspects. These operational controls include methods, systems, processes and
equipment to safeguard the environment, and the documented procedures, and the work
instructions.
• Safety data sheet
• Procedures
• Waste management plan / procedure
• Operational control is method, system, process, and equipment to safeguard the site activities
including other interested parties.
• Work instructions are established where their absence could lead to deviation from SAPAC’s
policy, objectives or targets, or could cause a significant impact on the environment.
• Inspection and/or maintenance programs are developed, and implemented for equipment,
machines and systems associated with significant environmental aspects and emergency
response programs.
• Particular attention is paid to hazardous waste management.
• Purchasing is controlled by specifying and communicating HSE requirements, and by
monitoring of supplier performance.
12.5 Emergency Preparedness and Response

SAPAC identifies potential accidents, and emergency situations, and develops appropriate
response plans for preventing, and mitigating associated environmental impacts.
• Environmental emergency response plan.
• Spill response plan.
• MR identifies potential aspect that cause impact and emergency situations, to include
hazardous materials, dangerous activities, and potential hazards created by outside forces.
• Each potential hazard is evaluated to determine whether emergency response plan is
warranted, and where relevant, appropriate emergency plan / procedure is developed.
• Environmental emergency response plan / procedure is documented. All personnel are made
aware of the procedure, and where they are located.
12.6 Checking
A. Monitoring and Measurement & Evaluation of Compliance
SAPAC monitors and measures performance of road construction activities that can cause a
significant environmental impact, and evaluates its compliance with applicable laws, and
regulations, and NEOM code of practice. Measuring, and test equipment used for verification of
environmental performance is calibrated, and properly controlled.
• Air quality & dust monitoring checklist.
• Noise monitoring checklist.
• Monitoring program.
• The system which are used for monitoring environmental performance with regard to
significant identified aspects, and for evaluating compliance with laws, and regulations are
documented monitoring sheet.
• Accidents, and other unsafe events are monitored through several means including reporting
systems.
Impact Indicator How to Monitoring Target

monitor frequency
Dust Dust Measures Daily NEOM-environmental
concentrations PM10, PM2.5 department limits or
by Haz Dust international limits
EPAM 5000
machine
Air quality Air Daily visual Daily NEOM-environmental
concentration monitoring department limits or
international limits
Water Water pollutant Daily visual for Daily NEOM-environmental
water department limits or
contamination international limits
Ground & Ground & soil Daily visual For each refueling, NEOM-environmental
soil contamination checks and servicing department limits or
activity international limits
Material Resource Monitor the Ongoing NEOM-environmental

resources conservation source of fill department limits or
materials (sand, international limits
gravel and
rock).
Noise Noise level, dB Short term (15 Daily NEOM-environmental
minute) noise department limits or
measurements international limits.
at site
boundaries to
ensure site is
meeting
maximum
permissible
noise levels for
construction
sites in KSA.
Terrestrial Desert animals Ensure Ongoing NEOM-environmental
ecology awareness department limits or
training for international limits.
encountering
Spiny-tailed
Lizard is
delivered to all
workers.
Workers Well-being & Audit worker’s Monthly NEOM-environmental

welfare health accommodation department limits or
to determine it international limits.
is safe and
hygienic
12.7 Non-Conformity, Corrective Action and Preventive action

• Accident investigation and reporting.
Non conformity corrective action
Corrective Action Request (CAR) is initiated and implemented to address EMS non-
conformances. Non- conformance is a deviation from the policy, procedure, standard,
instruction, and specification, legal and regulatory requirement or from any other requirement
which SAPAC established, or to which it subscribes.
• CARs assign the responsibility for handling, and investigating the non-conformance for
mitigating any impacts, and caused for implementing measures to prevent recurrence of the
non-conformance.
• Upon implementation of corrective or preventive actions, CARs are followed up to verify
that the action was indeed implemented, and that it is effective.
• CARs are initiated, documented, processed, and monitored.
• Accidents and/or Injuries are reported and documented.
12.8 Control of Records
SAPAC maintains environmental records to demonstrate conformance with legal, regulatory
and other requirements of ISO 14001:2004. There is a procedure for establishment, storage and
retention of records.
• Control of Documents
• Control of Records
All environmental records are maintained and under control of Document Controller to retain
through Aconex software system.
Following are the types of records maintained:
o Aspect / impact register
o Objective, targets and programme
o Weekly environmental performance report
o Emergency spill response plan
o External communication record
o Internal audit report
o Management review records.

• Storage locations and retention times for records are specified in the master list of forms.
• Regular back-ups are being performed to assure safe keeping, and retrieval of such records
during their retention periods.
12.9 Internal Audit

SAPAC periodically conducts internal audits. The purpose of the audit is to verify whether the
system conforms with stated requirements including ISO 14001, and whether it is properly
implemented, and maintained. Internal audits are conducted in accordance with an established
audit program
• Internal audit procedure
• All elements and activities of the EMS are audited at least twice a year. The actual frequency
depends on the status, importance and past conformance history of the element of activity.
• Internal audits are conducted in accordance with a documented internal audit plans
established by the MR.
• Non-compliance results of internal audits are reported using a Non-Conformity Report. The
form is used to document identified non-conformances, and for initiating and processing
related corrective actions.
• Results of internal audits are reported using an internal audit summary report. These results
are reported to the top management, and are discussed within the framework of management
reviews.
12.10 Management Review
A. Management Review
The top management conducts periodical reviews of the EMS. The review evaluates environmental
results, and performance of the EMS, and consider changes to policy, objectives, and other
elements of the system. The purpose is to ensure continuing suitability, adequacy, and
effectiveness of the EMS. The review is documented.
Top management reviews of the EMS are conducted at least once a year. Management reviews
consider (mainly but not limited to):
o Suitability of policy.
o Environmental performance compliance,
o Setting up objectives, targets, programmes for continual improvement,
o Adequacy of aspect-impact identification,

o Corrective and preventive actions,
o Follow-up actions from previous management reviews.
o Recommendations for improvement.
o The results of participation and consultation.
o Relevant communications from external interested parties including complaints.
• Results and conclusions of management reviews are documented in management review
meeting.
12.10.1 Internal Audit
SAPAC shall ensure that internal audits of the environmental management system are
conducted at planned intervals to:
• Determine whether the environmental management system conforms to planned arrangements
for environmental management including the requirements of this international standard, and
• Has been properly implemented and is maintained.
The procedure for an audit shall cover the following elements:
• Goals;
• Scope;
• Organization and resources;
• Planning and preparation;
• Activities during the audit;
• Report on conclusions, follow-up measures, and frequency.
13. ENV Training Matrix

SAPAC-NEOM ENV Training Matrix
14. Environmental Management of Change

Introduction
Contractors, over the course of a project, may need to change some aspect of project delivery. Changes to
project delivery may result in environmental impacts that are unforeseen and/or were not included in the initial
assessment. Such changes may affect compliance obligations, controls and conditions detailed in the relevant
Environmental Accord and Management Plans for the project. This procedure describes:
• the process by which project changes are triggered of change are identified
• The processes by which change is communicated to NEV for assessment
• the mechanism by which proposed project changes are assessed
Purpose
The purpose of this procedure is to describe the means by which Contractors and other Project
Entities ensure that changes to project execution plans are assessed. The
objectives of this procedure are:
1. To describe the types of events that may trigger a change that may affect the management of environmental
risks;
2. To describe how these changes are notified to Employer and NEV; and
3. To describe the actions that may be taken by Employer and subsequent requirements to be implemented
by Contractor.
Roles and Responsibilities

1. Contractor
a. Contractor shall ensure that all site activities, facilities and construction methodologies that deviate
from those originally presented at the ENVID Workshop and detailed in the Environmental Accord is
brought to the attention of the Proponent and PEC/PMC.
2. Employer
a. Employer shall ensure that all changes are assessed for feasibility.
b. Employer shall ensure that NEV is informed of proposed changes to project execution that deviate
from those originally presented at the ENVID Workshop and detailed in the Environmental Accord.
3. NEOM Environment
a. NEOM Environment shall review the proposed changes and, where acceptable, apply to update the
applicable Environmental Accords / Permits.
Management of Change (MOC) Request Form
NEOM Environment
Management of Change (MOC) Request Form
PART A: To be completed by CONTRACTOR
SECTION 1 - PROJECT DETAILS (To be completed by Initiator)
Project Name MOC Number
Contractor Name: MOC Initiator
NEOM Region MOC Initiation Date
Environmental Permit no.
SECTION 2 - MOC DESCRIPTION AND CLASSIFICATION (To be completed by Initiator)
Change Description:
Change Reason:
Construction Method Change Contract Change Order New Receptor Other Change Event or Trigger (Specify):
Change Category (Mark all that
apply): Change in Location, Facilities or
Contract Extension New Stressor
Access
Proposed Action:
SECTION 3 - MOC SUPPORTING DOCUMENTS (To be completed by Initiator)
Photographs Reports Method Statements Other (Specify):

Supporting Documents Attached
(Check all that apply): Engineering Drawings /
LUP (coordinates) Correspondence (Proponent, Authorities, etc.)
Sketches
PART B: To be completed by NEV

SECTION 4 - MOC APPROVAL STATUS (To be completed by NEV)
Change Reviewed: Yes No Review Completion Date:
Approval Status: Approved Rejected Approved with comments Assessment Required
Comments:
MOC Reviewer Name: MOC Approver Name:
Signature Signature:
Date Date

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Contract: NEOM Mountain Military Road Upgrade Contract No.

ENVIRONMENTAL MANAGEMENT SYSTEM

NEOM MOUNTAIN MILITARY ROAD UPGRADE

Work order No : 100322/009

Project : 1000322/009 Doc. No: 100322-SPC-ENV-PLN-00000

Issue for Ahmed Alnaima

12.1 Competence, Training and Awareness .............................................................................................. 37

• Construction of more than 1546 km idealizations of the main roads nationwide

1.2 Building Projects

Figure 1: Location and authorized extent of the proposal

Figure 2: Location of the new Laydown area

1.4 Current Scope of Work

1.4.1 Scope of Works includes but not limited to:

• Limited clearing, grubbing, stripping

Services during construction

Table 2: Project schedule overtime

4.1.1 Project Manager (PM)

4.1.2 Environmental Manager

• Environmental Managers manage the development and implementation of environmental

4.1.3 Emergency Response Coordinator

4.1.4 Spill Control Team

4.1.5 Security Team

4.1.6 All Personnel

Figure 3: Company Structure in NEOM and in the project

• Development of a best-in-class EMS to align with the requirements of international standards

6. Determining the scope of the Environmental Management System (EMS)

7. Environmental Management System

7.2.1 Actions to address risks and opportunities

Opportunities identified by the company may lead to:

The company will manage risk and opportunities as follows:

competence, communication, documentation and documentation control.

8.2 Dust & Odour

8.3 Surface Water Impacts

Spillage and leakage

• Construction machinery will be checked regularly.

• Onsite vehicle washing will not allow.

8.4 Land Clearing and Soil Waste

8.5 Flora and Fauna

8.5.1 Spiny Tail Lizard Prevention and Mitigation Measures

Mitigation Protection Measures

8.5.2 Potential Impacts

8.5.3 Ecological Procedure

• Criterion 1 - Genera, species, or subspecies that are critically endangered, endangered, or

Archaeology and Cultural Heritage Interests

8.5.4 Marine Ecology Impacts SAPAC adhere ESIA

8.6 Noise and Vibration Impacts

8.7 Traffic Impacts

8.8 Waste Management Impacts

8.8.1 Waste Classification

Non-Hazardous Industrial Waste - Any waste generated by industrial processes or civil

Concrete wash out

Grit Blasting Material

Waste (Hazardous Waste)

Sewage / Septic Tank / Waste Water

Waste Collection Bin

Hazardous Waste Storage Area

Contaminated Soils and Sludge

Waste handling and transportation

Non-Hazardous Waste handling

Hazardous Waste handling

Waste water management

Objectives, Targets and Plans

10. Legal and other requirements

11. NEOM Environmental Code of Practice for Construction