Non-Technical Summary Al Zour Refinery Project · 2021. 3. 9. · 5 Environmental Non-Technical Summary Al Zour Refinery French Saipem and South Korean SK. In addition to carrying

Non-Technical Summary

Al Zour Refinery Project January 2021

2 Environmental Non-Technical Summary Al Zour Refinery

Contents 1. INTRODUCTION ....................................................................................................................................................................... 4

Purpose and Content of the Non-Technical Summary (NTS) ..................................................................................... 4

Project Background ..................................................................................................................................................................... 4

Main aims of the project ........................................................................................................................................................... 6

Regulatory Context and Standards ....................................................................................................................................... 6

Environmental Impact Assessments ..................................................................................................................................... 7

2. PROJECT DESCRIPTION ......................................................................................................................................................... 8

Process Description ..................................................................................................................................................................... 8

Assessment of Alternative Sites ............................................................................................................................................. 9

Environmental Measures Incorporated in Al Zour Refinery ...................................................................................... 10

Air Emissions Abatement ................................................................................................................................................... 10

Wastewater Treatment, Reuse and Disposal .............................................................................................................. 10

Solid Waste Strategy ............................................................................................................................................................ 11

Noise Control and Abatement ......................................................................................................................................... 11

Odour Abatement ................................................................................................................................................................. 11

Environmental Stewardship ............................................................................................................................................... 12

Monitoring ............................................................................................................................................................................... 12

3. BASELINE CONDITION ........................................................................................................................................................ 13

Environmental Baseline Study ............................................................................................................................................... 13

4. NOISE ......................................................................................................................................................................................... 15

Noise Studies and Monitoring .............................................................................................................................................. 15

5. AIR QUALITY ............................................................................................................................................................................ 16

Air Emissions Studies and Monitoring ............................................................................................................................... 16

6. MARINE AND COASTAL ENVIRONMENT ..................................................................................................................... 17

Marine and Coastal Environment ........................................................................................................................................ 17

7. SOLID WASTES ....................................................................................................................................................................... 20

Non-Hazardous Solid Waste Generation, Handling & Disposal.............................................................................. 20

Hazardous Waste Generation, Storage and Handling ................................................................................................. 20

8. HAZARDOUS MATERIALS .................................................................................................................................................. 22


Hazardous Materials Management ..................................................................................................................................... 22

9. WASTEWATER......................................................................................................................................................................... 23

Wastewater Treatment ............................................................................................................................................................ 23

10. TRAFFIC ................................................................................................................................................................................ 25

Traffic Analysis and Transport ............................................................................................................................................... 25

11. ENVIRONMENTAL RELATED ASPECTS ...................................................................................................................... 26

Socioeconomics.......................................................................................................................................................................... 26

Assessment of Landscape and Visual Impacts ............................................................................................................... 26

Groundwater Monitoring and Contaminated Land ...................................................................................................... 27

Emergency Response ............................................................................................................................................................... 28

Decommissioning and Closure Management Plan ....................................................................................................... 28

Environmental Management System (EMS) .................................................................................................................... 29

Technical Safety .......................................................................................................................................................................... 30

Greenhouse Gases (GHG) ....................................................................................................................................................... 30


1. INTRODUCTION Purpose and Content of the Non-Technical Summary (NTS) This NTS provides an overview of the main environmental findings from the Environmental Impact Assessments (EIAs) and during the Engineering and Construction phases of the Project. The content of the NTS is summarised below.

• Section 1 introduces about the project background, Regulatory Context and Standards, and Project Environmental Impact Assessments

• Section 2 summarises the project description, Process Description, Assessment of Alternative Sites and Environmental Measures Incorporated of the project

• Section 3 briefs about the baseline conditions • Section 4 to 10 summarises environmental impacts • Section 11 provides the environmental related aspects

It is important to note that this NTS does not, and is not intended to, convey all the information relating to the aspects and impacts of the Project. Its intention is to present key information, describe the main findings and conclusions, enabling the reader to understand the significant environmental effects of the Project without needing to refer to the detailed assessments. Project Background Kuwait Integrated Petroleum Industries Company (KIPIC) is building a world class Refinery, the Al-Zour Refinery Project. Al Zour Refinery will encompass all the activities and facilities required to upgrade up to 615,000 barrels per calendar day of Kuwait crude oil to produce high value products and fuel oil. The Refinery construction started in October 2015, the actual progress of the engineering, procurement, and construction (EPC) phase is 95.71%. The first Oil in the Refinery is projected for 2021.

KIPIC has divided the ZOR into five discrete packages including: Package 1 – Main Process Units, Package 2 – Support Process Units, Package 3 – Utilities and Offsites, Package 4 – Tank Farm and Package 5 – Marine and Export Facilities.

The project was divided into five packages, in addition to the contract to rehabilitate the Al-Zour refinery land, the five project packages were distributed to four global joint ventures.

Amec (Wood) was awarded the front-end engineering design (FEED) and project management consultancy (PMC) contract for the refinery. The first package (major manufacturing units) is implemented by the alliance that includes the following companies Spanish Tecnicas Reunidas, Chinese Sinopec and Hanwha South Korea. The second and third packages (support and infrastructure services units) includes Fluor British Company, South Korean Hyundai and Daewoo also South Korean. The fourth package (tank farm) includes the Italian Saipem and the Indian Essar. For the fifth package (marine export facilities), the Joint Venture is South Korean Hyundai,


French Saipem and South Korean SK. In addition to carrying out preliminary work for the project land within a separate contract with the Dutch company Van Oord.

The Environmental Consultants actually working in Al Zour Refinery Construction and Pre-commissioning are registered environmental consulting firms and the Kuwait Environment Public Authority (KEPA) has certified it as Class ‘A’ environment consultants, the Consultants review the compliance with KEPA regulatory requirements and standards, KIPIC’s HSE guidelines, EIA requirements and procedures, develop and perform the Environmental Monitoring of the site and submit the Environmental Monitoring Report to KEPA.

The Environmental Consultants are:

• Package 1. Environment World Company (EWC)

• Package 2 and 3. Wataniya Environmental Services (WES)

• Package 4. Bureau Veritas (BV)

• Package 5. Environment Word Company (EWC)

In support of the construction of Al Zour Refinery, the laydown area is being used for the accommodation of construction workforce, laydown of equipment and materials, warehouses, and other construction support activities. This area is situated about 10 Km away in the North-Western direction of Al Zour Refinery. Figure 1 illustrates the Project location at Al-Zour area.

Figure 1: Project Location


Main aims of the project The main reasons and benefits from the project are the following:

• Providing a continuous and safe source to cover the needs of the Ministry of Electricity and Water in Kuwait from a fuel oil product with a low sulphur content (less than 1 percent).

• Production of high-quality petroleum products, in conformity with international specifications, with a view to exporting to world markets.

• Alignment with one of the environmental goals in the State of Kuwait regarding improving air quality by reducing sulphur oxide emissions from power plants, where the emission rate will decrease by 75 percent from the current situation.

• Refining Kuwaiti heavy crude oil with the aim of increasing economic returns, especially when implementing the second phase of the project through the production of high-quality petroleum products in the future.

• An alternative insurance for the Shuaiba refinery after its closure in terms of providing high-quality petroleum products.

• Positive and effective contribution to the economy of the State of Kuwait by contributing to the development plan and activating the role of the private sector by creating job opportunities in supportive businesses in the implementation and operation phases of the project.

• Adding investment attraction factors to the areas adjacent to the project for their economic advancement.

• Create new job opportunities for national employment. Regulatory Context and Standards Environment Protection Law No. 42 of 2014 amended by Law 99 of 2015 and its Executive Regulations are the prevailing environmental legislations in Kuwait which is covered in this report. Some Permits were based on previous applicable laws. The main applicable executive regulations issued by KEPA are:

• Decision No. 2 of 2015 for conducting Environment and Social Impact Assessment Study (ESIAS).

• Decision No. 5 of 2016 Executive Regulations on Chemicals Management. • Decision No. 6 of 2017 for Management of Hazardous, Medical, Municipal, Solid and

Sludge Waste. • Decision No. 8 of 2017 on the executive regulations for protection of external environment

from pollution. • Decision No. 12 of 2017 for Protection of Sea and Coastal Environment from Pollution

Decision No. 3 of 2020 on Executive Regulations concerning the Occupational Safety of Employees in all Establishments


• Decision No. 4 of 2020 on Air Quality, Noise, Temperature and Lightning in indoor environments.

• Decision No. 5 of 2020 Regulations related to Flaring/Burning of Gases to Protect Ambient Air Quality

For environmental guidelines not been developed yet for the state of Kuwait, accepted international standards are used (e.g. Canadian Soil Quality Guidelines for Environmental and human health).

In addition to KEPA Environmental legislation, the project is in compliance with KIPIC’s HSE guidelines, Project Procedures and EIA requirements and procedures.

Environmental Impact Assessments Finalizing the Front-End Engineering Design (FEED) in 2006, an independent Environmental Impact Assessment (EIA) process was performed following an Initial EIA submitted by KNPC in first week of May 2005 to the Kuwait Environmental Public Authority (KEPA) for the proposed project. EIA is a process undertaken for certain types of major projects, which are judged likely to have potentially significant environmental effects, it assesses the environmental consequences of a proposed development in advance, with emphasis on the prevention of unacceptable impacts. After this EIA the project has submitted different EIAs according to KEPA requests. Figure 2 shows the Project EIAs in Al Zour Project. Public consultation was not required by law.

Date Type Study Name Commissioned Author (s) 2006 Terrestrial Main EIA KNPC EWC 2006 Marine Marine EIA Study KNPC KISR &DNV 2008 Marine Disposal of Dredged Material KNPC WES 2013 Terrestrial Soil Remediation PMC EWC 2013 Marine Marine Outfall PMC EWC 2013 Terrestrial Update Main EIA Study KNPC EWC 2014 Terrestrial Soil Remediation Addendum KNPC EWC

2014 Terrestrial Solid Handling Pier & Small Boar Harbor Addendum KNPC EWC

2014 Terrestrial Borrow Area KNPC EWC 2014 Terrestrial Barge Dock KNPC EWC 2014 Terrestrial Laydown Area KNPC Napesco 2014 Terrestrial Traffic Analysis and Transport Planning Study KNPC & Louis Berger EWC 2014 Terrestrial Temporary Facilities KNPC EWC 2014 Terrestrial Access Roads KNPC & Louis Berger EWC

Figure 2: EIAs to KEPA. Al Zour Project


2. PROJECT DESCRIPTION Process Description The main purpose of the Refinery is converting crude oil into usable saleable products. The key product of the Al Zour Refinery is Low Sulphur Fuel Oil (LSFO). Other distillate products, Liquified Petroleum Gas (LPG), Naphtha, Kerosene and Diesel are also produced. The Al Zour design emphasises sulphur reducing process units such as hydrotreatment units and sulphur recovery units. There are no crackers or coke processing units (typical process units designed to produce lighter products) in Al Zour.

Figure 3: Overall Site Plan Al Zour


The crude oil will be received and stored on site and subsequently processed in crude distillation columns, separating them into constituent components, producing LPG, Naphtha, Kerosene, Diesel and LSFO.

The major process units are the Crude Distillation Units, Naphtha, Diesel and Kerosene Hydrotreatment Units, Atmospheric Residue Desulphurization Units and Heavy Oil Cooling Unit. Support Units include the Sulphur Recovery Unit, which remove sulphur as a saleable product from acid gas streams received from the upstream process units. After recovering part of it, virtually all the remaining H2S is converted in SO2 by the Tail Gas Treating Units before being discharge to atmosphere. Other support units are the Hydrogen Production Unit, Hydrogen Compression Unit, Hydrogen Recovery Unit, Saturated Gas Unit, Sour Water Stripper Unit and Amine Generation Unit.

Supporting facilities include low pressure, high pressure and gas flare systems, a wastewater treatment unit for various categories of industrial wastewater, stormwater and sanitary sewage, utility boilers, cooling water system, tankage, and marine terminals for both solid and liquid products.

Assessment of Alternative Sites Four Practicable Alternative Locations were studied for Al Zour and their environmental benefits Study focused on the following four locations:

1. Ras Al-Sabiyah 2. Shuaiba 3. Umm Al Heman 4. Az Zour

Weight Linear Summation Method (WLSM) was used to compare alternatives because it provides a structural basis on which comparison can be made. A conceptual model was developed involving the following four major issues: Air Quality, Marine Environment, Geology and Spatial Environment. Az Zour Area was considered the most suitable site. This is based on the availability of adequate space to accommodate all requirements for the Al Zour Refinery, less impact on ambient air quality for residential communities, and less potential impact to the marine environment, Sabiyah. Az Zour is also suitable for any future expansion of the Refinery.


Environmental Measures Incorporated in Al Zour Refinery The Al Zour Refinery has been designed to mitigate all environmental impact, and numerous environmental best practice measures and Best Available Control Technologies (BACT) have been incorporated. These are summarized below for ease of reference, after assessment of impacts has been conducted, additional recommendations are presented as appropriate to further mitigate impacts. Air Emissions Abatement Principal environmental measures regarding air emissions at the Al Zour Refinery include:

• BACT for combustion sources: high-efficiency furnaces, periodic stack performance testing, monitoring and analysis of fuel sulphur-content, fuel oil hydrotreatment to reduce fuel-bound nitrogen content and minimize generation of fuel NOx during combustion.

• BACT to limit NOx emissions: e.g. the hydro-treating process is expected to reduce the Nitrogen content in fuel oil by about 40-50%.

• BACT for sulphur recovery: Sulphur Recovery Units (SRU) with tail-gas treatment, designed to meet local regulatory standards as well as US EPA, New Source Performance Standards, and SRUs designed for stable operation and adequate spare capacity, process vents containing acid-gas routed to an acid-gas flare,

• BACT for flares will include minimizing number of flare stacks, designing flares for smokeless and low noise operation, monitor pilot flames, providing gap control on blanketing surge vessels to minimize need for flaring, selecting relief valves and control valves to promote leak-free operation, optimizing the sequencing of unit start-ups and shutdowns to avoid simultaneous flaring from different process units, and providing adequate flare gas recovery systems.

• Controlling fugitive emissions (e.g. VOCs) through measures such as: relief valves routed to flare, open-ended valves equipped with cap or second valve; pumps incorporating double mechanical seals, reciprocating and centrifugal compressors with venting to flare, closed process drains etc; and implementing a plant-wide Leak Detection and Repair (LDAR) Programme.

• Controlling storage tank fugitive VOC emissions via measures including double seals and pole wipers for floating roof tanks, and a robust seal inspection programme.

• Enclosing wastewater treatment system equipment in contact with hydrocarbons or odorous compounds where feasible.

• Wastewater Treatment, Reuse and Disposal Principal environmental measures regarding the treatment of wastewater generation at the Al Zour Refinery include:

• Zero Liquid Discharge (ZLD) of industrial and process wastewaters, and maximum reuse of all treated wastewater (e.g. irrigation water, washdown water, firewater make-up, boiler feedwater make-up, etc).


• BACT to include primary (corrugated plate interceptor, dissolved air flotation, and chemical treatment), secondary (biological treatment, sedimentation), and tertiary (final polishing to filter out remaining impurities) treatment.

• Separate handling of sour-water streams including sour water stripper unit (SWSU) to ‘strip off’ pollutants such as H2S, NH3 and hydrocarbons, with the SWSU overhead stream routed back to the SRU for sulphur recovery, and SWSU effluent to desalters, water recovery and reuse.

• Sanitary wastewater and storm water collection and treatment system. Solid Waste Strategy Principal environmental measures regarding solid waste generation at the Al Zour Refinery include:

• Implementing a robust waste handling and control strategy including segregating hazardous, non-hazardous, and incompatible wastes, secondary containment, etc.

• Minimizing waste generation through optimizing operations, ensuring maximum reclaiming, recycling, and recovering precious metals from spent catalysts by third parties.

• Using only KEPA approved waste transporters and disposal sites and implementing a robust waste consignment note (manifest) system.

• Applying sludge dewatering technology such as centrifuge or filter-presses to concentrate solids.

Noise Control and Abatement Principal environmental measures regarding noise abatement at the Al Zour Refinery include:

• Using mufflers and silencers for construction equipment, with vendors to target maximum equipment noise at 85 dB(A) at 1 metre distance.

• Providing high noise sources with sound-reducing enclosures, acoustical insulation, silencers, or other engineering methods to minimize noise.

• Including a hearing protection programme for personnel within the Al Zour Refinery overall HSE Management Programme.

• Conducting periodic noise monitoring surveys around individual process units and Refinery fence line.

Odour Abatement Principal environmental measures regarding odour abatement at the Al Zour Refinery include:

• A strategy to address odour nuisance conditions via the Al Zour Refinery EMS. • Focusing particularly on noxious odours and gas emissions from the wastewater treatment

facilities, process and support units, laboratory, chemicals neutralization, sewerage. • Using bulk containers to minimize emissions during drum unloading.


• Using low-emission components combined with a robust LDAR to minimize fugitive losses and associated odours.

Environmental Stewardship Principal environmental stewardship measures at the Al Zour Refinery include:

• Ensuring compliance with applicable international treaties and protocols • Avoiding the use of ozone-depleting substances (ODSs), asbestos containing materials

(ACMs) or products, and prohibiting the use of equipment containing Polychlorinated Biphenyls (PCBs).

• Operating Al Zour Refinery with energy efficiency measures to minimize emissions of Green House Gases (GHGs).

• Ensuring no chromium-based corrosion inhibitors are used for cooling water treatment. • Environmental Management System (EMS) certification to ISO14001.

Monitoring Principal environmental measures regarding air, water and groundwater monitoring include:

• Using Continuous Emission Monitoring Systems (CEMS) for main pollutants from stacks, providing readouts in the control room

• Applying area monitoring for hazardous pollutants such as H2S, and providing for ongoing ambient air quality monitoring

• Analyzing the sulphur content of fuel-oil or fuel-gas for the Al Zour Refinery. Use of LIMS (Laboratory information management system)

• Providing in-line sampling at all wastewater discharge points • Implementing groundwater monitoring wells at both upgradient and downgradient

locations around the process units, tank farms and Refinery fence line. An environmental philosophy was developed and used in the design of the Al Zour Refinery. The environmental philosophy is consistent with the stated goal of safeguarding the environment of Kuwait as well as with KPC HSSE Vision.


3. BASELINE CONDITION Environmental Baseline Study The following specialized studies were conducted as part of the background investigation, which were used to develop the baseline report:

• Land use • Water use • Demography and socioeconomics • Geology • Seismic characteristics • Hydrology (surface and ground) • Terrestrial and aquatic ecology • Coastal and marine environments • Air Quality • Meteorology • Noise Monitoring and Measuring

The key issues identified in the report are the following: The project site itself is a relatively undeveloped zone. The existing site consists of desert sand, sabkhas and sparse vegetation. Although much of the immediate surrounding area is undeveloped, the industrial plants of the Texaco Refinery and Al Zour Power station are located very close to the boundaries of the Refinery to the east and south respectively. There is a low population density in the general area of the site. Prior to construction starting there was village settlement located within the northeast portion of the Al Zour Refinery site. Private chalets are located to the north of the Refinery along Bnaider beach and to the South Khiran Area. The demographic and socio-economic survey revealed that commercial and residential buildings in the village on site (i.e. non-industrial buildings) were generally in a poor state of repair. The village was relocated as part of the Refinery development, and compensation has been agreed. The housing development (Al Khiran) that was under construction to the south of Az Zour power station has been growing to a mega planned community, the development incorporates many kilometres of waterways connecting with the Al Khiran estuary, broad canals were excavated into lowlands, and the spoil was used to build up the land for residential development. The geology of the site comprises Undifferential Ghar and Fars formation. The dominant sediment type in Al-Zour area are Calcareous sandstone, oolitic sand, fine sandy limestone and clayey sand.


For southeast Kuwait where the Refinery site Az Zour Site is proposed, there is no significant seismic activity, either currently or previously reported. The Refinery area is characterized by shallow ground water with water close to the surface. There are no major fresh water sources or sewage discharges in the Az Zour coastal area. The soil and groundwater investigation did not identify any significant contamination in underlying soils or groundwater. The terrestrial ecology survey concluded that the project area is typical of much of Kuwait. Flora and fauna were identified and recorded as part of the assessment. The project area is not considered as sensitive from an ecological perspective as in the northern region of Kuwait (e.g. Subiyah). The coastal survey showed that the area is covered with coarse to finely grained and medium sand. Finely grained sediments are found in the north-eastern corner of the study area. In general, the grain size of the sediment becomes finer offshore. Coral has been identified offshore. Water quality analyses during the coastal survey revealed that all parameters were within KEPA limits for both surface marine and bottom marine waters, except Total Suspended Solid (TSS) which is recorded to be slightly higher than KEPA sea water criteria, this is expected to be due to the temporary or local conditions prevailing in the nearby coastal regions. Ambient air quality monitoring was conducted at several locations around the proposed site, there was no violation of KEPA ambient air quality standards observed at the place and time samples were collected. The measured pollutant concentrations reflect the meteorological conditions at the time of sampling. It is expected that concentrations for some of the air pollutants sampled, particularly sulphur dioxide (SO2), could have been significantly higher had meteorological conditions placed passive samplers directly in the path of the power plant’s emissions. This is confirmed with reference to other studies because baseline sulphur dioxide levels are known to be high in the Az Zour area, and in fact, throughout much of Kuwait. Baseline noise measurements were taken at a variety of locations around the perimeter of the planned Refinery site. Monitoring was conducted during both day and night time and the measurements indicate compliance with the applicable KEPA noise criteria.


4. NOISE Noise Studies and Monitoring The main purpose of the Noise study was to evaluate the potential community noise impact due to the noise emissions from Al Zour Refinery. In the original EIA (2006) a noise prediction program was performed using SOUNDPLAN 6.2. Noise prediction were simulated for construction, normal operating conditions and start up and shut down with full flaring. The noise impact during construction and normal operation were predicted to be lower than the most stringent noise requirement promulgated by Kuwait regulatory authorities. In start-up and shutdown situation, even the results are over the regulated limits, equipment liability and redundancy ensure that large flare releases scenarios will be both extremely rare and of short duration, a plant wide power failure, very conservative scenario, that represent the maximum design load case for the flare system. The Refinery will be operated so the units start up and showdown events are controlled, and shutdown do not occur simultaneously, thus minimizing loads to the flare system. In 2013 a noise modelling study was performed using CUSTIC 2.0 software to estimate the dispersion of noise in the air. Noise modelling was carried out to study the general noise levels for two seasons (summer and winter), for the Refinery which will be operated in Al-Zour area. Major noise sources in the Refinery were identified from plot plan provided by KIPIC. These sources were placed, scaled and geo referenced on bitmap loaded into the program. The results of the model show borderline and adjacent areas at the Refinery site compliance with environmental noise limits. In general, the results of the model indicate that the noise levels in most areas of the Al Zour Refinery and its surrounding are less than the allowable limit of Kuwait EPA standards. As part of the Construction Quarterly Monitorings, the trend of Equivalent Noise Levels in different locations over the Al Zour Refinery fulfil the KEPA Community Noise limits for Industrial and Commercial Areas (Decision 8 of 2017 Appendix 1 - Table 5).


5. AIR QUALITY Air Emissions Studies and Monitoring As part of identifying and assessing the major sources of emissions to air from the Refinery, including both major continuous emission sources such as those from power plant, boilers, heaters, furnaces, flares and incinerators, and fugitive emissions (e.g. VOCs), the main EIA (2006) subjected the most significant ones to air quality modelling and assessment, using the Atmospheric Dispersion Modelling Software, Version 3.1 (ADMS 3). The dispersion model ADMS 3 was used to assess the effect of emissions from a wide range of industrial and process types such as power plant, boilers, heaters, furnaces, flares and incinerators, and a number of industrial source types. The parameters Nitrogen oxides (NOx) and Sulphur oxides (SOx) for Normal and Maximum scenarios were modelled, as the key parameters of concern to KEPA. It is considered that the modelling results demonstrate that the air quality impacts associated with the Al Zour Refinery at Az Zour are acceptable for the Al Zour Refinery will provide LSFO (i.e. 1% weight Sulphur) to replace the up to 4% weight Sulphur content fuel oil that is currently available and being used by the electric power generation industry in Kuwait. This will help enable the power industry to satisfy the KEPA ambient air quality criteria for SOx criteria both in the Az Zour area as well as in other parts of country. Al Zour Refinery emissions, considered both in isolation and when also considering emissions from the power station (including the power station extension), satisfy SOx and NO2 criteria at the Al Zour Refinery site fence for both normal and maximum emission cases. Al Zour Refinery emissions during emergency flare scenario, during upset conditions and on site from the tank farms areas satisfy relevant criteria. In 2013 an assessment methodology for the air dispersion modelling was performed that follows the guidance specified by the US-EPA guideline on Air Quality Models using the CALPUFF Air dispersion model. The different scenarios showed that in Al Zour normal operation the parameters Ground Level Concentration (GLC) are below the KEPA limits, Operation of Al Zour with Az Zour Power Plant showed that the GLC exceeded the KEPA limit mainly from the emissions of Az Zour Power Plant (Al Zour Contribution to GLC is only 9.4%), Acid Flares scenario showed KEPA limit fulfilment with adequate design and in Multipoint Ground Flares, since the emissions from ground flares are mainly during emergency situations the GLC’s were also compared to occupational exposure limit of KEPA and were found to meet the occupational limit. As part of the Construction Quarterly Monitoring, the trend for Ambient Air Data shows compliance with KEPA regulations. Specific parameters like Particulate Matter, Non-Methane Hydrocarbons, Sulphur Dioxide and Nitrogen Monoxide present exceedances in certain monitoring performed, these parameters were impacted by weather condition and emissions from Al Zour Power Plant (Decision 8 of 2017 - Tables 1 (a) and 1 (b)).


6. MARINE AND COASTAL ENVIRONMENT Marine and Coastal Environment The marine environment consists primarily of moderately well sorted, medium grained, oolitic sand within extensive sand–dominated channel. Carbonate contents of samples collected from a station in the study area were recorded to be high (72%). The tidal flat contains a muddier runnel located behind a ridge at the edge of the flats. The coastal profile of this area shows that the beach has a gentle slope of about 1:30. The area is covered with coarse to finely grained and medium sand. Finely grained sediments are found in the north-eastern corner of the study area. In general, the grain size of the sediment becomes finer offshore. Specialized marine site investigation was performed to undertake an extensive series of metocean, geotechnical and geophysical surveys on the marine environment including, sedimentation modelling studies, wave, wind, and current modelling. Several Environmental Documents were prepared and submitted to KEPA including Marine study to support Environmental Impact Statement, Environmental Impact Assessment Offshore Borrow Areas and Environmental assessment of dredged material disposal and development of Dredging management plan. Also, Environmental Studies where prepared for the Marine Outfall, Barge Dock and Heavy Haul Road, Solids Handling Pier and Small Boat Harbour, and Soil Remediation Baseline Water quality analyses undertaken revealed all the measured parameters are within KEPA limits for both surface marine and bottom marine waters, except total suspended solid which is recorded to be slightly higher than K-EPA sea water criteria due to the temporary or local conditions prevailing in the nearby coastal regions. The creation of increased suspended sediment concentrations within the water column is just an inevitable consequence of the aggregate dredging process. However, mitigation measures were in place to minimize this change to the physical environment. These mitigation measures focused on either seeking to reduce the increase in suspended sediment and minimising the area affected by the increase (see Figure 5 Silt Sea Curtains). Meteorological conditions were monitored using a Meteorological monitoring station installed on a temporary jetty. The measured parameters are Temperature, Barometric Pressure, Humidity, Wind Direction, Wind Speed, Tide level. The sea water monitoring works are carried out by 7 environmental monitoring buoys deployed on the sea (see figure 4); the locations were approved by KEPA. The parameters measured by the sensors on the buoy were Turbidity, Dissolved Oxygen, pH, Salinity, Conductivity and Water temperature. Every buoy had its own built data logger, kept in the main body of the buoy in a waterproof canister, the buoy recorded data on a time interval of every 15 mins, the data was transmitted to a receiving server with the help of the local internet. The buoys maintenance was done every 2 – 3 weeks during summer and every 4 – 5 weeks during winter.


Figure 4: Buoys Deployed at the Sea

During Construction, all physical parameters nutrients and heavy metals in seawater were generally within the prescribed standards of KEPA decision No 12 of 2017, Table 1, Seawater Quality Guidelines. The results of sediment analysis are compared with Consensus Based Sediment Quality Guidelines (CBSQG) developed by Contaminated Sediment Standing Team of Wisconsin Department of Natural Resources, published in 2003 (CCME, 1999) for heavy metals in sediments. Generally, the heavy metal concentrations except Nickel and Chromium all other are within prescribed standards. Exceedances of Nickel, Chromium and Arsenic concentration in marine (bottom) sediments are due to variations in natural background levels and not related to project activity. Exceedances of Nickel and Chromium were also recorded in previous studies, these levels as representative of natural variability rather than an anthropogenic source of pollution. The Benthic studies showed moderate abundance of benthic community. The phytoplankton community showed relatively common biomass per cubic meter in the study area, while zooplankton community, on the other hand, showed frequent biomass. The phytoplankton results indicated that the phytoplankton communities have improved and showed higher values compared to baseline data. The macro epi-benthic communities were surveyed show Mollusca, Polychaeta, Chordata, and Echinodermata as the most abundant marine phyla, followed by Cindaria and Crustacea. Porifera and Bryozoa showed the lowest abundance. The fish community


(Actinopterygii) showed similar numbers identified and counted in situ than baseline understanding that fish communities vary seasonally. Liquid wastes such as sewage from toilets, and solid wastes: domestic garbage including food wastes, paper and cardboard, plastics, other packaging, and medical wastes during construction were collected and returned to the Al Zour Refinery to be transported by KEPA authorized waste management companies. The Operational wastes like oil rags, machinery maintenance remains, broken parts, packaging also will be collected and transported to Al Zour Refinery within the waste management system.

Figure 5: Sea Curtain in Al Zour


7. SOLID WASTES Non-Hazardous Solid Waste Generation, Handling & Disposal Al Zour Refinery includes facilities for the temporary storage of non-hazardous wastes. Non-hazardous solid wastes generation include, but are not limited to, various resins, filters, membranes, and desiccants. The following criteria for handling and disposing of non-hazardous solid waste were implemented:

• Non-hazardous solid waste was segregated as much as possible to optimise the amount of material that can reused or recycled.

• Containers for storing various non-hazardous wastes were selected for the specific service intended and equipped with tightly fitting lids.

• Rubbish chutes and waste receiving areas were designed to prevent the spread of fire or discharge of airborne pollutants or odours. The chutes and storage areas were maintained free of debris and cleaned and disinfected on a regular basis. Bulk containers were readily accessible to collection vehicles.

• Permanent waste was transported and disposed by KEPA approved third parties. Hazardous Waste Generation, Storage and Handling The waste production was design to be reduced in quantity and quality by developing the technology which is used following clean technology and choosing alternatives of the product or raw materials that are less dangerous to the environment and public health. E.g. selection of non-ozone depleting substances in refrigerant and fire protection systems, use of non-asbestos containing materials for insulation and gaskets, and use of non-PCB containing transformer oils. Waste reduction techniques include return of spent catalysts to suppliers for precious metals recovery. Wastes are not transferred outside the site unless it is removed by an approved of Environment Public Authority Waste Company. Temporary storage in an environment friendly way was observed. Any contractor that produces hazardous wastes due to its activity do not deal with any waste carriers or storage, treatment, or elimination sites, which do not have an identification number from Environment Public Authority and necessary licenses from concerned authorities. Wastes are transferred to special sites determined by concerned authorities in the state. The Refinery is under an EMS that include a waste management plan. The waste management plan did incorporate the existing KIPIC waste management procedures and practices. The waste management plan is to ensure that appropriate waste management practices are followed in accordance with relevant prevailing national laws, regulations, and requirements regarding the protection and preservation of the environment. In addition, the waste management is review periodically by personnel working within the area of the Al Zour Refinery where waste is generated


related to operations and evaluate the available methodologies for reducing or eliminating those wastes. This includes recycling and reuse where feasible. Any hazardous waste generated such as un-used paints, thinners, oils, greases, acids, or corrosives have been collected in an appropriate storage location and placed in sealed drums prior to offsite disposal to a KEPA approved facility. Care was taken not to mix potentially incompatible materials. Firefighting, safety, and spill control equipment is be readily available, should an accidental discharge of hazardous material occur. In compliance with KEPA Decision No. 6 of 2017, KIPIC’s waste management plans and EPC waste management procedures, all the waste generated during construction activities were segregated and disposed of in approved KEPA disposal locations. The details of waste generation are submitted to KEPA in Environmental Monitoring Quarterly Reports.

Figure 6: Central Waste Accumulation Area in Al Zour


8. HAZARDOUS MATERIALS Hazardous Materials Management A wide variety of potentially hazardous materials will be used within the various systems that comprise the Al Zour Refinery. These include water treatment chemicals such as hydrochloric acid, sulphuric acid, caustic, chlorine, catalysts, and water conditioning chemicals such as corrosion inhibitors and oxygen scavengers. During the operations phase, Safety Data Sheets (SDSs) will be made available at the guardhouse, administration building, control room building, and chemical storage warehouse building. During construction, all hazardous material is stored and managed appropriately in storages located within each EPC Contractor controlled area. Materials within these areas are stored according to compatibility and all flammable materials are segregated and stored appropriately. All hazardous materials are contained within temporary or permanent secondary containment to prevent a release to soil or groundwater. Bunded areas have impermeable floors and bunds, including the chemical storage warehouse. During operation, the Al Zour Refinery will fully incorporate and comply with all KEPA HSE criteria including that for handling, treatment, storage, and disposal of hazardous materials. The appropriate handling and danger placards are displayed wherever hazardous chemical materials are handled, transported, or stored. Storage of hazardous chemicals were in accordance with the provisions of the KEPA regulations and KIPIC Guidelines. Hazardous materials storage during operation of the Al Zour Refinery will either be in fixed tanks (at various bunded locations on the site), in a compressed gas cylinder storage area or in a Chemical Storage Warehouse. The Chemical Storage Warehouse is likely to contain hazardous materials in bottles, pails, drums, bags, or similar containers. The design, construction and operation of this warehouse will be in accordance with KEPA licensing requirements as specified under Article No. 18 and the United Nations Classification System for separation of hazardous chemical materials. Category 1 explosive materials are not envisaged for the Al Zour Refinery. Typical safety features included in the Chemical Storage Warehouse includes firewalls to separate materials that are combustible, flammable, corrosive, or toxic including acids and alkalis. The Chemical Storage Warehouse floor has a chemical resistant coating, and impermeable kerbing will be used to provide secondary containment where needed.


9. WASTEWATER Wastewater Treatment Al Zour Refinery will require large volumes of water for cooling tower and boiler feedwater (BFW) makeup, as well as process usage, potable water and sanitation, and other Refinery services. KIPIC current plan is for as much of the Al Zour Refinery water demand to be met by wastewater recycling and reuse as possible, with the rest being supplied by the local desalination plant. The Al Zour Refinery design incorporate best environmental engineering practices such as Best Available Control Technology (BACT) to avoid, prevent or mitigate the discharge of all harmful emissions to meet (or exceed) applicable KEPA environmental standards. KIPIC proceed based on zero liquid discharge (ZLD) for the Al Zour Refinery. KEPA requires that all discharges to sea be 500 meters or more offshore. Although an outfall pipeline for offshore discharge will be provided as part of the Al Zour Refinery design, it will not exist during the early construction phase. Throughout the construction period no wastewater effluents have been discharged to the environment (either to land or sea) without first having been analyzed to verify compliance with all applicable KEPA discharge criteria. If sample analysis indicates that the water in the retention pond(s) is not of acceptable quality for discharge it is pumped back to the packaged wastewater treatment or collected via vacuum truck for transport to an appropriate wastewater treatment facility. An overall peak workforce of more than 60,000 construction staff (divided into four separate EPC contractor camps) was working in the Al Zour Refinery. Wastewater effluents are generated on a short-term basis because of the various construction activities associated with building the Al Zour Refinery, and its scheduled start-up and maintenance activities. These include sanitary wastewater, wash-down water, stormwater, water from groundwater de-watering activities, and wastewater from hydrostatic testing activities (i.e., from asset-integrity testing of pipelines and Storage Tanks etc). Hydrostatic test water with low levels of a proprietary biocide and corrosion inhibitors is collected or treated in the Refinery to ensure compliance with applicable KEPA discharge criteria. By definition, ZLD overcomes any environmental impacts encountered in discharging wastewater to the marine environment. However, during ZLD equipment downtime, discharge to the marine environment will occur from the observation basin. The Al Zour Refinery wastewater treatment system is being designed for continuous operation, using multiple process trains to provide suitable system flexibility. This will allow for downtime of any individual piece of equipment without a complete shutdown of the wastewater treatment system or violation of applicable KEPA discharge standards. Wastewaters of different characteristics will be segregated, and will be subjected to the level of treatment necessary to ensure maximum wastewater recycling (e.g. as


irrigation water for landscaping, washdown water, firewater make-up, boiler feed water make-up, and particularly cooling tower water makeup) - as part of the ZLD approach.

Figure 7: Wastewater Treatment Plant Al Zour


10. TRAFFIC Traffic Analysis and Transport In 2013 a Traffic Analysis and Transport Planning Study was developed for the traffic examination of the internal roads and access roads, the logistics behind the transportation of manpower and goods from the laydown area to the Refinery and the design of temporary and permanent roads and ancillary structures. The size of the manpower required to construct the Refinery implies that a large fleet of vehicles to access the Refinery site every day. The study undertook the design of the optimum transportation system that ensures that during construction and operation, people and goods move to or inside the Refinery safely and without delays. An iteration process followed consisting on the design of a series of mitigation options and their consequent evaluation. The mitigation options capacity was analyzed to evaluate the different alternatives based on levels of service, construction costs and constructability. Based on this evaluation, a preferred alternative was identified. The study recommended a 4-lane access road that will extend south from the north end of the laydown area, span over Route 40 on a temporary bridge and over Road 270 on a roundabout interchange and continue parallel to Route 40 to reach the roundabout that leads to the future Route 40 interchange #6. During construction, EPC access were processed via dedicated access roads that intersect the proposed Refinery access road at either small roundabouts or T-intersections. This alternative included the construction of a permanent bridge on Al Zour Power Station Road and a utility overpass. During the operational stage, while the bridge over Route 40 and access to the laydown will be removed, the temporary bridges over Road 270 could remain and used to provide alternative access to Route 40NB through an intersection North of Interchange # 5. Also, a new link from the Refinery Access Road to the proposed Interchange #5 on Route 40 could be added to provide access to the Refinery from Route 40 SB bypassing Road 270.


11. ENVIRONMENTAL RELATED ASPECTS Socioeconomics The proposed Al Zour Refinery have positive benefits on the regional employment market and local economy, due to the recruitment of more than 60,000 construction workers (at peak). In addition, there are positive benefits because of supply, maintenance, and service contracts to local businesses. In 2000, all the occupants of the Az Zour village were served notice to vacate the village and they had two years to clear the property. Each household was given rights to a new plot in the Al Khiran city that will be built west of the highway, and agreed financial compensation, which was settled. This approach to compensation follows the precedent set by the expansion for the power station for taking and using land for industrial use in this concession area. As such, the greatest social impact has already occurred before the start of construction. KIPIC was not involved in the relocation of the village North of Al Zour Refinery. The overall economic impact is positive, as this is one of the reasons for the development. As such, the focus is on the impact on local populations and other associated issues. Several Social welfare procedures have been developed by KIPIC to manage Social aspects including:

• KIPIC Environment & Social Guidelines for Contractors (KIPIC/HSE/ENCSR/19/1515) • KIPIC Environmental and Social Audit Guidelines (KIPIC/HSE/ENCSR/20/1513) • Environment and Social External Complaint Recording & Tracking Procedure for

Contractors (KIPIC/HSE/ENCSR/20/1517) • Social Incident Reporting and Investigation Procedure for Contractors

(KIPIC/HSE/ENCSR/20/1518) • Social Counselling Procedure for Contractors (KIPIC/HSE/ENCSR/20/1519)

Assessment of Landscape and Visual Impacts The proposed project falls in an expansive, flat low lying, costal landscape part of a promontory which juts into the Arabian Gulf. The project site land is mainly open desert scrub but also comprises a cemetery (the cemetery does not appear to be used for burials any longer). The project site is located on a plot of land, the majority of which is without any significant structures or buildings. The area is dominated by a large oil-fired electricity-generating power station, Al Zour, with twin stacks (192 m high). This power station is being expanded to double in capacity. Al Zour power stations are adjacent to the Al Zour Refinery and to the south east of the project area. Adjacent and east of the Al Zour Refinery is a Texaco oil storage facility and associated pipeline and small port facilities, with beach chalets located on the coast side. Further houses are located northwest


of the Al Zour Refinery project site, spread out along the coast. Nomadic farmers occasionally use the land around the site and use the vegetation to feed their livestock. The nature and scale of the Al Zour Refinery is partly compatible with the site context due to the adjacent power-plant (due for expansion) and near-by oil storage facility. The height and scale of the proposed structures are also compatible with surrounding industrial structures although the size of the Al Zour Refinery will be larger and emphasize the industrial character after construction. Receptors at long distance will consider the proposed Refinery in context with the existing industrial developments adjacent to the site. The proposed project is set in context with adjacent industrial areas where the visual environment is dominated by the Al Zour power station and oil storage facility, both to the east. Local observers will be potential visually impacted by the new development, although the village was relocated prior to development of the Refinery. The impact of the Refinery on the desert landscape surrounding the site is minimised due to the development being adjacent to the Al Zour power station and industrial areas to the east. Impacts on landscape character are therefore minimised. Groundwater Monitoring and Contaminated Land During the monitoring period variations from the initial conditions carried out in November 2016 were noticed. These variations might be due to Sabkha flat below the construction site and laydown area, and seawater intrusion at construction site due to its closeness to coastline. Additionally, there are no specific sources of contamination at the site that can contribute to these variations in groundwater. Contractor is also following approved Environment Management Plan for the construction phase which assures that there is no leaching to groundwater from construction works. During construction, different monitoring wells were built to extract groundwater both on site and laydown area, the water analyzed do not show important variations compared to the groundwater baseline. In addition, during operation a groundwater monitoring well system will be installed around the process and tank farm areas will provide a further means for monitoring contamination at the Al Zour Refinery Site. These wells shall be located so that representative samples of the groundwater that may be impacted by operation of the proposed facility can be obtained. Placement of the wells will include a minimum of one up-gradient location and two down-gradient locations. The tank farm area shall be regarded as a single unit. A minimum of two up-gradient and five downgradient groundwater monitoring wells will be installed along the perimeter of the tank farm. Down gradient wells will be located no more than 500 meters apart.


Emergency Response KIPIC is committed to the safety of its employees, installations, and society. All applicable safe standards, procedures and best practices are followed during process selection, design, construction, and operation of various facilities. However, even with the best safe working practices, emergency incidents may and do still occur. Therefore, in that sense the Al Zour Refinery has an adequate level of Emergency Preparedness to deal with any such incident effectively and efficiently, thereby minimizing the consequences. Emergency Preparedness comprises of the following integral components:

• Prevention and mitigation: to eliminate or reduce the chances or lessen the effects of an emergency, for example, by adopting safe design, operating and maintenance practices.

• Emergency plans: written procedures and guidelines on how to respond efficiently and effectively, with the right resources and trained personnel, should an emergency occur.

• Response: activities immediately following the alert or disaster. • Restoration: returning all used and affected systems and services to normality as soon as

practicable after the emergency has been resolved and any adverse impacts mitigated. KIPIC has developed and implemented a Major Incident Procedure Plan (MIPP) for its refineries. The MIPP provides a procedural framework for responding to emergency incidents such as fire and flammable or toxic releases and has been approved by the appropriate Kuwaiti authorities. KIPIC MIPP, the principal features of which have been described above, has enabled a similarly stringent Emergency Response Plan to be implemented for the Al Zour Refinery, and ensures that KIPIC will apply a unified and collective KIPIC approach to responding to emergencies at all its installations - including the Al Zour Refinery eventually - and other associated facilities (eg oil terminals). Such an Emergency Response Plan (based on KIPIC’s MIPP) for the Al Zour Refinery.

Decommissioning and Closure Management Plan KIPIC will develop a full conceptual Decommissioning and Closure Management Plan (DCMP) for the Al Zour Refinery which will involve consultation with KEPA, plus local community consultation as closure planning progresses. There are likely to be three project stages which decommissioning of the Al Zour Refinery will go through: pre-decommissioning consents and contracts; decommissioning activity obligations; and post-decommissioning responsibilities. Specific environmental-related decommissioning and closure objectives associated with the Al Zour Refinery are predicated around meeting all Kuwaiti legal and regulatory requirements (including KEPA criteria), and mitigating any impacts (environmental, public health, safety, social) within the impact vicinity of the site.


In addition, the final goal of a successful eventual decommissioning of the Al Zour Refinery must be to ensure that any post-closure site maintenance is so far as possible removed, and to mitigate any long-term environmental-related liabilities. Elements such as these in establishing an ongoing DCMP for the Al Zour Refinery, will send a robust signal that post-closure, the Al Zour Refinery will be optimally decommissioned, prior to handover back to the state or private use. Environmental Management System (EMS) At this stage of the project, the EPC contractors have certified EMSs in place, covering their own operations. KIPIC is working on an EMS, in line with the requirements of ISO14001, that will be similarly implemented for the Al Zour Refinery. As a tried and tested system, it will provide the same structured approach for the optimum management of environmental issues at the Al Zour Refinery. The principal mechanism by which this will be done is through KIPIC Manual. As part of the HSE Management System, KIPIC has developed specific procedures related to Environmental and Health including:

• Procedure on Air Pollution Monitoring and Control (KIPIC/HSESF/SYSEN/18/1507) • Procedure on Monitoring of Wastewater Treatment and Disposal

(KIPIC/HSESF/SYSEN/18/1501) • Procedure for Solid Waste Management (KIPIC/HSE/ENCSR/20/1509) • Environmental & Social Impact Assessment (EIA) Procedure (KIPIC/HSE/ENCSR/20/1510) • Procedure for Identification and Evaluation of Environmental Aspects

(KIPIC/HSE/ENCSR/20/1511) • Management of Energy and Resources Procedure (KIPIC/HSESF/SYSEN/18/1505) • Environmental Guidelines During Shutdown/Start-up (KIPIC/HSESF/SYSEN/18/1504) • Guideline on Management of Wildlife Habitat (KIPIC/HSE/ENCSR/20/1502) • Guidelines for Handling of Sludge (KIPIC/HSE/ENCSR/20/1506) • Spent Catalyst Management Guideline (KIPIC/HSE/ENCSR/20/1503) • Environmental System Objective and Target (KIPIC/HSESF/SYSEN/18/1508) • Guidelines for Soil Contamination (KIPIC/HSESF/SYSEN/18/1512) • Personal Protective Equipment and Respiratory Protection Program

(KIPIC/HSESF/HE/19/001) • Occupational Health Management (KIPIC/HSESF/SYSOH/18/1601) • Chemical Hazard Management Procedure (KIPIC/HSESF/SYSOH/18/1602) • Office Ergonomics (KIPIC/HSESF/SYSOH/18/1603) • Indoor Environment Quality Management (KIPIC/HSESF/SYSOH/18/1604) • Noise Exposure control & Management (KIPIC/HSESF/SYSOH/18/1605)


Technical Safety As part of Process Safety, all EPCs have carried out Hazard Identification (HAZIDs), Hazard and Operability (HAZOPs) and FSA (Fire Safety Assessment) studies in identifying process hazards in their respective designs followed by Quantitative risk assessment (QRA) for likelihood and consequences of these hazards, considered credible accidental events, to ensure that the Al Zour design overall is robust that all hazards are manageable, risks emanating are ALARP (as Low As Reasonably Practicable) and meet the risk acceptance criteria set for the Al zour Development individual (plant worker) and societal risks (third party). Safety Integrity Level (SIL) classification and verifications have been specifically carried out of safety critical systems taking into consideration system redundancy in identifying minimum performance requirements for Project development. These were assessed in the form of probability of failure on demand. FWDA (Firewater Demand Assessment) throughout process units have been carried out to identify firewater requirements during a fire hazard for extinguishing and cooling purposes of process inventory and load bearing structure, manned facilities etc. and in sizing firewater pumps and firewater tanks. This was followed by Hydraulic Analyses (HA) in establishing velocity and pressure profiles through the firewater network and at each delivery point in compliance to Project Design Engineering Specs and Codes such as SHELL DEP and NFPA. Buildings fire safety has been extensively addressed with safety design measures rigorously applied for detection, prevention, control, and mitigation of building fires. Greenhouse Gases (GHG) The challenge of balancing energy supplies to meet growing global demands, while concurrently considering associated environmental impacts, is leading to an ever-increasing focus on greenhouse gases (GHG) emissions and their potential mitigation. Petroleum refineries are complex facilities with hundreds of thousands of sources of air pollutants including greenhouse gases (GHG), the vast emissions of these atmospheric pollutants pose a great concern to global communities due to their contributions towards global warming, the primary GHG emitted by the petroleum refining industry are carbon dioxide (CO2) and methane (CH4). In addition to the combustion-related sources (e.g., process heaters and boilers), there are certain processes, such as hydrogen production units, and sulphur recovery plants, which have significant process emissions of CO2. Methane emissions arise from process equipment leaks and crude oil storage tanks. Flaring of waste gas also contributes to the overall CO2 and CH4 emissions at the refinery. In Al Zour Refinery proven and efficient design measures were incorporated as per industry and operating practices to minimize the generation and release of greenhouse gases (GHGs). In operation GHG emissions will be reported annually.