environmental and social management plan liban …

ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

LIBAN LAIT INDUSTRIAL FACILITY

ESMP REPORT

22 February 2019

LEPAP Environmental and Social Management Plan

Liban Lait

February 2019 Page i

ABBREVIATIONS AND ACRONYMS

ASL Above Sea Level CIP Cleaning In Place EIA Environmental Impact Assessment EA Environmental Audit EHS Environmental, Health and Safety ESA Environmental and Social Assessment ESMP Environmental and Social Management Plan GRM Grievance Redress Mechanism HR Human Resources L Liters LEPAP Lebanon Environmental Pollution Abatement Project m2 Square meters m3 Cubic meters MoE Ministry of Environment MoEW Ministry of Energy and Water MSDS Material safety Data Sheets NOx Nitrogen Oxide O&M Operation and Maintenance PPE Personal Protective Equipment PVPP Polyvinylpolypyrrolidone SES Social and Environmental Standards

SESP Social and Environmental Screening Procedure WB World Bank WWTP Wastewater Treatment Plant


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TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS .................................................................................... i

TABLE OF CONTENTS .........................................................................................................ii

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

1.1 OVERVIEW ................................................................................................... 4

1.2 THE OBJECTIVE OF ESMP .......................................................................... 4

1.3 BRIEF DESCRIPTION OF THE INDUSTRY .................................................. 4

1.4 DESCRIPTION OF THE WORKFORCE ...................................................... 10

1.5 GRIEVANCE REDRESS MECHANISM FOR WORKERS ........................... 11

1.6 GRIEVANCE REDRESS MECHANISM FOR AFFECTED COMMUNITIES . 12

1.7 Social Impacts ............................................................................................. 12

1.7.1. LEBANON LABOR LAW .............................................................................. 12

1.7.2. HEALTH AND SAFETY PROCEDURES ...................................................... 12

1.8 MAIN ENVIRONMENTAL IMPACTS ............................................................ 14

2 SUB-PROJECT DESCRIPTION .............................................................................. 16

2.1 WASTEWATER QUANTITIES AND SOURCES .......................................... 16

2.2 PROJECT COMPONENTS AND DESIGN FEATURES ............................... 20

2.2.1 Existing Infrastructure ...................................................................................... 20

2.2.2 Foreseen Treatment ........................................................................................ 21

2.3 SUMMARY OF ENVIRONMENTAL AND SOCIAL LEGISLATIONS

RELEVANT TO WASTEWATER TREATMENT ........................................... 24

2.4 SCREENING OF THE PROJECT AND APPLICABLE WORLD BANK (WB)

SAFEGUARD POLICIES ............................................................................. 27

3 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ....................................... 31

4 ENVIRONMENTAL AND SOCIAL MONITORING PLAN ......................................... 44

5 EMERGENCY PREPAREDNESS AND RESPONSE PLAN .................................... 50

6 STAKEHOLDERS MEETING .................................................................................. 52


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Table of Figures

Figure 1 : Liban Lait - Location of Plot No. 762 (1/20,000) .................................................... 5 Figure 2 : Liban Lait – Haouch Snaid (Google Earth Satellite Image) .................................... 5

Figure 3 : Liban Lait – Boundaries of Plot No. 762 (Google Earth Satellite Image) ................ 6

Figure 4 : Liban Lait - Location and Surroundings of the Dairy Processing Plant ................... 6

Figure 5: Liban Lait - Location and Surroundings of the farm ................................................ 7

Figure 6: Process Area at Liban Lait ..................................................................................... 9

Figure 7: Portable Fire Extinguishers and Fire Hose Reels at Liban Lait ............................. 14

Figure 8: PPE worn by workers at Liban Lait ....................................................................... 14

Figure 9: Silage Moisture Drained in Open Trenches ......................................................... 17

Figure 10 : Existing wastewater treatment infrastructure (in yellow the location of the existing

ponds, in red the location of the planned WWTP) ............................................................... 21

Figure 11: Flowchart of the treatment steps ........................................................................ 22

Figure 12: Consultation meeting for the ESMP of the WWTP, Liban Lait, 13 June 2018 ..... 53

List of Tables

Table 1: Liban Lait Employees and working shifts ............................................................... 10

Table 2: Wastewater Sources per production line in Liban Lait ........................................... 16

Table 3 : Wastewater Quantities and Sources at Liban Lait ................................................ 17

Table 4 : Maximum Allowable Limits for Wastewater Discharge into Surface Water ........... 18

Table 5 : Available Wastewater Measurements results during the auditing process ............ 19

Table 6: List of legislation relevant to the sub-project .......................................................... 25

Table 7: List of Attendees of the Consultation meeting held at the Liban Lait ...................... 52


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1 INTRODUCTION

1.1 OVERVIEW

An Environmental Audit (EA) of the Liban Lait industrial facility was financed through a fund

granted to the Ministry of Environment (MoE) from the IDF/Improve Capacity for

Environmental Compliance Project under the activity “Supporting Industrial Pollution

Abatement in Lebanon III” (Contract No. FC002).

The EA report was submitted to the Ministry of Environment for review and was approved

through the letter No. 1544/B Dated 19 March 2018.

Wastewater resulting from the Liban Lait plant located in Hosh Sneid Cadastral District

(Baalbeck, Bekaa) is currently directly discharged into a nearby water stream which

eventually discharges into the Litani River after a preliminary separation of the solids from

the liquid stream. As part of its obligations towards the national legislations, Liban Lait is

required to treat its effluent prior to its discharge into the nearby water stream.

In order to achieve environmental compliance in terms of wastewater discharge, Liban Lait is

currently keen to implement an industrial wastewater treatment plant (WWTP) and is seeking

financing under the Lebanon Environmental Pollution Abatement Project (LEPAP).

This document is an Environmental and Social Management Plan (ESMP) submitted to the

LEPAP, which pertains to the WWTP to be implemented at Liban Lait industry.

1.2 THE OBJECTIVE OF ESMP

The WWTP foreseen to be implemented at “Liban Lait” is a category II subproject according

to the ESA of LEPAP and the World Bank OP 4.01., hence an ESMP is required.

In fact, the overall objective of the ESMP is to assist in minimizing the impacts to the

environment and surrounding communities and reach a set of environmental and social

objectives. The ESMP ensures that the environmental and social objectives of the projects

are met through monitoring in order to avoid or mitigate adverse effects on the environment

and the population.

The ESMP is compiled based on the environmental audit report prepared in accordance with

Lebanese environmental laws and guidelines, the World Bank Safeguard Policies and

similar projects best practice.

1.3 BRIEF DESCRIPTION OF THE INDUSTRY

Liban Lait Plant is located on plot No. 762 of Hosh Sneid Cadastral District (Caza of

Baalbeck, Mohafaza of the Bekaa) in an industrial zone, at an altitude of 1,015 m above Sea

Level (ASL). The industrial facility is surrounded by adjacent agricultural lands, few

residential units and a military compound.


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The total allocated site area amounts to 30,000 m2 for the processing Plant and 60,000 m2

for the farm. The Main Products are dairy products (Fresh and pasteurized Milk, Skimmed

Milk, Yogurt, Ayran, Labneh, different types of cheese), Juices, Plastics (HDPE containers

for yogurt and PET bottles for Ayran) and Fertilizers from manure.

Figure 1 : Liban Lait - Location of Plot No. 762 (1/20,000)

Figure 2 : Liban Lait – Haouch Snaid (Google Earth Satellite Image)


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Figure 3 : Liban Lait – Boundaries of Plot No. 762 (Google Earth Satellite Image)

Figure 4 : Liban Lait - Location and Surroundings of the Dairy Processing Plant


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Figure 5: Liban Lait - Location and Surroundings of the farm

The main production processes of Liban Lait can be summarized as follows:

Farm Process (Raw Milk and Manure) and skimmed Milk, with a total annual capacity

of 750,000 L

The farm has 1,256 dairy cows, 1,065 heifers (1-22 months) and between 50 to 100 calves

(3 months), which are distributed into 4 hangars. The dairy cows are milked mechanically.

The milk is transported in stainless steel pipes and stored in stainless steel tanks. The milk is

also refrigerated (4-50C) during the storage time for 72 hours maximum. As the milk reaches

the production facility, it is tested to check the microbial and chemical parameters on a daily

basis upon every delivery, then it is cooled to 4~5 ºC. Washing and cleaning of cows takes

place by using the reject reverse osmosis water and untreated water.

The skimmed milk is produced in the same way as the UHT milk but it is fat free,

wherein, in a first stage prior to the pasteurization stage, the raw milk is entered into a

separator that skims the fat. This fat that is collected goes to the cream processing unit

(located in the process area) where centrifugation occurs and the skimmed milk is then

pasteurized with UHT technique by heating it at 140 °C (275 °F) (the temperature

required to kill spores in milk) for 3 to 5s. The last stage includes steam sterilization of

the milk to extend its lifetime before bottling (multilayer cartoon bottles). The fat is re-

injected in other production lines (i.e. fresh and pasteurized milk).

Yogurt, with a total annual capacity of 330,000 L

The cooled milk is pasteurized under 95 ºC for 5 minutes and then taken to the cream

separator where the cream is separated from the milk. The collected cream is taken to

the cream processing unit and the remaining milk goes to the homogenization unit and

then cooled to 45ºC. After cooling, bacterial cultures are added to the milk to initiate the


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fermentation process, then it is directly filled in plastic containers (5 Kg, 1 Kg, and 2 Kg).

The containers are transferred to the storage rooms while a temperature of 45˚C is

maintained till the pH reaches 4.85. At this stage, the product inside the containers

becomes harder and it is moved to the refrigerator at 3˚C. Two hours later, the yogurt is

ready and stored.

Ayran, with a total annual capacity of 560,000 L

After the process of producing yogurt as per the above, water, salt and whey are added to

yogurt and stirred. The liquid mixture is then filled in plastic bottles and refrigerated when

stored. Out of specifications products are used to produce Chanklish. There is not a

standalone production line for Chanklish. The Chanklish production is done manually where

salt, pepper and spices are added to the out of specifications products. The output is left for

fermentation for about 8 hours before being packed.

Labneh, with a total annual capacity of 200,000 Kg

The cooled raw milk is pasteurized under a temperature of 95˚C for 5 min and then cooled to

45˚C, further to which yogurt starter culture is added to initiate and enhance fermentation.

About 2h30min later, the pH reaches 4.85. The content is then cooled to 37˚C with shaking.

After this, the content is cooled to 5˚C till the next day (20 hours). Water and salt solution

(2%) are added to the cooled yogurt and transferred to strained bags to begin mechanical

dripping to finally produce and pack Labneh. The left over whey is then taken as it is and

used for Ayran, calves fodder and cheese process.

Several kinds of cheese, with a total annual capacity of 224,000 Kg

- Feta (60,000 Kg)

- Double Crème (26,000 Kg)

- Accaoui and Accaoui Chiki (30,000 Kg each)

- Halloum (78,000 Kg)

The cooled raw milk is pasteurized, further to which cheese starter culture (yeast or mold) is

added to initiate the coagulation of milk. About 1 hour later, the obtained coagulated mixture

is strained in permeable bags. The coagulated mixture is pressed to separate the whey from

the cheese. The cheese is cut into pieces . Then, production steps differ according to the

desired type of cheese.

Fruit Juices, with a total annual capacity of 34,320 L

Fruits concentrates (pineapple and orange) are mixed together with water and sugar. The

100% concentrated fruit juice is then filled, packed and labeled.

Fruit Nectars, with a total annual capacity of 936,000 L

The fruit nectars are produced by the same process of concentrated juices as described

above. However they are 45% concentrated juices.


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Plastics (HDPE Containers for Yogurt/ PET Bottles for Liquid Ayran), with a total

annual capacity of 4,576,000 pieces.

High density polyethylene pellets are added to the molding machines, where they are heated

to the elastic point. By injecting the melted pellets in a container shape mold, the plastic

takes the shape of the yogurt tanks. The mold is cooled in a closed system and then ready

for use.

PET Bottles are made from small pre-form polyethylene bottles. The pre-form bottles are

added to the molding machine, where they are heated to reach the elastic point, then air is

blown in the pre-form bottles to take the last shape. The hot bottles are then cooled in a

closed system and packed to be used.

Fertilizers, with a total annual capacity of 370,000 Kg

The farm produces fertilizers from manure. The manure is collected inside the stables and

outside in the external yards next to stables. The manure inside the stables is collected

mechanically. Each stable is equipped with a long scraper that collects the manure produce

from the cows and push it all into a central canal then to the collecting underground tanks

equipped with mixer and pump. Each pool has a capacity of 27 m3 and is continuously mixed

to homogenize the manure. The mix is then pumped to the separation tank (250 m3). This

manure is pumped through centrifugal pumps to separate the solid from the liquid. The solid

part is then dried in the open air for organic fertilization while the liquid part is discharged into

the nearby water stream and is expected to be further treated once the nutrient recovery and

water recycling unit is implemented. The manure produced in the external yards is kept

outside to dry and then collected to be sold later. This process happens only in good

weathering conditions, especially from May to October. In the winter, the manure is collected

and left in the external yard. When the compost is finished, it is screened. The screening is

needed to sort into different sizes. The smaller sizes are filled in bags and sold to the florists

and gardens. The large ones are sold to farmers.

Figure 6: Process Area at Liban Lait

The main environmental issue faced at Liban Lait is the generation of wastewater (described

in Section 2.1 below) in addition to the following:

The generation of air emissions mainly from the generators and boilers;

The generation of manure from the cattles’ farm;

The generation of odors, ammonia and methane from the farm;

The generation of solid wastes mainly recyclables (cartons, plastics, nylon and wooden

pallets).


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A minor generation of hazardous waste inlcuding used oils and lubricants.

The carbon monoxide and sulfur dioxide emissions of all generators and boilers are below

the regulatory limits. Nitrogen oxides levels are also below the limit values except for one of

the generators. Liban Lait is required to follow a regular maintenance program in order to

ensure the sufficient operation of the generators and the boilers. Furthermore, a catalytic

converter for nitrogen oxide reduction should be installed for the non-compliant generator in

order to further minimize the emissions.

The manure generated at the farm is currently composted on-site and sold for farmers. The

farm cleaning activities are a source of odors and ammonia and methane emissions in the

area. Once the wastewater is treated properly, the odours issue will be resolved.

Used oils and lubricants currently sold to third parties shall be sold for recycling. The solid

wastes generated are mainly the following:

Plastic pallets are reused on-site;

Salt, sugar, culture starter, bacterial cultural bags currently sold to third parties shall be

reused or sent for recycling;

Caps, cartons, nylon and wooden pallets are currently sold to third parties; Liban Lait is

advised to send them back for recycling.

As the production lines systems is fully automated, the interventions from labors is limited to

minor regular check ups and to scheduled maintenance. The number of labors involved

depends on the type of interventions.

1.4 DESCRIPTION OF THE WORKFORCE

Liban Lait currently engages 25 managerial employees and 153 production employees.

Table 1: Liban Lait Employees and working shifts

Type Number

Total number of employees 488

Number of Full Time Employee 487

Number of Part Time Employee 1

Number of Managerial Employees 25

Number of Production Employees 153

Number of Female Employees 41

Nationality of Employees Lebanese and Bengali

Employees Residence Close – by villages

Work Schedule 13 hrs./day


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Days per week: 6

Shifts per day: 2

Days per year: 288

The only part-time employee at Liban Lait is the representative of the National Social

Security Fund. Women are mostly working in the administrative positions in the plant in Hosh

Sneid and the offices in Beirut (human resources, accounting, purchasing..etc.) but also in

the laboratory and the quality department.

All employees are ensured under workmen compensation plan. The Bengali employees are

considered as daily labours and they are all covered under workmen compensation plan as

well.

Syrian workers are recruited as daily workers on a need basis (i.e. trucks loading and

unloading).

Liban Lait follows the stipulations of the Lebanese Labor Law dated 23rd September 1946,

with Amendment Law 207 issued on 26th May 2000, however there is no written policy in this

regard.

Liban Lait doesn’t have a workers’ association but has a written code of conduct that

includes the industry’s internal policies mainly with regards to the grievance, the health and

safety instructions and the fire and electrical shutdown risk prevention systems.

1.5 GRIEVANCE REDRESS MECHANISM FOR WORKERS

There is a grievance mechanism available at Liban Lait. The purpose of grievance handling

is to establish a procedure for the fair, orderly, and speedy resolution of disputes that

sometimes arises between supervisors and employees. This shall serve as the exclusive

company procedure for the resolution of job-related concerns/complaints and grievances.

An employee may utilize this procedure to review an alleged violation or misapplication of

company policies or rules pertaining to employment in the department involved, or applicable

laws and regulations that directly and adversely affected the employee. Complaints can be

resolved informally or through the assistance of the HR department if informal attempts

failed. It is processed through the direct manager/supervisor who prepares the non-

conformity report and send it to the HR department for making the proper assessment and

taking the needed actions accordingly(verbal and written notifications and warnings).

Moreover, The HR Manager may be contacted for informal counselling, if the employee

believes he cannot approach the department Manager/Supervisor with the problem. The HR

Manager will meet with the employee, the supervisor, or both as may be appropriate, to

assist in amicably resolving their differences.

It should be noted that the existing grievance redress mechanism for workers is also

applicable to all those who would undertake any construction and/or operation activities on


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Liban Lait’s site. Therefore, this grievance mechanism shall be applied to all contractors’

workers operating onsite.

1.6 GRIEVANCE REDRESS MECHANISM FOR AFFECTED COMMUNITIES

External complaints are currently reported through phone calls and through emails. All the

complaints are directly handled by the quality department, and the customers are

compensated accordingly.

It is also worth mentioning that a grievance redress mechanism is available at the LEPAP

level and it allows all those who believe they are being affected by a LEPAP financed sub-

project to raise their concerns and have them resolved. It is a complaints mechanism

addressing the mitigation and monitoring of any potential negative impacts in a timely

manner.

It should be noted that the existing grievance mechanism for affected communities shall be

further detailed and improved to include the following information: precise timeline,

departments involved and responsibilities as per Section 3 below.

1.7 SOCIAL IMPACTS

1.7.1. LEBANON LABOR LAW

As per the applicable social legislations mentioned in Section 2.3 below and according to

Article 22 of the Lebanese Labor Law, it is forbidden to employ employees aged less than 14

years. Hence, exposing young employees (14 years of age) to risks affecting their life,

health, physical, mental, spiritual, moral or social development is not possible within Liban

Lait.

1.7.2. HEALTH AND SAFETY PROCEDURES

The Health and Safety Procedures implemented in Liban Lait can be summarized as follows:

- Medical tests for the production staff are carried out periodically.

- Personal Protective Equipment (PPE) such as protective clothing, hairnet, eye

protection, and ear protection are worn in the different production areas.

Impervious boots of chemically resistant material are worn when necessary (i.e. while

handling chemicals such as medicine for cows)

Body suits, aprons, and gloves of chemical resistant material should be worn at all

times. Contaminated clothing are cleaned and dry thoroughly before reuse.

Eye protection and protective clothing are worn during handling of Chemicals.

Respiratory masks are worn during handling of Formalin.

Safety glasses, lab coat, gloves (impervious), and dust respirator are worn while

handling Citric Acid.

Face protection masks and gloves are worn when in contact with Copper Sulphate.

Hairnets are worn all the time.

- An eye wash station and drench shower are present within the Plant.

- There are policies and procedures related to hygiene. Good housekeeping rules are

practiced; Dust dispersal during cleanup operation is avoided.


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- The milking machine and milk storage equipment are kept clean and in good condition.

- All equipment, machines and tanks are sanitized after use. Safety instructions for using

all the machines are given on a weekly basis.

- Every container in the plant is well labeled with material identification, supplier name,

manufacture date and expiry date.

- The Plant is well ventilated. A general mechanical ventilation system is available within

the plant.

- Pest management strategy is applied within the farm area; and

- Fire protection system is installed in the different production lines. The fire alarm system

is equipped with the following:

Smoke and heat detectors, installed in each area of the plant;

Beam Detectors, installed in the large areas (process area, filling area, overfilling area

and warehouse);

Horns: 7 horns are distributed in and around the plant to alert the people in case of

fire

A main control panel installed (to show the place of the fire or alarm in case).

12 Pull stations to manually alert people in case of fire.

Liban Lait is equipped with portable fire extinguishers and fire hoses. In fact, the fire

suppression system is equipped with the following:

Fire Sprinkler systems, installed in the warehouse, and in the top of all the

refrigerators;

CO2 fire Suppression, installed in the process MCC electrical room;

Fire trace System, installed for all the UPS and closed panels;

Extinguishers, distributed throughout the plant (CO2, Powder or Foam);

Hoses: 14 hoses are installed throughout the plant.

Moreover, an Evacuation Plan is implemented in Liban Lait. The factory is divided into three

evacuation zones:

1. Zone 1: Utility, Process, Filling and Offices Employees

2. Zone 2: Offices, Filling and Over filling Employees

3. Zone 3: Warehouse Employees.

It should be noted that the WWTP will be equipped as part of Zone 1.

With respect to spills, no emergency response plan is implemented.

On the Job trainings are obligatory for new employees and minimum once a year for existing

employees.

The facility has reported a fire incident that occurred in 2005 in the storage area which lead

to air emissions to the environment. During July 2006, the milk production process suffered

from bombardment which ultimately led to negative environmental impacts and pollution

risks to the surrounding area.

The facility reported about complaints from the near residential/ neighboring buildings due to

the odor emissions produced from the activities of the dairy farm, mainly from the animal

manure and possible dead cows.


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Photos representing some of the existing health and safety measures implemented at Liban

Lait are presented in the photos below:

Figure 7: Portable Fire Extinguishers and Fire Hose Reels at Liban Lait

Figure 8: PPE worn by workers at Liban Lait

Liban Lait Management is keen to provide continuous trainings to all employees and

workers. The trainings are mostly technical and related to the different departments’

responsibilities; no training on social aspects are currently delivered at Liban Lait.

The trainings addressed to workers are mainly related to personal hygiene and food safety.

On another hand, the training addressed to the employees usually cover the following

subjects: new software, new processes and procedures, specific engineering matters.

1.8 MAIN ENVIRONMENTAL IMPACTS

Liban Lait conducted an Environmental Audit (EA) in order to assess the impacts of its

activities and to allow a better planning of the actions needed to avoid or reduce undesirable

effects and/or impacts.


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The EA report was approved by the Minister of Environment through its Letter No. 1544/B

dated 19 March 2018.

As highlighted in the EA report, the main environmental issues associated with Liban Lait are

summarized here below:

The process and domestic wastewaters are not treated properly. Process and domestic

wastewaters from the dairies production building (i.e. Cleaning in Place (CIP) system,

cleaning of production areas and equipment) and from the cow farms is collected by

separate drainage system to a main collection / separation tank where the solids are

separated from the liquid wastewater stream via a screw press as a first step of

treatment. After that, the liquid is discharged without any further treatment to the

adjacent land, owned by the facility, where the settling tanks are constructed. The solids

from the main tank are collected and are either composted or sold to third parties as

fertilizer. Process wastewater from the CIP system of the milking parlor along with the

wastewater from the moisture drainage of the silage are also drained directly to the

adjacent land without any further treatment, via open unpaved trenches; this would result

in polluting the Litani River

High NOx concentrations have been detected at one of the generators (500 KVA CAT

Generator, dated 2005), which is located on a concrete slab, in a partly enclosed area,

open from one side with two big doors. Regular maintenance and emissions monitoring

shall be conducted along with the installation of a catalytic converter for NOx

concentration minimization.

The used oils, oil containers, hydraulic oil containers, used lubricants containers, NaOH

bags and HNO3 containers are currently sold to a third party. These hazardous wastes

shall be returned to the supplier for reuse or sent for recycling.

Medical waste generated at the farm is currently sent to third party for disposal. These

wastes shall be disposed of according to the best environmental management practices.

Noise was measured 1 m next to the generators. The noise measurement required at the

proximity of the nearby residential units surrounding the plant was not conducted

because it is a military area and the team was not allowed to approach it. Sound proofing

doors are suggested to be installed in front of the generators. Although generators are

located indoors, the doors are not appropriate for keeping noise at low levels.

The bags and containers of the following raw materials are currently being disposed of

with municipal waste: salt, sugar, culture starter, NaOH and HNO3. It is suggested that

they are returned to the corresponding suppliers as per the requirements of the materials

safety data sheets.

The used oils and lubricants are currently being sold to third parties. Liban Lait is

requested to send them back for recycling.

The Action Plan and Compliance Strategy for Liban Lait has been divided into 12 sub-

projects as per section 7.3 of the Environmental Audit (EA) of Liban Lait.

Sub-project No. 1 consists of the installation of a WWTP. The following ESMP will include all

the necessary actions, mitigation measures, management and monitoring plan set forth in

view of not compromising the potential of the sub-project and hence ensuring its

sustainability.


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2 SUB-PROJECT DESCRIPTION

As stated above, sub-project No. 1 consists of the installation of a WWTP for the domestic

and process wastewater in order to comply with the national ELVs for WW discharge and the

Wrold Bank environmental health and safety guidelines and to alleviate the impacts of odors

on the surrounding areas.

2.1 WASTEWATER QUANTITIES AND SOURCES

Industrial wastewater is mainly generated from CIP and cleaning activities of the farm and

the manufacturing plants. A summary of the wastewater sources per production line is

presented in the table below:

Table 2: Wastewater Sources per production line in Liban Lait

Production line

Wastewater sources

CIP

Whey Cleaning of Floors

Pasteurization

Bottles Rinsing

Cleaning of Equipment

Other

Farm

X

X

X

Spraying of

cows

- Silage

moistening Fresh, Pasteurized/

UHT and skimmed

milk

X

X

X

X

Yogurt and Ayran

X

X

X

X

X

Labneh X X X X

Cheese X X X X Preparation

of brine

solution

100% Concentrated

Fruit Juices and

Fruit Nectars

X

X

X

HDPE containers for

Yogurt X

PET bottles for Ayran

X

Fertilizers X X

Whey from the dairies production activities is collected to a designated tank and is either

mixed with silage in order to be used as fodder in the farms or reused in the processing of

some cheeses.

Process and domestic wastewater from the dairies production building (i.e. CIP system,

cleaning of floors, etc.) and from the cow farms is collected through a separate drainage

system to a main collection/separation tank where the solids are separated as a first step of

treatment from the liquid stream of the wastewater via a screw press. Resulting liquid is

discharged to the adjacent land without any further treatment. The solids from the main tank

are collected and are either composted or sold to third parties as fertilizer.


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Process wastewater from the CIP system of the milking parlor along with the wastewater

from the moisture drainage of the silage are drained directly to the adjacent land without any

further treatment, via open unpaved trenches.

The rejected water from the RO treatment is estimated to be 70.800 m3/yr and is gathered in

an underground tank and mainly reused in the cow farms for cleaning purposes. When the

usage decreases, the overflown water is discharged to the wastewater sewage drainage,

which ends up into the main collection/separation tank.

Figure 9: Silage Moisture Drained in Open Trenches

Finally, the moisture of the silage, which is stored as fodder in open spaces, is drained under

the silage’s own weight onto the ground, wherefrom it is discharged via open unsealed

trenches to the adjacent plot. The estimated quantities of the generated wastewater per

source are presented in the table here below:

Table 3 : Wastewater Quantities and Sources at Liban Lait

Sources of wastewater Annual

production

(m3/year)

Daily flows

(m3/day)

Final Discharge

System

Whey from dairy production process 1,080 3.75 Collected and reused as calves

fodder

CIP in dairy production lines 69,400 241.0 Collected to a main

collection / separation tank

(solids separation) and the

liquid effluent is discharged

to the adjacent empty plot

without further treatment.

Cleaning of production areas and equipment 4,032 14

Bottles’ rinsing 1,500 5.2


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Wastewater from the cow farms 80,000 277.8

Domestic uses 3,665 12.7

Pasteurization 500 1.8

CIP in milking area 4,400 15.3

Discharged untreated to the

adjacent empty plot via open

trenches

Silage moisture drain: Liban Lait uses 130

tons of corn per year; it is fermented onsite,

resulting of a considerable amount of

wastewater, but it is difficult to quantify

Unable

to

quantify

-

RO reject

70,800

(Included in the

volume from

cleaning the cow

farms)

-

Reused for cleaning the cow

farms and the excess reject

water is collected to the main

collection/separation tank

(solids separation) and the

liquid effluent is discharged

to the adjacent empty plot

without further treatment.

TOTAL 235,377 571.44

Daily flows are based on 288 days of annual operation as reported by Liban Lait. At present,

the total quantity of wastewater discharged is estimated at 572 m3/day; however, wastewater

quantities are expected to reach 1,000 m3/d in the coming years due to the expected

increase in production within the facility.

The wastewater quantities generated per production line has been estimated since flow

meters have not been installed at the industry.

The WWTP shall allow Liban Lait to move towards environmental compliance by discharging

treated wastewater with the following characteristics:

Table 4 : Maximum Allowable Limits for Wastewater Discharge into Surface Water

Substance

Max. Allowable limits for WW

Discharge into Surface Water

according to Decision 8/1

Max. Allowable limits for WW

Discharge according to the

WB EHS Guidelines for the

wastewater and ambient

water quality

pH 6-9 6-9

Temperature (ºC) 30 -

BOD (5 day, 20ºC) (mg/l) 25 30

COD (dichromate) (mg/l) 125 125

Total Phosphorus (mg/l) 10 2

Total Nitrogen (mg/l) 30 10

Suspended solids (mg/l) 60 50

Oil and grease (mg/l) 30 10


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19

February 2019

Sulphates (mg/l) 1,000 -

Coliform bacteria (37ºC in

100ml)

2,000 400

The limits values for BOD, COD and suspended solids are almost the same according to the

requirements of the WB and the MoE. The allowable limits for total phosphorus, total

nitrogen and oil and grease are more stringent according to the WB requirements. However,

the water recycling and nutrient recovery is expected to allow LIban LAit to comply with the

national wastewater environmental standards and the World Bank allowable limits.

Three (3) wastewater samples were taken at Liban Lait during the Environmental Auditing

Process: one sample from the discharge point of the production building, another sample

from the farm, and a third from the main collection/separation tank.

Wastewater contains high concentrations of organic compounds, measured as COD and

BOD5, due to the organic loads and the chemicals uses in the central CIP system for the

cleaning of the process equipment. The TSS content is low because the whey is separated

at an early stage and does not end up to the main collection tank.

Table 5 : Available Wastewater Measurements results during the auditing process

Substances

Measurements at the

Outflow of the

production building

Measurements at the

Farm

Measurements at

the Main Collection

Tank

June

2016

August

2016

March

2017

Substan

ce

June

2016

August

2016

March

2017

Substan

ce

June

2016

March

2017

pH 11 11.7 8 7 7.47 7 7.5 7

BOD (5 day, 20ºC)

(mg/l) 580 219 2,960 3,780 9,190 19,800 4,180 13,300

COD (dichromate)

(mg/l) 960 5,630 6,560 5,470 25,600 26,400 6,430 20,300

Total Phosphorus

(mg/l) 2.3 - 5 4.5 - 9 6.1 7

Total Nitrogen

(mg/l) - <0.03 % 508 4,760 <0.03 % 2,520 7,060 1,920

Suspended solids

(mg/l) 80 - 97 85,000 - 39,800 112,000 24,000

Oil and grease

(mg/l) 26 456 118 74 1,100 211 118 178

Sulfates (mg/l) - - 75 - - 5 - 5

Total coliform

(CFU/mL) - - - 1.1 x 10

4 - - 5.5 x 10

4 -

The “farm” sample was collected from one of the three farms within the facility. The

differences shown in the results above are mainly due to the sampling process adopted.


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20

February 2019

Wastewater from the farms contains very high loads of COD, BOD, TSS and Total Kjeldahl

Nitrogen, which is expected from such wastewater as that resulting from farms which mostly

consists of animal feces.

In fact, the values measured in the main collection / separation tank which constitutes the

only type of treatment currently applied by the facility before the wastewater is discharged

onto the adjacent land, are all incompliant with the discharge limits (except from Total

Phosphorus), hence the crucial need for the WWTP.

2.2 PROJECT COMPONENTS AND DESIGN FEATURES

2.2.1 EXISTING INFRASTRUCTURE

The industrial plant had previously installed a WWTP, which is no longer operational;

however, the corresponding infrastructure is still present on site.

Liban Lait has constructed two open cylindrical tanks having respectively 13 and 14 meters

in diameters, which were supposed to be operated as anaerobic reactors for the treatment of

the liquid wastewater from the main collection/separation tank. It is however important to

note that the mentioned tanks are uncovered and are not equipped with any devices for

mixing the wastewater or collecting/utilizing the biogas.

Furthermore, the facility has constructed a set of 3 settling/stabilizing tanks for wastewater

treatment: two of them have a depth of 4.5 m and the third 6.0 m, with a total volume of

17,460 m3 and a total surface of 3,480 m2.

As per the existing design, the wastewater collected in the main collection/separation tank,

will be treated first in the two anaerobic reactors and then it would flow to the set of the three

settling/stabilization tanks for further treatment before it is discharged either to the adjacent

plot or to Litani River.


Liban Lait

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February 2019

Figure 10 : Existing wastewater treatment infrastructure (in yellow the location of the existing ponds, in red the location of the planned WWTP)

2.2.2 FORESEEN TREATMENT

Liban Lait decided to adopt a nutrient recovery and water recycling system with a total

design capacity of 1,000 m3/day taking into consideration the current wastewater flow and

the quantity of wastewater which is expected to be reached within the coming years due to

the increase of production.

With this type of treatment, the majority of the currently produced liquids are recovered as

clean water while the crop nutrients are segregated and concentrated.

The treatment process consists of the following steps:

- Dairy and farm wastewaters are mixed in the main collection tank;

- The wastewater is passed through two screw presses in a row in order to collect the

solids;

- Solids are transferred to the composting section at Liban Lait for further treatment

while the resulting liquid is transferred to the main feed tank;

- The resulting liquid goes through the first wave system to further separate the solids

which are also transferred to the composting unit for treatment;

- The resulting liquid goes through the second wave system which results in the

production of a liquid fertilizer on one hand and clean water on another hand.

Below is a flowchart representing the treatment process.


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22

February 2019

The liquid fertilizer produced will be stored on-site in the existing 15.000 m3 concrete ponds

in addition to a 30.000 m3 storage tank which will be constructed by Liban Lait.

Liban Lait will be using the liquid fertilizer produced for the cultivation of 10.000 tons of corn

needed for animal feeding. The liquid fertilizers will also be used by the neighboring farmers

for growing fruit trees, vineyards and forage crops.

It should be noted that the treatment process does not generate any odors since there will

be no ammonium in the liquid fertilizer.

The main components of the treatment plant are the following:

- Control and Information Package

It includes the information and controls system design. The controls and instrumentation are

driven remotely by local iPad or from the control panel touch screen. The operator can

control and monitor the entire system for total and instantaneous measurements of liquids,

water, chemical consumption and electrical consumption. Shutdown conditions notify the site

operator and/or any of the dairy management.

The customized iPad allows the operator to control and monitor the operation while working

in the immediate vicinity of the equipment or remotely from home, office or anywhere there is

Wi-Fi internet access.

- Inlet Suspended Solids Separation

It consists of a screen system including a manure feed pump, automated feed polymer

system, high performance coagulation/flocculation chamber (patent pending), and patented

separation screen with cover. This system is expected to achieve a 99.99% removal of

phosphorus and suspended solids.

- Fine Solids Separation System

It consists of a very efficient removal of entrained fine solids due to a settlement approach

requiring little energy. The fine solids are controlled with is a single pump in addition to a

stainless-steel cartridge filter which is flexible across a range of particle size for an increased

membrane protection.

Figure 11: Flowchart of the treatment steps


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February 2019

- Nutrient RO Membrane System

The Reverse Osmosis (RO) Membrane System is an established technology functional for

nutrient liquids. This RO features include:

A high surface area membrane configuration which assures consistent operation;

A built-in anti-fouling capacity so that water recovery is optimal and stable;

An automated cleaning system which works in conjunction with the cleaning solution for

a daily removal of impurities;

A nutrient recovery capacity of up to 80%;

A membrane designed to minimize the feed pressures to save electricity, to reduce

pump capacity and to maximize motor and pump life for the RO pumps.

The main civil works required are the following:

- A 5.000 m3 tank used as a feed tank;

- A 30.000 m3 pond for the storage of liquid fertilizers;

- A treatment building to host all the equipment.

The civil works are expected to require the following equipment:

a. Excavator (1);

b. Chain Loader (1);

c. Trucks (2);

d. Concrete mixer trucks.

Labor force required for sub-project

The above mentioned works are expected to be completed within a period of six months

through a private contractor who will need to hire around 20 labors intermittently. The

mentioned labors will be mobilized specifically for the construction of the WWTP; thus, they

won’t reside on the sub-project’s premises and will be transported onsite on a daily basis as

needed. This means that there won’t be any labor camp on-site throughout the sub-project

construction period.

However, the contractors’ workers will have to abide by the environmental, health and safety

regulations of Liban Lait in addition to the construction’s mitigation measures mentioned in

Section 3 below during their interventions on the site.

It should also be mentioned that the contractor’s labors shall undergo trainings on major

health and safety matters and applicable code of conduct. In addition, they are entitled to a

full insurance coverage complying with the occupational health and safety requirements.

The contractors’ workers will also have access to Liban Lait grievance redress mechanism in

case of complaints.

It is the responsibility of Liban Lait and the contractor to ensure the minimum health and

safety requirements are applied and the Lebanese Labor Law and the World Bank

Standards are met. For this matter, the below Day Laborers Policy requirements shall be

applied.


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February 2019

Day Laborers Procedure:

a. Recruitment :

Name, address and copy of ID to be kept in a registry by the contractor and to be

provided to Liban Lait;

Ensure that the age of the workers are compliant to the national labor law;

Ensure that the workers do not pay a mediator fee for the employment to any third

parties.

b. Inductions and conditions :

Day laborers shall be given a training on the following topics:

. Health and safety guidelines;

. Emergency preparedness and response plan;

Day laborers shall be informed about their duties and rights, working hours, rates and

schedule of payments, work schedule…etc.;

A record of the wage payments and hours worked shall be kept;

The workers shall be provided with protective equipment as described in Section 3

below.

c. Responsibility of Liban Lait and Contractor :

Liban Lait is responsible to enforce the contractor to implement the labor and health and

safety conditions onsite. This could be followed upon by appointing someone to regularly

inspect the construction site, to undertake frequent conversations with the workers onsite

and to check the employment records. The contractor is therefore requested to:

Keep a record of the names and information of the laborers onsite;

Ensure that the workers’ age is compliant with the national labor law;

Ensure that the workers have received the trainings mentioned above;

Ensure that the workers are using the needed protective equipment and are following the

applicable safety procedures;

Ensure that the workers are receiving their wages and that a record of their payments is

being kept;

Ensure that the workers have access to water and proper sanitation facilities.

2.3 SUMMARY OF ENVIRONMENTAL AND SOCIAL LEGISLATIONS RELEVANT TO

WASTEWATER TREATMENT

The main Lebanese environmental and social legislations addressing wastewater

management is presented in the table below:


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February 2019

Table 6: List of legislation relevant to the sub-project

Reference Date Description

Decree No.

8471/2012

12/07/2012 Environmental Compliance for Establishments Decree

According to this decree, industrial enterprises are required to carry

out an environmental audit (EA) including an Environmental

Management Plan (EMP) at the facility level and to execute the

required mitigation measures in order to be eligible to apply for the

Environmental Compliance Certificate (ECC).

The ECC is a three-year renewable certificate proving the

adherence of the industry to environmental standards and

application of an environmental management system.

Decision No.

52/1

29/07/1996 Environmental Quality standards for air, water and soil

The Decision sets the National Standards for Environmental

Quality (NSEQ) and the Environmental Limit Values (ELVs) for Air

and Water, as well as Maximum Permissible noise levels (Annex

10 of MOE Decision 1/52). It can be noted that the document

encompasses a wide scope of Standards set forth by MoE. The

following sections and tables relate most closely to the project at

hand:

- Annex 10: Maximum Permissible noise levels,

- Annex 14: Permissible Air Pollutant Content and Time of

Exposure.

Decision No.

8/1

01/03/2001 Air emission standards and wastewater discharge

The decision provides environmental limit values (ELVs) for

wastewater discharge into different receiving media (sewerage

system, surface water and sea).

It should be noted that the decision No. 8/1 presents an update of

some of the standards included in the previous decision No. 52/1.

The following sections and tables relate most closely to the WWTP

project :

- Table 2: New standards of Environmental Limit Values

(ELV) for wastewater discharge (into the sea, into surface

water, into the sewerage system) have been set.

Decision 29/1 2018 Work regulations for foreigners

Restricts a substantive number of jobs to Lebanese citizens in

order to protect the workforce and reduce unemployment. These

consist of all jobs practiced by Lebanese citizens include tiling,

plastering, gypsum board, iron, wood and aluminum profile

installation and other decorative tasks. Engineering is also


Liban Lait

26

February 2019

restricted to Lebanese citizens.

On March 21, 2018, a clarification letter was issued by MoL

regarding Decision 29/1, which states that Syrians are allowed to

occupy jobs in the construction sector that are not restricted to the

Lebanese as per Decision 29/1 of 2018.

Abolishment of

article 522

2017 The Committee for Administration and Justice of the

Lebanese Parliament declares the abolition of Article 522 on

15 February 2017

Abolishment of article 522 of the Penal Code that exempts a rapist

from punishment if he marries his victim.

Decree 3791

(amending

Decree 7426 of

2012)

2016 Set and apply the official minimum wage for employees and

workers subject to the labor law and the cost of living ratio

Raises the minimum daily wage to US$20

Law 293 2014 Law on Protection of Women and Family Members from

Domestic Violence –

Advances women’s rights and safety. Establishes important

protection measures and related policing and court reforms, but

leaves women at risk of marital rape and other abuse

Decree 8987 2012 Forbids the employment of adolescents and children under 18

years of age in jobs that pose a risk to their health, safety and

behaviour

Decree 11802 2004 Organizing occupational safety, safety and health in all

institutions subject to labor law

Provides the general regulations for the prevention of occupational

hazards and accidents, and the promotion of health and safety in

all industrial establishments subject to the Labor Law. These cover

prevention and safety, occupational health, the safe use of

chemicals at work, as well as occupational noise standards

MoL Decision

49/1

1997 Abolition of child labour

Forbids the employment of adolescents and children under 18

years of age in non-industrial settings, unless a medical

examination proves them apt to perform such work.

Labor Law and

its updates

Amendment

Law 207

issued on 26th

May 2000

23/09/1946

Amendment

Law 207

passed in

26/05/2000

Sets the framework and rules governing the relationship between

employers and employees, including:

Minimum age of employment: 13 years (if the candidate is in

good health); subject to yearly medical examinations until the

age of 18.

Minimum age for employment in industrial workplaces and

tedious tasks and works requiring substantial physical effort, or


Liban Lait

27

February 2019

those posing health risks: 15 years

Minimum age for employment on tasks and works that pose

risks or hazards to health and safety: 16 years

Employment record issued by the Ministry of Labor specific to

every employee, comprising name, nationality, employer name,

photograph, specialty, health consultations, and dates of

joining and leaving each establishment.

Working hours for employees under the age of 18 years: ≤6

hours, including a one-hour break following 4 continuous

working hours. Working hours must exclude the period

between 7:00 pm and 7:00 am.

Adolescent employees must be given a resting period of at

least 13 consecutive hours between two working shifts.

Overtime work and work during breaks, on weekends and

holidays are forbidden for adolescents.

Minimum vacation days for adolescents: 21 days following

employment for a complete year; 2/3 of which must be taken

continuously.

No gender discrimination is allowed in the workplace regarding

work type, remuneration, employment, promotion, training and

clothing. Employment of women in industrial settings and other

tedious and risky works is forbidden

The right of women for a paid maternity leave (10 weeks

according to the latest legislation)

It is forbidden to fire women during their maternity leave

Maximum weekly working hours: 48 hours with a 1-hour break

(mid-day)

Working hours can be reduced based on the level of physical

effort required by the job

Right of employees to a continuous 9-hour resting period

during a working day

The right of employees for a continuous 36-hour break every

week

The right of employees hired since at least 1 year to 15 days of

vacation per year, without the right of employers to fire

employees during their leave.

The right of employees to a paid occupational sick leave in case of

occupational accident, the duration of which varies based on the

case.

2.4 SCREENING OF THE PROJECT AND APPLICABLE WORLD BANK (WB)

SAFEGUARD POLICIES

The Environmental and Social Assessment Report (ESA) of the LEPAP includes specific

procedures for environmental assessment to be applied to activities and sub projects

planned, according to the importance of their environmental impacts and in accordance with

the safeguard policies of the World Bank mainly OP 4.01 on “Environmental Assessment”,

taking also into consideration the national EIA Decree No. 8633 of 2012.


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February 2019

According to the LEPAP ESMF, an industrial WWTP containing non-hazardous materials is

considered as a category II sub-project and thus requires the preparation of an ESMP.

OP 4.01 is solely triggered among the World Bank’s Environmental and Social safeguards.

The implementation of the WWTP at Liban Lait is not expected to cause any physical or

economical displacement or lack of access to designated parks, therefore the Involuntary

Resettlement Policy OP 4.12 would not be triggered in this sub-project.

It is to be noted that the World Bank issued the World Bank Group Environmental, Health,

and Safety Guidelines (known as the "EHS Guidelines"). General EHS Guidelines contain

information on crosscutting environmental, health, and safety issues potentially applicable to

all industry sectors. General EHS guidelines related to wastewater and ambient water quality

along with the specific EHS for Dairy processing and for Metal, Plastic, and Rubber Products

Manufacturing.

The present ESMP is prepared in line with the relevant guidelines summarized here below:

In the context of their overall ESHS management system, facilities shall be implemented with

a vision to:

- Understand the quality, quantity, frequency and sources of liquid effluents in its

installations;

- Plan and implement the segregation of liquid effluents principally along industrial, utility,

sanitary, and stormwater categories, in order to limit the volume of water requiring

specialized treatment;

- Identify opportunities to prevent or reduce wastewater pollution through such measures

as input substitution, or process modification (e.g. change of technology or operating

conditions/modes);

- Assess compliance of their wastewater discharges with the applicable discharge

standards.

Process wastewater treatment standards shall also be consistent with applicable Industry

Sector EHS Guidelines, i.e., in this case, specific EHS for Dairy processing, and for Plastic

and Rubber Products Manufacturing.

The pollutant load of dairy effluent is primarily composed of significant organic content,

biochemical oxygen demand (BOD) and chemical oxygen demand (COD). Whey may also

contribute to high organic loads in wastewater. Salting activities during cheese production

may result in high salinity levels in wastewater. Wastewater may also contain acids, alkali,

and detergents with a number of active ingredients and disinfectants, including chlorine

compounds, hydrogen peroxide, and quaternary ammonia compounds. The wastewater may

have a significant microbiological load and may also contain pathogenic viruses and

bacteria. The following preventive management measures can be used to prevent the

contamination of the WW stream:

- Avoid milk, product, and by-product losses (e.g. from spills, leaks, excessive

changeovers, and shut downs) through the adoption of good manufacturing procedures

and facility maintenance;


Liban Lait

29

February 2019

- Separate and collect product waste, including rinse waters and by-products, to facilitate

recycling or further processing for subsequent use, sale, or disposal (e.g. whey and

casein);

- Install grids to reduce or avoid the introduction of solid materials into the wastewater

drainage system;

- Process and foul drains should be separate in process areas and should discharge

directly to a treatment plant and/or municipal sewerage system;

- Pipes and tanks should be self–draining, with appropriate procedures for product

discharge prior to, or integral with, cleaning procedures;

- Subject to sanitary requirements, recycle process water including condensate from

evaporation processes, for preheating and heat-recovery systems for heating and

cooling processes, to minimize water and energy consumption;

- Adopt best-practice methods for facility cleaning, which may involve manual or

automated CIP systems, using approved chemicals and/or detergents with minimal

environmental impact and compatibility with subsequent wastewater treatment

processes.

Techniques for treating industrial process wastewater of the dairy sectors include flow and

load equalization; sedimentation for suspended solids reduction using clarifiers; biological

treatment, typically for the dairy WW : anaerobic followed by aerobic treatment, for reduction

of soluble organic matter (BOD); biological nutrient removal for reduction in nitrogen and

phosphorus; chlorination of effluent when disinfection is required; dewatering and disposal of

residuals;. Additional engineering controls may be required to contain and neutralize

nuisance odors. Grease traps, skimmers or oil water separators for separation of floatable

solids are specially adopted for the treatment of the food and beverages and dairy

processing wastewater; Source segregation and alternate treatment methods are typically

used for high salinity streams that contribute to elevated TDS levels in the wastewater,

specifically for the dairy effluents.

Process wastewater used in the plastic molding and forming processes can be subdivided

into three main categories: (1) cooling (or heating) water for plastics production; (2) surface

cleaning and wash water used both for plastics product surface cleaning and equipment

washing; and (3) finishing operation water to remove waste plastic material or to lubricate

the product. Cooling (and heating) water may be a source of thermal pollution if discharged.

Toxic pollutants potentially detectable in process wastewater discharged by contact cooling

and heating processes include phthalates (e.g. bis [2-ethylhexyl] phthalate [DEHP]).

Cleaning water may be characterized by significant levels of biochemical oxygen demand

(BOD5) and chemical oxygen demand (COD), total suspended solids (TSS), total organic

carbon (TOC), oil and grease, total phenols, and zinc. Finishing water may contain

significant levels of TSS and water soluble additives (e.g. phthalates).

Techniques for treating industrial process wastewater of the Plastic manufacturing sectors

include the installation of activated carbon process to remove soluble organics, including

phthalates (particularly important in manufacturing of plasticized PVC) and the recycling of

the process water through sedimentation / settling units and removal of the suspended

solids, oils and grease.


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February 2019

Occupational health and safety hazards associated with dairy operations include:

Exposure to biological and microbiological agents may be associated with inhalation

and ingestion of dust and aerosols, particularly in milk powder operations. Dust from

the ingredients used in dairy processing and high levels of humidity may cause skin

irritation or other allergic reactions.

Exposure to chemicals (including gases and vapors) typically involves chemical-

handling activities related to cleaning operations and disinfection of process areas, in

addition to the maintenance of heating (thermal oils) and cooling systems (ammonia).

Workers at dairy processing facilities are exposed to heat from process activities and to

cold in refrigeration areas and rooms.

The main sources of noise in a dairy processing facility are centrifuges, homogenizers,

spray towers, and filling and packing machinery which are all typically located in

enclosed buildings.

The following are recommendations for the prevention and control of exposures to biological

hazards:

- Avoid dust- and aerosol-generating activities (e.g. use of compressed air or high-pressure

water for cleaning) and, where they cannot be avoided, provide proper ventilation of

enclosed or semi-enclosed areas to reduce or eliminate exposure to dust and aerosols;

- Install exhaust ventilation equipped with filters and / or cyclones, at sources of dust;

- Provide workers with PPE that is appropriate for the process activity;

- Ensure physical segregation of work and welfare facilities to maintain worker personal

hygiene;

- Avoid direct contact with non-conforming dairy products.

As for the physical hazards, the following additional industry specific recommendations are

presented here below:

- Provide workers with training in the proper use of equipment (including the proper use of

machine safety devices) and personal protective equipment (PPE), such as hearing

protection;

- Demarcate transport corridors and working areas and ensure the proper placement of

handrails on platforms, ladders, and stairs;

- Projects should try to reduce the number of accidents among project workers to a rate of

zero, especially accidents that could result in lost work time, different levels of disability,

or even fatalities. Facilities should also maintain a record of occupational accidents,

diseases, and dangerous occurrences and accidents.


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February 2019

3 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

Activity

Expected

Environmental and

social Impacts

Proposed Mitigation Measures

Cost associated

with

implementing

mitigation

measures

Period of

implementing

mitigation

measures

Responsibility for

implementing mitigation

measures

Construction / installation phase

Emissions from construction

equipment and vehicles

Air pollution Equipment and vehicles shall be regularly

maintained in line with manufacturers’

recommendations to minimize polluting

exhaust emissions.

All new equipment and vehicles shall meet

the relevant national regulations and WB

directives for emissions standards.

Vehicles and equipment shall be turned off

when not in use.

Construction equipment and vehicles shall be

monitored periodically to ensure they meet

the agreed standards.

Regular checkups and preventive

maintenance

Corrective maintenance

Minor / included in

construction costs

Weekly Construction contractor and

supervision consultant

Noise and vibration from

construction works and

equipment

Noise pollution and

vibration

Construction activities shall be limited to

normal daylight working hours. A works

schedule shall be followed and/or other

specific restrictions on works shall be

established.

Construction activities shall be limited to

Minor / included in

construction costs

Ongoing Construction contractor and



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February 2019

Activity

Expected

Environmental and

social Impacts


Cost associated

with

implementing

mitigation

measures

Period of

implementing

mitigation

measures

Responsibility for


measures

permissible work hours in rural, residential

areas as per Annex 10 of MoE’s Decision No.

52/1

All construction equipment and vehicles shall

be in good working order and maintained in

line with manufacturers’ recommendations.

Noise control engineering techniques shall be

in use where practical i.e. the use of mufflers,

silencers, enclosures etc. Noise emissions

shall be monitored against set control targets

to meet required standards.

Spills from construction

vehicles and equipment

Soil and water

pollution

Stringent onsite pollution control measures

shall be applied to prevent soil and water

contamination from oil and fuel. Condition of

vehicles and equipment shall be periodically

checked. Equipment and vehicles shall be

regularly maintained in line with

manufacturers’ recommendations.

Any spills shall be contained and cleaned up.

All vehicles shall carry absorbing pads.

Protective equipment and trays shall be used

when refueling or changing oil on vehicles

and equipment.

Designated areas shall be defined for the

storage of fuel, lubricants, coolants, paint,

solvents etc.

Leakage detection system where needed;

Regular checkups and preventive

maintenance

Minor/ included in

construction costs

Ongoing Construction contractor and



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February 2019

Activity

Expected

Environmental and

social Impacts


Cost associated

with

implementing

mitigation

measures

Period of

implementing

mitigation

measures

Responsibility for


measures

Corrective maintenance;

Assigned personnel for emergency

situations

Waste generation from

construction activities

(including hazardous waste)

Soil and water

pollution

Proper waste collection and subsequent

disposal shall take place at Baalbeck landfill.

Hazardous wastes (oils and grease from

grease trap) shall be collected in closed

tanks, temporarily stored in the recycling area

and handed over to an authorized company

for final treatment/disposal.

Excavated materials will be transported for

disposal at Baalbeck Landfill

Minor/ included in

construction costs

Weekly Construction contractor and


Disruption of existing

services from

implementation of drainage

and connection works

Interruption of

existing plant

operation

Contractors shall protect existing installations

and buildings from potential damage during

the execution of works. In the event of

damage, the contractor shall undertake

repairs

Minor/ included in

construction costs

Ongoing upon

occurrence

Construction contractor and


Traffic Congestion Disruption, health

and safety impacts

as well as social and

economic impacts

Develop and implement a traffic management

plan

Erect road safety features

Included in

construction costs

Quarterly Construction contractor and


Accidents from construction

activities

Construction health

and Safety

Health, safety and environmental regulations

shall be imposed on all employees and

workers of Liban Lait in addition to the

contractors workers

Minor/ included in

construction costs

Daily Libany Lait Management,

construction contractor and



Liban Lait

34

February 2019

Activity

Expected

Environmental and

social Impacts


Cost associated

with

implementing

mitigation

measures

Period of

implementing

mitigation

measures

Responsibility for


measures

Signature of an agreement between Liban

Lait and the contractor shall include the

enforcement of the environmental, health and

safety measures applied by the industry on

the contractors’ workers during the whole

construction works period

Provision of all necessary safety equipment,

fire protection measures and monitoring

instruments

Provision of PPE (helmets, boots, earplugs)

Provision of construction barriers and proper

warning signs

Properly labelling and storing chemicals

Properly rating electrical installations and

equipment

Emergency response plan shall be prepared

and implemented by Liban Lait

Absence of sanitation, social

and medical facilities and

services;

Construction

workers welfare /

workforce social

issues

Provision of good sanitation, social and

medical facilities and services including good

water and sanitation facilities;

Develop, implement and disseminate

occupational health and safety guidelines

Employ qualified fist aider and safety officer

First aid kits to be available on site for use by

the workers.

The GRM implemented by Liban Lait shall be

applicable to the contractor to help identify

and address potential problems during

Included in

construction costs

Continuous Construction contractor and



Liban Lait

35

February 2019

Activity

Expected

Environmental and

social Impacts


Cost associated

with

implementing

mitigation

measures

Period of

implementing

mitigation

measures

Responsibility for


measures

construction.

Employment Opportunities Implementing clear and transparent

procedures for recruitment of labor and

sourcing of goods and services will enhance

the positive impact.

Preference will be given to residents of local

communities, in the case of unskilled labor,

and preference given to local suppliers in the

case of goods and services.

Included in

construction costs

Quarterly Construction contractor and


Social impacts Construction

workers welfare /

workforce social

issues

Keep an employment record by registering all

labors and workers involved in the

construction works on a daily basis by the site

operator. The following minimum information

shall be registered: Name, address, copy of

ID, …etc. in addition to keeping a record of

all the wage payments and hours worked for

each worker

Keep a record of all the injuries and accidents

on-site ;

Enforcement of the health and safety

measures

Application of the code of conduct for

contractors’ workers

Included in

construction costs

Daily Construction contractor and

Liban Lait


Liban Lait

36

February 2019

Operation phase

Treatment Efficiency and Effluent Quality

Wastewater collection

system

Soil and water

pollution

All sewers, collection channels and manholes

shall be kept watertight.

Ongoing inspection and maintenance of the

WCS shall be performed to monitor leaks,

pipe corrosion etc.

Included in O&M

costs

Weekly WWTP Operator

Discharge of effluent to

recipient water stream/ Litani

river and/or inefficient

WWTP operation

Water quality

degradation

WWTP will operate at optimum efficiency levels

commensurate with the design criteria and

required compliance. In case of emergency

conditions, special emergency actions shall be

taken as per the Emergency Response Plan in

Section 5 below in order to avoid release of

untreated effluent into natural recipients and

public sewer systems.

As addressed in the monitoring plan, effluent shall

be regularly monitored to ensure water quality

standards as prescribed by the Decree on

Conditions for Discharge of Wastewater into

Natural Recipients and Public Sewer Systems

(Decision No. 8/1).

An operation and maintenance manual and

related procedure shall be set and made available

by the supplier. The document shall target, at a

minimum, the following:

Operator and staff responsibilities;

Staff guidance for emergency situations;

Identification of MoE requirements and

the obligation to meet these

500,000 USD/year

200 USD/sample

Cost of trainings

and

documentation

included in the

supplier’s offer

Continuous

Monthly

Sampling: Regularly

as required by the

supplier and Bi-

annually by third

party

Training: Yearly

WWTP Operator, third party


Liban Lait

37

February 2019

requirements;

Operating procedures including a detailed

description of each major treatment

unit/process with relationship to related

units, safe operating procedure for normal

operation, including common operating

problems, safe operating procedures for

operating during emergency conditions,

and any fail-safe features;

A program of regularly scheduled

inspection and maintenance; and

An emergency plan

Filter backwashing Water pollution Backwash wastewater shall be recycled into the

system and treated

Included in

operation and

maintenance

costs

According to the

supplier’s

requirements

WWTP operator

Polymers Environmental

pollution

The polymers used during the treatment phase

shall be used in appropriate optimal dosage

commensurate with influent and effluent quality as

per supplier’s recommendations. The storage,

handling and disposal of waste shall be conducted

in line with the MSDS obligations.

Included in

operation and

maintenance

costs

Continuous WWTP Operator

Pump failure Outflow of

wastewater

To prevent the accidental flow of water from the

pumping station due to pump failure, spare pumps

shall be provided and installed

Spare parts costs

are included in the

supplier’s offer for

the first year.

3% annually

thereafter

During planning of

the project and

contract negotiations

with supplier

Liban Lait Management/

Maintenance team

Power outage Malfunctioning of

plant

In order to ensure that power is available to the

plant at all times, a UPS shall be put in place to

cater for the transitionary period between the

20,000 USD Continuous Liban Lait Management

/maintenance team


Liban Lait

38

February 2019

electrical outage and the operation of the

generator set.

Incident discharge of

operational wastewater to

surrounding area

Water quality

degradation

Implementation of a second feed tank of 5 m3

capacity to be used for storage in case of

spills / bad product production, etc.

Continuous analysis of the influent and

effluent quality in the on-site laboratory, as

addressed in the monitoring plan

Regular monitoring of sewer line and

manholes for visible leakages/ overflows

Immediate repair operation for the damaged

portion of sewer line

De-siltation of blocked sewers/ manholes with

sewage pumping machines storing and

disposal at appropriate refusal area after

treatment

Ensure proper covering of manhole and avoid

dumping of solid waste to prevent chocking of

sewer line

Included in the

supplier’s offer.

Continuous

As per the

monitoring plan

WWTP Operator

Solids Generation

Disposal of solids generated

at the screw presses and the

first wave steps

Soil and water

pollution (problems

arising due to bad

odour, insects,

polluted air, etc.)

The solids will be used for composting, which will

be undertaken on site. Safety procedures for

internal transportation and disposal shall be

established.

Included in

Operation and

maintenance

costs

Continuous WWTP Operator

Health and safety

Acute intoxication caused by

erroneous drinking of

untreated wastewater

Health and safety

hazard of WWTP

personnel

Take extreme care when handling the

polymers

Training and education programs shall be

organized for employees.

Included in O&M

costs

Training cost

Continuous WWTP Operator, Liban Lait

Management


Liban Lait

39

February 2019

Personnel of the WWTP shall undergo

periodical medical checks to ensure no

negative impacts arise from their employment

at the WWTP.

included as part of

supplier’s offer

Slips and falls on floors

made slippery by water, as

well as falls into ponds, pits,

or tanks causing injuries or

drowning

Health and safety

hazard of facility

personnel

Use safety shoes or boots with non-slip soles.



60 USD /

Personnel Safety

shoes

Training cost

included as part of

supplier’s offer

Continuous WWTP Operator, Liban Lait

Management

Fire and explosions due to

the potential formation and

release of flammable gases

during processing (e.g., ,

hydrogen)

Health and safety

hazard for WWTP

personnel

Fire extinguishers of the “dry” type will be

provided in all buildings containing electro-

mechanical equipment and electrical

installations, which are in-line with applicable

standards.

Fire extinguishers and hoses shall be

regularly inspected by the fire department

An outdoor hydrant network will be

constructed at the plant, in accordance with

the appropriate regulations

5,000 USD During construction

and operation

Construction contractor /

maintenance team

Health and safety hazard:

airborne hazards not only

create unpleasant odors but

may also pose the risk

of respiratory and

gastrointestinal infections for

the operators

Social Impact

(Human Health

Cost)

Personnel of the WWTP shall undergo

periodical medical checks to ensure no

negative impacts arise from their employment

at the WWTP.



Assigned personnel for emergency situations

Organization chart providing a list of relevant

personnel/people to contact in case of

emergencies with their respective phone

numbers. The chart should be easily

Included in O&M

costs

Continuous Liban Lait Management /

WWTP Operator


Liban Lait

40

February 2019

accessed by all staff/workers and available in

Arabic.

Social

Health benefits for the

general public from the

implementation of the

WWTP

Social Impact

Ensuring WWTP operation commensurate

with design criteria and required compliance

levels, ensures the targeted higher quality of

effluent discharged into receiving water

bodies, and thus increases health conditions

and improves quality of life to local residents.

Included in O&M

costs

Training cost

included as part of

supplier’s offer

Continuous Liban Lait Maintenance

Team / WWTP Operators

Socio-economic benefits Socio-economic

benefits

Support the project with awareness

campaigns and trainings on benefits of

composts and liquid fertilizers

Included in O&M

costs


Team

Complaints of people

affected by the WWTP

activities and operation

Social impact The internal GRM already available at Liban

Lait shall be enforced to ensure that the

workers’ rights are being protected.

Monthly follow-up, documentation and

monitoring of the internal GRM

The external GRM shall be further detailed to

include the following information:

departments and responsible entities,

timeline for each step of processing the

complaints, contact information

The external GRM shall be amended to allow

anonymous and oral complainants to be

submitted

The external GRM shall enforce the

documentation of all complaints submitted on

a monthly basis


Team


Liban Lait

41

February 2019

Post - Operation / Decommissioning phase

Transport, installation and

decommissioning of the

WWTP may pose potential

safety risks to local

communities and workers.

Technical and

Operational Impacts

/ Health and Safety

The responsible contractor(s) and sub-

contractor(s) shall submit closure plans for

approval before starting the decommissioning

works. In the closure and demolition of

abandoned facilities, any residual wastewater

or solids must be properly disposed.

Clear warning / danger signs shall be

installed to alert employees of Liban Lait of

decommissioning works.

Personal protective equipment shall be

provided to workers.

Safety management plan required to be

submitted by the contractor(s) and sub-

contractor(s), shall be implemented and

monitored for compliance during

decommissioning.

Workers shall undergo specific orientation

and regular training on safety during

decommissioning.

Included in

decommissioning

costs

Ongoing Decommissioning contractor

and supervision consultant

WWTP that is removed from

use may contain residual

wastewater. Abandoned

equipment from the WWTP

may pose physical risks to

humans who may come into

contact with them, along

with any number of long

term environmental risks,

risks to wildlife, regulatory

issues, and liabilities to the

owner.

Environmental /

Health and safety /

Social Impacts

Residual wastewater may often be

discharged to a nearby sanitary sewer, when

available; Alternatively, the responsible party

may hire a licensed wastewater hauler to

remove residual liquid wastes.

Solids shall be adequately collected and

disposed of in the solid waste management

facility operational and licensed for such

purposes at the time of decommissioning.

Tanks cannot be abandoned and shall be

either removed from site or filled in place

using an inert solid or other such approved fill

Included in

decommissioning

costs




Liban Lait

42

February 2019

material.

Left over polymers Environmental

Pollution

Left over polymers shall be removed from the

site. If possible, the responsible party could

arrange to return the polymers to the

manufacturer, or alternatively sell or give

them to a different WWTP to be used for their

intended purpose, or have them disposed of

properly.

Minor / Included in

Decommissioning

costs

Ongoing Decommissioning Contractor

and Supervision consultant

Noise and vibration from

demolition works and

equipment

Noise pollution and

vibration

Decommissioning activities shall be limited to

normal daylight working hours. A works

schedule shall be followed and/or other

specific restrictions on works shall be

established.

All construction equipment and vehicles shall

be in good working order and maintained in

line with manufacturers’ recommendations.

Noise control engineering techniques shall be

in use where practical i.e. the use of mufflers,

silencers, enclosures etc. Noise emissions

shall be monitored against set control targets

to meet required standards.

Minor / Included in

decommissioning

costs



Introduced flora and weed

species

Environmental

Impact

Top-soiling and planting of the site with

native, locally sourced plants or grasses; and

/ or

Grading, levelling and re-contouring to ensure

no voids or uneven surfaces; and

Rendering the site safe for future land use.

Included in

Decommissioning

costs



Emissions from

decommissioning equipment

Air pollution Equipment and vehicles shall be regularly

maintained in line with manufacturers’

Included in

Decommissioning

Ongoing Decommissioning Contractor



Liban Lait

43

February 2019

and vehicles recommendations to minimize polluting

exhaust emissions.

All new equipment and vehicles shall meet

the relevant national regulations and WB

directives for emissions standards.

Vehicles and equipment shall be turned off

when not in use.

Decommissioning equipment and vehicles

shall be monitored periodically to ensure they

meet the agreed standards.

costs

Waste generation from

decommissioning activities

(including hazardous waste)

Soil and water

pollution

Proper waste collection and subsequent

disposal shall take place at the solid waste

management facility operational and licensed

for such purposes at the time of

decommissioning.

Hazardous wastes (oils and grease from

grease trap) shall be collected in closed

tanks, temporarily stored in the recycling area

and handed over to an authorized company

for final treatment/disposal.

Minor/ Included in

decommissioning

costs

Weekly Decommissioning contractor


Disruption of existing

services from

implementation of drainage

and connection works

Interruption of

existing plant

operation

Contractors shall protect existing installations

and buildings from potential damage during

the execution of works. In the event of

damage, the contractor shall undertake

repairs

Minor/ Included in

decommissioning

costs

Ongoing upon

occurrence

Decommissioning contractor



Liban Lait

44

February 2019

4 ENVIRONMENTAL AND SOCIAL MONITORING PLAN

Monitoring Parameters Sampling Location

Type of

Monitoring

Equipment

Monitoring Frequency Estimated Cost Responsibility

Construction / Installation phase

Air quality

Exhaust emissions from vehicles and

equipment

Level of dust (amounts of sediment

particles and airborne particles)

Working area Visual inspection,

Measurement

devices (if

needed)

Check vehicle and

equipment service

history

Once a week in the dry season

during construction, and after

complaints

300 USD/

Measurement

event

Construction contractor

Noise level Sensitive receptors in

the plant vicinity

Monitoring

through site

inspection and

measurement

devices

Regularly during construction,

as appropriate, or upon

complaints from citizens

300 USD/

Measurement

event


Waste generation and management Working area Visual inspection,

disposal records

Regularly during construction,

as appropriate. Internal reports

on amounts and disposal

records to be prepared daily

and monthly

Included in

construction costs


Water tightness Collectors, pipes and

WWTP facilities

Test certificate;

visual inspections

During construction Included in

construction costs



Liban Lait

45

February 2019


Type of

Monitoring

Equipment


Health and safety Working area Visual observation

and photographic

documentation.

Maintaining a

record

(documentation

and log) of injuries

and accidents

specifying cause

and location

description.

Maintaining a

record of all the

training activities

(and their

frequency) related

to health and

safety

Maintaining a

monthly record of

all the grievances

submitted by the

workers or the

affected

communities

Continuous, during

construction

Included in

construction costs


Operation phase


Liban Lait

46

February 2019


Type of

Monitoring

Equipment


Two types of wastewater monitoring are to

be implemented: (1) Internal, to ensure

good WWTP operation, as per supplier's

requirements, an (2) By third party, as

required for the MoE in order to confirm

compliance in terms of wastewater

discharge.

Wastewater chemical and physical

parameters:

Flow

Temperature

pH,

total suspended solids (TSS) (mg/l)

BOD5 (mg O2/L)

COD (mg O2/L)

total phosphorus concentration (mg

P/L)

total nitrogen concentration

total oil and grease concentration

(mg/L)

WWTP inlet and outlet Laboratory testing Regularly as required by the

supplier

Bi-annually by third party

Included in plant

operation

200 USD/sample

Liban Lait Management

and WWTP operator

and third party (needed

when reporting to MoE)

Liquid fertilizers quality:

regular quantity (m3 /d)

Total nitrogen concentration (mg N/kg

D.S.)

Total phosphorus concentration (mg

P/kg D.S.)

Total potassium concentration (mg

Second wave line Tests of quality of

the liquid

fertilizers

Visual observation

and photographic

documentation

Once per semester for all

analyses, except for total

heavy metals to be carried out

once per year

500 USD /

measurement

event

WWTP operator for

sampling/documentation

Third party for analysis


Liban Lait

47

February 2019


Type of

Monitoring

Equipment


K/kg D.S.)

Maintaining a

record of type,

quantity, and

disposal location

of generated

liquid fertilizers

Once per month

Noise levels WWTP Boundary

sensitive receptors

Measurement

devices

Site inspection: once a month

Ad hoc monitoring to be

undertaken as appropriate

Testing: Once a year during

operation, baseline analysis

needed

300 USD /

Measurement

event


WWTP operators

Compliance with legal regulations and

internal procedures for safe material

handling

On site Visual observation

and photographic

documentation

Maintaining a

record of injuries

and accidents

specifying cause

and location

description

Periodic Included in

operation costs


and Maintenance /

WWTP operators

Health and safety Working area Maintaining a

monthly record of

all the grievances

submitted by the

Continuous, during operation Included in

operation costs

WWTP Operator


Liban Lait

48

February 2019


Type of

Monitoring

Equipment


workers or the

affected

communities

Post Operation / Decommissioning phase

Air quality

Exhaust emissions from vehicles and

equipment

Level of dust (amounts of sediment

particles and airborne particles)

Working area Visual inspection,

Measurement

devices (if

needed)

Check vehicle and

equipment service

history

Once a week in the dry

season, and upon complaints

300 USD/

Measurement

event

Decommissioning

contractor

Noise level Sensitive receptors in

the plant vicinity

Monitoring

through site

inspection and

measurement

devices

Regularly, as appropriate, or

upon complaints from citizens

300 USD/

Measurement

event

Decommissioning

contractor

Waste generation and management Working area Visual inspection,

disposal records

Regularly, as appropriate.

Internal reports on amounts

and disposal records to be

prepared daily and monthly

Included in

decommissioning

costs

Decommissioning

contractor

Health and safety Working area Visual observation

and photographic

documentation.

Continuous, Included in

decommissioning

costs

Decommissioning

contractor


Liban Lait

49

February 2019


Type of

Monitoring

Equipment


Maintaining a

record of injuries

and accidents

specifying cause

and location

description.


Liban Lait

50

February 2019

5 EMERGENCY PREPAREDNESS AND RESPONSE PLAN

Monitoring efforts would be in vain in the absence of an organized record keeping practice. It

is normally the responsibility of the project administration (Liban Lait Management through

its Operation and Maintenance teams) to ensure development of a database that includes a

systematic tabulation of process indicators, performed computations, maintenance

schedules and logbook and process control/performance monitoring outcomes. Such a

historical database benefits both the project administrator and surrounding communities.

The project administrator should submit a semi-annual report to the assigned regional

authority, namely the Ministry of Environment (MoE) according to its requirements.

Contingency measures and plans in case of emergency have been addressed briefly

throughout this report, including namely:

- Stand-by equipment (pumps, dewatering equipment, etc.);

- Back-up power supply (electrical generators) maintaining the operation of the WWTP

in case of any local power failure;

- Overflows for WWTP in case of plant failure (at the various stages of treatment);

- Regular checkups and preventive maintenance;

- Corrective maintenance;

- Process operational procedures;

- Leakage detection system where needed;

- Firefighting system;

- Signs as needed;

- Ladders as needed;

- Personal Protective Equipment (PPE);

- Training of Personnel;

- Assigned personnel for emergency situations;

- Organization chart providing a list of relevant personnel/people to contact in case of

emergencies with their respective phone numbers. The chart should be easily

accessed by all staff/workers and available in Arabic.

Throughout the construction and operation of the project, the workforce is to be continuously

informed of any hazardous issue that may materialize during these periods. Moreover,

residents in the project area and relevant municipalities and authorities should in turn be

informed accordingly should a hazard persist during the operational period.

Stringent emergency procedures are to be assigned in the aim of intercepting any pollution

that may occur as a result of structural damage due to any natural disaster occurrences.

. As noted in the Environmental and Social Management Plan here above, an emergency

plan shall be included as part of the Operation and Maintenance Manual provided by the

supplier upon commissioning of the sub-project.

The emergency plan shall be designed to ensure effective operation of the treatment works

under emergency conditions, and shall consist, at a minimum, of the following elements:


Liban Lait

51

February 2019

- A vulnerability analysis which shall estimate the degree to which the treatment works

would be adversely affected by each type of emergency situation which could reasonably

be expected to occur, including but not limited to those emergencies caused by natural

disaster, civil disorder, strike, sabotage, faulty maintenance, negligent operation or

accident;

- The vulnerability analysis shall include, but is not limited to, an estimate of the effects of

such an emergency upon the following: (1) Power supply; (2) Communication; (3)

Equipment; (4) Supplies; (5) Personnel; (6) Security; and (7) Emergency procedures to be

followed.

- An evaluation of the possible adverse effects on public health and the environment due to

such an emergency; and

- An emergency operation plan for ensuring, to the maximum extent possible, uninterrupted

operation of the treatment works and a manual of procedures for the implementation of

such plan, including procedures for the notification of the MoE and municipal authority.

The plan and manual shall address each of the emergency situations described in the

vulnerability analysis.

A requirement should be set in the contract signed between Liban Lait and the supplier,

which requires the awarded contractor to perform regular and frequent maintenance

checkups of the facility.

These preventive measures and design considerations will ensure a continuous and

uninterrupted operation of the facility while catering for any potential environmental or social

adverse impact.


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52

February 2019

6 STAKEHOLDERS MEETING

A Consultation meeting for the Environmental and Social Management Plan of the WWTP

was held at Liban Lait, Hosh Sneid, on Wednesday 13 June 2018 in the presence of the

following attendees:

Table 7: List of Attendees of the Consultation meeting held at the Liban Lait

No. Institution Representative Mobile/Tel Email

1 Ministry of Industry Soha Yazbek 71-325002 [email protected]

2 Ministry of Environment Ebtihaj Abou Chakra 70-827011 [email protected]

3 American University of Beirut – Faculty of Agriculture

Mustapha Haidar 03-334319 [email protected]

4 Mayor of the Municipality of Brital

Ahmad Ismail 70-770999 [email protected]

5 Vice Mayor of the Municipality of Brital

Ali Abbas Younes 79-134692 -

6 Vice Mayor of the Municipality of Talia

Phillipe Abou Haidar 71-384837 -

7 Mayor of the Municipality of Hosh En Nabi

Fouad Saeed El Haj Hassan

70-147735 -

8 Owner of a nearby land Hassan Audi 71-642022 -

9 MOE/LEPAP Cynthia Kayem 76-301060 [email protected]

10 Liban Lait – General Manager Marc Waked 05-959444 [email protected]

111 Liban Lait – Plant Manager Anis El-Khatib 08-345230 [email protected]

12 Liban Lait – Agriculture Department Manager

Adnan Haj Hassan 03-203473 [email protected]

13 Liban Lait – Technical Manager

Hassan Jadel Aoun 03-961698 [email protected]

14 Local community representative

Rachid Al Halabi 71-379150 [email protected]


Obeida Seifeddine 03-021231 [email protected]

16 Liban Lait - Quality Assurance Ghenwa Haj Hassan 03-795907 [email protected]


Dominique Dandan 71-794104 [email protected]

18 Liban Lait – Senior HR Fatima Ghosn 70-988772 [email protected]

mailto:[email protected]















Liban Lait

53

February 2019

Figure 12: Consultation meeting for the ESMP of the WWTP, Liban Lait, 13 June 2018

The meeting involved mainly the potential impacted stakeholders, whom are the mayors of

the Municipalities of the surrounding villages and an owner of nearby land, a representative

from the Ministry of Environment, the Ministry of Industry and the American University of

Beirut.

An invitation was sent to the Mayor of Hosh Sneid, the Ministry of Public Health, the Ministry

of Agriculture, the Governor of Baalbeck/Ministry of Interior and Municipalities, and the

neighboring military unit, however, they were not able to attend the meeting. The General

Manager of Liban Lait commited to share with them the PowerPoint presented during

meeting.

The ESMP of the WWTP planned for execution at Liban Lait was presented by Mrs. Cynthia

Kayem, the monitoring and evaluation officer at the LEPAP project, with specific emphasis

on the potential negative impacts of the WWTP and the planned mitigation measures during

the phases of construction, operation, and decommissioning.

The main concern of the attendees – especially of the Mayor of the Municipality of Hosh En

Nabi and the owner of the nearby land who seemed to be the most affected – was the odors

generated from the accumulation of untreated wastewater at Liban Lait, its negative impact

on the Litani River and on the health of the residents of the surrounding villages.


Liban Lait

54

February 2019

In addition, Mr. Hassan Audi expressed his concern regarding the location of the current

screw press and the planned WWTP. He was specifically complaining about the odors and

the unpleasant view caused by the mentioned equipment.

Mrs. Kayem explained that the WWTP is not expected to generate any odors. Mrs. Ebtihaj

Abou Chacra, the representative of the MoE, explained that nor the MoE neither any other

institution can force Liban Lait to change the location of the sub-project. However, it is

obligatory for Liban Lait to ensure that no adverse impacts are caused to the neighboring

area. For that matter, it is mandatory for Liban Lait to undertake all needed measures to

reduce the impacts of the screw press and the WWTP on the landscape in the area. One of

the proposed actions was to request the industry to plant trees in a row next to Mr. Audi’s

land in a way that the screw press and the WWTP will be unseen. By the end of the

discussion, Mr. Audi was convinced of the proposed measures and asked Mr. Marc Waked,

the General Manager of Liban Lait, to commit to execute the actions agreed upon.

Mr. Waked reiterated on the importance of the WWTP implementation and pledged that

Liban Lait will execute and operate the sub-project taking all the concerns into consideration

and executing all mitigation measures as needed. The attendees were happy to know about

the plan of Liban Lait to implement a WWTP which will reduce the odors and have a positive

impact on the close by Litani River. They were very cooperative and understanding of the

period needed for the WWTP to start operating, and hence improve the surrounding air and

water quality. They also expressed their wish that other industries in the region would follow

the lead of Liban Lait and manage their wastewater properly.

The attendees expressed their content that mitigation measures were taken into

consideration and they were informed about the exact location of the WWTP within the

premises of Liban Lait.

Finally, Mrs. Cynthia Kayem highlighted that monitoring reports will be submitted regularly to

the MoE and accordingly the MoE and LEPAP team will be closely following up on the

construction and operation of the WWTP. Thus, the attendees can communicate any

concerns they have in the future by contacting Liban Lait directly or by referring to the

grievance mechanism of LEPAP.

environmental and social management plan liban …

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