Download - Ma'aden Wa'ad Al-Shamal Phosphate Project

DEPARTMENT: SAFETY AND ENVIRONMENTAL

REPORT NO: 60-R400-WH/G.06f/0073

REPORT TITLE: UMM WU'AL ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

PROJECT REFERENCE A03

PROJECT NO: 60-R400-WH

PROJECT LOCATION: SAUDI ARABIA

PROJECT TITLE: UMM WU'AL PHOSPHATE PROJECT

CLIENT: MA'ADEN (SAUDI ARABIAN MINING COMPANY)

CLIENT PROJECT NO 2-115-12-12-2-2

CLIENT DOCUMENT NO MD-513-000-HS-EN-RPT-0070

PM Authorisation: AD

Rev Issue Date Pages Revision Description Prepared Checked Approved

A01 7 Jun 2013 ALL ISSUED FOR CLIENT REVIEW CF AD AD

A02 26 Jun 2013 ALL ISSUED FOR FEED FCL CF AD

A03 29 Aug 2013 ISSUED FOR FEED FCL CF AD

DOCUMENT ISSUED FOR:

Preliminary For Information

For Review For Use

For Approval For Enquiry

For FEED

Document Title. UMM WU'AL Revision C01

Ma’aden Doc No. MD-513-000-HS-EN-RPT-0070 of 463

Jacobs Doc Nº. 60-R400-WH/G.06f/0073 Date August 2013

Project Name: UMM WU'AL PHOSPHATE PROJECT

TABLE OF CONTENTS EXECUTIVE SUMMARY ......................................................................................................................... 6

1.0 INTRODUCTION ..................................................................................................... 25

1.1 PROJECT UNDERSTANDING AND OVERVIEW ............................................................... 25

1.2 UMM WU’AL PROJECT SITE .............................................................................................. 26

1.3 THE ESIA ............................................................................................................................. 27

1.4 ESIA SCREENING .............................................................................................................. 28

1.5 SCOPE OF THE ESIA ......................................................................................................... 28

1.6 PREPARATION OF THE ESIA ............................................................................................ 29

1.7 ENVIRONMENTAL PERMITTING....................................................................................... 29

1.8 REPORT STRUCTURE ....................................................................................................... 29

2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ........ .......................... 33

2.1 INTRODUCTION ................................................................................................................. 33

2.2 LOCAL AND NATIONAL LEGISLATION AND STANDARDS ............................................ 33

2.3 INTERNATIONAL GUIDELINES AND POLICIES ............................................................... 37

2.4 OTHER STANDARDS AND GUIDANCE ............................................................................ 46

2.5 RELEVANT ENVIRONMENTAL STANDARDS AND GUIDELINES ................................... 48

2.6 OTHER CONSIDERATIONS ............................................................................................... 53

3.0 CONSIDERATION OF ALTERNATIVES ..................... .......................................... 54

3.1 INTRODUCTION ................................................................................................................. 54

3.2 PROJECT JUSTIFICATION ................................................................................................ 54

3.3 DO-NOTHING OPTION ....................................................................................................... 57

3.4 SELECTED SITE SUITABILITY .......................................................................................... 57

3.5 ALTERNATIVES CONSIDERED......................................................................................... 58

3.6 POLLUTION CONTROL ALTERNATIVES ......................................................................... 62

3.7 APPLICATION OF BAT ....................................................................................................... 63

3.8 RESOURCE EFFICIENCY .................................................................................................. 73

4.0 DETAILED DESCRIPTION AND LAYOUT OF THE PROPOSED DEVELOPMENT ..................................................................................................... 74

4.1 INTRODUCTION ................................................................................................................. 74

4.2 MAIN FEATURES OF THE PROJECT ............................................................................... 74

4.3 PROJECT LOCATION ........................................................................................................ 75

4.4 SITE LAYOUT ..................................................................................................................... 75

4.5 SITE CONNECTIVITY ......................................................................................................... 80

4.6 NEIGHBOURING INDUSTRIES.......................................................................................... 80

4.7 PROJECT SCHEDULE ....................................................................................................... 85

4.8 WORKFORCE AND NUMBER OF EMPLOYEES .............................................................. 85

4.9 CONSTRUCTION PHASE .................................................................................................. 87

4.10 PRE-COMMISSIONING AND COMMISSIONING PHASE ................................................. 92

4.11 OPERATION PHASE .......................................................................................................... 93

4.12 PRODUCT AND RAW MATERIALS STORAGE AND HANDLING FACILITIES .............. 120

4.13 POWER ............................................................................................................................. 124

4.14 WATER .............................................................................................................................. 125

4.15 WASTEWATER ................................................................................................................. 131

4.16 WASTE MANAGEMENT FACILITIES ............................................................................... 134





4.17 SUPPORTING BUILDINGS AND INFRASTRUCTURE.................................................... 141

5.0 IMPACT ASSESSMENT METHODOLOGY ..................... .................................... 142

5.1 PROJECT SITE LOCATION ............................................................................................. 142

5.2 IMPACT ASSESSMENT CRITERIA ................................................................................. 144

5.3 IMPACT ASSESSMENT REPORTING ............................................................................. 148

5.4 MITIGATION MEASURES AND REPORTING ................................................................. 148

5.5 CONCLUSION ................................................................................................................... 148

6.0 AIR QUALITY AND METEOROLOGY ....................... .......................................... 149

6.1 INTRODUCTION & SCOPE .............................................................................................. 149

6.2 BASELINE CONDITIONS/ EXISTING ENVIRONMENT ................................................... 149

6.3 AMBIENT AIR QUALITY ................................................................................................... 151

6.4 IMPACT ASSESSMENT ................................................................................................... 159

6.5 COMMISSIONING AND OPERATIONS ........................................................................... 163

6.6 GREENHOUSE GAS EMISSIONS ................................................................................... 181

6.7 MITIGATION ...................................................................................................................... 183

7.0 TERRESTRIAL ENVIRONMENT ........................... ............................................... 185

7.1 INTRODUCTION ............................................................................................................... 185

7.2 BASELINE CONDITIONS ................................................................................................. 185


7.4 MITIGATION ...................................................................................................................... 219

8.0 BIOLOGICAL RESOURCES .............................. .................................................. 226

8.1 INTRODUCTION ............................................................................................................... 226

8.2 METHODOLOGY .............................................................................................................. 229

8.3 ECOLOGICAL BASELINE ................................................................................................. 235


8.5 OPERATION...................................................................................................................... 260

8.6 CLOSURE / DECOMMISSIONING ................................................................................... 264

8.7 MITIGATION ...................................................................................................................... 265

9.0 NOISE & VIBRATION ................................. .......................................................... 273

9.1 INTRODUCTION ............................................................................................................... 273



9.4 CLOSURE / DECOMMISSIONING ................................................................................... 292

9.5 MITIGATION ...................................................................................................................... 292

10.0 WASTE MANAGEMENT .................................. .................................................... 295



10.3 MITIGATION ...................................................................................................................... 303

11.0 WATER QUALITY MANAGEMENT .......................... ........................................... 310

11.1 INTRODUCTION ............................................................................................................... 310



11.4 MITIGATION ...................................................................................................................... 326

12.0 SOCIO-ECONOMIC ASPECTS ............................................................................ 332





12.1 INTRODUCTION ............................................................................................................... 332

12.2 PROFILING BASELINE CONDITIONS ............................................................................. 332



12.5 MITIGATION ...................................................................................................................... 352

12.6 MONITORING ................................................................................................................... 358

13.0 TRAFFIC AND TRANSPORT INFRASTRUCTURE .............. .............................. 359

13.1 INTRODUCTION ............................................................................................................... 359


13.3 NATIONAL BACKGROUND .............................................................................................. 359

13.4 REGIONAL AND LOCAL BACKGROUND ........................................................................ 361


13.6 MITIGATION ...................................................................................................................... 373

14.0 UTILITIES INFRASTRUCTURE AND USAGE ................ .................................... 375

14.1 INTRODUCTION ............................................................................................................... 375



14.4 MITIGATION ...................................................................................................................... 383

15.0 HEALTH AND SAFETY ASPECTS ......................... ............................................. 384

15.1 INTRODUCTION ............................................................................................................... 384


15.3 NATIONAL HEALTH ......................................................................................................... 388

15.4 REGIONAL HEALTH ......................................................................................................... 395

15.5 LOCAL HEALTH ................................................................................................................ 396

15.6 HEALTH AND SAFETY IN CONSTRUCTION .................................................................. 397

15.7 HEALTH AND SAFETY IN DESIGN ................................................................................. 397


15.9 COMMISSIONING AND OPERATIONS ........................................................................... 410

15.10 DECOMMISIONING .......................................................................................................... 413

15.11 MITIGATION ...................................................................................................................... 414

16.0 SUSTAINABLE DEVELOPMENT ........................... ............................................. 419

16.1 INTRODUCTION ............................................................................................................... 419

16.2 SUSTAINABLE DEVELOPMENT CONTEXT ................................................................... 419

16.3 ASSESSING SUSTAINABLE DEVELOPMENT ................................................................ 423

16.4 SUSTAINABLE DEVELOPMENT ASSESSMENT OF THE PROJECT............................ 426

16.5 SUSTAINABILITY CONCLUSION AND RECOMMENDATIONS ..................................... 429

17.0 CUMULATIVE IMPACTS ASSESSMENT...................... ...................................... 431

17.1 INTRODUCTION ............................................................................................................... 431

17.2 EXISTING AND FUTURE PROPOSED PROJECTS ........................................................ 431

17.3 CUMULATIVE IMPACT WITH OTHER PROJECTS......................................................... 432

17.4 CONCLUSIONS ................................................................................................................ 436

18.0 SUMMARY OF IMPACTS AND MITIGATION ................. .................................... 438

19.0 ABBREVIATIONS AND ACRONYMNS ....................... ........................................ 443

20.0 REFERENCE LIST ................................................................................................ 449





APPENDICES APPENDIX A –ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN (EMMP) APPENDIX B – ENVIRONMENTAL EMERGENCY RESPONSE PLAN (EERP) APPENDIX C – STAKEHOLDER ENGAGEMENT PLAN APPENDIX D – AMEBIENT AIR QUALITY ASSESSMENT APPENDIX E – ECOLOGY SURVEY APPENDIX F – NOISE MONITORING SURVEY APPENDIX G – WATER QUALITY ANALYSIS APPENDIX H – SOCIO-ECONOMI SURVEYS APPENDIX I - TRAFFIC SURVEY

Document Title. UMM WU’AL ESIA Revision A03

Ma’aden Doc Nº. MD-513-000-HS-EN-RPT-0070 of 463



EXECUTIVE SUMMARY

ES1.0 INTRODUCTION

The Saudi Arabian Mining Company (Ma’aden) intends to develop the Umm Wu’al Phosphate Project in the Kingdom of Saudi Arabia. This Project is based on the exploitation and processing of the Umm Wu’al phosphate deposit, taking advantage of existing and future railway infrastructure, linking the phosphate deposits of Umm Wu’al in the northern region with the Industrial City of Ras Al Khair on the Arabian Gulf (see Figure 1-1 below).

ES1-1: Location of the Umm Wu’al Phosphate Project Sites

The implementation of those elements of the Project to be developed at Umm Wu’al will increase fertiliser production and export from the Kingdom of Saudi Arabia.

The Project will be part funded by international banks and export credit agencies from OECD countries and, therefore, the Environmental & Social Impact Assessments (ESIAs) have been developed with regard to international environmental standards, notably the World Bank Group, and specifically the International Finance Corporation’s (IFC), Performance Standards on Environmental and Social Sustainability (2012) and the Equator Principles (as reviewed in 2012).

Due to the nature and scope of the Project, the assessment of the two main sites will be subject to different national regulatory requirements, namely the Presidency of Meteorology and Environment (PME) (for the development at Umm Wu’al) and the Royal Commission (RC) (for the development at Ras Al Khair). A separate ESIA will therefore be produced for each Project site.

ES2.0 PROJECT DESCRIPTION

The Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex in the Sirhan-Turaif region of northern Saudi Arabia will include the following components: Mine, Beneficiation, Phosphoric Acid Plant, Sulphuric Acid Plant, Purified Phosphoric Acid Plant, Sodium TriPolyPhosphate Plant, Mono and Dicalcium Phosphate Plant and the associated infrastructure required to process the extracted ore.





ES2.1 SITE LOCATION

The Umm Wu’al site (see Figure 2-1 below), is situated within the Northern Borders Province of the Kingdom of Saudi Arabia close to the border with Jordan, and covers an area of approximately 58km2. The Mine is located close to the border with Jordan within the 10km border security zone and 26km to the southwest of the Iraq border. The proposed Waad Al Shamaal Phosphate Industrial Complex lies within the boundaries of the planned Waad Al Shamaal City development, 13km to the south of the Mine. There is also a well field area for the abstraction of water located approximately 60km to the east of the Waad Al Shamaal Phosphate Industrial Complex.

The closest sizable population centre is Turaif, which is located approximately 40 km to the south-west of the site, and has a population of 48,929, of which 82% are Saudi nationals. The nearest settlement in Jordan is identified as Ar Ruwayshid, some 80-90km to the north.

ES1-2: Layout of the Umm Wu’al Phosphate Project Si te

ES2.2 CONSTRUCTION

The construction phase of the project is divided into an Early Works Package, and main construction phase. The Early Works package allows the preparation of the site in advance of the main construction phase and will commence in September 2013. Works include grading and levelling of the industrial complex area, temporary roads, laydown areas, waste areas and construction camp areas. Temporary flood protection works are also required.

A separate Construction Environmental Management Plan (CEMP) has been developed for the Early Works, to allow commencement of construction.

ES2.3 MAIN CONSTRUCTION

The process facilities will mainly be constructed using off site pre-fabrication, and modular construction. The infrastructure works will be constructed with local contractors, where available, undertaking specific aspects of the work. The construction works will be performed





in many areas at the same time to meet the required schedule.

A construction camp area has been identified 5km to the south of the Industrial Complex area. The construction camp will include temporary site offices and associated facilities, accommodation area and communal facilities including recreational and sports facilities, kitchens and dining halls, laundry facilities, medical centre, and a mosque.

The temporary facilities will include the storage of 2 days potable of water supply provided through delivery by tanker from Turaif, or via a locally sunk well. This water will be used for drinking, as well as for construction activities such as concrete mixing and dust suppression. Wastewater will be collected via septic tanks and emptied by tanker to the temporary wastewater treatment facility located within the construction camp. Power will be provided by diesel generators until the installation of a sub-station connecting to the national grid is provided.

The construction schedule will generate vehicle movements to and from the site as well as within the construction site. Traffic movements are estimated to be:

• Maximum 250 vehicle movements for transport of workforce per shift;

• 3 to 5 HGVs per day for supplies to the temporary camp and removal of waste;

• 60 water tankers per day for potable water supply during the early works period (until the water treatment plant is functioning); and

• 293 HGVs per week for materials and equipment supply to site

Particular attention will be paid to areas which may impact or be impacted by the simultaneous development of Waad Al Shamaal essential infrastructure and phase 1 residential development.

Anticipated solid wastes generated during the 30 month construction include concrete, pipework and steel off-cuts, electrical cable waste, municipal waste and solid sanitary waste.

ES2.4 COMMISSIONING

The main activities and sequence of operations during the pre-commissioning and commissioning phase can be summarised as follows:

• Hydrotesting of pipelines and tanks;

• Flushing & cleaning of pipelines;

• System dry-out;

• Inerting;

• Systematic conformity check of equipment;

• Static, de-energized test of equipment;

• Preliminary, and Functional checks;

• Operational test; and

• Pre-Start up activities.

Hydrotesting of pipelines, tanks, and vessels will be conducted using fresh (desalinated) water, provided from the well sunk for the construction phase, or the Project wellfield, once operational. The total quantity of fresh water will be minimised through hydrotest water reuse. Discharge of hydrotest wastewater will be routed to the contaminated stormwater pond for testing prior to its reuse or disposal.

ES2.5 OPERATION

To support the proposed operations the Project provides infrastructure will include a wellfield supplying the Project’s water demand, and associated water treatment, cooling water, loading / unloading, materials handling and storage facilities, auxiliary and emergency power,





wastewater treatment, drainage services and waste facilities.

The Project also involves the provision of administrative areas such as offices, a training centre, workshops and laboratories, and the provision of housing and essential services for the Ma’aden staff who will operate the facility.

Processes undertaken on site as part of the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex include:

• Open cast mining of phosphate containing rock by blasting, drilling and excavation of the rock.

• Separation of the phosphate ore from other rock constituents through flotation.

• Sulphuric A=acid production using molten sulphur, heated air and catalysts. The heat generated is used to produce energy enabling the Project to be largely energy self-sufficient.

• Merchant grade phosphoric acid production using rock slurry reacted with the sulphuric acid, and kaolin, before being filtered. The resultant phosphoric acid is evaporated to concentrate it to produce merchant grade phosphoric acid for export and use in other processes. Waste includes and phosphogypsum and fluorosilic acid which is neutralised with lime and gases which are scrubbed before being released to atmosphere.

• Merchant grade phosphoric acid is desulpherised, defluorinated and purified to produce food grade phosphoric acid. Solvent used in the process are regenerated and fumes are scrubbed and oxidised. Fluorosilic acid is precipitated out as sodium fluorosilicate, and phosphogypsum waste is also produced as a waste.

• Purified phosphoric acid is mixed with soda ash and caustic soda to produce a mixture of Monosodium Phosphate and Disodium Phosphate which is dried and heated to high temperature to produce dry Sodium TriPolyPhosphate

• Merchant grade phosphoric acid is also defluorinated with diatomaceous earth, and passed through a scrubbing system which generates fluorosilic acid, which is neutralised with calcium hydroxide. The phosphoric acid is combined with limestone slurry to produce phosphogypsum and a defluorinated phosphoric acid, which is heated and again reacted with limestone slurry and the recycle stream of Mono and Dicalcium Phosphate to produce Monocalcium Phosphate and Dicalcium Phosphate product.

All gypsum and neutralised fluorosilic acid wastes are disposed of to a lined Phosphogypsum Storage Facility.

Liquid sulphur required for the production of sulphuric acid, will be transported by rail to the Industrial Complex while soda ash, and limestone and other materials required for use in the chemical process will be transported by road. The processed materials will be transported by rail from the Umm Wu’al site to the proposed industrial complex at Ras Al Khair or to Jubail / Dammam for storage, use and/or export.

Energy generated by the chemical processes in the form of heat and steam will be used to generate most of the power for the plant through the provision of Steam Turbine Generators. An auxiliary boiler for initial start-up of the sulphuric acid plant and emergency diesel generator for back-up and black start of the facilities will also be provided. The facility will however, also be connected to the national grid. All fuel storage tanks are bunded, to prevent pollution from spillages and any contaminated waters are to be disposed of at specialist facilities.

Raw water will be abstracted from the Tawil aquifer to provide for the needs of the Project; following abstraction water will be pumped to the water treatment plant which uses reverse osmosis for the supply of process and potable water.

In recognition of the scarcity of water in this region, and the low recharge of the aquifer, waste water volumes from all treatment process units have been minimised and re-used wherever possible. Brine generated by reverse osmosis is re-used as the medium within the brine open cooling water circuit, for slaking limestone in the fluorosilic acid neutralization plant within





phosphoric acid plant and as a dust suppressant at the mine. These approaches reduce the quantity of wastewater for disposal, and minimise the demand for raw water.

The on-site Industrial Wastewater Treatment Plant will condition any discharges arising before directing it to the water management system of the lined phosphogypsum storage facility for evaporation. The on-site sanitary wastewater treatment plant will receive all the sanitary effluent discharges from the wellfields, mine and Industrial Complex by a combination of gravity sewers, pressurized sewers and tankered waste imports. Domestic wastewater will be treated on site for use as irrigation water. Sludge will be dewatered for disposal to land as cake or at licensed facilities.

Waste oil and engine coolant will be collected and held in separate storage tanks before being tankered offsite by a specialist contractor for processing or safe disposal.

A significant quantity of solid waste will be generated by the Project. The on-site facilities include:

• Temporary Waste Rock Dump - waste rock generated during the first 5 years of exploitation through the mining operations will be stored in the north east of the mine area, prior to commencement of backfill operations. These will be removed and re-handled in Years 8 to 11 of production life to be used as backfill and provide access to underlying reserves. All run off from the temporary waste dump will be captured by perimeter ditches and pumped to the mine pit de-watering system.

• Tailings Storage Facility – includes storage areas for tailings, stockpiling of optical ore sorter reject (OOSR) material which is used as top cover for dust suppression, storage for off specification tailings, and an evaporation / stormwater attenuation pond. The facility includes a basal lining system for drainage and collection of excess water released by the stacked tailings

• Phosphogypsum Storage Facility – a lined facility designated for the receipt of phosphogypsum wastes and wastes associated with the neutralisation of fluorosilic acid. Residual brine, which cannot be reused, and any conditioned effluent from the industrial wastewater treatment plant is to be used as part of the slurry medium for the phosphogypsum and therefore will undergo evaporation from ponded areas of the stacks.

In addition to the processing plant and mine, the Project includes a general administrative and maintenance area, which includes a number of support buildings as follows:

• Workshops and warehouses;

• Gatehouses and weighbridge;

• Administration building and clinic;

• Central Quality Control and Research and Development laboratories;

• Training centre;

• Cafeteria;

• Mosque; and

• Security and reception buildings.

A portion of the Waad Al Shamaal City development will be constructed in parallel with this Project to provide permanent accommodation for employees who will operate the Mine and associated Industrial Complex, and their dependents. This comprises:

• Accommodation;

• Community facilities;

• Local roads and utilities; and

• A highway to connect the residential and Industrial Complex to Highway 85.





ES2.6 WORKFORCE

During the construction phase, the workforce is estimated to be between 7,000 and 10,000 direct workers. Construction work week will be 10 hours / day for 6 days / week.

During the operation phase, the Mine and associated Industrial Complex will operate 24 hours per day. In accordance with Saudi Labour Law, the proportion of Saudi employees is required to be 65% at the commencement of the project, rising to a minimum of 85% by year 5 of the Project’s operation.

Operations staffing is estimated to at least 700 individuals on site within any shift, working 8 hour shifts and 12 hour shifts. The operational workforce will be predominantly transported to site by bus.

The number of daily visitors is estimated on average to be 4 persons per day, and up to 154 trainees attending training at the site with 116 Heavy Goods Vehicles (HGV) that will visit the site on a daily basis to deliver materials required for the operation of the Project.

ES3.0 CONSIDERATION OF ALTERNATIVES

The proposed Mine and Industrial Complex have been developed following the consideration of a range of project and design alternatives including:

• Alternate Project “Do Nothing” option;

• Site alternatives;

• Alternative production options;

• Surface / flood water management options;

• Pollution control alternatives; and

• Waste management alternatives.

Potential social and environment factors were included in the identification and selection of alternatives during the front end design phase.

In addition, as the Project progressed the proposed facilities were tested against Best Available Techniques (BAT), as required under the Presidency of Meteorology and Environment General Environmental regulations (2001), and the International Finance Corporation (IFC) Performance Standards.

The IFC has defined, in Performance Standard 3, the following objectives for promoting efficient use of resources and pollution prevention:

• To avoid or minimise adverse impacts on human health and the environment by avoiding or minimising pollution from project activities;

• To promote more sustainable use of resources, including energy and water; and

• To reduce project-related greenhouse gas emissions.

ES4.0 SUMMARY OF SIGNIFICANT IMPACTS

The Environmental and Social Impact Assessment (ESIA) for the Umm Wu’al Mine and Waad Al Shamaal Industrial Complex has been undertaken according to the Presidency of Meteorology and Environment (PME) General Environmental Regulations (2001), and draft supplementary Standards (2010), and World Bank and IFC guidance. It has considered all potential impacts of the construction, commissioning, operation and closure / decommissioning of the Project on the environment, employees, and local community. Furthermore, it has also considered these effects in combination with each other and with other development in the area.

The ESIA includes an Environmental Management and Monitoring Plan (consisting of a number of sub-plans), and an Emergency Environmental Response Plan,. These plan detail the measures identified in this phase for the mitigation of any impacts, and the measures for emergency preparedness in the event of an accident. In addition, Ma’aden will implement and





Environmental Management System for the project in line with international best practice. These plans are considered as “Live” documents, which are updated with any further recommendations identified in future phases.

The results of the impact assessment are summarised below. Potential impacts predicted as being of medium to high significance were assessed against appropriate mitigation measures to predict the residual impact significance. Potential impacts of lower significance were also identified, and although specific mitigation measures are not required for these aspects, a series of recommendations which are considered as good management practices are identified. An overarching recommendation is the ongoing development, implementation and maintenance an Environmental Management and Monitoring Plan (EMMP) and Environmental Emergency Response Plan (EERP), both of which are provided in outline as part of this ESIA tailored to each phase of the Project.

ES4.1 AIR QUALITY AND METEOROLOGY

Impacts of the Project on air quality were assessed against current air quality conditions,. The contributions from the Project were compared as additional contributions to the existing situation to determine the overall impact of the Project on air quality.

The Presidency for Meteorology and Environment has defined Air Quality Standards for a variety of potential pollutants from point sources, and ambient air quality. Point source emissions are compared to the more stringent of PME and IFC standards. PME standards are used to determine compliance with ambient air quality, since according to IFC local standards take precedence, and IFC are only used in the absence of local standards.

The potential impact of greenhouse gases has also been assessed as required by the IFC’s Performance Standard 3 and Equator Principles 2.

ES4.1.1 RESULTS

Concentrations of sulphur dioxide, carbon monoxide and nitrogen dioxide generated by the Project fall below the PME Standards ambient air quality standard levels, and.remain below these when added to the background concentrations. Particulate matter is present in high background concentrations around the site; dominated by contributions from dust storms in the area. The results of the modelling indicated that the additional contributions from the Project will be minimal.

The Project will generate emissions of greenhouse gases throughout its operation. The International Energy Agency estimated the total carbon dioxide emissions in KSA as 446 Million tonnes in 2010. Of this total, 104 Million tonnes were from manufacturing and industry.

Wherever possible the production of carbon dioxide (CO2) has been reduced in all stages of the project. The utilisation of the waste heat, and steam from the process to power steam turbine generators allows the Project to be largely energy self sufficient, making a significant contribution to the minimisation of CO2 emissions.

The total estimated CO2 emissions generated by the Project including operations and vehicle emissions would be approximately 77,706 tonnes per year. This falls below the 100,000 tonne threshold defined by the World Bank/IFC standards. In addition, the best available technology would be used for the Project which could further reduce total CO2 emissions in the future.

There are no medium or high negative impacts identified by the Impact Assessment, however, a number of recommendations are made to address low significant impacts.

ES4.1.2 RECOMMENDATIONS

Recommendations for the construction phase are focussed on the reduction of dust impacts. These include:

• The development and implementation of a Construction Environmental Management Plan.

• All dust generating materials being moved to be covered with a suitable weighted





tarpaulin.

• Pedestrian routes within the construction area are to be provided for the workers.

• The amount of materials stockpiled to be minimised as far as is practicable, with any required stockpiles aligned parallel to the prevailing wind direction.

• Exposed soils / dust generating stockpiles to be covered with gravel or crushed stone where feasible to reduce windblown dust generation.

• The speed limit for vehicles to be reduced to prevent the generation of dust clouds.

• Damping down of road surfaces to be implemented.

• Uneven surfaces on construction traffic routes to be graded periodically.

Recommendations for the operational phase are focused around the monitoring of emissions and include:

• Undertake monitoring of emissions as detailed by the PME with reporting to the relevant authorities.

• Appropriate maintenance of important mitigation equipment such as scrubbers, catalyst beds etc.

• Competencies and training requirements of staff with environmental responsibilities, and lines of communication in the event of an emergency (including accidental releases of hazardous substances).

• Minimising use of auxiliary and back up boilers.

In addition, Ma’aden will undertake regular audits of environmental management plans to confirm their on-going effectiveness.

Prior to the commencement of operations, ambient air quality data will be gathered and such data sets built on during the course of operations as appropriate.

ES4.2 TERRESTRIAL ENVIRONMENT

The Project area is currently an undeveloped site. The baseline assessment involved the analysis of soil and groundwater samples taken around the site. These indicated that soils are generally unpolluted. Levels ofselenium are below guide levels for industrial use, although are at or just above levels for residential. Low levels of naturally occurring radioactive materials are found to be present in the phosphate ore.

Groundwater resources are present at the site.. The Tawil aquifer is the dominant source of groundwater in the area. The acquifer has limited recharge and therefore represents a finite water resource for the area. Analysis of groundwater samples suggest the water is slightly saline and would require treatment prior to use as potable water.

The assessment of effects considers impacts from all phases on soils and groundwater using the source-pathway-receptor method, and includes some modelling of impacts on groundwater resources.

ES4.2.1 RESULTS

The impact assessment identified potential for impacts on the soil resources, and degradation of soil quality from accidental spills during all phases. The modelling, however, suggests that the release of pollutants from accidental spills is likely to be rare, and therefore the potential for impacts is reduced.

There is also potential to impact the groundwater resources through depletion of the limited recharge aquifer impacting both on the long term water resources in the area, but also creating drawdown of the aquifer affecting other users.

There is also potential for impacts during operation from leakage of chemicals from the plant





facilities or from catastrophic failure of the plant. The likelihood of this occurring, however, is very low.

The following mitigation measures were identified to mitigate potential impacts of high or medium significance:

• Stockpiling of soils for reuse as part of the Project design to minimise impacts on soil resources.

• All storage tanks shall be above ground and maintained in good condition and inspected regularly. A record must be kept of all liquids/tanks/containers delivered to the site.

• All vehicles used on site shall be serviced and maintained to the highest standard, with a record kept of maintenance undertaken.

• Designated refuelling, maintenance and storage areas shall be constructed in line with pollution prevention guidelines. These areas shall be hard-surfaced and contained by walls or bunds, with drainage systems and collection arrangement for spills and stormwater management

• Hydrotesting, flushing and disposal of wastewater will be undertaken in line with appropriate measures to control, collect and treat the produced water.

• Wastewater should be treated where required to comply with water quality standards applied to discharge and as a minimum will pass through an oil/fuel interceptor facility.

• Any accidental spill/leak will be fully cleaned as soon as the incident occurs.

• Design shall be such that accidental release from bunded containment areas would still discharge to a site drainage system in preference to entering the ground

• Groundwater level monitoring shall be undertaken prior to and during the Project life.

• Waste materials shall be removed from site where possible following decommissioning. Any materials or plant to remain on site must be checked and contained/treated as necessary prior to site closure to ensure no potential soil contamination source remains.

• Drainage systems, including evaporation ponds shall be retained and shall continue to be maintained for a period after operations have ceased, while they are still producing significant potentially contaminative liquid.


In addition to the specific mitigation measures identified a number of good management practise recommendations have been identified to prevent and reduce pollution from accidental spills, and protection of the soil and groundwater resources. The focus of these are the implementation of procedures for prevention of and reaction to accidental releases of hazardous substances, the training of staff, and the implementation of monitoring of groundwater levels and quality during operation and following closure / decommissioning.

ES4.3 BIOLOGICAL RESOURCES

The Project is located within Northern Wildlife Management Zone, a designated International Union for the Conservation of Nature Category IV Protected Area. The Protected area covered by the Project is state owned.

The area around the Mine site consists of a relatively flat area of sand sheet and gravel plains and low rock outcrops, with no significant tree cover. There are very few wells but herders are present near ephemeral pools with grazing sheep.

A number of protected species are present in the project are. These include:

• Arabian wolf (Canis lupus arabs);

• Sand cat (Felis margarita);

• Blanford’s fox (Vulpes cana);





• Greater Spotted Eagle (Aquila clanga);

• Saker Falcon (Falco cherrug);

• Houbara Bustard (Chlamydotis undulata macqueenii);

• Egyptian Vulture (Neophron percnopterus);

• Pallid Harrier (Circus macrourus);

• European Roller (Coracius garrulous);

• Spiny tailed lizard (Uromastyx aegyptius microlepis); and

• Several species of reptile listed as High Conservation Priority.

ES4.3.1 RESULTS

The impact assessment identifies several medium and high significance impacts on both habitats and species from the project.

The Project itself will result in the direct impact on approximately 59km2 of the designated Northern Wildlife Management Zone Protected Area. The loss of biological resources under IFC principle 6 requires consideration of appropriate measures to avoid or minimise impacts. Where this is not possible restoration of the area is required, or a biodiversity offset area provided if restoration of the area cannot be undertaken effectively.

There are also potential impacts on protected species as a result of habitat loss, degradation and fragmentation.

Project construction and operations may result in the killing and injury of species on-site, especially through vehicle movements. Pollution of the habitats, soils, and potential water resources from spills etc., are also significant impacts. Disturbance as a result of noise during construction and operation may also impact on certain species including protected birds.


• Designate, demarcate and maintain unfenced exclusion zones adjacent to the Mine and Industrial Complex to protect sensitive habitats from unauthorized access to ensure no net loss of habitat functionality. This should be an equivalent area to that impacted (i.e. 59km2). Within this area undertake habitat restoration and rehabilitation works.

• Prior to site clearance and cut / fill operations complete a pre-construction site survey for globally / regionally endangered, vulnerable and / or near threatened species (i.e. Arabian wolf, sand cat and Blanford’s fox). This is to account for any changes to the status of species as determined from the baseline surveys.

• Avoid areas where globally / regionally endangered, vulnerable and / or near threatened species are recorded as having a place of rest of shelter (i.e. den) during pre-construction site survey. Where avoidance is not possible, undertake displacement / exclusion measures to reduce impacts of killing / injury.

• Avoid Houbara bustard nesting period wherever possible (i.e. February - April), and if this cannot be avoided use bird deterrents prior to the commencement of construction activities to deter nesting birds.

• Provide signage warning of the presence of wild animals on haul routes, raise driver awareness and enforce speed limits for vehicles

• All contractors / employees shall receive a Site Induction which includes the ecological value and sensitivity of the Project area.

• Restrict vehicle movements to defined haul / access routes to minimise risk of wildlife collisions with vehicles.





• All security fencing that is installed, other than around evaporation ponds etc., will allow for the passage of large lizards and medium sized mammals (e.g. sand cat, Blanford's fox).

• All industrial waste water treatment facilities, containment systems and evaporation ponds shall be securely fenced to prevent the ingress of mammal and reptile species. Use bird deterrents (i.e. predator kites) to deter bird species utilising these areas.

• Do not permit unauthorised access, recreational activities or hunting within habitat exclusion zones.

• Light pollution will be minimised by restricting lighting to essential areas only, and by using directional lighting to reduce light spillage. Working at night will be avoided and earth moving equipment will be fitted with more efficient sound reduction equipment wherever possible.

• Native plant species of local provenance shall be used wherever practicable to reduce the risk of transmitting biological pathogens and alien species. Implement a quarantine procedure for all plant specimens brought to the Project area.

• A Habitat Restoration Plan shall be developed for the phased rehabilitation of the Mine as extraction progresses throughout the life of the Project


To evaluate the success of the proposed mitigation a robust and comprehensive ecological monitoring plan will be implemented prior to the commencement of construction activities. The scope of this monitoring plan will be developed in full consultation between Ma’aden and the governing bodies within the Kingdom of Saudi Arabia. Under this plan, sensitive ecological receptors and indicator species will be monitored to assess the effectiveness of the proposed mitigation measures in managing these impacts.

Compensatory habitat equivalent in area to that being impacted (59km2) will be provided. This is to be in the form of unfenced exclusion zones to allow species to move across the area and which are managed to restore, rehabilitate and enhance their ecological value. A Biodiversity Management Plan will be developed to set out the measures required to enhance the ecological integrity and functionality of the habitats based on the findings of the ecological monitoring. The Plan will be reviewed and adjusted in line with any findings to ensure successful delivery of the objectives for the compensatory area.

Ma’aden shall liaise with the Waad Al Shamaal City developers and Government bodies to co-ordinate provision of offset areas for implementation of habitat enhancement, protection and restoration / rehabilitation measures. This might include designating areas between the mine and Waad Al Shamaal City as protected areas

ES4.4 NOISE AND VIBRATION

Potential impacts of the Project on noise and vibration were modelled and assessed. The contribution from the Project was compared to the PME Noise and Vibration Standards for both daytime and night-time.

ES4.4.1 RESULTS

Baseline noise measurements taken at the Project site boundary are within the PME and IFC standards. The Project has been designed to comply with the requirements laid down in the PME general environmental regulations (2001) and draft Supplementary Standards (2012) and include measures such as housing of potentially noisy plant and equipment.

As a result, the modelling shows that potential negative impacts are likely to be of low significance in all phases.


There are no specific mitigation measures required as part of the Impact assessment, however, recommendation include:





• A revised noise and vibration assessment should be undertaken prior to construction to ensure compliance with applicable standards. This should include work to establish and ensure acceptable vibration and air overpressure during blasting operations.

• A series of trial blasts to be undertaken at the mine with measurements of vibration and air overpressure to inform the noise and vibration assessment.

• Temporary sound-proof enclosures and anti-vibration measures should be employed to reduce noise levels on site, in keeping with the results of the updated noise and vibration mode.

• A noise and vibration management plan should be developed detailing measures to monitor and control noise and vibration emissions during construction. This Plan should include monitoring of noise at the Mine site boundary, particularly the north western and western boundaries, to determine compliance with applicable standards and guidelines and assess the need for mitigation.

• Regular audits of the above monitoring and management plan should be undertaken and revised in line with results.

ES4.5 WASTE MANAGEMENT

Waste from Turaif is currently disposed of in a municipal landfill, located approximately 5km north of the city. However, access to this landfill has been denied for Project waste.

The levelling and grading as part of the early works has been designed to ensure waste is minimised, and all materials are reused on site.

The city of Waad Al Shamaal will include Class I, II and III landfills which are expected to be complemented by recycling and thermal treatment technologies. The Project proposes to use these facilities when they become available.

ES4.5.1 RESULTS

The impact assessment identifies medium significance impacts associated with the generation of wastes by the Project and the lack of available off-site waste management infrastructure during construction, and commissioning and early stages of operation.

Waste types identified during this assessment include:

• Non-hazardous solid wastes: construction debris, wood (pallets), empty drums and containers (plastic and metal), packaging (paper, cardboard, plastics), waste rock from mining, silaceous materials and tailings, municipal wastes and sanitary waste sludges;

• Hazardous solid waste: batteries; filters; empty oil, chemical or paint containers; fabrics contaminated with oil; phosphogypsum, fluorspar, sodium fluorosilicate, calcium fluorosilicate, spent catalyst, spent activated carbon, spent electrical equipment, industrial wastewater treatment sludge, oily sludge and clinical waste; and

• Hazardous liquid waste: waste oils, lubricants and fuels and drainage waters contaminated with these, solvents; paint; thinners; hydraulic fluid; and cleaning chemicals; contaminated hydro-test water.

The most significant wastes generated by the Project are to be managed on site as follows:

• Mine wastes are used to progressively backfill, and close the excavated pit.

• Optical ore sorter rejects, tailings and phosphogypsum, and fluorosilicates are to be stored in dedicated, lined and appropriately engineered waste storage facilities. These will remain on the site following decommissioning.

All other wastes are to be stored on site temporarily in suitable storage containers / transported off site by PME approved waste carriers to off-site licensed waste management facilities.

The assessment also identifies a high significance impact associated with the on-site waste





storage facilities associated with potential failure of these containment systems,


• Ma’aden shall devise a waste management strategy for the disposal wastes in collaboration with Turaif Municipality, the PME, and Waad Al Shamaal developer which identifies appropriate local disposal / recycling facilities that are operated in accordance with regulatory requirements and industry good practise.

• EPC Contractor will develop a Construction Waste Management Plan, and Ma’aden to develop an Operational Waste Management Plan to identify in more detail anticipated wastes, and their quantities, and undertake waste planning for treatment and disposal.

• Ma’aden shall commission a condition report prior to decommissioning identifying key issues such as condition of lining and drainage system for the on-site waste storage facilities.

• Ma’aden shall develop further the outline closure plan to include maintenance programme, monitoring and reporting strategy and emergency action plan for the waste storage areas and shall resource and implement these plans.

ES4.5.2 RECOMMENDATION

In addition to the specific mitigation measures identified a number of good management practise recommendations have been identified reduce the impact of waste from the Project. The focus of these are the implementation of procedures for the management, maintenance and monitoring of waste storage areas, and prevention of and reaction to accidental releases of wastes, reduction of waste storage times, the training of staff, and waste contractors, the selection of appropriate and as necessary specialist contractors for the handling, transportation and disposal of waste and audit of waste contractors and their off-site facilities and the collection and reporting of data on waste arisings.

ES4.6 WATER QUALITY MANAGEMENT

There is an extensive network of ephemeral wadis, and four in particular, that run across the Project area into a natural depressions in the landform. The wadis are wide shallow channels, apparent from the vegetation they support. These wadis present a flood risk to the project.

Water samples taken from an accumulation of surface water in a depression fed by wadi flow in 2012 show high levels of heavy metals, which exceed the ambient surface water quality standards set by the PME. Soil samples in the area were taken as part of the ground investigation, and analysed for presence of heavy metals which identified concentrations of heavy metals within the superficial deposits tested. The levels of these are lower than international guidelines for residential use. Surface water quality analysis identified concentrations of some heavy metals in exceedence of the PME ambient water quality standards however, given the Greenfield nature of the site, the evapo-concentration processes highlighted by the leach testing, and the nature of the local geology, the levels of metals in the surface water are considered to be attributable to natural causes.

Flood modelling has been undertaken, and a combination of protection (e.g. bunds) and wadi diversion will be required to protect the Project from flooding during heavy rainfall. With the exception of the one of the wadis (known as the middle wadi), natural restoration of channel will be allowed following closure / decommissioning. The middle wadi will be permanently diverted to allow for the development of the Waad Al Shamaal City.

The tailings storage facility and phosphogypsum storage facility will be left in place and will require on-going management and maintenance to ensure that the environment is protected from contaminated discharges following decommissioning.


There are no specific mitigation measures required as part of the Impact assessment, however, recommendations for the prevention and reduction of pollution from accidental spills,





and protection of the surface water systems include:

• Provide training of staff in environmental awareness and pollution prevention, and lines of communication for accidental releases of hazardous substances;

• Construction of designated refuelling, maintenance and storage areas in line with pollution prevention guidelines. These areas are to be hard-surfaced and contained by walls or bunds, with drainage systems and collection arrangement for spills and stormwater management;

• Ensuring the availability of pumps and spill mitigation materials such as absorbent granules to contain and recover hazardous substances following release;

• Implementation of procedures to be followed in the event of accidental release of hazardous substances;

• Ensuring vehicles used to empty septic tanks are fit for purpose and operated by trained members of staff to prevent spillage;

• Ensure washing-out of concrete delivery, mixing and pouring plant and equipment are undertaken in a designated area and all wash water shall be contained for subsequent treatment and re-use and / or discharge;

• Undertake a programme of surface water sampling to establish the current ambient water quality, and monitor throughout project. Monitoring should be continued following decommissioning;

• Monitoring of treated sewage effluent quality to ensure compliance with required standards;

• Identification of suitable users and areas for the use of treated effluents and agree arrangements for its supply and/or application;

• Condition report to be produced before decommissioning identifying key issues such as condition of lining and drainage system;

• Implementation of a management plan prior to decommissioning of the facility, to include maintenance, monitoring and reporting strategy and emergency plan; and

• Regular audits of the above monitoring and management plan to be undertaken and revised in line with results.

ES4.7 SOCIO-ECONOMICS

The Project will provide many benefits to the region and to Turaif in particular. The new development will create greater opportunities for employment and for local and regional businesses to provide goods and services to Ma’aden, its contractors and its workers.

Potential negative socio-economic impacts include loss of access to land for the local community, and increased strain on local services.

A Stakeholder Engagement Plan has been developed as part of the ESIA and will be maintained throughout the project lifetime.


• EPC Contractor shall develop and implement a procedure for the management of unexpected archaeological resources, and shall report any finds to Ma’aden and in accordance with National requirements.

• EPC Contractor shall provide the workforce with tool box talks on the subject to raise awareness of the importance of cultural and heritage resource finds.

• The EPC Contractor shall minimise the area of land required for use during the construction.





• Ma’aden shall provide on-going community consultation and in particular provide guidance and assistance regarding use of alternative sites and respond to concerns in accordance with the Stakeholder Engagement Plan process.

• Ma’aden to enter into an agreement with Turaif Municipality regarding the capacity of municipal services to be supplied to the Ma’aden housing during the early stages of operation. Where capacity is not available, Ma’aden to establish alternative service provision.


Implementation of the following measures is recommended to manage the potential impacts identified and to maintain good management practices:

• Develop Social Impact Management Plans (SIMP) as required under Ma’aden Environment and Communities Assurance Project manual, and implement in full all identified recommendations;

• Employ local resources with skills to suit the required roles where available, and use local companies to supply goods and services wherever feasible;

• Implement a comprehensive training programme to ensure the appropriate skill sets are developed and transferred to new personnel;

• Induction training to be provided to all foreign and non-Muslim workers on the local culture and practices, and camp management procedures to be established to minimise interactions and possible tensions; and

• Seek to support employment in the region and within other Ma’aden projects following decommissioning of the Project facilities.

ES4.8 TRAFFIC AND TRANSPORT

The Project area is served by Highway 85, a dual carriageway which connects Dammam in the Eastern Province and the border with Jordan. A new junction off Highway 85 is currently under construction at Turaif.

Public transport options for the region include a daily bus service operating between Turaif and Riyadh, and Turaif Domestic Airport, which is served by a single daily flight to and from Riyadh.

The railway is currently not fully operational and no passenger service is currently operating. The Umm Wu’al Phosphate Project requires a length of 135km of track to connect to the existing railway at Al-Jalamid, which transports phosphate from the existing Al-Jalamid Mine to the processing plant at Ras Al-Khair. There are no medium or high negative impacts identified by the Impact Assessment, however, medium significant benefits are identified for the operational phase once the rail infrastructure for the region is completed.


A Traffic and Transport Plan will be developed as part of the Environmental Monitoring and Management Plan, prior to commencement of any activities on site. In accordance with the IFC Guidelines, Project vehicles will avoid accessing the public highway wherever possible. Where vehicles must use the highway network, access to the site will be routed via the eastern approach on Highway 85 to avoid impacts on the local community in Turaif.

Further recommendations include:

• Co-ordination and liaison with the Airport authorities, operators, and Turaif Municipality to, to address any potential impacts from influx of workers to the area.

• Co-ordination and liaison with the Ministry of Transport, Saudi Railway Company, and the local authorities during all phases to ensure coordination of programmes and minimise use





of road transport wherever possible;

• Confirmation of capacity within the rail network and availability of trains to deliver materials required during all phases;

• Development and implementation of rail scheduling and operational procedures;

• Management of start and finish times to reduce peak traffic flows;

• Undertake traffic risk assessments during all phases and implementation of any recommendations;

• Identification of access / traffic routes for vehicles both on and to the site (including transport for the workforce);

• Implementation of measures to segregate pedestrians from vehicle areas;

• Implementation of driver training and awareness for both Ma’aden personnel and contractors;

• Implementation of measures to protect the local community where appropriate;

• Provision of suitable wheel washing equipment to prevent materials being deposited on the public highway;

• Re-use of materials on site to reduce the requirement to import bulk materials from other locations.

ES4.9 UTILITIES INFRASTRUCTURE & USAGE

Significant economic and environmental benefits can be achieved by minimising the use and consumption of utilities services. Direct savings can be realised by the reduction in energy consumption and water supply reduction through the minimisation of wastage and unnecessary uses. There are currently no utilities and infrastructure available at the site; new infrastructure will be installed to service the Project.

Potential negative impacts of medium or high significance on the utilities infrastructure are not anticipated to occur as a consequence of the Project commissioning, construction, operation or decommissioning phases.


Implementation of the following measures is recommended to manage the potential impacts identified as being of low significance and to maintain good management practices.

• Confirm sufficient capacity within the Turaif sanitary wastewater treatment system/landfill to accommodate the wastewater / sludge generated at during the construction programme;

• Undertake monitoring of the temporary boreholes to supply potable and non-potable water for construction to ensure that these do not negatively impact the supply at existing wells used by the local population;

• Confirm the extent to which the existing telecommunications network can accommodate the connections required by the Project; and

• Maximise water re-use in construction and commissioning.

ES4.10 HEALTH AND SAFETY

The local facilities in Turaif comprise a general hospital with 200 beds, four operating rooms and one emergency room. The general hospital is capable of treating all injuries, with the exception of chemical injuries. There are also four general public health centres one of which operates a night shift, a dental clinic, and a diabetes clinic. In addition, there are three private health centres.

The nearest large general hospital is located in the regional capital of Ar’ar approximately





230km to the South-east. Recent investment in the region has enabled the construction and opening of a new cardiac centre at the hospital, providing a comprehensive cardiology service including cardiac catheterization and cardiac surgical operating facilities.

The health and safety of both employees and the local community has been considered as an integral part of the project design. The design process has included HAZID workshops and a series of detailed HSE assessments has been made for specific parts of the facility as part of the Front End Engineering Design process. Eliminating or reducing the risk of many of the potential operational Health and Safety impacts has been a central theme in this phase.

ES4.10.1 RESULTS

Out of a total of 75,825 workplace injuries in KSA in 2010, approximately half occurred in the construction industry. 21% of all deaths in 2009 to non-Saudi residents occurred as a result of accident or injury. Consultation with Turaif Municipality highlighted that 50% of all deaths in the area were the result of Motor Vehicle Accidents.

Potential sources of impacts during the construction phase include exposure to environmental factors (Air Quality, Noise, Water & Contamination), increased vehicle movement, Occupational Health & Safety of Construction Workers (including accidents and injuries, and mental health); and exposure to communicable and non-communicable diseases.

The implementation of safety in design principles reduced the potential impacts during operation considerably. Those identified included exposure of the workforce to airborne pollutants and dust, traffic and transport (including community effects); occupational health, accidents and incidents; and communicable and non-communicable diseases.

The impact assessment highlighted exposure of the workforce to workforce accidents, increase of communicable diseases amongst the workforce, and traffic impacts on the community as being of medium significance. Traffic safety impacts on the community were identified to be of medium significance.


• A risk assessment will be undertaken which shall define the specific risks and mitigation, including working hours, exposure limits, and use of PPE as required.

• Early engagement with local service providers to assess the capacity of the region to absorb any potential issues should be undertaken, and this will inform the design and staffing of the facilities to ensure local services are not adversely affected. This consultation should include all emergency services to ensure agreement is reached on the most effective mechanisms to deal with any major incident

• Training and awareness on issues such as defensive driving will be provided to the workforce and suppliers

• Decommissioning will be planned by developing, procedures, and any HSE requirements to ensure the project is decommissioned safely and effectively, using the correct PPE etc in line with requirements and intended future use.

• Implementation of the closure plan and associated post closure monitoring and maintenance requirements.


Consideration is to be given to extending defensive driver training to the local community given the current high death rate from motor vehicle accidents.

Implementation of a comprehensive health screening and monitoring programme is to be undertaken to ensure workforce health is maintained, and reduce the spread of any communicable diseases (e.g. chickenpox, TB, gastrointestinal infections etc.).

The Environmental Emergency Response Plan will detail the procedures and process to be





followed to protect both the workforce and the local community from potential harm in the event of an incident. This would include liaison with the local authorities to ensure services are (a) available, and (b) able to cope. Provision for evacuation to hospitals in Ar’ar is also to be included for incidents which the on-site medical facilities cannot treat (e.g. chemical, burns, heart conditions etc.), and which may be time critical. Given the distances involved in any transfer to Ar’ar, fully trained on-site medical staff will need to be able to treat to a level which allows safe transfer of the patient to the hospital facilities either through air transport or ambulance.

ES4.11 SUSTAINABLE DEVELOPMENT

The sustainable development assessment identified a number of positive and negative impacts associated with the project. These indicate that the Project faces a common challenge in terms of sustainability.

Negative impacts are typically associated with environmental sustainability. The positive impacts, though fewer in number are of greater magnitude, and are associated with socio-economic and infrastructure benefits.

The recommended areas of focus for the Project in terms of sustainability which are to be implemented in future phases include:

• Application of existing Ma’aden project processes, specifically the Environmental and Communities Assurance Manual; and

• Establishment of objectives, targets and key performance indicators to monitor achievement of the goals established for the Project and progress towards sustainable development; and

• Implementation of continuous improvements as identified by the Project’s Environmental Management System and associated monitoring, measurement and auditing

ES4.12 CUMULATIVE IMPACTS

Cumulative effects occur within the Project when the impacts identified within the assessment may collectively be of greater significance than the individual impact implies. Potential impacts associated with the proposed development may also be acceptable in isolation, but when considered in the context of other developments in the immediate vicinity, may become more significant.

Emissions to air from the Project can be expected to collectively impact on the air quality of the area, impacting the workers’ and community health as additional industrial facilities are constructed and become operational. It should also be noted that the development of the Waad Al Shamaal City Development and the community therein, will create sensitive receptors in the future that do not currently exist.

Demand on the Tawil aquifer as a source of water is expected to be significant as the Waad Al Shamaal City is developed. This is a finite and non-renewable water resource given the extremely low recharge rates and the cumulative impact of the Project on the groundwater resource is considered to be significant. Alternative sources of water will need to be piped from the coast as the city develops.

The development of Waad Al Shamaal City can be expected to result in further habitat loss and fragmentation within the Northern Wildlife Management Zone with increased disturbance, injury and mortality to Nationally and Internationally vulnerable species. The cumulative impact of the future project is therefore considered to be significant, although, the proposals to protect the Umm Wu’al mountain area as a recreation area could assist in protecting some of the vulnerable species and habitats.

The influx of people into the area and the increasing industrial activity may present cumulative health impacts on both employees and the wider community. Furthermore the development of the industrial zones brings these impacts closer to the community zone. These impacts can be readily managed, through strategic planning and assessment of the Waad Al Shamaal City development





The Waad Al Shamaal City development is envisaged to generate a significant level of economic development, and provide a range of community services and infrastructure. Thus the positive socio-economic benefits are considered to the highly significant. The concerns regarding access to land for cultural uses will be exacerbated by the Waad Al Shamaal City development however, there are opportunities for access to alternative lands for herding and grazing.

ES5.0 CONCLUSIONS

The predicted impacts of the proposed Umm Wu’al Phosphate Project are within the standards as defined by the Presidency of Meteorology and Environment in their Environmental Regulations. Many of the impacts are of low significance.

For those impacts identified as High or Medium, mitigation measures have been developed to further reduce the potential significance to Low.

All mitigation measures and recommendations have been detailed in the Environmental Monitoring and Management Plan for implementation during the next phases of the project.

The impact assessment identifies a number of areas where the impacts from the Project when combined with the proposed development of Waad Al Shamaal City, may result in significant cumulative impacts. These include:

• Air Quality – Negative;

• Terrestrial Environment – Negative;

• Biological Resources – Negative;

• Community and Employee Health and Safety – Negative; and

• Socio-Economic Aspects – Positive.

Of paramount importance is the continuous assessment of the environmental “headroom”, so as not to overload the carrying capacity of the area.

As a key stakeholder in the Waad Al Shamaal City development, Ma’aden shall make this ESIA available for use in cumulative impact assessments of future project ESIA, and shall liaise with the Presidency of Meteorology and Environment, Saudi Railway Company and Waad Al Shamaal City developer to support collaborative and multi-stakeholder solutions for cumulative impacts.





1.0 INTRODUCTION

The Saudi Arabian Mining Company (Ma’aden) intends to develop the Umm Wu’al Phosphate Project in the Kingdom of Saudi Arabia. This project is based on the exploitation and processing of the Al Khabra phosphate deposit and the utilization of captive natural resources in the northern region of the Kingdom of Saudi Arabia (KSA), and is taking advantage of the existing and planned railway infrastructure, linking the phosphate deposits of Umm Wu’al area in the northern region with the Industrial City of Ras Al Khair on the Arabian Gulf (refer to Figure 1-1).

Figure 1-1: Location of the Umm Wu’al & Ras Al Khair Phosp hate Project sites.

Ma’aden has formed a joint venture with Mosiac, the largest producer of phosphate fertilisers in the world, and Saudi Basic Industries Corporation (SABIC) to deliver this substantial project.

1.1 PROJECT UNDERSTANDING AND OVERVIEW

The Umm Wu’al site in the Sirhan-Turaif region of northern Saudi Arabia will include the following components: Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex including Beneficiation, Phosphoric Acid Plant, Sulphuric Acid Plant, Purified Phosphoric Acid Plant, Sodium TriPolyPhosphate Plant, Monocalcium Phosphate / Dicalcium Phosphate plant and required utilities to process the extracted ore. The Processing Complex is located within the boundary of the proposed Waad Al Shamaal Development City.

The processed materials will be transported from Umm Wu’al via existing railway infrastructure some 1500km to Ras Al Khair Industrial City, on the Arabian Gulf where materials will be further processed as fertiliser products or stored for export, or directly to Jubail or Damman some 70km and 145km further down the east coast respectively, for export.

Ras Al Khair is an existing Industrial City and port facility located on a peninsula in the Eastern Province of Saudi Arabia; the facility will be expanded to include new chemical production plants for Ammonia, Di-Ammonium Phosphate and Nitro Phosphate Potash. Proposed developments also include all supporting infrastructure and connection to existing utilities within the Ras Al Khair Industrial City. For the purpose of this report the new developments





proposed by Ma’aden at Umm Wu’al will be referred to as the Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex (‘the Project’).

The industrial units to be developed at Umm Wu’al and Ras Al Khair will produce the following products:

• Merchant Grade Phosphoric Acid (MGA) 1,500,000 tpy;

• Purified Phosphoric Acid (PPA) 100,000 tpy;

• Sodium TriPolyPhosphate (STPP) 90,000 tpy;

• Monocalcium Phosphate and Dicalcium Phosphate (MCP/DCP) 250,000 tpy;

• Compound Fertilizer (DAP 2,228,094 tpy and NPK 766,920 tpy); and

• Ammonia 1,089,000 tpy.

Ma’aden has awarded a contract to Jacobs Engineering Group to provide a bankable feasibility study and front-end engineering design (FEED) for both elements of the Project (i.e. Umm Wu’al and Ras Al Khair).

Partnering with Woods Hole Group Middle East (WHGME), a Presidency of Meteorology & Environment (PME) and Royal Commission (RC) approved consultant, Jacobs’ scope of work includes the preparation of the bankable Environmental and Social Impact Assessments (ESIAs) for both the Umm Wu’al and the Ras Al Khair sites as well as the environmental permits required by the Royal Commission for Ras Al Khair.

The Umm Wu’al Phosphate Project will be part funded by a Lending Institution (which may include international banks and export credit agencies from OECD countries, therefore the ESIAs have been developed with regard to international environmental standards, notably the World Bank Group and specifically the International Finance Corporation’s (IFC) Performance Standards on Environmental and Social Sustainability (2012) and the Equator Principals (as reviewed in 2012).

Due to the nature and scope of the Project and the fact that the assessment of each site will be subject to different regulatory requirements (i.e. PME and RC); a separate ESIA will be produced for each Project site.

1.2

1.3 UMM WU’AL PROJECT SITE

The Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex project site is a greenfield site located in the Northern Province of the Kindgom of Saudi Arabia, approximately 40km to the Northeast of the city of Turaif. The Mine is located close to the border with Jordan and within the 10km security strip, and approximately 26km Southwest of the Iraq border. Approximately 13km to the south of the proposed mine and outside the security strip, is the Industrial Complex, which is within the boundaries of the planned Waad Al Shamaal Development city.

The Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex (the ‘Project‘) will include the following:

• Mine;

• Beneficiation plant;

• Sulphuric Acid Plant (SAP);

• Phosphoric Acid Plant (PAP);

• Purified Phosphoric Acid Plant;

• Sodium TriPolyPhosphate Plant;

• Monocalcium Phosphate/Dicalcium Phosphate plant;





• Utilities (power, water supply1, wastewater treatment, drainage etc.);

• Raw materials and product storage and handling facilities;

• Waste storage and management facilities;

• Fuel storage;

• Rail infrastructure;

• Roadways; and

• Administrative buildings.

The Project also includes the first phase of development of a residential area for Ma’aden’s permanent employees (approximately 1,000 employees) and dependents in the community zone of the Waad Al-Shamaal City which is required to housed employees participating in the start-up, testing and commissioning of the phosphate plants. Associated “essential infrastructure” to support the residential area, such as a basic road network throughout the site, water supply and sewage collection service to the residential area, and storm drainage improvements are also included.

Figure 1-2 Umm Wu’al Mine and Waad Al Shamaal Phosphate In dustrial Complex

1.4 THE ESIA

The purpose of this ESIA is to identify environmental and social impacts at an early stage of the Project, assess these impacts and where necessary propose mitigations to be implemented. The ESIA is to provide the relevant parties; regulators, lenders and other stakeholders with sufficient information on the proposed Project, to allow them to make informed decisions on the Project. The principal audiences for the Project are identified as:





• The Presidency of Meteorology and Environment (PME);

• The Ministry of Water and Electricity (MoWE);

• The Deputy Ministry for Mineral Resources (DMMR);

• Financial Institutions adopting the Equator Principles (EPFIs); and

• Stakeholders impacted by the project

Screening and scoping of the ESIA was undertaken for the Project on the basis of International and National requirements and the potential risks and impacts of the Project. The screening and scoping process undertaken for the Project is detailed within the ESIA Terms of Reference document [MD-512-0000-HS-EN-SOW-0001].

1.5 ESIA SCREENING

The Presidency of Meteorology and Environment is the authority responsible for the environmental performance of developments within the KSA (with the exception of designated Industrial Cities) and is therefore the regulatory body for the Project. General Environmental Law and Rules for Implementation (2001) and draft supplementary Environmental Standards 2012 provide the regulatory basis for the control of environmental aspects of the Project. Article 5 of the General Environmental Law notes ‘the agency in charge of implementation of the project shall be responsible for conducting the environmental assessment studies in accordance with the environmental basics and standards determined by the competent agency in the rules for implementation’. The General Environmental Law provides details of the content of the environmental assessment required for different types of development. The proposed development has been classified as a “Third Category” development by the PME.

Equator Principles Financial Institutions require borrowers to comply with the Equator Principles, to ensure that that the Project has been developed in a manner that is socially responsible and reflects sound environmental management practices. The first Principle involves the categorisation of the Project based on the magnitude of its potential risks and impacts. The proposed development is considered Category A: Projects with potential significant adverse environmental or social risks and/or that are impacts that are diverse, irreversible or unprecedented.

1.6 SCOPE OF THE ESIA

The scope of the ESIA is the Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex including associated water wellfield, road and rail connections, materials storage and loading/unloading areas, and the residential area and associated essential infrastructure required for the Ma’aden Phosphate Project’s employees. Saudi Railway Company (SAR) is responsible for generating a separate ESIA for the railway line connecting the two sites.

The ESIA Terms of Reference identified the following primary issues which required detail study as part of the assessment:

• Ambient Air Quality and Emissions to Air;

• Water Quality Management;

• Solid Waste Management;

• Terrestrial Environment (including hydrogeology);

• Noise and Vibration;

• Biological Resources; and

• Socio-Economic Aspects





1.7 PREPARATION OF THE ESIA

The baseline environmental and social conditions at the Project site have been determined by reference to existing literature and the collection of baseline data; these activities were sub-contracted to Woods Hole Group Middle East. Specialist studies have been undertaken by Jacobs or its sub-consultants SRK and Woods Hole Group Middle East on all of the above aspects, with the exception of waste management, and the addition of a traffic survey.

This ESIA examines the possible impacts from the proposed scheme using the methodology described in Section 5.0 Impact Assessment Methodology, possible mitigation measures and the residual impact(s).

1.8 ENVIRONMENTAL PERMITTING

The ESIA forms the means by which approval for the Project is sought from the national environmental regulator, the PME. Other permits, licences and approvals required to allow the project to proceed are detailed in Table 1-1 below.

Table 1-1: Permitting Requirements

Umm Wu’al Site Gov’t Department Obtained Comment

Environmental permit to construct and operate each of the project facilities

Presidency of Meteorology and Environment (PME)

No To be secured via this ESIA

Electric Power and Co-Generation Licence

Electricity & Co-Generation Regulatory Authority (ECRA)

No Ma’aden to pursue

Exploration Licence Ministry of Petroleum and Minerals (MoPM)

Yes N/a

Mining Licence MoPM Yes N/a

Easement Permit MoPM No Ma’aden to pursue

Water well drilling and abstraction licence issued in the name of the Project Company

Ministry of Water and Electricity (MoWE)

No Ma’aden progressing

Temporary hazardous/non-hazardous waste disposal permit

Turaif Municipality No Initial discussions underway

Industrial Licence Ministry of Industry and Commerce (MoIC)

No Ma’aden to pursue

The easement permit, which provides access to and rights to use the land required for the Project, and the water well drilling and abstraction licence, which provides rights to obtain the water from the aquifer, are the key permits to be secured to allow the project to proceed. Securing these permits is the responsibility of Ma’aden, and is underway.

While no specific permit is required for the mining operation and associated infrastructure within the border security zone, all structures are required to be temporary in nature.

1.9 REPORT STRUCTURE

The structure of the ESIA is as follows:





ES Executive Summary. This provides an overview of the Umm Wu’al Phosphate Project phases relevant to the Umm Wu’al site, potential environmental and social impacts and proposed mitigation and monitoring strategies.

Section 1 Introduction. This section provides a basic description of the Project, including the key components of the project and an overview of the processes to be undertaken at the facility.

Section 2 Policy, Legal and Administrative Framewor k. This section summarises the key elements of national, local, and international legislation that apply to the proposed Umm Wu’al Phosphate Project. A summary of the relevant aspects of the legislation and regulations is provided and how these apply to the project.

Section 3 Consideration of Alternatives. This section provides a description of the alternatives considered as part of the Project development, and includes description of the application of Best Available Techniques (BAT) within the project.

Section 4 Detailed Description and Layout of the Pr oposed Development. This section provides a description of the proposed works at the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex Project site including details of the process and infrastructure design, plot plans and the different phases of the project (construction, commissioning, operation and decommissioning / closure) with their proposed schedules.

Section 5 Impact Assessment Methodology. This section details the criteria applied to the assessment of potential impacts arising from the proposed Project elements described in Section 4. It provides definitions of impact magnitude and significance as they apply to the potential effects on environmental aspects.

Section 6 Air Quality & Meteorology. This section presents the results and conclusions of the assessment of ambient air quality and local climate in the vicinity of the facility in order to establish baseline conditions, and the predicted impacts resulting from air emissions (including greenhouse gases, where appropriate) during the various stages of development of the plant.

Section 7 Terrestrial Environment. This section presents the findings of the onshore physical environment baseline survey, its evaluation and the likely impacts on the physical environment. The investigation addresses regional and local geological and hydrogeological conditions, characterises the soil and groundwater quality and presents the results of modelled water abstraction and spill scenarios to determine impacts on receptors.

Section 8 Biological Resources. This section details the field investigation and literature review, the baseline assessment and presents the evaluation of the potential environmental impacts to terrestrial ecology during the lifetime of the Umm Wu’al Phosphate Project.

Section 9 Noise & Vibration. This section presents the identification of existing noise sources and sensitive receptors that could be affected by the noise generated by the project, conclusions of the noise baseline survey and assessment of the environmental impacts on receptors resulting from noise generated during the lifetime of Umm Wu’al Phosphate Project (in light of applicable criteria, existing noise levels in the area and modelling based predictions).

Section 10 Waste Management. This section presents the findings of the baseline investigation detailing the waste management facilities that are available for the Project, including waste rock, process, hazardous and municipal wastes. The potential environmental impacts resulting from waste management during the lifetime of the Project are evaluated. Visual/ aesthetic impacts on the landscape, are also addressed.

Section 11 Surface Water Management. This section provides an overview of the predicted impacts on the water environment and/or Wastewater treatment facilities due to various wastewater discharges resulting from the construction, commissioning and operation of the Project.





Section 12 Socio-Economic Aspects . This section includes a general description of the socio-economic characteristics on a national, regional and local level including demography, economic activity, employment, infrastructure, land use and education. Each characteristic is assessed subjectively based on a review of existing published information, and the results of community surveys. This section includes also a description of the archaeological and cultural characteristics on a national and regional level. Potential impacts on the socio-economic and cultural aspects are evaluated for each phase of the Project

Section 13 Traffic and Transport Infrastructure. This section includes a description of the existing transport infrastructure, and traffic, and an assessment of the potential impacts of the Umm Wu’al Phosphate Project on the usage and demands on transport systems.

Section 14 Utilities Infrastructure and Usage. This section provides a description of the existing utilities, and evaluation of the utility infrastructure and usage impacts associated with the Umm Wu’al Phosphate Project.

Section 15 Health and Safety Aspects. This section presents a brief description of the potential health and safety issues associated with the Umm Wu’al Phosphate Project.

Section 16 Sustainable Development. This section includes an analysis of how the sustainable development elements are integrated into life cycle phases of the Project.

Section 19 Cumulative Impacts Assessment. This section includes an assessment of the cumulative effects that are likely to result from the Project on all affected environmental and socioeconomic conditions in the Study Area including other existing, approved and/or planned projects in the region that could reasonably be expected to have a combined effect.

Section 18 Summary of Impacts and Mitigation . This section summarises in table form the potential impacts identified and the corresponding mitigation measures/recommendations that have been identified in light of their applicability and cost effectiveness, including any interactive impacts between issues.

Section 19 Abbreviations & Acronyms. This section comprises a list of abbreviations and acronyms contained within the ESIA Report.

Section 20 Reference List. This section comprises a list of references contained within the ESIA Report.

APPENDICES

Appendix A Environmental Management & Monitoring Pl an. This appendix translates the findings and recommendations of the ESIA process into a succinct, clearly defined set of procedures and plans for implementation on the ground for all project stages to allow social and environmental impacts to be managed. The EMMP identifies those parties responsible for implementing the mitigation measures identified and integrates with existing documents including corporate and site specific management policies. The EMMP includes an outline of environmental action plans, staffing and training recommendations, and includes an outline Closure Plan for the Umm Wu’al Mine.

Appendix B Environmental Emergency Response Plan Ou tline This document outlines the suggested procedures regarding incidents that can potentially impact worker safety, public health and/or cause environmental damage during the operation phase of the Umm Wu’al Phosphate Project.

Appendix C Stakeholder Engagement Plan . This document outlines the approach to be taken in supporting the communications and engagement objectives, processes and deliverables required to support the delivery of the Umm Wu’al Phosphate Project. Methods for effective two-way stakeholder consultation are outlined for development and implementation by Ma’aden during the life of the project, ensuring that mechanisms for feedback and response are incorporated into the communication cycle list.





Appendix D Ambient Air Quality Assessment. This Appendix provides the baseline ambient air monitoring data, and results of the air dispersion modelling of the point and fugitive emission sources at the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex.

Appendix E Ecology Survey. This appendix presents the detailed results of the terrestrial ecology baseline survey.

Appendix F Noise Monitoring Survey and Assessment. This appendix presents the baseline noise monitoring data, presents the results of noise modelling undertaken for the Project, and includes the calibration certificates for each of the noise meters.

Appendix G Water Quality Results. This appendix presents the baseline water quality testing results.

Appendix H Socio-Economic Survey. This appendix presents the results of the socio-economic surveys / consultation undertaken with Ma’aden, governmental bodies, and local stakeholders as part of this ESIA.

Appendix I Traffic Survey. This appendix presents the results of the traffic surveys undertaken as part of this report.





2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1 INTRODUCTION

The highest institutional authority for the environment within the Kingdom of Saudi Arabia (KSA) is the Presidency of Meteorology and Environment (PME). The PME has overall authority for ensuring that development projects in the Kingdom of Saudi Arabia (KSA) adhere to environmental standards and is the responsible authority for approval of the EIA procedures. All mining projects are also subject to approval by the Ministry of Petroleum and Mineral Resources (MoPM) with the environmental aspects of these projects being reviewed by the Presidency of Meteorology and Environment (PME).

The proposed Umm Wu’al mine and Waad Al Shamaal Phosphate Industrial Complex (the Project) falls within the jurisdiction of the PME; as such the key environmental regulations and standards applicable to the Project are the PME General Environmental Regulations and Rules for Implementation (2001) and draft supplementary Environmental Standards (2012).

The KSA is subject to international protocols and agreements adopted by the Kingdom and to other national environmental guidelines and standards, such as those developed by the Deputy Ministry for Mineral Resources (DMMR) and Ministry of Municipalities and Rural Affairs (MoMRA). Since the Project shall seek international financing, the Project shall also reference the international guidance and standards of the World Bank Group and specifically the International Finance Corporation (IFC – part of the World Bank Group) as appropriate. Also in accordance with the requirements of the IFC and PME the Project shall utilise Best Available Techniques (BAT) for environmental control (refer to Section 3).

The guidelines and standards relevant to the Project are used as a basis for evaluating the project’s impacts and are summarised in the subsequent sections of this document. As the guidelines and standards are presented as a summary, the full and most recent legislation will be consulted prior to implementation of any mitigation or monitoring actions.

All relevant standards, guidelines and performance thresholds which are introduced in the following sections are referenced as relevant within the individual technical assessment Sections of this ESIA: Sections 6 – 16.

2.2 LOCAL AND NATIONAL LEGISLATION AND STANDARDS

2.2.1 PRESIDENCY OF METEREOLOGY AND ENVIRONMENT

The PME is the competent authority for environmental regulation in Saudi Arabia and is responsible for the general regulatory framework for the development and enforcement of environmental rules and regulations.

The PME General Environmental Regulations and Rules for Implementation were enacted in October 2001. Appendix 1 of the General Environmental Law and Rules for Implementation, 2001 outline the Environmental Protection Standards relevant to facilities in the Kingdom of Saudi Arabia.

The PME (2001) General Environmental Protection Standards for New Facilities (Article 7) are outlined as:

• All new major facilities as well as major modifications to existing facilities shall be designed, operated and maintained so as to avoid exceedances of the ambient environmental standards as promulgated for the Kingdom at the time of approval of the design.

• Each new major facility or major modification of an existing facility shall incorporate the best available technology for control of pollutant discharges and for the disposal of wastes resulting from the operation of the facility.

• All new facilities and modifications of an existing facility shall be designed and operated so as to avoid the discharge of any toxic substance, whether specifically regulated or not, in sufficient quantities to be harmful to public health.





In 2012 the PME developed a number of draft supplementary Environmental Standards revising in part the General Standards for the Environment issued by the PME in Appendix 1 to the General Environmental Law and Rules for Implementation. These Standards are:

• Standard 1: Material Recovery and Recycling of Waste

• Standard 2: Mobile Source Emissions

• Standard 3: Environmental Noise

• Standard 4: Control of Emissions to Air from Stationary Sources

• Standard 5: Prevention of Major Accidents

• Standard 6: Storage and Material Reclamation Facilities – Design and Operation

• Standard 7: Thermal Treatment and Incineration – Design and Operation

• Standard 8: Waste Acceptance Criteria

• Standard 9: Waste Classification

• Standard 10: Drinking Water Quality

• Standard 11: Biological Treatment Design and Operation

• Standard 12: Waste Regulatory Control and Compliance

• Standard 13: Waste Handling and Storage

• Standard 14: Waste Training and Assessment of Technical Competence of Operators

• Standard 15: Waste Transportation

• Standard 16: Landfill Design and Operation

• Standard 17: Industrial and Municipal Wastewater Discharges

• Standard 18: Best Practicable Environmental Option for Waste Disposal

• Standard 19 : Ambient Air Quality

• Standard 20: Ambient Water Quality

In the event that the PME regulations do not specify a standard relevant to the project site, then the project shall use for reference other recognised regulations as a basis for technical justification in the following order:

• Royal Commission Environmental Regulations (RCER) 2010;

• The U.S. Environmental Protection Agency (US EPA);

• U.S. State environmental rules and guidelines;

• European Union (EU) members environmental rules and guidelines; and

• Other internationally recognised and accepted regulatory bodies.

2.2.2 ESIA REQUIREMENT

The General Environmental Regulations and Rules for Implementation (2001) Appendix 2.1 establishes the procedure for the preparation and auditing of environmental impact assessment, and identifies the key principles for Environmental Assessment of the Project, which are:

• The nature and magnitude of the intended activity and existence of similar projects at the site or similar site.

• Extent of depletion of natural resources by the installation, particularly agricultural lands and mineral resources.





• Location of the installation and the nature of the surrounding environment and nearby residential habitats.

• The type of power used.

Moreover, Appendix 2.1 includes Guidelines for Classification of Industrial and Development Projects and indicates that the method of assessment is dependent on the classification of the project based on the level of expected impacts of these projects into three categories:

• First Category Projects: Projects with Limited Environmental Impacts

• Second Category Projects: Projects with Significant Environmental Impacts

• Third Category Projects: Projects with Serious Environmental Impacts

The Guidelines provide a list of example projects for each category. Major chemical industries such as fertilizer plants, are designated Category 3; projects anticipated to have serious negative effects on the environment and as a result require a comprehensive ESIA. Comprehensive ESIA are required to be undertaken by a qualified consulting office or agency approved by the PME, in accordance with Appendix 2.4 of the General Environmental Law and Rules for Implementation; Guidelines for Compiling an EIA study.

The ESIA scoping undertaken for this Project identifies the mine, processing plants, well fields and associated infrastructure as a Third Category project in accordance with the above.

2.2.3 DEPUTY MINISTRY FOR MINERAL RESOURCES (DMMR)

The DMMR is the sole agency concerned with the application and administration of the Saudi Mining Executive Regulation and Mining Investment Code (MoPM, 2009). Article 27 of the Mining Investment Code addresses the protection of the environment and mandates that the holder of a Mining License, Raw Materials Quarry License or Small Mine License shall carry out the following:

• An environmental evaluation study to be approved by the General Presidency for Meteorological and Environmental Protection within thirty (30) days from receipt date as prescribed by the Regulation, whereby the licensee undertakes to take all necessary measures and precautions at all times to preserve and protect water resources, the environment and wildlife from any hazardous waste or any other environmental damage.

• Rehabilitation of the license area and its maintenance to leave it in a safe and orderly condition as prescribed by the Regulation.

• Protection of and reporting to, the Ministry of any archaeological sites, buildings, engravings, etching, drawings and other such relics that may be found within the license area. The Ministry, in turn, shall inform the concerned authority.

The Ministry of Petroleum and Mineral Resources provides Environmental Instructions for Mining Management (MoPM, 2009) which reflect the requirements of the PME, World Bank Group and good practice in undertaking ESIA for projects. These advise:

“Mining Activities require appropriate environmental management in all fields particular to mineral exploration, processing, extraction and production. Therefore, economic and environmental issues must be considered when taking a decision related to any mining project, taking into account that mineral deposits are non-renewable. The community's social and economic needs must also be considered taking into account that such minerals, particularly non-metallic minerals, constitute huge reserves for the use of future generations through integrated and advanced programs and plans.”

Article 2 of the mine licence secured by Ma’aden for this Project includes the following specific requirements:

“The Company must:





• Submit to the Ministry a study evaluating the environmental effects compiled by specialists working in that field, in three original copies, and the Company must act in accordance with it in adopting all the precautionary measures required at all times in order to protect the water sources and the environment and the native life and protect it from any dangerous residues or from any other environmental damage.

• Abide by and comply with the environmental regulations in force in the Kingdom, and take all health and safety precautions required when constructing and maintaining its installations, and it must protect the health and safety of its employees and all other properly authorised personnel when they enter the area covered by the Licence.

• It must rehabilitate the area covered by the Licence, and protect it and leave it in a good and sound condition.”

2.2.4 MINISTRY OF WATER AND ELECTRICITY

The Ministry of Water and Electricity (MoWE) is the designated ministry in KSA responsible for policy and regulation of water and sanitation services. There is no separate regulatory agency for the sector. MoWE has two main water programmes – water resources development, which includes all activities related to geological and hydrological studies, wastewater reuse investigations, well drilling and dam construction, and the preparation of the national water plan; and drinking water supply (Food and Agriculture Organization of the United Nations 2009).

MoWE licences the abstraction of groundwater, and regulates the establishment of any WWTP with regard to public health and environmental aspects. The Wastewater Treatment & Re-use Policy provides regulation and standards for the disposal and reuse of wastewater with a view to maximising water efficiency while providing adequate protection of public health and the environment from pollution and infectious diseases (MoWE, 2010).

2.2.5 MINISTRY OF LABOUR

Royal Decree No. M/51 Labor Law (2005), is the principal legislation defining the Occupational Health and Safety rights of all workers within Saudi Arabia. The law seeks to provide the guiding principles for workers’ rights in terms of pay, welfare, working hours and conditions and access to healthcare. The most relevant chapters and articles relating to Health and Safety are detailed below.

Part VI – Work conditions and circumstances provides the regulations for pay, working hours, leave and rest periods.

• Chapter 2 (Articles 98 – 100) set out the guidelines for working hours, which seeks to ensure that workers do not work more than 8 hours a day (40 hours per week), either through regular working patterns, or through averaging across a three week period for shift workers. Working hours are reduced for the period of Ramadan.

• Chapter 3 (Articles 101 - 108 ) define the daily and weekly resting periods for all workers, including the provision of time for prayer, minimum rest times, and meals.

• Chapter 4 (Articles 109 - 118) provide the relevant guidance for the provision of annual and sick leave, including the regulations for remuneration.

• Part VIII - Protection against occupational hazards, major industrial accidents and work injuries, and health and social services, is the principal section related to the protection of the health of workers.

• Chapter 1 (Articles 121 – 126) define the general level requirements on employers to protect workers from occupational hazards.

• Chapter 2 (Articles 127 – 131) define the employers responsibilities for the prevention of major accidents.





• Chapter 3 (Articles 132 – 141) define the rights of employees in the event of work injury or workplace induce disease, including remuneration.

• Chapter 4 (Articles 142 - 148) define the employers duties to provide health and social facilities for workers, including the provision of first aid facilities, access to medical supplies, and welfare facilities including prayer rooms. In particular article (147) states:

“An employer operating in remote locations, mines, quarries and oil exploration centres shall provide his workers with accommodation, camps and meals.”

Article (148) requires employers to provide transportation for employees from their residence to work location where access to transport is limited.

Part XII - Working in mines and quarries, defines the additional requirements on employers for any facility related to the specific industry, including working hours, and provision of medical facilities. In particular, Article (192) states:

“An employer shall establish a rescue point in the vicinity of the workplace, equipped with necessary rescue and first aid equipment. Said point shall be equipped with suitable means of communication for immediate access and the employer shall appoint a trained technician to supervise the rescue and first aid operations.”

2.3 INTERNATIONAL GUIDELINES AND POLICIES

2.3.1 THE WORLD BANK GROUP

The World Bank Group is a family of five international organisations that makes leveraged loans:

• International Bank for Reconstruction and Development (IBRD);

• International Development Associated (IDA);

• International Finance Corporation (IFC);

• Multilateral Investment Guarantee Agency (MIGA); and

• International Centre for Settlement of Investment Disputes (ICSID).

Of most relevance to the Project is the IFC.

The IFC is an international financial institution which offers investment, advisory, and asset management services to encourage private sector development in projects. It was established in 1956 as the private sector arm of the World Bank Group to advance economic development by investing in strictly for-profit and commercial projects which reduce poverty and promote development.

To provide a means of managing the social and environmental risks and impacts on projects, the IFC have developed their Performance Standards on Social and Environmental Sustainability (revised in 2012). The Performance Standards are designed to help avoid, mitigate, and manage risks and impacts as a means of doing business in a sustainable way, including stakeholder engagement and disclosure obligations of the client in relation to project-level activities. The IFC Performance Standards (2012) are:

• Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts

• Performance Standard 2: Labour and Working Conditions

• Performance Standard 3: Resource Efficiency and Pollution Prevention

• Performance Standard 4: Community Health, Safety, and Security





• Performance Standard 5: Land Acquisition and Involuntary Resettlement

• Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

• Performance Standard 7: Indigenous Peoples

• Performance Standard 8: Cultural Heritage

The IFC developed the World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) to provide technical reference documents with general and industry-specific examples of Good International Industry Practice as defined in IFC’s Performance Standard 3: Resource Efficiency and Pollution Prevention. The IFC uses these Guidelines as a technical source of information during project appraisal activities. The following guidelines of IFC are relevant to the Project:

• General Environmental, Health, and Safety Guidelines, April 30, 2007;

• Environmental, Health and Safety Guidelines for Mining, December 10, 2007;

• Environmental, Health and Safety Guidelines for Large volume inorganic compounds manufacturing and coal tar distillation, December 10, 2007;

• Environmental, Health and Safety Guidelines for Phosphate fertilizer plants manufacturing, April 30, 2007; and

• Environmental, Health and Safety Guidelines for Water and Sanitation, December 10, 2007

On applying these Guidelines, the IFC expect that when host country regulations differ from the levels and measures presented in the EHS Guidelines, projects will achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternate performance level protects human health and the environment.

2.3.2 EQUATOR PRINCIPLES

The Equator Principles, established in June 2003, and subsequently reviewed in 2006 and 2013 is a risk framework for identifying, assessing and managing environmental and social risks in project finance transactions. This framework is based on the IFC Performance Standards and the World Bank Group EHS Guidelines. Equator Principles Financial Institutions (EPFIs) have adopted the Equator Principles in order to ensure that the Projects financed are developed in a manner that is socially responsible and reflects sound environmental management practises. The principles comprise a set of ten broad principles that are underpinned by the environmental and social policies, standards and guidance of the IFC. The Equator Principles are as follows:

• Principle 1: Review and Categorisation;

• Principle 2: Environmental and Social Assessment;

• Principle 3: Applicable Environmental and Social Standards;

• Principle 4: Environmental and Social Management System and Action Plan;

• Principle 5: Stakeholder Engagement;

• Principle 6: Grievance Mechanism;

• Principle 7: Independent Review;

• Principle 8: Covenants;





• Principle 9: Independent Monitoring and Reporting; and

• Principle 10: Reporting and Transparency.

2.3.3 ESIA REQUIREMENT

When a Project is proposed for financing, the EPFI is required to categorise the Project based on the magnitude of its potential risks and impacts. This screening is undertaken using the following categorisation scheme of the IFC:

• Category A: Projects with potential significant adverse environmental social risks and/or impacts that are diverse, irreversible or unprecedented;

• Category B: Projects with potential limited adverse environmental social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures; and

• Category C: Project with minimal or no adverse environmental and social risks and/or impacts

The Umm Wu’al Mine and Processing Complex element of the Umm Wu’al Phosphate Project is considered to be a Category A project.

2.3.4 PROJECT COMMITMENTS

This ESIA report prepared during the Front End Engineering and Design (FEED) stage of the Project has been conducted in accordance with the requirements of the PME as well as the IFC Performance Standards and the Equator Principles (EPIII) as far as practicable (See Table 2-1 and Table 2-2 respectively).

Those Performance Standards highlighted in italics have been identified as having limited or no relevance to the Project.





Table 2-1 Ma’aden’s commitment to the IFC Performance Sta ndards for the Umm Wu’al Mine and Processing Comple x

IFC Performance Standards Comment

Performance Standard 1

Assessment and Management of Social and Environment al Risks and Impacts.

Requirements: Environmental and Social Management System (ESMS): a methodological approach to managing environmental and social risk and impacts in a structure way on an ongoing basis. The ESMS will incorporate: (i) policy; (ii) identification of risks and impacts; (iii) management programmes; (iv) organisational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement; and (vii) monitoring and review.

Objectives:

• To identify and evaluate environmental and social risks and impacts of the project.

• To adopt a mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimize, and, where residual impacts remain, compensate/offset for risks and impacts to workers, Affected Communities, and the environment.

• To promote improved environmental and social performance of clients through the effective use of management systems.

• To ensure that grievances from Affected Communities and external communications from other stakeholders are responded to and managed appropriately.

• To promote and provide means for adequate engagement with Affected Communities throughout the project cycle on issues that could potentially affect them and to ensure that relevant environmental and social information is disclosed and disseminated.

The following documents demonstrate adherence to this Performance Standard during FEED Stage:

• Environmental and Social Impact Assessment (ESIA); • Environmental Monitoring Management Plan (EMMP); • Emergency Response Plan (EERP); and • Stakeholder Engagement Plant (SEP) and ESIA Socio-

economic Chapter.

Ma’aden will establish an ESMS relevant to the Project and support any ongoing management and reporting as required.

Ma’aden will use the ESMS to manage the implementation of the actions necessary to meet the applicable requirements of all Performance Standard.


Labour and Working Conditions

Requirements are outlined for: Working Conditions and Management of Worker Relationship; Protecting the Work Force; Occupational Health and Safety; Workers Engaged by Third Parties; Supply Chain.

Objectives:

• To promote the fair treatment, non-discrimination, and equal opportunity of workers.

• To establish, maintain, and improve the worker-management

Sections 12 and 15 of the ESIA identify and assesses potential impacts that the proposed project could pose on workers’ health and conditions as well as proposing measures to manage and monitor them. These have been integrated in the EMMP and EERP as appropriate (Appendices A and B).





relationship. • To promote compliance with national employment and labour laws. • To protect workers, including vulnerable categories of workers such as

children, migrant workers, workers engaged by third parties, and workers in the client’s supply chain.

• To promote safe and healthy working conditions, and the health of workers.

• To avoid the use of forced labour.


Resource Efficiency and Pollution Prevention

Requirements are outlined for: Resource Efficiency (Greenhouse Gases and Water Consumption); and Pollution Prevention (General, Hazardous Materials Management and Pesticide Use and Management)

Objectives: • To avoid or minimize adverse impacts on human health and the

environment by avoiding or minimizing pollution from project activities. • To promote more sustainable use of resources, including energy and

water. • To reduce project-related GHG emissions.

The ESIA documents how potential impacts on human health and the environment were identified and assessed.

Section 3 of the ESIA specifically identifies and describes the assessment of the key strategic and technological alternatives that have been considered for the Project, and the integration of best available techniques (BAT) principles within the facility design in order to minimise significant impacts.

The Project will emit more than 25,000 tonnes of CO2 equivalent annually (primarily associated with the MCP/DCP and STPP plants); therefore GHG emissions have been estimated and are reported within Section 6. Since the anticipated GHG emissions are below 100,000MT Ma’aden are not required to quantify GHG emissions annually.


Community Health, Safety and Security

Objectives: • To anticipate and avoid adverse impacts on the health and safety of the

Affected Community during the project life from both routine and non-routine circumstances.

• To ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.

Sections 12 and 15 identify and assesses potential impacts that the proposed Project could pose on workers and community's health as well as proposing measures to manage and monitor them. These have been integrated to the EMMP and EERP as appropriate (Appendices A and B).


Land Acquisition and Involuntary Resettlement

Ma’aden has been allocated the Government land for the Project. Section 12 identifies and addresses potential impacts resulting from changes to access to the land upon which the Project is to be built.

Due to the nature of the Project site location and land ownership,





no assessment of resettlement is required as part of the ESIA.


Biodiversity Conservation and Sustainable Managemen t of Living Natural Resources

Objectives:

• To protect and conserve biodiversity. • To maintain the benefits from ecosystem services. • To promote the sustainable management of living natural resources

through the adoption of practices that integrate conservation needs and development priorities.

The ESIA documents how potential impacts biodiversity and living natural resources were identified and assessed.

Section 8 of the ESIA specifically identifies the existing ecological status of the site and describes the assessment of potential impacts to the biodiversity, habitats, and ecosystem services as a result of the Project as well as proposing mitigation measures to manage and monitor them. These have been integrated into the EMMP as appropriate (Appendix A).


Indigenous Peoples Section 13 of the ESIA describes the assessment of potential impacts that the proposed Project could pose to indigenous peoples that may inhabit the region. The baseline assessment identifies no indigenous peoples occupying the land, but notes expatriate herders are found tending livestock.


Cultural Heritage

Objectives: • To protect cultural heritage from the adverse impacts of project

activities and support its preservation. • To promote the equitable sharing of benefits from the use of cultural

heritage.

Section 13 of the ESIA describes the assessment of potential impacts that the proposed Project could pose to cultural or archaeological heritage as a result of the Project.





Table 2-2- Ma’aden’s commitment to the Equator Principles (EPIII) for the Umm Wu’al Umm Wu’al Mine and Proce ssing Complex

Equator Principles Comment

Principle 1 Review and Categorisation

Categorisation of the project based on the magnitude of its potential risks and impacts in accordance with the environmental and social screening criteria of the International Finance Corporation (IFC).

Classification of the project under Appendix 2.1 of the Rules for Implementation is to be confirmed by the PME, although following the ESIA Scoping the Project is considered to be a Third Category.

It is anticipated that the Equator Principle Financial Institutions (EPFIs) will categorise the Umm Wu’al Mine and Processing Complex as a Category A project.

Principle 2 Environmental and Social Assessment

Assessment process to address to the EPFI’s satisfaction, the relevant environmental and social risks and impacts of the proposed Project. The Assessment Documentation should also propose measures to minimise, mitigate and offset adverse impacts in a manner relevant and appropriate to the nature and scale of the proposed Project.

For Category A projects the Assessment Documentation includes an Environmental Impact Assessment (ESIA).

The ESIA Scoping Report identified the relevant environmental and social risks and impacts of the proposed Project.

Informed by the ESIA Scoping Report, the ESIA was completed to assess all aspects of the Umm Wu’al Mine and Processing Complex including the wellfield, mine, proposed chemical plants, road and rail connections, and materials storage and loading/unloading areas., utilities and infrastructure.

The Project is not expected to emit more than 100,000 tonnes of CO2 equivalent annually; therefore an alternative analysis to evaluate less greenhouse gases (GHG) intensive alternatives was not required.

Principle 3 Applicable Environmental and Social Sta ndards

Compliance with host country legislation / permits is required to be addressed in the first instance,

For Projects located in Non Designated Countries, the assessment is required to evaluate compliance with the respective IFC Performance Standards and World Bank Group EHS Guidelines.

For Projects located in Designated Countries, the relevant host country laws, regulations and permits apply.

Saudi Arabia is a Non Designated Country; therefore the assessment process outlined in this ESIA evaluates compliance with the IFC Performance Standards and EHS Guidelines. Where PME Regulations are more stringent however, these have been applied.

Early consideration of the applicable standards was communicated to FEED engineering and design teams via an Environmental Basis of Design.

Principle 4 Environmental and Social Management Sy stem and Action Plan

An ESMS to be developed and maintained by the Client for all Category A and B Projects. An Environmental and Social Management Plan is also required to address issues raised in the Assessment and incorporate actions required to

Ma’aden will establish and maintain an ESMS.

Appendix A of this ESIA report includes an Environmental Management & Monitoring Plan (EMMP) developed to address and manage the environmental aspects and impacts related to the construction, commissioning and operation of the Project. The EMMP is





comply with the applicable standards. considered appropriate as an ESMP.

It is anticipated that all applicable standards will have been met to the satisfaction of the EPFI. However, if it is deemed necessary by the EPFI to prepare an Action Plan (AP) to address any gaps identified, Ma’aden will work with the EPFI to resolve this.

Principle 5 Stakeholder and Engagement

For all Category A and Category B Projects, effective stakeholder engagement must be demonstrated as an on-going process in a structured and culturally appropriate manner with affected communities and where appropriate other stakeholders.

For projects with environmental or social risks and adverse impacts, disclosure should occur early in the Assessment process, in any event before the Project construction commences, and on an ongoing basis.

The Socio-Economic Chapter of the ESIA (Section 13) and the Stakeholder Engagement Plan (SEP) (Appendix C) both address stakeholder engagement appropriate to this Project.

The SEP outlines the approach to be taken in supporting the communications and engagement objectives, processes and deliverables required to support successful delivery of the Umm Wu’al Phosphate Project. It also identifies the range of people and organisations that may be regarded as stakeholders in the Project, and describes the strategy to be used for engaging with these stakeholders in a culturally appropriate manner. The SEP will continue to be developed by Ma’aden for the life of the Project.

Principle 6 Grievance Mechanism

For all Category A and, as appropriate, Category B Projects, the client will, as part of the ESMS, establish a grievance mechanism designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance.

The SEP (Appendix C) provides an Action Plan which initiates a grievance mechanism for use during the life of the Project. This will be developed further and maintained by Ma’aden during all phases of the Project.

Principle 7 Independent Review

For all Category A and, as appropriate, Category B Projects, an independent Environmental and Social Consultant not directly associated with the client will carry out an Independent Review of the Assessment Documentation including the ESMP, ESMS and the Stakeholder Engagement process documentation in order to assist the EPFI's due diligence, and assess Equator Principles compliance.

An Independent Technical (Mining) Advisor has been appointed to the Umm Wu’al Phosphate Project.

The EPFI to advise if further Independent Reviewers are appropriate for the Umm Wu’al Mine and Processing Complex (Category A) Project.

Principle 8 Covenants

The client will covenant in the financing documentation: to comply with all relevant host country environmental and social laws; regulations and permits to

The ESIA will provide the initial documentation to demonstrate compliance with the appropriate regulations as well as commitments





comply with the ESMP and AP (where applicable), to provide periodic reports to the EPFI demonstrating compliance, and to decommission facilities, where applicable and appropriate, in accordance with an agreed decommissioning plan.

related to the outline plans developed for environmental management and decommissioning/closure.

Ma’aden will establish and maintain an ESMS relevant to the Project and support any on-going management and reporting as required by the EPFI.

Principle 9 Independent Monitoring and Reporting

To assess Project compliance with the Equator Principles and ensure ongoing monitoring and reporting after Financial Close and over the life of the loan, the EPFIs will for all Category A and, as appropriate, Category B Projects, require the appointment of an Independent Environmental and Social Consultant, or require that the client retain qualified and experienced external experts to verify its monitoring information which would be shared with the EPFIs.

The EPFI to determine the appropriate requirements for independent monitoring and reporting for the Umm Wu’al Mine and Processing Complex (Category A) Project. .

Principle 10 Reporting and Transparency

For all Category A and, as appropriate, Category B Projects;

• The client will ensure that, at a minimum, as summary of the ESIA is accessible and available online

• The client will publicly report GHG emission levels during the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually.

EP III Annex A Notes:

Clients encouraged to report publicly on Projects emitting over 25,000 tonnes. In some instances, public disclosure of the full alternatives analysis or project-level emissions may not be appropriate.

Ma’aden will liaise with the EPFI to confirm requirements for disclosing the Assessment Documentation (e.g. Executive Summary of the ESIA) online for this Category A Project.

The Project is not expected to emit more than 100,000 tonnes of CO2 equivalent annually; therefore annually reporting of such emissions will not be required.





2.4 OTHER STANDARDS AND GUIDANCE

The following standards, principles and guidelines have also been used as reference in undertaking the environmental and social impact assessment for the Umm Wu’al Mine and Processing Complex.

2.4.1 MA’ADEN ENVIRONMENTAL AND SOCIAL MANAGEMENT

In 2007, Ma’aden established its corporate Environmental Management System functions and policies. Environmental aspects of activities, products and services are assessed for significance and moderated by a Ma’aden cross-functional team. Aspects assessed include air and water emissions, releases to land, use of raw materials and natural resources, use of energy and emission of heat, radiation and vibration, waste and by-products, and physical attributes. The impact of activities on wildlife and biodiversity are also assessed.

The Ma’aden Phosphate Company Safety, Health, Environment and Quality Policy (2012) demonstrates Ma’aden’s commitment to improve the environmental (as well as health, safety and quality) performance and standards associated with its activities.

The Ma’aden Project Manual implements the Safety, Health, Environment and Quality Policy, primarily through the Environment and Communities Assurance’ guide (MD-101-SMPM-PM-EN-GUI-0001) and Environmental Protection Requirements (MD-101-SMPM-PM-EN-PEI-0001), while Ma’aden’s Engineering Standard and Project Specifications also include Environmental Health & Safety Design Criteria (MD-101-SMEM-EC-GE-CRT-0001).

2.4.2 SAUDI GEOLOGICAL SURVEY

The Saudi Geological Survey (SGS) provides advisory services to the government of KSA on geological matters. It has been authorized to study geological aspects of environmental issues and to determine ways to protect and mitigate the harmful effects of mining activities. A manual has been published by The Saudi Geological Survey Mining Development Department and other sectors relevant to mining industry in the Kingdom has published a manual providing guidelines for the identification of the main factors to be considered when preparing an EIA study for mining projects in Saudi Arabia (Al Madani et al, 2008).

2.4.3 SAUDI WILDLIFE AUTHORITY

The Saudi Wildlife Authority (SWA) is empowered to conduct wildlife research and use this information to promote conservation and sustainable development, and in particular to protect and undertake restoration and protection of native fauna and flora.

The Saudi National e-government portal states that are several legal instruments, national strategies in KSA to protect the wildlife over and above international instruments to which the Kingdom is party, listing these as:

• The Preserved Areas System and Regulations for Wildlife;

• System and Regulations for Hunting Animals and Wild Bird;

• The National Strategy for Biological Diversity Conservation in KSA; and

• The Convention for Preserving Wildlife in the Six Gulf States.

2.4.4 ISLAMIC PRINCIPLES FOR THE CONSERVATION OF THE NATURAL ENVIRONMENT

The sustainable use of natural resources and the conservation of the environment are Islamic principles pertaining to the right and privilege of all people. Islamic principles hold that the protection, conservation and development of the environment and its natural resources are a mandatory duty to which every Muslim should be committed.

The Islamic trust of stewardship towards the natural environment has been summarized as follows:

• There should be no extravagance, excessive use or over-utilization,

• There should be no illegitimate or unlawful attempts at destroying natural resources,





• There should be no damage, abuse, pollution or distortion of the natural environment in any way, and

• There should be no construction and development of the earth, its resources, elements and phenomena without the improvement of natural resources, the protection and conservation of all existing forms of life, the cultivation of land, and the reclamation and cleaning of the soil, air and water.

As ownership of all environmental elements is a common and shared right, it is the responsibility of both individuals and the ruling authorities to uphold these duties, especially in terms of prevention or treatment of damage. The State is therefore seen as having the right in Islamic law to hold individuals, organizations, establishments and companies responsible for whatever measures are necessary to protect and conserve the environment and natural resources.

2.4.5 INTERNATIONAL CONVENTIONS

The Kingdom of Saudi Arabia is a contracting party to the World Heritage Convention and is also party to a number of international conventions of relevance to this Project, listed below:

Date International Convention

1960 International Convention for Safety of Life at Sea (SOLAS) Accession21985

1967 Agreement for the Establishment of a Commission for Controlling the Desert Locust in the Near East (as amended), Rome Acceptance 1972

1973 International Convention for the Prevention of Pollution from Ships (MARPOL) Accession 2005

1979 Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention) Ratified 1991

1982 United Nations Convention on the Law of the Sea (UNCLOS) Montego Bay

Consent to be bound 1996

1985 Vienna Convention for the protection of the Ozone Layer, Vienna Accession1993

1987 Montreal Protocol on substances that deplete the ozone layer and its Amendments Accession 1993

1989 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal Ratified 1990

1990 Cairo Declaration on Human Rights in Islam Signed 1990

1991

The Arab Declaration on Environment and Development. Adopted by the Arab Ministerial Conference on Environment and Development in Cairo, A/46/632, cited in U.N. Doc. E/CN.4/Sub.2/1992/7, 20.

Adopted 1992

1992 Agenda 21 and the Rio Declaration on Environment and Development Signed 1992

1992 Protocol to the International Convention on Civil Liability for Oil Pollution Damage Accession 2006

1992 UN Framework Convention on Climatic Change (UNFCCC) New York Accession 1994

1992 Convention on Biological Diversity, Rio de Janeiro Accession 2001 1994 United Nations Convention to Combat Desertification Accession 1994

1994 Agreement relating to the Implementation of Part XI of the UN Convention on the Law of the Sea 1982 (UNCLOS), New York

Consent to be bound 1996

2000 Cartagena Protocol on Biosafety to the Convention on Biological Diversity, Montreal

Accession 20073

2 "Accession" is the act whereby a state accepts the offer or the opportunity to become a party to a treaty already negotiated and signed by other states. It has the same legal effect as ratification. Accession usually occurs after the treaty has entered into force. 3 Adopted in 2000 as a supplementary agreement to the Convention on Biological Diversity and entered into force on 11 September 2003





2000

United Nations Convention against Transnational Organised Crime, supplemented by three Protocols; Protocol against Trafficking in Persons, Especially Woman and Children; Protocol against Smuggling of Migrants and Protocol against Illicit Manufacturing of and Trafficking in Firearms, New York

Ratified 2005

2001 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Accession 1996

2003 United Nations Convention against Corruption, New York Ratified 2013

2004 Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade

Accession 2000

2005 Kyoto Protocol to the UN Framework Convention on Climate Change Accession 2005

2006 Convention on the Right of Persons with Disabilities, New York Ratified 2008

2.5 RELEVANT ENVIRONMENTAL STANDARDS AND GUIDELINES

In addition to the IFC requirements, the Project must specifically adhere to the environmental guidelines and standards set by the PME and Ma’aden as appropriate.

As referred to in Section 2.2.1, in the event that the PME do not specify a standard relevant to the project site, then the project shall use for reference other recognised regulations as a basis for technical justification:

• Royal Commission Environmental Regulations (RCER) 2010;

• The U.S. Environmental Protection Agency (US EPA);

• U.S. State environmental rules and guidelines;

• European Union (EU) members environmental rules and guidelines; and

• Other internationally recognised and accepted regulatory bodies.

The IFC requires that when host country regulations differ from the levels and measures presented in the IFC Environmental, Health, and Safety Guidelines, projects are expected to achieve whichever is more stringent.

The hierarchy of standards to be used for the Umm Wu’al Phosphate Project is presented in Figure 2-1.





Figure 2-1: Hierarchy of standards for Umm’Wual Phosphate Project

In addition to the PME, the Project should also demonstrate compliance with the requirements as set out in the Relevant Licensors’ Specification and Ma’aden design standards.

2.5.1 INTERNATIONAL ENVIRONMENTAL STANDARDS

As indicated in Figure 2-1 above, where numerical standards have not been developed by the IFC or the PME, the regulatory assessment criteria for the ESIA will be derived from other international standards or guidelines, including US and EU regulations. Reference will also be made to best international practice as documented in the following guidance:

• General Environmental, Health, and Safety (EHS) Guidelines, April 30, 2007;

• Environmental, Health and Safety Guidelines for Mining, December 10, 2007;

• Environmental, Health and Safety Guidelines for Large volume inorganic compounds manufacturing and coal tar distillation, December 10, 2007;

• Environmental, Health and Safety Guidelines for Phosphate fertilizer plants manufacturing, April 30, 2007;

• Environmental, Health and Safety Guidelines for Water and Sanitation, December 10, 2007;

• World Bank: Environmental Assessment source book updates “Health Aspects of Environmental Assessment July 1997”. This Update provides guidance to task managers and borrowers on systematically integrating public health and safety concerns into environmental assessment;

• World Health Organisation (WHO) guidelines for ambient air quality and irrigation water quality; and

Lend er Institution /

IFC

Ma’aden

Saudi National / PME

RCER-2010

US EPA US State Environmental Rules & Guidelines

European Union Rules & Guidelines WHO

RCDC 2006

Saudi National / PME

Ras Al Khair Umm Wu’al

RCER-2010





• Legislation of the EU and the U.S. Environmental Protection Agency (US EPA).

The following sections provide a summary of the environmental guidelines relevant to the Project, which are elaborated more fully within the Project Environmental Design Basis. The most stringent of these will be used as a basis for evaluating project impacts or as described in the impact sections or as otherwise described in the impact sections.

2.5.2 AIR ENVIRONMENT

2.5.2.1 AMBIENT AIR QUALITY STANDARDS

The IFC General EHS Guidelines (2007) require that project air ‘emissions do not result in pollutant concentrations that reach or exceed ambient quality guidelines and standards’. Standards are those established through national legislative and regulatory processes, and guidelines refer to levels ‘primarily developed through clinical, toxicological, and epidemiological evidence’.

IFC guidelines for ambient air quality standards are provided in IFC General EHS Guidelines on Air emissions and Ambient Air Quality (April 30, 2007).

The PME define ambient air as ‘that portion of the atmosphere, external to buildings, to which the general public has access’.

The PME Environmental Standard 19 - Ambient Air Quality prescribes the standards for ambient air quality parameters by defining the concentration and a specified averaging time, and in some cases a number of allowable exceedances. These standards include provision for dispersion zones within which air quality may exceed the defined standards if this zone does not impinge upon a sensitive receptor (subject to PME approval).

Ambient air quality criteria and standards which are relevant to the design of the facilities at Umm Wu’al comprise, but are not limited to, the following:

• IFC General EHS Guidelines on Air emissions and Ambient Air Quality, Table 1.1.1 WHO Ambient Air Quality Guidelines (April 30, 2007).

• PME Environmental Standard 19 - Ambient Air Quality (2012),

• Appendix A for threshold concentrations for ambient air pollutants.

2.5.2.2 SOURCE AIR EMISSION STANDARDS

Air quality criteria and standards used during the design and assessment of the Project comprise the following:

• IFC, EHS Guidelines, (April 30, 2007);

• IFC, EHS Guidelines, Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation (December 10, 2007):

• Table 1 outlines the guideline air emission levels relevant to Chemical Acid Plants.

• Section 1.1 includes recommendations for emission prevention and control measures.

• IFC, EHS Guidelines, Phosphate Fertiliser Plants Manufacturing (April 30, 2007):

• Table 1 outlines the guideline air emission levels specific to Phosphate Fertiliser Plants.

• Section 1.1 includes recommendations for dust management strategies which may require some specific design consideration.

• PME (2001) General Environmental Regulations and Rules for Implementation, Appendix 1 Environmental Protection Standards

• 11-C Emissions from Fertilizer Plants





• 11-H Visible Emissions from Industrial Activities

• PME Environmental Standard 4- Control of Emissions to Air from Stationary Sources Standard for KSA(2012),

• Appendix A, Table A1 provides emission limit values for emissions to air from stationary sources

2.5.3 WATER ENVIRONMENT

2.5.3.1 AMBIENT WATER QUALITY STANDARDS

The mining and beneficiation processes will not involve the direct discharge of liquid effluents to surface or ground waters, but uncontaminated surface water run-off may be directed to near-by wadis.

The receiving water criteria for PME jurisdiction are specified in:

• PME (2001) General Environmental Regulations and Rules for Implementation, Appendix 1, Environmental Standard 12 – Receiving Water Guidelines.

• PME Environmental Standard 20 - Ambient Water Quality (2012)

• Appendix A – Classification of Water Bodies and Appendix B – Prescribed concentrations and values.

2.5.3.2 WATER QUALITY CRITERIA AND STANDARDS

The FEED approach for water quality within PME jurisdiction will be that the facility must take necessary precautions to ‘prevent direct or indirect contamination of surface, ground and coastal waters that may be caused by solid or liquid residues’ (PME, 2001).

Water quality criteria and standards to which the facilities at Umm Wu’al will be designed to comply with, are identified in the following documentation:


• Table 2 outlines the guideline effluent emission levels specific to Phosphate Fertiliser Plants (including to fluoride and temperature).

• IFC, EHS Guidelines, Mining (December 10, 2007):

• Water Use and Quality (Section 1.1) and Table 2 Effluent Guidelines (relevant to ‘site runoff and treated effluents to surface waters for general use’ only).

• PME (2001) General Environmental Regulations and Rules for Implementation, Appendix 1 Environmental Protection Standards

• 13 - Performance Standards for Direct Discharges provides details of the standards for physiochemical pollutants (B-1), organic pollutants (B-2) inorganic pollutants (B-3) and biological pollutants (B-4) for direct discharge to water bodies

• 14 - Pre-treatment Guidelines for Discharge to Central Treatment Facilities provides details of physiochemical pollutants (D-1), organic and inorganic pollutants (D-2) for discharge of wastewater to centralised wastewater treatment plants

• PME Environmental Standard 17 - Industrial and Municipal Wastewater Discharges (2012)

• Prescribed Concentrations and Values for discharges into industrial and municipal wastewater plants, emergency discharges and discharges to coastal waters, surface waters, land and wadi provided in Appendix B





2.5.4 WASTE AND MATERIAL MANAGEMENT AND TRANSPORT

2.5.4.1 WASTE MANAGEMENT

Information relevant to waste classification and management, to which the Umm Wu’al Phosphate project has been designed to comply with, are identified in the following documentation:

• IFC General EHS Guidelines (April 30, 2007), Guideline 1.6 Waste Management;

• IFC, EHS Guidelines, Mining (December 10, 2007);

• IFC, EHS Guidelines, Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation (December 10, 2007):

• Table 4 outlines the guideline waste generation benchmarks.


• Table 4 outlines the guideline waste generation benchmarks.

• PME General Environmental Regulations and Rules for Implementation (2001):

• Article Fourteen

• Appendix 4, Hazardous Waste Control Rules and Procedures, Article IV - The Concepts of Wastes and Hazardous Waste;

• PME Environmental Standard 8 - Waste Acceptance Criteria (2012)

• PME Environmental Standard 9 - Waste Classification (2012)

• PME Environmental Standard 13 - Waste Handling and Storage (2012)

2.5.5 HAZARDOUS MATERIAL MANAGEMENT AND TRANSPORT CRITERIA AND STANDARDS

Information relevant to these criteria and standards, and to which the facilities at Umm Wu’al were designed to comply with, are identified in the following documentation:

• IFC, General EHS Guidelines, April 30, 2007:

• Hazardous Materials Management (Guideline 1.5);

• Occupational Health and Safety (Guideline 2.0);

• Transport of Hazardous Materials (Guideline 3.5);

• Emergency Preparedness and Response (Guideline 3.7).

• IFC, EHS Guidelines, Mining, (December 10, 2007):

• Hazardous Materials (Section 1.1).

The PME regulations in relation to hazardous waste are also relevant for hazardous material management and transportation.

2.5.6 NOISE

2.5.6.1 ENVIRONMENTAL NOISE STANDARDS

The potential noise emissions from the Umm Wu’al facility are subject to a number of design criteria and standards which were applicable to noise emissions from the facilities. Information relevant to noise emissions and management, and to which the Umm Wu’al Phosphate project has been designed to comply with, are identified in the following documentation:

• IFC, General EHS Guidelines, April 30, 2007;

• Environmental, Noise (Guideline 1.7);





• Occupational Health and Safety, Physical Hazards, Noise (Guideline 2.3).

• PME General Environmental Regulations and Rules for Implementation (2001), Article Thirteen, 13.3.

• PME Environmental Standard 3 - Environmental Noise (2012)

2.6 OTHER CONSIDERATIONS

2.6.1 BEST AVAILABLE TECHNIQUES

PME General Law & Rules for Implementation (2001), article six requires projects to “utilise the best possible and most suitable technologies for the local environment and use materials which introduce the lowest possible level of pollution to the environment”. Article 7 of Appendix 1 of the Regulations, General Environmental Protection Standards for New Facilities, requires new facilities to “incorporate the best available technology for control of pollutant discharges and for the disposal of wastes resulting from the operation of the facility”.

Best Available Technology is not elaborated further within the PME Regulations, however, the EU Directive on Integrated Pollution Prevention and Control (IPPC) introduces the definition of Best Available Techniques (BAT) which is used within the ESIA.

As part of the assessment of alternatives within the ESIA, best available techniques are considered. The following BAT reference documents (BREFs) produced by the European Commission are considered of relevance to the project:

• European Commission (2009) Management of Tailings and Waste-Rock in Mining Activities;

• European Commission (2007) Integrated Pollution Prevention and Control Reference Documents on BAT for the Manufacture of Large volume Inorganic Chemicals - ammonia, acids and fertilizers industries;

• European Commission (2007) Reference Document on BAT for Production of Speciality Inorganic Chemicals solids and other industries;

• European Commission (2009) Reference Document on BAT for Energy Efficiency; and

• European Commission (2001) Reference document on the application of BAT to Industrial Cooling system.

Additionally industry specific documentation on Best Available Techniques is also of relevance to the Project:

• European Sulphuric Acid Association (ESA) and the European Fertilizer Manufacturers Association (EFMA) (1999), Reference document on the application of Best Available Techniques Pollution Prevention and Control in the European Fertilizer Industry Booklet 3 of 8 –Production of Sulphuric Acid; and

• European Fertilizer Manufacturers Association (EFMA) (2000) Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry Booklet 4 of 8 – Production of Phosphoric Acid.

The relevant standards, guidelines and performance thresholds applied for the Project are referenced as relevant within the individual technical assessment chapters.





3.0 CONSIDERATION OF ALTERNATIVES

3.1 INTRODUCTION

This Section firstly provides an overview of the justification for the Umm Wu’al Phosphate Project and associated proposed facilities at Umm Wu’al and then describes various feasible project and design alternatives considered. It outlines how potential social and environment impacts are considered for the FEED design phase and provides justification for the selected alternatives, with a focus on the alternatives where social and environment outcomes are a determining factor in selecting the preferred alternative. Consideration is given to the application of Best Available Techniques (BAT) to the Project in accordance with the requirements of the Presidency of Environment and Meteorology (2001) in addition to International Finance Corporation (IFC) Performance Standards. Through their Performance Standard 3, the IFC outlines requirements for Resource Efficiency (Greenhouse Gases and Water Consumption) and Pollution Prevention (General, Hazardous Materials Management and Pesticide Use and Management). The objectives for this Performance Standard are as follows:

• To avoid or minimise adverse impacts on human health and the environment by avoiding or minimising pollution from project activities;

• To promote more sustainable use of resources, including energy and water; and

• To reduce project-related Greenhouse Gas (GHG) emissions.

The project and design alternatives considered for the proposed Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex include:

• Alternate Project “Do Nothing” option;

• Site alternatives;

• Configuration and alternative production options;

• Pollution control alternatives;

• Wastewater pre-treatment alternatives; and

• Waste management alternatives.

Following the consideration of these alternatives, the selected Project elements are developed to FEED. Section 4 Detailed Description and Layout of the Proposed Development provides a detailed description of the ensuing Project design option which was brought forward to the environmental and social impact assessment process.

The analysis of alternatives takes into account a range of factors with varying criteria depending on the option being assessed. Examples include health, safety, social, and environment; technical risk; capital and operating costs; operability; construction schedule; and geo-political risk. Typically, the selected alternative represents a compromise or balanced outcome as it is unlikely that all criteria for all factors can be simultaneously maximised and in fact maximising one factor may come at the expense of another. The analysis of alternatives is therefore iterative and represents an interplay of potentially competing demands.

3.2 PROJECT JUSTIFICATION

One of the priorities of the Ninth National Development Plan (2010-2014), produced by the Ministry of Economy and Planning, and other government strategy such as Vision 2020 is the diversification of the industrial sector and diversification of exports to reduce the Kingdom’s dependence on hydrocarbon extraction and refinement. The Kingdom of Saudi Arabia (KSA) has some of the largest phosphate reserves in the world and the growth of the phosphate industry is likely to play a pivotal role in national development. The Saudi Arabian Mining Company (Ma’aden) was formed by Royal decree in 1997 to facilitate the development of Saudi Arabia’s mineral resources. Ma’aden is a key strategic organisation which has been





tasked with the primary purpose of developing the mining industry and leading the privatisation of the mining sector within the KSA. Current forecasts of market conditions indicate global demand for fertiliser products has increased supported by the development of the expanding economies in the larger developing countries (such as India, China, and Brazil) along with the sustained demands of the United States and Europe.

Figure 3-1 below provides a diagram showing the global fertilizer trade-flow, production and consumption. It is based on 2010 fertilizer trade flows above the threshold of 400,000 product tonnes, the main countries producing fertilizer products and raw materials in 2011, and the fertilizer consumption in main consumption countries for years: 2010/11 to 2015/16 (International Fertiliser Industry Association 2013).





Figure 3-1: Global fertiliser trade-flow, production and c onsumption (International Fertiliser Industry Assoc iation 2013).





A key initiative implementing the vision enshrined within the Ninth National Development Plan is the proposed Waad Al-Shamaal City Development the establishment of which is defined within Council of Ministers Resolution No. 87 dated 20 February 2012 (Bechtel 2013). The primary purpose of the Waad Al Shamaal City development is to promote economic development in the North of the Kingdom, including but not limited to direct and indirect job creation, and employment opportunities, educational and training benefits, and improved access to services. The development of the Al Khabra deposit through the Umm Wu’al Phosphate Project, and specifically through the development of the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex represents the cornerstone of the Waad Al Shamaal City development.

3.3 DO-NOTHING OPTION

The ‘Do-Nothing’ option involves abandoning the idea of the Umm Wu’al Phosphate Project; in this scenario the Mine and associated Industrial Complex would not be established. This option would lead to no change in the current environmental or social impacts, however the economic benefits of developing the Project would not be realised.

The development of the mining and mineral industry is one of the key strategies for diversifying the economy of the Kingdom of Saudi Arabia. The ‘Do-Nothing’ option will not help growth and diversity in the Saudi economy, given that a significant percentage of the Kingdom’s GDP is based on the development and export of oil and natural gas resources. This dependence reduces the resilience of the economy during times of global financial instability, such as during the Global Recession of 2009. Industrial diversification is an imperative to ensure that the Kingdom maintains economic growth.

Furthermore, the Project represents the first step in developing the Waad Al Shamaal City, and improving economic development in this region of Saudi Arabia in particular. The ‘Do-Nothing’ option would hamper the development of the Waad Al Shamaal City, based as it is on leveraging mineral resources and phosphate as the anchor industry. As a result the ‘Do-Nothing’ option would stymie the wider development potential in this region of Saudi Arabia.

Therefore, the Project seeks to follow internationally accepted protocols and relevant legislation, design out where possible environmental and social impacts and where impacts remain apply project-specific mitigation and monitoring measures as identified in later Sections of this Environmental and Social Impact Assessment (ESIA). In this way the Project will be developed with an acceptable level of environmental and social impacts, and will significantly contribute to the Kingdom’s economy.

3.4 SELECTED SITE SUITABILITY

As part of its ongoing exploration activities Ma’aden has been evaluating the potential of a number of sites within the Turayf-Sirhan basin in northern Saudi Arabia, with a view to outline additional phosphate resources to support its expansion plans. These explorations have included assessment of five northern phosphate project areas; Thaniyat Turayf, Widyan ar Rushaydah, Al Amud, Umm Wu’al and Al Jalamid. Active exploration of the Al Jalamid and Umm Wu’al licence blocks, has been a key activity resulting in the commencement of mining at Al Jalamid in 2011.

Mining Licence 42/Q assigns the geographic area of the Umm Wu’al mine to Ma’aden for exploitation. This area is in the north-west of the wider Al Khabra exploration area (), and its location within the Border Security Zone, while presenting operational challenges in terms of access and the prohibition of permanent structures above ground level, means that the mining operation, does not impinge on any human rights of way, since access to this zone is already prohibited. Furthermore, the mine location, limits the sterilization of other areas of the exploration, thus facilitating future exploitation of the wider phosphate resources.





Figure 3-2 – Location of Umm Wu’al Mine within the wider A l Khabra exploration license.

The Industrial Complex location is determined by the boundary of the proposed Waad Al Shamaal City development, and within this the area designated for Ma’aden use. The site is located to the north of the area, to minimize the distance that crushed ore needs to be conveyed. This location also distances the Industrial Complex from the proposed future Waad Al Shamaal community.

The configuration of the Industrial Complex is oriented around the rail infrastructure as envisaged by the Waad Al Shamaal City development Master Plan, and in consideration of the prevailing wind direction, which sees winds primarily from the north-west. Thus materials storage facilities are located on the west of the site for ease of loading and unloading. Plant emitting to atmosphere and the tailings, and phosphogypsum storage facilities are located on the east of the site to take advantage of the prevailing wind to disperse air-borne emissions and particulates away from both the community, and the working environment. The location of the tailings and phosphogypsum storage facilities to the east, also allows for their future expansion, should future mining utilise the same Industrial Complex.

3.5 ALTERNATIVES CONSIDERED

The Project elements for which alternatives were considered, and environmental and social factors were influential are:

• Beneficiation technology • Mine backfill • Reuse of Brine • Phosphogypsum stacking method (wet vs dry) • Wadi Diversions

3.5.1 BENEFICIATION

The original pre-feasibility study included calcinations as the beneficiation process. An options appraisal of calcination and flotation the two principle technology approaches was undertaken by the design team.

While it was noted that according to the work undertaken during the pre-feasibility study, the calcination process may use c. 40% less water than flotation, these results were queried, and





an assertion made that the flotation process could be made more water efficient than had been reported. Additionally it was noted in the pre-feasibility stage that the calcinations process would produce a lime by-product that could be used for Fluorosilic acid (FSA) neutralisation, whereas the flotation process does not generate a useful by-product and lime is required to be sourced outside of the project. The options appraisal however, identified significant technological, and economic disadvantages for the calcination process; high levels of scaling, higher capital and operational costs, thus the flotation option was selected.

Nonetheless, the design approach has sought to minimise water use, through water reuse in the flotation process, and reclamation of water from tailings and slimes through mechanical filter processes to produce “dry” tailings. This latter approach has the following added benefits:

• Dry tailings reduce land take required, as these can be stacked higher; and

• Dry tailings significantly reduce the risk of dam failure and potential impacts to soil, surface, and ground water resulting from the subsequent contamination.

3.5.2 MINE BACKFILL / TAILINGS MANAGEMENT

Progressive backfilling of the mine void with waste rock formed a central tenant of the mining design. Within the Pre-feasibility study the first 5 years of tailings were proposed to be returned to a tailings management facility located to the west of the site, prior to transferred by conveyor back to the mine for use in conjunction with waste rock as backfill material.

Investigation of the characteristics of the ore and resultant waste rock, indicated that waste rock alone was likely to fill the mine void. Thus the original approach would require a final elevation above grade of approximately 10m, and would require transportation of the tailings from the beneficiation plant to the mine area throughout the first 5 years. The alternate option involved the use of the Tailings Storage Facility (TSF) adjacent to the beneficiation plant for the duration of the project.

Since a TSF was required adjacent to the beneficiation plant for tailings generated from year 5 onwards, the additional transportation requirements and uncertainty of the geochemistry of the tailings were considered to outweigh the potential environmental benefits of reusing tailings as backfill. These environmental factors, together with the technological and economic issues surrounding the double handling of material and the equipment requirements for transporting tailings back to the mine, resulted in selection of the option to use the TSF for the duration of the Project.

Additionally, since the results of the geochemical analysis of the beneficiation tailings are not yet completed, a precautionary approach to the storage of these was deemed appropriate. Thus the TSF is lined to eliminate potential contamination of soil, surface or groundwater.

Consideration was also given to the option to dispose of phosphogypsum as backfill in the mine. This option was discounted due to the large quantities to be transported, the increased height above grade that would result in the Border Security Zone and potential contamination of soil, surface and groundwater resulting from the composition of the phosphogypsum.

3.5.3 COOLING SYSTEM AND BRINE REUSE

The original design included localised cooling towers and associated brine generation. Brine is generated by the reverse osmosis (RO) process required to treat water abstracted from the aquifer for use in the process. The brine is a waste product which would normally be disposed of in evaporation ponds. Given the Project’s location in a region of water scarcity, and the reliance on fossil water abstracted from a non-renewable aquifer, water efficiency is a key concern for the Project. Thus the option of reuse of brine was considered and the following possible uses identified:

• Use in a cooling tower;

• Use for dust suppression; and

• Use as a slurry agent for FSA neutralisation.





Each of these potential uses were found to be viable, thus the alternate option reusing brine rather than disposing of it to evaporation ponds has been applied in the Project design.

The design includes a cooling tower system which utilises 350m3/h of the brine reject from the central RO system. This cooling tower will serve users that do not require the lowest process fluid temperatures achievable with the fresh water cooling tower since the brine will exchange heat via an indirect closed loop of process water and thus result in higher temperatures at the process fluid side. Blowdown water from the brine cooling tower will be employed such that:

• 52m3/h of brine will be used to form limestone slurry which will be used to neutralise the FSA generated by the Phosphoric Acid Plant (PAP);

• 86m3/h will be pumped to the mine maintenance area for dust suppression on mine haul roads;

The balance of 242m3/h will be directed to the phosphogypsum stack contact water drainage system where it will evaporate.

It is estimated that 177m3/h of water will evaporate from the brine cooling tower which represents the saving in water abstracted from the well fields if this concept were not implemented. This is calculated to be equivalent to 2.3Mtpa of water not abstracted from the aquifer.

The use of brine as a cooling water and centralising the cooling tower was determined to lower energy and raw water demand, in turn reducing requirements for water treatment, while also addressing the issue of brine disposal.

3.5.4 PHOSPHOGYPSUM STACKING

The original design considered use of a dry stacking system with a view to minimising water demand of the project. However the water balance identified an excess of approximately 413m/h of waste water from the process, which was to be directed to the phosphogypsum stack for evaporation. In light of the availability of this waste water consideration was given to the feasibility of operating a wet stacking system with this quantity of available water.

The wet stacking approach was considered preferable by the Project partners for the following reasons:

• Increased stability and increased heights of the stack could be achieved, providing technological and safety benefits;

• Reductions in the generation of dust from the stack, thereby benefiting air quality down wind of the phosphogypsum storage facilities;

• Reductions in noise generated by the conveyors and stacking equipment required for the dry stacking process, through the piping of slurried phosphogypsum; and

• Reduced operating costs.

The study concluded that the wet stacking option was not only feasible, but would not require make-up water. Thus the wet stacking option has been incorporated into the design.

3.5.5 WADI FLOW MANAGEMENT

Three wadis systems are found within the vicinity of the Industrial Complex, of these the Middle Wadi was considered to pose a potential flood risk to the Industrial Complex, since its course passed directly across the site from east to west. Two options for the management of the wadi flow were considered:

1. Earthworks to facilitate a route through the site and on towards the natural depression in the landform to the west of the site; or

2. Diverting the wadi in a cutting to the south outside the eastern site boundary to drain it to the South Wadi.

Option 1 requires: reconfiguration of the gypsum stockpile footprints and heights, extension of conveyor systems and crossing of the wadi, wadi training and the provision of flood protection embankments, providing culverts under the main site access road and railway, and re-





alignment and protection of the roads and pipelines connecting the main site to the water well field.

Option 2 requires: a bund across the wadi, construction of a deep diversion channel in the limestone/sandstone geology and minor realignment of the proposed road alignments.

The Middle wadi flood management options have advantages and disadvantages as follows:

Option Advantages Disadvantages

1 • Lower overall cost

• Shorter time to construct earthworks

• Maintains the close to the existing wadi route and discharge destination

• Greater residual risk to process site as the wadi passes closer to the site.

• Does not protect the Phase 2 Process Area development.

• Requires culvert under rail / road access adjacent to site.

• Requires reconfiguration of gypsum stockpile footprints and possibly loss of storage volume available.

• Involves both gypsum stockpiles being adjacent to flood flows, which have the potential to exceed design capacity, and possibly infiltrate the storage.

• Involves both gypsum stockpiles being adjacent to the wadi flow, and therefore catastrophic breach of either gypsum containment could result in contamination of the wadi flow.

• Likely increased flow at the end of the engineered diversion, may increase velocity and erosion potential of the wadi flow waters.

2 • Reduced residual risk to process site as wadi diversion is further from the site.

• Protects the Phase 2 Process Area development.

• Wadi diversion cutting will generate materials which may be used in the construction.

• Diversion route follows edge of a single gypsum stockpile, thereby reducing potential for inflow of flood waters, and possible contamination from catastrophic breach of gypsum containment.

• Larger overall cost.

• More time needed to construct earthworks.

• Minor road rerouting needed.

• Likely increased flow at the end of the engineered diversion, may increase velocity and erosion potential of the wadi flow waters in the South wadi.

The diversion of the Middle wadi to the South wadi was considered to have lower environmental, technical and economic costs and therefore is implemented in the design.

The northern portion of the Mine is also crossed by a wadi system. The original design involved the mining of the area through which the wadi flows from year 15. The potential for





the pit to be flooded, and wadi water contaminated by the mining activites was identified and the following options considered:

1. Not mining the wadi area;

2. Diversion of the wadi at the eastern boundary of the mine with a bund such that the wadi flow is directed to the north toward the Jordanian border;

3. Diversion of the wadi at the eastern boundary of the mine with a bund such that the wadi flow is directed through the infrastructure corridor to the north of the mine pit until reaching the original course to the west of the mine; and

4. Diverting the wadi along a pillar of unmined land along the faultline, which has a high waste: ore ration and is therefore of lower economic value, via a constructed channel, slightly to the south of the existing route, and directing the flow to join the original course to the west of the mine.

Option Advantages Disadvantages

1 • No alteration to the wadi flow, in particular its route into Jordan (although this is shortlived)

• Steralises a significant area of the mine, reducing the economic potential of the mine.

2 • Allows full mine area to be exploited

• Reduced cost of earthworks since route is small

• Amends the flow of the wadi such that route is entirely altered

• Final destination of wadi flow altered

• Requires earthworks to generate the new wadi channel

3 • Returns the flow to the original route to the west of the mine, retaining flow into Jordan and final destination of flow

• Higher costs associated with earthworks, due to longer route

• Amends the flow of the wadi across the mine such that the route is entirely altered


• Requires construction very close to the International border

• Narrow mine infrastructure corridor insufficient in width

• Compromises use of the corridor

4 • Maintains flow of the wadi across the mine area, retains flow into Jordan and final destination of flow

• Allows for retention of the wadi route across the mine following closure, facilitating rehabilitation of any ecosystems along its route


• Steralises area of the mine, along the faultline reducing economic potential of the mine

It was determined that option 4 provides environmental advantages, and the least substantial technological and economic disadvantages than the other options and has therefore been implemented in the design.

3.6 POLLUTION CONTROL ALTERNATIVES

The selection of pollution control measures is an integral part of the design process. Pollution control measures have been included in the FEED to achieve the more stringent of the emissions / discharge limits provided by the national regulator the PME, or the IFC. Both





require consideration, and application, where appropriate of Best Available Technique (BAT). The following sections outline the application of BAT within the FEED.

The development of the Detailed Design by the selected Engineering Procurement and Construction (EPC) contractor, may result in modifications to the BAT selection, however compliance with the regulatory requirements of the International Finance Corporation (IFC) and the Presidency of Meteorology and Environment (PME) are necessary as a minimum.

3.7 APPLICATION OF BAT

The European Union, under its Directive on the Control of Pollution (Integrated Control and Pollution Prevention (96/61/EC)) has established a benchmark standard for industrial activities, which relates to the main aspects of industrial design and operation and sets out the Best Available Techniques (BAT) for pollution prevention and control. The BAT is detailed for each major industrial activity in a series of documents called the EU BAT Reference (BREF) notes. There are a number of BREF notes applicable to the Project, and these have been used to guide the design development in FEED; a process which should continue into Detailed Engineering, and throughout the Project.

The following sections assess the application of BAT within the FEED for the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex, against the BAT guidance available.

3.7.1 SULPHURIC ACID PLANT

To assess the application of BAT for the Sulphuric Acid Plant (SAP), Table 3-1 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for Sulphuric Acid Plants:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals – Ammonia, Acids and Fertilisers, 2007” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive). Chapter 4 – Sulphuric Acid.

While the above BAT reference document does not set legally binding standards, they are designed to give a basis for the guidance of industry. Note BAT recommendations which are not applicable for this Project and have been excluded.

Table 3-1: Comparison of proposals and international BAT guidance - Sulphuric Acid

BAT Reference Document (BREF) Proposals

1. BAT is to use recoverable energy: co-generated steam, electrical power, hot water

The reaction of sulphur with oxygen to produce SO2 is highly exothermic. The thermal energy is captured in the form of high pressure steam which is used to generate power and low pressure steam using two independent steam turbine generators, 100% of which is used to supply the majority of the Project’s low pressure steam and electrical demand.

Approximately 3.5Gj/ tonne of 100% H2SO4.

A heat recovery system (HRS) whereby acid cooling is in part achieved by rejecting heat to a low pressure steam generation system is excluded from the base design on the basis of higher investment cost and complexity, however, the Invitation to Bid allows EPC bidders to include HRS as an option.

2. BAT is to apply a combination of the following techniques and achieve the conversion rates and

The design utilises a double contact / double absorption process whereby one of the absorbers is used prior to the final catalyst bed(s) resulting in a shift in the conversion equilibrium and overall






emission levels given below:

a. Double contact / double absorption; b. Single contact / absorption; c. Addition of a 5th catalyst bed; d. Using a caesium promoted catalyst in bed 4

or 5; e. Change over from single to double

absorption; f. Wet or combined wet/dry processes; g. Regular screening and replacement of

catalyst, especially of catalyst bed 1; h. Replace brick arch converters by stainless

steel converters; i. Improve raw gas cleaning; j. Improve air filtration e.g, by two stage filtration

(sulphur burning) k. Improve sulphur filtration e.g. by applying

polishing filters (sulphur burning); l. Maintaining heat exchanger efficiency; and m. Tail gas scrubbing, provided that by-products

can be recycled on site. Emission levels:

Conversion rate – 99.9 – 99.92%

SO2 – 30-340mg/Nm3

Note 1: These conversion rates relate to the conversion including the absorption tower, they do not include the effect of tail gas scrubbing.

Note 2: These levels might include the effect of tail gas scrubbing

higher conversion efficiency.

The design is a 4 pass system which achieves a conversion rate of >97%, a performance of 2kg SO2 per tonne of acid and SO2 emissions of 1250mg/Nm3.

The regular screening and replacement of catalysts is an operational rather than design issue, however it should be noted that the proposed replacement frequency for the catalyst in bed 1 is every 3 years.

The design utilises a number of BAT technologies and approaches to achieve the IFC 2kg/t acid performance standard.

3. BAT is to continuously monitor the SO2 levels required to determine the SO2 conversion rate and the SO2 emission limit.

SO2 monitoring is provided within the design.

4. BAT is to minimise and reduce SO3 / H2SO4 mist emissions by applying a combination of the following techniques and to achieve the emission levels given below.

a. Use of sulphur with a low impurity content; b. Adequate drying of inlet gas and combustion

air (only for dry processes); c. Use of larger condensation area (only for wet

catalyst process); d. Adequate high performance candle filters

after absorption; e. Control concentration and temperature of the

absorber acid; and f. Apply recovery / abatement techniques in wet

processes such as electrostatic precipitator (ESP), wet electrostatic precipitator (WESP), wet scrubbing

Emission levels:

H2SO4 – 10 - 35 mg/Nm3

The design includes the following BAT technologies:

• Gas drying;

• Circulating acid temperate/ concentration control; and

• High performance candle filters.

However the design does not achieve the BAT emission levels, but does achieve 60mg/Nm3 (0.075kg/tonne H2SO4, in accordance with the IFC emission level guideline.

The design includes raw gas is drying to minimise H2SO4 mist emissions






5. BAT is to minimise of abate NOx emissions. The design basis is to meet the most stringent requirement of PME or World Bank guidelines for NOx emissions, in this case 200mg/Nm³ as per IFC.

NOx levels can be minimized by applying low NOx burners; however, the burner design is proprietary to the technology provider, therefore no further information is available at this time.

6. General BAT is to minimise energy losses by:

• Avoiding steam pressure reduction without using the energy;

• Adjusting the whole steam system in order to minimise excess steam generation;

• Using excess thermal energy on-site or off-site; and

• Using steam for generating electrical power, if local factors prevent the use of excess thermal energy on-site or off-site.

As indicated above, the design includes utlisation of 100% of the steam generated to produce energy for the Project.

An auxiliary boiler with 20MWe capacity is provided for SAP start up, and other upsets, and is proposed to operate continuously at 20% capacity.

7. BAT is to improve the environmental performance of the production site by a combination of the following techniques:

a. Implementation of an Environmental Management System (EMS)

b. Carry out routine energy audits c. Recycling or re-routing mass streams d. Efficiently sharing equipment e. Increasing heat integration f. Preheating of combustion air g. Maintaining heat exchanger efficiency h. Reducing waste water volumes and loads by

recycling condensates, process and scrubbing waters

i. Applying advanced process control systems j. Maintenance

The implementation of an Environmental Management System (EMS) shall be undertaken by the EPC contractor during the construction phase. During operation of the facility, Ma’aden will be responsible for EMS implementation. The EMS will outline the necessary requirements for managing and improving environmental performance at the facility.

The existing phosphate production facility at Ras Al Khair operated by Ma’aden Phosphate Company, an affiliate of the Saudi Arabian Mining Company Ma’aden has recently been received accreditation for the following ISO standards:

• ISO 9001 (Quality Management);

• ISO 140001 (Environmental Management); and

• ISO 50001 (Energy Management).

8. BAT for storage is to apply BAT given in European Commission (2005) BREF on Emissions from Storage.

The main storage requirements for the SAP are for a 1012m3 sulphur day tank and for a 108m3 diesel day tank. These tanks are provided with secondary containment and will be continuously monitored for leaks.

3.7.2 PHOSPHORIC ACID PLANT

To assess the application of BAT for the Phosphoric Acid Plant (PAP), Table 3-2 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for PAPs:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals – Ammonia, Acids and Fertilisers, 2007” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive). Chapter 5 – Phosphoric Acid.






Table 3-2: Comparison of proposals and international BAT guidance – Phosphoric Acid


1. BAT for new installations is to achieve P2O5 efficiencies of 98% or higher.

The efficiency over the filter is expected to be 98% or higher, however of both reactor and filter, the expected performance figure is a 95% yield on P2O5. The plant will be one of the most efficient in the world, and few if any are currently known to achieve 98%.

2. BAT for the wet process is to minimise the emissions of P2O5 by applying one or a combination of the following techniques:

a. Entrainment separators, where vacuum flash coolers and/or vacuum evaporators are used;

b. Liquid ring pumps with recycling of the ring liquid to the process; and

c. Scrubbing with recycling of the scrubbing liquid.

The vapours from the PAP evaporation / concentration stage are passed through an Entrainment Separator, two scrubbers and a scrubber separator to minimise emissions.

Scrubbing liquid is re-circulated and reused in the scrubbing system.

3. BAT is reduce dust emissions from rock grinding e.g. by application of fabric filters or ceramic filters and to achieve dust emission levels of 2.5 – 10mg/Nm3

Rock grinding does not take place within the PAP; rather the plant is supplied with rock slurry from the beneficiation plant. The beneficiation plant is fitted with dust collector systems.

4. BAT is to prevent dispersion of phosphate rock dust by using covered conveyor belts, indoor storage and frequently cleaning / sweeping the plant grounds.

All conveyor systems included in the design are covered. All crushing, grinding and milling activities which may generate dust are undertaken under cover, or are provided with dust extraction systems.

5. BAT is to reduce fluoride emissions by application of scrubbers with suitable scrubbing liquids and to achieve fluoride emission levels of 1-5mg/Nm3 expressed as Hydrogen Fluoride (HF).

The PAP includes a scrubber system which is designed to achieve 5mg/Nm3 expressed as HF from each of the three stacks.

6. BAT for wet processes is to market the generated phosphogypsum and FSA, and if there is no market to dispose of it.

No market for phosphogypsum of FSA generated by the Project has been identified within KSA. Therefore the Project includes provision of two lined storage facilities.

7. BAT for wet processes is to prevent fluoride emissions to water e.g. by application of indirect condensation system or by scrubbing with recycling or marketing the scrubbing liquid.

Fluorine emissions to water are prevented through the recycling of scrubbing liquid. Any blowdown is directed to the FSA neutralisation process where contained fluorine is stablised through the formation of Flurospar.

8. BAT is to treat wastewater by applying a combination of the following techniques:

a. Neutralisation with lime; b. Filtration and optionally sedimentation; and

Recycling of solids to the phosphogypsum pile.

Wastewater generated is reused within the process where possible, a small quantity is used to form the lime slurry which is used to neutralise FSA, and other wastewaters.

Phosphogypsum, and Fluorspar are both directed to the phosphogypsum storage facilities.

9. BAT is to improve the environmental performance of the production site by a

The implementation of an Environmental Management System (EMS) shall be undertaken by the EPC contractor during the construction






combination of the following techniques:

a. Implementation of an Environmental Management System (EMS)

b. Carry out routine energy audits c. Recycling or re-routing mass streams d. Efficiently sharing equipment e. Increasing heat integration f. Preheating of combustion air g. Maintaining heat exchanger efficiency h. Reducing waste water volumes and loads by

recycling condensates, process and scrubbing waters

i. Applying advanced process control systems j. Maintenance

phase. During operation of the facility, Ma’aden will be responsible for EMS implementation. The EMS will outline the necessary requirements for managing and improving environmental performance at the facility.

The existing phosphate production facility at Ras Al Khair operated by Ma’aden Phosphate Company, an affiliate of the Saudi Arabian Mining Company Ma’aden has recently been received accreditation for the following ISO standards:

• ISO 9001 (Quality Management);

• ISO 140001 (Environmental Management); and

• ISO 50001 (Energy Management).

10. BAT for storage is to apply BAT given in European Commission (2005) BREF on Emissions from Storage.

All tanks within the PAP process are provided with secondary containment and will be continuously monitored for leaks.

3.7.3 DOWNSTREAM PLANTS

No specific BAT guidance is available for the phosphoric acid purification process, however BAT guidance is available for STPP and DCP, and are provided in the following sections.

3.7.4 SODIUM TRIPOLYPHOSPHATE (STPP) PLANT

To assess the application of BAT for the STPP Plant, Table 3-3 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for STPP Plants:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals – Solids and Others, 2007” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive). Chapter 6 – Inorganic Phosphates.


Table 3-3: Comparison of proposals and international BAT guidance – STPP


1. BAT is to reduce the impact on the environment by selecting either purified non-fertiliser grade wet phosphoric acid or pure thermal grade phosphoric acid for the production of food grade phosphates.

The STPP process utilises purified food grade phosphoric acid generated on site, following production of phosphoric acid in the PAP.

2. BAT is to maintain the consumption of main raw materials in the maximum range of 581 – 588kg P2O5 equivalent and 545-550kg NaOH equivalent per tonne of STPP by optimising and controlling process parameters.

The Technology provider is allowing for a 2% loss of product due to mechanical/dust losses. Without these equipment losses the STPP plant would use 578.5kg of P2O5 equivalent/ per tonne of STPP. This number will be provided more accurately during detail design and the selection of the dust filtration equipment.

100 % NaOH would be 554 kg NaOH per tonne of






STPP with losses. Again the 2% mechanical losses are impacting this ratio. Without any losses the ratio would be 543.5 kg NaOH per tonne of STPP.

The BAT converts the Na2CO3 to NaOH for comparison.

3. BAT is to reduce the total emissions to below the following levels by applying a suitable combination of preventative and abatement techniques:

Fluorine – 0.3kg F/ tonne of STPP

P2O5 – 0.5kg P2O5/tonne of STPP (wet air streams)

Dust – 0.9kg dust / tonne of STPP (dry air streams)

The AEL for dust is <20mg/Nm3, and for fluorine is <3mg F/Nm3

The emissions levels achieved by the process are:

Fluorine – 0.01 kg/tonne of STPP

Fluorine concentration (F<1mg/NM3 dry air)

P2O5 – and dust emissions per tonne of STPP are to be determined in detail design, but are anticipated to meet BAT.

4. BAT is to minimise the total consumption of thermal energy within the range of 4.8 – 8.3Gj per tonne of STPP (depending on the concentration of the purified non-fertiliser grade wet phosphoric acid) by controlling the concentration of the supplied acid and optimising the process on a regular basis.

LPG is used as the source of thermal energy for the calciner. Approximately 5Gj per tonne of STPP is used. This is in addition to 0.34Gj of electrical energy per tonne of STPP produced.

3.7.5 MONOCALCIUM/DICALCIUM (MCP/DCP) PLANT

To assess the application of BAT for the MCP/DCP Plant, Table 3-4 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for DCP Plants:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals – Solids and Others, 2007” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive). Chapter 6 – Inorganic Phosphates.


Table 3-4: Comparison of proposals and international BAT guidance – DCP


1. BAT is to reduce the impact on the environment by selecting either purified non-fertiliser grade wet phosphoric acid or pure thermal grade phosphoric acid for the production of food grade phosphates.

The MCP/DCP process utilises purified food grade phosphoric acid generated on site, following production of phosphoric acid in the PAP.

2. BAT is to maintain the consumption of main raw: PPA & CaO (and/or CaCO3) in the maximum range of 0.4-0.5 tonnes P2O5 equivalent and 0.2-0.3 tonnes Ca equivalent per tonne of 18% DCP by optimising and controlling process parameters.

In order to achieve BAT the amount of phosphoric acid and calcium carbonate required to achieve the required 18% DCP is flow ratio is controlled. The limestone flowrate is set by the 0.4-0.5 tonnes P2O5 equivalent required and is optimised through proportional integrative derivative (PID)






looping tuning.

3. BAT is to reduce the content of phosphates in the wastewaters to 0-5g P per m3 of wastewater by recovery of spills from acid conditioning and reaction, and the reuse of water.

Process water is reused in the scrubbing system, and therefore generation of wastewaters are intermittent and small scale.

4. BAT is to reduce the total dust emissions to air to <20mg/Nm3 in the exhaust gas by using a suitable combination of preventative measures and de-dusting techniques.

Dust collection systems are installed as part of the design to achieve <5mg/Nm3 with the exception of the limestone silo and hopper filters which achieve <50mg/Nm3. Total dust emissions have not been calculated.

5. BAT is to minimise the total consumption of thermal energy within the range of 40-350kWh per tonne of 18% DCP (depending on the concentration of the purified non-fertiliser grade wet phosphoric acid) by controlling the concentration of the supplied acid and optimising the process on a regular basis.

Energy efficiency of the gas fired rotary drier is to be addressed in detailed design.

3.7.6 TAILINGS AND WASTE ROCK

To assess the application of BAT for the tailings and waste rock generated from the mining of phosphate, Table 3-5 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for tailings and waste rock from mining activities:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques for the Management of Tailings and Waste Rock from Mining Activities, 2009” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive).


Table 3-5: Comparison of proposals and international BAT guidance – Tailings and Waste Rock


1. BAT is to evaluate alternative options for:

a. Minimising the volume of tailings and waste rock generated, e.g. by proper choice of mining method;

b. Maximising opportunities for the alternative use of tailing and waste rock such as:

• Use as aggregate; • Use in the restoration of other mine sites;

• Use in backfilling c. Conditioning the tailings and waste rock

within the process to minimise environmental or safety hazard.

An evaluation of mining methods was undertaken. Conventional truck and shovel with drilling and blasting has been selected for the majority of the mining operation, but includes a component of ripping in waste material of thickness less than 3m. This method is expected to bring operational efficiency, best selectivity, and low dilution factors.

Waste rock is used to progressively backfill the mine void.

The temporary waste rock dump required prior to commencement of backfill operations, is to be contained to minimise potential for contamination of infrequent surface water flows with any contact warter from the dump.

Dry tailings are generated by the process, and stored within an engineered storage facility,

2. BAT is to provide a suitable management strategy for tailings / waste rock that cannot be avoided and that are not suitable for alternative use.






3. BAT is to apply a life cycle management approach to tailings and waste rock.

thereby minimising environmental and safety hazards.

4. BAT is to: a. Reduce reagent consumption; b. Prevent water erosion c. Prevent dusting; d. Carry out a water balance and use the results

to develop a water management plan; e. Apply free water management; and f. Monitor groundwater around all tailings and

waste rock areas.

The use of reagents within the beneficiation process is per requirements to achieve the required rock slurry.

The resultant tailings are 80% solid, and from experience at Al Jalamid are understood to result in minimal dust generation. Tailings are stored in an engineered facility with contact water management systems, thereby protecting water systems.

The outline Environmental Monitoring and Management Plan (EMMP) (see Appendix A) developed as part of the ESIA includes groundwater monitoring requirements appropriate to the site and the associated risks.

4. BAT is to prevent the generation of acid rock drainage (ARD), and where this is not possible control it or apply treatment options.

Initial geochemical analysis of the waste rock indicates ARD to be of minimal concern. It is understood tailings to be of similar composition, however final analysis has not yet been received.

4. BAT is to locate tailings or waste rock facilities such that a liner is not necessary. However, if this is not possible and the seepage quality is detrimental and/or the seepage flowrate is high, then seepage needs to be prevented, reduced or controlled.

The temporary waste rock facility is not lined, and minimal seepage is anticipated. Since the full geochemical analysis of the tailings is not available, the tailings management facility is designed with liner as a precautionary approach.

4. In relation to emissions to water BAT is to: a. Reuse process water; b. Mix process water with other effluents

containing dissolved metals; c. Install sedimentation ponds to capture eroded

fines; d. Remove suspended solids and dissolved

metals prior to discharge of the effluent to receiving watercourses;

e. Neutralise alkaline effluents with sulphuric acid or CO2; and

f. Remove arsenic from mining effluents by the addition of ferric salts.

Potentially contaminated water from the waste rock dump, surface water collecting in the working mine pit, and contact water from the tailings storage facility is to be directed to contaminated water ponds, and tested prior to any discharge to the environment. Waters not complying with ambient water quality standards, are evaporated in situ, and the resultant solids disposed to a licensed waste facility as appropriate.

5. In relation to noise BAT is to: a. Use continuous working systems; b. Encapsulate belt drives in areas where noise

is a local issue; and c. Create the outer slope of a heap and then

transfer ramps and working benches into the heap’s inner area as far as possible.

The operation of the mine is proposed as a 24hour operation. Thus the equipment, conveyor etc used will be in operation continuously. The primary ore crusher is below ground level and enclosed, and conveyors are covered thereby providing noise abatement. These are addressed as part of the noise impact assessment.

7. BAT is to: a. Divert natural external runoff; b. Manage tailings or waste rock in pits; c. Apply a safety factor of at least 1:3 to all

heaps and dams during operation, and d. Carry out progressive restoration /

revegetation.

External runoff is diverted away from the tailings storage facility by the wadi diversion scheme.

Waste rock is managed primarily in pit through its use as backfill. Insufficient excavated area is available for the management of tailings in this way. Waste rock and tailings storage facilities are






designed with a 1:3 slope.

The mine is to be progressively backfilled / restored. More detail of the restoration of the TSF will be developed through Project life.

8. BAT is to monitor heaps the following: a. Bench / slope geometry; b. Sub-tip drainage; and c. Pore pressure And to carry out the following:

• Visual inspections • Geotechnical reviews

• Independent geotechnical audits

Monitoring requirements are included in the outline EMMP developed with the ESIA and are to be further developed through the detailed design phase by the EPC contractor.

9. BAT is to: a. Carry out emergency planning; b. Evaluate and follow up incidents;

The Environmental Emergency Response Plan (Appendix B) sets in motion the means by which this BAT is achieved.

10. BAT is to: a. If possible, prevent and/or reduce the

generation of tailings / waste rock; b. Back fill tailings under the following conditions

when:

• Backfill is required as part of the mining method

• The additional cost of backfilling is at least compensated for by the higher ore recovery

• In open pit mining if the tailings easily dewater and thereby a TSF can be avoided or reduced in size

• Use nearby mined out open pits if available for backfilling

• Backfill large stops in underground mines c. Backfill tailings in the form of paste fill if the

conditions to apply backfill are met and if

• There is a need for a competent backfill

• The tailings are very fine, so that little material would be available for hydraulic backfill

• It is desirable to keep water out of the mine, or where it is costly to pump the water draining from the tailings

d. Backfill waste rock under the following conditions: • It can be backfilled within an underground mine

• One or more mined out open pits are nearby

• The open pit operation is carried out in such a way that it is possible to backfill the waste rock without inhibiting mining operations

e. Investigate possible uses of tailings and waste rock.

The mining schedule is devised to allow for the progressive backfill of the mine void with waste rock. In sufficient void space is available given the anticipated expansion factors that tailings may also be used for backfill. Therefore a TSF is required for the duration of the Project.

11. BAT is to: The outline EMMP developed as part of this ESIA,






a. Develop closure and after care plans during the planning phase of an operation, including cost estimates and then to update them over time. However the requirements for rehabilitation develop through the lifetime of an operation and can first be considered in precise detail in the closure phase of a TSF; and

b. Applying a safety factor of at least 1:3 for dams and heaps after closure

includes and outline closure plan for further development and refinement by Ma’aden throughout the duration of the Project, and in advance of closure.

3.7.7 COOLINGS SYSTEMS

To assess the application of BAT for the cooling systems Table 3-6 below provides a comparison between the proposals and the BAT Reference Document (BREF) which includes internationally agreed BAT specifically for cooling systems:

• BAT (Best Available Techniques) Reference Document (BREF) entitled “Reference Document on Best Available Techniques to Industrial Cooling Systems, 2001” reflects an information exchange carried out under Article 16(2) of Council Directive 96/61/EC (IPPC Directive).


Table 3-6: Comparison of proposals and international BAT guidance – Cooling Systems


1. BAT is to: a. Increase the overall energy efficiency; b. Reduce the use of water and cooling water

additives; c. Reduce emissions to air and water; d. Reduce noise; e. Reduce entrainment of aquatic organisms;

and f. Reduce biological risks

The cooling water system design utilises brine from the treatment of raw water by reverse osmosis. This approach reduced the quantity of water required to be abstracted by 15%. The brine cooling system makes energy savings in pumping raw water equivalent to a 450kW motor running continuously for 20 years, and in treating the raw water by RO is equivalent to a 200kW motor running continuously for 20 years. A reduction in size of the RO plant of 2.9Mtpa (28%) is also achieved by the design. Furthermore, the volume of brine for disposal is reduced from 3.2Mtpa to 1.7Mtpa; a reduction of 47%.

3.7.8 BAT CONCLUSIONS

As identified in the sections above, the Project utilises techniques and activities identified as BAT, however in a number of instances the application of these techniques does not result in the achievement of all the emissions levels identified as BAT. Nonetheless it should be noted that the values provided by BREF are provided as guidance to industry to which continuous improvement should aspire. The Project is to be compliant with the regulatory requirements as identified in Section 2 – Policy, Legal and Administrative Framework, and has sought to implement BAT to the extent possible within the technological and economic context of the Project. Air dispersion modelling reveals that ambient air quality at receptors and the available environmental headroom are not reduced as a result of the Project. Therefore it is considered that sufficient application of BAT has been achieved, and additional investment to achieve further emission reductions, are not warranted.





3.8 RESOURCE EFFICIENCY

IFC Performance Standard 3 provides for the consideration of resource efficiency and pollution prevention and control. Within this context, the IFC EHS Guidelines provides specific resource efficiency and energy efficiency benchmarks indicators against which projects may be assessed. Thus over and above the assessment of the application of BAT, the Project can be assessed in terms of the extent to which it meets the resource efficiency benchmark indicators set out in both the General and Sector Specific EHS Guidelines. These industry benchmark indicators, are supplied to provide guidance on industry best practice.

Table 3-7 provides a comparison between these industry benchmark indicators, and the Project performance, and demonstrates that for the most part the Project is meeting or exceeding industry benchmark indicators. Where the project does not achieve industry best practice benchmark indicators, it should be noted, that it does nonetheless achieve the required regulatory standards.

Table 3-7: Comparison of Resource and Energy Consumption

Product Unit IFC Industry Benchmark 1

Project

Phosphoric Acid

Tonne phosphate rock/tonne P2O5 2.6 – 3.5 3.5

Tonne H2SO4 / tonne P2O5 2.1 – 2.3 2.9

KWh / tonne P2O5 120 - 180 95

m3 cooling water / tonne P2O5 100 - 150 0.9 (evaporate)

Tonne phosphogypsum/tonne P2O5 4 - 5 5.3

mg/Nm3 Fluorides 0.6 - 5 5

kg SO2/tonne HF 0.001 – 0.01 N/A

Tonne CaSO4 (anhydrite)/tonne HF 3.7 <1

Sulphuric Acid mg SO2 / Nm3 30 - 350 1250





4.0 DETAILED DESCRIPTION AND LAYOUT OF THE PROPOSED DEVELOPMENT

4.1 INTRODUCTION

As introduced in Section 1.0 Introduction, the Ma’aden Umm Wu’al Phosphate Project will be based on two sites, namely Umm Wu’al and Ras Al Khair. The proposed industrial complex at Ras Al Khair Industrial City will include an Ammonia Production Plant, a Diammonium Phosphate (DAP)/Nitrogen Phosphate Potash (NPK) Plant and a Materials Storage and Handling Facility, and is the subject of a separate Environmental and Social Impact Assessment (ESIA). The Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex will include an open cast mine and an industrial complex which will include a Beneficiation plant, Sulphuric Acid Plant (SAP), Phosphoric Acid Plant (PAP), Purified Phosphoric Acid (PPA) plant, Sodium TriPolyPhosphate (STPP) plant, Monocalcium Phosphate/Dicalcium Phosphate (MCP/DCP) plant and required utilities. For the purpose of this report, the new developments proposed by Ma’aden at the Umm Wu’al site will be referred to collectively as the Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex (‘the Project’). Where addressed separately the following naming shall be applied throughout the report; Umm Wu’al Mine (‘the Mine’) and Waad Al Shamaal Phosphate Industrial Complex (the ‘Industrial Complex’).

4.2 MAIN FEATURES OF THE PROJECT

The Project will produce the following products:

Table 4-1: Umm Wu’al Phosphate Project – Products

Main Facilities Product Quantity

Mine Phosphate Ore 13.5Mtpa

Beneficiation Plant Phosphate Concentrate 5.3Mtpa

Sulphuric Acid Plant Sulphuric Acid 5Mtpa

Phosphoric Acid Plant Merchant Grade Phosphoric Acid(MGA) 1.5Mtpa

Purified Phosphoric Acid Plant PPA 0.1 Mtpa

Sodium TriPolyPhosphate plant STPP 0.09Mtpa

Monocalcium Phosphate/Dicalcium Phosphate (MCP/DCP) plant

MCP/DCP 0.25Mtpa

Molten Sulphur, will be transported by rail to the Industrial Complex while Soda Ash, and Limestone; other materials required for use in the chemical process will be transported by road. The following processed materials will be transported by rail from the Umm Wu’al site to the proposed industrial complex at Ras Al Khair or to Jubail / Dammam for storage, use and/or export:

Table 4-2: Umm Wu’al Phosphate Project - Materials Transf er

Storage and Use at Ras Al Khair DAP/NPK Plant

Storage and Export from Ras Al Khair

Export from Jubail / Damman

Merchant Grade Phosphoric Acid (MGA)

Merchant Grade Phosphoric Acid (MGA)

Sodium TriPolyPhosphate (STPP)

Raffinate Purified Phosphoric Acid (PPA)

Mono/Dicalcium Phosphate (MCP/DCP)

Sulphuric Acid





4.3 PROJECT LOCATION

The Umm Wu’al site, illustrated in Figure 4-1, is situated within the Northern Borders Province of the Kingdom of Saudi Arabia close to the border with Jordan. The Project is to be developed on Government land provided for this purpose. Ma’aden holds the exploration and mining licence for the Al Khabra deposit and surrounding area, allowing the development of the project in this location.

The Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex cover an area of approximately 58km2. The mine covers an area of 37.82km2 and is located close to the border with Jordan within the 10km border security zone and 26km to the southwest of the Iraq border.

Approximately 13km to the south of the proposed mine and outside the border security zone, is the location of the proposed Waad Al Shamaal Phosphate Industrial Complex, which is within the boundaries of the planned Waad Al Shamaal City development. There is also a well field area for the abstraction of water located approximately 60km to the east of the Waad Al Shamaal Phosphate Industrial Complex.

The closest sizable population centre is Turaif, which is approximately 40 km to the south-west of the site, with a population of 48,929, of which 82% are Saudi nationals (Central Department of Statistics and Information, 2010). The nearest dwellings within Jordan appear to be developments along the route of Highway 10 transecting the Mafraq region of Northeast Jordan, some 80-90km to the north of the International border with the Kingdom of Saudi Arabia; the most sizable of which appears to be Ar Ruwayshid as shown in Figure 4-1 and the satellite image in Figure 4-2.

4.4 SITE LAYOUT

Figure 4-3 and Figure 4-4 illustrate the proposed site layout of the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex.





Figure 4-1: Site Location of the Umm Wu’al Site





Jordan

Saudi Arabia

Iraq

Turayf CityTuraif Airport

Ruwayshid Airfield

Ar Ruwayshid Airfield

Ar Ruwayshid Settlement

390,000

390,000

400,000

400,000

410,000

410,000

420,000

420,000

430,000

430,000

440,000

440,000

450,000

450,000

460,000

460,000

470,000

470,000

480,000

480,000

490,000

490,000

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510,000

510,000

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520,000

530,000

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540,000

540,000

3,50

0,00

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0 5 10 15 202.5 Kilometers

Landsat 7 Satellite Imagery courtesy of the U.S. Geological Survey - January 2013

Figure 4-2: Satellite Image of the Closest Settlements to the Project (January 2013)





Figure 4-3: Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex Layout





Figure 4-4: Waad Al Shamaal Phosphate Industrial Complex L ayout





4.5 SITE CONNECTIVITY

The Project site will be accessed via the Trans-Arabian Highway (National Highway 85) from a proposed junction 7.5km east of Turaif and from a proposed 135km railway branch line taken from the recently constructed 2400km long North South Railway Line. Once the branch line is completed the site will be approximately 1600km by rail from the Port of Ras Al Khair (RAK) on the Arabian Gulf, which will be developed to cater for the planned throughput of product exports and raw material imports. Figure 4-5 illustrates the connectivity of the site with other parts of Saudi Arabia.

Figure 4-5: Site Connectivity

4.6 NEIGHBOURING INDUSTRIES

This Project represents the first industrial development within the proposed Waad Al Shamaal Development City. As such the site is considered a greenfield site. To the south of the project site, on the National Highway 85 is a poultry farm, and in the surrounding area transient livestock herding stations can be found (see Figure 4-1)

The primary purpose of the proposed Waad Al Shamaal City development is to promote economic development in the Northern Province of Saudi Arabia for the benefit of residents in this region. The Waad Al Shamaal City development is envisaged to include further downstream industries related to phosphate, other primary mineral industries and other industrial and service facilities, and will provide infrastructure to support the Industrial Complex including roads, rail, electrical power facilities, gas distribution, water supply and distribution systems, wastewater collection system and treatment plant, facilities for solid waste handling and a storm drainage protection system. It is also proposed to include development of a full residential community to house employees of the industries and to accommodate a full range of commercial and governmental facilities to serve the residents (Bechtel, 2012). Figure 4-6





indicates current proposals for the development of Waad Al Shamaal City, while Figure 4-7 shows the phasing of the development (Bechtel 2013).

Figure 4-6: Waad Al Shamaal City development [Source: Bech tel 2013]





Figure 4-7: Proposed Phasing of the Waad Al Shamaal City D evelopment [Source: Bechtel 2012]

The initial phase of the Waad Al Shamaal City development will include the first phase of development of a residential area for Maaden’s permanent employees (approximately 1,000 employees) and dependents in the community zone development. In addition to its residential area, Maaden will also simultaneously develop “essential infrastructure” to support the residential area, such as a basic road network throughout the site, water supply and sewage collection service to the residential area, and storm drainage improvements. These are described in more detail in Section 4.6.1.

In addition to the Ma’aden residential area, other elements of the community will be developed simultaneously, although not under Ma’aden’s direct management. These other elements will include community infrastructure (schools, mosques, commercial areas, civic facilities such as police and fire stations and government buildings, and other facilities, as well as separate residential areas for employees of these facilities. Site-wide infrastructure will also be provided in conjunction with these facilities.

Other developments within the Waad Al Shamaal City are outside the scope of this ESIA, and will be the subject of a separate Environmental Assessment, however, given the concurrent development of the Ma’aden residential area and essential services adjacent to the Project site, the potential environmental and social impacts of the housing and essential services as well as the Project‘s impacts on these receptors will be considered in this ESIA.

4.6.1 WAAD AL SHAMMAL ESSENTIAL SERVICES

Concurrent with the development of the Umm Wu’al mine and associated processing complex, a portion of the Waad Al Shamaal City Development will be constructed to provide permanent accommodation for approximately 1,000 Ma’aden employees who will operate the mine and associated processing complex, and their dependents. This ‘essential infrastructure’ comprises:

• Accommodation (villas and apartments);

• Community facilities (schools, mosques, emergency services, retail and social facilities);

• Local roads;

• Local utilities (power, telecommunications, potable and irrigation water supply, sewerage and stormwater collection);

• A highway to connect the residential and phosphate complex to Highway 85

Figure 4-8 identifies in blue the aspects of the Waad Al Shamaal city development included within the scope of this ESIA.





Figure 4-8: Waad Al Shamaal City Essential Services – Phas e 1 up to 2016 as included within the scope if the ESIA identified in blue [Based on: Bechtel 2013]

The ‘essential infrastructure’ is to be available for occupancy by the second half of 2016 to provide necessary infrastructure for Ma’aden employees participating in the start-up, testing and commissioning of the phosphate plants.

4.6.2 WAAD AL SHAMAAL CITY

In parallel to the residential development being carried out by Ma’aden, it is planned that a separate agency will develop additional residential areas and infrastructure for a population other than Ma’aden employees. It is intended that this agency will be the ultimate city developer and operator (similar to the Royal Commission in Jubail and Yanbu). The decision of which agency will take this role is pending from the Ministry of Petroleum and Mineral Resources (MoPM).





The King Abdullah Project for Waad Al Shamaal City Development Masterplan estimates that the total employment in Waad Al Shamaal at the end of 2016 will be 2,458. This comprises Ma’aden employees (1000) and other residents. This results in a total population of the community of 4,588 individuals.

The King Abdullah Project for Waad Al Shamaal City Development Masterplan report also defines the infrastructure required and corresponding population at 2021 (defined as Phase 1) for the whole Waad Al Shamaal City (i.e. separate to the development associated with the Project). Based on the masterplan assumptions the infrastructure requirements for Waad Al Shamaal City at 2021 are as follows:

• Provision of internal roads;

• Provision of power supply to deliver 13.7MW;

• Provision of 1,078m3/day of potable water;

• Provision of 506m3/day of irrigation water;

• Provision of sanitary wastewater collection / treatment facilities for 862m3/day; and

• Provision of solid waste collection and disposal facilities for 23 tonnes of waste per day

The provision of these infrastructure services is described below, as they are of relevance to the Project in terms of their availability for Ma’aden housing provided for the Project.

Power will be provided to Waad Al Shamaal by the Saudi Electricity Company (SEC). SEC will provide transmission lines from the national grid connections at Tabajal and Qurayyat. SEC will also construct substations and transmission lines within Waad Al Shamaal. The interface point between SEC and Ma’aden (and the other development agency) is yet to be agreed. Should this permanent power not be available when required, the residential area will be power by local diesel generators.

Potable water will be tankered from Turaif to the temporary potable water pumping station adjacent to the community, stored in tanks, and pumped around the residential area. In the longer term potable water will be supplied from a wellfield accessing the Tawil aquifer, and treated and distributed through a centralised treatment, storage and distribution network.

A network of sanitary wastewater pipes will be constructed around the community. In the short term this network will connect to septic tanks from which wastewater will be tankered to the Turaif sewerage treatment plant, assuming this is fully operational by 2016 and also has spare capacity to supply the required TSE for irrigation purposes. In the long term this network will connect to the Waad Al Shamaal permanent wastewater treatment plant.

Solid waste will be disposed of to the existing Turaif landfill until such time as the landfills identified to service the Waad Al Shamaal City are in operation.

The centralised infrastructure services anticipated to service Waad Al Shamaal are envisaged to be operational by 2021; the end of Phase 1.





4.7 PROJECT SCHEDULE

Project phases and planned timing is summarised in Table 4-3.

Table 4-3: Umm Wu’al Mine and Waad Al Shamaal Phosphate I ndustrial Complex Schedule

Project Phase Start Finish

Front End Engineering Design and Bankable Feasibility Study July 2012 July 2013

ESIA Scoping Meeting with the Presidency of Meteorology and Environment

December 2012 December 2012

Presidency of Meteorology and Environment Site Visit May 2013 May 2013

Presidency of Meteorology and Environment Approval for Commencement of Early Works sought May 2013 May 2013

Presidency for Meteorology and Environment Review of ESIA for Environmental Approval July 2013 November 2013*

EPC Contract Award & Commencement of Detailed Engineering July 2013 November 2015

Early Works & Site Preparation October 2013 April 2014

Detailed Engineering December 2013 September 2015

Main Construction May 2014 March 2017

Commissioning February 2016 July 2017

Facility Ready For Start Up May 2016 July 2017

* Predicted date subject to PME review duration.

4.8 WORKFORCE AND NUMBER OF EMPLOYEES

During the construction phase, the workforce is estimated to be between 7,000 and 10,000 direct workers as per current schedule. Construction work week will be 10 hours/day for 6 days/week.

During the operation phase, the mine and associated industrial complex will operate 24 hours per day. The anticipated operational workforce used within the OPEX calculations is summarised in Table 4-4. It should be noted that in accordance with Saudi Labour Law, the proportion of Saudi employees is required to be 65% at the commencement of the project, rising to a minimum of 85% by year 5 of the Project’s operation. Thus the employment values identified in Table 4-4. Table 4-4 represents indicative figures to be refined as the Project progresses.





Table 4-4: Operational Workforce Estimate

MANPOWER Number of Personnel

2017 2018 2019 2020 2021 2022 2023 2024- 2033 2034 -2037

VP Saudi 1 1 1 1 1 1 1 1 1

Manager Saudi 14 14 14 14 20 20 22 30 33

Manager NS 10 10 10 10 22 22 22 0 1

Supervisor Saudi 114 114 114 114 157 157 159 168 168

Supervisor NS - Western 57 57 57 57 57 57 57 31 31

Skilled Saudi 330 330 330 330 381 381 381 381 381

Skilled NS - Eastern 36 36 36 36 36 36 36 36 36

Semiskilled Saudi 435 435 435 435 515 515 511 539 571

Semiskilled NS - Eastern 20 20 20 20 8 8 8 0 0

Unskilled Saudi 137 137 137 137 155 155 151 195 191

Unskilled NS - Eastern 125 125 125 125 121 121 129 101 97

TOTAL 1,279 1,279 1,279 1,279 1,473 1,473 1,477 1,482 1,510

Total Saudi 1,031 1,031 1,031 1,031 1,229 1,229 1,225 1,314 1,345

Total Non Saudi (NS) 248 248 248 248 244 244 252 168 165

Saudization Percentage 81 81 81 81 83 83 83 89 89





Operations staffing is estimated to at least 700 individuals on site within any shift, working 8 and 12 hour shifts; 0600 to 1400, 1400 to 2200 and 2200 to 0600 and 0600 to 1800 & 1800 to 0600 respectively.

The operational workforce will be transported to site by bus, and private car, resulting in an estimated 20 vehicles per hour at peak times.

The number of daily visitors is estimated on average to be 4 persons per day, and up to 154 trainees attending training at the site; this is including the 116 Heavy Goods Vehicles (HGV) that will visit the site on a daily basis to deliver materials required for the operation of the Project.

4.9 CONSTRUCTION PHASE

The construction phase of the project is to be divided into an Early Works Package, and main construction phase. The Early Works package allows the preparation of the site in advance of the main construction phase and is envisaged to commence in September 2013.

4.9.1 EARLY WORKS

The early works package will allow preparation of the site, and basic infrastructure provision to allow Engineering Procurement and Construction (EPC) contractors to commence construction. The early works package is divided into two phases.

Phase 1 will include the following:

• the preparation of the Industrial Complex, including the Rail loading area and perimeter roads to deliver the levels required for the efficient functioning of the Project;

• preliminary grading of laydown areas and temporary roads and associated drainage;

• construction of temporary road network around, and within the Industrial Complex and laydown area, and connecting roads to the construction camp, Highway 85 and the Waad Al Shamaal interim construction road;

• clearance and preparation of the construction camp; and

• excavation and construction of temporary flood protection works (wadi diversion scheme) from in-situ materials at the Industrial Complex (completion of the wadi diversion will occur during the main construction phase).

Phase 2 will involve the preliminary grading of the waste storage areas and includes grading and bunding both the Phosphogypsm Storage Facility (PSF) and Tailings Storage Facility (TSF).

The preparation of the process area will involve cut and fill activities deliver the levels required for construction of the process plants. The cut and fill calculations undertaken for the early works indicate that all material derived from this process will be reused on site as part of the cut and fill, the preparation of temporary roads, and the implementation of the embankments, and bunds required for the wadi diversion scheme.

A significant element of the early works package, which will continue into the main construction phase, will be the flood protection works, which will involve realignment of the wadi to the north of the Industrial Complex to prevent encroachment on the Project area, and the diversion of the middle wadi currently running through the Industrial Complex to the southern wadi. These wadi realignment and diversions will comprise bunding, permanent culverts, and rock erosion protection and are illustrated in Figure 4-9.





Figure 4-9: Wadi Re-alignment and Diversion Schematic

4.9.2 MAIN CONSTRUCTION PHASE

The various construction areas are illustrated in Figure 4-10 and Table 4-5 provides a summary of the scope of each area shown.





Figure 4-10: Waad Al Shamaal Phosphate Industrial Complex Construction Areas





Table 4-5: Identification of Construction Areas

Construction Area Type Facilities associated with Construction Area Total Area

Laydown, Fabrication & Office Space General Services and Utilities

16,000 m2

Process Plant Area 230,000 m2

Laydown, Fabrication & Office Space Beneficiation

37,500 m2


Laydown, Fabrication & Office Space SAP

37,500 m2


Laydown, Fabrication & Office Space PAP

37,500 m2


Laydown, Fabrication & Office Space PPA

16,000 m2


Laydown, Fabrication & Office Space DCP/MCP

4,000 m2


Laydown, Fabrication & Office Space STPP

4,000 m2


Laydown, Fabrication & Office Space Administration/Maintenance Buildings etc.

14,000 m2

Plant Area 6,0000 m2

It is envisaged that the process facilities will be constructed using major contractors with the standing and capability to deliver a ‘vertical package’ type arrangement, reliant on off-site pre-fabrication and modular construction. The infrastructure works will be constructed using a more traditional ‘horizontal package’ arrangement, by subcontracting with local contractors where available to undertake areas of work on a by discipline type of arrangement.

4.9.3 TEMPORARY FACILITIES

An area of 1.5km2 to the south of the contractor’s laydown area has been allocated for the camp area. 1km2 has been allocated to the EPC Contractors, with 0.5km2 allocated to the early works contractor for use as camp and equipment storage/maintenance The location of the construction camp some 5km to the south of the main Industrial Complex area is shown in Figure 4-1.

While the construction camp is yet to be designed, it is anticipated to include site offices and associated facilities, and accommodation consisting of approximately 100 eight person rooms, 35 four person rooms, 5 two-person rooms and ten individual suites. Communal facilities proposed for the camp include:

• Recreation building, including sports facilities; • Kitchens and Dining halls; • Laundry; • Medical centre; and • Mosque. Utilities provided for the construction camp; wastewater treatment, waste disposal, are described in section 4.9.4 below.





4.9.4 CONSTRUCTION UTILITIES

The temporary facilities will include provision for the storage of 2 days potable of water, estimated to be some 5.2 million litres of water, which will be delivered by tanker to the site from Turaif, or a locally sunk well. This water will be used for drinking, as well as in construction for activities such as concrete mixing and dust suppression.

Wastewater conveyance will be provided within the temporary facilities to septic tanks to be emptied by tanker to temporary wastewater treatment facility to be provided within the Construction Camp. Sanitary wastewater will be treated for use in irrigation, to the standards required by the Ministry of Water and Electricity (MoWE).

Power will be provided by an array of diesel generators to provide the anticipated power demand of 16MW, until such time as the installation of a sub-station connecting to the National Grid.

The wastes anticipated to be generated during the 30 month construction are provided in Table 4-6.

Table 4-6: Anticipated Construction Wastes

Waste Stream Tonnes

Concrete Waste 9,324

Pipework offcuts etc. 11,373

Steelwork offcuts etc. 7,560

Electrical Cable Waste 1,480

Miscellaneous Construction Waste 37,072

Municipal Waste 7,062

Solid Sanitary Waste 546

Total 96,892

Hazardous wastes are not quantified, but may be expected to include empty drums and containers (oil, chemicals, paints), resins, oil contaminated materials, filters, oils and lubricants, chemicals, paints, thinners, solvents, fire fighting agents etc.

A Construction Site Waste Management Plan (CWMP) will be prepared, in compliance with regulations and best practise, and implemented by the Contractor before the production of any waste material. This plan will identify in more detail the types and volumes of waste and how this waste will be handled, stored, managed, treated, disposed of and controlled. The requirements for this CWMP are addressed in the outline Environmental Management and Monitoring Plan (Appendix A).

Suitably qualified and accredited sub-contractors will be used during the removal and transportation of hazardous materials. All records for the transportation and disposal of hazardous waste will be maintained (and kept available for random inspection) on site.

In the absence of recycling facilities in the Northern Borders Province, all construction waste, is anticipated to be re-used on site, or disposed to a licensed waste management facility.

4.9.5 TRAFFIC AND LOGISTICS

The construction works will be performed in many areas at the same time to meet the required schedule. This will result in large movements of personnel and materials to and from the Mine area located inside the border security zone, as well as throughout the Industrial Complex.





Particular attention will be paid to areas which may impact or be impacted by the simultaneous development of Waad Al Shamaal essential infrastructure and phase 1 residential development.

It is anticipated that workers will be transported to the site by dedicated fleet of buses, with an estimated maximum of 250 vehicle movements per shift. Traffic movements required to support the temporary camp are anticipated to be 3 to 5 deliveries/waste collections by HGVs per day. To supply the temporary accommodation camp with potable water a further 60 water tanker movements per day are required; this will cease once a well and water treatment plant are in place.

Materials and equipment required for the construction of the Project will be delivered by rail and HGV. The North-South Railway will be available for deliveries of materials from the Eastern Province to Al-Jalamid, where they would be unloaded and delivered to Umm Wu’al by HGVs. Materials such as steelwork, piping, cabling, prefabricated process equipment and general construction materials are anticipated to be delivered by rail. The majority of construction materials are expected to be transported to the site by road; either from their port of origin (e.g. Jubail or Yanbu), or from the rail head at Al-Jalamid where they would be unloaded and delivered to site by HGV resulting in approximately 293 movements per week. Locally won materials, such as sand and fill etc will be utilised wherever possible to reduce the requirement to import bulk materials from other locations

4.10 PRE-COMMISSIONING AND COMMISSIONING PHASE


• Hydrotesting of pipelines and tanks; • Flushing & cleaning of pipelines; • System dry-out; • Inerting; • Systematic conformity check of equipment; • Static, de-energized test of equipment; • Preliminary, and Functional checks; • Operational test; and • Pre-start up activities.

Hydrotesting of pipelines, tanks, and vessels will be conducted using fresh (desalinated) water in order to meet quality criteria needed for this activity and to avoid corrosion damage to the equipment prior to start-up. In particular, tanks filled to a pre-set level, will be required to maintain this loaded state for a certain period of time before being drained. The total quantity of fresh water to be used during hydrotesting activities is not available at this stage, but the total quantity will be minimised through hydrotest water reuse by transferring it from one tank to another. However, as the tanks have different volumes, careful planning in the hydrotest sequence will be applied, considering the construction schedule, applicable engineering standards and project specifications. The fresh water needed for hydrotesting activities will be supplied from the well sunk for the construction phase, or the Project wellfield when operational. Approximately 83,000m3 of water will be required, of which 4,000m3 will be demineralised water, which is anticipated to be reused.

Discharge of hydrotest wastewater will be routed to the contaminated stormwater pond and analysed to determine compliance with surface water standards, or where non-compliance discharged to the industrial wastewater treatment plant for treatment. The location of any discharge ponds, or discharge to the environment will be determined on the basis of an assessment of recharge / drainage capacity. The rate of discharge will be controlled in order to avoid overloading the receiving stream. These activities to be undertaken by the Contractor, are addressed in the EMMP (Appendix A). Hydrotest water, may also be captured and stored as initial charge water for the phosphogypsum wet stacking system.





4.11 OPERATION PHASE

The Block Flow Diagram shown in Figure 4-11 illustrates the proposed operation of the mine and associated processing complex.

In summary the operation of the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex involves the open cast mining of phosphate containing rock which undergoes initial crushing before being transported by conveyor to the beneficiation plant. Non ore containing material is rejected, and ore containing rock is passed through a flotation process to separate the phosphate from the gangue and form rock slurry and tailings which are dewatered and disposed of in a tailings storage facility with the rejected material.

Sulphuric acid is produced on site through the combustion of molten sulphur and reaction with heated air with the assistance of vanadium oxide and alkali sulphate catalysts ; the process generates heat which is used to produce energy for the Project enabling it to be largely self-sufficient, and gases containing sulphur dioxide and hydrogen sulphide.

The rock slurry is reacted with the sulphuric acid, and kaolin to produce weak phosphoric acid, and phosphogypsum waste. The concentration of the weak phosphoric acid through an evaporator system results in the production fluorisilic acid (FSA) which is neutralised with lime to produce fluorspar, gaseous fluorides which are scrubbed before being released to atmosphere and 54% Phosphoric acid (Merchant Grade). This MGA is both a product for export and an input to other processes.

In the Purified Phosphoric Acid (PPA) plant the MGA undergoes desulphurisation and defluorination, and metal removal resulting in the formation of gypsum, CO2, and small quantities of HF and SiF4 as well as H2S. FSA is precipitated out as sodium fluorosilicate. The resultant phosphoric acid is purified through contact with a solvent; traces of organic impurities are absorbed by activated carbon before further concentration of the acid and decolourisation with hydrogen peroxide to produce Food Grade Phosphoric Acid. Solvent is regenerated and solvent containing fumes are scrubbed before undergoing thermal oxidisation,

The PPA is mixed with of soda ash and caustic soda to produce a mixture of Monosodium Phosphate (MSP) and Disodium Phosphate (DSP) which is dried and calcined to produce dry Sodium TriPolyPhosphate (STPP).

MGA from the PAP is also defluorinated with diatomaceous earth, generating SiF4 which is passed through a scrubbing system which in turn generates FSA which is neutralised with calcium hydroxide to produces calcium fluorosilicate and calcium silicate solids. The acid is combined with limestone slurry resulting in a reaction producing gypsum and a defluorinated phosphoric acid, which is heated and again reacted with limestone slurry and a recycle stream of MCP/DCP to produce a granular MCP / DCP product which is dried and screened.

All gypsum and neutralised FSA wastes are disposed of to a lined PSF.

In support of the above mining and chemical processes the Project provides infrastructure in the form of a wellfield supplying the Project’s water demand, and associated water treatment, cooling water, loading / unloading, materials handling and storage facilities, auxiliary and emergency power, wastewater treatment, and drainage services as well as the waste facilities referred to above.

The Project also involves the provision of administrative areas such as offices, a training centre, workshops and laboratories, and the provision of housing and essential services for the Ma’aden staff that will operate the facility.





Figure 4-11: Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex Block Flow Diagram





The mine and associated processing facilities and infrastructure are designed for a 25 year life. The following sections describe the main processes undertaken at the Umm Wu’al Mine and Processing site.

4.11.1 MINING

The Umm Wu’al mining licence number 42/Q was granted by the MoPM to Ma’aden on 26th July 2006. The licence area is located within the Al Khabra mining concession and covers an area of 37.82km², of Government land, allocated to Ma’aden for the purpose of developing the Umm Wu’al Mine. The mining licence allows exploitation of the resource for a period of 30 years from the date of the licence. The licence includes standard conditions regarding the protection of the environment and restoration of the mine, as identified in Section 2 Policy, Legal and Regulatory Framework.

Figure 4-12 illustrates the proposed mine layout.

Figure 4-12: Mine Layout [Source: SRK (2013a)]





4.11.1.1 MINING DESCRIPTION

The phosphate deposit is relatively shallow and will be mined using open pit methods working 4 hours per day, 330 days per year. The average mine depth is expected to be 25m with the maximum depth to be 45m and the mine life is expected to be in the region of 28 to 30 years.

Traditional drilling and blasting techniques are proposed, with overburden soils being excavated and stripped away from the bedrock. The mining will commence in the northwest of the Mining Licence and progress east and south.

The Ore Reserve Estimate calculates some 390,000,000 tonnes of ore to be available from the selected pit shell, of which 54% is classified as measured, and the remaining indicated; a further 47,300,000 tonnes is inferred. It is, therefore, estimated that the Umm Wu'al Mine will produce an average of 13.5Mtpa raw phosphate rock. Based on a mine life of 29 years an average of 31.6 million tonnes of waste rock per year will be generated (SRK, 2013b).

The production schedule is designed to maintain a constant feed of P2O5 of some 2.35Mtpa which due to variations in grade will require an ore head feed of some 14-16Mtpa. The average waste stripping ratio is 2.6 (tonne waste: tonne ore), but the thickness of waste varies and increases with the life of mine as thicker waste zones have been inferred.

Shallow overburden of less than 3m depth will be excavated via ripping and dozing, while thicker overburden will be subject to drilling and blasting. The ore and interburden will be mined as separate units where possible.

Blasting is to be conducted using Ammonium Nitrate Fuel Oil (ANFO) as the principal base charge; using diesel as the type of fuel oil. Ammonium nitrate will be stored in a dedicated magazine building located to the north of the Industrial Complex and loaded into licenced explosives trucks for transportation to the mine face. Fuel oil will be added and mixed with the ammonium nitrate prior to being loaded into the blast holes. Drilling is anticipated to be a daily activity, while blasting will occur once every second day in the first five years of operation, and daily thereafter. An anticipated 20-30 tonnes of ANFO will be used daily.

Figure 4-13 illustrates the progressive stages of pit excavation proposed for the life of the Mine devised by SRK to minimise material re-handling, and vehicle movements within the mine.





Figure 4-13: Pit Stage Plan [Source: SRK (2013a)]

Waste rock (overburden and inter-burden) waste from the initial mine development (approximately 20Mt), the first 1.5 years, will be stored at a temporary waste rock dump some 1km2 by 10m high located in the north east of the mine licence. The temporary waste rock dump is split into two dumps. This is to avoid building in the middle of the existing wadi which currently crosses the area from east in a north-westerly direction.

Two separate drainage systems are provided. Channels constructed around the perimeter will intercept rain water runoff emanating from the waste rock in water drainage channels and convey the water to designated discharge locations.

From the geochemical analysis water from the waste rock dumps is currently classified as “dirty” water, it is therefore proposed that this water is collected via sumps in the WRD drainage solution and pumped to the pit dewatering system to promote evaporation.

Backfilling of the pit will commence from Year 1.5. The backfilling of the mine will occur progressively as shown in Figure 4-14, with the temporary waste rock dump removed and re-handled in later years of production life as backfill to create access to reserves. By progressively backfilling the pit as part of regular mining operations reclamation and closure activities are effectively part of regular operations. Closure of the mine is addressed within Attachment 1 of Appendix A – Environmental Management and Monitoring Plan.





Figure 4-14: Progressive mining and backfill operations [Source: SRK (2013a)]





There is insufficient backfill material to completely fill the mine void. However the backfill approach illustrated in Figure 4-15 is expected to result, at the end mine life (year 29), a 4Mm3 void space in the south-east corner of the mine. Waste rock re-handling may be required to ensure that the whole excavation is backfilled. The deficit is equivalent to a height difference in the final land surface of less than 11cm.

Figure 4-15 – Mine at End of Life [Source: SRK 2013a]

Until year 15 the mining activity will impact the existing wadi bed only through the transportation of material to the waste dumps. At year 15 the wadi will be diverted to the south, to run along a pillar of unmined land (see Figure 4-16) left along the fault in the rock which has lower phosphate content, and a high stripping ratio. The wadi realignment will allow the wadi to continue to flow across the area along a similar route to the existing path, and will be directed to exit the mine site, at the original point as it approaches the International Border.

Figure 4-16 illustrates the flood extents for a 1 x 20year water level and identifies the proposed route across the mine, for the pillar which will accommodate the wadi diversion channel once mining in the wadi area commences.





Figure 4-16: Flood Extents and Pillar Route

The pillar will provide a channel for the wadi flow capable of accommodating a 1 in 20 year flood event; an event frequency considered appropriate given the channel will not be required to be operational until year 15 of the mine’s 25 year design life. The channel will be lined to provide assurance against pillar instability with a sprayed on soil-cement mixture of relatively low quality but which is found to be successful in protecting surfaces of slopes against erosion. The pillar and associated channel will remain in place as the mining progresses, and the excavated pits are gradually backfilled.

Figure 4-17: Sketch of the Proposed Pillar and Wadi Divers ion Channel

Stormwater breaching the pillar channel, or falling directly into the working mine pit will be pumped out, and transferred to evaporation ponds located within the mine infrastructure corridor on the west, south west side of the mine. Stormwater will be tested for contaminants;





where stormwater is found to meet the ambient water quality standards, it will be discharged to the nearest wadi system. Where found to be contaminated, it will be retained within the evaporation pond.

Ore from two principal horizons shall be delivered to the Primary Ore Crusher (POC); horizon 2 and horizon 3 as defined in the Mineral Resource Estimate (SRK 2012b) which is estimated to account for approximately 83.5% of the ore reporting to the POC. The remaining 15.5% of ore reporting to the POC has been identified as being delivered from horizons 1 and 4.

Ore will be hauled from the mine face and unloaded at the POC. The POC is to be located within the mining concession, at the eastern boundary in an excavation approximately 15m deep. To minimize stockpiling and re-handling of material, ore generated from the mine will be fed directly into the Primary Ore Crusher, however, a stockpile equivalent to one month of normal production, some 1Mt of ore will be stored adjacent to the POC to allow for disruptions to normal mining operations.

Initial unloading, and any rock breaking required for large rock, occurs within an enclosed, temporary fabric building fitted with bag filter system to minimise dust emissions. Vehicles will unload ore to one of the two grizzly feeders, which transfers material via covered conveyor to the jaw crusher. Ore is crushed to achieve 100% passing 150mm and transported via an inclined, covered belt feed conveyor to the first transfer tower. From here the crushed ore is transported to the beneficiation plant via a 12km long conveyor.

The POC has a total capacity of 3,000 metric per hour and is split into two parallel primary crushing circuits. Ore horizons will be mixed to form a single Run of Mine (RoM) material prior to feeding the crushing circuits. The layout and section of the POC is provided in Figure 4-18 and Figure 4-19.

Figure 4-18: Primary Ore Crusher Layout [Source: SRK 2013a]





Figure 4-19: Primary Ore Crusher section [Source: SRK 2013c]

Above ground permanent structures are prohibited within the Border Security Zone, therefore the Primary Ore Crusher is located 15m below surface.

The primary crushing equipment, including the dump station, bins, and screens will be covered and any dust will be removed using dust extraction system linking to a bag-house. The conveyors will also be covered to minimize dust. Additionally, a total of 87m3/hr of brine is to be transferred from the reverse osmosis plant within the Industrial Complex to the Mine for use in dust suppression. This brine will be sprayed by mining water trucks for dust suppression on haulage roads.

The conveyor transporting the crushed ore to the beneficiation plant is discussed in Section 4.12.2.

4.11.2 MINING INFRASTRUCTURE

The mining infrastructure supports the mining operation and includes the Mine Maintenance Area (MMA) located 3km inside the border security zone, inside the mining concession and the Ammonium Nitrate Facility (ANF) located in the north of the processing site.

The Mine Maintenance Area comprises the following:

• Potable water storage and distribution;

• Diesel storage and distribution;

• Heavy vehicle refuelling;

• Light vehicle refuelling;

• Heavy vehicle wash bay, including oily water separation and wash water recycle;

• Light vehicle wash bay, including oily water separation and wash water recycle;

• Mine vehicle tyre bay;





• Heavy vehicle lubrication storage and distribution;

• Mine water truck filling station for dust suppression (brine will be used for this duty);

• Domestic sewage storage; and

• Raw well water storage for and pumping to the fire fighting system.

Buildings provided in this area include laboratory and core store, vehicle maintenance, workshops and warehouses, administration, facilities, medical centre, canteen, fire station, control rooms and entry/exit check points.

The Ammonium Nitrate Facility (ANF) will handle, store and prepare explosives, detonators and cartridges at a separate location. Bulk ammonium nitrate (AN) storage facilities will turnover of large quantities of stock, and are designed to store one month’s supply of AN; approximately 900t. The AN is expected to be packaged in 1t palletised bulk bags and delivered in twenty foot containers with sufficient capacity for approximately 28t each. It is expected that the warehouse will be on a split level with the AN stored on the upper level. The bulk bags will be emptied into a suitable sized hopper which screens the AN.

The ANF will also include:

• Potable water storage and reticulation;

• Domestic sewage storage;

• Raw well water storage for and pumping to the fire fighting system; and

• Emergency power generation;

• Administration.

The MMA and ANF will operate 24 hours a day.

Potable water is delivered to a storage tank (2 day capacity) via the potable water pipeline. The stored potable water is pumped to the MMA/ANF buildings for services. Sewage generated in these buildings is stored in tanks until removed daily by a sewage truck for treatment at the Sanitary Wastewater Treatment Plant (SWTP). The fire water system will normally be pressurised with potable water from the potable water tank, and uses potable water during small fires. In the event of a large fire, untreated raw well water is sourced from two storage tanks (the stored water is sourced from the untreated raw well water pipeline).

Brine is delivered from a pipeline and stored in a tank. The stored brine is then pumped from the tank into two Water trucks for dust suppression of roads.

Diesel is delivered to a storage tank (7 day capacity) via a pipeline for used for vehicle refuelling and for use in blasting. Diesel is pumped to the local day tanks in the heavy and light vehicle refuelling areas, and will be transferred by road to the mine for use in blasting activities. The storage and distribution areas are bunded.

Service fluids, e.g. oils and coolants are delivered in a tanker (except for EP Grease which will be delivered in bulk bags) and unloaded to a storage tank. Waste oil/coolant is stored in a tank until drained and removed by trucks. The storage and distribution areas are bunded.

Vehicles will undergo washing in one of two bays provided at both heavy and light vehicle washing areas. The waste wash water will flow to a settling pond which under flocculant addition will separate out into solids and oil-water solution. Solids will be air dried and removed via a front end loader. The solution will overflow into a sump where oil will be skimmed into a collection dry and the water will be recycled back via a sump pump.

4.11.3 BENEFICIATION PLANT

The Umm Wu’al phosphate deposit contains phosphate of varying concentrations from 12.5% up to 20.25% with chert and clay. The beneficiation process is designed to separate the gangue minerals of calcite (calcium carbonate - CaCO3) and silica (SiO2) from the phosphate mineral. The Phosphates deposits from the Mine are mostly of lower grade at ~17%





Phosphorous and require processing and upgrading to a marketable concentration with P2O5 content of ≥30%.

The Beneficiation plant will process 13.5Mtpa and produce 5.3Mtpa of phosphate concentrate that will be delivered to the Phosphoric acid plant located within the same site as the Beneficiation plant. The Beneficiation plant will operate 24 hours per day for 350 days per year.

Figure 4-20 illustrates the overall beneficiation process which is described in more detail in section.





Figure 4-20: Block Flow Diagram – Beneficiation





Run of mine rock with a maximum size of 150mm is conveyed to the beneficiation plant and is screened and sorted to remove chert which is discharged to the tailings storage facility (TSF) described in Section 4.16.2. An optical sorter and X-ray transmission (XRT) sorter are employed to remove siliceous material, which is also discharged to the TSF. These sorting techniques contribute to improved water and energy efficiency in mining industries, by ensuring waste materials are removed, rather than proceeding through the process for treatment. Non chert material is discharged into the secondary crushing circuit (impact crushers) and the crushed product is re-cycled back over the pre-screen to deliver a uniform size to a blended ore stockpile which has a capacity of 180,000 metric tonnes or approximately 6 days storage.

Dust collector systems will extract dust, which is filtered through a dust collection filter, with the clean air being vented to atmosphere. Periodic pulse air is used to knock the dust particles off the dust collection filter. The dust particles fall into the dust collection silo through a rotary valve, which ensures a vacuum pressure is maintained within the dust extraction system. The dust collection silo will be periodically emptied by a vacuum truck. Additionally, process water is sprayed on the blended ore stockpile to control dust.

The blended ore is fed into blade mills with process water, to form a slurry, which is screened and ground to separate slimes. The purpose of the Blade Mill is not to break the ore down in size, but to break up the mud and clays and clean the rocks surface. A dust collector system is included here also. Hydrosizer units are used to achieve size classification by using up-flow water flow to remove finer smaller particles from the slurry. Water is drained from the sized material and de-watered sized ore tested to determine the grade of the sized material. If it meets the required grade it is milled/washed and pumped to the Phosphoric acid plant. If it fails to meet the required grade it is milled and sent to a flotation circuit.

Water from de-watering is discharged to the on-plot water treatment plant for subsequent return to the beneficiation process.

Oversize material undergoes further grinding, milling, crushing. If the sized material meets the required grade specification it will be pumped to the concentrate tank, if not it will be pumped to the de-slime cyclones from which underflow is directed to the floatation process, while overflow is thickened using flocculant before being dewatered.

The beneficiation plant uses open circuit reverse flotation whereby the gangue minerals (silica and carbonate) are floated and the phosphate mineral is depressed reporting out the bottom of the last cell. Flotation reagents (amine, sulphonated fatty acid and phosphoric acid) and process water are added before the slurry is fed to one of the six floatation trains.

Froth from the floatation circuit gravitates to the tailings thickener, and the concentrate flows out from the bottom of the last cell into a pump hopper.

The concentrate is pumped to thickening cyclones located above the belt filter plant. Thickening cyclone underflow gravitates onto the belt filter; the filter will operate in a three stage counter wash cycle using potable water to remove soluble chloride from the concentrate. Washed belt filter cake discharges onto a conveyor belt and discharges into a re-pulper tank where potable water is added to obtain the correct density to pump to the phosphoric acid plant. The final filtrate from the filtered concentrate is pumped to the water treatment plant.

Flotation tailings are pumped to the tailings thickener, flocculant is added to aid in settlement. Thickener underflow and slimes thickener underflow is dewatered. With filter cake being discharged into the tailings management facility and filtrate pumped back to the water treatment plant for reuse in the beneficiation process.

A tailings storage facility with an area of 5km2, (2km by 2.5km) is provided adjacent to the beneficiation plot for receipt of 5.8Mtpa of beneficiation tailings. Dewatered tailings with a minimum 80% solids by weight will be dry stacked in a truncated pyramid format and is anticipated to reach a height of 45-50m, over the course of the project life (see Section 4.16.2 for further details of the Tailings Storage Facility and its design).





All process water streams including drainage water are returned to an on plot process water treatment facility which will treat 950m3/hr. Flocculant is added to help settle out any solids; and 0.525Mtpa wastewater treatment sludge is discharged to the tailings storage facility adjacent to the plot. Froth water is pumped to the tailings de-watering for water recovery, while remaining water is pumped to a clarifier and then to process water tanks for return to the beneficiation plant for reuse.

The reverse osmosis (RO) plant within the beneficiation plot will produce water of potable quality to be used as rinse water to remove soluble chloride from the flotation plant concentrate. Additionally some process water is diverted through a RO plant for seal water usage in the slurry pumps around the Beneficiation plant. Brine from this RO plant will join up with brine from the first RO plant which treats a process water bleed stream in order to control the chloride levels in the circulating process water. Brine streams equalling 138m3/hr from both RO plants will be combined and discharged to the battery limit of the beneficiation facility.

Reagents used in the beneficiation plant include Phosphoric acid (Phosphate depressant), Amine Collector (silica collector), Sulphonated fatty acid (carbonate collector) and Flocculant. These will be delivered to central bulk storage facility located inside battery limits (ISBL). Storage, dosing and mixing tanks are provided for the required reagents. These are all located within a bunded area, which collects any spills / run off.

Most areas within the beneficiation plot will be set out for ease of maintenance of the large process equipment. Some areas will have a roof but will not be enclosed. The exception to this is the flotation circuit which will be located inside its own building complete with travelling gantry crane for maintenance. However, the beneficiation process includes dust collection systems and dust suppression spraying to minimise dust emissions.

Figure 4-21 illustrates the inputs and outputs of the beneficiation process.

Figure 4-21: Simplified Beneficiation Mass Balance

4.11.4 SULPHURIC ACID PLANT

The Sulphuric Acid Plant (SAP) is designed to produce a maximum yearly capacity of 5,445 metric kilotons of 100% Sulphuric Acid. The plant is split into three identical trains, each having a nominal capacity of 5,500tpd of 100% H2SO4. The principal steps involved in the process of producing Sulphuric Acid include burning sulphur in air to form sulphur dioxide, combining the sulphur dioxide with oxygen to form sulphur trioxide, and absorbing the sulphur trioxide into water to form sulphuric acid (refer to Figure 4-22).





Figure 4-22: Sulphuric Acid Plant Block Flow Diagram





The SAP is designed as a ‘Double Conversion – Double Absorption Contact Process’, using licensor proprietary catalyst. The reaction is highly exothermic and the heat generated is used to generate high pressure steam (65 bar, superheated), which is exported to the power plant. It is expected that there will be sufficient steam to supply the total power (electricity) requirement for the Umm Wu’al site.

The SAP is designed to be independent of the other plants at the Umm Wu'al facility site due to the high dependency of the power generation plant on receiving the bulk of its steam from the production of sulphuric acid

4.11.4.1 SULPHURIC ACID PROCESS DESCRIPTION

The SAP will produce sulphuric acid from molten sulphur. Molten sulphur is supplied to the site by train from the Berri Gas Plant and the future Wasit Gas Plant near Jubail. Molten sulphur is fed from the central storage area to three day tanks each with a 24 hour capacity of 1,012m3, one for each of the three production lines.

Liquid sulphur is combusted in burners with dry air from atmosphere to produce SO2. The air is dried by contact with 98.5 wt% H2SO4 in the drying tower. A demister is positioned in the top part of the Drying Tower; this helps to remove any acid mist captured in the air after contact with H2SO4. During normal operation, the dried air leaving the drying tower flows to the sulphur furnace.

The sulphur burners can burn either liquid sulphur or fuel oil/diesel. Fuel oil/diesel is used to start up the sulphur furnace. When the furnace reaches high temperature to allow for sulphur burning, the fuel oil is turned off and the liquid sulphur is pumped in. When the sulphur furnace is at operating conditions, the furnace temperature is hot enough to auto-ignite the sulphur. Sulphur reacts with the oxygen to produce SO2. This reaction is fast, complete and is highly exothermic. The excess heat of combustion can be effectively captured by producing high pressure steam

The reaction of sulphur dioxide with oxygen to produce sulphur trioxide is an equilibrium reaction which proceeds quickly in the presence of the vanadium oxide catalyst. The double contact process is used for this project. Sulphur dioxide is passed over four packed catalyst (converter) beds. The catalyst is a mixture of vanadium oxide and alkali sulphates which are promoters. Each bed can have a different catalyst composition to maximize the conversion reaction. To achieve the required point source emissions standards, a fifth converter bed, or tail gas scrubbing system will be applied.

An intermediate absorption Tower is utilized to absorb SO3 from the process gas after the third converter bed. The Final Absorption Tower is used to capture SO3 following the final converter bed pass. A network of heat exchangers (superheaters, economizers, and interchangers) is used to recover and exchange heat from the process gas between the Converter bed stages. This heat is used to produce high pressure steam which is sent to the Power Island and used to generate electrical energy via Steam Turbine Generators.

Due to the exothermic reactions involved in the SAP process, significant heat must be removed from the H2SO4 that circulates through the drying tower, intermediate Absorption Tower, and Final Absorption Tower. A closed loop cooling water system is used for cooling the acid. Product acid is cooled by a combination of closed loop and open loop cooling water.

The sulphuric acid generated by the SAP is stored at approximately 105°C within the SAP plot and in tanks with a capacity of 8,347m3, before being pumped to the project storage tanks in the storage area.

Sumps are also provided to collect any acid from Drying Tower, Stack, and spills from any equipment in acid service and in the boiler area, diesel/fuel oil area and liquid sulphur area. A liquid level will be maintained in the liquid sulphur sump to allow for quenching of any liquid sulphur. Following a spill or drainage, solid sulphur will be manually removed by plant personnel so that it does not enter the sump pump. The contents of the non-acid service sumps are sent to neutralization prior to the industrial wastewater plant.





Figure 4-23 illustrates the inputs and outputs of the SAP process.

Figure 4-23: Simplified SAP Mass Balance

4.11.5 PHOSPHORIC ACID PLANT

The Phosphoric Acid Plant (PAP) is designed to produce 1.5Mtpa of P2O5 as a base for merchant grade acid (MGA). The plant is split into three identical trains, each having a nominal capacity 1,615tpd P2O5 as MGA. The principal steps involved in producing Phosphoric Acid include grinding phosphate rock received from the beneficiation plant, reaction with sulphuric acid, filtration of the resultant slurry to separate 28% phosphoric acid from the gypsum by-product and clarification and concentration via evaporation of the phosphoric acid to produce 54% MGA.

The PAP is designed as a dihydrate process, using Jacobs’ proprietary technology; the process is illustrated in Figure 4-24 and described in more detail in Section 4.11.5.1.





Figure 4-24: Phosphoric Acid Plant Block Flow Diagram





4.11.5.1 PHOSPHORIC ACID PROCESS DESCRIPTION

Phosphate rock slurry and sulphuric acid (98.5% H2SO4) are pumped separately into the Jacobs Annular Reactor where they combine to form phosphoric acid and calcium sulphate dihydrate (CaSO4•2H2O) or gypsum. Kaolin is used to promote stable crystallisation in the reactor, and although the reaction is exothermic the temperature is controlled to promote formation of dehydrate gypsum crystals. Rock digestion and gypsum crystallization occur in the Reactor and the Cooler Seal Compartment with very high slurry recirculation and mixing. Reaction slurry from the Reactor is transferred to the Maturation Tank before being pumped to the Tilting Pan Filters. The final compartments of the Maturation Tank provide additional residence time for increased crystal growth.

The fumes released during the reaction stage from the Annular Reactor and Maturation Tank are vented to the Fume Scrubber.

In the filtration section, two Tilting Pan Filters separate phosphoric acid and gypsum. The two filters operate in parallel. The following process description applies to each individual filter.

The reactor slurry to the filter initially passes into feed boxes which distribute the slurry onto the filter pans which are rotating below. The gypsum cake is formed in the pans and the liquid in the pans passes through the cake, filter cloth, and a hose before entering the appropriate stationary vacuum compartment inside the central valve below the pans. After forming the initial cake in the filter pans, the gypsum solids are counter current washed four times on the filter to reduce the water soluble P2O5 in the solids to less than 1.0% P2O5. Filter product acid containing approximately 28% P2O5 is pumped to the 28% acid clarification and storage area. Dry gypsum cake (20% moisture content) at a rate of 1,350tph will be re-slurried and piped to the PSF described in Section 4.16.3.

The 28% P2O5 concentration acid is then clarified, with the sludge returned to the reactor and the overflow sent to the concentration unit.

The 28% P2O5 is cooled (in heat exchangers supplied by the cooling tower dedicated to the PAP) and clarified before being transferred to the concentration process. The acid sludge generated by the clarification is returned to the reactor.

The 28% P2O5 contains more than 55% free water therefore further concentration of the acid is accomplished in an evaporator, in which the primary mechanism is removal of water by boiling under vacuum. The evaporator system utilises four evaporators per train and has been designed to produce an acid concentration of 54% P2O5 that has less than 23% free water. The vapours leaving the evaporation stage contain FSA and are passed through an Entrainment Separator to two FSA Scrubbers and FSA Scrubber Separator.

The FSA recovered from the entrainment separator is collected and sent for neutralization with lime to produce CaF2, or fluorspar; a stable form of fluorine, before being pumped to a clarified. Water is recovered for use in lime slurry production and 120m3/hr of fluorspar is transferred to the gypsum conveyor for disposal at the PSF.

The 54% P2O5 concentration acid is then clarified and the sludge is returned to the 28% concentration acid clarifier and the overflow is sent to storage tanks.

Following evaporation to achieve 54% phosphoric acid, the acid is again clarified, with any sludge being diverted back to the 28% acid clarification stage, and the clarified 54% phosphoric acid directed to product storage tanks located outside the battery limit of this process.

Gaseous fluorides are generated in the Reaction, Filtration, and Concentration areas are vented through a plant-wide header system to the Fume Scrubber. To prevent deposition of silica, the fluoride vapour from the Reactor and Maturation Tank is washed with water sprays at three locations:

• with a single spray every 10 meters in the ventilation duct;

• with 5 sprays at the scrubber inlet plenum; and

• with multiple sprays upstream of the first scrubber packing stage.





After these initial sprays, the gases flow horizontally through a void spray section and then three packing stages and one demister stage in series. The first two packing stages are washed with recycled process water. The third stage is continuously washed with recycled process water from the Filter Scrubbers and the demister intermittently washed with fresh process water. The final demister stage eliminates droplet entrainment.

The fume scrubber operates at a slight vacuum, from about minus 150mm H2O (g) at the inlet to about minus 400mm H2O (g) at the outlet. The vacuum is provided by the Scrubber Exhaust Fan which discharges to the Stack. Spray water effluent from the scrubber is sealed and drains to the Process Water Sump and is pumped to the Fume Scrubber spray nozzles, thereby recirculating the water. Blowdown from the scrubber is directed to the secondary FSA seal tank.

Fumes from the scrubber are discharged via a 50m high fume scrubber stack at 60°C. The process is designed to minimise fluorine emissions, and achieved 5mg/Nm3 emission standard. It is anticipated that approximately 86,300kg/h or 78,804 Am3/h gases to be emitted from each of the three Exhaust Stacks. Three sample points are included within the design to monitor emissions. Sampling will be continuous, or as per PME instruction.

Figure 4-25 illustrates the inputs and outputs from the process.

Figure 4-25: Simplified PAP Mass Balance

4.11.6 PURIFIED PHOSPHORIC ACID PLANT

The Purified Phosphoric Acid (PPA) Plant will receive a feed of MGA from the Phosphoric Acid Plant. The PPA plant is designed to purify 100,000tpy (P2O5 basis) of Phosphoric Acid. The unit will be split into two trains each designed for 50% of the total capacity. The plant provides 50% (P2O5 basis) of the purified phosphoric acid as feedstock to the STPP unit to produce 88,000tpy of STPP. The remaining 50% of phosphoric acid (P2O5 basis) will be concentrated to meet Food Grade Phosphoric Acid requirements.

The PAP treats supplied Phosphoric Acid to remove metals, fluorine and organic contaminants to meet food grade specification, and production of phosphoric acid concentrated at 65% P2O5 (89.7% H3PO4). Figure 4-26 illustrates the process and Section 4.11.6.1 describes the process further.





Figure 4-26: Purified Phosphoric Acid Block Flow Diagram





4.11.6.1 PURIFIED PHOSPHORIC ACID PROCESS DESCRIPTION

The pre-treatment of the Merchant Grade Phosphoric Acid (MGA) received from the Phosphoric Acid Plant (PAP), involves mixing the MGA in a series of four stirred reactors with phosphate rock slurry to reduce the concentration of sulphates, kaolin and caustic soda to reduce the fluorine concentrations and sodium sulphide to remove the heavy metals. Each reaction results in the target contaminant precipitating out of the acid which is subsequently filtered to remove these and achieve concentration of the acid to 53% P2O5; the correct content for the solvent extraction process.

The reactions also result in the formation of carbon dioxide, and small quantities of hydrogen fluoride (HF), hydrogen sulphide (H2S), silicon fluoride (SiF) and silicon tetrafluoride (SiF4).

The vent lines from the reactors are connected to two scrubbing systems. The first scrubber prevents the emission of fluorine from the reactors to atmosphere through aqueous scrubbing on a recirculation loop with a make-up of process water. Fluorine concentrations are to achieve level of 3ppm (= 2.3mg/m3). The second scrubber uses caustic solution (NaOH) to remove traces of fluorine and H2S gases. The H2S emissions are monitored to assure a maximum level of 3ppm (= 4.1mg/m3)

A small amount of sodium hydroxide (NaOH) is added to precipitate the fluorosilic acid (H2SiF6) generated as sodium fluorosilicate (Na2SiF6). The gypsum slurry also generated by this pre-treatment process contains 47% P2O5 and 5-6% solids. The gypsum filter cake with typically 40% moisture is conveyed to the PSF.

The Solvent Extraction process is principle purification step in the process. Two trains each consisting of three Bateman Pulsed Columns perform the main steps. In the first column a barren Methyl Isobutyl Ketone (MIBK) solvent and the pre-treated acid are contacted, the raffinate and a dirty laden solvent are produced. Prior to entering the second column the dirty laden solvent is reacted with barium carbonate to reduce the sulphate concentrations present in the solvent stream. The barium sulphate produced precipitates and is settled out as a sludge from the solvent. In the second column the dirty laden solvent and a recycle of purified acid are contacted, a clean laden solvent and a dirty acid are produced. The dirty acid is fed to the first column with the conditioned acid. Finally in the third column deionised water and the clean laden solvent are contacted to produce the purified acid and barren solvent. All three aqueous product streams, the raffinate, the dirty recycled acid and the purified acid are stripped of any solvent that they contain. During the stripping all three streams are concentrated to the required 43% P2O5 content.

All vents from all vessels are connected to the barium system scrubber which is designed to remove MIBK prior to thermal oxidation to eliminate solvent emissions prior to vent of emissions to atmosphere.

Post Treatment consists of steps to achieve the final fluorine and colour specification, two parallel post treatment trains are provided. Firstly organic carbon is removed by passing the purified acid through an absorber bed of granular activated carbon. Secondly the acid is concentrated prior to defluorination by direct addition of steam to achieve <10ppm fluorine. Finally the product acid is bleached with hydrogen peroxide to ensure the final product is stable and will not develop a colour over time. The quality of the resultant final PPA food grade product (65% P2O5) is verified by laboratory and sent to product storage or the STPP plant.

The spent NaOH streams are diverted to the waste treatment system. The activated carbon bed, can only be regenerated a specific number of times before being exhausted and requiring disposal off site in a licensed waste facility.

The acid containing vents from various units are scrubbed in a Vent Scrubber. Demineralised water and Caustic are used as scrubbing solution. Some effluent gases are also treated in a thermal oxidizer prior to release to atmosphere.

Figure 4-27 illustrates the inputs and outputs of the PPA process.





Figure 4-27: Simplified PPA Mass Balance

4.11.7 SODIUM TRIPOLYPHOSPHATE PLANT

The Sodium TriPolyPhosphate (STPP) Plant will produce 88,000tpy of Food and Technical Grade Sodium TriPolyPhosphate, from the 50,000tpy of P2O5 supplied by the PPA.

The Sodium TriPolyPhosphate Plant will consist of two sections. The wet section involves neutralisation of the purified phosphoric acid with a sodium source, and associated scrubbing of exhaust gases, and concentration of the salt solution through evaporation. The dry section comprises drying and calcination of the salt solution to produce the anhydrous STPP, scrubbing of the exhaust gases with the feed to the calciner to recover any entrained product, cooling and hydrating, crushing and sieving the product to the required size range, milling of oversized product its combination with the under sized product and recycle to the calciner and bagging of the final product. Figure 4-28 illustrates the process.





Figure 4-28: STPP Block Flow Diagram





4.11.7.1 STPP PROCESS DESCRIPTION

Fifty per cent of the purified phosphoric acid (PPA) is received from outside battery limits (OSBL) and stored in the PPA Feed Tank immediately prior to use. The feed tank is sized to hold a maximum amount equal to the quantity consumed by the STPP Plant during a normal 24-hour period.

PPA, a combination of soda ash and caustic soda are introduced into a series of four reactor tanks in the proper stoichiometric ratio and mixed using agitator. The solutions are mixed in stoichiometrically correct proportions to provide a 5:3 molar Sodium to Phosphorus ratio in the feed ortho solution to produce PentaSodium TriPolyPhosphate, also known STPP.

This “Salts Solution” is forwarded to the spray dryer, where the solution is pumped into the spray dryer via the spraying nozzles. The spray dryer is equipped with a number of hammering vibrators to prevent accumulation of the material. The spray dryer mixed powder is fed by a series of screw feeders to the rotary calciner, where it is heated indirectly by Natural Gas to temperatures of approximately 600°C. The calciner product is conveyed to the rotary cooler where cooling water cools the product to 40°C.

The exhaust gases at the bottom of the spray dryer are sucked via two cyclones to the wet scrubber before release to atmosphere. Exhaust gases from the calciner are mixed with the spray dryer inlet gases for energy efficiency.

The screening process segregates the solid STPP product into separate streams based solely on the size of the solid particles (lump, granule, powder, dust, etc.). The product stream is fed to a rotating screen. The coarse faction is milled and the product conveyed to the powder storage silo. Some coarse factions are recovered and conveyed to the granular silo. Silos direct the product via screw conveyors to the bagging machine, where product is bagged into one tonne big bags. Filled bags are transported to storage/warehousing/shipping areas.

The loading units are equipped with ducts which capture fine solid “dust” particles which would otherwise be lost, representing lost product and a source of solid emissions. These streams are routed to a Dust Collector Package which compacts the particles together and conveyed back to the inlet of the Calciner.

Figure 4-29 illustrates the inputs and outputs of the STPP process.

Figure 4-29: Simplified STPP Mass Balance

4.11.8 MONO/DICALCIUM PHOSPHATE PLANT

The Mono/Dicalcium Phosphate (MCP/DCP) plant is designed to produce either Monocalcium Phosphate or Dicalcium Phosphate which are predominantly used for animal forage / dietary supplementation. The plant is designed to produce Dicalcium Phosphate at a rate of 0.25Mtpa (Dry DCP basis).

MCP/DCP production comprises two identical trains. Each train is able to produce either MCP or DCP. MCP will have a typical analysis of minimum phosphorus (as P) of 21% and minimum





calcium (as Ca) of 17%. DCP will have a typical analysis of minimum phosphorus (as P) of 18% and minimum calcium (as Ca) of 24%.

Figure 4-30 illustrates the process, which is described in more detail in Section 4.11.8.1.

Figure 4-30: MCP/DCP Block Flow Diagram

4.11.8.1 MCP/DCP PROCESS DESCRIPTION

Quarried limestone rock delivered to site by truck is stored before being crushed and ground for use in the MCP/DCP production process. Ground limestone is mixed with blowdown (process water from the scrubbing package) to produce limestone slurry which is pumped to the MCP/DCP pre-mix reactor. The limestone crushing and grinding plant will be operated between eight hours and sixteen hours a day, depending on whether MCP, DCP or a combination of both are produced.

MGA produced in the Phosphoric Acid Plant has too high fluorine and sulphuric acid content for the typical applications of MCP/DCP therefore, the MGA is defluorinated. Diatomaceous earth (DE) (SiO2) is mixed with a side stream of recirculated acid ensuring that the DE is properly mixed and wetted before entering the defluorination tank. This prevents DE creating dust and clumping inside the defluorination tank. The defluorination reaction produces silicon tetrafluoride (SiF4) vapour in solution. This vapour is stripped from the acid and the vapour swept from the tank by the defluorination exhaust gas scrubbing system which draws a large volume of atmospheric air through vents in the tank roof, through the tank vapour space and into the scrubber. A two-stage venturi scrubber which uses process water removes silicon tetrafluoride from the vent gas. The defluorination scrubber waste (bleed) contains FSA (H2SiF6) which is neutralised by dosing with calcium hydroxide to produces calcium fluorosilicate and calcium silicate solids. The neutralised FSA sludge is transferred by truck to the PSF, while the neutralised liquid is returned for reuse in the process.

Defluorination recirculation continues for a minimum of four hours after which limestone slurry from the MCP/DCP limestone system is added to complete the desulphurisation. This reaction results in the generation of phosphogypsum / defluorinated phosphoric acid slurry.





Defluorinated Phosphoric Acid is stored in two tanks with a total storage capacity of 24h acid consumption to provide surge capacity between the batch defluorination process and the continuous MCP/DCP production process in a bunded area.

Defluorinated acid is heated and is fed into MCP/DCP pre-mix reactor with 64 wt% limestone slurry to create a thick slurry/paste, before entering the MCP/DCP reactor. In the MCP/DCP Reactor, a proprietary pin/pug mill, the defluorinated phosphoric acid / limestone mixture is combined with a recycle stream of MCP/DCP to form a relatively dry granular DCP or MCP product of the required size range, and CO2 and water by-products. The reactor discharges onto a conveyor over which air swept to remove acid mist, fumes and dust from the hot reactor products. The air is treated in; a single stage wet venturi scrubber which uses process water to collect dust and mist. This scrubbing system captures any dust and acid mist in the air stream to allow the air to be vented. The scrubber blow-down liquor is then used to make up limestone slurry with process water used as makeup.

The MCP/DCP product is dried using a steam tube rotary dryer, which evaporates most of the free water. As the product dries out and is partially broken up by the tumbling action of the Dryer, significant quantities of dust are generated. Dust is removed from the Dryer through dryer cyclone and any fine dust not removed by the cyclone is then removed by the exhaust gas dust collector package; a baghouse filter which removes dust from the exhaust gas to a level sufficient to meet environmental discharge criteria.

The product is screened by mass and size. The conveyors, screens, mills and other equipment handling dry MCP/DCP are completely enclosed to prevent dust escaping to the environment. Dust from each of these equipment items is extracted through ducts connected to the MCP/DCP dust collector package and collected dust solids are returned to the process.

The final product is bagged using a semi-automated bagging machine into 1m3 bulk bags for, export by rail. Dust generated by the product bagging machine and product truck loading chute is extracted and collected by the MCP/DCP product bagging dust collector package and returned to the process.

4.12 PRODUCT AND RAW MATERIALS STORAGE AND HANDLING FACILITIES

The principal method for delivery of raw materials and export of product to/from the site is via rail. The project includes provision for rail sidings to enable loading / unloading of materials, via 12 loading arms. Some materials of smaller quantity will be delivered by road.

4.12.1 PRODUCT AND RAW MATERIALS STORAGE

The principal raw material for the process is the phosphate ore. A stockpile equivalent to one month of normal production, some 1Mt of ore, is provided adjacent to the POC to allow for disruptions to normal mining operations. This stockpile is to be approximately 320m by 250m and 10m high.

Raw materials delivered to the site are stored, either within the OSBL storage area, or delivered directly to storage facilities within the relevant process unit plot. Table 4-7 summarises the import and storage of raw materials at the project site.





Table 4-7: Raw Materials Storage

Raw Material Storage Area

Quantity (tpy)

Delivered By

Tank / Silo Capacity

No. of Tanks / Silo

Total Storage Capacity

Central Storage

Molten Sulphur

OBSL 1,784,376 Rail 16,810 m3 3 50,430 m3

Limestone OBSL 161,000 Road n/a n/a

Caustic Soda OBSL 192,000 Road 4,887 m3 2 9,774 m3

Storage within Process Plots

Molten Sulphur

SAP Rail 1012 m3 3 3,036 m3

Sulphuric Acid SAP Generated onsite

8,347 m3 2 16,694 m3

Fatty Acid (collector)

Beneficiation 23,760 Rail System fill only

Amine (collector)

Beneficiation 19,008 Rail 1,169 m3 2 2,338 m3

Flocculant Beneficiation 243 Road System fill only

Defoamer PAP Road 9.8 m3 3 30 m3

Kaolin PAP 37,476 Rail 252 m3 1 252 m3

Lime PAP 192,000 2036 m3 1 2036 m3

Kaolin/ clay PPA 13,200 Road 60t 1 60t

Barium Carbonate

PPA 825 Road 10t 1 10t

Methyl Isobutyl Ketone (solvent)

PPA 600 Road 80 m3 1 80 m3

Sodium Hydroxide

PPA/STPP Road 300 m3 2 600 m3

Sodium Sulphide

PPA 2000 Road n/a n/a 14 big bag

Hydrogen Peroxide

PPA 810 Road 50 m3 1 50 m3

Hexafluorosilic acid

PPA 440 Road 20 m3 1 20 m3

Soda Ash STPP Road/Rail 2,642 m3 2 5,284 m3

Caustic Soda STPP & MCP/DCP

97,500 Road 215.7 m3 2 431.4 m3





Raw Material Storage Area

Quantity (tpy)

Delivered By

Tank / Silo Capacity

No. of Tanks / Silo

Total Storage Capacity

Lime MCP/DCP 540 Road 380 m3 1 380 m3

Diatomaceous Earth

MCP/DCP 1,000 Road 30 m3 1 30 m3

The following products are stored on site for export by rail.

Table 4-8: Product Stored for Export

Raw Material

Quantity (tpy)

Delivered to OSBL Storage

Tank Capacity

(m3)

No. of Tanks

Total Storage

Capacity (m 3)

Exported To

Sulphuric Acid

5,528,952 Pipe 8,347 10 83,470 Ras Al Khair

MGA and Raffinate

132,557 Pipe 5,616 8 44,928 Ras Al Khair

MGA 2,327,207 Pipe 5,417 3 16,251 Ras Al Khair

PPA 81,900 Pipe 1,907 3 5,721 Ras Al Khair

STPP 89,400 Bagged n/a n/a Jubail / Dammam

MCP/DCP 250,000 Bagged n/a n/a Jubail / Dammam

4.12.2 MATERIALS HANDLING FACILITIES AND TRANSPORT

The movement of crushed ore and solid waste product around and between the mine and the process plant utilise a number of conveyor belt systems:

• Ore Conveying System from the Mine to the Beneficiation Plant – 2,500tph

• Gypsum Transfer Conveyor and Stacker – 1,7500tph

• Reject Ore Conveyor – 300tph

The crushed phosphate ore is discharged from the crusher to a transfer tower located approximately 45m downstream of the crusher, which directs the ore via chutes to a new conveyor for transport to a second transfer tower. The ore is discharged to the Overland Conveyor system, where it is transported, via a trough shaped belt conveyor system, the 14km to the beneficiation plant. Figure 4-31 provides an example of such an overland conveyor system.





Figure 4-31: Example Overland Conveyor System

The Overland Conveyor is covered to minimize dust emissions, and includes dust extraction systems for the removal of dust generated. The dust collected in these systems is disposed of to the Tailings Storage Facility (refer to Section 4.16.2 for further details of this waste storage area).

In the event of a failure of the Overland Conveyor the crushed ore will be re-routed through chutes and a conveyor to a Truck Loading Station located approximately 50m from the crushing plant. This facility will enable the ore to be transferred to the Beneficiation Plant by truck along the main access road between the Mine and the Industrial Complex, which runs parallel and to the west of the conveyor route.

On arrival at the beneficiation plant the ore greater than 9mm in size is passed through an optical sorter to remove siliceous material. The silaceous material removed by the optical ore sorter is rejected and conveyed to a transfer tower and from there via chutes to a Mobile Telescopic Conveyor running west to east alone the Tailings Storage Facility.

Phosphogypsum generated at the PAP, is transferred to the PFS via a slurry pipe system which conveys the phosphogypsum over a distance of up to 1,600m for disposal at the lined PSF (refer to Section 4.16.3 for further details of this waste storage area).

In addition to the above, gypsum slurry generated by the PPA plant is pumped to the PFS, while gypsum cake and neutralised fluorosilic acid generated by the MCP/DCP plant are trucked to the stacks for disposal.

In addition to the above specific materials handling systems, the Project also includes a materials handling facility for materials arriving at and being exported from the site.

The materials handling facility will unload a 55 tank wagon train delivering 5,407tpd (330 days per year) of molten sulphur from Saudi Aramco facilities at Berri and Wasit in the Eastern Region daily. Twelve dedicated loading arms are provided to enable each train to be loaded / unloaded within 8 hours. Molten sulphur is unloaded via heated pipework, via the sulphur pits, to three dedicated heated sulphur tanks. Provision is also made for the unloading of other raw materials that may be delivered to site by rail in the future.

The loading for export will consist of one 68 tank wagon train per day to transport 6,709tpd of MGA, and raffinate, and one 20 wagon train, which will consist of 5 tank wagons for MGA (460tpd), three tank wagons for PPA (237tpd), 12 tank wagons for Sulphuric Acid (1,010tpd) and a flatbed train consisting of 9 box car wagons for MCP/DCP (758tpd) and 4 box car wagons for STPP (271tpd).





Specific product handling systems are provided for the bagging of dry product (MCP/DCP and STPP). These systems are to provide automatic bagging of material, within enclosed environments, with associated dust collection systems to minimise loss of product, and potential dust emissions to the environment.

In addition of material handling by rail, a number of raw materials will be delivered to site by road in trucks. These include limestone / lime (from a local quarry), caustic soda / soda ash (from Jubail) and kaolin (from Ha’il) and are anticipated to require some 74 trucks per day. Other materials of smaller quantities such as flocculant, vanadium catalyst, MIBK solvent, barium carbonate, activated carbon, caustic soda, hydrogen peroxide, calcium hydroxide, and diatomaceous earth will also be delivered by truck.

4.13 POWER

The facility will be connected to the national grid, supplied by Saudi Electric Company, however it is anticipated that the site will be self-supporting through the provision of Steam Turbine Generators in combination with an auxiliary boiler and emergency diesel generator.

4.13.1 STEAM TURBINE GENERATORS

The Power Generation Plant located at Umm Wu’al, industrial complex will receive high pressure steam from the SAP and will in normal circumstances generate power and low pressure steam using two independent Steam Turbine Generators. The estimated maximum Gross Electrical Output from each turbine train (during 110% SAP operation) is 92.6MWe. During normal operating case this reduces to 78.2MWe Gross

The power generating facility deliver 802,000kg/hr of low pressure steam; 100% site LP steam demanded by consumers during all operating conditions, and 100% of all electricity demand. Supplementary electricity and high pressure steam demand will be supplied by the auxiliary boiler.

Table 4-9: Umm Wu’al Power Demands

User Electrical Requirement

(kVA)

LP Steam Requirement

(kg/hr)

Beneficiation (incl Mine & Conveyors) 35,874 -

SAP 59,152 105,000

PAP 55,342 600,000

PPA, STPP, MCP/DCP 10,642 74,000

Utilities, Storage, Administration 6,000

Power Plant 8,000

Water Intake 4,800

TOTAL 179,810 779,000

4.13.2 AUXILIARY BOILER

A 20MWe auxiliary boiler designed to run continuously at 20% capacity under normal operation is provided to supply initial start up steam for the SAP (1 train) and also to provide supplementary high pressure (HP) steam as required. It will also be used to provide steam requirements for a single PAP train when the Sulphuric Acid Plants are not working. The boiler is specified to be capable of operating with both Arabian Light Crude (ALC) and Natural Gas as the fuel. The auxiliary boiler is supplied with a flue gas desulphurisation unit, to ensure compliance with the required point source emissions limits and has a stack height of 40m.





4.13.3 EMERGENCY DIESEL GENERATOR

Emergency generation consisting of two 2MWe (approx) net diesel driven generators are provided for back-up and black-start conditions site. The Emergency Diesel Generators (EDG) will provide the required consumable power required by the auxiliary boiler during start-up. The EDG is supplied by fuel oil from local 48 hour capacity storage tank and forwarding pumps arrangement. The EDG will be located inside a building, and will be complete with combustion air and flue gas ducts and any coolers required

4.13.4 FUELS

The site has no internal production of fuel so supply will be met by the provision of unloading facilities from road truck to storage, and transfer pumps to the users. Four fuels will be available for use by the Project; ALC, Diesel, Gasoline and Natural Gas.

Fuel oil is delivered to site by rail or road tanker and offloaded using a dedicated offloading pump for storage. Fuel oil is stored in a bunded tank with 3,308m3 capacity. Two days storage capacity is provided, equating to a nominal 190m3 at continuous use of 4m3/h using a dedicated transfer pump (with spare). Diesel is supplied to the auxiliary boiler to provide steam at plant start-up, and to the SAP preheater for start-up.

Diesel is also supplied to the site by tanker and stored in two diesel storage tanks each with 1,445m3 capacity. Diesel is provided to supply the emergency diesel generator diesel storage tank and is also distributed to the MMA diesel storage tank for vehicle refuelling and as the supply for the use in blasting. A gasoline storage tank with a capacity of 271m3 is also provided for vehicle refuelling.

All fuel storage tanks are bunded, with oil / water separators. Any spills / contaminated waters are to be tankered off for disposal.

The site is also to be connected to a Natural Gas supply provided by Saudi Aramco. There will be no storage of Natural Gas on site; rather the fuel will be piped directly to the users namely the MCP/DCP dryer and STPP dryer and calciner. The auxiliary boiler is to have the capability to utilise this fuel also.

4.14 WATER

Raw water abstracted from the Tawil aquifer will be used to supply the water needs of the Project. Water will be abstracted from wellfield to the east of the Project site, and pumped to the Project for treatment and use. The total water demand consists of 2,204m3/hr sourced from the wellfields, 164m3/hr of assumed water in the ore, and 0.45m3/hr recovered from the air supplying the SAP. Losses from the daily water consumption include the moisture content of waste effluent and solid streams, evaporation from cooling towers and phosphogypsum storage facilities and the reject streams from the water treatment plant. A proportion of the water consumed is also incorporated into various products for export from the site. Figure 4-32 provides a schematic of the water balance for the Project, and illustrates the extent to which the Project maximises water recycling and reuse.

In recognition of the scarcity of water in this region, and the low recharge of the aquifer, waste water volumes from all treatment process units have been minimized and re-used wherever possible to reduce the amount of water abstracted from the wells. Furthermore, the brine generated by the by the RO is re-used as the medium within the brine open cooling water circuit, for slaking limestone in the FSA neutralization plant within PAP and as a dust suppressant at the mine. Decant water from the phosphogypsum storage facility is returned to the process for use in the slurrying of the phosphgypsum for transport. These approaches reduce the quantity of wastewater for disposal, and minimise the demand for raw water for these activities.





Figure 4-32: Project Water Balance





4.14.1 WELLFIELDS

The wellfields are located 60km to the east of the Project site, as identified in. The wellfields location has been determined following extensive study and modelling by SRK and illustrated in Figure 4-33 below.

Figure 4-33: Wellfield Location [Source: SRK 2013d]

The wellfields will deliver the required 18Mm3/y of raw water annually over a 29 year period, and consist of twenty boreholes, plus 4 standby wells configured in an inverted L shape with boreholes spaced 1km apart as indicated in Figure 4-33. Raw water is abstracted by pumps and transferred to four groundwater storage tanks each with a capacity of 15,000m3. Figure 4-34 provides a schematic to illustrate the wellfield design.





Figure 4-34: Wellfields Schematic

Twelve observation wells, one per two supply wells are anticipated to be required to monitor the performance of the well field over time.

The wellfields are accessed by a service road along the service corridor to and along the wellfield.

Raw water is pumped to the water treatment facilities within the Processing Complex, to provide process water, including cooling water, demineralised water, and potable water. Some raw water is pumped directly to the beneficiation plant for use in the floatation process.

The basis of the water demands is provided in Table 4-10.

Table 4-10: Site water requirements

Unit Process Water

m3/h

Potable Water

m3/h

Demineralised Water

m3/h

Cooling Water

Raw Water

Beneficiation - 0.3 - 660

PAP 855 0.3 -

SAP 45 0.3 136 1607

MCP/ DCP 19 0.3

PPA / STPP 50 0.3/0.3 60 6157/163

O&U area 123(1) 0.3 26 904 (9) 1562

O&U area 276(5)

Power Island 0.3

Mine 6 25

Ammonium Nitrate Storage 0.1

Administration Area 4.6

Operation Area 3.0

Site Main Entrance 0.3

Total 1542(7) 16.4 (3) 222 2247

Design 1689(6) 50.0 (2) 265(4) 2486(8) (1)Water makes up supply to Open Loop Cooling system (2)Potable water production is based on total demand + 34 m3/h for Fire System filling and re-filling after one event. (3)Potable water distribution considers the total continuous demand + additional 2 safety showers and 2 eyes wash stations operating simultaneously in one of the areas (intermittent: 10.6 m3/h). (4)Demineralised Water design flow includes a 20% margin. (5)Process Water to 2nd Pass RO Capacity for demineralized water production. (6)1st Pass RO design capacity including users demand + waste and wash water (7)Process Water demand including 2nd Pass RO. (8)Includes 10% margin to cover users peak flows. (9)Return LP Condensate cooling.

4.14.2 PROCESS WATER

Process water will be produced by the treatment of raw water by acidification and decarbonisation, followed by pre-treatment and reverse osmosis. First pass RO permeate is to be utilised as Process Water.





Pre-treatment for RO will include one or two stages of filtration. Sand filtration will be required for removal of soluble iron and manganese after pH elevation and oxidation using sodium hypochlorite.

First pass RO permeate is believed to be of sufficient quality for the majority of Process Water users.

The RO will generate 677m3/hr of brine; 340m3/hr will be directed to one of the cooling towers as make up. Some 87m3/hr of brine will be tankered to the MMA for use as dust suppressant on the haul roads within the mine, while the remainder, some 250m3/hr for which there is no further use will be directed to the PSF contact water system for evaporation.

4.14.3 COOLING WATER

Cooling Water will be derived from process water to supply site cooling towers. Cooling water systems will be treated to prevent scale, corrosion, and microbial growth by chemical dosing regimes as decided by the nominated cooling treatment chemical supplier. Any suspended solids present within the recalculating Cooling Water will be removed by side-stream filtration.

Two central cooling towers packages are located north of the PAP and east of the SAP units, and downwind of the prevailing wind direction, to minimise drift across the site (refer to Figure 4-4).

The open cooling water circuit receives hot cooling water return from the SAP, PAP, PPA and STPP plants. This cooling tower package will comprise of Cooling Towers, Induced Draft type fans, distribution pipework and cooling water sump.

Fresh first pass RO water will be provided to make up for the losses from the Cooling Tower. Cooling Tower losses comprise of losses due to evaporation and losses due to purge. Cooling water from this system is supplied to the SAP (3 lines, for product acid cooling), PPA, STPP, PAP and side stream filtration.

Additionally a brine open cooling water circuit is included within the design. This receives hot brine return from the intermediate heat exchanger. Brine from different heat exchangers is combined and routed to the top of a vendor supplied cooling tower package comprising Cooling Towers, Induced Draft type fans, distribution pipework and cooling water sump. Cooling Tower losses comprise of losses due to evaporation and losses due to purge. First pass RO reject will be provided to make up for these losses.

Cooling water from this system is distributed to brine/closed loop cooling water heat exchangers for each PAP train, utility services and side stream filtration, located adjacent to the brine cooling tower.

The cooling water sumps are sized to accommodate approximately 15 minutes of the total RO water / brine recirculation capacity. Any overfilling of the sumps in these systems, caused by heavy rain will discharge via an overflow to Clean Storm Water Collection.

In addition to the open loop systems, there are four closed cooling water circuit, one for the Utility system and three for PAP plant (one circuit per each train). Each circuit consists of a storage Tank, pumps and a heat exchangers. Each closed loop cooling water system receives hot cooling water return from Power Generation Plant, Steam Condensate system, Instrument Air system and MCP/DCP plant. Cooled Brine from the Brine open loop cooling water is utilised to remove the heat from returned hot cooling water.

This configuration has been determined as offering the lowest water use, best brine re-use and meets the process unit requirements in terms of water temperature and chloride contamination mitigation. Additionally this configuration provides lower temperature water to SAP (and others) which has positive impacts on the sizing of heat exchangers and other equipment with associated financial benefits.

The cooling water systems are shown in Figure 4-35.





Figure 4-35: Cooling Water Systems





4.14.4 RAW WATER TREATMENT

The water treatment processes adopted for the Project involves:

• Decarbonation;

• Pre-treatment for Reverse Osmosis;

• Two pass Reverse Osmosis;

• Remineralisation for potable water; and

• Ion exchange polishing for demineralised water

The raw water received from the aquifer is decarbonated to reduce the concentration of calcium carbonate that may otherwise precipitate in the subsequent RO units and negatively impact their recovery rate. The raw water is dosed with sulphuric acid and then fed into the top of one of the three packed towers provided at atmospheric pressure while air is forced up from the bottom of the tower to strip the CO2. The air becomes saturated with CO2 and is removed at the top of the tower.

Decarbonated water is fed to the RO pre-treatment process; this comprises of pressure sand filters and UF membrane filtration to produce water of sufficient quality for supply to the RO unit.

The UF filtered water is supplied to the two pass RO system. First pass RO water is drawn off between the two RO passes and is supplied to the Industrial Complex as process water. Some first pass RO water is also supplied to the Potable water system. To meet the drinking water requirements the potable water will be post treated with CO2 and Calcite filters to remineralise the water.

The remaining first pass RO water is supplied to the second pass RO unit for further purification, second pass permeate is supplied to the PPA process and to the deionisation unit. Second pass reject is recycled to the supply to the first pass RO unit.

The final water treatment process is the Demineralisation process. Second pass RO permeate is further treated using a mixed bed ion exchange system to polish the treated water for use within the PPA, SAP and for Boiler Feed Water make up.

The water treatment process is illustrated in Figure 4-36.

Figure 4-36: Raw Water Treatment Block Flow Diagram

4.15 WASTEWATER

4.15.1 INDUSTRIAL WASTEWATER

Within the Industrial Complex, discharge waste effluent expected to be small and intermittent, in nature from process upsets, spills and wash-downs from tanks and hard standings.





The following is typical of the expected wastewater streams and composition:

• Wastewater by-products of the production of phosphoric acid are descalants and gas scrubbers wash-down water which may contain FSA.

• Wastewater discharges from the purification of the fertilizer grade to produce animal feed via solvent extraction process would include arsenic and fluorine by-products;

• Discharges from the STPP production plant will contain some STPP (but which is not considered a health risk);

• Wash-down water may contain traces of soda ash (non-hazardous), fluoride impurities, and solvent;

• General Contaminants of concern include micropollutants such as poly-aromatic hydrocarbons (PAH) (e.g. from diesel oil, fossil fuel burning) and heavy metals arsenic, cadmium, mercury, chromium, cobalt and copper.

It is not the intention to treat the industrial wastewater discharges and effluents generated at the Industrial Complex to a standard that makes them suitable for release to the environment or to a quality that makes them available for recovery to the water treatment plant. The purpose of the IWTP is to “condition” the discharges arising from Umm Wu’al into a form that can be safely discharged to the contact water system of the PSF for evaporation. To this end, the effluents will be neutralized, depleted of fats, oils and greases and polished to remove suspended solids. The wastewater will not be chemically or biologically oxidized to remove Chemical Oxygen Demand since the discharge will not find its way to a water course. Nor will the effluent be disinfected as there is no intention to use it for irrigation. The IWTP will treat up to 50m3/hr peak flow, with a nominal 600m3/day average daily design flow (25m3/hr).

Dilution and homogenization of the various wastewater streams will be take place in a covered Reception / Equalisation Tank. This tank will be mixed / aerated to maintain solids in suspension to prevent sludge accumulations and odours. Upon reaching a certain level a float switch will initiate automatic start-up of the Treatment Plant. The wastewater will be screened for large objects and fibrous materials before passing through a lamella separator for suspended solids removal. The effluent is then pumped through to a dissolved air flotation (DAF) package where coagulant, flocculants and caustic are injected via a static mixer and free and emulsified oils are separated from the main flow and skimmed from the surface to be treated with the sludge lines. Flow from the DAF will then gravitate to the final effluent pump station via a tertiary drum filter for fine suspended solids removal. Solids will be backwashed to the balancing tank. Sludge from the process is thickened and oil is recovered in a 5m3 oil storage tank and the subnatant liquors returning by gravity to the balancing tank. Thickened sludge is pumped to a dewatering centrifuge. Polymer is injected into the sludge to enable dewaterability and promote cake formation. The concentrate liquors gravitate from the centrifuge to the balancing tank whilst the dewatered cake at approximately 27% is discharged to a hopper and conveyor where it is transferred to a skip for offsite disposal.

A neutralisation plant for managing acidic spills may be located adjacent to the IWTP.

Waste oil and engine coolant generated at the MMA will be collected and held in separate storage tanks before being tankered offsite by a specialist contractor for processing or safe disposal. Waste oil arising from the light and heavy vehicle wash-bays will be retained in waste oil storage drums and also transported off site for reprocessing or disposal.

4.15.2 SANITARY WASTEWATER

Domestic wastewater shall be treated on site with the resultant treated sanitary wastewater effluent (TSE) used for irrigation. The sanitary wastewater treatment plant (SWTP) shall receive all the sanitary effluent discharges from the wellfields, mine and Industrial Complex by a combination of gravity sewers, pressurized sewers and tankered waste imports.

Sanitary wastewater generated at the MMA is directed to septic tanks, with overflow to a soakaway, while the mine itself, watch towers and check point, the Ammonium Nitrate Facility (ANF) and wellfield booster stations are served by septic tanks with no overflow outlet, otherwise known as closed cesspits. Each of these septic tanks are collected by tanker and





transported to the SWTP for treatment. The buildings located within the administration and process areas will have a local sump which will collect all the sanitary drainage from this area and pump this to the SWTP. Sanitary wastewater from individual process units is directed to dedicated closed septic tanks at each unit and the contents are tankered to the SWTP.

Sanitary wastewater is macerated passed through an automatically raked screen. The raw influent contains rags and other suspended non-biodegradable material; the screenings are discharged to a bin or skip for disposal off site. Primary and humus solids are co-settled in the primary settlement tank then passed to the biological treatment stage for oxidation of wastewater.

The liquors undergo secondary treatment in anoxic, followed by anaerobic biological reactors, before being passed through an humus lamella separator, and directed to the tertiary filtration system for the removal of fine solids prior to disinfection by a chlorination system to meet discharge standards for use as irrigation water, providing some 16m3/hr of irrigation water.

Sludge is pumped in discreet batches for dewatering in a simple bagged gravity filter system which can accept one days sludge production. Around 400l of sludge will be produced every day at 3% DS (assumed) which is dewatered in the bag filter system to around 50%DS for land disposal as cake.

The package wastewater treatment plant will produce waste sludge from the waste water treatment process. The sludge will collect in the hopper of the primary settlement unit and be discharged at pre-set intervals to allow a degree of pre-thickening to occur. The sludge will be pumped to an intermittently mixed sludge storage tank before being transferred to a package sludge thickening and dewatering process. A bag filter system is proposed to produce a sludge with 50% dry solids, the bags are removed and stored on a rack for solar drying, before being disposed off-site in a licensed waste management facility. Figure 4-37 illustrates the process.

Figure 4-37: Block Flow Diagram Sanitary Wastewater Treatm ent





4.16 WASTE MANAGEMENT FACILITIES

A significant quantity of waste will be generated by the Project. The principal waste streams are identified in Table 4-11 together with details of the waste management facility to which they are disposed.

Table 4-11: Principal Waste Streams

Waste Stream Source Generating Activity Quantity (t py) Classification Disposal Destination

Overburden/Interburden Mine Ripping and dozing at the mine to access the ore horizons

33,650,0004 Inert Yr1-5 Waste Rock Dump

Yr6-29 Backfilled in Mine

Silaceous materials Beneficiation Optical Ore Sorter rejects silaceous material >9mm contained within the crushed ore delivered to beneficiation

1,653,000 Inert Tailing Storage Facility

Tailings Beneficiation Flotation process separating silica and carbonate from the phosphate, and subsequent thickening, and dewatering

5,582,000 Non-hazardous Tailing Storage Facility

Phosphogypsum PAP Reaction of rock slurry, H2SO4 and dilute P2O5 and subsequent washing,

11,407,000 Hazardous Phosphogypsum Storage Facility

Fluorspa PAP Neutralisation of FSA with lime 1,224,000 Hazardous Phosphogypsum Storage Facility

Phosphogypsum PPA Pretreatment of MGA from the PAP 39,000 Hazardous Phosphogypsum Storage Facility

Sodium Fluorosilicate PPA Precipitation of FSA generated by the defluorination of reduced H2SO4.

Hazardous Phosphogypsum Storage Facility

Phosphogypsum MCP/DCP Defluorination of MGA from the PPA 18,000 Hazardous Phosphogypsum Storage Facility

Calcium Fluorosilicate & Calcium Silicate

MCP/DCP Neutralisation of FSA with calcium hydroxide 126 Hazardous Phosphogypsum Storage Facility

Spent Vanadium Catalyst

SAP Conversion of SO2 to SO3 840 m3 Hazardous Off Site Thermal Treatment of Regeneration

Activated Carbon PPA 1000 Hazardous Off Site Thermal Treatment of Regeneration

4 Average quantity per year. Actual quantities estimated by the mining schedule vary per year.





All other wastes generated by the Project are to be transferred off site for disposal in licensed waste management facilities, either in Turaif, or in facilities developed as part of the Waad Al Shamaal City development. Where necessary hazardous and clinical wastes, which cannot be accommodated locally, will be transported to the nearest hazardous waste treatment facility in appropriate waste transportation vehicles.

4.16.1 TEMPORARY WASTE ROCK DUMP

Waste rock (overburden and inter-burden) generated through the excavation, stripping, and blasting at the mine during the first 5 years of exploitation, will be stored at temporary waste rock dump located in the north east of the mine licence, prior to commencement of backfill operations. The waste dump is split into two separate units to avoid building it in area of an existing wadi as shown in Figure 4-38. During these first 5 years, approximately 20M tonnes of waste rock will be stored. Temporary dumps will be removed and re-handled in Years 8 to 11 of production life to be used as backfill and provide access to underlying reserves.

Figure 4-38: Temporary Waste Rock Dump [Source SRK 2013e]

The temporary waste rock dump is not lined, however all run off from the temporary waste dump will be captured by perimeter ditches and pumped to the mine pit de-watering system, which directs potentially contaminated water to attenuations ponds located in the western infrastructure corridor, where water will be tested for compliance with surface water discharge limits; if compliant water will be discharged to the nearest wadi, where not, this will be retained and evaporated in the pond.

4.16.2 TAILINGS STORAGE FACILITY

The beneficiation plant will generate 8.5Mtpa of tailings; some 170Mt over the life of the mine, with an anticipated volume of 140Mm3. Tailings will be conveyed to the Tailings Storage Facility (TSF) with an area of 5km2, (2km by 2.5km) adjacent to the beneficiation plot. Figure 4-39 shows the plot plan for the TSF, which includes an area for the stockpiling of optical ore sorter reject (OOSR) material, storage for off specification tailings, and an evaporation / stormwater attenuation pond of 46,000m2 capacity.





Figure 4-39: Tailings Storage Facility Plot Plan (N.B. PCMR and OOSR are used

synonymously).[Source SRK 2013f]

A water and off-specification material storage area has been provided directly to the west of the TSF waste deposition area. This area includes the contact water storage/clarification pond and the temporary storage area for off-specification tailings.

Dewatered tailings with a minimum 80% solids by weight will be dry stacked in a truncated pyramid format and is anticipated to reach a height of 30m to 35m, a 20year period in two lifts, (SRK 2013d) over an assumed life of mine (LoM) of 20 years. Increasing the LoM to 29 years would require deposition of a third tailings lift at the TSF.

Siliceous material rejected by the optical ore sorter, will be conveyed separately to the TSF, deposited in a temporary stockpile before being used to progressively restore the tailings stack, through the construction of the permanent outer TSF slopes (in accordance with requirements to ensure stability), and provide dust mitigation. Optical ore sorter reject (OOSR) material (also known as PCMR) will be deposited using a mobile fleet on the side slopes of the deposited tailings material and over the top surface of the first and second lift.

While the tailings are considered to be of benign composition, the TSF design includes provision of a basal lining system which enables drainage and collection of excess water that may be released by the stacked tailings and optical ore reject material. Table 4-12 provides details of this lining system.

Table 4-12: TMF Basal Liner Composition

Liner component Purpose

500mm gravel To provide the seepage water transfer zone and a suitable working platform / running surface for the MHS during placement of tailings lift 1

Geotextile separator To provide protection to the upper-side of the HDPE geomembrane liner.





Liner component Purpose

HDPE geomembrane liner To provide the artificial sealing liner to the TSF.

Geotextile separator To provide protection to the under-side of the HDPE geomembrane liner.

100mm reworked sub-grade

To remove all particles in excess of 10 mm in diameter with the intention of providing a suitable surface for installation of the overlying geosynthetics

Tailings will be conveyed to transfer tower 1, from whence the tailings materials handling system deposits the tailings into the facility using a spine conveyor located along the southern boundary of the TMF coupled with a crawler mounted boom (with trip conveyor and stacker) conveyor orientated perpendicular to the spine conveyor to deposit the tailings over the TSF area. The fixed spine conveyor will operate in an East/West orientation and the crawler/stacker conveyor will operate in a North/South orientation. Figure 4-40 illustrates the progressive deposition of tailings and OOSR in the TSF.

Figure 4-40: Tailings Storage Facility – Progressive Depos ition [Source: SRK 2013f]

Dust control on vehicle routes and laydown areas is provided by water bowsers spraying a brine mixture, while fogging canons are to be provided to for the materials handling facilities. The application of OOSR provides dust suppression across the TSF as the absence of fines within this material limit the potential for dust generation.

The contact water management system comprises a permanent surface water ditch has been provided along the perimeter of the battery limits a series of open ditches around the footprint





of the waste mass and on intermediate waste lift levels that are designed to collect and manage the seepage from the waste together with contact surface water run-off from the design storm event. The ditches channel collected fluids to the low point of the TSF located in the south-west corner of the footprint where they discharge into a lined settlement pond for evaporation located in the strip of land to the west of the waste mass. The water balance for the TSF is provided in Figure 4-41.

Figure 4-41: TSF Water Balance [Source: SRK 2013f]

Construction and post construction monitoring systems are to monitor deformation, pore water pressure, seepage rates/quantities, stored volumes and precipitation run off as a minimum to ensure the safety and stability of tailings.

4.16.3 PHOSPHOGYPSUM STORAGE FACILITIES

The area designated for the receipt of phosphogypsum wastes and the fluorspar, Calcium Fluorosilicate and Calcium Silicate generated by the neutralisation of FSA from the PAP, PPA and MCP/DCP and is located in the east of the Industrial Complex. The road to the wellfield bisects the PSF, consequently there will be two separate storage ‘stacks’ for phosphogypsum; each is 3km2. The area designated for this waste stream is currently transected by an ephemeral wadi course, which is to be diverted to the wadi to the south of the Industrial Complex as part of the works.

The basal lining approach used for the PSF will be akin to that described in Section 4.16.2. Slurryed phosphogypsum will be piped to the PSF where it will flow into a conveyance ditch on the perimeter of the stack. The phosphogypsum is deposited through a decanting process as the slurry flows around the stack perimeter. Deposited phosphogypsum is removed with a backhoe, placed on the perimeter dyke and levelled to raise the stack. An initial charge of 40,000m3 of water is required for the operation of the stack (to be supplied by storing





construction water). In the first three years of operation the stacks will operate a three compartment system, which reduces the evaporation of water (see ).

Figure 4-42 – Plan view of Phosphogypsum Storage Facility with Three Compartments

Discharge lines are strategically placed around the periphery of the stack to facilitate the efficient building of the stack. These lines are raised and mved as needed to facilitate stack construction on an on-going basis. The slurry flow is moved from compartment to compartment as needed to allow the progressive building of the stack and to keep the three compartments at relatively the same height.

Each ‘stack’ is expected to be approximately 50m high with angle of repose of approximately sH:1V and will be built progressively. Figure 4-43 illustrates this.





Figure 4-43: Phosphogypsum Storage Facility in Section





Brine which cannot be reused elsewhere in the facility and any industrial wastewater effluents arising from the process will be directed to the phosphogypsum stack.

Decant / contact water derived from gradual compression of the material driving out water, or from precipitation is collected via conveyance ditches, which direct the water to a separate lined containment basin adjacent to the stack. This water will be pumped to the gypsum mixing tank for re-use in slurrying the phosphogypsum for transportation.

Construction and post construction monitoring systems are to monitor deformation, pore water pressure, seepage rates/quantities, stored volumes and precipitation run off as a minimum to ensure the safety and stability of the ‘stacks’.

4.16.4 OTHER WASTES

The Project will generate other wastes which will be temporarily stored on site, in appropriate storage areas, providing secondary containment where necessary, before being transported off site for disposal in a waste management facility licenced to accept the waste. Examples of the wastes to be disposed of off-site include, but are not limited to:

• Oils and coolants, and oil contaminated water from the MMA;

• Spent vanadium catalyst;

• SWTP and IWTP sludges;

• Activated carbon;

• Dust extraction filter waste;

• Clinical wastes; and

• Municipal wastes

4.17 SUPPORTING BUILDINGS AND INFRASTRUCTURE

4.17.1 ADMINISTRATIVE AREAS

In addition to the above, the Project includes a general administrative and maintenance area, which includes a number of support buildings as follows:

• Workshops and warehouses;

• Gatehouses and weighbridge;

• Administration building and clinic;

• Central Quality Control and Research and Development laboratories

• Training centre

• Cafeteria

• Mosque; and

• Security and reception buildings.





5.0 IMPACT ASSESSMENT METHODOLOGY

Section 3 Consideration of Alternatives describes the various project / design alternatives considered as part of the Project development; the selected Project elements have been described in Section 4 Detailed Description and Layout of the Proposed Development. This Section, Impact Assessment Methodology, presents an overview of the general impact assessment methodology applied to the assessment of potential impacts arising from the Project elements so that this is not repeated across Sections 6 – 16.

The impact assessment criteria, outlined in the following sub-sections, have been applied to the assessment of each of the proposed Project elements during construction, operation and decommissioning stages and documented within Sections 6-16. Where specific methods of assessment have been applied for an environmental aspect, these are presented in the relevant Section (6-16).

In accordance with IFC Performance Standard 1 Assessment and Management of Environmental and Social Risks and Impacts, the methodology for this Environmental and Social Impact Assessment (ESIA) has been developed in accordance with good international industry practice and potential impacts have been identified in the context of the Project’s area of influence.

5.1 PROJECT SITE LOCATION

The Project site, illustrated in Figure 5-1, is situated within the Northern Borders Province of the Kingdom of Saudi Arabia close to the border with Jordan. The Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex covers an area of approximately 58km2. The mine covers an area of 37.82km2 and is located close to the border with Jordan within the 10km border security zone and 26km to the southwest of the Iraq border. Approximately 13km to the south of the proposed mine and outside the border security zone, is the location of the proposed Waad Al Shamaal Phosphate Industrial Complex, which is within the boundaries of the planned Waad Al Shamaal City development. There is also a well field area for the abstraction of water located approximately 60km to the east of the Waad Al Shamaal Phosphate Industrial Complex. The closest sizable population centre is Turaif, which is approximately 40km to the south-west of the site

The Umm Wu’al Mine, and Waad Al Shamaal Phosphate Industrial Complex will include an open cast mine and an industrial complex which will include a beneficiation plant, Sulphuric Acid Plant (SAP), Phosphoric Acid Plant (PAP), Purified Phosphoric Acid (PPA) plant, Sodium TriPolyPhosphate (STPP) plant, and Monocalcium Phosphate/Dicalcium Phosphate (MCP/ DCP) plant. Utilities required for the operation of the Project include the provision of a wellfield consisting of 24 wells approximately 60km to the east of the site, water treatment, and wastewater treatment facilities, cooling water provision and connection to natural gas, electric and telecommunications supply.





Figure 5-1 – Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex





5.1.1 ESTABLISHMENT OF BASELINE CONDITIONS

Baseline information for the ESIA has been collated from desk-based studies and literature reviews, sites visits and monitoring, and consultation. These can be summarised below, with further detail of literature review provided in Section 20 – Reference List:

Literature Review:

• Environmental impact assessment reports previously completed for the Ma’aden Phosphate Project (2000, 2005, 2006, 2008, and 2012);

• King Abdullah Project for Waad Al Shamaal City Development Masterplan (2013);

• Saudi Arabian Monetary Agency (SAMA) 48th Annual Report (2012);

• Central Department of Statistics and Information (2010) – Census Statistics; and

• Ministry of Economy and Planning (2009) Ninth Development Plan.

Site Visits and Consultation:

• September 2012: Preliminary site visit to review existing land use and identify receptors;

• November 2012: Ecological Baseline Survey, part 1a;

• December 2012: Environmental Scoping meeting with the Presidency for Meteorology and Environment (PME);

• December 2012: Air monitoring and ecological baseline survey, part 1b;

• January 2013: Air and noise monitoring, water sampling and consultations with Ma’aden staff, government officials and local community;

• February 2013: Air monitoring, and traffic counts;

• March 2013: Air monitoring, traffic survey;

• April 2013: Air monitoring and ecological baseline survey, part 2; and

• June 2013: Noise monitoring.

5.2 IMPACT ASSESSMENT CRITERIA

Prediction and evaluation of environmental and social impacts within Sections 6-17 of this ESIA are considered against the baseline (including its value / sensitivity). In addition to the Key Principles provided by the PME (2001) and draft supplementary guidance notes (2012), and as a basis for assessing environmental impacts, the methodology applied to this ESIA has been developed using a combination of the criteria, methodology and guidance provided by international requirements/best practice.

The PME Key Principles are as follows:

• “Nature and magnitude of the intended activity and the existence of similar projects at the site or similar sites;

• Extent of depletion by the installation of the natural resources, particularly agricultural lands and mineral resources;

• Location of the installation and the nature of the surrounding environment and nearby residential clusters;

• Type of power used.”

The international sources considered are as follows:





• IFC (2012) Performance Standard 1 IFC Performance Standard 1 Assessment and Management of Environmental and Social Risks and Impacts (and associated Guidance Note);

• Directive 2011/92/EU on the assessment of the effects of certain public and private projects (codified version of the initial Directive of 1985 and its three amendments 97/11/EC, 2003/35/EC and 2009/31/EC)5; and

• Impact Assessment Guidelines and the ES Review Criteria from the Institute of Environmental Management and Assessment (IEMA).

The ESIA methodology has been adopted in combination with PME requirements on ESIA content.

The following factors are considered in classifying each potential impact generated by the Project, as presented in Table 5-1:

• Frequency: Occurrence of activity producing the impact, e.g. continuous, intermittent or a single event / less than once per year;

• Likelihood: Probability of impact occurrence (e.g., 100%, 50%, 0%);

• Extent: Spatial extent of the impact (e.g. within 2km of site boundary, outside the Project site but within 20km, within 200km, within KSA, outside KSA;

• Duration: Extent in time of the impact. Short term impact (less than the life of the project), medium term impacts (equal to the lifetime of the Project) and long term impacts (greater than the lifetime of the Project);

• Magnitude: Impact magnitude defined in relation to the limit criterion specified by the PME or international standards where available.

• Type of impact: Positive or negative effect; direct or indirect action.

• Potential significance: A combination of all the factors described in the preceding bullet points is used to determine the type and significance of a potential impact prior to mitigation. This is defined as low, medium or high.

Table 5-1 presents the terminology used throughout Sections 6-17 to describe and rank environmental and social impacts according to the categories defined above. Figure 5-2 presents how these criteria are combined in order to assess the significance of the potential environmental and social impacts identified.

Table 5-1 Terminology Used to Describe Environmental and Social Impacts

Category Terminology Definition

Scope of Impact (1)

Frequency

Continuous

Frequent

Infrequent

Rare

Uninterrupted or on a daily basis

Once or more per day

Less than once per day

Single event / less than once per year

Likelihood

Certain

Likely

Unlikely

No impact

Impact possibility estimated to be 100%

Impact possibility estimated as between 50% and 99%

Impact possibility estimated as < 50%

Zero estimated possibility of impact

Extent

Local

Provincial

Regional

Within 2 km of the Project site

Outside the Project site but <20 km away

Outside the Project site but < 200 km away

5 The European Commission has proposed amendments to this Directive 2011/92/EU. Following a review of the proposed amendments, it is not considered that the amended Directive will significantly alter the impact assessment criteria defined for use in this ESIA.





Category Terminology Definition National

International

Within KSA

Outside KSA

Duration

Short

Medium

Long

Less than the life of Project

The life of project

Greater than the life of Project

Magnitude(2)

Very low

Low

Medium

High

Very high

Defined in relation to the limit criterion where available, e.g.:

• Very low: Parameter < 10% limit criterion

• Low: Parameter 10 to <50% limit criterion

• Medium: Parameter 50 – 100% limit criterion

• High: Parameter 100 – 200% limit criterion

• Very High: Parameter > 200% limit criterion.

Or, for qualitative assessments:

• Very low: No degradation/adverse alteration to resource/receptor

• Low: Minor degradation/adverse alteration to resource/receptor

• Medium: Moderate degradation/adverse alteration to resource/receptor.

• High: Significant degradation/adverse alteration to resource/receptor.

• Very High: Permanent degradation/detrimental alteration to resource/receptor.

Type of Impact

Effect Positive

Negative

Beneficial impact

Adverse impact

Action

Direct

Indirect

Impact caused solely by activities within scope of Project

Impact which does not result directly from by activities within the scope of Project, but which has a connection with the Project’s presence.

Potential Significance

Significance

Low

Medium

High

Any low magnitude impact, or medium magnitude impact that is unlikely to occur or is of short duration.

Any medium magnitude impact that is certain or likely to occur and of medium or long duration. Also, any high magnitude impact that is unlikely to occur, of short duration, or local in extent.

Any high magnitude impact that is certain or likely to occur, of medium or long duration, and regional in extent.

(1) (2)

All terms are characteristics of the impact(s). For example, duration refers to duration of impact, not the activity causing it. As indicated, the impact magnitude for some environmental aspects can be defined in relation to the limit criterion specified by the PME or international regulations, or best practices when national standards are not available. However, in the absence of definitive quantitative criteria, a qualitative assessment of the magnitude is used relating to the impact type.





Figure 5-2: Combination of ESIA Criteria Used to Assess th e Potential Environmental and Social Impacts Identi fied





5.3 IMPACT ASSESSMENT REPORTING

The findings of the assessment process for each environmental aspect are presented in Sections 6 – 17 with the significance of any predicted environmental impacts being defined as Low, Medium or High and documented in bold italics .

Impacts predicted as being of medium to high significance are then assessed against appropriate mitigation measures to predict the residual impact significance. An example of how Sections 6 – 17 report the mitigation identified for impacts of medium to high significance is illustrated by Table 5-2. The Identification (ID) Codes assigned to each impact are used to reference the impacts and association mitigation measures through other sections of the ESIA (e.g. Section 18 Summary of Impacts and Mitigation).

Table 5-2: Example of Impact and Mitigation Summaries

ID Code Impact Potential

Significance Mitigation Measure Significance

after Mitigation

T2

Increase in Vehicle movement will result in potential road traffic accidents during Construction

High

A structured approach to traffic management and vehicle standards should be specified and safety measures should be implemented. Ensure the transport plan for the Project is developed and implemented during the lifetime of the project. Establish pedestrian routes within the construction area to be used by workers;

Medium

5.4 MITIGATION MEASURES AND REPORTING

Two types of mitigation measures are identified through this ESIA Report in order to alleviate or manage the potential impacts identified:

• Type 1: Measures to be taken to manage potential impacts considered to be of medium or high significance. Following application of these measures, residual impacts are expected to be lower.

• Type 2: Recommended measures that could be taken to manage impacts classified as low/insignificant. These measures can be considered as good management practices.

5.5 CONCLUSION

The impact assessment methodology applied across this ESIA demonstrates an appropriate mitigation hierarchy for predicted impacts which gives preference to the avoidance of impacts over minimisation. This is achieved firstly by the examination of feasible alternatives; alternative project locations, designs, or operational processes, as documented in Section 3 Consideration of Alternatives, and then the remainder of the ESIA outlines the alternative ways identified for dealing with any predicted environmental and social impacts.





6.0 AIR QUALITY AND METEOROLOGY

6.1 INTRODUCTION & SCOPE

This Chapter presents a summary of the existing ambient air quality in the vicinity of the Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex (referred to herein as the Project) site and the prediction of potential air quality impacts resulting from the various stages of the Project. The phases considered in this assessment include construction, operations, and de-commissioning. Detailed Project emissions input data as well as modelling results are presented in Appendix D.

6.2 BASELINE CONDITIONS/ EXISTING ENVIRONMENT

6.2.1 INTRODUCTION

This Section presents a description of the baseline air quality and meteorological conditions at the Project site, based on a desktop review of relevant literature and data collection by WHGME. Site visits were conducted by WHGME on December 2012, January, February, March and April 2013.

The literature review for the Project includes previous environmental assessments conducted for Ma’aden in order to gather information about the regional context. Studies reviewed include:

• GHD Global Pty / Environmental Consulting Bureau (ECB) (2008) Ma’aden Phosphate Project Supplementary Environmental Impact Assessment.

• SNC Lavalin (2005) Environmental Impact Study – Chemical Complex, Ma’aden Phosphate Project Bankable Feasibility Study Report, Volume 13B.

• Sofreco-Technip (2012) Environment Scoping Study and HSE Report, Ma’aden Phosphate Project Bankable Feasibility Study Report, Volume 10 and Annexes.

• SRK Consulting (2000) Environmental Baseline Assessment for the Northern Phosphate Project Sites.

6.2.2 REGIONAL AIR QUALITY DATA

The Project represents the first industrial development within the proposed Waad Al Shamaal Development City and is currently an undeveloped, rural area. As such, the site is considered a greenfield site.

Ambient air quality data for this assessment was provided by local monitoring data collected on the site by WHGME in 2012-2013 and from the SRK Northern Phosphate Sites Environmental Baseline Report from 2000.

6.2.3 METEOROLOGY

The climate of the proposed Project area is typical of the desert environment in Saudi Arabia. Summers are generally long, hot and dry while winters are short and cool. There are transitional seasons separating the two defined seasons of summer and winter.

The Mine area in the proposed Project site is located north-east of Turaif city. Table 6-1 provides a summary of the average monthly conditions in Turaif during the period from 1978-2005, based on data from the Presidency of Meteorology and Environment (PME). Recent meteorological data from Turaif airport from September 2011 to August 2012 is also presented in Table 6-2.





Table 6-1: Average Meteorological Conditions in Turaif Ci ty 1978-2005

Month Temp (oC)

Relative humidity (%)

Prevailing wind direction

Wind speed (m/s)

Rainfall (mm)

Jan 7.3 67 W 8 15.2 Feb 8.9 58 W 9 15.0 Mar 12.8 47 W 9 12.7 Apr 18.7 36 W 9 11.6 May 23.6 28 W 9 3.9 Jun 27.2 25 W 8 0.1 Jul 29.3 26 W 8 0.0 Aug 29.3 26 W 8 0.0 Sept 26.6 27 W 7 0.3 Oct 21.2 38 W 7 7.4 Nov 13.9 53 E 7 10.9 Dec 8.8 65 ESE 7 13.0

Source: PME (2005) Table 6-2: Meteorological data for Turaif City from Septe mber 2011 – August 2012

Month Temp

Min ( oC) Temp

Max (oC) Hum Min

(%) Hum

Max (%)

Wind Mean (m/s)

Wind Max (m/s)

Total Prec (mm)

Sep-11 17 38 12 91 4 12 0 Oct-11 9 32 15 98 3.6 13 0 Nov-11 2 22 15 100 3.6 11 0 Dec-11 0 20 9 100 3 10 9 Jan-12 0 17 15 98 3.6 12 10.9 Feb-12 1 22 19 100 5 18.5 6.3 Mar-12 1 25 9 100 5 15 0.3 Apr-12 6 32.5 8 82 4.6 29 0 May-12 12 35 7 87 3.6 17 0.6 Jun-12 17 43 5 64 4.6 16 0 Jul-12 18 43 8 76 4 11 0 Aug-12 19 39 9 91 4 10 0

Source: Turaif Airport 2011-2012

6.2.4 TEMPERATURE

As shown in Table 6-1, average temperatures range from 21–29°C in summer and 7–14°C in winter. More recent data from 2011 and 2012 shows temperatures ranging of 0 ºC in winter months to a high of 40ºC in March 2012.

6.2.5 PRECIPITATION

Table 6-1 also shows that the average precipitation range over the monitoring period was 0-4 mm in summer and 7–15mm in winter. More recent data from 2011-2012 shows similar trends to the earlier monitoring data. There was almost no precipitation in the months from September to December and from April to August. The highest total precipitation value of 10.9mm was recorded in January 2012.

6.2.6 HUMIDITY

Table 6-1 shows that the average relative humidity over the long term monitoring period ranged from 25 to 67%. More recent data from 2011-2012 shows humidity ranging from a minimum of 7 to a maximum of 100%.





6.2.7 WIND

Long term monitoring data shows that the prevailing wind direction for the majority of the year is from the west changing to east or east south east for two months of the year. The average wind speed ranged from 3-5 m/s. Data from 2011-2012 shows the maximum wind speed to be 29 m/s. The annual wind rose for the period September 2011 to August 2012 is shown below in Figure 6-1, showing again the predominant wind direction to be westerly. Meteorological monitoring at the nearby Al Jalamid phosphate mine was conducted by SRK for 12 months during 1999-2000 and was made available for this assessment. This data shows similar meteorological trends.

Figure 6-1: Annual Wind Rose for September 2011 to August 2012

Source: WHG, 2013

6.3 AMBIENT AIR QUALITY

6.3.1 INTRODUCTION

Existing sources of air pollutants in vicinity of the Project Site are limited. The Project represents the first industrial development within the proposed Waad Al Shamaal Development City. The closest sizable population centre is Turaif, which is approximately 40 km to the south west of the site. Existing pollution sources in the wider are include: • National Highway 85 located 25 km south of the Project site (which runs from Al Qurayyat

in the west to join highway 95 north west of Jubail);

• Turaif;

• Turaif Airport, located to the north east of Turaif; and

• The existing Al Jalamid mine, located some 100 km east of the Project. The Al Jalamid site consists of a phosphate mine, beneficiation plant and supporting infrastructure in an area of approx. 50 sq. km.

The closest sensitive receptors in the area are also located in Turaif. The only exception to this is a chicken farm currently located 30 km to the southwest of the Project site. However, this chicken farm will be moving to an alternate location prior to commencement of project operations. As part of the first phase of the Wadd Al Shamal city development, residences will be developed for the Ma’aden Phosphate staff - the proposed site is south of Umm Wu’al mountain. The Project site is located within an international-boundary buffer zone, a 10 mile





restricted zone adjacent to the border of Jordan. The nearest dwellings on the Jordanian side appear to be developments along the route of Highway 10, transecting the Mafraq region of north east Jordan, some 80-90 km to the north of the international border; the most sizable of which appears to be Ar Ruwayshid.

6.3.2 AMBIENT AIR QUALITY BACKGROUND AND MONITORING DATA

The purpose of background data in a modelling context is to derive justifiable additions to the process contributions (PC) to allow a good indication of the overall predicted environmental concentration in a region for comparison to Ambient Air Quality Standards (AAQS). Modelling tools used can actually combine the contemporaneous hourly air concentration derived from a process with the background concentration measured during that hour. This gives the best indication of predicted environmental concentration (PEC) since the overall results undergo the averaging process within the modelling tools. However, this requires a continuous and extensive data set, which is not available here.

The second approach is to identify appropriately averaged background environmental data to add to the PC. Thus, the addition of annual average background data to 1 hour PC for comparison to a 1-hour AAQS is usually inappropriate, since it gives no indication of the likely extremes of the range of measured background concentrations. Set against this is the conservative assumption that a peak background measurement coincides with a peak PC assessed concentration (hence why the combination of contemporaneous data in models is the best approach).

The closest relevant hourly data available in the Umm Wu’al region are derived at a distance too remote from the current site to be relevant, so the approach taken for this analysis is to make use of the data produced at the site. This comprises the initial baseline study undertaken in by SRK in 2000 and the recent sampling data undertaken at the site as part of this Project.

6.3.2.1 SITE MONITORING

Gradko tubes were placed by WHGME on the site for the measurement of SO2, NO2 20%, NOx, and PM10 levels. The results of this monitoring are presented in Table 6-3, Table 6-4, Table 6-4, Table 6-5 and Table 6-6, and the location of the diffusion tubes are shown in Figure 6-2. The three sampling periods were: • December 2012– January 2013;

• January– February 2013; and

• March – April 2013.





Figure 6-2: Umm Wu’al Air Quality Monitoring Sites

For SO2, NO2 and NOx, tubes were installed at the corners of the Mine area and the rear of the existing chicken farm at a height of 1.5 m, along with controls and removed as per the schedule provided in the tables. The exposed Gradko tubes were sent to Gradko Environmental, in the UK for analyses. SO2 levels were determined by ion chromatography. NO2 20% and NOx concentrations were determined by UV spectrophotometry.





Table 6-3: Result of SO 2, NO2 20% and NOx Monthly Levels at the Project site (De c 2012 – Jan 2013).

Monitoring period

Tube Type

Tube Serial

number

Location N E

Relative location ug/m 3

ppb

04/12/2012 - 07/01/2013

NOx 078748

31 59 37.9 39 00 47.3

NE corner of the Mine area

5.71 2.97 NO2 20% 078711

2.10 1.09

SO2 078674 1.33 0.50

04/12/2012 - 07/01/2013

NOx 078749

31 58 18.6

38 59 57.7

Old Border Guards station

5.08 2.65 NO2 20% 078750

7.04 3.67

SO2 078712 2.08 1.08 NOx 078713 0.34 0.18 NO2 20%

078675 < LOD < LOD

04/12/2012 - 07/01/2013

SO2 078751

31 56 41.4 39 01 41.3

SE corner of the Mine area

0.32 1.41 NOx 078715 2.70 0.17 NO2 20% 078714

2.31 1.20

SO2 078676 7.56 2.84

05/12/2012 - 06/01/2013

NOx 078752

31 38 04.3 38 51 16.7

Ma’aden Camp point 1

4.52 2.36 NO2 20% 078716

0.36 0.19

SO2 078677 0.93 0.35

05/12/2012 - 07/01/2013

NOx 078753

31 55 42.1 38 59 28.9

SW corner of the Mine area

5.77 3.00 NO2 20%

078717 2.87 1.49

SO2 078678 2.57 0.96 Source: Gradko 2013 Table 6-4: Results of SO 2, NO2 20% and NOx Monthly Levels at the Project site (Ja n –Feb 2013).

Monitoring period Tube Type

Tube Serial

number

Location N E


ppb

06/01/2013 -

19/02/2013

NOx 078754 31 45 41.6

38 57 24.8

Inside the plant area

2.71 1.41 NO2 20% 078701 2.38 1.24

SO2 078679 4.37 1.64 07/01/2013

-19/02/2013

NOx 078738 31 58 18.6

38 59 57.7

Old Border Guards station

4.34 2.26 NO2 20% 078702 1.17 0.61

SO2 078680 1.21 0.45 07/01/2013

-19/02/2013

NOx 078739 31 57 30.0

39 00 10.8

Mine area 4.09 2.13 NO2 20% 078703 1.80 0.94

SO2 078664 10.43 3.91 07/01/2013

-19/02/2013

NOx 078740 31 55 42.1

38 59 28.9


2.71 1.41 NO2 20% 078704 1.37 0.72

SO2 078665 1.58 0.59 07/01/2013

-19/02/2013

NOx 078741 31 56 41.4

39 01 41.3


4.20 2.19 NO2 20% 078705 1.20 0.62

SO2 078666 1.97 0.74 08/01/2013

-19/02/2013

NOx 078742 31 38 04.3

38 51 16.7


6.65 3.46 NO2 20% 078668 5.38 2.80

SO2 078667 13.95 5.23 13/01/2013

-19/02/2013

NOx 078743 31 38 33.4

38 49 29.4

Chicken farm (outside) east

side.

4.63 2.41 NO2 20% 078706 6.30 3.28

SO2 078669 7.55 2.83 08/01/2013

-19/02/2013

NOx 078744 31 39 03.6

38 47 28.6

Chicken farm (outside) west

side

13.76 7.17 NO2 20% 078707 5.82 3.03

SO2 078670 13.73 5.15 Source: Gradko 2013





Table 6-5: Results of Gradko Tube Monthly Measurement of SO 2, NO2 20% and NOx levels at the Project site (Mar –April 2013)

Monitoring period

Tube Type

Tube Serial

number

Location N E


ppb

13/03/2013 -

12/04/2013

NOx 119184 31 59 37.9

39 00 47.3

NE corner of the Mine area

6.20 3.23

NO2 20% 119204 2.88 1.50 SO2 119164 1.27 0.48

13/03/2013 -

12/04/2013

NOx 119185 31 56 41.4

39 01 41.3


6.88 3.58

NO2 20% 119205 2.49 1.30 SO2 119165 2.46 0.92

13/03/2013 -

12/04/2013

NOx 119186 31 55 42.1

38 59 28.9


6.30 3.28

NO2 20% 119206 2.83 1.48 SO2 119166 2.25 0.84

14/03/2013 -

14/04/2013

NOx 119187 31 38 04.3

38 51 16.7


3.27 1.70

NO2 20% 110207 3.43 1.79 SO2 119167 10.45 3.92

14/03/2013 -

12/04/2013

NOx 119188 31 38 03.4

38 51 17.9

Ma’aden Camp Point 2

3.56 1.85

NO2 20% 119208 1.81 0.94 SO2 119168 6.35 2.38

14/03/2013 -

12/04/2013

NOx 119189 31 38 33.4

38 49 29.4

Chicken farm (outside) east

side

3.08 1.60 NO2 20% 119209 3.40 1.77

SO2 119169 0.82 0.31 14/03/2013

- 12/04/2013

NOx 119190 31 39 03.6

38 47 28.6

Chicken farm (outside) west

side

6.21 3.24

NO2 20% 119210 5.99 3.12 SO2 119170 LOD LOD

Source: Gradko 2013 A PM10 high volume sampler was also installed at a fixed location at the rear of the Project site on 15th March 2012 for data collection over a 30 day period. Daily readings were taken and weighed to determine the concentrations of PM 10 in the air.

Depositional quantities and samples for chemical analysis of dust were obtained via the installation of Bergerhoff jars at the rear of the Project site and inside the Mine for 30 day periods in January and February 2013. The off-site analysis of samples collected in the Bergerhoff jars was undertaken at Exova Co. Ltd in Dammam 2nd Industrial Area. Laboratory analyses included testing for heavy metals (Cd, Cr, As, Cu, Zn, Pb, Hg, Ni, Co, Sb, Se, Mo, Ag) and radionuclides. Results of PM10 monitoring over a 30 days period from 16th March to 14th April 2013 are shown in Table 6-6. The average amount of dust collected per day was 0.49 g.





Table 6-6: PM10 data collection from 16th March – 14th April 2013

No. Starting date Time Dust weight (g) Pressure

average (inches in H2O)

PM10 Concentration

1 16/03/2013 17:00 0.464 18.5 278.50 2 17/03/2013 17:00 0.859 20.6 526.97 3 18/03/2013 17:00 0.253 17.8 154.39 4 19/03/2013 17:00 0.285 18.5 173.76 5 20/03/2013 17:00 0.165 19.7 100.25 6 21/03/2013 17:00 0.177 19.7 107.26 7 22/03/2013 17:00 0.081 21.7 49.39 8 23/03/2013 17:00 3.234 20.7 1978.71 9 24/03/2013 17:00 0.192 19.8 117.58 10 25/03/2013 17:00 0.041 18.6 24.91 11 26/03/2013 17:00 0.390 18.0 235.30 12 27/03/2013 17:00 0.426 17.0 256.13 13 28/03/2013 17:00 0.091 18.0 55.05 14 29/03/2013 17:00 0.024 17.7 14.46 15 30/03/2013 17:00 0.188 18.5 113.13 16 31/03/2013 17:00 0.751 21.5 454.69 17 01/04/2013 17:00 0.742 20.0 447.29 18 02/04/2013 17:00 0.770 18.5 463.36 19 03/04/2013 17:00 0.181 18.5 108.92 20 04/04/2013 17:00 1.907 17.5 1145.59 21 05/04/2013 17:00 0.808 21.0 496.12 22 06/04/2013 17:00 0.135 19.0 81.95 23 07/04/2013 17:00 0.105 17.5 63.08 24 08/04/2013 17:00 0.130 20.1 78.43 25 09/04/2013 17:00 0.165 19.0 100.16 26 10/04/2013 17:00 0.770 17.5 465.38 27 11/04/2013 17:00 0.876 17.0 529.91 28 12/04/2013 17:00 0.512 17.3 309.99 29 13/04/2013 17:00 0.145 21.1 89.03 30 14/04/2013 17:00 0.087 18.6 53.04

Source: WHG, 2013 A conversion factor was applied to convert monthly data to annual data and then compared to PME standards in Table 6-7 below. Exceedances of the PME standards are shown in bold. Results of the site monitoring for PM10 show high levels of particulates that exceed annual PME standards.

Table 6-7: Gradko Diffusion Tubes Conversion from Monthly to Annual Data (ug/m 3)

Pollutant PME AAQS

Dec-Jan Jan-Feb March-April

NOX annual 100 2.64 2.99 2.81 SO2 Annual 80 .80 6.84 2.185 PM10 annual 80 NA - 168*

Source: Jacobs 2013 *Conversion factor of 1.8 assumed. Results of the laboratory analysis conducted on dust samples collected through Bergerhoff jars are in January and February 2013 shown in Table 6-8.





Table 6-8: Chemical Analysis of Dust Samples

Parameter

Mine 07 Jan 2013 19 Feb 2013

Mine 19 Feb 2013 12 Apr 2013

Ma’aden Comp 06 Jan 2013 19 Feb 2013

Ma’aden Comp 19 Feb 2013 14 Apr 2013

Dust Content 160 mg 230 mg 590 mg 720 mg

Reporting unit(mg/kg) Antimony 0.21 0.16 < 0.1 < 0.1 Arsenic 4.8 2.5 4.3 2.4

Cadmium 1.3 0.64 0.69 0.34 Chromium 46 26 30 17

Cobalt 10 5.1 8.7 5.1 Copper 23 9.0 14 8.4 Lead 14 6.4 8.6 5.0

Mercury 1.6 < 0.1 < 0.1 < 0.1 Molybdenum 4.7 2.6 2.8 1.6

Nickel 41 21 38 23 Selenium 2.5 0.96 1.6 0.86

Silver 3.4 2.1 0.81 0.90 Zinc 160 36 66 27

Source: WHG, 2013

As shown in the results above, the concentrations of the various heavy metals in the dust for samples taken in Jan – Feb are approximately double those recorded in Feb – Apr 2013. The dust jars in the second cycle were exposed longer as the dust content collected in the first month of the cycle was very low.

A comparison of the Jan – Feb 2013 results between the Mine and the Chemical Complex site (titled Ma’aden Comp) shows that the concentration of most heavy metals was higher at the Mine site than the Chemical Complex. The concentrations of chromium, nickel and zinc were on the higher side of the heavy metals found in the dust.

6.3.2.2 BACKGROUND CONCENTRATIONS

The samples taken above were recorded over periods of time different to the averaging period for the relevant AAQS. In order to derive relevant background concentrations for comparative purposes, scaling factors can be derived. This can involve detailed statistical analysis, and pragmatic approaches to compare modelling results and AAQS over different averaging periods, using a conversion factor to scale them appropriately. For example, for a 1 month to 1 year comparison, the scaling factor is calculated as 1.8 (so to compare a 1 month to a 1 year standard, divide the monthly conc. by 1.8). Details of the calculations applied for the Project background are included in Appendix D. Exceedances of PME standards are shown in bold. The values to be used for background concentrations in this analysis are shown in Table 6-9.

Table 6-9 Background Concentrations Used in the Assessmen t

Pollutant and averaging period PME AAQS

Derived background

concentration (µg m-3)

Derived background concentration at the

Border receptor (µg m-3)

NOX 1H3H 660 109 33.2 NOX annual 100 6 SO2 1H3H 730 61.2 13.6 SO2 24H2H 365 25.1 SO2 Annual 80 5.1 PM10 24H1H 150 1979 PM10 annual 50 62





All background levels were within PME standards, except PM10 levels. The PM10 data collected shows higher maximum daily concentrations of 1979 and 1145 µg m-3 on two days in March 2013 alone (probably during dust storms). The following is a general description of the pollutants of concern in the Project area and a description of ambient measurements related to each.

Nitrogen Dioxide

Nitrogen dioxide (NO2) is a brownish gas that can irritate the lungs and cause breathing difficulties at high concentrations. NO2 is generally not directly emitted from an emission source, but is formed through a reaction between nitric oxide (NO) and atmospheric oxygen. NO and NO2 are collectively referred to as NOX and are major contributors to ozone formation. NO2 also contributes to the formation of PM10. In high concentrations, the result is a brownish red cast to the atmosphere and reduced visibility.

In the general urban environment the principal sources of oxides of nitrogen (NOx) are traffic, and to a lesser extent industry, shipping and households.

Background NO2 concentrations recorded at the at the Umm Wu’al site (diffusion tube and SRK 2000 data) are well within the PME maximum annual and hourly standards.

Carbon Monoxide

Carbon monoxide (CO) is a colourless gas that interferes with the transfer of oxygen by the blood. CO is emitted almost exclusively from the incomplete combustion of fossil fuels. On-road motor vehicle exhaust is the primary source of CO. In cities, 85 to 95 % of all CO emissions may come from motor vehicle exhaust.

Natural background levels of carbon monoxide (CO) range between 0.06 and 0.14 µg/m3. Concentrations in urban areas typically depend on weather and traffic density, and they also vary greatly over time and with distance from the source. The 8-hour average concentrations are generally lower than 20 µg/m3.

In relation to PME standards for the 1-hour average and 8-hour average at the background concentrations did not exceed the above-criteria concentrations.

Sulphur Dioxide

Sulphur dioxide (SO2) is a product of high sulphur fuel combustion. The main sources of SO2 are coal and oil combustion in power stations, industry and for domestic heating. Industrial chemical manufacturing is another source. It can cause plant leaves to yellow, and corrode iron and steel.

Existing SO2 concentrations at the Umm Wu’al site (diffusion tube and SRK 2000 data) are within the PME 1-hour average, 24-hour average and annual standards.

Particulate Matter (PM 10)

Particulate pollution is composed of solid particles or liquid droplets that are small enough to remain suspended in the air. Particulate matter pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter also forms when gases emitted from industrial and combustion sources, and motor vehicles undergo chemical reactions in the atmosphere. Particulate pollution also can include bits of solid or liquid substances that can be highly toxic. Exposure to such particles can affect both the lungs and heart.

PM10 refers to particulate matter less than 10 microns in diameter, about one seventh the thickness of a human hair. Major sources of PM10 include motor vehicles; wood burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning, industrial sources, windblown dust from open lands; and atmospheric chemical and photochemical reactions. Suspended particulates produce haze and reduce visibility.

PM10 concentrations monitored at the Umm Wu’al site (diffusion tube and SRK 2000 data) exceeded PME annual standards and 24 hour PME standards. It should be noted that the high concentration of PM 10 in the desert regions are likely to be associated with sand storms from





seasonal high winds, and it would not be possible to separate such natural particulate contributions from anthropogenic contributions.

Fluorides/Hydrogen Fluoride

Hydrogen fluoride (HF) is a colourless, pungent liquid or gas that is highly soluble in organic solvents (e.g., benzene) and in water. Hydrofluoric acid is the fluoride synthesized on the largest scale. It is produced by treating fluoride minerals with sulphuric acid. Hydrofluoric acid and its anhydrous form hydrogen fluoride are used in the production of fluorocarbons and aluminium fluorides. HF can result in fatal exposure through inhalation or upon contact with the skin. The PME has not specified any standards for HF specifically, but the monthly RC standard for Fluoride is 1 µg m-3. No HF monitoring data for the site is currently available.

Ozone (03)

Ozone is a secondary pollutant formed in the lower atmosphere by the action of sunlight (insolation) on NOx and volatile organic compounds (VOCs). Under strong summer insolation, coastal recirculation is likely to become a large natural photochemical reactor. Most of the NOx emissions and other ozone precursors are transformed into oxidants, acidic compounds, aerosols and ozone, which may potentially result in the exceedance of thresholds. Ozone is effectively generated at a regional scale from emissions from both industrial and urban areas, and a proportion of the observed ozone at any one location may result from advection within the recirculating air masses. This complicates data interpretation from the AQMSs and means that interpretation of pollution episodes need to be considered on a regional basis in addition to the impact of localized sources.

6.4 IMPACT ASSESSMENT

6.4.1 OVERVIEW

The Project may impact upon the air quality and meteorology environment during construction, commissioning and operational and decommissioning phases. The potential significance of these impacts upon air quality and meteorology at the site is assessed with reference to the methodology presented in Section 5 Impact Assessment Methodology with the sensitivity of the impacted resource / receptor also taken into account. The Project will be represented as two separate sites within the same domain. The first consists of the Mining area and the second the Chemical Complex, comprised of the beneficiation area, sulphuric and phosphoric acid plants.

Based on available data, the contributions from each Project site component were compared to the existing air quality conditions to determine the overall impact of the Project on air quality. The IFC require that emissions do not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards or in their absence, the current WHO Air Quality Guidelines or other internationally recognized sources. As a result, this analysis relies on PME standards for determining Project impacts.

Additionally, Project analysis has been conducted in accordance with the IFC’s Performance Standards and the Equator Principles related to GHG emissions requirements. Project consistency with Equator Principle 2 and IFC Performance Standard 3 are included in this analysis.

The methodology adopted for this assessment and proposed mitigation measures for each impact are summarized in the following sections. The detailed dispersion modelling methodology and results obtained are presented in Appendix D.

6.4.2 ASSESSMENT METHODOLOGY

6.4.2.1 CONSTRUCTION PHASE

The assessment of construction phase impacts on air quality and climate considers fugitive emissions such as dust and vehicle emissions that will arise primarily during construction of the Chemical Complex. Dust emissions will be generated from road traffic on un-metalled roads, earth clearance operations, and wind driven ‘site erosion’ typical of a site of this nature.





The US EPA AP42 methodologies were used as the basis of the assessment for the construction phase.

6.4.2.2 COMMISSIONING AND OPERATION PHASES

This Section considers the emissions from point sources and fugitive air emissions which will be generated as a result of the operation of the proposed Mine and Chemical Complex sites. To inform the impact assessment for this Project phase, air dispersion modelling was undertaken to represent point source emissions and model outputs compared with PME standards. The approach taken for this analysis was to assess the projected point source emissions for each site individually, as well as fugitive emissions resulting from activities at each site and then to present the combined total emissions for the site. For fugitive emissions, US EPA AP42 was used primarily to estimate dust emissions from activities at the site, EU and EPA approaches are used to estimate fugitive emissions from vehicles at the site.

Version 8.2 of the American Meteorological Society / US-EPA AERMOD model was used to generate Project emissions. AERMOD is a new generation atmospheric dispersion model developed by a working group comprising of scientists from the American Meteorological Society (AMS) and the U.S Environmental Protection Agency (USEPA). AERMOD incorporates the following modules:

• Building Profile Input Program (BPIP), designed to determine the important buildings for each stack in ten degree wind directional increments, following the Good Engineering Practice (GEP) Stack Height and Building Downwash guidance (USEPA, 1985).

• AERMET meteorological pre-processor designed to calculate meteorological variables used in air dispersion modelling assessments from a variety of formats of data reported worldwide

• AERMAP Terrain pre-processor used to include the effects of the Complex terrain in the model. Though this module was not applied in this study as there were no appreciable terrain gradients (> 1:10) in the areas were maximum concentrations occurred.

Background concentrations for the site were developed based on SRK 2000 data and the diffusion tube data input into the AERMOD model as this is a more extensive dataset. Details of the background concentrations used are detailed in Table 6-10 above. Background concentrations are presented in the analysis as combined with the Mine, the Complex, and with the combined Project.

The Chemical Complex will be represented as a series of point source, area and line emissions in the model, to represent identified stacks, road, railway lines and fugitive emissions from identified areas of the site. Because there are no point source emissions from the mining area, the Mine will be modelled as a series of fugitive emissions from the area footprint of the Mine. Individual emission sources, point or fugitive, will be assigned to one of two source groups, Mine or Complex, thus allowing the peak air concentrations arising from each area to be identified, the process contribution (PC) identified and compared to relevant AAQS. Total predicted environmental concentration (PEC) in air is calculated by combining the PC with the ambient background concentrations.

Results are presented for both the Mine and the Chemical Complex as well as combined air emissions from all sources. Air emissions were also modelled for sensitive receptor locations, including one in Turaif, one on the border of Jordan at the point closest to the Mine, and one in the proposed residential area located in Waad Al Shamal city.

6.4.2.3 DECOMMISSIONING

At the end of operational lifespan of the Industrial Complex and it is assumed that equipment will be dismantled and salvaged using the best available techniques at the time of decommissioning. Usable materials should be salvaged for recycling or reuse while hazardous and toxic waste shall be disposed of according to PME regulations.





6.4.3 CONSTRUCTION IMPACTS

6.4.3.1 INTRODUCTION

Construction activities could negatively impact air quality on the Project site. Specific potential impacts on the air quality environment due to construction are summarised in Table 6-10 and discussed in the following text.

Table 6-10: Construction Phase Impacts Assessment

Factor AQ1 AQ2

Receptor Importance / Sensitivity

Low Low

Frequency Continuous Continuous

Likelihood Likely Likely

Extent Local Local

Duration Short Short

Magnitude Medium Medium

Effect Negative Negative

Action Direct Direct

Significance Low Low

6.4.3.2 IMPACTS FROM CONSTRUCTION DUST EMISSIONS

Heavy construction activities are expected to generate dust emissions that may have a substantial temporary impact on local air quality. Dust generation is likely to be particularly significant in a dry environment such as that of Saudi Arabia.

As described in Section 3 – Detailed Description and Layout of the Proposed Development, planned construction is to occur over a 3 year period starting in 2013. Construction work will involve soil disturbance and movement, concrete mixing, excavation, compaction and piling.

Table 6-11 outlines the potential emission calculations with and without mitigation. Below are the parameters derived for calculating dust emissions relevant to site clearance and construction activities assuming recommendations such as those outlined in Section 6.7.2 of the ESIA. Exact construction equipment to be utilised for the Project is not known at this time, but Table 6-11 below is indicative of the type of construction equipment and resulting construction dust that would be generated by the Project.





Table 6-11: Construction Dust Emission Calculations 1 Truck Unloading (veh/hr) 35 Estimated maximum truck flow Truck Volume (Mg) 10 Estimated Total Material Handling (Mg/hr) 350 Calculated Dust mitigation efficiency (%) 75 For four times daily watering

TSP emission rate (kg/hr) 0.38

Calculated based on AP-42 Table 11.9-4, Refer to Equation (1)

2 Truck Loading 2-way truck flow (veh/hr) 40 Estimated maximum truck flow Truck volume (Mg) 10 Estimated Total material handling (Mg/hr) 200 Calculated Dust mitigation efficiency (%) 75 For four times daily watering



3 Bulldozing Moisture content (%) 7.9 Mean value from AP-42 Table 11.9-3 Silt content (%) 6.9 Mean value from AP-42 Table 11.9-3 Dust mitigation efficiency (%) 75 For four times daily watering



4 Vehicle traffic on unpaved road Silt content (%) 4.3 Mean value from AP-42 Table 11.9-3 Moisture content (%) 2.4 Mean value from AP-42 Table 11.9-3 Average weight of vehicle (Mg) 36 Estimated 2-way truck flow (veh/hr) 100 Estimated maximum truck flow Average one-way travel distance w/in the site 0.7 Estimated Dust mitigation efficiency (%) 75 For four times daily watering Dust reduction due to speed control (%) 50 Speed limit reduced to 10 km/hr

TSP emission rate (kg/hr) 4.5 Calculated based on AP-42 Sec

13.2.2, Refer to Equation (4) 5 Site erosion TSP emission rate (Mg/ha/yr) 0.85 AP-42 Table 11.9-4 Total site area (m2) 21,000 Estimated Percentage exposed active work area 50 Estimated Dust mitigation efficiency (%) 75 For four times daily watering


Calculated

Total TSP emissions (unmitigated) 5.53 kg/hr 5.3e-5 g/s/m 2

Source: Jacobs, 2013

Equation 1 TSP emission rate (kg/hr) = 0.001 (Total material handling) (Mg/hr) Equation 2 TSP emission rate (kg/hr) = 0.018 (Total material handling) (Mg/hr) Equation 3 EF = 2.6(s)1.2/(M)1.3100 Equation 4 E = k(s/12)a(W/3)b / (M/0.2)c

s = silt moisture content W = mean vehicle weight M = surface material moisture content (%) Constant for TSP; k=10; a=0.8; b=0.5; c=0.4

Conversion: E = E(281.9)Veh(L) E = TSP emission rate (kg/hr) Veh = 2-way truck flow L = Ave one way travel distance w/site 1 lb/VMT = 281.9 g/VKT 1 kg = 2.2 lb





Existing dust levels are already high and construction can be expected to substantially contribute to dust levels on the Project site, however construction would add little to existing dust levels outside the property boundary. Therefore, construction dust impacts are considered to be of low significance.

Impact AQ1 –Low Significance

6.4.3.3 IMPACTS FROM CONSTRUCTION EXHAUST EMISSIONS

Vehicles and large construction machinery operating during construction are sources of gaseous exhaust emissions, including NOx, CO, PM10 and hydrocarbons. As described in Section 3 – Detailed Description and Layout of the Proposed Development, planned construction is to occur over a 3 year period starting in 2013, during which time the number of trucks arriving at the Project area be approximately 110per day in the peak period.

Although vehicle exhaust emissions will be released close to ground level (i.e. close to the breathing zone of receptors), these emissions will generally be released in open areas where rapid dispersion and dilution will occur. Thus, the maximum concentrations are expected at or near each facility rather than the site boundary. In addition, such emissions will be limited to the duration of the construction phase.

The magnitude of exhaust emissions associated with construction activity is likely to be low outside the Project site and high near the construction area. NOx and CO concentrations from exhaust emissions during construction were projected to be of low magnitude when added to the baseline. However, overall PM10 and PM2.5 levels are expected to be high due to the high existing background levels recorded at the AQMS, even though the contribution from the Project is considered minimal.

Existing PM10 levels are already high and exhaust emissions from construction would further contribute to PM10 levels on the Project site, but would add little to existing PM10 levels outside the property boundary. Therefore, impacts from exhaust emissions during construction are considered to be of low significance. Impact AQ2 –Low Significance

6.5 COMMISSIONING AND OPERATIONS

6.5.1 INTRODUCTION

Impacts during the commissioning and operations phase include exhaust emissions from vehicles, emissions from operations of the beneficiation plant, the phosphoric acid plant (PAP), emissions from the sulphuric acid plant, cooling tower emissions, and emissions from the Mine area. Impacts are discussed below by pollutant. Specific impacts on air quality due to operational activities are summarised in Table 6-12 and discussed in the following text. A discussion of fugitive emissions for the Complex and radiological impacts from uranium exposure are also included. Table 6-12: Operational Phase Impacts Assessment Factor AQ3 AQ4 AQ5 AQ6


Low Low Low Low

Frequency Continuous Continuous Continuous Continuous

Likelihood Likely Likely Likely Likely

Extent Local Local Local Regional

Duration Medium Medium Medium Medium

Magnitude Low High Low High

Effect Negative Negative Negative Negative

Action Direct Direct Direct Direct

Significance Low Low Low Low





Factor AQ7 AQ8 AQ9


Low Low Low

Frequency Continuous Continuous Continuous

Likelihood Likely Likely Likely

Extent Local Local Local

Duration Medium Medium Medium

Magnitude High High High

Effect Negative Negative Negative

Action Direct Direct Direct

Significance Low Low Low

6.5.2 OPERATIONAL IMPACTS

Figure 6-3 shows a lay out of the proposed Project site including the proposed Mining area and the Chemical Complex site. For this analysis, impacts during the commissioning and operations phase will be described in three parts, those attributable to the Chemical Complex, those attributable to the Mine, and a discussion of the combined impacts on the site.





Figure 6-3: Umm Wu’al Project Layout

6.5.2.1 CHEMICAL COMPLEX

The Chemical Complex site will be comprised of industrial buildings including: tanks, conveyors and pipetrains of varying sizes. Buildings with a significant height in the vicinity of an air emission source can substantially modify the dispersion characteristics of the emissions, usually interfering with dispersion and reducing its effectiveness. Typical US EPA guidance for dispersion modelling is to include all buildings within a factor of 2.5 times of the stack release height. For this analysis, all significant structures or groups of structures proposed were included within the model, based on the latest Chemical Complex plot plan (as of March 2013). For the Complex modelling, the nominal release height for the STTP Scrubber stack has been increased to 25m to allow discharges above the enclosing steel work. This will be subject to design review as the Project progresses. All buildings included are shown in





Table 6-13 and Figure 6-4.





Table 6-13: Buildings Included in Air Quality Modelling f or the Chemical Complex

Structure (or group of structures)

Number Average Maximum Height (m)

Beneficiation plant Modelled as 1 area

20

Beneficiation clarifier 1 10 Sulphuric acid plant 3 30 Phosphoric acid plants 3 20 PAP feeder tanks Modelled as 1

area 15

PAP drying and storage Modelled as 1 area

15

Sulphuric acid tanks 6 18 Tank and storage area 1 18 PPA plant 2 12 Power plant 1 30 MCP/DCP plant 2 25 Warehouse 1 1 18 Warehouse 2 1 12

Source: Jacobs, 2013 Figure 6-4 is a 3-D representation of buildings and sources at the chemical Complex site within AERMOD viewed from the west.

Figure 6-4: Proposed Chemical Complex Buildings in a 3D Re presentation of the Site in AERMOD

Fugitive emissions for the Project were modelled based on US EPA AP42 guidance. The methodologies for each emissions source are described in detail in Appendix D. The fugitive emissions from each area described are summarised in





Table 6-14.These fugitive sources were simplistically modelled as six area and one line source, defined by the footprints of the areas of site where these activities take place.





Table 6-14: Projected Maximum Fugitive Emissions from Com plex

Description Area (m2)

Activities Emissions (g/s)

AREA1 Phosphogypsum Storage Facility (PSF)

6.00E+6 Unloading of material from conveyor from PAP and beneficiation plant

Truck unloading in waste area

0.052(PM10)

AREA2 Beneficiation area

5.50E+5 Unloading of ROM from conveyor

Loading of conveyor to PAP

Loading of conveyor to Tailings Storage Facility

0.018 (PM10)

AREA3 Cooling tower 3.50E+3 Area emissions of dust from cooling tower

5.0e-5 (PM10 )

LINE1 Fugitive emissions from railway sidings

2.7E+4 Locomotive emissions in sidings

0.0083 (PM10)

0.014 (VOC)

0.52 (NOX)

0.13 (CO)

AREA4 Tailings Storage Facility (TSF)

4.56E+6 Unloading of material from conveyor

Truck unloading in waste area

0.042 (PM10)

AREA5 Site area for fugitive vehicle emissions

2.10E+06 Vehicle emissions from transport and truck deliveries to chemical Complex

0.0017 (PM10)

0.0049 (VOC)

0.05 (NOX)

0.036 (CO)

AREA6 Fugitive emissions from diesel and MIBK tanks

6.00E+03 Emissions from 2 diesel tanks and 1 MIBK tank

0.015 (VOC)

AREA7 PAP dust area source

1.50E+05 Unloading of conveyor from beneficiation

Loading of conveyor to PSF

0.0041 (PM10)

Note: Following design change introducing wet stack in preference to dry stack the fugitive (dust) emissions generated by the transportation of slurried phosphogypsum (rather than dry), will be reduced at the PSF. Modelling has not been re-run, as the modelled scenario is considered to be conservative for the updated wet stack design.

The stack parameters, tanks and area sources in each of the units depicted above and the pollutant emissions rates used in the modelling analysis are presented in Appendix D. Emissions from the proposed Chemical Complex facility including the fugitive emissions above have been modelled for NO2, CO, SO2, PM10, VOC, and HF. The modelling results for the 6 pollutants from the Chemical Complex are included in Table 6-15. The Table shows the





peak air concentration averaged over the period of the relevant ambient air quality standard. Results are compared to the PME standards. Any exceedances are represented in bold.

The combined contributions resulting from all proposed Project facilities are summarised below in Table 6-19 for 2009. The combined impacts of both the Mine and Chemical Complex are discussed on a pollutant-specific basis.

Table 6-15: Maximum Modelled Stack Discharge Concentratio ns for Criteria Pollutants at the Chemical Complex (µg/m 3)

PME AAQS 2008 2009 2010 2011 2012

NOX 1H3H 660 389 376 453 408 375 NOX annual 100 17.6 12.6 18.2 17.6 17.9 CO 1H3H 40000 100 98.1 117 106 98.2 CO 8H3H 10000 32.7 27.8 26.9 24.9 25.1 SO2 1H3H 730 540 548 553 552 555 SO2 24H2H 365 150 140 152 142 146 SO2 Annual 80 42.3 43.8 42.5 42.3 38.7 PM10 24H1H 340 197 196 318 233 165 PM10 annual 80 16.7 16.5 20.1 16.4 15.1 VOC 3H1H 160 60.3 38.2 39.7 40.1 28.2 HF monthly* 1 0.48 0.55 0.50 0.51 0.42

Source: Jacobs, AERMOD, 2013 Note: All results are µg m-3

* RC standard as no PME standard for HF

The results show that PCs for all pollutant emissions from the Project are within PME ambient air quality standards.

Fugitive emissions associated with the Complex consist of:

• Loading/Unloading from the conveyor in the beneficiation area;

• Locomotive emissions;

• Emissions from diesel storage tanks;

• Loading/unloading at the Phosphogypsum storage

• Vehicle emissions from cars/coaches/trucks on the site;

• Waste storage ;and

• Area emissions of dust from cooling tower.

6.5.2.2 MINING AREA

The mining area is comprised of the following activities that contribute to fugitive PM10 emissions:

• Blasting;

• Loading material onto trucks;

• Driving tuck to crushing area;

• Unloading from truck at crushing area;

• Crushing/sizing;

• Loading onto conveyor for transport to Beneficiation area in the Phosphate plant;

• Loading waste onto truck for return to mining area;

• Driving truck to waste tipping area; and

• Unloading Mine spoil from truck at infill area.





The fugitive emissions associated with the Mine are summarized in Table 6-16. Additionally the area includes heavy equipment that would also result in fugitive emissions. All sources of fugitive emissions have been included in the Project totals shown in Table 6-19.

Table 6-16: Projected Maximum Fugitive Emissions from Min e

Description Area (m2) Activities Emissions (g/s)

AREA1 Crushing Area

2.00E+5 Unloading of mined ore from trucks.

Crushing activities

Loading of ROM onto conveyor

0.31 (PM10)

PAREA1 Mining Area 3.72E+7 Dust from blasting

Emissions from explosives

Loading ore onto trucks

Driving trucks on unpaved roads

Vehicle emissions from Mine machinery and trucks

Unloading of waste from trucks

27.37 (PM10)

1.64 (VOC)

17.8 (NOX)

3.77 (CO)

PAREA2 Mine Maintenance Area

1.50E+6 Emissions from 1 diesel tank 0.0047 (VOC)

Source: Jacobs, 2013 In addition NOX, CO and PM10 VOC fugitive emissions will arise from the operation of trucks and other site machinery and fugitive VOCs would arise from diesel/oil tanks in the Mine maintenance area. The modelling results for the 6 pollutants from the mining area are included in Table 6-17.

Table 6-17: Maximum Modelled Stack Discharge Concentratio ns for Criteria Pollutants at the Mine (µg/m 3)

PME

AAQS 2008 2009 2010 2011 2012

NOX1H3H 660 233 233 233 232 233 NOX annual 100 7.5 7.1 8.5 7.7 6.5

CO1H3H 40000 388 384 386 391 378 CO8H3H 10000 204 231 258 214 156

SO2 1H3H 730 8.3 8.2 8.3 8.4 8.1 SO224H2H 365 2.4 1.8 2.5 2.4 1.5 SO2 Annual 80 0.13 0.13 0.17 0.13 0.11 PM10 24H1H 340 155 120 218 165 124 PM10 annual 80 10.5 10.0 12.2 10.8 9.4 VOC 3H1H 160 43.3 43.5 43.6 45.1 36.1 HF monthly* 1 0 0 0 0 0

Source: Jacobs, AERMOD, 2013 Note: All results are µg m-3


The modelling results show that all of the mining operations would be within PME standards.





6.5.2.3 PREDICTED COMBINED CONCENTRATIONS FROM BOTH SITES

The predicted air emissions concentrations resulting from either site are shown in Table 6-18. No year is noticeably the “worst case” for all pollutants, reflecting the multiplicity of pollutants and sources in the Complex site covered in this Project. 2009 is used as a typical year for further analysis of results below.

The concentrations shown include Project contributions from both site and background air concentrations (data from the SRK 2000 report and on site diffusion tubes). The AERMOD post-processor takes the hourly results data and combines these with the hourly background air concentration to provide a better indication of the actual air concentration than that achieved by simply adding an average background level. Exceedances are shown in bold. The “Total” column is the total peak concentration observed including contributions from all sources such as road traffic.

Table 6-18: Combined PECs from the Mine and Complex (µg/m 3)

PME

AAQS Mine

Mine+ Bkg

Complex Complex +

Bkg Total inc.

Bkg NOX 1H3H 660 233 342 376 485 606 NOX annual 100 7.1 13.1 12.6 18.6 50.3

CO 1H3H 40000 384 384 98.1 98.1 384 CO 8H3H 10000 231 231 27.8 27.8 231 SO2 1H3H 730 8.2 69.4 548 622 622 SO2 24H2H 365 1.8 26.9 140 165 165 SO2 Annual 80 0.13 5.2 43.8 48.9 48.9 PM10 24H1H 340 120 2099 196 2175 2175 PM10 annual 80 10.0 72 16.5 78.5 78.5 VOC 3H1H 160 43.5 43.5 38.2 38.2 43.5 HF monthly* 1 0 0 0.55 0.55 0.55

Source: Jacobs, AERMOD, 2013 Notes: Background data for NOx is the Gradko tube results factored by 6.8 for hourly standard

NB no background data for VOC or HF, Note: All results are µg m-3


The inclusion of background ambient air concentration data shows the domination of background data for PM10 by local dust storm events in the area, which exceeds any industrial contribution. Contour plots for each pollutant are shown below.

Pollutant levels form the combined Mine and Complex sites are shown in Table 6-19 for 2009 at nominated sensitive receptors. Pollutant levels are compared to PME standards. IFC/WB standards are also shown for informational purposes for comparison to emissions levels at the international border with Jordan. Violations of PME standards are shown in bold. All pollutant levels are within the PME AAQSs, with the exception of PM10 levels. As noted above under background concentrations, this is largely due to dust storm events.

Table 6-19: PECs from the Project at discrete receptors ( µg/m 3)

Discrete Receptors NOX 1H3H

PM10 24H1H

HF 1M1H

SO2 1H3H

CO 1H3H

VOC 3H1H

PME AAQS (IFC/WB Standards)

660 (200) 340 (50) 1 730

(500) 40000 160

Turaif (17km south west of the site) 159.6 1986 0.0019 118 26.47 1.8

The border with Jordan at the closest point to the mine 144 2029 0.0012 74.4 273 23.1

The proposed residential area close to site 239 2005 0.0051 144 74.2 5.5

Source: Jacobs, AERMOD 2013 Note: All results are µg m-3, *Since PME has no HF standard, RC standard for HF is used NB no background data for CO, VOC or HF





6.5.2.4 IMPACTS FROM NOX

Air concentrations of nitrogen oxides are compared to the hourly and annual standards in Table 6-18. Maximum combined site hourly emissions including background concentrations were 606µg m-3 for 2009. This is under the PME AAQS of 660 µg m-3. Annual NOx emissions were 50.3µg m-3, which is also within PME standards.

Contour plots of the hourly averaged NOx results from AERMOD for the Complex and the Mine in 2009 are included in Figure 6-5. Therefore, impacts were considered to be of low significance.

Complex





Mine

Source: Jacobs, AERMOD 2013

Figure 6-5: Contour plots of 1H3H PC for NOX(µg/m 3) (2009)


6.5.2.5 IMPACTS FROM CO

Air concentrations of carbon monoxide are compared to the hourly and eight hour standards in Table 6-18. Maximum hourly emissions for the Project were 384 µg m-3 and eight hour emissions were µg 231 in 2009. These are considerably lower than the relevant AAQS’s of 40000µg m-3and 10000µg m-3respectively. This demonstrates that the Project would be compliant with the relevant environmental regulations. Contour plots of the hourly averaged CO results for 2009 of the Complex and the Mine are included in Figure 6-6 demonstrating that concentrations were highest immediately adjacent to the Complex. Impacts were considered to be of low significance.





Complex

Mine Source: Jacobs, AERMOD 2013

Figure 6-6: Contour plots of 1H3H PC for CO(µg/m 3) (2009)






6.5.2.6 IMPACTS FROM SO2

Air concentrations of oxides of sulphur are compared to the hourly and 24 hour standards in Table 6-18. Maximum hourly emissions were 622 µg m-3 and 24 hour emissions were 165 µg m-3 in 2009. Annual emissions were 48.9 µg m-3for the combined Project plus the background in 2009. Maximum concentrations were well below the 730 µg m-3 (hourly), 365 µg m-3 (24-hourly) and 80 µg m-3 (annual) AAQS’s, demonstrating that the site would be well within the relevant environmental regulations.

A contour plot of the hourly averaged SO2 results for 2009 of the Complex is included in Figure 6-7. No SO2 emissions would be associated with mining operations. Based on all of the above, impacts to SO2 were considered to be of low significance.


Figure 6-7: Contour plots of 1H3H PC for SO 2 (µg/m 3) (2009)






6.5.2.7 IMPACTS FROM PM10

Project generated air concentrations of Particulate Matter (PM10) are compared to the 24-hourly and annual standards in Table 6-18. Maximum concentrations were 2175µg m-3 (24-hourly) and 78.5 µg m-3 (annual) for 2009. This is above the relevant PME AAQS of 340 µg m-3, but within the 80 µg m-3 annual standard. However, the existing PM10 values were found to be higher than the AAQS’s, demonstrating that high regional background PM10 concentrations are leading to exceedances of the relevant environmental regulations.

A contour plot of the 24-hourly PM10 concentrations at the Mine in 2009 is included in Figure 6-8.


Note - The scale on the graph in Figure 6-8 is 1-tenth of the calculated concentration

Figure 6-8: Contour plot of 24H1H PC for PM 10 at the Mine (µg/m 3) (2009)

Given the high baseline concentrations, no amount of mitigation on point source PM emissions (which are relatively low) will reduce the general PM10 issue in the local environment. Therefore, PM10 impacts are considered to be of low significance.






6.5.2.8 IMPACTS FROM HF

Air concentrations of HF are compared to the monthly RC fluoride standards in Table 6-18. Maximum monthly µg m-3 emissions were 0.55. These are below the RC AAQS of 1 per month. The results demonstrate that the site would be within the relevant environmental regulations.

A contour plot of the monthly averaged HF results for 2009 of the plant is included in Figure 6-9, demonstrating that concentrations would be highest immediately adjacent to the Complex. NO HF emissions would be generated by the Mine. Therefore, Project impacts on HF would be considered of low significance.


Figure 6-9: Contour plot of monthly average HF at the Comp lex






6.5.2.9 IMPACTS FROM VOCS

Air concentrations of VOCs are compared to the one hour PME standards in Table 6-18. Maximum hourly emissions were .43.5µg m-3. These are well below the PME AAQS of 160 µg m-3 per hour. The results demonstrate that the site would be within the relevant environmental regulations.

A contour plot of the monthly averaged VOC results for 2009 of the Complex is included in Figure 6-10, demonstrating that concentrations would be highest immediately adjacent to the Complex. Therefore, Project impacts on VOCs would be considered of low significance.


Figure 6-10: Contour plots of 1H3H PC VOC (µg/m 3) (2009)


6.5.3 RADIOLOGICAL IMPACTS

Phosphate ore tends to have relatively higher concentrations of uranium and so a screening radiological assessment was undertaken to assess likely doses to workers at the mine exposed to dust generated there and to the raw material in-ground. If these doses are judged to be acceptable then those resulting from offsite movement will be no worse, since the same material is involved (assuming soil/sand is derived from the underlying rock) and concentrations will only decrease by dilution as the rock is processed. The assessment considered doses resulting from inhalation of dust and from external irradiation from the rock and soil.

Experience shows that the main environmental problem associated with tailings waste is due to leaching of radionuclides into surface and ground waters. The two waste stores associated with the Project are designed to best practice and will be lined and bunded, allowing control of leachate to be maintained. In the arid environment around Umm Wu’al infiltration into the stack and hence potential for leaching will be low.





The assessment undertaken is a conservative one based on the concentration of all radionuclides (including all daughter radionuclides at secular equilibrium) in the original ore. It is assumed there is no chemical concentration of the final form of the waste is involved (there is additional of significant quantities of inert material as part of the waste management process). It is recognised that as a result of the acidification process, that there is a partial geochemical separation of the uranium and radium isotopes. However, this is unlikely to result in an increase in concentration, since additional inert material will be added as part of the post-processing which bulks the concentrations back to the initial values. This can be seen in the geochemical characterisation report (MD-510-0000-PM-GE-RPT-0012) there is little change in uranium concentration between the rock and the tailings waste. Obviously, well documented observations that concentrations in phosphogypsum stacks are higher than local soils are implicit from this due to the derivation of this material from phosphate ore with elevated radionuclide concentrations. Concentrations in tailings and phosphogypsum waste will not be significantly different to those measured in the rock and so this assessment will also cover exposures in those areas as well

Results of the assessment are shown in Table 6-20 for the three natural series described above. The total dose from exposure to radionuclides by inhalation of dust or by external exposure to the soil whilst standing upon it is 125 µSv/yr. This is lower than typical average exposure to background radiation of ~2 mSv/yr (UNSCEAR, 2008). The actual exposures at the site are likely to be even lower as a very conservative assumption on dust in air has been made for the assessment and it is likely that at those concentrations PE would be required, which would also reduce these doses. In addition, the external dose will be reduced as a result of shielding by the vehicle, in which it is assumed the majority of work will be undertaken. Therefore, Project impacts from radiological exposure are considered to be of low significance.

Table 6-20: Calculation of Radiological Dosage from Expos ure to Project Ore and Waste

Nuclide

Inhalation Dose co-efficient (Sv/Bq)

External dose co-efficient (Sv/y per Bq/kg)

Inhalation dose (Sv/y)

External dose (Sv/y)

Total (Sv/y)

Uranium238 series

U238 0.000008 2.99E-09 1.58E-06 4.21E-08 1.62E-06

Th234 7.7E-09 2.05E-08 1.52E-09 2.89E-07 2.91E-07

Pa234m 0 2.48E-08 0 3.5E-07 3.5E-07

Pa234 4E-10 3.84E-06 1.58E-13 1.08E-07 1.08E-07

U234 9.4E-06 3.81E-09 1.86E-06 5.37E-08 1.91E-06

Th230 0.0001 3.4E-09 1.98E-05 4.8E-08 1.98E-05

Ra226 9.5E-06 1.48E-08 1.88E-06 2.09E-07 2.09E-06

Rn222 1.3E-08 8.74E-10 2.57E-09 1.23E-08 1.49E-08

Po218 3.3E-09 2E-11 6.52E-10 2.82E-10 9.35E-10

Pb214 1.5E-08 5.49E-07 2.96E-09 7.74E-06 7.75E-06

Bi214 1.4E-08 3.21E-06 2.77E-09 4.52E-05 4.52E-05

Po214 0 1.83E-10 0 2.58E-09 2.58E-09

Pb210 5.6E-06 1.06E-08 1.11E-06 1.49E-07 1.26E-06

Bi210 9.3E-08 0 1.84E-08 0 1.84E-08

Po210 4.3E-06 1.87E-11 8.5E-07 2.63E-10 8.5E-07





Nuclide

Inhalation Dose co-efficient (Sv/Bq)

External dose co-efficient (Sv/y per Bq/kg)

Inhalation dose (Sv/y)

External dose (Sv/y)

Total (Sv/y)

Subtotal 2.71E-05 5.42E-05 8.13E-05

Uranium235 series

U235 8.5E-06 3.38E-07 7.83E-08 2.22E-07 3.01E-07

Th231 3.3E-10 5.6E-08 3.04E-12 3.68E-08 3.68E-08

Pa231 0.00014 1.05E-07 1.29E-06 6.87E-08 1.36E-06

Ac227 0.00055 5.07E-10 5.07E-06 3.34E-10 5.07E-06

Th227 0.00001 2.33E-07 9.22E-08 1.53E-07 2.45E-07

Ra223 8.7E-06 2.92E-07 8.02E-08 1.92E-07 2.72E-07

Rn219 0 1.23E-07 0 8.06E-08 8.06E-08

Po215 0 3.87E-10 0 2.54E-10 2.54E-10

Pb211 1.2E-08 1.1E-07 1.11E-10 7.26E-08 7.28E-08

Bi211 0 1.02E-07 0 6.73E-08 6.73E-08

Tl207 0 4.85E-09 0 3.19E-09 3.19E-09

Subtotal 6.61E-06 8.97E-07 7.51E-06

Thorium232 series

Th232 0.00011 2.92E-09 7.16E-06 1.36E-08 7.18E-06

Ra228 0.000016 8.79E-15 1.04E-06 4.08E-14 1.04E-06

Ac228 2.5E-08 2.04E-06 1.63E-09 9.49E-06 9.49E-06

Th228 0.00004 7.25E-09 2.61E-06 3.37E-08 2.64E-06

Ra224 3.4E-06 2.17E-08 2.21E-07 1.01E-07 3.22E-07

Rn220 0 8.46E-10 0 3.93E-09 3.93E-09

Po216 0 3.71E-11 0 1.73E-10 1.73E-10

Pb212 1.9E-07 3.25E-07 1.24E-08 1.51E-06 1.52E-06

Bi212 3.1E-08 4.06E-07 2.02E-09 1.89E-06 1.89E-06

Po212 0 0 0 0 0

Tl208 0 7.38E-06 0 1.23E-05 1.23E-05

Subtotal 1.11E-05 2.54E-05 3.64E-05

Total 4.47E-05 8.05E-05 1.25E-04

Source: Jacobs 2013


6.6 GREENHOUSE GAS EMISSIONS

6.6.1 INTRODUCTION

CO2 emissions associated with the Project could also result in negative impacts upon global greenhouse emissions. Specific potential impacts on the air quality environment due to the greenhouse gas emissions are summarised in Table 6-21 and discussed in the following text.





Table 6-21: Greenhouse Gas Emissions Impacts Assessment

Factor AQ10

Receptor Importance / Sensitivity Low

Frequency Continuous

Likelihood Likely

Extent International

Duration Long

Magnitude High

Effect Negative

Action Direct

Significance Low

6.6.2 GHG IMPACT ASSESSMENT

As described in the Section 2 – Policy, Legal and Administrative Framework, the proposed Project is subject to the Equator Principles and the IFC Performance Standards. As such, Principle 2 and IFC Performance Standard 3 include requirements for resource efficiency and pollution prevention. This includes the requirement to minimize the Project impacts upon greenhouse gas emissions. According to the Equator principles, Principle 2, if the Project is expected to emit more than 100,000 Metric tonnes of CO2 equivalent annually, an alternative analysis to evaluate less greenhouse gases (GHG) intensive alternatives is required.

The International Energy Agency (IEA) has estimated the total CO2 emission in KSA was 446 Million Metric tonnes in 2010 (IEA, 2012). Of this total, 104 Million Metric tonnes were from manufacturing and industry. The proposed Project is anticipated to generate CO2 emissions through industrial and mining operations. Construction vehicles would also be a source of CO2 emissions, however, these emissions would be temporary and are not included in the discussion below. Energy use from the emergency diesel generator is also excluded from this discussion as it is only operational in emergencies. Table 6-22 shows the total Project CO2 emissions associated with Project operations primarily from the chemical complex, with a small portion from the mine.

Table 6-22: Total GHG Emissions by Source Category

Source Type MW Distance Travelled

Annual MT CO 2 Emissions

Auxiliary Boiler 4 700

Heavy Equipment at the Mine 4.45 2,000

Trains 6,400 km per day 3.8

Operational Vehicles 39,300 km per day 2.2

MCP/DCP 60,000

STPP 15,000

Total 77,706

Source: Jacobs, 2013. The following calculations are based on Table 2.12 and Table 2.15 of the U.S. Department of Energy’s Transportation Energy Data Book (Davis 2012) and the UK EA GHG emission factors paper. Operational CO2 emissions calculations are based on FEED data. Represents the ‘worst case’ operational scenario.

Notes: MW=Megawatts MT= Metric tonnes





As described in the Section 4 – Detailed Description and Layout of the Proposed Development, energy consumption has been minimized wherever possible throughout all phases of the operational life of the Project. The Sulphuric Acid Plant is designed as a ‘Double Conversion – Double Absorption Contact Process’, which means that it generates high pressure steam that is expected to be able supply the total power (electricity) requirement for the Umm Wu’al site. Therefore, the Project would not increase total energy demand.

The total estimated CO2 emissions that would be generated by the Project including operations and vehicle emissions would be 77,706 MT. Therefore, emissions associated with the proposed facility are not expected to significantly incrementally impact global greenhouse gas emissions.


6.7 MITIGATION

6.7.1 OVERVIEW

In accordance with the methodology established in Section 5 – Impact Assessment Methodology, mitigation measures are to be implemented to minimise potential negative impacts of the activities on the air quality, including construction dust and operational emissions. The impact assessment has identified no negative impacts of medium or high significance; however, recommendations can be made to apply good management practice and mitigate those negative impacts identified of low significance.

6.7.2 CONSTRUCTION RECOMMENDATIONS

The EPC Contractor shall develop, implement and maintain a construction phase Environmental Emergency Response Plan (EERP) and a Construction Environmental Management Plan (CEMP) as based on the Environmental Management and Monitoring Plan (Appendix A of this ESIA). These plans should detail responsibilities and procedures for environmental and emergency response management during construction, including:

• Cover of all dust generating materials being moved by truck,etc., with a suitable weighted tarpaulin;

• Establish pedestrian routes within the construction area to be used by workers;

• Minimisation of the amount of materials stockpiled as far as is practicable, with any required stockpiles aligned parallel to the prevailing wind direction ;

• Cover of exposed soils in heavily trafficked areas such as roads or car parks and dust generating stockpiles where feasible with gravel or crushed stone to reduce wind blown dust generation;

• A reduced construction site speed limit to prevent the generation of large dust clouds form vehicles;

• Subject to water availability and the time of the year, surface spraying of road surfaces with water and a soil binding agent;

• Periodic grading of any uneven surfaces that arise on construction traffic routes;

• Routing of pedestrian areas away from dust generating areas; and

• Implementation of a monitoring programme to verify construction vehicles comply with regulations.

6.7.3 COMMISSIONING AND OPERATIONS RECOMMENDATIONS

The site operator shall develop, implement and maintain an Environmental Emergency Response Plan (EERP) and Environmental Management and Monitoring Plan (EMMP) for the operational phase, to further protect against impact of local air quality. These plans should detail responsibilities and procedures for environmental and emergency response management during operation, including:

• Emissions monitoring and reporting to relevant authorities;





• Appropriate maintenance of important mitigation equipment such as scrubbers, catalyst beds etc.;

• Competencies and training requirements of staff with environmental responsibilities, and lines of communication in the event of an emergency (including accidental releases of hazardous substances);

• Minimizing use of auxiliary and back up boilers;

• Minimisation of stockpiled materials, provision of suitable cover for potentially dust generating materials, and consideration of aligning stockpiles parallel to the prevailing wind direction;

• Damping down of roads, and storage areas for dust suppression, and periodic grading of uneven surfaces;

• A reduced site speed limit to prevent the generation of large dust clouds form vehicles;

• Monitoring of dust suppression measures used on the tailings and phosphogypsum storage areas;

• Monitoring and maintenance of dust extraction systems to ensure effectiveness; and

• Regular audits of the above management plans to confirm their ongoing effectiveness.

Prior to commencement of operations, ambient air quality data should again be gathered and such data sets built on during the course of operations.

Further more detailed recommendations are included in the Operational Implementation Plan within the Environmental Management and Monitoring Plan included in Appendix A.





7.0 TERRESTRIAL ENVIRONMENT

7.1 INTRODUCTION

This section presents the findings of the terrestrial environment baseline review and the likely impacts on the terrestrial environment arising from the Project. The assessment addresses regional and local geological and hydrogeological conditions, characterises the soil and groundwater quality as well as groundwater resources issues, and assesses potential impacts on receptors. Baseline conditions and related impact assessment for surface water are provided in Section 11 – Surface Water Management. Surface water information is only presented in this chapter where it relates to the groundwater environment or local soils. Similarly, any impacts on the terrestrial environment relating to dust are covered in Section 6 - Air Quality & Meteorology.

The Umm Wu’al area is part of an extensive gently undulating and relatively featureless, wind-swept Al Hamad gravel plain. Undulations in topography are reflected in a 20 m difference in elevation across the whole Umm Wu’al Mine with the surface elevation approximately 860 m above sea level. Most of the Umm Wu’al region is covered by a thin residual soil that has been periodically cut into by gentle dipping temporal water courses, known locally as wadis. The area is sparsely vegetated with vegetation being generally confined to the network of wadi flow channels. These are relatively minor channels within the phosphate deposit area and drain into a larger wadi flowing from the north to the south outside the western boundary of the deposit area (SRK, 2013c).

7.2 BASELINE CONDITIONS

7.2.1 INTRODUCTION

The terrestrial environment baseline conditions of the Project site have been established taking into consideration the geological and hydrogeological information collated by previous studies and field investigations carried out for the Project and other supporting local and regional information. The geological and hydrogeological baseline conditions have been determined through reference to existing literature, and the results of the SRK studies on mining, hydrology and hydrogeology / water supply (SRK 2004, 2013a, 2013b). These studies present information based on extensive literature searches and field investigations including:

• Data from the Al Jalamid wellfield and Saudi Aramco;

• Hydrocensus data collected in 2002, 2003, 2012 and 2013;

• Test and observation well works to assess water levels and hydraulic characteristics of the aquifer; and

• Water quality analysis on samples taken from the test and observation wells.

This data was used to update the Conceptual Site Model, and construct numerical models which predicted the local and regional impact of the required groundwater abstraction from a variety of wellfield layouts and locations.

A programme of soil sampling and testing was undertaken across the project site which included 101 shallow soil samples which were analysed for a range of chemical parameters to characterize the soil chemistry and identify occurrences of existing contamination.

7.2.2 REGIONAL GEOLOGY

The information regarding regional geology described in this section is derived from the Geological Map and Explanatory Notes of the Al Jawf Quadrangle (Meissner, et al., 1989) and description of the geology of the shield area of western Saudi Arabia (Brown, Schmidt and Huffman, 1989).





Figure 6-11: Extract of the stratigraphy of the regional g eology [Source: Based on a compilation by Brown, Schmidt and Huffman (1989)]

The solid geology of the Kingdom of Saudi Arabia is characterised by the Precambrian crystalline rocks of the Arabian Shield, which is overlain by thick Palaeozoic, Mesozoic and Tertiary sedimentary rocks, known as the Arabian Shelf (see Figure 6-11). These formations are generally composed of sandstones, limestones and shales. The sedimentary rock sequences are up to 10 km thickness in places.

The younger Tertiary rocks include notable phosphate bearing horizons, that can be laterally continuous over several hundred kilometres within the study area.

The regional structural geology is characterised by several geological structures. The study area is occupied by two sedimentary basins; the Wadi Sirhan Basin to the west and the Widyan Basin to the east. The basins are separated by the Ha’il arch, a major N-NW trending anticline.

The Sirhan Graben Fault and the Umm Wu’al Fault are found to the south-west of the study area. The furthest structure is the Sirhan Graben and consists of five north-west to south-east trending parallel faults approximately 100 km to the south-west of the study area. The Umm Wu’al Fault runs parallel to the Sirhan Graben Faults approximately 30 km to the south-west of the study area and it is the closest known structural discontinuity.

7.2.3 LOCAL GEOLOGY

Based on published information (Brown, Schmidt and Huffman, 1989) and the Project Mining Report (SRK, 2013a), the site is underlain by Tertiary rocks of the Turayf Group, comprising the Jalamid, Mira and the Umm Wu’al Formations. The Tertiary layers comprise interbedded carbonate rocks of limestones and dolomites, shales and phosphorites. The Tertiary formations also contain the phosphate bearing lithologies of the Al Jalamid mine, located to the east of the Project.

The Turayf Group is underlain by Cretaceous sedimentary sequences. The younger Aruma Formation is predominantly composed of argillaceous and horizontally interbedded limestones. The older Waisa Formation is characterised by horizontally bedded sandstones with general occurrence of siltstone and shale.

The Waisa Formation is underlain by the Supra-Jauf Formation of various lithologies, generally comprising sandstones, limestones and shales of Jurassic-Carboniferous age.

Umm Wu’al mining licence





Beneath the Carboniferous layers lies the Jauf Formation. This formation is composed of Early to Middle Devonian heterogeneous sedimentary rocks of sandstones, limestones and shales.

The Jauf Formation is underlain by fluvial sandstones of the Tawil Formation. The Tawil formation is characterised by medium to thick cross-bedded, well sorted quartz sandstones, with iron concentrations and iron cement in places. Minor interbeds of thin silty sandstone and shale generally occur in the middle and lower sections of the formation. The Tawil is proposed to be the main aquifer to provide water supply for the site.

The Tawil Formation is underlain by Lower Silurian sedimentary rocks of the Qalibah Formation. The Qalibah Formation comprises graptolitic shales with isolated sandstone and siltstone bands in its upper sections, and micaceous sandstones with minor laminated shales and siltstones in the lower part.

The Silurian layers are underlain by Ordovician sedimentary rocks of the Zarga, Sarah and Quassim Formations. The formations are mainly composed of sandstones and silty sandstones with intercalated layers of shales.

Beneath the Ordovician formations lies the last member of the Arabian Shelf, the Cambrian SAQ Formation. The SAQ comprising fine to coarse sandstones with interbedded siltstone and shale layers, lying unconformably over the crystalline basement rocks.

The local geology is summarised in Table 6-23.

Table 6-23: Regional Stratigraphic Column [Source: SRK, 2013b (modified from BRGM, 2008)]

Period Formation Thickness (m) Notes

Tertiary Jaramid, Mira and Umm Wu’al

~160 Phosphate bearing sequences comprised of micrites, bioclastic limestones, vuggy limestones, chert, phosphatic limestones, phosphatic sands, phosphatic sandstones

Cretaceous Aruma ~150 Horizontally bedded limestone

Waisa ~150 Horizontally bedded sand and limestones

Angular Unconformity

Jurassic - Carboniferous

Supra-Jauf N/A Includes various units comprising dipping (anticlinal) limestones, shales and sandstones. Not present in the

vicinity of the site. Devonian Jauf 200 - 300 Dipping (anticlinal) inter-bedded

sandstones, limestones and shales. Tawil 400 - 500 Dipping (anticlinal) sandstones

Silurian Qalibah ~700 Dipping (anticlinal). Includes the Sharawra Sandstone and the Qusaiba

shale. Ordovician Zarga + Sarah

Formation ~350 Dipping (anticlinal) sandstone and

shales. Qassim

Cambrian SAQ ~700 Dipping (anticlinal) sandstone.

Pre-Cambrian Basement Rocks N/A Crystalline Bedrock





Additional information on bedrock was obtained from several phases of ground investigation. Three boreholes have been constructed as part of the 2003 initial hydrogeological feasibility study (SRK, 2004). The boreholes are located 25 km ENE of the proposed Ma’aden phosphate mine and targeted the Tawil aquifer. The boreholes provided information to a depth of 850 m. The description of the encountered rock strata is summarised below:

• 0 – 167 mBGL, cherty micritic limestone with cavities (Aruma Formation).

• 167 – 240 mBGL, fine grained sandstone and argillic siltstone with occasional shale beds (Zallum Formation, lower part of Aruma Formation).

• 240 – 257 mBGL, medium grained calcareous sandstone (upper part of Jauf Formation).

• 257 – 411 mBGL, mainly red and green banded shale with thin horizons of siltstone and sandstone (lower part of Jauf Formation).

• 411 – 850 mBGL, fine to very coarse grained sandstone with occasional thin horizons of shale. The sandstone is noticeably more coarse in lower section (670 – 850 mBGL), (Tawil Formation).

Information on deeper bedrock strata was also available from two further boreholes, the Ma'aden Test Well and Ma’aden Observation Well, drilled during 2012, for aquifer testing purposes (SKR, 2013b). The borehole logs provide detail to a depth of 1,490 m. The logs recorded various sequences of sedimentary rocks and confirmed the heterogeneity of the published bedrock geology. The description of the encountered rock strata is summarised below:

• 0 – 170 mBGL, soft limestone, small proportion of siltstone and chert, (Umm Wu’al and Mira Formations).

• 170 – 260 mBGL, limestone interbedded with siltstone, shale and chert (from 220 mbgl), (Aruma Formation).

• 260 – 350 mBGL, fine, occasionally medium to coarse sandstone interbedded with siltstone and shale, (Jubah Formation).

• 350 – 670 mBGL, silty sandstone and fine to coarse sandstone, interbedded with shale, (Tawil Formation).

• 670 – 1240 mBGL, shale, fine to medium sandstone and fine sandstone, (Sharawra Formation).

• 1240 – 1490 mBGL, siltstone, shale and fine to medium sandstone, (Quisaba Formation).

The exploratory holes undertaken between December 2012 and March 2013 as part of the Geotechnical Investigation Umm Wu’al Phosphate Project were targeting the upper horizons of the phosphatic formations, and only provided information to a depth of 30 m (SRK, 2013c). A total of 119 exploratory hole logs were available. The majority of the exploratory holes were targeting the 10 to 15m BGL horizons.

The encountered bedrock strata confirmed the published information. Various rock types were recorded beneath the site. The sandstones were typically described as moderately weathered, moderately strong rocks with closely to widely spaced joints.

The encountered carbonate rocks were silty grey limestones, dolomitic limestones and dolomites. The carbonate rocks were described as moderately strong to strong, moderately weathered rocks with close to widely spaced joints.

Conglomerates were recorded as moderate strong, severely to moderately weathered rocks with very closely to medium spaced joints.

The main structural features within the Project Area are as follows:

• A major N-NW trending anticline whose axis is known as the Ha’il Arch;





• the Wadi Sirhan Graben and associated faults; and

• the Umm Wual fault.

The Ha’il Arch is a post-Hercynian event horst structure that is thought to reflect past displacements along large north – south trending faults passing at great depth to the west of Al Jalamid village (SRK, 2013b). It folds all of the strata beneath the angular unconformity dividing the sedimentary succession into two distinct basins: the Wadi as Sirhan basin to the west and Widyan Basin Margin to the east.

The Umm Wu’al fault trends NW-SE and is in close proximity to the Al Khabra Mining Licence (approximately 15.5 km at its closest point).

7.2.4 SOILS AND SUPERFICIAL DEPOSITS

An indication of the soil types present in the Project area has been taken from “Saudi Arabia: An Environmental Overview” (P Vincent, 2008). The general soil map of Saudi Arabia (Figure 8.6 in the report) shows that soils at the site and across the surrounding area are of the Calciorthid-type. They typically have a calcium carbonate equivalent content of 15% to 40% and most importantly, where rock exposures are not too numerous, irrigated agriculture is possible. Land Use is addressed in Section 12 – Socio-Economic Aspects

The encountered soils and superficial deposits in the investigations from December 2012 to March 2013 were heterogeneous and predominantly granular in nature, typically described as dense brown sands with variable silt and gravel content. Bands of gravel and silt deposits were generally encountered as interbedded lenses within the sandy deposits. Occasional bedrock boulders and conglomerates were also recorded within the superficial layer.

The thickness of the superficial deposits is variable, generally ranging from 0.5 mBGL to 12 mBGL. The maximum recorded thickness exceeded 15m.

7.2.5 SOIL QUALITY

A total of 101 soil samples for environmental analysis were collected on the Project site during the 2013 ground investigations (Fugro, 2013). The soil samples were obtained from various locations across the site, at depth intervals up to 1.0 m below the existing grade.

The samples were analysed for a range of determinands:

• General soil parameters.

• Organics suite.

• Metals.

These results show soil pH is slightly above neutral, in the range 8.1 to 9.0 (i.e. slightly to moderately alkaline). Organic matter content of surface soils is in the range 0.5 to 1.0 % and there is no evidence for significant levels of salinity.

No local soils contamination standards were identified against which to assess the soils analysis results. Therefore, a range of other national guidelines were consulted as a guide to relative contamination levels, these included standards from the UK, USA, Netherlands and Western Australia (EA 2009, USEPA 2009, DEC 2010).

All organic compounds analyses were below limits of detection.

The levels of all metals analysed are below intervention guideline values for residential use, with the exception of selenium. Selenium is consistently around or just above the available residential guideline values, but well below guidelines for industrial use where these are available.

Generally, there is no evidence of soil contamination in these results (Fugro, 2013). The soil concentrations are expected to reflect local natural/background values. It should be noted that many of the Total Dissolved Solids results, which reflect water soluble salts in the soil, are indicative of conditions which can have detrimental effects on plant growth and infrastructure. The levels of Chloride and Sulphate in the soils, while considered to be naturally occurring, indicate conditions that may be corrosive to concrete and metals.





There is limited information with which to assess soil fertility and potential agricultural use. However, organic matter content of surface soils is low and Phosphorous levels are low. There are occasional relatively high levels of Zinc, but not such that should limit agricultural use. There are relatively elevated levels of Selenium in most samples; potential agricultural use would need to consider the sensitivity to and the potential to concentrate Selenium of proposed plant species. These data suggest that soils in the Project area are likely to be of low fertility but suitability for future vegetation development can not be ruled out, provided adequate irrigation could be provided and possibly with some soil improvement being required.

7.2.6 GROUNDWATER

It has been reported that hydrogeological studies undertaken as part of the Pre-Feasibility Study (PFS) concluded that groundwater is more than 160 m below surface (SRK, 2013a). However, the surveys undertaken (SRK, 2004 – and SRK, 2013b), suggest that groundwater levels within the Umm Wu’al region are between 250 and 350m below ground levels and under confined conditions. Groundwater was not encountered during the 2012-2013 ground investigations (Fugro, 2013) due to the relatively shallow depth of the exploratory holes (a maximum of 30 mBGL).

The main hydrogeological units of the study area are summarised in Table 6-24.

Table 6-24: Hydrogeological Sequence [Source: SRK, 2004]

Hydrogeological Unit Formation Member Main Lithology Classification

Recent Cover Superficial Deposits

N/A Limestone and shale Aquifer

Aruma N/A Limestone and sandstone with shale bands

Aquifer

Wasia N/A Sandstone with shale bands

Aquifer

Jauf Upper Jauf

(Jubah)

N/A Sandstone and limestone with shale bands

Aquifer

Jauf N/A Shale with sandstone bands at base

Aquitard

Tawil Tawil N/A Sandstone with shale bands

Aquifer

Qalibah Qalibah Sharawra Sandstone

Sandstone with shale and siltstone at the top

Aquifer

Qusaiba Shale

Shale with siltstone and sandstone bands

Aquitard

Lower Tabuk Qassim, Zarga and

Sarah

N/A Interbedded sandstone and silty sandstone

Aquifer

Saq Saq N/A Interbedded siltstone and sandstone

Aquifer

The average transmissivity (m2/d) and storativity values for the different aquifer units, compiled from various sources during the 2004 hydrology study (SRK, 2004), are summarised below:





• Recent Cover: 15552 m2/d, 0.45.

• Tawil Aqifer: 2632 m2/d, 0.01.

• Tawil/Sharawra Aquifers: 475 m2/d.

• Tabuk Aquifer: 233 m2/d.

• Saq Aquifer: 1805 m2/d, 0.09.

The hydrogeology and water supply report (SRK, 2013b) compiled an assessment of regional aquifers based on various published sources. The recent, superficial, deposits in the area are expected to have limited potential to hold groundwater and are unlikely to represent a significant, arealy contiguous water resource. Simiarly, the Aruma and Wasia Formations are generally thin and are expected to be above the prevailing water table. Water quality is expected to be poor in these formations, with high salinity. The Wasia may be locally exploited but is highly variable. The Jubah is recognised in some areas as a minor aquifer but is not exploited in the area of the Project.

The Tawil aquifer is proposed as the main hydrogeological unit to supply the water demands of the Project. The variation of the Tawil aquifer thickness is indicated on Figure 6-12. The Ha’il Arch seems to delineate a change in physical characteristics (finer grained) of the Tawil Aquifer west of the Ha’il Arch with an associated reduction in hydraulic conductivity (SRK, 2013b).

Figure 6-12: Thickness of the Tawil Aquifer [Source: SRK, 2013 - based on, previous publication (BRGM,2008)]

The Tawil and Sharawra Sandstone are likely to be hydraulically linked as they are not separated by a thick and well developed aquitard; however, there is a greater incidence of very fine grained sandstone, siltstone and shale in the Sharawra, therefore the latter tends to





have lower overall hydraulic conductivity. The overlying shales of the main Jauf formation are believed to confine both aquifer units at depth, although it is expected that some leakage will occur where more permeable horizons exist within the Jauf aquifer.

The available aquifer property values mainly relate to the Tawil and Saq aquifers with only limited data for the Sharawra Sandstone and the near surface units, and no data for the Juaf aquifer. There is no aquifer property data for any of the units to the west of Ha’il Arch (in the immediate vicinity of the Umm Wu’al licence area) or to the south of the main road from Turaif to Al Jalamid.

Pumping tests were conducted on the Tawil formation by SRK in 2004, using a purpose drilled 850 m deep borehole and observation wells (test interval between 460 and 850 mBGL). The first significant water strike recorded during drilling of these wells was at the base of the Lower Jauf shale member, at around 400 mBGL. The rest water level from this strike was between 270 and 273 m BGL, indicating that the Tawil Formation is confined at this location. The preferred values of transmissivity and storativity derived from these tests were: transmissivity = 1.12E-02 m2/s and storativity = 3.49E-04.

Further pumping tests were carried out in the new boreholes drilled during 2012 (Ma’aden Test and Observation Wells) during June 2012 and March 2013 (SRK, 2013b). These also targeted the Tawil aquifer (test interval between 500 and 950 mBGL). The Tawil Formation was again found to be confined, with rest water levels around 320 mBGL. The preferred values of transmissivity and storativity derived from these tests were: transmissivity = 2.178E-

03 m2/s and storativity = 9.7E-05.

7.2.7 AQUIFER VULNERABILITY

KSA environmental regulation/guidance provides a method to determine the vulnerability of an aquifer to pollution (Kingdom of Saudi Arabia National Environmental Standard Industrial and Municipal Wastewater Discharges, PME En_EnvStand17). This requires further assessment for any aquifer classified as Moderate or higher vulnerability.

Using this methodology, the Tawil and Saq aquifers are classified as Negligible vulnerability. The uppermost groundwater, reported at 250m depth, may be classified as Low or Negligible vulnerability, depending on whether or not it is considered that the overlying of sub-horizontal layering of limestones and sandstones create confined conditions. The quality of the main aquifer (Tawil) used for abstraction locally and the source for the proposed wellfield, is not vulnerable to pollution.

7.2.8 AQUIFER RECHARGE

The climate of the study area is arid, characterized by sporadic and isolated rainfall events. Daily rainfall data have been obtained from the Presidency of Meteorology and Environment for Turaif Airport for the period January 1978 to October 2012 (with missing calendar years 1980, 1981 and 1997). Turaif Airport is located approximately 40km to the south-west of the site. In addition, for the data from January 1999, the duration over which daily rainfall occurred on each day was provided.

The daily rainfall data provided for Turaif Airport indicates that the annual average rainfall is approximately 87mm, although the annual totals vary significantly between 30mm and 300mm. The annual rainfall totals for the period of record are shown in Figure 6-13. .





0

50

100

150

200

250

300

350

1978

1979

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

Year

Rai

nfal

l Dep

th (

mm

)

Figure 6-13: Annual Rainfall – Turaif Airport

The rainfall data indicates that rainfall is rare and very sporadic, with rainfall rarely occurring on consecutive days. The summer season, which is largely devoid of any rainfall, runs from March to September.

More details of the local climate are provided in Section 6 - Air Quality & Meteorology.

Due to the extremely arid and hot conditions of the study area, aquifer recharge is very limited.

From data analysis and a literature review carried out as part of the 2004 initial phase of hydrogeological studies for the Project site (SRK, 2004), it was estimated that a conservative groundwater recharge of 1% of the observed precipitation is likely to occur, this equates to a recharge rate of between 0.5 – 1mm per year. This is in agreement with a recent regional study (BRGM, 2008), which concluded that recharge is unlikely to exceed a few millimetres and will certainly be less than 5 mm.

On a regional scale it is likely that there will be a number of mechanisms of groundwater recharge which influence the deep aquifers of the study area:

These may include the following mechanisms:

• Direct recharge at aquifer outcrop and eventual mixing with older water at depth;

• Lowering of groundwater heads within the aquifers due to abstraction resulting in release of water stored in the overlying aquifers;

• Vertical flow through faults and fault zones resulting in recharge from aquifers either above or below (depending on the direction of the hydraulic gradient).

The regional recharge mechanism is visualised in a conceptual hydrogeological model as shown in Figure 6-14.





Figure 6-14: Conceptual Hydrogeological Model [Source: BRGM, 2008]

Data presented in the report “Groundwater Management in Saudi Arabia” (UN, 2009 ) indicates a gradual decline in major aquifer water levels in KSA since the start of the data in 1980. A declining trend in aquifer water levels in the Project area may also be expected and the UN report also states that the water table in the Tawil aquifer declined by 34m between 1981 and 2002.

7.2.9 POTENTIOMETRIC SURFACE & GROUNDWATER FLOW

Hydrogeological surveys carried out in 2004 and 2012 (SRK, 2013b) suggest that groundwater levels in water supply boreholes within the detailed study area are between 250 and 350 mBGL, with groundwater at 270mBGL at the proposed wellfield location.

The highest groundwater elevations within the Tawil occur to the south and south east of the region and ensue as a result of increased recharge over the Tawil outcrop and beneath the sand dunes. Moving northwards, flow appears to be channelled along the strike (NW-SE) of a number of faults and graben structures. This suggests that successive faulting has created a zone of enhanced permeability within the Tawil aquifer and vertically adjacent units. To the north of the faults there is a N-S groundwater divide that is approximately co-incident with the axis of the Ha’il Arch, with groundwater flow to the east and west conditioned by shallow hydraulic gradients of 1:750 and 1:3,000 respectively. It should be noted that the aquifer is expected to be unconfined along the axis of the Ha’il Arch and located closer to the ground surface (approximately 200m below ground level) (SRK, 2013b). The main discharge zone in the Project Area is in the northeast, along the border between KSA and Iraq. The main flow components are conceptualised in Figure 6-15.





Figure 6-15: Conceptual Hydrogeological Flow Regime [Source: SRK, 2013]

7.2.10 ABSTRACTIONS

Widescale abstraction from the Saq aquifer and overlying units has been taking place since 1985, predominately to provide water for domestic supply and irrigation. The majority of abstractions exploit the Tawil Aquifer and occur to the south of the Umm Wu’al site.

According to the Hydrogeology and Water Supply report (SRK, 2013b), whilst there was a large increase in abstraction rates between 1984 and 2000, this trend appears to have flattened off with rates remaining consistent throughout the period 2000 – 2005.

A summary of water consumption by aquifers is given in the Table 6-25.





Table 6-25: National Aquifer Supply Summary [Source: Complied by SRK (2013b) from BGRM, 2008]

Aquifer Model layer

1984 (Mm3/a)

2005 (Mm3/a)

% of total in 2005

STQ 1 141 1388 15.9

Khuff 3 87 159 1.8

Jubah 5 86 12 0.1

Jauf 6 9 158 1.8

Tawil 7 39 876 10.0

Quwara 9 90 128 1.5

Kahfah 11 187 298 3.4

Saq 13 1427 5708 65.4

Total 2064 8727 100.0

The largest groundwater abstraction within the region is related to the Al Jalamid wellfield, located approximately 100 km to the SE of the Project site (SRK, 2004 – confirmed by SRK, 2013b). The wellfield supplies water to the Al Jalamid phosphate mine. The wellfield comprises a total of 7 wells, which all abstract groundwater from the Tawil aquifer. The exact date and details of when the wellfield became operational is not known. It is assumed that some wells began pumping in June 2009 with the remaining wells becoming operational in early 2012. The current abstraction rate is believed to be in the order of 1350 m3/hr. Comparison between historical drawdown from 2008 against recent groundwater level records suggest that the dynamic water level in the wellfield is currently about 20m below pre-operational levels (SRK, 2013b).

A cement plant is known to be located to the south of the Trans-Arabian highway between Turaif and Arar, however to date no information has been obtained regarding water usage.

A survey of water supply wells conducted during the PFS hydrogeological studies (RSK, 2004 – updated by RSK, 1013b) identified a number of smaller abstractions in the region of the Project. The results are reproduced in Table 6-25. A number of these appear to be abstracting from the Tawil aquifer. Some may be short term, related to construction and oil and gas projects. The closest identified abstraction to the Project is well EW6 to the north, which appears to be used to supply small quantities of water to local people (herders) and livestock. Groundwater is also used by ARAMCO for their gas well drilling operations. The ARAMCO abstractions are considered to be temporary.

The town of Turaif (approximately 40 km southwest of the Project) may obtain water supply from groundwater. The 2004 survey identified one well in the vicinity of the town (1-NW-30), which may not exploit the Tawil aquifer and appeared to be out of use. The 2012 survey did not revisit this location. The 2004 survey suggested that the town is supplied from wells to the southwest, including EW8 and AJ03, which are among the more significant domestic abstractions identified from the Tawil aquifer (see Table 6-26). Water is also supplied to Turaif via a pipeline from Al Jouf.





Table 6-26: Results of SRK Water Census Survey [Source: RSK, 2013]

Well Name X Y Z Depth (mBGL)

Target Formation

Year Completed

Date Visited

SWL (mbtc)

Monthly Abstraction

(m3)

TDS (ppm)

EC (ms/m)

Temp (ºC) pH Redox

(mv)

AJ-02 557988 3479490 817 723 Tawil 1992 Mar-13 259 1490 35

AJ-03 557940 3479495 815 706 Tawil 1992 2003 249 1490 216 35 7

AJ-04 557990 3477995 815 701 Tawil 1992 2012 249 1490 35

SRK_Q1 568789 3509703 830 850 Tawil 2004 2003 272 220 35 7.2

Nov-12 268

SRK_OB1 568761 3509813 831 700 Tawil 2004 2003 267

Nov-12 268

SRK_OB2 568497 3509638 833 850 Tawil 2004 2003 267

Nov-12 270

TW-01-2004 581140 3488590 789 2004 N/A

OW-01-2004 581096 3488599 789 953 2004 N/A 223

OW-02-2004 580890 3488494 788 951 2004 N/A 224

EW6 547041 3539041 898 601 Tawil 1984 Dec-03 325 864 2085 254 34 8

Aug-12 1548 309 30 7.5

EW8 553211 3478638 825 2000 Tabuk 1984 Dec-03 270 24529 662 126 52 8

Dec-12 35 7

New well at EW8 553504 3478168 833* 750 Tawil 2001 Dec-03 270 12960

Dec-12 6713.28 1536 305 38 7.24

84 523697 3502214 No information

1-NW-88 511702 3491818 862* 350 1990 Dec-03 150

Roadside Quarry 531130 3485787 700 Tawil 2000 Dec-03 260 21600 270 32 8

Dec-12 297

S-457 529697 3498908 878 425 Tabuk 1951 323

S-459 564679 3475907 806 327 Tawil 1951 246 1507 55






Target Formation

Year Completed

Date Visited

SWL (mbtc)

Monthly Abstraction

(m3)

TDS (ppm)

EC (ms/m)

Temp (ºC) pH Redox

(mv)

WW-5A2 605052 3461097 789 480 Tawil 1951 303 2431 34

1-NW-30 467682 3503361 No information

Al Jalamid Well Field 546838 3485643 100 Tawil 6804000

Aramco Well Al Jalamid 2

555043 3485153 889* 1998

Aramco_Water_Well_No1

524796 3504431 885* Oct-12 339

862* Mar-13 339

Aramco_Water_Well_No2

524303 3504374 No information

JLMD_OW_1,2,3 / JLMD_PW1,2 586479 3481832 789** 2008

JLMD-801 554128 3475400 No information







UMWL-801 507637 3539985 No information

UMWL-802 507137 3539985 920** Sharawra

(No Tawil)

2009 558




SP106 557336 3479069 812* 400 Tawil 2011 Aug-12 1074 215 34 7.2

Mar-13 18000 186 32.6 6.68 206

STWW-4501 432755 3507220 No information






Target Formation

Year Completed

Date Visited

SWL (mbtc)

Monthly Abstraction

(m3)

TDS (ppm)

EC (ms/m)

Temp (ºC) pH Redox

(mv)

STWW-4502 432255 3507220 745** 2009 560

STWW-5201 West of Ha’il Arch 1280 Sharawra - 332.5 750# 47.4

STWW5202 West of Ha’il Arch 1189 Sharawra - 338.9 1427 45.3

STWW-5301 West of Ha’il Arch 1524 Sharawra 2011 - 365.8 1850# 51.6

STWW-5302 West of Ha’il Arch 1494 Sharawra 2011 - 365.42 2869 53.2

STWW-5701 West of Ha’il Arch 762 Tawil 2012 - 322.35 3638 34

STWW-5702 West of Ha’il Arch 411 Tawil - 322.04 5061 34.3

Notes:

* Elevation from Hand held GPS ** Elevation from SOFRECO PFS 2012 # measured in the field (rather than in the lab)





7.2.11 GROUNDWATER QUALITY

Regional groundwater quality data, predominantly for the Tawil Aquifer, was compiled by SRK (2013b) and is summarised in Table 6-27.





Table 6-27: Regional Groundwater Quality [Source: SRK, 2013b]

Aquifer Well Temp (oC)

Cond. (us/cm) pH

TDS (mg/l)

Ca (mg/l)

Mg (mg/l)

Na (mg/l)

K (mg/l)

Cl (mg/l)

SO4 (mg/l)

HCO3 (mg/l)

NO3 (mg/l)

SiO2 (mg/l)

Eocene S451 1417

Tawil

WW5A2 34 2431

EW-6 34 2685 7.5 2085 177 100 314 18 500 702 232 4 13

EW-8 34 3450 7.8 2170 231 89 379 15 563 649 229 33 19

AJ-3 35 7.4 1490 89 58 236 25 501 251 238 3 Nil

AJ-2 35 1490

AJ-4 35 1490

Q1 2140 8 1163 99 59 176 44 534 265 <3 MW-01-04 40 1420 6.5 700 MW-02-04 39 1140 6.7 600

Tabuk

S459 55 1507

EW-8 55 1070 8.2 662 27 31 175 35 170 68 348 11 27

Saq 435

EU - - - - - - - - 250 - - 50 -

WHO - - 6.5 – 8.5 - - - - - - - - - -

IFC - - 6-9 - - - - - - - - - -

PME - - ABD ABD - - 150 - ABD ABD - - - N.B. Most parameters in the table are indicators of water type (e.g. major ions) and do not have associated water quality standards. Where available, associated European or Worldwide standards are quoted. The PME Env Standard 20 document does not have specific groundwater criteria for most parameters, only stating “Above Background Levels” (ABD) for some. The PME standard of 150 mg/l for Sodium (Na) must relate to the protection of known freshwater resources with no salinity impacts, as it is very low compared to any slightly saline water and compared to any stated aquifer values.





The data indicates that water temperature for the Tawil Aquifer is likely to range from 35 to 40ºC and is expected to be of a fairly neutral pH. The concentration of Total Dissolved Solids (TDS) is anticipated to be between 600 and 2000 mg/l, whilst the concentration of Chloride is expected to be approximately 500 mg/l and Sodium between around 175 and 350 mg/l.

These regional groundwater quality data have been compared to standards set out in the KSA National Environmental Standard for Industrial and Municipal Wastewater Discharges (PME), Appendix B, for discharges to surface waters and municipal collecting systems. Where there are applicable data, water from two wells (EW-6 and EW-8) would be just above the specified limit for sulphate (SO4) for discharge to both receptors. Water from one well (EW-8) would be above the specified limit for nitrate (NO3) for discharge to surface waters.

The regional groundwater quality data have also been compared to water quality standards when available:

• Drinking water standards produced by the World Health Organisation (WHO, 2011)

• European Union Directive 98/83/EC

• International Finance Corporation (World Bank Group) Mine Effluent Guidelines

Regional groundwater quality is shown to exceed EU standards for Chloride. Although there are no specific health protective standards set, the salinity levels in most of these waters are unlikely to be acceptable for potable water use without treatment.

Shallower aquifers such as the Tawil are reported as been generally more mineralised than underlying Sharawra, Tabuk and Saq (SRK, 2013b).

Site specific groundwater quality data for the Tawil aquifer was obtained from the aquifer test boreholes installed for the Project (SRK, 2013b). Data from the Umm Wu’al Ma’aden Test and Observation boreholes are presented in Table 6-28.

Compared to the regional data (Table 6-27), TDS, Chloride and Sodium levels for the Umm Wu’al boreholes are around the lower range of values for regional water quality, indicating salinity levels at the lower end of the expected range. These data have also been compared to the KSA National Environmental Standard for Industrial and Municipal Wastewater Discharges (PME), Appendix B, for discharges to surface waters and municipal collecting systems. Where there are applicable data, the majority of samples are close to (but below) the Phosphate limit and above the turbidity limit for discharge to surface waters.

Compared to the WHO, EU and IFC water quality standards, there are common exceedances for turbidity, boron and manganese and two samples exceed guidelines for a few other metals (arsenic, copper, aluminium, iron). Exceedances are highlighted with red background in Table 6-28.





Table 6-28: Local Groundwater Quality (Tawil Formation) [Source: SRK, 2013b]





KEY (All values in mg/l unless specified)

EU European Union Directive 98/83/EC

WHO World Health Organisation, guideline values for chemical that are of health significance in drinking-water

IFC International Finance Corporation (World Bank Group) Mine Effluent Guidelines

DOC Dissolved Organic Carbon

TDS Total Dissolved Solids (180°C)

M_T_S Ma'aden Test Well Sample

M_O_S Ma'aden Observation Well Sample A The value applies to a sample of water intended for human consumption obtained by an adequate sampling method at the tap and taken so as to be representative of a weekly average value

ingested by consumers. Member States must take account of the occurrence of peak levels that may cause adverse effects on human health. B Water supplied from a distribution network (at the point where it emerges a tap for human consumption), a tanker (at the point where it emerges from the tanker) and water used in food

production (at the point where it is used) must comply with this guideline value within 15 calendar years after the entry into force of this Directive. The value for lead from five years after the entry

into force of this Directive until 15 years after its entry into force is 0.025 mg/l. Member States must ensure that all appropriate measures are taken to reduce the concentration of lead in water

intended for human consumption as much as possible during the period needed to achieve compliance with the parametric value. When implementing the measures to achieve compliance with

that value Member States must progressively give priority where lead concentrations in water intended for human consumption are highest. C Member States must ensure that the condition that [nitrate]/50 + [nitrite]/3 <= 1, the square brackets signifying the concentrations in mg/l for nitrate (NO3) and nitrite (NO2), is complied with and

that the value of 0.10 mg/l for nitrites is complied with ex water treatment works

Note1 Acceptable to consumers and no abnormal change.

Note2 Tot.<Filtered from laboratory result.





7.2.12 SURFACE WATER

The proposed works at Umm Wu’al lie in an area drained by wadis. The wadis are ephemeral watercourses which drain the surrounding higher ground to depressions in the ground surface generally to the west of the main Project area. The wadis are generally dry but flow in response to heavy, but infrequent rainfall. Three main wadis have the potential to pose a flood risk to the site, all these flow from east to west towards the natural depression in the landform which lies to the west of the site. Wadis also flow across the KSA-Jordan border.

Site specific flood estimate studies undertaken in 2013 indicate that the site is at risk of flooding in a 1 in 200 year flood event.

More details on the surface water environment, including the related impact assessment is provided in Section 11 – Surface Water Management.


7.3.1 OVERVIEW

The development of the Project may result in potential impacts to the terrestrial environment during the construction, commissioning, operation and decommissioning/ closure phases. Accidental events may also result in potential impacts. The assessment of impacts on quality of soil and quality of groundwater has been undertaken on the basis of a Source-Pathway-Receptor approach. Given the existing site conditions described in the baseline, where a deep groundwater system exist and the vulnerability of the uppermost groundwater is defined as Low or Negligible and the vulnerability of the Tawil and Saq aquifers defined as Negligible, groundwater / spill modelling was considered of limited value. Therefore risks to the groundwater system have been assessed qualitatively.

The significance of potential impacts on soils, geological deposits and groundwater have been assessed and where appropriate, mitigation measures identified and the resulting residual impacts evaluated. Potential groundwater impacts relate to water quality and also water resource potential and existing abstractions, which may be impacted for example by groundwater abstraction for the development.

The assessment of surface water impacts is provided in Section 11 – Surface Water Management. Any groundwater input to surface water flows, primarily in the wadis, during rainfall events, will be ephemeral and relate solely to the rainfall event. This eventually is therefore considered part of the surface water assessment and not discussed further in this chapter. Similarly the ecological habitats associated with the wadis will be dependant on surface water and potentially shallow sub-surface flows during rainfall events. Any impacts on the deeper permanent groundwater bodies discussed in this chapter will not relate to ecological habitats and therefore no discussion of ecology is presented in this chapter. Section 8 - Biological Resources provides the full ecology assessment.

The storage and handling of non-hazardous and hazardous materials and wastes generated during all phases of the project may lead to spillages and releases which could impact the terrestrial environment if not adequately managed. A detailed assessment of waste management is presented in Section 10 - Waste Management and of wastewater management in Section 11 – Surface Water Management. These aspects are not assessed in detail in this section.

The magnitude and significance of impacts are assessed and defined according to the criteria presented in Section 5 - Impact Assessment Methodology Each impact is identified by a unique reference number (in the format “TE#”) in the impact assessment and mitigation sections.

7.3.2 CONSTRUCTION

The construction phase of the Project is considered to present potential impacts upon the soils and groundwater at the site from activities such as: leveling and other earthworks; facility construction; trenching, excavation and backfilling for subsurface infrastructure; vehicle movements; chemical and fuel/oil movement and storage; and general maintenance activities.





The excavation of the mine pit is an ongoing activity and is considered under Operations (Section 7.3.4).

Potential impacts on the terrestrial environment due to the above activities are summarised in Table 6-29 and discussed in the following text.

Table 6-29: Construction Phase Potential Impacts Summary Factor TE1 TE2 TE3 TE4 TE5

Receptor Importance/ Sensitivity

Medium Low Low Medium Medium

Frequency Continuous Continuous Continuous Frequent Frequent

Likelihood Likely Certain Certain Likely Unlikely

Extent Local Local Local Local Local

Duration Medium/Long Long Medium Short Short

Magnitude Low Low Low High Low

Effect Negative Negative Negative Negative Negative

Action Direct Direct Direct Direct Direct

Significance Medium (locally only)

Low Low High Low

7.3.2.1 IMPACT ON SOIL RESOURCES

General construction activities, including vehicles movements and earthworks, have the potential to cause soil erosion, including an increase in the effect of wind and storm water erosion. There is currently no agricultural land use in the Project area, but the potential for future vegetation growth has not been ruled out in the baseline, supported by irrigation and potential soil improvements. The soils are also linked to ecology, where other conditions are appropriate particularly local to wadis.

The utility of the soil present within the Project areas will be largely lost due to the presence of the built infrastructure and associated services. The soils present at the Project site are present across a much wider area and therefore the local soil resources are not rare or unique. However, if developed with irrigation the soils have localised ecology value, particularly in the vicinity of wadis, this indicates a degree of sensitivity to the potential impacts. It should be noted that the assessed potential impact significance is limited to soils within parts of the Project area and that because these soil types extend across a much wider area the impact on regional soil resources will be low or negligible.

Impact TE1 – Medium significance (locally only)

7.3.2.2 ALTERATION OF TOPOGRAPHY

Earthworks required during construction of the Project are limited to some cut and fill activities to achieve leveling and/or re-grading. The Detailed Description and Layout of the Proposed Development document indicates that, based on cut and fill calculations undertaken for the early works, all material derived from this process will be reused on site as part of the cut and fill, the preparation of temporary roads, the implementation of the embankments and bunds required for the wadi diversion scheme.

The significance is considered to be low due to the limited scale of planned activity and the lack of significant natural topographic features.

Impact TE2 – Low significance





7.3.2.3 ALTERATION OF THE RECHARGE REGIME

Alteration of surface drainage and infiltration patterns could affect groundwater recharge rates. This includes long term reduction in recharge below paved/surfaced areas. However, the depth to groundwater is significant in the project area, recharge has been assessed to be a very small percentage of annual precipitation in the baseline, and the baseline also showed how the key recharge areas of the main abstracted aquifer (Tawil Aquifer) are located outside the Project Area. In addition, the paved/surfaced area will be small relative to the surrounding environment. Also, there will be local diversion of some wadi channels and disconnection of part of one wadi, but any local change in recharge rates is anticipated to be negligible. Therefore, this impact is considered to be of low significance.

Impact TE3 –Low significance

7.3.2.4 DEGRADATION OF SOIL QUALITY

Maintenance activities could include small repairs, routine lubrication and wash down of equipment. A large amount of equipment may be involved in the construction phase and the routine maintenance tasks may pose a significant contamination risk if not controlled. Release of larger quantities of washdown water, which may contain contamination, is identified as the most significant potential source of contaminants related to maintenance. A medium significance is assessed.

Construction activities will require a large number of vehicle movements and the introduction of oils, fuels and chemical storage both for construction purposes but more significantly in preparation for the operational phase. Spillage or leakage from vehicles, tanks or pipelines represents a significant risk and for the worst case scenario, if not controlled, the potential impact on local soils is considered to be of high significance.

Impact TE4 –High significance

7.3.2.5 DEGRADATION OF GROUNDWATER QUALITY

The same activities described above relating to potential impact on soils (TE4) are also relevant to the potential impact on the quality of the underlying groundwater. The local soils if contaminated in this way would become a source and pathway for the contaminants to impact on the groundwater. However reported data in the baseline conditions indicate that the local groundwater is present at a depth of well over 100m and the aquifers used for abstraction are reported in the baseline to be at least 250m below surface. Protection will be offered to all groundwater by the attenuation (reduction) of contaminants that would occur as they migrated vertically through such a thick sequence before reaching groundwater, while the exploited aquifers will also be protected by at least one overlying aquitard. The significance of the potential impact on groundwater quality is assessed as low.

Impact TE5 –Low significance

7.3.3 COMMISSIONING

Commissioning activities which may impact the terrestrial environment include; hydrostatic testing, flushing/cleaning of pipelines and accidental release of hazardous substances. In addition, the potential spillage and leakage risks described for the construction phase are present, albeit the scale of activity and therefore the risks are much lower for the commissioning phase and will be less significant than the potential impacts specific to this phase.

Potential impacts on the terrestrial environment due to the above activities are summarised in





Table 6-30 and discussed in the following text.





Table 6-30: Commissioning Phase Potential Impacts Summary Factor TE6 TE7


Medium Medium

Frequency Infrequent Infrequent

Likelihood Likely Unlikely

Extent Local Local

Duration Long Long

Magnitude Low/Medium Very Low



Significance Medium Low


Hydrostatic testing and flushing will be carried out on new tanks and pipelines. Desalinated fresh water will be used for these activities. During these activities the water used could pick up trace concentrations of contaminants, potentially including hydrocarbons and inorganic contaminants. Discharge of the wastewater produced may therefore negatively impact soils quality. However, the impact on soils is expected to be minimal, particularly in comparison to operational releases and is considered to be of low significance.

Small amounts of hazardous or contaminative materials may be used during the commissioning phase, such as for testing process plant or in minor repairs and modifications. The amounts of these materials expected to be used during commissioning are small, however if not controlled significant impact from spillage could occur. Therefore, any potential impacts to local soils are considered to be of medium significance.

Impact TE6 – Medium significance


The described activities specific to the commissioning phase have the potential to impact on the underlying groundwater quality, with any soils which become contaminated by the activities acting as a source and pathway (as discussed in the construction phase). However, given the medium significance of potential impact on soils and the protection offered to groundwater by nature of its depth and overlying aquitards, the significance is assessed as low.


7.3.4 OPERATIONS

Operational activities which could potentially impact the terrestrial environment include the excavation of the mine pit, operation of the processing plants at the Waad Al Shamaal Phosphate Industrial Complex (PIC) and transport of raw materials and products.

Potential impacts on the terrestrial environment due to the above activities are summarised and discussed in the following text.





Table 6-31: Operation Phase Potential Impacts Summary Factor TE8 TE9 TE10 TE11 TE12 TE13 TE14 TE15


Low Medium Medium Medium Medium High High Low

Frequency Frequent Continuous Continuous Rare Rare Continuous Continuous Continuous

Likelihood Certain Unlikely Unlikely Unlikely Unlikely Certain Unlikely Certain

Extent Local Local Local Local Local International Local Local

Duration Long Medium Medium Medium Medium Medium Medium Long

Magnitude Low Low Low High Low Low/ Medium

Low/ Medium

Low

Effect Negative Negative Negative Negative Negative Negative Negative Negative

Action Direct Direct Direct Direct Direct Direct Direct Direct

Significance Low Low Low Medium Low Medium Medium Low





7.3.4.1 MINE BLASTING

This activity is specific to the operational phase and relates to rock blasting within the mine excavation as part of the rock extraction process. It will continue throughout most of the operational phase. The potential impacts arising from rock blasting on the terrestrial environment are limited to the local increase in fracturing of rock adjacent to the mine pit both laterally and beneath the pit. The increased fracturing will produce higher rock permeability and therefore higher rates of infiltration with reduced attenuation of any migrating contaminants. However the effect will not extend far beyond the base of the mine pit relative to the depth of groundwater and therefore the impact of increasing the risk to groundwater is very minor and the assessed significance is low.



Along with the PIC processing plants the main administrative and maintenance area includes various support buildings: Workshops; Warehouses; Fire station; Domestic and Administrative residential buildings (for approximately 1,000 employees). Operations will generate traffic movement, maintenance operations and solid and liquid waste. Impacts due to traffic movements should be considerably less than during the construction phase. Impacts due to routine operations may pose a significant contamination risk if not controlled. Waste management facilities are provided and waste will either be stored on-site or transported off-site to suitable disposal facilities. The significance of potential impact for these activities is medium.

Specific activities with related potential impacts on local soil quality include:

• Wastewater generation – resulting from activities such as equipment washdown, cleaning, descaling and sludge supernatant discharge. Contaminants in wastewater streams may include: flurosilicic acid, arsenic and fluorine byproducts, STPP (but which is not considered a health risk), soda ash (non-hazardous), fluoride impurities, solvent such as tri-butyl phosphate (TBP). General Contaminants of concern include micropollutants such as PAH (e.g. from diesel oil, fossil fuel burning) and heavy metals arsenic, cadmium, mercury, chromium, cobalt and copper. The wastewater will be treated at the Industrial Wastewater Treatment Plant (IWTP), which will remove dissolved and suspended solids and neutralise the effluent. The discharge from the IWPT will be directed to a lined area of the Phosphogypsum Storage Facility (PSF) for evaporation, to prevent any impact on local soil quality. .

• Stormwater discharge - run-off generation from the mine and PIC site may be significant during the short periods of heavy rainfall that can be experienced in the Project area. Runoff from the PIC site will have the greater potential for contaminants but a stormwater drainage collection system will be in place to capture this run-off. Stormwater from the mine will be routed to a wadi initially, but contamination from vehicles and blasting will collect in pits and be pumped to lined evaporation ponds.

• In all areas, the first flush from storm events will convey rainwater or firewater into catch pits in each area, from where submersible pumps will transfer the water to a contaminated water pond. The contaminated water pond is located adjacent to the IWTP and when it is in use, an operator will be required to test the contents in order to determine whether it is environmentally compliant and therefore acceptable to discharge directly to the wadis, or requires to go to the IWPT.

• Runoff and Seepage from the Tailings Storage Facility (TSF) and PSF - Both the TSF and PSF will have impermeable liners, bund structures with capacity for storm inputs and peripheral interceptor drains. The stack will also have an underdrainage collection system. The runoff and seepage from both is not expected to have a high potential for contamination, but a water treatment system will be added if required following chemical profiling.





• Temporary waste rock dumps will be operating and will then be removed and re-handled in Years 8 to 11 of production life to be used as backfill and provide access to underlying reserves. The temporary waste rock dump is not lined, however all run off from the temporary waste dump will be captured by perimeter ditches and pumped to the mine pit de-watering system, which directs potentially contaminated water to attenuations ponds located in the western infrastructure corridor. Water will be tested for compliance with surface water discharge limits; if compliant water will be discharged to the nearest wadi, where not, this will be retained and evaporated in the pond.

• Brine from the Reverse Osmosis Plant is proposed to be sprayed on roads to the mine. The brine will evaporate, rather than infiltrate to groundwater. This process is expected to create a salt crust, while existing soils are generally reported to have relatively low salt contents suggesting they are not affected by a salt crust. This impact will however be limited to the road surfaces and a small area of adjacent soils.

Although these specific activities have the potential to generate significant levels of contaminants in the water, the control and treatment measures incorporated in the base design will prevent introduction of significant contaminants into local soils, or in the case of brine spraying the extent is very limited, and therefore the assessed potential impact is low. Occurrence of accidents and spills is covered as separate impact factors.

It should be noted that potential impacts relating to dust generation are assessed Section 6 - Air Quality & Meteorology and are not discussed here.



The various operational activities described above for TE9 have the potential to impact on underlying groundwater quality subsequent to an impact on soil quality covered by TE9. However the potential impact relating to groundwater is very limited due to the depth of groundwater and the presence of at least one protective aquitard above locally productive aquifers. The significance is therefore assessed as low.


7.3.4.4 DEGRADATION OF SOIL QUALITY FROM ACCIDENTS AND SPILLS

Potential impacts to the quality of local soils may result from unplanned and accidental releases, leaks and spills. Significant potential releases may result from storage of large volumes of material associated with the PIC, during transport and handling of input materials and process products and from breach of TSF or PSF containment.

The assessment of potential impact from accidents and spills are discussed below for different aspects of operation.

Transport

Large volumes of raw materials and process products will be transported to and from the site by rail and road.

Major imports by rail include: Molten sulphur (5,407 tonnes/day of tanked liquid).

Major exports by rail include: Sulphuric Acid (1,010 tonnes/day of tanked liquid), Merchant grade phosphoric acid (MGA) and raffinate (7,169 tonnes/day of tanked liquid), Purified Phosphoric Acid (PPA) (237 tonnes/day of tanked liquid), Mono / Di Calcium Phosphate (MCP / DCP) (758 tonnes/day, bagged), Sodium Tri Poly Phosphate (STPP) (271 tonnes/day, bagged).

Imports by road (truck) include: Caustic soda, Flocculant, Vanadium catalyst, MIBK solvent, Barium carbonate, Activated carbon, Caustic soda, Hydrogen peroxide, Calcium hydroxide, Diatomaceous earth, Kaolin, limestone, fatty acid and amine collectors, and soda ash.

Fuel oil, diesel and gasoline will also be delivered by road tanker.





Accidents during transport and the absence or inadequacy of containment associated with materials handling facilities cannot be ruled out. The likelihood of major spillages is considered to be unlikely, although not insignificant given the long distances of transportation. The potential magnitude is assessed as high for some substances handled in large volumes (e.g molten sulphur, acids and raffinate) and for fuels/oils. Molten sulphur would solidify when released so the impact would be limited to soils in the immediate vicinity, while the other hazardous liquids have the potential to affect soil quality over a wider area and, in the case of major incidents, to impact on the quality of underlying groundwater, where this isn’t protected by virtue of large depth and overlying aquitards to minimize vertical migration. The potential impact for this aspect is considered to be of medium significance.

Failure of TSF or PSF Containment

Failure of the engineered containment for the TSF and PSF could lead to release of contaminated run-off and seepage to underlying and surrounding soils and groundwater. The runoff/seepage from both the TSF and PSF has the potential to contain substances hazardous to the water environment. This remains to be confirmed following detailed geochemical profiling. This is considered to be particularly the case with respect to the PSF, which will receive a wider range of inputs from the PIC processing plants. The Phos Acid Pilot Plant Study (Jacobs 2013a) suggests that levels of metals, Chloride, Fluoride and Sulphate are likely to be at a level that will have low potential for contamination in the stack. However, residual acids may be significant and heavy metals have not been included in the analysis. Low levels of radionuclides are known to occur in this type of byproduct, with U-238 typically in the range 0.1 to 0.2 Bq/g and Ra-226 in the range 0.5 to 1.3 Bq/g (CPCB, 2012). The same reference document states that “there is no restriction for use of phosphogypsum in agricultural applications from the radiological safety considerations.” It is therefore considered that the level of radionuclides that may be released from the stack would not have a discernible impact on soil quality.

A conservative approach is taken in the stack design and it will include a multi-layered liner, collector drain system and lined evaporation pond for collected runoff and seepage. The design is such that a significant release is unlikely and given the high evaporation rates, impact on soil quality would be relatively small scale. The potential impact on soils from this specific source, given the design, is assessed as medium magnitude and a consequent medium significance.

The contaminative potential of releases from the similarly engineered TSF is considered to be of low magnitude and therefore the potential impact associated with this specific source is considered to be of low significance.

Accidental Release of Raw Materials or Process Products from Storage Tanks

A range of different input materials and process products are associated with the PIC processing plants, the most significant of which based on volume and hazard include: sulphuric acid, molten (liquid) sulphur, caustic soda, phosphoric acid (various grades), raffinate and fuels (diesel, fuel oil). The base design includes for all tanks being located within bunded areas of hardstanding with a capacity of at least 110% of the tank capacity. Therefore the only risk of an impact from storage tanks is if this containment fails, which is highly unlikely if constructed and maintained appropriately.

Key selected hazardous materials storage, based on capacity and contents, are listed in Table 6-26 below.





Table 6-4: Key potentially hazardous materials storage

Location Feature Details

Plant Item Tank Contents Tank Capacity (m3)

Throughput

SAP Diesel/Fuel Oil Day Tank Distillate Fuel Oil 108 3,696 m3/yr

SAP Liquid Sulphur Day Tank Sulphur (molten) 1,012 333,708 m3/yr

PAP FSA Storage 24% FSA 905 38 m3/hr

PAP FSA Storage 24% FSA 905 38 m3/hr

PAP FSA Aging 24% FSA 628 170 m3/hr

PAP FSA Aging 24% FSA 628 170 m3/hr

PAP Acid Cooling Tank 28% P2O5 4,241 200 m3/hr

PAP Acid Cooling Tank 28% P2O5 8,385 200 m3/hr

PAP Aging Tank 28% P2O5 7,698

PAP Aging Tank 28% P2O5 7,698

PAP Evaporator Feed 28% P2O5 2,984

PAP Evaporator Feed 28% P2O5 2,984

PAP 54% Acid Pump Tank 54% P2O5 1,510 400 m3/hr

PAP 54% Acid Pump Tank 54% P2O5 1,510 400 m3/hr

PAP 54% Clarifier 54% P2O5 2,513 102 m3/hr

PAP Weak Sulphuric Acid 5% Sulphuric Acid 1,526 313 m3/hr

Common and Infrastructure

Diesel Storage Tank Diesel 1,016 5.0 m3/hr


Diesel Storage Tank Diesel 1,016 5.0 m3/hr


Liquid Sulphur Storage Tank

Liquid Sulphur 10,093 191 m3/hr








Caustic Soda Storage Tank

Caustic Soda (50% conc.)

3,676 22 m3/h


Caustic Soda Storage Tank

Caustic Soda (50% conc.)

3,676 22 m3/h


Sulphuric Acid Storage Tank

Sulphuric Acid (98.5% conc.)

6,223 500 m3/h



5% Sulphuric Acid 6,223 500 m3/h





Location Feature Details

Plant Item Tank Contents Tank Capacity (m3)

Throughput


























MGA Storage Tank MGA (54% P2O5, 75% H3PO4)

3,773 453 m3/hr



3,773 453 m3/hr



3,773 453 m3/hr


MGA + Raffinate Storage Tank

MGA (54% P2O5, 75% H3PO4) +

Raffinate (32% P2O5, 44% H3PO4)

4,115 450 m3/hr


Concentrated PPA Storage Tank

Purified Phosphoric Acid

(62% P2O5, 85 wt% H3PO4)

1,385 200 m3/hr




(62% P2O5, 85 wt% H3PO4)

1,385 200 m3/hr




(62% P2O5, 85 wt% H3PO4)

1,385 200 m3/hr


Fuel Oil Storage Tank Fuel Oil 2,405 40 m3/hr





The main chemicals of concern in relation to accidental release from the storage facilities would be the various acids and fuels/oils, as they are relatively mobile when released, create a significant impact on local soil quality and are in many cases stored in large volume. It should be noted that although liquid sulphur is stored in the largest tanks, it would rapidly solidify on release and would create a surface impact that would be relatively easy to remediate.

Although the probability of a significant spillage/leakage incidence is unlikely, given the base design control measures, the potential magnitude is assessed as high and the potential impact is assessed as Medium.

Leaks/Spills from Infrastructure and Services

Smaller volume leakage and spillages from pipes, storage tanks and domestic and support facilities may occur during the lifetime of the Project. Substances released could include: fuel/oil, domestic sewage and wastewater, and chemicals from laboratory facilities.

Long duration impacts to soils and superficial geology may be generated, however the impact will be limited to the location of the release and the magnitude is considered to be low. Therefore, this aspect is considered to be of low significance.

Firewater Runoff during Emergency Event

In the event that firefighting is necessary, a large volume of firewater runoff could potentially be generated. This run-off could contain process chemicals from the PIC site, hydrocarbons and fire-fighting foam which may impact soil quality if the final discharge is not controlled. As this would be an emergency situation, complete containment and controlled discharge cannot be guaranteed.

Soils and superficial geology could be impacted by contaminative substances with a medium to high magnitude and medium to long duration. Therefore, this aspect is considered to be of medium significance.

In summary of the various aspects relevant to accidents and spills, it is considered that the potential impact significance is medium.


7.3.4.5 DEGRADATION OF GROUNDWATER QUALITY FROM ACCIDENTS AND SPILLS

Each of the aspects described for TE11 above has the potential to impact on the underlying groundwater resulting from contaminants being introduced to the soils and superficial geology. However, although some of the potential occurrences of soil contamination covered in TE11 could be locally very significant, it is considered that the attenuation (cleansing) effect of the very thick sequence of unsaturated rock above groundwater (even at the base of the mine), and the presence of an aquitard above the main groundwater aquifers, results in a low significance.


7.3.4.6 DEPLETION OF GROUNDWATER RESOURCES

A 3D transient modeling exercise has been undertaken to determine the level of impact to be expected on the Tawil Aquifer as a result of a pumping rate of 18Mm3/yr for the full LoM (29 years). The modeling suggests (scenario 5) a likely drawdown of about 20m (minimum of 18m and maximum of 24m), with a likely drawdown at the Al Jalamid mine (the other major wellfield in the area) of 2.9m (minimum of 2.6m and maximum of 3.2m).

It has been estimated (SRK, 2004) that the combined groundwater abstraction for the Project and for the Al Jalamid mine (the other major wellfield in the area) corresponds to 1.65% of the total water available from the Tawil aquifer. It should be noted that any change in groundwater recharge rates in the project area as a result of the development will be completely negligible in comparison with the required groundwater abstraction.

Although this relatively low percentage suggests the water required is available for abstraction, it is known that recharge to deep aquifers like the Tawil is very low and therefore this water





resource is effectively non-renewable. This is evidenced by falling groundwater levels in the country’s major aquifers.

The significance of this impact is difficult to assess, with a reported (UN, 2009) increasing reliance on desalinated water in preference to groundwater across the country.

Overall, it is considered that the significance of impact on regional and national groundwater resources will relate to future government policy and strategy on groundwater resource protection and replacement. However, for the purposes of this assessment it is considered to be of medium significance.


7.3.4.7 IMPACT ON OTHER AQUIFER USERS

Preliminary estimations and groundwater modeling undertaken by SRK have indicated that the volumes of water required to be abstracted for the Project and the Al Jalamid wellfield approximately 100km to the SE are small compared to the total available water in the Tawil aquifer.

As indicated above, an additional drawdown of about 3m is expected at the Al Jalamid wellfield, the operation of which had already resulted to date in a local drawdown of 20m. It would be expected that for such a large wellfield, the Al Jalamid has been designed to accommodate a further drop in groundwater levels of this order of magnitude.

Key other predicted impacts are as follows:

• No drawdown effect is expected to the north west of the wellfield; however a drawdown of up to 3-4m is expected to the north east;, This drawdown is considered neglible given the depth of the aquifer, and the anticipated rapid reduction in the drawdown as active abstraction stabilises;

• EW6 is the closest known active abstraction to the possible wellfield sites (around 30km to the north) and is used by herders for their livestock. For the preferred wellfield location (Scenario 5, SRK 2013b) the predicted drawdown at EW6 relating to the proposed wellfield abstraction is 2.0m; and

• EW8 lies to the south of the possible wellfield locations at a similar distance to EW6. It is one of the supply wells for the town of Turaif. An associated drawdown of 1.4m is predicted at EW8, for the preferred wellfield location.

There are other smaller groundwater abstractions closer to the Project, as listed in Table 6-26, and many of these also abstract from the Tawil aquifer. Some of the abstractions are believed to be short term for construction and oil and gas projects.

There is also a risk that groundwater quality deteriorates overtime as a result of continued exploitation and continued worsen drawdown. However, the scale of the predicted drawdown at the closest known active abstractions is very small compared to the depth at which water is abstracted from the Tawil aquifer and it is considered very likely that the abstraction wells can accommodate the slight reductions in water level predicted.

Given the information available the magnitude of impact on other aquifer users is assessed as low to medium, as is the significance.


7.3.4.8 DEPLETION OF NATURAL PHOSPHATE RESOURCES

The Tertiary phosphorite deposits which will be exploited at the mine, can be considered a non-renewable resource given the geological timescale in which they take to form. The removal of some deposits at the Umm Wu’al mine will therefore have a permanent impact on the available phosphorite resources in KSA.

The phosphorites at Umm Wu’al and across the whole Hazm Al-Jalamid area form part of the extensive Middle East-North Africa phosphate belt. An estimated extraction of approximately 370 million tonnes of phosphate-bearing rock over the 29 years of the mine life is considered





to be a minor reduction in the resource available in the overall phosphate belt and even within KSA. The estimated phosphate resources in KSA is 7,800 million tonnes (USGS data presented at the 18th AFA International Fertilizer Form, Feb 2012) and therefore the Umm Wu’al production would represent less than 5% of the national resource and a negligible amount of the global resource.

The significance of this necessary impact is assessed as low.


7.3.5 CLOSURE / DECOMMISSIONING

Potential impacts from this phase of the project are both short term, resulting from decommissioning activities, and long term legacy issues resulting from materials and conditions left in place.

Impacts on the terrestrial environment due to the related activities are summarised in Table 6-27 and discussed in the following text.

Table 6-5: Closure / Decommissioning Phase Potential Impa cts Summary Factor TE16 TE17 TE18 TE19 TE20


Medium Medium Medium Medium Medium

Frequency Frequent Frequent Continuous Continuous Continuous

Likelihood Likely Unlikely Likely Unlikely Unlikely

Extent Local Local Local Local Local

Duration Short Short Long Long Long

Magnitude High Low Medium Low High

Effect Negative Negative Negative Negative Negative

Action Direct Direct Direct Direct Direct

Significance Medium Low Medium Low Medium


Similar impacts from general decommissioning activities, including associated maintenance activities, are expected as from construction activities. Release of quantities of contaminated materials, including residual process materials and products and release of larger quantities of washdown water, are identified as the most significant risk. Potential impact to soils is considered to be of medium to high magnitude and of medium significance.

Maintenance activities could include small repairs, routine lubrication and wash down of equipment. A large amount of equipment may be involved in the decommissioning phase and routine maintenance tasks may pose a significant contamination risk if not controlled and have a medium significance.



The medium significance of potential impact on soil quality described above for TE15 is not predicted to result in the same level of significance for underlying groundwater. This is because of the depth to groundwater and the effect this has on the risk from shallow soil contaminants, as described in previously discussed potential impacts. The assessed significance is low.






7.3.5.3 LEGACY IMPACTS ON SOIL QUALITY

Any remaining plant items, services and demolition wastes left on site could pose a contaminative risk and limit potential future uses. The potential impact to soils and limits on future land use are considered to be of medium magnitude and of medium significance.

The TSF and PSF will be left in place permanently following decommissioning. These features will gradually dry out and are expected to be stable sediment masses and substantially dry before their liner and drainage systems are likely to degrade. As discussed for the operational phase chemical profiling is required to be undertaken and it is anticipated that the PSF will contain contaminants including residual acids and potentially heavy metals, as well as low levels of some radionuclides which are typically at acceptable levels in relation to agricultural land use. The potential impact is considered to be medium, but decreasing over time as the material in the TSF and PSF dries out and consolidates.


7.3.5.4 LEGACY IMPACTS ON GROUNDWATER QUALITY

Any contaminants entering the local soils from remaining plant, services and wastes etc, or from the TSF and PSF, are not predicted to have a discernible impact on the underlying groundwater because of the depth of unsaturated rock. The impact significance is therefore assessed as low.


7.3.5.5 LEGACY IMPACTS ON SOIL STABILITY

The backfilled mine pit will represent a large area of disturbed ground which could be considered for further use following the end of the Project life. The area is currently within the border security zone, with no access or development permitted. However, there is a risk that stability issue may pose a risk to vehicle movements by the border / military police. In particular, it is possible that the finished landform may be lower in parts of the mine area than original ground surface due to shortfall of backfill and settling effects.

In the unlikely event of the designation of the area changing in the future, further development may become possible. The magnitude and resultant significance of impact on potential future agricultural uses are considered to be low as no building structures or infrastructure services would be involved. The potential for future construction on the former mine site would be dependant on the type of construction.

Potential instability impact is expected to have a medium to high magnitude and the assessed associated significance is low/medium.


7.4 MITIGATION

7.4.1 OVERVIEW

Impacts identified in Section 7.3 that are predicted to be of medium (including low/medium) or high significance are assessed against appropriate mitigation measures in this section and the residual impact significance assessed. It should be noted that many of the potential impacts that have been assessed as being of low significance will still be mitigated by measures presented in the tables below. For example, although potential impacts on groundwater quality have been assessed as low largely due to the depth to groundwater, the measures adopted to protect soil quality will further protect groundwater quality as contaminated soils would be a source and pathway to contaminate underlying groundwater.





7.4.2 CONSTRUCTION PHASE - IMPACTS AND MITIGATION

ID Code

Impact Potential Significance

Mitigation Measure Significance after

Mitigation TE1 Loss of soil resource due to Project

construction Medium (at local level only)

• Where possible soils will be stockpiled and reused as part of the Project design to minimize impact.

Some areas of soil resource will be unavoidably lost due to development. It should be noted that the soil types are present across a much wider area and the significance to regional soil resources is Low

Low (at local level only)

TE4 Degradation of soil quality due to construction processes.

High • designated refuelling and maintenance areas and areas for delivery and storage (in tanks/containers) of potentially contaminative liquids will be constructed. These areas will be hard-surfaced and contained by walls or bunds, with drainage systems and collection arrangement for spills and stormwater management.

• all storage tanks shall be above ground and maintained in good condition and inspected regularly. A record must be kept of all liquids/tanks/containers delivered to the site.

• all vehicles used on site shall be serviced and maintained to the highest standard, with a record kept of maintenance undertaken.

• at each vehicle wash area, there shall be a regularly maintained washwater collection and recycling system.

Low





7.4.3 CONSTRUCTION PHASE RECOMMENDATIONS

The contractor shall develop, implement and maintain a construction phase Environmental Emergency Response Plan (EERP) and a Construction Environmental Management Plan (CEMP). These plans will detail responsibilities and procedures for environmental and emergency response management during construction, including:

• Minimum technical standard of construction plant;


• Procedures to be implemented following an accidental release of hazardous substances, e.g. during refuelling, including details of containment and recovery measures to be applied; and

• Availability of pumps and spill mitigation materials such as absorbent granules to contain and recover hazardous substances releases.

The contractor will undertake regular audits of the above management plans to confirm their ongoing effectiveness.

There are no specific recommendations required in relation to the low significance potential impacts associated with topography, recharge and groundwater. It should be noted however that the mitigation measures put in place for TE4 will also further protect groundwater quality.





7.4.4 COMMISSIONING PHASE - IMPACTS AND MITIGATION

ID Code



Mitigation TE6 Degradation of soil quality due to

commissioning processes Medium In addition to the mitigation measures presented for TE4,

the following measures should be adopted.

• specific commissioning activities such as hydrotesting and flushing and disposal of wastewater will be undertaken in line with methodologies ,agreed in advance, which contain appropriate measures to control, collect and treat the produced water as appropriate.

• wastewater will be treated if required to comply with water quality standards applied to discharge and as a minimum will pass through an oil/fuel interceptor facility

Low

7.4.5 COMMISSIONING PHASE RECOMMENDATIONS

If commissioning phase activities are not already included within the Construction Environmental Management Plan (CEMP) and Environmental Emergency Response Plan (EERP), discussed in section 4.2.1.1, additional corresponding documents should be compiled for the phase.

There are no specific recommendations required in relation to the low significance potential impact associated with groundwater quality. It should be noted however that the mitigation measures put in place for TE6 will also further protect groundwater quality.





7.4.6 OPERATIONS PHASE - IMPACTS AND MITIGATION

ID Code



Mitigation TE11 Degradation of soil quality due to accidents

and spills Medium The measures included in TE4 will be designed in part to

minimise the potential for accidents and spills. Additional measures are as follows.

• any accidental spill/leak will be fully cleaned as soon as the incident occurs, and if required polluted soil/sand will be excavated and removed to a licenced waste disposal site. Any accidental spill/leak will be recorded.

• where possible the site design would be such that accidental release from bunded containment areas would still discharge to a site drainage system in preference to entering the ground.

Low

TE13 Depletion of groundwater resources Medium • groundwater level monitoring should be undertaken prior to and during the Project life to allow appraisal of long term impacts. This can be supplied to the Ministry to assist in continued assessment of overall status of Tawil aquifer.

• efficient re-use of suitable water within the project is a key consideration and all practical design measures (during detailed design stage) should be taken to maximise this and hence minimise the abstraction.

Low

TE14 Impact on other aquifer users Medium • groundwater level monitoring and efficient reuse of water by the project to be incorporated in design

Low





7.4.7 OPERATION PHASE RECOMMENDATIONS

The site operator shall develop, implement and maintain an Environmental Emergency Response Plan (EERP) and Environmental Management and Monitoring Plan (EMMP) for the operational phase, to further protect against impact of local soil and groundwater quality . These plans will detail responsibilities and procedures for environmental and emergency response management during operation, including:


• Procedures to be implemented following an accidental release of hazardous substances, e.g. during refuelling, including details of containment and recovery measures to be applied;

• Availability of pumps and spill mitigation materials such as absorbent granules to contain and recover hazardous substances releases; and

• Maintenance procedures of all equipment, pipelines and drainage systems in place.

The operator will undertake regular audits of the above management plans to confirm their ongoing effectiveness.

Prior to commencement of operations, chemical profiling will be undertaken to assess the requirement, if any, for treatment facilities assigned to the runoff/seepage from the TSF and PSF.

There are no specific recommendations for the low significance potential impacts associated with mine blasting, soil. No mitigation is possible for the reduction in national phosphate resources (TE15). Further detailed recommendations are included in the Operational Implementation Plan provided within the Environmental Management and Monitoring Plan supplied at Appendix A.





7.4.8 CLOSURE / DECOMMISSIONING PHASE - IMPACTS AND MITIGATION

ID Code


Mitigation Measur e Significance after

Mitigation TE16 Degradation of soil quality due to

decommissioning activities. Medium • See TE4. Low

TE18 Degradation of soil quality related to Project legacy

Medium • any demolition and other waste materials left on site, along with disused plant etc must be checked and contained/treated as necessary prior to site closure to ensure no potential soil contamination source remains. If materials cannot be made safe in this regard they must be removed from site.

• the drainage systems, including evaporation ponds, for the TSF and PSF shall continue to be maintained for a period after operations have ceased, while they are still producing significant potentially contaminative liquid.

Low

TE20 Soil stability at the mine pit location following restoration

Medium • the backfilled material should be compacted ensure the stability is sufficient to sustain vehicle movements.

• In the unlikely event of the designation of the area changing and other development becoming possible, further stability measures may need to be put in place to re-enforce local ground conditions

Low

7.4.9 CLOSURE / DECOMMISSIONING PHASE RECOMMENDATIONS

Many of the decommissioning activities will be similar to those undertaken during construction in relation to the potential for contamination of the terrestrial environment and therefore an Environmental Emergency Response Plan (EERP) and Environmental Management and Monitoring Plan (EMMP) which covers the decommissioning phase is required.

There are no specific recommendations required in relation to the low significance potential impacts associated with groundwater. It should be noted however that the mitigation measures put in place for TE16 and TE18 will also further protect groundwater quality.





8.0 BIOLOGICAL RESOURCES

8.1 INTRODUCTION

This section describes the ecological baseline for the proposed phosphate mine at Umm Wu’al in the Sirhan-Turaif region of northern Saudi Arabia, and presents the findings of the assessment of likely impacts arising from the construction, commissioning, operational and decommissioning phases of the project.

The Umm Wu'al ecological Study Area, hereafter referred to as the Study Area, is approximately 2947km2 and is shown on. The Study Area includes the principal locations of development associated with the Umm Wu'al phosphate mine which covers an area of approximately 59km2. These are referred to as:

• the Mine – the relatively undisturbed area controlled by rangers of the Frontier Forces close to the international border between Saudi Arabia and Jordan and the location of the actual Umm Wu'al mine; and

• the Industrial Complex to the south of the mine – the remaining project area that is not patrolled by the Frontier Forces and is currently open to the public. The Industrial Complex is located near Umm Wu'al and includes the Waad Al Shamaal city development included within the scope of this ESIA and the Umm Wu'al wells.

The Study Area, including the Mine and Industrial Complex which hereafter are collectively referred to as the Project area, is located within true steppe desert in the far north of the Arabian Peninsula adjacent to the International border with Jordan (Figure 8-1). The Study Area resides within the Northern Wildlife Management Zone, an IUCN Protected Area (Category VI), and in close proximity to two further Protected Areas; Harrat al Harrah and At Tubayq which are approximately 70km south, and 170km south-west respectively (Figure 8-2).





Figure 8-1: Ecological Study Area and Nearby Protected Are as





Figure 8-2 Protected Areas in Saudi Arabia

The region encompasses the largest of Saudi Arabia’s basalt lava fields which extends northwards into Jordan and Syria. It is the most extensive lava field in the Arabian Peninsula and the area is characterized by huge sheets of weathered black basalt rock (harrahs). The harrahs were formed by lava flows in prehistoric times, and the Northern Wildlife Management Zone is dotted with extinct volcanic cones. The largely treeless area supports hardy perennial plants in networks of wadis and drainage lines.

There is a gentle increase in altitude from south to north across the Study Area. The area is dotted with extinct volcanic cones (makman), rugged basalt outcrops (jabals) and large silty depressions (qa‘), and cut by numerous large wadis and smaller washes (sha‘ib). Lava flows covered large areas of limestone and the weathering of these lava sheets has broken the basalt into rocks and boulders. Limestone gravel plains and undulating hills dominate central part of the Study Area while moderate areas of sand are more common around the Industrial Complex. Basalt predominates elsewhere, with large jabals and the Study Area is surrounded by undulating plains of chert and gravels virtually devoid of vegetation.

The basalts of the region extend south-west for over 7,000km2 and are contiguous with those of the Harrat al Harrat and At Tubayq Protected Areas. These sandstones are exposed along eastern edge of the Harrat in south and west and they extend eastwards to form a landscape of highly sculpted buttes and narrow canyons (Plate 8-1, illustrates these and the extreme weather experienced during the field visit).





Plate 8-1: Geomorphology at Umm Wu’al Mountain (Source: Panoramio.com)

The Northern Wildlife Management Zone is home to several important species including the Arabian wolf Canus lupus, Blanford’s fox Vulpes cana and the Houbara bustard Chlamydotis (undulate) macqueenii. It also attracts migratory birds including several globally threatened species and serves as an important corridor for various taxa to the nearby protected areas of Harrat al Harrat and At Tubayq (Goriup et al., 1988). The region also formed part of the historical range of the Arabian oryx Oryx leucoryx, cheetah Acinonyx jubatus, ostrich Struthio camelus syriacus, and possibly Arabian leopard Panthera pardus nimr (Child and Grainger 1990). The area may have once held both sand gazelle Gazella subgutturosa and mountain gazelle Gazella gazella, and functioned as part of the extended northern grazing grounds for these species before the area was effectively divided by major highways and development projects.

The Umm Wu'al mine is located within the 10km Border Security Zone which is patrolled. This high level of official presence close to the International border has protected several animals from illegal hunting, and has allowed the persistence of populations of other threatened mammals, such as the Arabian wolf and the striped hyaena Hyaena hyaena. However, the area beyond the Border Security Zone controlled by the rangers of the Frontier Forces shows signs of disturbance and over-grazing due to presence of large numbers of domestic livestock, principally sheep, goats, camels and donkeys.

8.2 METHODOLOGY

8.2.1 INTRODUCTION

Baseline conditions of the terrestrial ecology were determined through a review of existing literature to develop a regional context, and then supplemented through field surveys conducted in November & December 2012 and April 2013.





8.2.2 FIELD SURVEY METHODOLOGIES

Surveys were conducted in the field between 13–19 November, 3-6 December 2012 and 10-12 April 2013 by a team of ecologists using three complimentary approaches: (1) Vehicle survey to cover larger area; (2) Foot transect near the Mine; (3) Camera trapping. These three techniques are explained below in detail. The Study Area was defined in relation to known sites where several globally threatened species of birds, mammals and other wildlife had been seen in the last 10-50 years. The Study Area does not cover the location of the proposed well field, as this location was not determined at the time of the fieldwork. Nonetheless given the largely homogenous nature of the area, the field survey results are considered representative of the area in which the well field will be located. Furthermore mitigation measures include pre-construction surveys which will provide full geographic coverage.

Wildlife observations were collected in three principle ways: i) direct observations of mammals birds and reptiles from a moving vehicle; ii) careful scrutiny of ground for tracks and signs through evenly distributed 500m rapid assessment transects on foot (the Mine only); and iii) night observations by deployment of camera traps.

Figure 8-3 illustrates the locations of vehicle and foot transects.





Figure 8-3: Ecological Survey Vehicle and Foot Transects





8.2.2.1 VEHICLE SURVEY

The main survey method was vehicle based, following a path from the Chicken Farm to the Industrial Complex (i.e. Umm Wu’al), then visiting the Mine site en route to the wadis in between. A map showing the location of the Study Area and vehicle transects is shown in Figure 8-3.

A transect survey design was planned for the Study Area. Prior knowledge of the terrain and conditions provided assurance that pre-planned routes could be completed. A provisional survey zone of 47.3 km x 62.3 km = 2946.79km2 was identified for the project (Figure 8-3). GPS waypoints defining 5 km transects were laid down randomly. The basic design was transposed 20km further north than originally planned in response to actual ground conditions with the result that 30 full transects were completed in the main survey.

A more extensive semi-systematic approach was adopted in order to cover the area to record birds, reptiles and mammals, while continuing to distribute survey effort evenly across the Project area.

8.2.2.2 FOOT TRANSECTS AND HABITAT RECORDING

The vehicle survey was supplemented with foot transects and habitat recording at the Mine to provide a greater resolution of survey detail for this area (Figure 8-3). Transects were randomly selected and rapid assessment was conducted on foot, walking in line abreast for 200m (controlled by GPS) over a 50m transect width. All observations of wildlife and wildlife tracks and signs found were recorded, with verification by consensus where necessary with field survey colleagues. Animal tracks too old or unclear to identify with confidence were ignored. Track sets were scored individually but subsequently grouped into categories: not seen, few (1-5 sets), many (6-20), abundant (>20). Details of plant species, conditions present and abundance were added on completion of the foot transect.

Landform, dominant shrubs, grass species, herb layer plants and their growth condition were recorded in more detail at a single point along each transect. Sample points were semi-randomised by selection in advance by using the trigonometric centre point of the Mine. The vegetation sample points were then fixed by randomly applying a displacement to the reference point of zero, 200m in all directions along the transect to assess the impacts of mining activities in the area.

In the case of birds, walked transect census of 30 minutes duration were carried out at dawn, the time when most birds are active (i.e. singing, displaying and feeding). A transect was not possible every day because of security and accommodation constraints, the need for an early start for other work or adverse weather. A total of eight kilometres were travelled in 31 foot transects near the Mine. In the larger Industrial Complex area birds were recorded each day while carrying out the car transects from immediately after sun-rise to sun-set.

During the censuses all birds seen or heard, including those flying, were counted. Most were recorded within 30m of the observation although some particularly vocal species, with far carrying calls (e.g. Temminck’s horned lark Eremophila bilopha, Fan-tailed Raven Corvus rhipidurus) could be heard at 400m or more in distance. In view of this bias and that quiet skulking species might be missed, census results should not be regarded as an assessment of relative abundance of species. However they are an indication of the number of each species present in a given habitat.

All observations of human activity, livestock or wildlife, including data on habitat, tracks and signs, were collected. All ‘direct’ sightings of mammals and were recorded (i.e. group size, dominant activity and location). All animal signs and tracks were classed as ‘indirect’ observations. For all observations the context (recorded from the moving vehicle, on or off transect, in the course of a transect on foot, or casual exploration on foot) was indicated, enabling appropriate grouping for subsequent analysis. Locations of all livestock (camels, sheep and goats, donkeys) were recorded with distance information.





8.2.2.3 CAMERA TRAPS

The vehicle and foot-transects were supplemented with the use of fifteen Bushnell passive infra-red cameras. These were deployed most nights during field surveys in November and December 2012 and April 2013. The cameras were set up close to sun-set and removed shortly after sun-rise each day. As these were single night deployments at new locations, all cameras were baited with sardine to improve chances of photographing small predators. It should be noted that while experience suggests that sardine bait is highly attractive to small canids, the situation is less clear for other groups, notably cats and mustelids. The possibility that some species might in the worst case be repelled by sardine has not been fully investigated. Because cameras are baited, data reporting is limited to simple presence/absence information for each camera.

Cameras were set up at 9 locations (Figure 8-4) for a total of 45 camera nights (i.e. 1 camera left in position for 5 nights). The camera traps were in position for a total of 225 hours nocturnal trapping time and a total of 75 pictures were analysed.





Figure 8-4: Camera Trap Positions





8.3 ECOLOGICAL BASELINE

8.3.1 INTRODUCTION

This section describes the ecological baseline of the Project area as determined by a literature review and field surveys. Within the Kingdom of Saudi Arabia, there is limited legislation which affords specific species with legal protection and there is also limited data on the conservation status and population trends of individual species. Therefore the value, or potential value, of each biological resource has been developed using the following:

• the list of species of High Conservation Priority as prepared by the former National Commission for Wildlife Conservation & Development(undated), now the Saudi Wildlife Authority, in response to the ratification of the U.N. Convention on Biological Diversity (1993); and

• the International Union for the Conservation of Nature (IUCN) Red List (IUCN, 2012).

The species of High Conservation Priority are assigned a value in accordance with the following categories, and species may fall within one or more categories:

1. Genera, species, or subspecies that are critically endangered, endangered, or vulnerable (globally, regionally, or nationally); taxa which are locally extinct in the wild may be included, provided that there is an SWA policy to reintroduce them.

2. Genera, species, or subspecies that are endemic to the Arabian Peninsula, the Red Sea, or the Gulf.

3. Genera, species, or subspecies of which the conservation of populations within Saudi Arabia is essential to the conservation of the taxon (e.g. near-endemics and migrants for

which Saudi Arabia represents a critical range).

4. Relict genera, species, or subspecies that are of global, regional, or national significance.

5. Genera or species of special ecological importance (i.e. fulfilling a vitally important function in an ecosystem such as providing a key habitat for other species, serving as indicator species, etc).

6. Genera of species of significant economic importance.

7. Genera or species that serve a “flagship” function (i.e. high-profile species of cultural value, the protection of which will also protect large numbers of other species that share their habitats).

The IUCN Red List categorises species into nine groups based on their risk of global extinction, set through criteria such as rate of decline, population size, area of geographic distribution, and degree of population and distribution fragmentation. The nine categories are:

• Extinct (EX) – No known individuals remaining.

• Extinct in the Wild (EW) – Known only to survive in captivity, or as a naturalized population outside its historic range.

• Critically Endangered (CR) – Extremely high risk of extinction in the wild.

• Endangered (EN) – High risk of extinction in the wild.

• Vulnerable (VU) – High risk of endangerment in the wild.

• Near Threatened (NT) – Likely to become endangered in the near future.

• Least Concern (LC) – Lowest risk. Does not qualify for a more at risk category. Widespread and abundant taxa are included in this category.





• Data Deficient (DD) – Not enough data to make an assessment of its risk of extinction.

• Not Evaluated (NE) – Has not yet been evaluated against the criteria.

Using the list of species of High Conservation Priority and the IUCN Red List (IUCN, 2012), a geographical frame of reference has been developed to assign value (Table 8-1). To fully acknowledge the spatial range associated with some biological resources (e.g. migratory birds) and potential impacts outside national boundaries, a “very high” level of significance will be considered where appropriate.

Table 8-1: Criteria for Valuing Biological Resources

Value / Importance Criteria / Examples

Local

Areas of semi-natural vegetation or habitat considered to appreciably enrich the habitat resource within the context of the site and surrounding area. Sustainable populations of uncommon or declining species.

Provincial

Areas of habitat considered to enrich the habitat resource within 50 km of the site or within a defined geographic area of the country.

Provincially designated or protected sites.

Sustainable or strong populations of nationally scarce species (would be defined according to the size of the country and information available, e.g., species occurring in less than 5% of the land surface of the country).

Regional

Sites or habitats internationally recognised but not necessarily designated or protected (e.g., Important Bird Areas).

Strong populations of endemic or near-endemic species or subspecies to the Arabian Peninsula.

Extensive areas of semi-natural vegetation or habitats characteristic of the Arabian Peninsula.

National

Nationally designated or protected sites.

Best examples of habitat within the country (e.g., the largest area of a particular habitat, a good example of a threatened or declining habitat).

Strong populations of rare or nationally threatened species (e.g., a species occurring in less than 1% of the land surface of the country).

Value / Importance Criteria / Examples

International

Internationally designated sites or habitats.

Nationally significant populations of globally threatened or endangered species (e.g., IUCN Vulnerable or Endangered Red Data Book species).

Sites supporting >1% of a biogeographical population of a species or subspecies.

Not Valued (Negligible) Species, population or habitat not meeting any of the above criteria.

The IUCN Red List of species is founded on a scientific understanding of the population status and trends of species. The value of utilising the list of species of High Conservation Priority is that the cultural and economic value of species is recognised and assigned a value of importance.

The Study Area covers an area of approximately 2947km2 and the survey methods have been designed to maximise the coverage of the survey whilst optimising the characterisation of the ecological baseline. However there are limitations to the resolution of detail that can be established for such a large Study Area and it is not possible to determine the precise usage of the site by particular species, and the key locations which provide important foraging areas and of places of rest and shelter (i.e. dens, burrows, breeding sites etc). Accordingly, a pre-cautionary approach has been taken when assigning a value to each of the biological resources and the assessment of ecological impact.

8.3.2 DESIGNATIONS

The Study Area is located within the jurisdiction of the Northern Wildlife Management Zone which is designated as a Category VI Protected Area. The IUCN definition for this category is to:

"conserve ecosystems and habitats, together with associated cultural values and traditional natural resource management systems. They are generally large, with most of the area in a natural condition, where a proportion is under sustainable natural resource management and where





low-level non-industrial use of natural resources compatible with nature conservation is seen as one of the main aims of the area." (IUCN, 2012).

Category VI protected areas do conserve biodiversity, particularly at ecosystem and landscape scale, but the aim would not be to protect them strictly from human interference. Although scientific research may be important, it would be considered a priority only when applied to sustainable uses of natural resources, either in order to improve them, or to understand how to minimize the risks to ecological sustainability (IUCN, 2012). Therefore a key objective of this category of Protected Area is to promote the sustainable use of natural resources, ensuring consideration is given to the ecological, economic and social dimensions.

In addition, there are two Protected Areas to the south of the Study Area and Project. These are as follows:

• Harrat Al Harrah Protected Area: This is an IUCN Category IV site and covers an area of 12,150km2 the landscape is dominated by numerous uplifted extinct volcanic cones and black basaltic boulders of the middle Miocene, making vehicle access mostly impossible. The Harrat al Harrah Protected Area was one of the initial biodiversity reserves established in Saudi Arabia (Child & Grainger, 1990; Seddon et al., 1997). The reserve provides habitat to over 250 species of plants, 50 species of birds and 22 species of mammals (Nader 1995; Seddon et al. 1997). It is located approximately 26km south of the Project area

The definition for IUCN Category IV sites is:

"Habitat/Species Management Areas focus on more specific

areas of conservation in correlation to an identifiable species or habitat that requires continuous protection. These protected areas will be sufficiently controlled to ensure the maintenance, conservation and restoration of particular species and habitats - possibly through traditional means - and public education of such areas is widely encouraged as part of the management objectives. Habitat or Species Management Areas may exist as a fraction of a wider ecosystem or protected area and may require varying levels of active intervention including - but not limited to - the prevention of poaching, creation of artificial habitats, halting natural succession and supplementary feeding practices." (IUCN, 2012).

This site was in part designated to afford protection to the Houbara bustard Chlamydotis (undulata) macqueenii.

• At Tubayq Protected Area: This is an IUCN Category III site and covers an area of c.12,200km² south of Harrat Al Harrah. The site consists primarily of desert and sandstone rocky plateaus and is one of the last remaining strongholds for the Nubian Ibex Capra nubiana.

The definition for IUCN Category III sites is:

"These are comparatively smaller areas that are specifically allocated to protect a natural monument and its surrounding habitats. Natural Monuments or Features can be natural in the wholest sense, or include elements that have been influenced or introduced by humans. The latter should hold biodiversity associations or could otherwise be classified as a historical or spiritual site, though this distinction can be quite difficult to ascertain. As such, the classification then falls into two subcategories, those in which the biodiversity in uniquely related to





the conditions of the natural feature, and those in which the current levels of biodiversity are dependent on the presence of the sacred sites that have created an essentially modified ecosystem. Natural Monuments or Features have a high cultural or spiritual value which can be utilised to gain support for conservation challenges." (IUCN, 2012)

The Protected Areas have been identified by the Saudi Wildlife Authority, and the Northern Wildlife Management Zone is owned both by the State due its proximity to the international boundary with Jordan, and private tribal landlords. However the area covered by the Project is state owned. Protected Area's are valued at the National level.

8.3.3 HABITATS

The principle survey areas of the larger Umm Wu’al area and the Mine represent distinct habitats. The Umm Wu’al landscape comprises an undulating system of fixed vegetated areas, with a mix of grasses, shrubs and small trees with a generally Saharo-Sindian Biome character. There is little or no natural surface water, but a system of traditional wells facilitates seasonal exploitation by herders.

The Mine by contrast consists of a relatively flat area of sand sheet and gravel plains and low rock outcrops, giving a more Saharan character, with no significant tree cover ( Plate 8-2 and





Plate 8-3). There are very few wells (none were seen) but during the current survey a small number of herders were encountered near ephemeral pools during the surveys (i.e. there had been rain / snow-fall), and herds of sheep were grazing.

Outside these focal study sites, the habitats traversed by the survey to the north of Umm Wu’al and south of the Mine comprise primarily grasslands, with tree cover slowly diminishing with increasing latitude/longitude.

The sector of the Umm Wu’al, moving north via the Mine, is distinctive in following the line of a major fossil drainage system, where the water catchment in a flat landscape has created a wide braided channel system on a huge scale, with temporary water pools in the depressions and belts of shrubs and trees in between.

Plate 8-2: Haloxylon persicum near the Mining area





Plate 8-3: Calligonum comosum (left) and seen near the in ternational border (right)

Habitats within the Study Area are valued are valued at the National level based on the Northern Wildlife Management Zone designation.

8.3.4 FLORA

The Study Area is characterized by its sparse, patchy dwarf shrub vegetation, concentrated in small drainage lines, wadis and silty depressions. There are no trees, except for the occasional Tamarix arborea along large stream beds north of the proposed Industrial Complex and near the Mine. Dominant perennial shrub species include Haloxylon salicornicum, Salsola spp. Artemisia spp., Achillea fragrantissima, Astragalus trimestris. Zilla spinosa and Capparis spinosa are abundant on the margins of silty depressions.

Perennial grasses, which include several Stipagrostis spp. are sparsely distributed and poorly represented, probably due to intensive sheep and camel grazing in some areas. Chert/gravel plains (hamad) and rocky basalt slopes (harrahs) and jabals support few perennial plants. A community of Haloxylon persicum and Calligonum comosum grows on mobile sand drifts.

The southern parts of the Study Area and in association with Helianthemum lippii grows the edible fungus Terfezia claveryi, known as faq‘ah in Arabic. A local delicacy, faq‘ah is highly sought after by people from surrounding districts and fetches high prices in markets throughout the Kingdom.

A full list of plants recorded in the Study Area, or known to occur, is given below in Appendix E.

The plant species and communities within the project area will vary spatially and temporally subject to seasonal (e.g. rainfall, temperature) and geophysical (e.g. elevation) variations. The condition of plants was qualitatively assessed based on chlorophyll content of plants, and no significant variation was observed between the three trips (i.e. November and December 2012 and April 2013).

Flora within the Study Area are valued at the National level based on the Northern Wildlife Management Zone designation. In terms of the assessment of impact, impacts on flora have been combined with impacts on habitat.

8.3.5 FAUNA

Data was collected on many species of large and small mammal during the survey, in addition to 72 species of birds, and 11 species of reptile. Faunal diversity was observed by direct observations, footprints and camera traps is summarised in Figure 8-5.





Figure 8-5: Faunal diversity observed by direct observatio n - footprints & camera traps. 8.3.5.1 CAMERA TRAPS

In total, five mammal species were photographed, of which Blanford’s Fox (Plate 8-4) was strongly attracted to the sardine bait and was by far the most frequently recorded during the three field surveys (Table 8-2 ). Otherwise jerboa and hedgehog were the next most frequent encounters, then porcupine (Plate 8-5) whilst the Arabian wolf (Plate 8-6) was encountered only once. A brown-necked raven just after sunrise completes the data set.

Table 8-2: Summary Results of Opportunistic, Nightly Bait ed Camera Trapping

Common Name Scientific Name

Number of Triggers

Camera Position

Blandford’s fox Vulpes cana 25 1, 2, 3, 4, 6, 7, 5

Arabian wolf Canis lupus arabs

1 1

Hedgehog unknown 3 4,5

Jerboa unknown 7 3,5,6,9

Brown-necked raven Corvus ruficollis

2 1,3,5,7

Indian crested porcupine Hystrix indica

2 5

False triggers - 35 All camera traps





Plate 8-4: Sardine Baited Camera Trap - attractions for B lanford’s fox Vulpes cana

Plate 8-5: Indian crested porcupine Hystrix indica

Plate 8-6: Arabian wolf Canus lupus arabs





8.3.5.2 MAMMALS

The region used to be very rich in terms of mammals presence 150-20 years before and animals such as Striped hyaena Hyaena hyaena, caracal Felis caracal (historically recorded and possibly still present), Arabian Wolf Canis lupus (still present in the area), and the honey badger or ratel Mellivora capensis were recorded (local people pers. comm. 2012).

Now these mammals are not present these days and have been exterminated due to human settlements and developmental projects.

Seddon et al. (1997) have prepared a paper on the status of mammal species in the Harrat al Harrah Protected Area. Between 1991 and 1996 records of mammals were compiled and surveys and trapping undertaken. A total of 22 mammal species, including three domestic animals were recorded within the reserve's boundaries (Seddon et al., 1997). This included the Arabian wolf, the striped hyaena and the caracal.

The Project area may have been part of the former distribution of the Arabian oryx Oryx leucoryx before it was hunted to extinction. The last documented record from the area (south of Wadi Sirhan) was in 1926.

The following is a list of animals that used to be found in the vicinity of the Project (Table 8-3):

Table 8-3: Species historically recorded from the Study A rea

Common Name Scientific Name Last Known Activity

Striped Hyaena Hyaena hyaena used be found in the area 5-10 years before

Cheetah Acinonyx jubatus used to be found in the area some 50-70 years before, now extinct

Onager Equus hemionus used to be found in the area some 50-70 years before, now extinct

Nubian Ibex Capra (ibex) nubiana used to be found in this area some 50 years before, now locally extinct

Arabian Oryx Oryx leucoryx used to be found in this area some >100 years before, now locally extinct

Mountain gazelle Gazella gazella used to be found in this area some 50 years before, now locally extinct

Sand gazelle Gazella subgutturosa used to be found in this area between 30-50 years before, now locally extinct

Excluding domestic species and livestock, a total of 22 mammal species were recorded within the Study Area as part of the field surveys, or suspected to be present based on professional judgement and anecdotal evidence (see Appendix E). The evidence of mammals was recorded by either field sign (i.e. tracks and droppings), direct visual sightings (Plate 8-7) and camera traps. In addition a single dead specimen of the Ethiopian hedgehog Paraechinus aethiopicus was recorded near Umm Wu'al (Plate 8-8).

Many of the mammal species are listed as Least Concern (Global Assessment) on the IUCN Red List on the basis that there are no known major threats believed to be resulting in a significant decline in their population status. Indeed, during the field surveys evidence of these species was widespread throughout the Project area (e.g. Arabian hare Lepus capensis arabica and small mammal species).

However the conservation status of many of the larger and medium sized mammal species is less favourable and this is reflected on both the Global and Regional IUCN Red List. These species are described in more detail below:





Arabian wolf Canis lupus : The presence of the Arabian wolf within the Project area was confirmed through frequent field signs (e.g. tracks) and a single specimen was caught on a camera trap. This specimen is reported to be living in the area (pers. comm). From the present field surveys it is clear that wolves in the Umm Wu’al area are found in low numbers especially between Industrial Complex and the Mine, and due to their scavenging omnivorous behaviour they may benefit from the human settlements.

However this species is listed as Endangered at a Regional level (IUCN, 2011) due to the rate of population decline in the Arabian Peninsula. The principle causes of decline are persecution, a reduced prey base and hybridisation with domestic dogs.

Sand cat Felis margarita: The Near Threatened (IUCN, 2012) sand cat Felis margarita was also recorded within the Study Area. The sand cat is one of the rarest cats in the north of Saudi Arabia and during the field surveys in the Mine, a total of 21 foot prints were recorded in wadis. The presence of the cat was also confirmed by military personnel patrolling the mining area. The sand cat appears to have a markedly patchy distribution in the Project area.

Blanford’s fox Vulpes cana : This species was recorded as being locally common near the Industrial Complex. Although listed as Least Concern at a global level, the Blanford’s fox is listed as Vulnerable on the Regional level (IUCN, 2011) due to the rate of population decline in the Arabian Peninsula. The principle cause of decline is general persecution, poisoning and habitat loss due to expanding human development.

Honey badger Mellivora capensis: Although not directly recorded during the field surveys, the potential presence of honey badger has been indicated through anecdotal evidence and professional judgement. Although rare, it is possible that honey badger utilise the wadis between the Industrial Complex and the Mine. This species is listed as Least Concern at a global level, but as Near Threatened at a regional level by the IUCN (2011).

Marbled polecat Vormela peregusna : This species was first recorded from Saudi Arabia as a live animal caught in 1991 from the Study Area in Turaif (Nader 1991). During the present surveys, this species was not recorded however while talking with local people showing the picture of the animal, they claimed that this species is there between the Industrial Complex and the Mine. As per the IUCN Red List 2012, this species is listed as Vulnerable under criteria A2c (population reduction). It seems reasonable to infer at least a 30% reduction in the population in the last ten years due to the loss of steppe habitat. This reduction may continue into the future, as suggested by climate change models and land-use change.

Striped hyaena Hyaena hyaena : Although not recorded during the survey, the striped hyaena has historically been recorded within the Study Area, although there have been no recent sightings within the last 10 years. This species is classified as Near Threatened on the IUCN Red List of 2012.

During the course of the survey, several livestock species were recorded within the Project area (i.e. donkey, camel and sheep) and the domestic dog Canis lupus familiaris was on occasion present at the camps. The presence of livestock is considered further in Section 7.3.6.





Plate 8-7: Red Fox Vulpes vulpes Plate 8-8: Dead hedgehog

Untended herds of camel Camelus dromedarius range freely throughout the area. Dogs Canis lupus familiaris and feral cats F. silvestris are occasionally found in the area.

The Asiatic jackal Canis aureus has been recorded close to the Mine and therefore may be present at least seasonally in some parts of the area.

Those species of mammal which are globally or regionally threatened are valued at the International level. All other species (Least Concern and below) are valued at the Local level. This assignment of value is based on the regional conservation status of carnivores as published by IUCN (2011), in particular the Arabian wolf.

8.3.5.3 AVIFAUNA

The region, including the Harrat Al Harrah and At Tubayq Projected Areas, regularly contain 1% or more of the biogeographical or flyway population of Eurasian Dotteral Eudromias morinellus (i.e. 1,500 - 3,000 wintering); as well as the regionally threatened / declining saker falcon Falco cherrug, a regular passage migrant. Species restricted wholly or largely to the Middle East include the Arabian sand partridge Ammoperdix heyi, Hume’s owl Strix butleri, Finsch’s wheatear Oenanthe finschii, and short-toed lark Carpospiza brachydactyla (Jennings, 2010).

The region was one of the last places where the ostrich Struthio camelus syriacus occurred in Saudi Arabia before being hunted to extinction. The last documented record from the area was in January 1930 and fragments of ostrich shells can still easily be found throughout the area (Jennings 1986).

A total of 72 species of birds have been recorded through the field surveys (see Appendix E). The current list for the study area contains important species that include many migrants, notably birds of prey, but also water-birds, using the temporary pools after heavy rain. To the south of the Study Area is the Harrat al Harrah Protected Area which is an attraction to most of the birds due to fewer disturbances. This Protected Area is important as both a breeding ground and a seasonal winter refuge for Houbara bustard Chlamydotis (undulata) macqueenii.

The Study Area holds a diverse breeding community of larks that include desert lark Ammomanes deserti, hoopoe lark Alaemon alaudipes, crested lark Galerida cristata, Temminck’s horned lark Eremophila bilopha and thick-billed lark Ramphocoris clotbey.

The Study Area also regularly sees a significant number of a globally threatened species, and they are described below in more detail:

Greater Spotted Eagle Aquila clanga : Two birds were recorded near Umm Wu’al in the evening of 17 November 2012. This species has a small population which appears to be declining owing to extensive habitat loss and persistent persecution. It is therefore listed as Vulnerable (IUCN, 2012).





Saker Falcon Falco cherrug : One bird was caught near Umm Wu’al by a falconer in October 2012 and the captured bird’s picture was shown to us during the field surveys by a falconer, who reported that this bird is seen in winters in October and November almost each year. This species has been uplisted to Endangered because a revised population trend analysis indicates that it may be undergoing a very rapid decline. This negative trend is a result of unsustainable capture for the falconry trade, as well as habitat degradation and the impacts of agrochemicals, and the rate of decline appears to be particularly severe in the species central Asian breeding grounds. This classification is highly uncertain and may be revised when new information becomes available (BirdLife International & IUCN 2013).

Houbara Bustard Chlamydotis undulata macqueenii : This species is frequently seen and captured in the region by falconers and it was recorded breeding in Harrat al Harrah (Van Heezik & Seddon 1995, 97). This species is classified as Vulnerable because it has undergone rapid population declines over three generations (20 years) owing largely to unsustainable hunting levels, as well as habitat degradation (BirdLife International 2013).

During the field surveys this bird was not recorded by the survey team but local people confirmed the presence of this bird in the Umm Wu’al Industrial Complex area.

Egyptian Vulture Neophron percnopterus : This vulture was recorded in November at Umm Wu’al and this long-lived species qualifies as Endangered (IUCN, 2012) owing to a recent and extremely rapid population decline in India (presumably resulting from poisoning by the veterinary drug Diclofenac) combined with severe long-term declines in Europe (>50% over the last three generations (42 years) and West Africa, plus ongoing declines through much of the rest of its African range.

Pallid Harrier Circus macrourus : It was recorded at the Mine in November 2012. It is a passage migrant bird and is known to be undergoing steep population decline in Europe, although numbers in its Asiatic strongholds are thought to be more stable. Thus it is probably experiencing a moderately rapid population decline overall, and consequently it is categorised as Near Threatened (IUCN, 2012).

European Roller Coracius garrulous : It was recorded between Umm Wu’al and the Mine in the wadi. It is a passage migrant bird and this species has apparently undergone moderately rapid declines across its global range and it is consequently considered Near Threatened. Declines have been most pronounced in northern populations, and if similar declines are observed elsewhere in the species range it may warrant uplisting to Vulnerable (IUCN, 2012).

Those bird species which are globally or regionally threatened are valued at the International (i.e. Houbara bustard). All other species (Least Concern and below) are valued at the Local level.

8.3.5.4 REPTILES

A total of 11 reptile species were recorded within the Study Area during the field surveys, and includes lizards and snakes. Due to the periods of survey, it is possible that additional species of reptiles are present and weren't confirmed as being present during the filed surveys. The reptile species recorded are presented in Appendix E.

Several of the species are listed as species of High Conservation Priority, whilst the spiny tailed lizard Uromastyx aegyptius microlepis is listed as vulnerable on the IUCN Red List (Plate 8-9). This species is listed as Vulnerable as there has been a suspected population decline of over 30% over the past 15 years (3 generations) and this is expected to continue into the future (IUCN, 2013). This species is threatened from continued collection for food and medicinal purposes, and habitat change.





Plate 8-9: Spiny-tailed Lizard Uromastyx aegyptius microl epis

Those reptile species which are globally or regionally threatened are valued at the International level (i.e. Egyptian spiny tailed lizard). All other species (Least Concern and below) are valued at the Local level.

8.3.6 ANTHROPOLOGICAL ACTIVITY WITHIN STUDY AREA

Within the Study Area there are no permanent settlements. The town of Turaif lies some 40km to the south-west of Umm Wu’al and north-west of important wildlife areas (i.e. Protected Areas).

However there are a number of nomadic camps that have been recorded. A simple comparison of the crude encounter rate with campsites during survey work in November and December 2012, suggests that there were relatively more people using the area in November, with indices of encounter some 30-40% higher. Temporary encampments were recorded at 25 locations over the course of all three field visits, with some 41 individual shepherds counted at these sites (Figure 8-6).

Associated with the presence of the nomadic camps is the occurrence of livestock. These animals are currently grazing habitats within the Project and consist of donkeys, camel, domestic dog and sheep (Plate 8-10). The grazing of these livestock is likely to impact on the abundance and diversity of natural vegetation within the Study Area.





Figure 8-6: Herder Camps Recorded in Field Visits

All livestock groups were counted by species and number from the vehicle during vehicle transects. Where accurate counting was impractical, usually because of tightly bunched groupings, numbers were estimated. Raw observation totals by species are summarized in Figure 8-7. The most frequently encountered livestock were sheep followed by small numbers of donkeys and camels. However the sampling method for small stock was insufficient to produce a reliable population estimate, rather just actual count data is presented.

Plate 8-10: Sheep with temporary livestock feeding site near Umm Wu’al





Plate 8-11: Sheep at temporary livestock feeding site ne ar Umm Wu’al showing fodder and water tanker

Donkeys are widespread through the central and southern areas visited, and used extensively to carry grass bundles, firewood and other loads. The transect methodology has enabled the first estimation of livestock numbers in the Umm Wu’al area.

Figure 8-7: Numbers Domestic Animals Recorded within the P roject Area.

Within the Study Area there are existing locations where localized phosphate mining has been undertaken in the form of test pits (Plate 8-12).





Plate 8-12: Ma’aden Test Pit with an official from Ma’ade n Mining Company


The construction, commissioning, operation and decommissioning of the Project has the potential to impact on the ecological integrity and functionality of the Study Area, and to adversely affect individual species, populations and communities of plants and animals. To ensure that the impact assessment process is transparent and robust and permits the identification of targeted and specific mitigation measures, a systematic and rigorous approach to impact identification and characterisation has been adopted as outlined in Chapter 5: Impact Assessment Methodology. This systematic approach facilitates the identification of potentially significant impacts on the identified biological resources and has been augmented further as described in the following sections.

An ecologically significant impact is defined in the context of this assessment as 'an impact (negative or positive) on the integrity of a defined site or ecosystem and/or the conservation status of habitats or species within a given geographical area' (IEEM 2006) and whether there is a cultural or economic implications from the impact on the habitat or species in accordance with nationally identified High Conservation Priority species. The assessment of impact takes into consideration the 'value' of each ecological receptor, and the changes that might occur to its conservation status at the defined geographical scale described in Section 7.3.

The European Commission Habitats Directive 1994 (Article 1, sections (e) and (i)) provide a helpful definition of 'conservation status' for habitats and species. This definition has been interpreted as:

• habitats, conservation status is determined by the sum of the influences acting on the habitat and its typical species, that may affect its long-term distribution, structure and functions as well as the long-term survival of its typical species within a given geographical area; and

• species, conservation status is determined by the sum of influences acting on the given species concerned that may affect the long-term distribution and abundance of its populations within a given geographical area.

Impact significance for biological resources has been determined by comparing magnitude against the geographic value/importance of such resources. Table 8-4 shows the criteria used to define the type and magnitude of impacts on biological receptors. These are based on currently accepted guidelines produced in the UK (IEEM, 2006).





Table 8-4: Magnitude and Type Definitions for Potential I mpacts on Biological Resource

Magnitude / Type Criteria

High The change is likely to cause a permanent adverse effect on the integrity of a biological resource receptor.

Medium The change adversely affects the biological resource receptor, but no permanent effect on its integrity.

Low Minimal or no effect.

Medium Positive The change is likely to benefit the receptor in terms of its conservation status, but not so far as to achieve favourable conservation status6.

High Positive The change is likely to restore a biological resource to favourable conservation status, or to create a feature of recognisable value.

The identification and management of impacts has also taken into account the advice for protecting, restoring and enhancing biodiversity and ecosystem services as set out in the International Finance Corporation's Performance Standards, in particular Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Resources (2012), and the Equator Principles (2006). Furthermore, due to the fragility of this ecosystem and the patchiness of habitats and biological resources, a precautionary approach has been taken when assessing significance.

In assessing the impacts of the scheme, it is important to recognise the current baseline conditions of the Project area and the influence existing human activities and disturbance have on these. There are high levels of disturbance in the locality associated with the following activities:

• Grazing livestock;

• Un-authorised vehicle movements through the steppe habitat;

• Nomadic camps; and

• Soil extraction.

To aid consistency of the phosphate mine impact assessment, a standard list of potential adverse impacts for this Project has been developed for the construction, commissioning and operational phases. These impacts and the associated activity / cause are set out in Table 8-5 and Table 8-6. Impacts associated with the decommissioning phase are positive and are described further in Section 8.6.

When determining the significance of impact for each biological resource (e.g. habitats, mammals, birds and or reptiles), the species of highest 'value' and sensitivity has determined the impact assessment outcome.

6 The term “favourable conservation status” used is derived from the European Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora.





Table 8-5: Construction and commissioning impacts

Impact Activity / Cause

Habitat loss • Site clearance and cut and fill operations to prepare development areas (e.g. chemical processing / industrial complex, Waad Al Shamaal city development).

• Diversion of ephemeral wadi drainage channels / flood protection works.

• Construction of temporary haul routes and permanent roads. • Installation of utilities. • Construction of new water wells. • Installation of perimeter fence around mine. • Stockpiling of overburden from cut and fill operations.

Habitat degradation

• Site clearance and cut and fill operations to prepare development areas (e.g. chemical processing / industrial complex, Waad Al Shamaal city development).

• Smothering and compaction of habitat from storage of overburden arising from cut and fill operations.

• Changes to hydrological functionality of wadi drainage channels and the pattern of surface water flows (i.e. erosion and deposition).

• Increased use of natural environment by construction workforce. • See impacts under Pollution.

Habitat fragmentation

• Construction of roads and utilities. • Construction of temporary and permanent roads. • Installation of perimeter fence around mine. • Installation of conveyor systems. • Diversion of ephemeral wadi drainage channels.

Direct mortality / injury of species

• Site clearance and cut and fill operations to prepare development areas (e.g. chemical processing / industrial complex, Waad Al Shamaal city development).

• Construction of temporary haul routes and permanent roads. • Installation of utilities. • Installation of perimeter fence around mine. • Stockpiling of overburden from cut and fill operations. • Construction of new water wells. • Movement of construction vehicles.

Disturbance • Noise / vibration during construction. • Movement of construction vehicles and people during construction

and operation of the Sanctuary. • Increased use of natural environment by construction workforce.

Pollution • Noise and dust emissions. • Run-off from disturbed ground. • Spillage of oils / chemicals. • Insufficient storage of food waste attracting vermin.

Alien Species • Predation by domestic animals (i.e. dogs and cats). • Transmission of disease from domestic aninmals (i.e. dogs and cats). • Introduction of invasice plant species and biological pathogens

through landscaping.





Table 8-6: Operational impacts

Impact Activity / Cause

Habitat loss • Open cast mining. • Diversion of ephemeral wadi drainage channel within the mine

(Year 15).

Habitat degradation • Changes to hydrological functionality of wadi drainage channels and the pattern of surface water flows (i.e. erosion and deposition).

• Increased use of natural environment by operational workforce. • See impacts under Pollution.

Habitat fragmentation

• Permanent presence of significnat infrastructure, including security fences and roads.

Direct mortality / injury of species

• Open cast mining. • Diversion of ephemeral wadi drainage channel within the mine

(Year 15). • Increased hunting.

Disturbance • Increased movement of vehicles and people within the region. • 24hr operation of the mine and all supporting processes. • Increased use of natural environment by operational workforce.

Pollution • Noise pollution generated from the use of explosives, rock crushers and 24hr operations.

• Light pollution from 24hr operation of the mine and all supporting processes

• Run-off from rock storage areas in mine, tailings stockpile near processing complex and the phosphogypsum stack.

• Concentration of chemical pollutants in evaporation ponds. • Dust generation. • Spillage of oils / chemicals. • Emissions to air reducing air quality – possible impacts on

vegetation (e.g. acidification).

Alien Species • Predation by domestic animals (i.e. dogs and cats). • Transmission of disease from domestic animals (i.e. dogs and

cats). • Increased risk of hybridisation between Arabian wolf and domestic

dog.

For the purpose of the impact assessment the Project Area is described as the Mine (i.e. all mining excavation works) and the Industrial Complex. The Industrial Complex includes the chemical processing complex, phosphogypsum stacks and the Waad Al Shamaal city development included within the scope of this ESIA and the Umm Wu'al wells.

When undertaking the assessment process, a precautionary approach has been adopted to reflect the lack of specific data on population size and density, and a detailed understanding of how each species is utilising the area. In taking this precautionary approach, the species of highest conservation value have been used to characterise and determine the significance of impacts.

8.4.1 CONSTRUCTION & COMMISSIONING

Impacts predicted during the construction and commissioning phases are described further in the following sections. Specific potential impacts on biological resources due to the proposed construction and commissioning phases are summarised in Table 8-7 and described further below.





Table 8-7: Construction and commissioning impacts

Factor E1 E2 E3 E4 E5 E6 E7 E8 E9


National Local International Local International International Local International International

Frequency Continuous Single event Single event Single event Single event Single event Frequent Frequent Frequent

Likelihood Likely Likely Likely Likely Likely Likely Likely Likely Likely

Extent Local Local Provincial Local Provincial Provincial Local Local Local

Duration Medium Medium Medium Medium Medium Medium Medium Medium Medium

Magnitude Medium Medium High Low Medium Medium Low Medium Medium

Reversibility Irreversible Irreversible Irreversible Irreversible Irreversible Irreversible Reversible Reversible Reversible

Effect Direct Direct Direct Direct Direct Direct Direct Direct Direct

Action Negative Negative Negative Negative Negative Negative Negative Negative Negative

Significance High Low High Low High Medium Low High Medium





Factor E10 E11 E12 E13


Local International International International

Frequency Continuous Continuous Infrequent Infrequent

Likelihood Likely Likely Unlikely Unlikely

Extent Local Local Local Local


Magnitude Medium Medium Medium Medium

Reversibility Reversible Reversible Reversible Reversible

Effect Direct Direct Indirect Indirect

Action Negative Negative Negative Negative

Significance Low Medium Low Medium





8.4.2 DESIGNATIONS

The phosphate mine, processing complex and associated infrastructure fall within the Northern Wildlife Management Zone. A key objective for this category of Protected Area is to promote the sustainable use of natural resources ensuring consideration is given to its ecological, economic and social dimensions. Category VI protected areas do conserve biodiversity, particularly at ecosystem and landscape scale, but the aim would not be to protect them strictly from human interference (IUCN, 2012).

As such, the sustainable exploitation of the phosphate resource is in keeping with the principles of this category of designation. Notwithstanding this compatibility with the principles of this category, the construction and commissioning of the Project will impact on approximately 59km2 of natural habitat for which this Protected Area has been recognised. This impact represents approximately 0.5% of the total area of the Protected Area. Although this is not likely to detrimentally affect the integrity or functionality of this designation, it will have an impact on species of global and regional significance using this site. There is presently insufficient information to ascertain the quality of the Project area in comparison to the remainder of the Northern Wildlife Management Zone and so for this reason a precautionary approach has been taken. The impact on this Protected Area is predicted to be adverse high significant.

The construction and commissioning activities are in excess of 25km from the Harrat Al Harrah Protected Area (IUCN Category IV), and further still from the At Tubayq Protected Area (IUCN Category III). These sites will not be directly impacted as a direct result of the construction and commissioning activities. As a consequence, the construction and commissioning activities associated with the Project will not impact on the integrity or functionality of these designations.

In the absence of mitigation, the impact on the Northern Wildlife Management Zone is assessed as high adverse significant.

Impact E1 - High Significance .

8.4.3 DIRECT KILLING / INJURY

Site clearance and cut and fill operations to facilitate the Project during the construction phases, including the diversion of wadi drainage channels and flood protection works, have the potential to kill and injure mammal, bird and reptile species. Impacts are likely to arise from the direct damage and destruction to places of rest and shelter, breeding sites and nesting sites. There is also an increased risk that faunal species could be involved in collisions with construction vehicles as a consequence of increased road traffic and vehicle movements, although measures will be implemented to enforce speed limits and usage of designated haul / access routes.

The majority of species recorded within the Study Area are listed as being of Least Concern on the IUCN Red List (2012), and their conservation status is not currently threatened. As a consequence, the unintentional killing and injury of species which are of Least Concern (IUCN, 2012) during the construction / commissioning phase is assessed as low adverse significant.

Impact E2 – Low Significance .

However a number of globally and regionally threatened species that have been recorded as being present, or their presence is indicated from anecdotal evidence could be impacted. This includes the Arabian wolf (Regionally Endangered), sand cat (Globally Near Threatened), Blanford’s fox (Regionally Vulnerable), and the Egyptian spiny tailed lizard (Globally Vulnerable). In addition, the Houbara bustard (Globally Vulnerable) may potentially breed within the area of the Project and this is a ground nesting species.

The low population density and generally sparse distribution of these globally and regionally threatened species means that the loss of individual animals could represent a significant loss to the local population. Furthermore, should species that have historically been recorded in





the Study Area return (i.e. striped hyaena), the loss of individuals would constitute a significant impact to these recovering populations.

Furthermore, the Egyptian spiny tailed lizard is less mobile than the other species and tends to construct its burrows in areas where there is persistent vegetation through the summer months and from where they do not stray too far (i.e. predator avoidance). For this reason, there is a particular risk of killing and injuring this species during flood protection works and other impacts to wadi drainage channels.

Therefore, potential impacts of killing and injury on these threatened species during the construction / commissioning phases of the project are assessed as high adverse significant.

Impact E3 – High Significance .

8.4.4 HABITAT LOSS / DEGRADATION

During the construction and commissioning phases of the project, there will be impacts of habitat loss and degradation. Principally these impacts will be direct, arising from site clearance works, cut and fill operations, the temporary stockpiling of materials and the diversion of wadi drainage channels for flood protection works. Direct impacts of habitat loss and degradation could also potentially arise from vehicles deviation from defined haul routes and access corridors.

Indirect impacts of habitat degradation are also likely to arise from the diversion of the wadis and associated changes to the hydrological functionality of these drainage channels which could increase erosion and sediment deposition to the detriment of habitats.

Habitats impacted by the Project provide valuable natural resources for the faunal species recorded during the field surveys. This includes the provision of foraging habitat and places of rest and shelter and breeding sites. A reduction in the availability and quality of habitat will reduce the carrying capacity of the Project area. Impacts of habitat loss and degradation on species of Least Concern and below are predicted to be low adverse significant.

Impact E4 - Low Significance

However such impacts could result in significant adverse impacts on globally and regionally threatened species which are displaced from the Project area (e.g. Arabian wolf, Blanford's fox, sand cat, Houbara bustard). Displacement of these species has the potential to increase inter-specific and intra-specific competition for resources adjacent to the Project area and within the wider region, and increase the likelihood for con-specific aggression.

For example the loss and degradation of wadis in particular is likely to have a significant adverse impact on Blanford's fox. These habitats within the landscape tend to support more complex ecosystems and Geffen et al. (1992b) found that dry creek bed was the most frequently visited habitat in all home ranges for the Blanford’s fox in Israel based on the availability of small mammal prey. Under this scenario, the remaining wadis in the area would need to sustain an increased number of predatory carnivores.

Although some species such as Blanford’s fox and the Arabian wolf show evidence of habituation to humans, and even scavenge for food around areas of habitation, potential impacts of habitat loss and degradation on the globally and regionally threatened mammal species are predicted to be high adverse significant. This is on the grounds that there is evidence of these species within the Project area, and that the Project likely includes part of these species territories. At this stage it is unknown whether the Project area forms part of the core range of these species and so a precautionary approach has been taken.

Impact E5– High Significance.

Furthermore, there is potential for the value of the Project area for important breeding and over-wintering bird species (i.e. Egyptian vulture, Great spotted eagle and the Houbara bustard) and as a stop-over point for migrant species, to become less favourable. This is with particular reference to the Houbara bustard which may potentially breed within the project area. However these species, in particular the Houbara bustard, are highly mobile and the loss and degradation of habitat represents a small proportion of the overall habitat within the





Northern Wildlife Management Zone. Furthermore, there is no impact on the Harrat Al Harrah Protected Area which was established for the Houbara bustard.

Although the Egyptian spiny tailed lizard has been confirmed as being present on the site, populations appear to be small and localised. With the population of Turaif nearby, it is possible that this species has historically suffered from local collection and removal from the wild for food or sale.

Impacts of habitat loss and degradation on the Houbara bustard and the Egyptian spiny tailed lizard are predicted to be medium adverse significant.

Impact E6 - Medium Significance

8.4.5 HABITAT FRAGMENTATION

The installation of the security fence around the Mine and other areas of the Project area (e.g. Industrial Complex), and the construction of other significant infrastructure including roads and conveyor systems, has the potential to sever and fragment existing habitats (e.g. wadi drainage systems).

The fragmentation of habitats could impair their functionality (e.g. the separation of resting / breeding sites from foraging areas), and act as a barrier to the exchange of genetic material within the wider population by hindering the normal dispersal and migration of globally and regionally threatened species. Furthermore, the severance and fragmentation of habitats has the potential to increase the distances which some of the mammal species will need to travel, placing greater demands on their energy budgets to the extent that their survival is compromised.

The severance of habitats could also limit and act as a barrier to the potential ingress species currently absent from the Project area, or are limited in population size (e.g. striped hyaena and honey badger).

Impacts of habitat fragmentation on small mammals, species of Least Concern and below, and bird species are not predicted to be significant.


The impact on globally and regionally threatened mammal species is predicted to be high adverse significant. This includes the Arabian wolf (Regionally Endangered), sand cat (Globally Near Threatened) and Blanford’s fox (Regionally Vulnerable).

Impact E8 - High Significance

The Egyptian spiny tailed lizard typically lives in loose colonies and their home ranges tend to be limited to avoid predation (i.e. remain in close proximity to burrow). For this reason, the fragmentation of habitats has the potential to sever local populations of this species within the Project area, thereby reducing the viability of the species in this location. However, baseline surveys suggest that populations of this species are small and localised. The fragmentation of habitats is similarly likely to affect other reptile species that are present within the Project area (e.g. desert monitor).


8.4.6 DISTURBANCE

Within the Study Area, it was evident that there are existing ambient levels of disturbance in proximity to the Project site. This includes small scale phosphate extraction (Ma’aden text pit), brick kiln workings, herders with grazing livestock and the use of off-road vehicles (Figure 8-8).

Levels of disturbance associated with presence of a temporary workforce of approximately 7,000 – 10,000 people is not predicted to significantly increase during the construction phase. This workforce is likely to be comprised predominantly by expatriate workers without access to 4x4 vehicles, and recreation facilities will be provided within the worker camps to limit unauthorised access into adjoining habitats.





Figure 8-8: Illustration of Existing Disturbance to Land c lose to Highway 85 (outside of Project Area)

However, the construction phase will generate significant levels of noise disturbance and visual disturbance associated with the movement and operation of vehicles and machinery. These activities have the potential to result in the displacement of species from the Project area and the zone of influence, to the detriment of these individuals through increased competition of resources and / or displacement into habitats which are of lower quality. This includes the avoidance of the area by migrant, wintering and breeding bird species. However, some species that have long associations with human habitation are likely to benefit from the additional human presence (e.g. house sparrow and the house bunting).

The behaviour of those species and individuals not displaced is likely to be modified to avoid disturbance (e.g. less time spent foraging) and this could impact the viability of these populations (i.e. Egyptian spiny tailed lizard).

Impacts on species of Least Concern and lower are predicted to be of low significance.

Impact E10 - Low Significance.

In considering the existing levels of ambient disturbance, impacts on globally and regionally threatened species (i.e. Arabian wolf, sand cat, Blanford’s fox, Egyptian spiny tailed lizard and the Houbara bustard) are predicted to be a medium adverse significant.

Impact E11 - Medium Significance.

8.4.7 POLLUTION

During the construction and commissioning phase there will be a number of pollution pathways that could impact upon habitats and species, including those which are of conservation concern.

The construction phase of the Project will generate approximately 100,000 tonnes of construction waste, including food waste. The implementation of an effective waste management strategy will limit the potential for food waste to attract vermin, thereby avoiding any significant increase of predation on species. This strategy will also reduce the attractiveness of the construction camps to scavenging mammals (i.e. Arabian wolf and fox species) thereby reducing potential human / animal conflict.





The clearance of areas in preparation for development (e.g. Industrial Complex) and cut and fill operations has the potential to significantly increase soil erosion and sediment run-off during times of rainfall. Although the risk is intermittent, the erosion and deposition of sediments could potentially result in the loss and degradation of habitats within the ephemeral wadi drainage channels.

Construction activities also have the potential to generate significant amounts of dust. However full dust suppression techniques will be implemented to reduce dust emissions and the possible smothering of adjacent habitats.

Impacts of pollution are therefore assessed as low significance.

Impact E12 – Low Significance .

8.4.8 ALIEN SPECIES TRANSFER

During the construction and commissioning phases there a large workforce will be temporarily established within the Project area. There will be regulations in place to ensure that this workforce does not bring into the Project area any domestic pets such as cats and dogs. Domestic animals have the potential to act as vectors for the transmission of disease to wild animal populations of Arabian wolf and members of the Felidae family (e.g. sand cat, wild cat). For example the Arabian wolf population could be at risk of contracting canine distemper from domestic dogs brought to the Project area.

During the construction of the Ma'aden housing area within the Waad Al Shamaal city development, there is potential for extensive landscape planting to be undertaken. The importation of plants from commercial growers has the potential to introduce biological pathogens into the area. Furthermore, non-native and non-indigenous species brought to the area as part of landscaping proposals have the potential to spread into the wild from development areas to the detriment of native flora and fauna.

Impact E13 – Medium Significance .

8.5 OPERATION

Impacts predicted during the operational phase are presented in Table 8-8 and described further in the following sections.





Table 8-8: Operational impacts

Factor E14 E15 E16 E17 E18 E19 E20


International Local International International Local International International

Frequency Infrequent Frequent Frequent Frequent Frequent Frequent Infrequent

Likelihood Unlikely Likely Likely Likely Likely Likely Unlikely

Extent Local Local Local Local Local Local Local

Duration Medium Medium Medium Medium Medium Medium Long

Magnitude Medium High High High Medium Medium Medium

Reversibility Irreversible Reversible Reversible Reversible Reversible Reversible Reversible

Effect Direct Direct Direct Direct Direct Direct Indirect

Action Negative Negative Negative Negative Negative Negative Negative

Significance Medium Low High Medium Low Medium Low





8.5.1 DESIGNATIONS

The permanent operation of the Mine and Industrial Complex within the Northern Wildlife Management Zone is compatible with the principles of this designation, subject to the implementation of sustainable resource utilisation. Therefore the operation of the Mine and the Industrial Complex is unlikely to have any significant adverse impacts on the integrity and functionality of this site, or indeed that of the Harrat Al Harrah and At Tubayq Protected Areas.

Therefore the sustainable operation of the mine is not expected to have any further impacts on Protected Area designations over and above those identified during the construction phase.

8.5.2 DIRECT KILLING / INJURY

The loss of habitats within the Mine as mining progresses through the life of the Project has the potential to kill or injure faunal species. Larger mammal species are likely to have been displaced during the construction phase (i.e. Arabian wolf), and the on-going Mining activities, including the regular use of explosives, will largely deter other species from using the Mine. This includes Blanford’s fox, sand cat and Houbara Bustard.

There is also an increased risk that faunal species could be involved in collisions with operational vehicles as a consequence of increased road traffic and vehicle movements, although measures will be implemented to enforce speed limits and usage of designated haul / access routes.

During the operation phases of the Project there will be a series of leachate containment systems, industrial wastewater treatment processes and evaporation ponds. These are likely to contain hazardous chemicals and heavy metals and pose a risk to faunal species. However, these areas will be fenced to prevent ingress by mammal species, and deterrents will be used to deter birds (e.g. predator kites).

The impact of direct killing and injury on globally and regionally threatened species is predicted to be medium adverse significant.

Impact E14 – Medium Significant.

8.5.3 HABITAT LOSS / DEGRADATION

Impacts of habitat loss and degradation are predominantly restricted to the construction phase. The only additional impacts of habitat loss / degradation are associated with the excavation of the Mine. Impacts will arise during extraction operations, the establishment of rock stockpiles for overburden and the diversion of the ephemeral wadi which currently flows through the northern section of the mine (i.e. Year 15).

However, mining activities are to be phased such that habitat losses / degradation will be gradual, and the mine will be progressively restored during the life of the project. The restoration of the mine will utilise overburden and other waste materials arising from mining activities. The restoration of the mine will maximise opportunities for ecological restoration, although this will be limited based on the scale and significance of the initial damage caused.

Further impacts of habitat loss and degradation during the operational phase are assessed as adverse low significant for species of Least Concern and below.


However the loss and degradation of further habitats during construction has the potential to further consolidate impacts of reduced resource availability, a reduction in natural carrying capacity and increased competition for resources in areas beyond the Project. This is with particular reference to globally and regionally threatened species which are displaced from the Project area (e.g. Arabian wolf, Blanford's fox, sand cat).

Further impacts of habitat loss and degradation during the operational phase on globally and regionally threatened species are assessed as adverse high significant.

Impact E16 - High Significance





Impacts of further habitat loss and degradation on the Houbara bustard, which is suspected to breed within the area, and the Egyptian spiny tailed lizard which is present in low numbers, are predicted to be an adverse medium significant.


8.5.4 HABITAT FRAGMENTATION

There are no further impacts of habitat fragmentation predicted during the operational phase of the project. This is on the basis that all permanent infra-structure will have been established during the construction and commissioning phases of the Project. This includes the installation of security fencing around the perimeter of the Mine and the Industrial Complex.

8.5.5 DISTURBANCE

The Mine and the Industrial Complex will be operated 24hrs a day, 350 days a year. As a consequence there will be almost continual sources of noise disturbance arising from the use of explosives, rock crushers, conveyor systems and vehicle movements. Although some of these impacts will be more predictable and there is potential for some species to become habituated, other impacts will be less predictable (i.e. explosives).

Many of the mammal species are crepuscular or nocturnal and construction activities during these periods have the potential to significantly disturb the natural behaviour of these species (see Section 7.5.5). However the Arabian wolf and Blanford’s fox do have a capacity to become habituated to human disturbance.

The 24hr operation of the Mine and its supporting infrastructure also has the potential to disturb resident, over-wintering and migratory species (i.e. noise and light pollution rendering the site less favourable). However these species are mobile and would be likely to find alternative habitat to utilise.

Impacts of disturbance on species of Least Concern and below are predicted to be adverse low significant.

Impact E18 – Low Significance

In considering the existing levels of ambient disturbance, impacts of disturbance on globally and regionally threatened species (i.e. Arabian wolf, sand cat, Blanford’s fox, Egyptian spiny tailed lizard and the Houbara bustard) are predicted to be a medium adverse significant.

Impact E19 – Medium Significance

8.5.6 POLLUTION

Phosphate rocks can contain a number of heavy metals and the disturbance of this material through mining activities, and its exposure to air and water, creates a potential source of heavy metals that could enter into the natural environment (Pinsky 1988). In addition, although concentrations are low, sulfides when present have the potential to mobilise these metals when oxidised. Therefore the disturbance and subsequent stockpiling of over-burden within the Mine could potentially leach contaminants during periods of rainfall resulting in run-off into ephemeral surface waters.

Furthermore, although volumes of industrial wastewater from the Industrial Complex are not expected to be large, they are likely to contain fluorine, and a number of heavy metals. Industrial wastewaters will be treated in lined evaporation ponds in proximity to the phosphogypsum stack. It is not the intention that these industrial wastewaters should be discharged to the environment.

However the active management of all waste streams, including leachate containment systems and the correct disposal of hazardous wastes, will manage the risk of hazardous elements entering the natural environment. Should these materials enter the natural environment they have the potential to significantly interrupt the function of biological systems from the cellular level to the community level





Ongoing management of food wastes generated during the operation, in accordance with an operational waste management plan, will reduce the attractiveness of the residential complexes and office compounds to vermin, which would otherwise increase predation pressure on species and encourage scavenging mammals (i.e. Arabian wolf and fox species). More frequent encounters between operational staff and these species could increase persecution rates.

The excavation and crushing of phosphate rock and subsequent transport and processing will generate large volumes of dust. However dust suppression techniques will be implemented to reduce dust emissions and the possible smothering of adjacent habitats.


8.5.7 ALIEN SPECIES

During the operation of the Mine and Industrial Complex there will be a resident workforce of approximately 1300 people. There will be regulations in place to ensure that this workforce does not bring into the Project area any domestic pets such as cats and dogs for the reasons described in section 8.4.8. As such no further impacts of alien species on the natural environment are predicted.

8.6 CLOSURE / DECOMMISSIONING

Specific potential impacts on ecological receptors due to the proposed operation phase are summarised in Table 8-9, and are described further below.

Table 8-9: Closure / Decommissioning impacts

Factor E21


International

Frequency Continuous

Likelihood Likely

Extent Local

Duration Long

Magnitude Medium

Reversibility Reversible

Effect Direct

Action Positive

Significance Low

The closure / decommissioning phase of the Project will consist of two key stages:

• The restoration of the Mine within the Border Security Zone

• The decommissioning of the Industrial Complex and removal of the significant infrastructure to permit the restoration of previously disturbed areas.

The restoration of the mine will be achieved by using over and interburden material to backfill the void created following the removal of the phosphate rock. This restoration will be gradual and phased during the operational phase of the project.

In addition, the Industrial Complex will be decommissioned during which phase all the high value equipment will be removed. However essential Infrastructure will be retained for the





effective containment of the phosphogypsum stacks. However this will secure the on-going protection of the natural environment from potential leachates.

The restoration of the Mine and the Industrial Complex will facilitate the rehabilitation of natural habitats. These restored habitats will not have the same ecological value or function as those lost due to the level of disturbance to the soil profile however they will contribute to minimising impacts of habitat loss / degradation and fragmentation. A comprehensive Restoration Plan will be prepared outlining the proposals to maximise the ecological value of the restored habitats. This will include proposals for landscape seeding and planting, using native species of local provenance only. Local seed collection should be undertaken from the surrounding habitats to avoid the risk of introducing non-native species.


8.7 MITIGATION

8.7.1 SPECIFIC MITIGATION MEASURES

A hierarchical approach to mitigation development has been adopted to manage impacts identified for the construction, commissioning, operational and decommissioning phases of the Project. This approach consists of three distinct stages:

• Avoidance – avoid impacts wherever possible.

• Minimise – Reduce the effect of negative impacts that cannot be avoided.

• Compensate – Implement compensatory measures for remaining significant impacts.

The primary objective of the proposed mitigation measures is to protect and enhance the conservation status of habitats and species within and adjacent to the Project.

To evaluate the success of the proposed mitigation in achieving this primary objective, a robust and comprehensive ecological monitoring plan will be implemented prior to the commencement of construction activities. The scope of this monitoring plan will be developed in full consultation between Ma’aden and the governing bodies within the Kingdom of Saudi Arabia. Under this plan, sensitive ecological receptors and indicator species will be monitored to ascertain whether impacts are manifesting themselves as predicted, to assess the effectiveness of the proposed mitigation measures in managing these impacts.

Should it be identified that mitigation measures are not achieving the primary objective, then further interventions will be taken to reverse adverse trends.

The scale and magnitude of the project is such that it is not possible to satisfactorily reduce the significance of all impacts on biological resources. This is by virtue of the scale of the impacts which will directly impact 59km2 of the Northern Wildlife Management Zone. Although the sustainable utilisation of resources within this designated area is promoted, the Project will impact on a significant area within which a number of globally and regionally threatened species have been recorded. There is presently insufficient information to ascertain the quality of the Project area in comparison to the remainder of the Northern Wildlife Management Zone, or indeed the importance of the Project area to the globally and regionally threatened.

As a consequence, a central concept of the mitigation strategy is to work with the relevant Government bodies to offset these residual impacts by providing compensatory unfenced exclusion zones adjacent to the Mine and Industrial Complex. These areas should be managed in such a way to restore, rehabilitate and enhance their ecological value (e.g. control unauthorised access). The area managed in this way should be an equivalent area to that impacted (i.e. 59km2).

It is proposed to develop a Biodiversity Management Plan which will set out measures to protect, restore and enhance the ecological integrity and functionality of the habitats within the exclusion areas. By this means the medium residual impacts within the Project area would be offset by the improved conservation status of other areas within the Northern Wildlife Management Zone.





8.7.2 RECOMMENDATIONS

In addition to the specific mitigation measures described, a suite of recommendations which primarily consist of good management practices to address impacts of low significance have been documented. It is the intention that with the implementation of these measures, impacts of low significance can be reduced to no impact.





8.7.3 CONSTRUCTION AND COMMISSIONING PHASE - IMPACTS AND MITIGATION

ID Code Impact Potential Significance


Mitigation

E1 Designated Sites High • In collaboration with the relevant Government bodies designate and demarcate unfenced exclusion zones adjacent to the Mine and Industrial Complex to protect sensitive habitats from unauthorized access to ensure no net loss of habitat functionality. This should be an equivalent area to that impacted (i.e. 59km2). Within this area undertake habitat restoration and rehabilitation works.

Medium

E3 Direct killing / injury High • Ensure all contractors receive a Site Induction which includes the ecological value and sensitivity of the Project area, details on site access and exclusion zones, guidance on species identification and actions to take if encountered within development areas.

• Restrict clearance works to minimum requisite area. • In collaboration with the relevant Government bodies designate and

demarcate unfenced exclusion zones adjacent to the Mine and Industrial Complex to protect sensitive habitats from unauthorized access to ensure no net loss of habitat functionality. This should be an equivalent area to that impacted (i.e. 59km2). Within this area undertake habitat restoration and rehabilitation works.

• Restrict vehicle movements to defined haul / access routes to minimise risk of wildlife collisions with vehicles.

• Prior to site clearance and cut / fill operations complete a pre-construction site survey for globally / regionally endangered, vulnerable and / or near threatened species (i.e. Arabian wolf, sand cat and Blanford’s fox). This is to account for any changes to the status of species as determined from the baseline surveys.

• If globally / regionally endangered, vulnerable and / or near threatened species are recorded as having a place of rest of shelter (i.e. den) during pre-construction site survey, avoid wherever possible.

• Where avoidance is not possible, undertake displacement /

Medium





exclusion measures to reduce impacts of killing / injury. • Avoid Houbara bustard nesting period wherever possible (i.e.

February - April), and if this cannot be avoided use bird deterrents prior to the commencement of construction activities to deter nesting birds.

• Provide signage warning of the presence of wild animals on haul routes, raise driver awareness and enforce speed limits for construction vehicles.

E5 Habitat loss / degradation for threatened mammals

High • Restrict clearance works to minimum requisite area. • Restrict vehicle movements to defined haul / access routes to

minimise habitat loss / degradation. • Ensure all security fencing that is installed, other than around

evaporation ponds etc., allows for the passage of large lizards and medium sized mammals (e.g. sand cat, Blanford's fox).

Medium

E6 Habitat loss / degradation for vulnerable birds / reptiles

Medium Low

E8 Habitat Fragmentation for threatened mammals

High Medium

E9 Habitat Fragmentation for vulnerable reptiles

Medium Low

E11 Disturbance Medium • Do not permit unauthorised access, recreational activities or hunting within habitat exclusion zones.

• Avoided working at night wherever possible. • Fit earth moving equipment with more efficient sound reduction

equipment. • Use the following precautions when dealing with digging and earth

moving equipment: low-noise engines, noise tempering covers and procedures to keep the engine cover closed.

Low

E13 Alien species Medium • Use native plant species of local provenance wherever practicable to reduce the risk of transmitting biological pathogens and alien species. Implement a quarantine procedure for all plant specimens brought to the Project area.

Low





8.7.4 CONSTRUCTION AND COMMISSIONING PHASE RECOMMENDATIONS

The EPC Contractor shall develop, implement and maintain a construction and commissioning phase Environmental Emergency Response Plan (EERP) and Construction Environmental Management Plan (CEMP) as supporting documents to the Environmental Management and Monitoring Plan (EMMP) (Appendix A of this ESIA). These plans will detail responsibilities and procedures for environmental management and emergency response during construction and commissioning, including the following specifically targeted to biological resources:

• Speed restrictions to reduce dust emissions from construction vehicles;

• Site clearance procedures that allow species to move away before clearance, rather than being trapped within the construction area;

• A dust management strategy to reduce dust emissions from construction activities. This will include dust suppression of haul routes and covering loads on construction vehicles;

• Stockpile management systems and associated procedures to reduce dust emissions and run-off from temporary material stockpiles;

• A construction site waste management plan and erosion and pollution prevention measures to reduce the risk of contaminants entering the natural environment; and

• Identification and control of water discharges, to ensure the drainage capacity of the location, and to minimise erosion potential.





8.7.5 OPERATION PHASE - IMPACTS AND MITIGATION



Mitigation

E14 Direct killing / injury High • Provide signage warning of the presence of wild animals on all roads, raise driver awareness and enforce speed limits for operational vehicles.

• Ensure all industrial waste water treatment facilities, containment systems and evaporation ponds are securely fenced to prevent the ingress of mammal and reptile species. Use bird deterrents (i.e. predator kites) to deter bird species utilising these areas.

Medium

E16 Habitat loss / degradation for threatened mammals

High • In collaboration with the relevant Government bodies maintain exclusion zones adjacent to the Mine and Industrial Complex to protect sensitive habitats from unauthorized access to ensure no net loss of habitat functionality. This should be an equivalent area to that impacted (i.e. 59km2). Within this area undertake habitat restoration and rehabilitation works.

• Ensure all designed controls are implemented to reduce dust and noise emissions.

• Minimise light pollution by restricting lighting to essential areas only, and by using directional lighting to reduce light spillage.

Medium

E17 Habitat loss / degradation for vulnerable birds and reptiles

Medium Low

E19 Disturbance to threatened species

Medium Low






Ma’aden shall develop, implement, audit and maintain a Project Environmental Management and Monitoring Plan (EMMP) and an Environmental Emergency Response Plan (EERP) (refer to Appendix A EMMP and Appendix B EERP Outline respectively). These plans will detail responsibilities and procedures for environmental management and environmental emergency response during operation of the facility. This shall include in specific relation to management of biological resources:

• Speed restrictions to reduce dust emissions from operational vehicles;

• A dust management strategy to reduce dust emissions during the operational phase. This will include dust suppression of haul routes within the mine, the use of coverings on conveyor systems and reducing drop heights wherever possible, and active management of stockpiles and tailings to reduce wind blown dust;

• A waste management plan and erosion and pollution prevention measures to reduce the risk of contaminants entering the natural environment; and

• Provision of Site Induction to all personnel which includes the ecological value and sensitivity of the Project area, details on site access and exclusion zones, guidance on species identification and actions to take if encountered within Project areas.

Ma’aden shall liaise with the Waad Al Shamaal City developers and Government bodies to co-ordinate provision of offset areas for implementation of habitat enhancement, protection and restoration / rehabilitation measures. This might include designating areas between the mine and Waad Al Shamaal City as protected areas.




Mitigation

E21 Designated Sites Low (positive) Develop a Habitat Restoration Plan for the phased rehabilitation of the Mine as extraction progresses throughout the life of the Project.

Medium (Positive)






Ma’aden shall further develop the outline closure plan prepared for the ESIA over the Project life, to provide adequate detail for sound, and sustainable site decommissioning and closure. The closure plan should specifically detail the rehabilitation measures to be implemented as part of mine closure, and should consider provision of ecological monitoring to assess the success of habitat restoration / rehabilitation, and allow for corrective actions to be implemented as appropriate.

Ma’aden shall develop and ensure that decommissioning activities are undertaken in accordance with a decommissioning plan which addresses though is not limited to:

• Implementation of a site waste management plan and pollution prevention measures to reduce the risk of contaminants entering the natural environment.

• Implementation of speed restrictions to reduce dust emissions from operational vehicles and implementation of dust management strategy.





9.0 NOISE & VIBRATION

9.1 INTRODUCTION

This section details the existing noise sources and sensitive receptors that could be affected by noise or vibration generated by the Project, as well as conclusions of the noise baseline survey. An assessment of the likely noise and vibration impacts resulting from noise generated during the lifetime of the Project is then outlined (in light of applicable guidance and standards, existing noise levels in the area and modelling based predictions).

Where detailed information on noise levels associated with specific equipment, has not been available during the Front End Engineering Design (FEED) stage, a number of assumptions to estimate likely noise emissions associated with the proposed Project have been used within the impact assessment.

9.1.1 NOISE AND VIBRATION DEFINITIONS

In order to aid the understanding of this section definitions and clarifications are provided in Appendix F.


9.2.1 INTRODUCTION

Umm Wu’al Mine and Al Shamaal Phosphate Industrial Complex is a Greenfield site, with no development within its boundaries. In addition to the Project site boundary the following locations were identified as the closest potential receptors to noise and vibration impacts: • The new Residential Area at Waad Al Shamaal (approximately 15km to the west of the

Project site) • Ma’aden Compound (approximately 25km south south-west of the Project site) • Poultry farm (approximately 30km south south-west of the Project site)

The poultry farm, located adjacent to Highway 85, is due to move location before the operation of the Umm Wu’al Mine and Al Shamaal Phosphate Industrial Complex.

9.2.2 FIELD SURVEY 2013

Baseline noise monitoring was initially undertaken in December 2012 and January, March and April 2013. Unfortunately, the collected data was found to be unusable. Therefore, further noise monitoring was undertaken in June 2013 to provide details of the existing noise climate and provide a basis for the assessment of likely noise impact.

The surveys were undertaken following the requirements stated in the Presidency for Meteorology and Environment General - Environmental Standard for Noise (2012). A Cirrus Research plc CR 171A sound level meter was used with the instrument microphone at a height of 1.5 m above ground level in free field locations. Woods Hole Group Middle East (WHGME) conducted noise monitoring from 14 to 17 June 2013

Noise measurements were taken adjacent to the nearest noise sensitive receptor(s) off-site and at various locations on the boundary of the proposed project site, as illustrated in Figure 9-1. The closest receptors include a chicken farm near the Ma’aden compound, the future Ma’aden housing and herders camp south of the Umm Wu’al Mountain.

Coordinates of the monitoring locations are given below:

• NE corner of Mine: 31° 59' 37.9" N; 39° 00' 47.3" E • NW corner of Mine: 31° 58' 08.5" N; 38° 56' 36.7" E • SE corner of mine: 31° 56' 41.4" N; 39° 01' 41.3" E • SW corner of mine: 31° 55' 42.1" N; 38° 59' 28.9" E • Chicken farm: 31° 38' 33.4" N; 38° 49' 29.4" E • Near Umm Wu’al Mountain: 31° 45' 41.6" N; 38° 57' 24.8" E • Ma’aden Camp: 31° 38' 04.3" N; 38° 5 1' 16.7" E





Figure 9-1: Baseline Noise Monitoring Locations





9.2.3 NOISE MONITORING RESULTS

The results of the baseline noise monitoring are summarised in Table 9-1 below, with full results are provided in Appendix F.

Table 9-1: Noise Monitoring Data Summary

Location Averaged Noise Levels

LAeq (dB)

LAFmax (dB)

LA1 (dB)

LA10 (dB)

LA90 (dB)

Ma’aden Camp (24 hour survey)

46 87 54 49 38

Chicken Farm (Daytime) 45 58 51 46 37

Umm Wu’al (Daytime) 41 57 45 41 30

NE Corner of Mine (Daytime) 37 56 46 41 22

NW Corner of Mine (Daytime) 31 54 41 34 21

SE Corner of Mine (Daytime) 39 55 45 41 23

SW Corner of Mine (Daytime) 39 56 46 41 21

At the various corners of the mine site, averaged LAeq noise levels varied between 31 and 39 dB. For the purposes of this assessment LAeq noise levels at the boundary of the development will be assumed to be <40 dB.


9.3.1 INTRODUCTION

Noise will be generated at the Project site during construction, commissioning and normal operations, as well as during emergency operations of the proposed facilities.

The criteria for the evaluation of impacts were identified in Section 5 Impact Assessment Methodology and Table 9-2 and

Table 9-3 below present the definition of magnitude criteria define specifically for environmental noise impacts and the significance of noise impact assessment.

Table 9-2: Magnitude Definitions for Environmental Noise Impacts

Noise Level at Location of Receptor Magnitude of Im pact

Below or up to applicable noise limits Low

1 to 5 dBA above applicable noise limits Medium

6 - 10 dBA above the applicable noise limits High

> 10 dBA above the applicable noise limits Very high

Table 9-3: Decision Matrix for Significance Assessment of Environmental Noise

Frequency

Magnitude Low Medium High Very High

Continuous Low Medium High Very High

Frequent Low Low High Very High

Infrequent Low Low Low Medium

Once Low Low Low Medium





In order to assess potential noise and vibration impacts, consideration has been given to applicable standards and guidance. The applicable environmental noise limits for the Project are those of the PME Environmental Standard (2012); the World Bank Group (IFC) guidelines are included for reference as international good practice. In addition, reference is also made to BS 5228: 2009 - “Code of practice for noise and vibration control on construction and open sites” (Parts 1 and 2) to inform the assessment of the construction phase.

9.3.2 CONSTRUCTION

Construction of the project has potential to impact upon the baseline noise and vibration conditions at the site from activities such as: ground clearance and excavation, facility construction, HGV movements, diesel generators, compressors and piling.

Specific potential impacts on the noise environment due to the above activities are summarised in Table 9-4 and discussed in the following text.

Table 9-4: Construction Phase Impacts Assessment (Impact at Off-Site Noise Sensitive Receptors) Factor NV1 NV2 NV3

Receptor Importance / Sensitivity Medium Medium Medium

Frequency Frequent Infrequent Rare

Likelihood Certain Certain Certain

Extent Local Local Local

Duration Short Short Short

Magnitude Low Very Low Low

Effect Negative Negative Negative

Action Direct Direct Direct

Significance Low Low Low

During the construction phase, noise levels will fluctuate as the intensity of activities change. Details of the construction equipment to be used are unavailable at this stage of the Project and will be determined by the EPC Contractors. All construction activities must be in compliance with the Presidency of Meteorology and Environment (PME) 2012, Environmental Standards for Environmental Noise (Article 6 – Noise from Construction Activities) and BS 5228: 2009 (Part 1: Noise and Part 2: Vibration).

9.3.2.1 IMPACT FROM INCREASE OF NOISE LEVELS AT RECEPTORS - CONSTRUCTION

Noise levels will be variable during the construction phase as different stages of work are undertaken. The construction phase will include the use of mobile plant from mobile generators to power site tools; maximum sound power limits for outdoor equipment are stated in Table 7 of the PME Noise Standards (2012). No piling is required on site so there will be no raised noise levels from this type of activity. There will however be an increase in vehicle movements across the Project area with associated noise emissions. The potential impacts of the disturbance caused by noise on wildlife are addressed in Section 8 Biological Resources. Noise levels are predicted to be acceptable under PME Standards and given the significant distance to sensitive receptors, it is considered unlikely that adverse noise impacts will arise at any nearby noise sensitive premises.

Impact NV1 – Low Significance





9.3.2.2 IMPACT FROM INCREASE OF VIBRATION LEVELS AT RECEPTORS - CONSTRUCTION

As noted above there will be variable levels of activity during the construction phase. The use of earth moving equipment and compaction machines during the Early Work programme will cause additional levels of vibration in the area. There will also be increased numbers of construction plant and Heavy Goods Vehicles (HGV) in the Project area, which will all have an impact on vibration levels in the area. The potential impacts of this increased vehicle activity on the transport infrastructure are addressed in Section 13 Traffic and Transport Infrastructure while potential impacts on wildlife are discussed in Section 8 Biological Resource. No piling is required on site so there will be no raised vibration levels from this type of activity. Vibration levels are considered to be acceptable and given the significant distance to sensitive receptors the overall impact is considered to be low.


9.3.3 COMMISSIONING


• Hydrotesting of pipelines and tanks;

• Flushing & cleaning of pipelines;

• System dry-out;

• Inerting;

• Systematic conformity check of equipment;

• Static, de-energized test of equipments;

• Preliminary check;

• Functional check;

• Operational test; and,

• Pre-Startup activities.

9.3.3.1 IMPACT FROM INCREASE OF NOISE AND VIBRATION LEVELS AT RECEPTORS

Noise and vibration levels will be variable during the commissioning phase as different elements of the Industrial Complex are tested and prepared for operation. The noise levels will be within the operational design parameters. The main human receptors will include the workforce who will use Personal Protective Equipment where required, the receptors of the residential development and the Ma’aden Compound are located at a significant distance and are not expected to be impacted upon. Overall the levels are expected to be within acceptable operating levels.


9.3.4 OPERATION

The Umm Wu’al Mine and Waad Al Shamaal Phosphate Industrial Complex will include multiple noise sources large and small, associated with the operation of the equipment, plant, transportation and materials handling systems.

9.3.5 NOISE SOURCES

While limited information is available as part of the FEED on the noise generated by sources within the design and power levels of equipment from which to calculate these, a number of assumptions have been made in order to undertake this impact assessment. The following sections detail these.





9.3.5.1 MAIN CONVEYOR

The noise sources associated with the main conveyor, which runs for 14 km between the Primary Ore Crusher (POC) in the mine area and the Beneficiation Plant within the Industrial Complex, are the motors positioned at the transfer towers (at the start and end of the conveyor), and the noise generated during the material transfer at the transfer towers. The motor noise has been assumed to be 85 dB LAeq at 1 m, while the material handling noise has been assumed to be 110 dB LAeq at 1 m (equating to 93 and 118 LWA, respectively).

The transfer towers that handle the transfer of material to the tailing and gypsum stacking area (located in the east of the Industrial Complex) have also been included. The transfer towers also have motor and material handling noise sources, again at 93 and 118 LWA, respectively.

Note: Following design change introducing wet stack in preference to dry stack the noise levels generated by the transportation of slurried phosphogypsum via pipe (rather than dry via conveyor), are anticipated to be reduced. Modelling has not been re-run, as the modelled scenario is considered to be conservative for the updated wet stack design.

9.3.5.2 INDUSTRIAL COMPLEX

The new buildings proposed within the Industrial Complex have been included within the noise model, and have been assumed to be fully reflective. The noise model has been created to allow all noise sources located within buildings to radiate freely out of the buildings. This approach means that buildings provide no noise attenuation for those sources located within them, but do act as potential screening structures for all other sources within the model. This is considered to be a conservative approach.

The PAP, SAP and Power Plant noise sources have all been assumed to be radiating point sources, with a noise emission of 85 dB LAeq at 1 m. All noise sources are assumed to have a noise emission level of 85 dB LAeq at 1 m, which equates to an LWA of 93 dB, unless stated otherwise below.

General Noise Sources (Pumps, Fans, etc)

Pumps, fans, stacks, etc identified by the project team on the plot plants have been included within the Industrial Complex area of the noise model as radiating point sources. This approach identifies the main noise sources as available at the time of the modelling. Development of the detailed design has the potential to identify further noise sources.

Pump and fans have been generally been assumed to be at ground level (source at 0.5 m above the ground), and generally between 1 and 3 m from edge of the tank (for example) that they serve. Where two pumps are shown in close proximity on the available site plot plans, seemingly serving the same plant item, then one of the two has been assumed to be a ‘stand-by’ or ‘backup’ pump, and has not been considered operational within the noise model.

Cooling Towers

Two cooling towers have been included within the noise model, these being the open-loop and closed-loop cooling towers. The cooling towers are located east of the PAP, with each being 12.5 m in height. The larger open-loop cooling tower is 245 m in length and 15 m wide, while the closed-loop cooling tower is 79 m in length and 17 m wide. The open-loop cooling tower has 19 fans, each or which has been modelled as a radiating point source, positioned 1 m above the cooling tower and with a noise emission of 85 dB LAeq at 1 m. The closed-loop cooling tower has five fans, with each again being modelled as a radiating point-source 1 m above the cooling tower and with a noise emission of 85 dB LAeq at 1 m.

Heating Ventilation and Air Conditioning (HVAC) sys tems

A total of 20 buildings within the Industrial Complex have been identified as having HVAC systems associated with them. A total of 41 HVAC noise sources have been included within the Industrial Complex, with each positioned 1 m above the roof of the building it serves. Each HVAC system has an assumed sound pressure level of 85 dB LAeq at 1 m (again equating to a LWA of 93 dB).





9.3.5.3 MINE SITE

Mining Operation Three noise modelling scenarios have been considered, representing the mine operations forecast to take place: • Early in the first year of the mining operation, where activities are to be concentrated

around the north-west corner of the mine;

• In the fifth year of the mining operation, where activities will be taking place within a pit (with a pit depth of 30 m) and between the north-west corner and the centre of the mine site;

• In the twenty-fifth year of the mining operation, while activities are taking place within a pit (with a pit depth of 30 m) and between the centre and south-east part of the mine site.

It is considered that the noise modelling scenarios that have been selected give a good indication of the likely noise impacts associated with mining operation, with year 1 representing the worst impact on the north-western border, year 5 representing a general scenario where the equipment is operating in the centre of the mine site, and year 25 representing the worst impact at the south-eastern border.

The noise sources included within the noise model have been taken from BS 5228-1: 2009 or from equipment data sheets available for various pieces of Caterpillar mining equipment (given as a potential supplier of the mining equipment). The mine modelling scenarios have been created within the noise model allowing for the plant and equipment to be evenly spread along the working face of the mine. Table 9-5 details the assumed plant and equipment for each activity and year considered.

Table 9-5: Assumed Plant and Equipment for Mining Activit ies

Noise Source Sound Power Level dB(A) Reference

Number of Plant Items Operating

Year 1 Year 5 Year 25

Overburden

Dozer Ripper 116.0 BS 5228-1

Table C.6.28 + CAT844H

1 1 1

Drill 118.1 BS 5228-1 Table C.9.1

1 3 8

15 - 18 m3 Hydraulic Excavator

118.9 BS 5228-1 Table C.9.6 0 2 3

135 -145 t off highway truck 120.5

BS 5228-1 Table C.9.7 +

CAT 785 0 6 10

Ore and Interburden Equipment


118.9 BS 5228-1 Table C.9.6 4 5 5

85 -100 t off highway truck 115.5

BS 5228-1 Table C.9.7 +

CAT 777 19 20 20


118.9 BS 5228-1 Table C.9.6 2 3 3





Noise Source Sound Power Level dB(A) Reference

Number of Plant Items Operating

Year 1 Year 5 Year 25

Drill 118.1 BS 5228-1 Table C.9.1 3 6 6

Ancillary Equipment

280 – 335 kW Dozer

116.0 BS 5228-1

Table C.6.28 + CAT844H

4 6 10

Rock Breaker 123.4 BS 5228-1 Table C.9.13 1 3 3

Grader 115.0 BS 5228-1

Table C.6.31 + CAT24M

2 3 3

Wheeled Dozer 116.0 BS 5228-1

Table C.6.28 + CAT 844H

2 2 2

Off highway fuel truck

104.1 BS 5228-1 Table C.4.15

2 3 3

90 m3 Water Truck

108.6 BS 5228-1 Table C.4.88

2 5 5

11 – 13 m3 Wheeled loader 116.0

BS 5228-1 Table C.6.33 +

CAT 992K 2 2 2

15 t Explosive Carrier 103.5

BS 5228-1 Table C.4.4 2 3 3

Other Equipment

10kW Lighting Tower 93.5 BS 5228-1

Table C.4.86 9 14 14

60 – 70t Crane 104.7 BS 5228-1 Table C.4.39

2 2 2

Dewatering pump

96.8 BS 5228-1 Table C.4.88

2 3 3

Telehandler 106.5 BS 5228-1 Table C.4.54

2 4 4

Diesel Generator (mobile 200 – 250 kW)

93.1 BS 5228-1 Table C.6.39 2 4 4

Mine Maintenance Area (MMA)

The following buildings and tanks have been included within the MMA. All are assumed to be 6 m high unless otherwise stated:

• Admin building;

• Medical Centre (4 m high);

• Canteen;

• Facilities building;

• Switchboard/ Control Room;





• Fixed plant and light vehicle maintenance;

• Warehouse and Maintenance building (10 m high);

• Potable water storage tank (3 m high);

• Sewage storage tank (3 m high);

• Fire water storage tanks 1 and 2 (5 m high);

• Dust suppression water storage tank (5 m high);

• Diesel storage tank (3 m high);

• HV and LV Diesel fuel day tank (3 m high).

The following noise sources are included within the MMA area:

• 9 pumps have included within the noise model, at a height of 0.5 m above ground;

• 2 Heavy Vehicle (HV) wash facilities and 1 Light Vehicle (LV) wash facility have been included within the model;

• 4 HV’s and 2 LV’s have been assumed to be idling within the refuelling areas;

• 8 delivery trucks (delivering fuel, food, materials, tyres, etc) have been positioned on roads around the perimeter of the MMA;

• 6 buses have been included, with 3 in the parking bays, while the other 3 are on the southern access road;

• 50 HVs idling within the HV parking bays, to represent a shift change;

• All noise sources have been modelled as point-sources, using a noise emission level of 85 dB LAeq at 1 m;

• HVAC systems have been included within the noise model for four occupied buildings, these being the Canteen, Medical Centre, Admin Building and the Switchboard/ Control Room Building. A single HVAC unit per building has been assumed, modelled as a point-source and with a noise emission of 85 dB LAeq at 1 m.

Primary Ore Crusher (POC) The POC area is located on the eastern edge of the mine site. A total of 3 crushers have been included within the model (with the third understood to be a potential future crusher). The crushers are assumed to be located within an area that is 15 m below ground level, and within a small building, which is 8 m in height, and is therefore below ground level. As a worst-case, the three crushers freely radiate through the building they are enclosed within, with each being assigned a Sound Power Level (LWA) of 114 dB, producing noise levels of 85 dB LAeq at 1 m from the building housing the crushers.

Four additional noise sources have been included, these being two material tipping noise sources and two truck idling noise sources. The tipping noise sources have been assumed to be 85 dB LAeq at 1m (equating to an LWA 93 dB), while the truck idling noise level is 116 LWA (as per Caterpillar equipment data sheet).

9.3.5.4 RAIL

There will be rail movements as a consequence of the development, with rail sidings located to the east of the facility. There are expected to be a minimum of three trains a day (hence six rail movements). The maximum allowable number of wagons is 155 per train. Train speeds are expected to be in the order 40 km/h when loaded and 50 km/h when empty. There will also be loading and unloading activities at the sidings.





9.3.5.5 WELL FIELD

The well field will comprise of a series of wells, 24 in total, located in a ‘L’ shape, to the east of the Industrial Complex. Since the modelling was undertaken, the location of the wellfield has been altered to that shown in Section 4 Detailed Description and Layout of the Proposed Development. There has been no opportunity to update the model with this new location, however since the configuration of the wellfield remains the same, and its new location is further from sensitive receptors an assessment based on the modelling of the original location is considered to be acceptable.

The wells will be located at intervals of 1 km, and the pump associated with each well is assumed to be radiating noise at no more than 85 dB at 1 m, which equates to a sound power level of 93 dB. The well pumps are located within the ‘piping and services corridor’, which is a total of 6 m wide. It has been assumed that the pump will be located within the centre of the ‘piping and services corridor’, and as such will be located approximately 3 m from the edge of the corridor. Assuming a standard distance correction over hard ground and hemispherical noise propagation (20*Log 3 = 10 dB), a noise level at the boundary of the wellfield corridor of 75 dB (i.e. at the closest point to the well pump), would be anticipated.

9.3.6 NOISE MODELLING DETAILS

Predictions of likely noise levels have been undertaken using the CadnaA Noise Modelling Software Package, which incorporates the algorithms detailed in ISO 9613 - “Attenuation of Sound Propagation Outdoors”, 1993 and 1996, and has been validated by the software manufacturer (DataKustik).

The Industrial Complex is a new facility and as such no existing process plant or equipment is currently located within the Industrial Complex site boundary. It is understood that that there are no large intervening structures located between either the Industrial Complex or Mine site and any nearby noise sensitive receptors (as listed below), and as such none have been included within the noise model.

9.3.6.1 GROUND CONDITIONS

No existing ground topographical data has been included within the model. As a worst-case scenario it has been assumed that the Industrial Complex area is flat. As a result the noise predictions to be made at the nearby noise sensitive receptors will generate worst-case noise impact predictions when modelled.

The Mine area is assumed to be flat, with the exception of the POC, which has been taken as being 15 m below ground level and the excavated mine, which has been assumed to be 30 m deep (ie. 30 m below the general ground level of the model). The maximum pit depth is likely to be in the order of 45 m (SRK 2013).

Both the Mine and Industrial Complex areas have been assumed to be acoustically hard, and as such no acoustic ground absorption has been included within the model.

9.3.6.2 METEOROLOGICAL CONDITIONS (TEMPERATURE AND RELATIVE HUMIDITY)

An average annual temperature of 19oC has been assumed. An average annual relative humidity of 39% has been assumed, based on the mean of the average daily relative humidity levels recorded at the Turaif and Ar’ar airports.

9.3.6.3 BUILDINGS AND OTHER STRUCTURES

The buildings included within the Industrial Complex have been created using in Arcview GIS software package on the basis of the available plot plans and represents the latest available at the time of modelling. Building heights have been determined for the maximum average height of a structure or group of structures using design drawings, datasheets, site photographs and discussions with the Project team.

9.3.6.4 NOISE PREDICTION RECEPTORS

A total of 1,916 site boundary receptors have been included within the model (968 at the Industrial Complex and 948 at the Mine site). These receptor points have been positioned at





25 m intervals around the boundary of the Industrial Complex and Mine, at a height of 1.5 m above ground level.

A number of “off-site” noise sensitive receptors have been included within the noise model, as detailed below:

• Chicken Farm (although this is noted to be moved prior to the commencement of operations);

• Ma’aden Residential Area (within the Waad Al Shamaal City community area);

• Proposed Wa’ad Al Shamaal Community Housing (which will eventually include schools, mosques, commercial areas and civic facilities); and

• Turaif City.

In addition to the four off-site receptors listed above, noise modelling predictions have also been made along the International Border, located north of the mine site, between Saudi Arabia and Jordan. It should be noted that the International Border is largely unmanned and has no noise sensitive receptors positioned close to it, and has been included here to address trans-boundary issues. The nearest dwellings within Jordan appear to be some 80 to 90 km to the north of the International border between the Kingdom of Saudi Arabia and Jordan; the most sizable of which appears to be Ar Ruwayshid.

9.3.7 NOISE MODEL RESULTS AND ASSESSMENT

9.3.7.1 INDUSTRIAL COMPLEX

The results of the noise modelling for the Industrial Complex are summarized in Table 9-6 below, while Figure 9-2 illustrates the noise contour banding for the Industrial Complex Figure 9-2 is illustrative; any alterations to the design of buildings (whether noise emitting or not), the positions of buildings and identification of other noise sources during detailed design development will impact upon the noise contour plot. Nonetheless Figure 9-2 provides a visual representation of the extent of the modelled noise. The influence of the prevailing wind direction in the dispersal of noise is evident in the figure.

Table 9-6: Predicted Noise Levels Attributable to the Industri al Complex

Location Predicted noise level dB L Aeq

North-eastern Boundary 30.5 – 38.7

Eastern Boundary 30.5 – 64.0

Southern Boundary 37.2 – 40.5

Western Boundary 37.7 – 57.6

International Border <20

Ma’aden Compound <20

Chicken Farm <20

Turaif City <20

Site of future residential development <20





Figure 9-2: Umm Wu’al Industrial Complex indicative noise contour plot





Noise levels on the boundary of the site, are predicted to vary by between 30.5 and 64.0 dB LAeq with the highest noise levels predicted along the eastern boundary. The highest noise levels predicted on the north eastern, southern and western boundaries are 38.7, 40.5, and 57.6 dB LAeq, respectively.

Predicted off-site noise levels attributable to the Industrial Complex are very low and do not exceed the World Bank noise limits. Thus, predicted noise levels as identified by the model do not exceed World Bank or Presidency of Meteorology and Environment noise limits.

The operation of plant and equipment is not considered likely to result in perceptible vibration at any sensitive receptors outside the boundary of the site.

As such, based on currently available information, no significant noise and vibration effects are predicted.

An Emergency Diesel Generator (EDG), which consists of a 4 MW (approx) net diesel driven engine, is provided for back-up and black-start conditions, and will provide the required consumable power required by the auxiliary boiler during start-up. The auxiliary boiler, which will normally operate at just 20% capacity, will operate at full capacity during start-up situations. The noise impacts associated with the EDG and the auxiliary boiler, when operating at full capacity, are likely to increase the noise emissions at the facility, but when considering the large number of noise sources within the facility, are unlikely to significantly alter the predicted site boundary noise levels.

9.3.7.2 MINE AREA

The results of the noise modelling exercise for the mine area are summarized in Table 9-7, Table 9-8, for years 1, 5 and 25 respectively. The ‘A5 – High density industry’ category given within the PME standard would indicate an exceedence of the night-time noise limit of 55dB LAeq. As this area is devoid of receptors this is not of consequence.

Table 9-7: Predicted Noise Levels Attributable to Mine A rea (Year 1)


Northern Boundary 42.5 – 65.0


South-eastern Boundary 37.4 – 48.0

South-western Boundary 37.3 – 56.1


North-western Boundary 62.1 – 71.8

International Border 63.0*

Ma’aden Camp <20

Chicken Farm <20

Turaif City <20


*Maximum predicted noise level





During the first year, noise levels on the boundary of the site are predicted to vary between 37.3 and 71.8 dB LAeq, with the highest noise levels predicted along the north-western boundary. The highest noise levels predicted on the north, eastern, south eastern, south western, western and north western boundaries are 65.0, 66.5, 48.0, 56.1, 70.4 and 71.8 dB LAeq, respectively.

Predicted off site noise levels are very low and do not exceed the World Bank noise limits. However, the World Bank Limits are potentially exceeded on the north western boundary, with a marginal situation on the western boundary. Hence, further consideration of mitigation measures is required to ensure compliance with the World Bank guidelines.

During the first year of the mine operating, a maximum noise level of 63.0 dB LAeq has been predicted at the international border with Jordan, located north of the mine site. The ‘A5 – High density industry’ category given within the PME standard would indicate an exceedence of the night-time noise limit of 55 dB LAeq. As this area is devoid of receptors this is not of consequence.

Table 9-8: Predicted Noise Levels Attributable to Mine Ar ea (Year 5)




South Eastern Boundary 38.5 – 48.4

South Western Boundary 38.4 – 45.5


North Western Boundary 43.0 – 54.7

International Border 57.4*

Ma’aden Camp <20

Chicken Farm <20

Turaif City <20



In the fifth year, noise levels on the boundary of the site are predicted to vary between 38.4 and 67.7 dB LAeq, with the highest noise levels predicted along the eastern boundary. The highest noise levels predicted on the north, south eastern, south western, western and north western boundaries are 67.1, 48.4, 45.5, 43.8 and 54.7 dB LAeq, respectively.

Predicted off-site noise levels are very low and do not exceed the World Bank noise limits. Thus, predicted noise levels during the fifth year of operation are not expected to exceed World Bank or PME noise limits.

During the fifth year of the mine operating, a maximum noise level of 57.4 dB LAeq has been predicted at the international border with Jordan. The ‘A5 – High density industry’ category given within the PME standard would indicate an exceedence of the night-time noise limit of 55 dB LAeq. As this area is devoid of receptors this is not of consequence.





Table 9-9: Predicted Noise Levels Attributable to Mine Ar ea (Year 25)

Location Predicted noise level dB LAeq



South Eastern Boundary 42.0 – 50.1

South Western Boundary 35.9 – 46.2


North Western Boundary 34.9 – 39.3

International Border 44.3 *

Ma’aden Camp <20

Chicken Farm <20

Turaif City <20



During the twenty fifth year, noise levels on the boundary of the site are predicted to vary between 34.9 and 68.3 dB LAeq, with the highest noise levels predicted along the eastern boundary. The highest noise levels predicted on the north, south eastern, south western, western and north western boundaries are 53.1, 50.1, 46.2, 35.9 and 39.3 dB LAeq, respectively.

Predicted off site noise levels are very low and do not exceed the World Bank noise limits. Thus, predicted noise levels during year twenty five are not expected to exceed World Bank or PME noise limits.

During the twenty fifth year of the mine operating, a maximum noise level of 44.3 dB has been predicted at the international border with Jordan. . The ‘A5 – High density industry’ category given within the PME standard would indicate an exceedence of the night-time noise limit of 55 dB LAeq. As this area is devoid of receptors this is not of consequence.

Overall, based on currently available information, no significant noise impacts from general mining activities are predicted. The operation of plant and equipment associated with the mine is not considered likely to result in perceptible vibration at any sensitive receptors outside the boundary of the site. Consideration is given to blasting later in this assessment.

Figure 9-3 provides the indicative noise contour banding for the three mine scenarios, and the ongoing operation of the Industrial Complex. As with Figure 9-2; any alterations during detailed design development will impact upon the noise contour plot. Nonetheless Figure 9-3 provides a visual representation of the extent of the modelled noise for the Project for the three scenarios, and demonstrates the potential impact on nearby sensitive receptors to be very low. Variances between the contours in, and those show in Figure 9-2, are a function of the different scales and the coarser grid of the latter.





Figure 9-3: Indicative Noise Contours for Umm Wu’al Mine a nd Waad Al Shamaal Phosphate Industrial Complex





9.3.8 IMPACTS OF INCREASED NOISE LEVELS DURING OPERATION

Specific impacts predicted on the existing noise environment due to the proposed Project elements at the Industrial Complex and mine area are summarised in Table 9-10 and discussed in the following text.

Table 9-10: Operation Phase Impacts Assessment (Impact at Off-site Noise Sensitive Receptors) Factor NV4 NV5 NV6 NV7

Receptor Importance / Sensitivity Medium Medium Medium Medium

Frequency Frequent Continuous Frequent Continuous

Likelihood Certain Certain Certain Certain

Extent Local Local Local Local


Magnitude Very Low low Medium Low



Significance Low Low Low Low

9.3.9 RAIL IMPACTS

As detailed in section 9.3.5.4, there will be rail movements as a consequence of the development, with rail sidings located to the west of the facility. There are expected to be a minimum of three trains a day, hence six rail movements. There is the potential for rail movements throughout a 24 hour period throughout the year to suit site operations.

The nearest noise sensitive receptors (at the proposed Wa’ad Al Shamaal community housing development) at are located approximately 12.5 km.

Given the distance to sensitive receptors and the relatively slow speeds, it is not considered likely that noise levels would exceed the World Bank or PME noise limits, based on indicative noise calculations. At the associated sidings there are potential noise emissions from unloading and loading activities. This is a largely automated process and therefore no large mobile plant need to be considered. Instead, noise will be generated while raw materials are loaded and unloaded. As in the case of the rail movements themselves, given the likely noise sources and distances to sensitive receptors, the modelling indicates that noise levels would not exceed the World Bank or PME noise limits.


9.3.10 WELL FIELD

The 24 wells will be located at intervals of 1 km, within the ‘piping and services corridor’, which is a total of 6 m wide. It has been assumed that the pump will be located within the centre of the ‘piping and services corridor’, and as such will be located approximately 3 m from the edge of the corridor. Assuming a standard distance correction over hard ground and hemispherical noise propagation (20*Log 3 = 10 dB), a noise level at the boundary of the well field corridor of 75 dB (ie. at the closest point to the well pump), would be anticipated. While the model has been developed with the original location of the wellfield, the new location is some 60km north-east of the Project. The nearest noise sensitive receptors to the well field are those located at the Future Residential Development, approximately 75 km west of the well field, and Al Jalamid town approximately 55km south east of the wellfield.






9.3.11 BLASTING

Blasting will be undertaken such that there will be low probability of adverse comment, based on the guidance detailed in BS 6472-2: 2008. Given the likely frequency of blasting, it is recommended that vibration levels should not exceed 6 mms-1 in the vicinity of sensitive receptors. In addition, air overpressure should not exceed 120 dB (lin) in the vicinity of buildings used for human habitation.


9.3.12 CUMULATIVE NOISE IMPACTS

Consideration is required of the cumulative noise impacts from the various aspects of the operational noise assessment. It is considered that even when considered cumulatively noise levels attributable to the development will not exceed the World Bank or PME noise limits.

However, noise assessment will be an ongoing process during the facility design. Further consideration will be required during detailed design to confirm the assumptions within this report and to update the noise model as further information and noise data is available.

A noise level of <40 dB has been applied as the baseline existing noise level for the boundary of the mine and Industrial Complex, on the basis that the noise monitoring undertaken at the corners indicate baseline noise to range between 31 and 39 dB, thus it is considered reasonable, and conservative to use <40 dB along the mine boundary.

A noise level of <20 dB has been predicted for noise attributable to the Industrial Complex and noise attributable to the mine, for each of the off site noise sensitive receptors. It should be noted that the overall noise level, combining the noise attributable to the Industrial Complex and the mine area, would still be <20 dB for all off site sensitive receptors.

Table 9-11 considers the effect of predicted noise levels on existing noise levels with the highest predicted boundary noise level as detailed earlier within the chapter. The World Bank Ambient Noise Guidelines and PME permissible free field noise limits are provided for comparison.





Table 9-11: Cumulative Noise Impact

Location

Assumed Existing

Noise Level

dB L Aeq

Predicted Noise Level

dB L Aeq

Cumulative Predicted

Noise Level

dB L Aeq

World Bank Ambient

Noise Guidelines one hour LAeq (dB)

PME Permissible Free Field

Noise Limits

L Aeq,T (dB)

Northern Boundary of Mine

<40 67 67 70c N/A

Eastern Boundary of Mine <40 68 68 70c N/A

South Eastern Boundary of Mine <40 50 50 70c N/A

South Western Boundary of Mine

<40 56 56 70c N/A

Western Boundary of Mine <40 70 70 70c N/A

North Western Boundary of Mine <40 72 72 70c N/A

Industrial Complex North Eastern Boundary

<40 39 <43 70c N/A

Industrial Complex Eastern Boundary <40 64 64 70c N/A

Industrial Complex Southern Boundary

<40 41 <44 70c N/A

Industrial Complex Western Boundary <40 58 58 70c N/A

Ma’aden Camp 45a/50b <20 45a/50b 45a/55b 50a/65b

Chicken Farm 45a/45b <20 45a/45b 45a/55b 50a/65b

Turaif City 45a/55b <20 45a/55b 45a/55b 45a/55b

Site of future residential development

41a/41b <20 41a/41b 45a/55b 45a/55b

a Evening b Day time c Night time d Day time and Night time

The assumed existing noise levels for the Ma’aden Camp are based on the LAeq noise level of 46 dB recorded for the full 24 hour period. The night time noise level for the Chicken Farm is assumed to be the same as the daytime to give a worst case assessment. The Umm Wu’al daytime periods monitored have been averaged and provide the basis for the assumed existing noise levels at the site of the future residential development. It has been assumed that the night time noise level is the same as the daytime to give a worst case assessment. For Turaif City it has been assumed that existing noise levels are at the PME community noise standard to give a worst case assessment.





For the off site noise sensitive receptors considered, there are negligible noise increases compared to the existing situation and compliance with both the World Bank guidelines and PME community noise standards.

With the exception of the early months of operation of the mine, predicted noise levels at the boundaries of the site comply with World Bank guidelines. However, there is the potential for noise levels on the north western boundary of the mine site to exceed the World Bank guidelines. It should be noted that the areas at the boundary of the sites are not considered noise sensitive with respect to compliance with the PME community noise standards.

Impact NV7 – Low Significance (at off-site Noise Se nsitive Properties)

9.4 CLOSURE / DECOMMISSIONING

Closure / decommissioning of the Project is likely to comprise the cessation of mining activity and operation of Industrial Complex and the removal of the high value equipment, safe closure of storage ponds etc. Decommissioning is not expected to see the complete removal of the site infrastructure. Decommissioning activities are likely to generate noise and vibration in the same way as anticipated for the construction phase.

9.5 MITIGATION

9.5.1 OVERVIEW

In accordance with the approach described in Section 5 – Impact Assessment Methodology, mitigation measures are identified where impacts are determined to be of medium or high significance. The Project site is although generating noise and vibration as a result of activities, is a significant distance from the nearest sensitive receptors. Thus the impact assessment has identified no impacts of medium or high significance and no mitigation measures associated with these to be implemented. Nonetheless the following recommendations are made to address low significance impacts identified.

9.5.2 RECOMMENDATIONS

9.5.2.1 GENERAL

During detailed design, further more detailed information regarding the proposed noise sources, and more importantly data from suppliers on the sound power level of equipment will become available. Additionally, it is anticipated that further information on construction activities, and plant will become available during the detailed design and procurement phase of the project. Therefore it is a strong recommendation that the provision within the tender documentation for update of the noise modelling is undertaken by the EPC contractor, during detailed design.

Noise modelling software allows the individual contribution of the noise sources to the overall noise level at a receiver to be identified. Mitigation measures can then be effectively targeted on the most significant noise sources if necessary.

9.5.2.2 CONSTRUCTION

The EPC contractor should undertake a noise and vibration assessment and shall ensure compliance with applicable standards. This should include work to establish and ensure acceptable vibration and air overpressure during blasting operations. The contractor should undertake a series of trial blasts with measurements of vibration and air overpressure. This activity may be associated with the preparation of the POC area.

The contractor shall develop, implement and maintain a construction phase Environmental Emergency Response Plan (EERP) and a Construction Environmental Management Plan (CEMP). These plans will detail responsibilities and procedures for environmental and emergency response management during construction, and include:





• Noise Management Plan – detailing measures to control noise and vibration emissions during construction and should consider:

o Monitoring to verify construction plant comply with PME regulations for noise

o Reduced noise limit for night time construction

o Reduction of vehicle movements to minimise noise

All construction work should be undertaken using best practicable means following guidance such a BS 5228: 2009 - “Code of practice for noise and vibration control on construction and open sites”, or other internationally recognised guidance for the control of noise and vibration.

Temporary sound-proof enclosures and anti-vibration measures should be employed to reduce noise levels on site, in keeping with the results of the updated noise and vibration model as necessary.

9.5.2.3 COMMISSIONING

During commissioning, the contractor should undertake a noise monitoring exercise to ensure compliance with required standards and limits and validate the results of the noise modelling exercise. The noise monitoring exercise will enable any necessary mitigation measures to be identified. Noise measurements would continue until it is established that there is full compliance with the required standards and limits.

9.5.2.4 OPERATION

Ma’aden should establish a programme of noise monitoring during the early months of Mine operation. This will include monitoring of noise at the boundary of the Mine, particularly the north western and western boundaries, to determine compliance with applicable standards and guidelines and assess the need for mitigation. As appropriate, noise mitigation measures such as the creation of screening mounds or installation of temporary noise barriers could be adopted.

From the data obtained from the updated noise and vibration modelling, Ma’aden should review and update the proposals for blasting to ensure that vibration levels resulting in a low probability of adverse comment (as defined in BS 6472-2: 2008) would not be exceeded at sensitive receptors. In addition, blasting should be designed such that there is low probability that air over pressure would exceed 120 dB(lin) at sensitive receptors.

Ma’aden shall develop, implement and maintain an Environmental Emergency Response Plan (EERP) and Environmental Management and Monitoring Plan (EMMP) for the operational phase, to further protect against impact from noise and vibration . These plans will detail responsibilities and procedures for environmental and emergency response management during operation, and shall include as a minimum:

• Noise monitoring programme and procedures for the implementation of such to demonstrate compliance with ambient noise standards;

• Monitoring of vibration levels and air over pressure levels to demonstrate these meet regulatory / good practise requirements;

• Competencies and training requirements of staff with environmental responsibilities, and lines of communication in the event of complaint; and

• Maintenance procedures of all equipment in place to minimise noise from equipment.

The operator should undertake regular audits of the above management plans to confirm their ongoing effectiveness.





9.5.2.5 CLOSURE / DECOMMISSIONING

Prior to decommissioning / closure Ma’aden should evaluate potential noise and vibration sources associated with planned decommissioning activities, and establish measures to ensure these activities comply with the necessary noise guidelines at the sensitive receptors. It should be noted, that this activity will require consideration of sensitive receptors over and above those identified by this assessment, as a result of the development of the Waad Al Shamaal City in the intervening years.





10.0 WASTE MANAGEMENT

The purpose of this Section is to describe the existing waste management facilities and assess the impact of the Project on the existing waste management facilities and resulting from all waste generated during the construction, commissioning, operation and closure /decommissioning of the Project.

Impacts arising from the management of wastes in terms of air quality, transport and health and safety are addressed in the relevant Sections 6– Air Quality and Meteorology, 13– Traffic and Transport and 15– Health and Safety.


10.1.1 NATIONAL WASTE MANAGEMENT

The Ninth Development Plan notes that population growth over the last 40 years has increased pressures on the environment. It goes onto identify that environmental pollutants generated by human activity, most notably solid and liquid waste have increased, (Ministry of Economy and Planning, 2009a).

Currently municipal solid waste in the Kingdom of Saudi Arabia (KSA) is collected by the local municipality and taken to landfill sites; however, these are under pressure due to the increasing quantities of waste and increasing urban populations (Ministry of Economy and Planning 2009a). A number of waste management companies operate within KSA, and collect commercial and industrial wastes under contract. The World Bank predicts that in KSA, per capita waste generation will be 1.7 kilograms per day by 2025, resulting in a total of 50,424 tonnes per day municipal solid waste (World Bank 2012). Zafar, however, estimates that in 2013 the population of 29 million generated more than 15 million tons of solid waste per year, equating to 1.5 to 1.8kg per person per day (Zafar, 2013a).

Management of the increasing amounts of solid waste is an ongoing problem in the KSA. According to the Presidency of Meteorology and Environment the management of solid waste is challenged by the following:

1. Absence of institutional infrastructure capable of planning, regulating, and implementing an integrated waste management system.

2. Lack of capacity for waste collection and transport. In some small cities, capacity is at only 30%, whereas it reaches only approximately 50% in some metropolitan areas. In smaller communities and villages, waste collection almost does not exist.

3. Operational problems, including inadequate maintenance capabilities;

4. Lack of qualified and trained technical staff for management and operation, coupled with low pay;

5. Massive shortfall in financing provided from all sources;

6. Lack of public landfill space that adhere to environmental regulations;

7. Lack of legal and regulatory system that would allow for integrated waste management; and

8. Low-level public awareness regarding the solid waste issue.

Recycling facilities are slowly increasing, but recent studies indicate that the recycling rate is 10-15% largely from an informal sector extracting paper, metals and plastic from municipal waste (Zafar, 2013b). The Arab News reported in October 2013 that the Saudi Environment Society (SES) estimated that Saudi Arabia was losing approximately SR 40 billion per annum due to its lack of recyling facilities (Arab News 2012). The government of the KSA is now investing in solving this waste management problem, in part through a 2011 national budget allocation of SR 29 billion for the municipal services sector, including waste disposal and water drainage (Ibid). One of the targets is to raise the proportion of recycled waste to 75% (Ministry of Economy and Planning 2009a).





10.1.2 LOCAL WASTE MANAGEMENT

Municipal solid waste collection and disposal in Turaif, the city closest to the Project site, falls under the jurisdiction of the Saudi Arabian Ministry of Municipal and Rural Affairs (MOMRA), and is delivered by the Turaif Municipality.

Mr Faris Al Nuaimi, the Governor of Turaif, and Mr Hussain Ali Al Khlaif, the Manager of Utilities for Turaif Municipality participated in consultation interviews in January 2013, provided details of the waste management facilities in Turaif. Waste from Turaif is currently disposed of in a municipal landfill, located approximately 5km north of the city. The landfill site, constructed in the first quarter of 2006, comprises 32 unlined cells each measuring 70m by 25m and up to 3m in depth. The landfill accepts both solid and liquid waste which is deposited in separate cells. Since there are no current restriction on the geographical expansion of the facility, when a cell is filled another cell is opened. According to a community survey conducted in January 2013 only a small percentage of respondents in Turaif recognized their waste was collected by the municipality and taken to the municipal landfill. There are currently no facilities for recycling in Turaif.

The city of Waad Al Shamaal, when constructed will include landfill for Class I, II and III material which will be complemented by recycling and thermal treatment technologies (Bechtel 2013). The Project proposes to utilise these facilities when they become available, by 2021.

10.1.3 WASTE TO BE GENERATED DURING PROJECT LIFETIME

The PME distinguishes three physical forms of waste; liquid waste, solid waste and sludge and characterises these as hazardous waste, non-hazardous waste and inert waste. The following sections identify the wastes anticipated to be generated as a result of the Project.

10.1.3.1 CONSTRUCTION AND COMMISSIONING WASTE

Early Works to prepare the process area and build access routes are expected to begin in October 2013. The main construction phase will begin in the second quarter of 2014 and is due to be complete at the end of 2017.

The cut and fill operation to create the working platforms will be undertaken as part of the Early Works Phase, and has been designed as a material balance to eliminate the production of surplus inert waste material. Limited waste is expected to be generated as a result of the construction of the temporary accommodation camp since this comprises prefabricated buildings that will be assembled on site.

The anticipated waste streams resulting from construction and commissioning are:

• Non-hazardous solid wastes: construction spoil and debris, wood (pallets), empty drums and containers (plastic and metal), packaging (paper, cardboard, plastics), municipal wastes and sanitary wastewater sludges;

• Hazardous solid waste: batteries; filters; empty oil, chemical or paint containers; fabrics contaminated with oil; interceptor wastes, spent electrical equipment and clinical waste; and

• Hazardous liquid waste: waste oils, lubricants and fuels and drainage waters contaminated with these, solvents; paint; thinners; hydraulic fluid; and cleaning chemicals; contaminated hydro-test water.

Table 10-1 provides an estimate of the main materials and equipment required to construct the facility. Determination of more detailed estimates of materials required for construction, will be undertaken as the detailed design progresses. The storage, handling, installation, and use of the materials and equipment will generate waste during construction.





Table 10-1: Estimate of Materials and Equipment

Materials and Equipment Quantity

Equipment 5,600 items

Aboveground Pipe 535,000 metres

Underground Pipe 86,000 m

Firemain 46,000 m

Overhead Power Lines 373,000 m

HV Cable 386,000 m

LV Cable 2,358,000 m

Instrument Cable 790,000 m

Field Instruments 10,400 No.

F & G Devices 9,700 No.

Concrete (Foundations & Structures) 370,000 m3

Structural Steel 60,000 Tonnes

No Of Buildings (excl clad structures) 239 No.

Table 10-2 provides an estimate of the quantities of non-hazardous waste anticipated to be generated during construction based on the number of construction workers, and estimated construction materials, and equipment detailed above. Table 10-2: Non-hazardous Construction Waste

Waste Stream Tonnes 7

Concrete waste 9,324

Pipework off cuts etc. 11,373

Steelwork of cuts etc. 7,560

Electrical Cable Waste 1,480

Miscellaneous Construction Waste 32,072

Municipal Waste 7,062

Solid Sanitary Waste 546

Total 96,892

10.1.3.2 OPERATIONAL WASTES

The operation of the Mine and Industrial Complex is will generate the following principal waste streams:

• Non-hazardous solid wastes: waste rock from mining, silaceous materials and tailings from benefication, packaging (paper, cardboard, plastics), municipal wastes and sanitary wastewater sludges;

7 The above estimates are based on Waste and Resources Programme (WRAP) Netwaste Tool – wastage rates and the WRAP waste per £100,000 of

construction.





• Hazardous solid waste: batteries, filters, empty oil, grease and chemical containers; contaminated fabrics/ spill absorbents; physphogypsum, fluorspar, sodium fluorosilicate, calcium fluorosilicate, spent catalyst, spent activated carbon, industrial wastewater treatment sludge, oily sludge and clinical waste; and

• Hazardous liquid waste: waste oils, lubricants and fuels, solvents, hydraulic fluid and acids and other chemicals.

Contaminated wastewaters are addressed in Section 11 – Water Quality Management.

Table 10-3 summarises the estimated quantities of the main waste streams generated by the Mine and Industrial Complex during the operation of the facility. A full description of the waste streams and disposal process is provided in Section 4 Detailed Description and Layout of the Proposed Development.

Table 10-3: Estimated Quantities of Principal Operational Wastes Waste Stream Source Quantity

(tonnes/yr)8 Classification

Overburden / Interburden Mine 33,650,0009 Inert

Silaceous materials

(optical ore sorter rejects)

Beneficiation 1,653,000 Inert

Tailings Beneficiation 5,582,000 Non-hazardous

Phosphogypsum PAP 11,407,000 Hazardous

Fluorspa PAP 1,224,000 Hazardous

Phosphogypsum PPA 39,000 Hazardous

Sodium Fluorosilicate PPA Hazardous

Phosphogypsum MCP/DCP 18,000 Hazardous

Calcium Fluorosilicate & Calcium Silicate

MCP/DCP 126 Hazardous

Vanadium Oxide Catalyst SAP 84010 Hazardous

Activated Carbon PPA 1000 Hazardous

Municipal Waste All 40611 Non-hazardous

Sanitary Waste Sludge SWTP 4712 Non-hazardous

In addition to these wastes the operation of the Project is expected to require replacement of spent vanadium catalysts from the Sulphuric Acid Plant, and spent activated carbon from the Purified Phosphoric Acid plant. At least one of the catalyst beds, each of which range from 250 – 400m3 in size are to be recharged almost every year. Furthermore quantities of municipal wastes as identified in the table are anticipated.

The most significant wastes generated by the Project are to be managed on site as follows:

• Mine wastes are used to progressively backfill, and close the excavated pit;

8 Rounded to the nearest thousand 9 Average quantity per year. Actual quantities estimated by the mining schedule vary per year. 10 Average annual generation in m3 11 Based on estimated 1.2kg per person per work year (260 days), for all c 1,300 employees 12 Based on estimate of 0.06% of sanitary waste water is sludge





• Optical ore sorter rejects, Tailings and Phosphogypsum / Fluorspa / Fluorosilicates are to be stored in dedicated, lined and appropriately engineered waste storage facilities ad infinitum.

All other wastes are to be stored on site temporarily in suitable storage containers / transported off site by PME approved waste carriers to off site licensed waste management facilities.

10.1.3.3 CLOSURE / DECOMMISSIONING WASTES

The progressive backfill of the mine will result in a deficit of material at the end of the life of the mine, resulting in approximately 11cm depression across the whole mine area. Decommissioning of the facilities at the mine, i.e. the primary crusher and mine maintenance area, and decommissioning of the Industrial Complex can be expected to generate similar wastes to those identified for the construction phase, however it is reasonable to expect higher quantities of contaminated wastes,

• Non-hazardous solid wastes: demolition wastes, scrap metals and redundant plant silaceous materials and tailings from benefication, packaging (paper, cardboard, plastics), municipal wastes and sanitary wastewater and evaporation pond sludges;

• Hazardous solid waste: demolition wastes; contaminated scrap metals and redundant plant filters, empty oil, grease and chemical containers, contaminated fabrics/ spill absorbents, spent catalyst, spent activated carbon, industrial wastewater treatment sludge, evaporation pond sludges, oily sludge and clinical waste; and

• Hazardous liquid waste: waste oils, lubricants and fuels, solvents, hydraulic fluid and acids and other chemicals.

The quantification of these wastes should be undertaken as part of the closure / decommissioning plan (see Appendix A).


10.2.1 INTRODUCTION

This Section describes and assesses the impact on existing waste management system and those resulting from the generation of waste by the Project during from the construction, commissioning, operation and decommissioning/closure. Potential impacts from dust generation are assessed in Section 6 Air Quality and Meteorology, those from leaching and spillage are assessed in Section 7 Terrestrial Environment and potential impacts on habitat are assessed in Section 8 Biological Resources. The significance of potential impacts on existing and are characterised in accordance with methodology described in Section 5 Impact Assessment Methodology.

10.2.2 CONSTRUCTION AND COMMISSIONING

Early Works to prepare the Industrial Complex area and build access routes are expected to begin in October 2013. The main construction phase will begin in the second quarter of 2014 and is due to be complete at the end of 2017. The impacts are summarised in Table 10-4 and discussed in the subsequent sections.





Table 10-4: Construction Phase Impact Assessment

Scope of Impact WM1 WM2


Medium Medium

Frequency Frequent Frequent

Likelihood Likely Unlikely

Extent Provincial Local

Duration Short Short

Magnitude High High


Acti on Direct Direct

Significance Medium Low

10.2.2.1 GENERATION OF NON-HAZARDOUS AND HAZARDOUS WASTES

The generation of almost 100,000 tonnes of non-hazardous waste and an unconfirmed quantity of hazardous waste, represents a significant increase in waste generation in the area. Each cell within the Turaif landfill has a capacity of approximately 5,000m3; using a conversion factor for wastes arising from construction, demolition and excavation of 0.87 (WRAPb) each cell may be able to accommodate c. 4,000 tonnes of waste. Thus disposal of the Project’s construction waste in Turaif landfill would require in excess of 24 cells; a 43% increase in the size of the landfill. Utilisation of the existing waste management infrastructure in Turaif would place a significant strain on the facilities, and use of this facility has been denied by Turaif Municipality. The lack of waste management facilities available for use during construction is a key constraint to the Project, identification of suitable waste management facilities for construction waste is of paramount importance in advance of the commencement of construction activity.

Impact WM1 - Medium Significance.

10.2.2.2 ENVIRONMENTAL DEGRADATION DUE TO INCORRECT STORAGE / SPILLAGE

Incorrect storage of both hazardous and non-hazardous waste has the potential to contaminate soils, and surface water, generate litter and encourage vermin. It also presents a risk to wildlife. The EPC contractor is required generate a Site Waste Management Plan (SWMP), and to store wastes generated during construction and commissioning in accordance with the requirements of PME Standards 12 and 13, Waste Control and Waste Storage and Handling, therefore the potential impact is considered to be of low significance. Impact of spills on the soil, groundwater and surface water are addressed in Section 7 Terrestrial Environment and Section 11 Water Quality Management.

Impact WM2 - Low Significance.

10.2.3 OPERATION

The operation of the facility will produce both hazardous and non-hazardous waste. The nature of the hazardous waste means it has the potential to be of high significance unless mitigation measures are implemented. The impacts are summarised in

Table 10-5 and discussed in the following sections.





Table 10-5: Operation Phase Impact Assessment Scope of Impact WM3 WM4 WM5 WM6


Medium Medium Medium Medium

Frequency Frequent Frequent Infrequent Rare

Likelihood Unlikely Certain Certain Unlikely

Extent Provincial Local Regional Local

Duration Long Long Medium Short

Magnitude Medium Low Medium Medium



Significance Medium Low Medium Low

10.2.3.1 GENERATION OF NON-HAZARDOUS WASTES

The generation of non-hazardous wastes is reduced during the operation phase, with these primarily municipal wastes generated by employees. The quantity of municipal waste estimated to be generated by employees is approximately 406 tonnes per year; equivalent to a Turaif landfill cell every 3 years. While the demand for landfill capacity is less aggressive than during construction, the Project would need access to at least 7 landfill cells over its 20 year life; almost 20% increase to the existing capacity. In the context of the ongoing demand for landfill capacity, the potential impact on the existing waste management infrastructure is considered to be of medium significance.

It is noted however, that the Waad Al Shamaal City master plan includes the development of landfills that when operational would provide the landfill, and other waste treatment capacity required.

Impact WM3 - Medium Significance.

10.2.3.2 GENERATION OF HAZARDOUS WASTES

The most significant quantities of hazardous waste generated by the Project will be stored in the Project area ad infinitum.

The inclusion use of the mining waste to backfill the excavated pit limits the requirements for spoil heaps with their intendant impact on land take, and potential for soil and surface water contamination. However there are waste dumps are generated within the footprint of the mine in the early years of mine operations, until such time as sufficient void space is available for back fill. The impacts of the waste rock dumps on ground water and surface water, are addressed in Section 7 Terrestrial Environment, and Section 11 Water Quality Management respectively.

Optical ore sorter rejects, and tailings from beneficiation, are to be stored in the Tailings Storage Facility (TSF), and phosphgypsum, fluorspar and fluorosilicates are to be stored in the the Phosphogypsum Storage Facility (PSF) consisting of two phosphogypsum ‘stacks’. These waste storage facilities are designed to accommodate their contents and protect the environment. The impacts these facilities will have on the environment are addressed in Sections 6 Air Quality and Meteorology, 7 Terrestrial Environment, 8 Biological Resources, and 11 Water Quality Management.

Impact WM4 – Low Significance.

Other hazardous wastes, including clinical waste generated will be stored temporarily on site, before being transported by a registered waste carrier to a licensed waste management





facility. Since there are no licensed hazardous waste management facilities in the immediate vicinity of the Project site, hazardous wastes will need to be transported considerable distances for treatment, increasing risks associated with their transportation. Since the quantity of hazardous waste has been defined only broadly, and the capacity of hazardous waste facilities to take the wastes generated is unknown, therefore a conservative approach to the impact of other hazardous waste generation is taken.

Impact WM5 – Medium Significance.

10.2.3.3 ENVIRONMENTAL DEGRADATION DUE TO ACCIDENTAL EVENTS

There is the potential for accidental events during the operation of the Project which result in the release of hazardous substances. The uncontrolled release of hazardous waste from a storage area has the potential to have a negative impact on the environment through contamination of soil, surface water and groundwater, and wildlife.

Accidental release of wastes could be realised during the movement of materials on or off-site or through the use of inappropriate containers, overfilling, or container damage. The accidental release of wastes could contaminate the ambient air quality, contaminate water or soils.

Waste storage areas are contained within the Industrial Complex, and are therefore on hard-standing and within the contaminated water drainage system, thus accidental spills of hazardous material will be captured, and can be dealt with via operational spill control procedures.

Impact WM6 – Low Significance.

10.2.4 CLOSURE / DECOMMISSIONING /

Closure / decommissioning of the Project is likely to comprise the removal of the high value equipment, safe closure of storage ponds etc. Closure / decommissioning is not expected to see the complete removal of the site infrastructure.

Table 10-6: Decommissioning/Closure Phase Impact Assessme nt Scope of Impact WM7 WM8


Medium Medium

Frequency Continuous Rare

Likelihood Certain Unlikely

Extent Regional Provincial

Duration Long Long

Magnitude Low High



Significance Low High

10.2.4.1 ALTERATION OF THE LANDSCAPE

The generation of large quantities of tailings and phosphogypsum during operation, will result at closure, in a number of waste storage facilities which will alter the landscape and present ongoing alteration of the visual landscape in the vicinity of the Project. The Tailings Storage Facility ( will cover an area of 5km2 and reach a height of 30-35m. The Phosphogypsum Storage Facility will cover an area of 6km2 and reach a height of c. 50m. These waste storage structures represent major structures within the landscape which will remain following decommissioning and closure. These will be approximately one quarter the height of the Umm Wu’al mountain, the most significant geomorphological feature in the landscape. While





these new features alter the visual aesthetic of the landscape they are over 40km from the nearest settlement, Turaif, and more than 15km from the Ma’aden housing within the Waad Al Shamaal City, for this reason, the significance of this impact is considered low.

Impact WM7 - Low Significance.

10.2.4.2 DEGRADATION OF THE ENVIRONMENT DUE TO FAILURE OF CONTAINMENT

The tailings storage facility, gypsum storage areas are designed to be left in situ but will require ongoing management and maintenance by Ma’aden. Unmanaged it is possible that the containment structure fails, resulting in contamination of soils, surface waters and possibly groundwater. The long-term consequence of the failure of the gypsum stack are addressed in Sections 7 Terrestrial Environment, and 11 Water Quality Management. The requirement for ongoing management to ensure the ongoing protection of the environment from these wastes results in this impact being considered of high significance.

Impact WM8 - High Significance.

10.3 MITIGATION

Implementation of mitigation measures will be required during construction, commissioning, operation and decommissioning of the facility to minimise potential negative impacts of the activities on waste management systems. The mitigation measures comprise a combination of physical design features of the facility, management procedures and monitoring arrangements and are described in the subsequent sections. The following text assesses the impacts predicted as being of medium to high significance against appropriate mitigation measures to predict the residual impact significance.





10.3.1 CONSTRUCTION & COMMISSIONING PHASE – IMPACTS AND MITIGATIONS



after Mitigation

WM1 Generation of Hazardous and Non-hazardous Waste; impact on existing waste management facilities

Medium

• Ma’aden to devise a waste management strategy for the disposal of construction wastes in collaboration with Turaif Municipality, the PME, and Waad Al Shamaal developer which identifies appropriate local disposal / recycling facilities that are operated in accordance with regulatory requirements and industry good practise.

• EPC Contractor to develop a Construction Waste Management Plan to identify in more detail anticipated wastes, and their quantities, and undertake waste planning for treatment and disposal.

Low





10.3.2 CONSTRUCTION & COMMISSIONING PHASE RECOMMENDATIONS

The EPC Contractor shall develop, implement and maintain a Construction Waste management Plan (CWMP) based on good industry practise, an Environmental Emergency Response Plan (EERP) and a Construction Environmental Management Plan (CEMP) as supporting documents to the Environmental Management and Monitoring Plan (Appendix A of this ESIA). These plans will detail responsibilities and procedures for environmental management and emergency response during construction, including:

• Minimum technical standard of waste storage areas;

• Competencies and training requirements of staff managing waste storage areas and communication and procedures in the event of an emergency;

• Spill control procedures;

• Waste segregation, and storage procedures;

• Procedures to be implemented following an accidental release of hazardous substances, e.g. during refuelling, including details of measures to be adopted to stop, contain as far as practicable on site, and clean up spills, and to inform the relevant authorities in the event that a spill migrates (or occurs) off-site so that appropriate regional plans can be activated; and

• Availability of pumps and spill mitigation materials such as absorbent granules to contain and recover hazardous substances releases.

The contractor will undertake regular audits of the above management plans to confirm their ongoing effectiveness.

The EPC contractor shall: • Design, construct and manage and maintain storage areas for non-hazardous and

hazardous waste to prevent accidental and/or uncontrolled discharges of material.

• Implement waste segregation, and where possible recycling programme.

• Minimise the on site storage times;

• Uutilise / ensure the use of covered vehicles for the transportation of waste;

• Minimise the distance travelled;

• Provide training of all suppliers and sub-contractors in site waste management procedures

• Undertake an extensive audit of waste management facilities to confirm capacity to receive future quantities of waste, and operation in compliance with licence conditions and good industry practise

All designs, facilities and management systems will be complaint with PME Standards.





10.3.3 OPERATIONS PHASE - IMPACTS AND MITIGATION



after Mitigation

WM3 Generation of Non-hazardous waste – impact on existing waste facilities Medium • Ma’aden to devise a waste management strategy

for the disposal of operational wastes in collaboration with Turaif Municipality, the PME, and Waad Al Shamaal developer which identifies appropriate local disposal facilities that are operated in accordance with regulatory requirements and industry good practise.

• Ma’aden to develop an Operational Waste Management Plan to identify in more detail anticipated wastes, and their quantities, and undertake waste planning for treatment and disposal.

Low

WM5 Generation of Non-hazardous waste – impact on existing waste facilities Medium Low






Ma’aden shall develop a Waste Management Strategy for the Project lifecycle, which shall apply the waste hierarchy and shall be commensurate with good practice within the waste management industry. Appendix A – EMMP includes details of the Project approach to waste management. Ma’aden shall develop, implement, audit and maintain a Project Waste Management Plan in accordance with regulatory requirements and good industry practise, building on the Project EMMP and an EERP (refer to Appendix A and Appendix B respectively). This plan will detail responsibilities and procedures for waste management during operation of the facility. This shall include but, not be limited to:

• Waste and recycling objectives and targets;

• Waste segregation, storage and recycling / waste management procedures;

• Maximum storage times, and details of waste handling and labelling requirements;

• Selection, monitoring and auditing of waste contractors, and off site waste management facilities;

• Waste vehicle requirements;

• Competencies and training requirements of staff with responsibilities for managing waste storage areas, and procedures and lines of communication in the event of an emergency (including accidental releases of hazardous substances);

• Procedures to be implemented following an accidental release of hazardous substances, including details of containment and recovery measures to be applied; and

• Procedures for the monitoring of waste arisings and collection and reporting of data on these.

Ma’aden shall provide training for staff, sub-contractors and suppliers on the on-site waste management system (as appropriate), use of spill mitigation materials and equipment and procedures, in the event of an emergency (including accidental releases of hazardous substances).

Ma’aden shall undertake an extensive audit of waste management facilities to confirm capacity to receive future quantities of waste, and operation in compliance with licence conditions and good industry practise

Ma’aden shall undertake regular audits of the above management plans to confirm their ongoing effectiveness.







Significance Mitigation Measure Signif icance

after Mitigation

WM8 Degradation of Environment due to failure of containment High

• Ma’aden shall commission a condition report prior to decommissioning identifying key issues such as condition of lining and drainage system.

• Ma’aden shall develop further the outline closure plan to include maintenance programme, monitoring and reporting strategy and emergency action plan for the waste storage areas.

• Ma’aden shall resource and implement the closure plan and associated maintenance and monitoring plans.

Medium






Ma’aden shall further develop the outline closure plan prepared for the ESIA over the Project life, to provide adequate detail for sound, and sustainable site decommissioning and closure. The closure plan should detail procedures for the safe and environmentally sound decommissioning of the Industrial Complex, and management of the retained waste storage facilities.

Furthermore, the plan should consider including:

• Procedures for removal and disposal of wastes during closure / decommissioning;

• Waste segregation, storage and recycling / waste management procedures;

• Waste handling and labelling requirements;

• Selection, monitoring and auditing of waste contractors, and off site waste management facilities;

• Competencies and training requirements of staff with responsibilities for waste management in decommissioning, and lines of communication in the event of an emergency (including accidental releases of hazardous substances);

• Competencies and training requirements of staff with responsibilities for ongoing management, maintenance and monitoring of the retained waste storage facilities and procedures and lines of communication in the event of an emergency (including accidental releases of hazardous substances);

• Procedures for the ongoing management, maintenance and monitoring of the retained waste storage facilities, including monitoring location, and frequencies, and analysis of resultant data.

Ma’aden shall update (or develop new), implement, maintain and audit the EERP and EMMP so the documents remain adequate and effective for the decommissioning / closure phase. This should be undertaken in the context of the detailed closure plan developed over the course of the Project life, and in advance of decommissioning / closure.

Following decommissioning and demolition of the facility, a survey of the surface water and soil quality at the site should be completed to confirm that the presence and operation of the facility has not led to an unacceptable deterioration in quality. Should contamination be identified that could have been caused by the facility, a specific remedial plan will be developed to define the extent of contamination and remedial measures to be implemented.





11.0 WATER QUALITY MANAGEMENT

10.4 INTRODUCTION

The purpose of this Section is to describe the existing surface water system and associated water quality, and assess the impact of the Project on surface water and the existing surface water system resulting from the construction, commissioning, operation and decommissioning. The source of water for the Project is groundwater and impacts on this resource are assessed in Section 7 Terrestrial Environment. Potential impact on habitat/ecology is assessed in Section 8 Biological Resources. This chapter assesses the impacts of changes to the surface water system and water quality.


10.6 INTRODUCTION

The Kingdom of Saudi Arabia is the largest country in the world without a natural, perennial river connecting to the sea (CIA, 2013). As a result the water available comes from:

• Surface water; primarily in the form of dams to capture rainwater;

• Ground water in underground aquifers;

• Desalination; and

• Reclaimed wastewater (Vincent, 2008).

The Ninth Development Plan provides information on water policies and usage (Ministry of Economy and Planning 2009) and identifies the main demands for water and provides information on water sources (Table 11-1).

Table 11-1: Water Balance Eighth Development Plan

Description

2004

(Mm3/y)

2009

(Mm3/y)

Average Annual Growth

(%)

Water demand for municipal purposes 2100 2330 2.1 Water demand for industrial purposes 640 713 2.2

Water demand for agricultural purposes 17530 15464 -2.5

Total demand for water 20270 18507 -1.8

Renewable surface and ground water (Arabian Shield)

5410 5541 0.5

Non-renewable ground water 13490 11551 -3.1

Desalinated sea water 1070 1048 -0.4

Reclaimed agricultural wastewater 40 42 1.0

Reclaimed wastewater 260 325 4.6

Total available water resources 20270 18507 -1.8

[Source: Ministry of Economy and Planning 200913].

Table 11-1 demonstrates that while demand for water was reduced between 2004 and 2009 non-renewable groundwater was the source of the majority of water consumed; with renewable sources and desalination representing the other major sources. To continue this trend; addressing the demand side of water resource management and developing water-saving technology, three objectives are defined in the Ninth Development Plan:

13 Actual figures as identified in Chapter 25 Water and Sanitation in the Ninth Development Plan





• To achieve conservation of water resources and maximising effective utilisation rates.

• Good governance and rational and integrated management of the water and sanitation sector.

• Providing water and sanitation services efficiently, through effective partnership between the public and private sectors.

A key feature of the Ninth Development Plan relating to water conservation and efficiency is the issue the National Water Plan by 2103 (Ministry of Economy and Planning, 2009).

The Ninth Development Plan forecasts the following water demand for the Northern Borders by 2014:

• Municipal - 27 million cubic metres.

• Agricultural – 6 million cubic metres.

• Industrial – 3 million cubic metres (Ministry of Economy and Planning, 2009).

10.7 HYDRAULIC MODELLING

There are no permanent natural sources of surface water in the vicinity of the Project or Turaif. However, there is an extensive series of wadis that run east to west across the area into a natural depression in the landform. The wadis are charged during the sporadic rainfall events which result in an annual average rainfall of approximately 87mm.

A study of the wadi system was undertaken for all wadis draining catchments greater than 1km2. These catchment areas were identified using the Advanced Spaceborne Thermal Emission and Reflection Radiometer Ground Digital Elevation Model and high resolution satellite imagery provided by Infoterra. Three main wadis, proximal to the proposed Industrial Complex, present a potential flood risk to the Project. All three wadis flow from east to west across the region towards natural depressions in the landscape to the west of the Industrial Complex. The North Wadi measures approximately 100m wide and serves a catchment area of approximately 112km² where it flows adjacent to the northern perimeter of the site. The Middle Wadi runs through the middle of the Industrial Complex where the phosphogypsum is to be stored; this system serves a catchment area of approximately 30km². The South Wadi flows immediately south of the Industrial Complex, it measures 270m in width at the point adjacent to the site and serves a catchment of 207km². Additionally a main wadi flowing east to west through the northern area of the proposed mine was identified, which passes over the Jordanian border and back and then flows towards the natural depression in the landform to the south-west of the mine.

Statistical methods have been used to estimate flood flows on the wadi systems. These are widely used for areas with little or no flood data, as is the case at the Project site. Methods relevant to arid regions of the world (Farquharson 1992) are used with the data for Saudi Arabia and Yemen deemed most appropriate as the annual rainfall in these areas is more representative of that recorded in the Umm Wu’al area. In this statistical method the mean annual flood at gauged catchments in Saudi Arabia and Yemen has been related to catchment characteristics, in this case annual average rainfall and catchment area, to derive the relationship for mean annual flood, providing an indication of flood flows at the Project site. As statistical methods are prone to uncertainty another flood estimation technique, the United States Soil Conservation Service Unit Hydrograph method, was employed to validate the flood estimates derived using the statistical approach. For the 1 in 20 year flood estimates