ENVIRONMENTAL REGULATORY ISSUES

PADA PROYEK PEMBANGUNAN &

PENGOPERASIAN LNG PLANT

Ir. Habibie Razak, MM., ASEAN Eng., ACPESenior Project Manager & Seller Doer - Power, Oil & Gas

Sekretaris Bidang Distribusi Gas, Persatuan Insinyur Indonesia Pusat

Wakil Ketua Bidang Hukum dan Advokasi, Badan Kejuruan Sipil (BKS) PII

Workshop Continuing Professional Development (CPD) – Kelas Teknik LingkunganDitjen Bina Konstruksi, Kementerian PUPERAJakarta, 04 Oktober 2016

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IARE-DEFINISI INSINYUR:

Insinyur dari Wikipedia:Insinyur adalah orang yang bekerja dalam bidang teknik, yang berbekal pengetahuan ilmiah untuk menyelesaikan masalah praktis dengan menggunakan teknologi.

Insinyur menurut PII:Insinyur adalah orang yang melakukan rekayasa teknik dengan menggunakan ilmu pengetahuan untuk meningkatkan nilai tambah atau daya guna atau pelestarian demi kesejahteraan umat manusia

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IALNG LIQUEFACTION SYSTEM

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IALNG LIQUEFACTION SYSTEM

• Inlet Gas Compression

• Gas Treating; Amine Treatment, Dehydration, Mercury &

Benzene Removal.

• LNG Liquefaction Utilizing Patented Technology.

• Nitrogen Removal.

• LNG Storage.

• Condensate Storage.

• LNG Off Loading.

• Boil-off Gas Handling / Compression.

• Refrigerant Make-up.

• Utilities; Electrical power supply, Instrument Air, Utility Air,

Nitrogen, Plant Service Water (potable, utility, etc.).

• Vent and Drain Systems.

• Firewater System.

• Support Buildings: Control / Administration / Office Building(s),

Warehouse / Maintenance Building(s), Powerhouse Building.

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IAOVERVIEW OF PROJECT ENVIRONMENTAL ASPECTSSUBJECTS TO ENVIRONMENTAL REVIEW & PLANNING

• The project site location (topography, hydrology, geotechnical, site ambient condition, area required, area zonation, etc.)

• Air emissions associated with process equipment• Handling and storage of chemicals and liquids at the

site to prevent adverse impacts to ground water• LNG management from LNG liquefaction plant,

transportation down to customer side

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IAOVERVIEW OF PROJECT ENVIRONMENTAL ASPECTS

• The project site location (topography, hydrology, geotechnical, site ambient condition, area required, social condition, biological condition, etc.)

• Air emissions associated with process equipment• Handling and storage of chemicals and liquids at

the site to prevent adverse impacts to ground water

• LNG management from LNG liquefaction plant, transportation down to customer side

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IAPROCESS EQUIPMENT AND MANAGEMENT OF POTENTIAL ONSITE IMPACTS

• Air emissions (amine treatment and dehydration,

heaters, refrigerant and heavies knock-out drums,

boil off and compression and load-outs)

• Emissions were calculated based on the sources

operating continually on an annual basis.

• The applicable Indonesian emissions standards

are on a per-unit basis and contain limits in

milligrams per normal cubic meter (mg/Nm3) for

emissions of nitrogen dioxide (NO2), sulfur dioxide

(SO2), and particulate.

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IAINDONESIAN EMISSION STANDARDS

Example of LNG Plant Operational Emissions and Indonesian Emission Standards

SOURCE

EMISSIONS EMISSIONS

STANDARD

(MG/NM3)[2]

IN

COMPLIANC

E (YES/NO)Pollutant (mg/Nm3) (Tonnes/Yr)

Amine

Reboiler

NOX TBF TBF 1,400 YES

SO2 TBF TBF 1,200 YES

Particulate TBF TBF 300 YES

Regeneration

Gas Heater

NOX TBF TBF 1,400 YES

SO2 TBF TBF 1,200 YES

Particulate TBF TBF 300 YES

Notes [ ]:

1. See Appendix M for detailed emissions calculations.

2. Minister of Environment Decree No. Kep. 129/MENLH/2003, Appendix III emissions standards

for boilers

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IAMANAGEMENT OF CHEMICALS AND MATERIALS

• The project normally will be storing and

transferring LNG but it should be limited to store

additional potentially hazardous chemical supplies.

• The design phase will include appropriate

safeguards for storage and use of materials.

• In the operations phase, all materials will be used

and stored in a protective manner under the

implemented Environmental Management System

to minimize the chances for spills and leaks.

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IAMANAGEMENT OF CHEMICALS AND MATERIALS

Materials to be used/stored including but not limited to the

following:

• Gas Liquids - LNG storage with appropriate design

safeguards, limited storage of condensate in a small

tank.

• Refrigerants - ethylene, propane, and any other liquids

used as refrigerants for the project and supplies of each

have to be maintained on-site.

• Recovered Sulfur - The amine system is to remove the

trace amounts of sulfur, and the recovered material will

be incorporated as part of plant fuel. For high H2S

content in the gas stream normally will require dedicated

SRU

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IAMANAGEMENT OF CHEMICALS AND MATERIALS

Materials to be used/stored including but not limited to the

following (continued):

• Mercury - Mercury will be removed from the intake gas flow

via an adsorption unit associated with the dehydrator. The

adsorbent accumulates mercury for approximately a 5-year

or longer period before requiring replacement adsorbent

and disposal of the spent material as a hazardous material

under the applicable regulations.

• Other Reagents - additional materials are managed within

the processes (such as amine and catalysts), or are used

for maintenance purposes. All materials will be managed in

a secure manner protective to the environment in

conjunction with liquefaction plant spill and containment

planning.

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IASURFACE WATER AND GROUND WATER IMPACTS

• The project shall be designed and managed to minimize any

potential adverse impact to surface water and ground water.

• The liquefaction plant shall not directly discharge any

process waste-water to surrounding surface water.

• Process waste-water shall be limited to small quantities of

condensate waters that will be collected in a small tank. The

accumulated wastewater will be hauled off-site for either

energy recovery or treatment/disposal by appropriately

licensed treatment/disposal facilities.

• Storm water runoff shall be mitigated by site design

drainage planning.

• Properly designed containment systems for any stored

chemical materials or fuels and have to be managed under

a storm water pollution prevention plan as part of the

liquefaction plant environmental management system.

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IASURFACE WATER AND GROUND WATER IMPACTS

• Groundwater impacts of the project are anticipated to be

very minor if any. Any fill material to be added to the site

associated with construction will be sampled to confirm the

materials are suitably free of pollutant contamination prior to

use on the site.

• The only potential adverse impacts associated with

construction and operations would arise from unintended

accidental spills or releases.

• All fuels and liquid materials will be managed during

construction to avoid and capture any releases that could

migrate to groundwater.

• All chemical and fuel materials used during operations will

be maintained in appropriately designed containment and

will be managed to avoid potential spills or other releases to

the ground.

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IAENVIRONMENTAL RISKS AND MITIGATING FACTORS

PROJECT

ACTIVITY

ISSUES AND

POTENTIAL

IMPACTS

MITIGATION

MEASURES

MEANS OF

IMPLEMENTATION

RESPONSIBLE

PARTY

Land

clearing

Loss of

vegetation, loss

of agriculture

capacity, and

loss of timber

resources as a

result of land

clearing

Minimize “footprint”

Harvest usable timber

Minimizeimpacts fromtree cutting andland clearing

Clearing isrestricted to landrequired.

The project and

EPC contractor

for LNG plant

construction

Land

clearing

Reduction in

faunal habitats,

biodiversity, and

genetic diversity

Minimize “footprint”

Conserve the remaining area

Biological surveys, with

management as

necessary, based on

survey results

The project,

assisted by

consultants

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IAENVIRONMENTAL RISKS AND MITIGATING FACTORS

Land clearing and

earthworks

Soil instability,

erosion, and

sediment

transport due to

earthworks

Select a site with low relief

Implement erosion control measures

Minimize the need for cut and fill

Land clearing and grading following establishment of erosion protection measures

Erosion protection using vegetative matting and mulches, velocity reduction barriers, retaining walls, and sediment retention basins

Temporary stabilization, by seeding and/or mulching, applied to areas that would otherwise remain in a disturbed condition for more than 90 days

The project

owner, and

EPC

contractors

for LNG

plant

PROJECT

ACTIVITY

ISSUES AND

POTENTIAL

IMPACTS

MITIGATION

MEASURES

MEANS OF

IMPLEMENTATION

RESPONSIBLE

PARTY

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IAENVIRONMENTAL RISKS AND MITIGATING FACTORS

PROJECT

ACTIVITY

ISSUES AND

POTENTIAL

IMPACTS

MITIGATION

MEASURES

MEANS OF

IMPLEMENTATION

RESPONSIBLE

PARTY

Workforce

recruitment

Potential

dissatisfaction or

conflicts among

local residents as a

result of unrealized

employment

expectations

Integrated social

programs involving

community

consultation, job,

training, and conflict

resolution

Provision of education programs and vocational training in building skills

Community consultation, public participation, and conflict management

Development of conflict resolution and grievance procedures

The project,

and all EPC

and other

contractors

Workforce

deployment

Social or cultural

problems due to

interaction of

traditional villagers

with construction

workforce

Minimize opportunities

for interaction

Planning by contractors

The project,

and all EPC

and other

contractors

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IAENVIRONMENTAL RISKS AND MITIGATING FACTORS

PROJECT

ACTIVITY

ISSUES AND

POTENTIAL

IMPACTS

MITIGATION

MEASURES

MEANS OF

IMPLEMENTATION

RESPONSIBLE

PARTY

Perimeter fence

around LNG

property

Isolation of small

populations of some

species of wildlife

within the fenced

area could result in

nonviable

populations or

eventual reduction

in genetic diversity.

(Alternatively, the

protection afforded

by the fence could

benefit these

species.)

Manage the un-cleared

part of the project

property to conserve

ecological values

Vegetation and fauna within the project “footprint” will be monitored before any land clearing, and again after completion of land clearing.

The project

Displacement of

villagers

Loss of livelihoods,

reduced access to

resources.

Resettlement

Compensation

Development of alternative livelihoods

Provision of alternative access to resources.

Provision of training and construction employment.

The project

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IAENVIRONMENTAL REGULATORY ISSUESAMDAL, UKL/UPL REQUIREMENTS

• Environmental Impact Assessment or called AMDAL – Analisis

Mengenai Dampak Lingkungan. The types of businesses and

activities that are subject to the AMDAL requirements are

specified in the State Ministerial Ordinance of Environment No.

5 of 2012.

• If the proposed LNG project does not appear to be in a

category that requires a formal AMDAL process then UKL/UPL

will still be needed.

• LNG plant(s) with a capacity equal to or over 550 MMSCFD

will need an AMDAL regardless other factors.

• As noted in the ordinance of Environmental Ministry No. 13

Year 2010 Article 5 Page 2, the approval of UKL/UPL will be

completed by local government.

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IAENVIRONMENTAL REGULATORY ISSUESINTERNATIONAL LENDING STANDARDS – FINANCING PURPOSE

• Typically, financing institutions will require that the more

stringent of the IFC/World Bank or host country (Indonesia)

environmental performance standards be met as a condition of

providing loan financing.

• The IFC/World Bank standards will in most cases provide the

design and performance criteria for a new project seeking

international financing.

• The Government of Indonesia has established its own

environmental standards and guidelines for project design and

operations – including air quality standards, emission

guidelines, effluent limits, noise standards, and hazardous and

toxic waste management guidelines.

• Planning and strategy activities for permitting the proposed

liquefaction plant will need to consider the international

financing guidelines outlined immediately above. Accordingly,

the need and applicability of Indonesian and international

financing requirements should be confirmed.

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IAENVIRONMENTAL REGULATORY ISSUESINDONESIAN REGULATIONS RELATED TO WATER SUPPLY, WATER TREATMENT AND WASTE WATER TREATMENT

• PERMENKES No. 416 Year 1990 regarding the Requirements

and Monitoring of Quality of Water.

• Regulation of Ministry of Environment No. 4 Year 2007 regarding

Waste Water Standard on Oil & Gas and Geothermal.

• Kep-112/MENLH/2003 regarding Standard for Domestic Waste-

Water.

• Kep-42/MENLH/10/1996 Decree of the State Minister for

Environment; Waste Water Standard in Geothermal/Oil and Gas

Activities.

• Kep-51/MENLH/10/1995 Decree of the State Minister for

Environment; Liquid Waste Standards for Industrial Activities.

• BAPEDAL No. 1Year 1995 regarding B3 Waste Handling

Requirement.

• KEPMEN No. 115 Year 2003 regarding the Standard of Water

Quality.

Enai

TERIMA KASIH