Environmental Management Plan

ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
Upgrading from 10,000 Population Equivalent (PE) to 30,000 Population Equivalent

(PE) Sewage Treatment Plant (STP) at Lot 229, Pantai Tengah, Langkawi, Kedah for
KytoWater Sdn. Bhd.
CHAPTER 9
ENVIRONMENTAL MANAGEMENT PLAN
(EMP)
9.0 Introduction
This chapter presents the Environmental Management Plan (EMP) which has been formulated for
the STP project to assist in the environmental management of the potential impacts identified in
Chapter 7, to ensure proper implementation of the project. Part of this chapter presents the
Emergency Response Plan (ERP), which provides procedures and actions to be taken in the event
of an emergency outbreak at the project site.
9.1 Environmental Management Plan

An EMP is recommended to be outlined in order to manage all the potential impacts identified in
the report. EMP is a practical tool for the implementation of mitigation and protective measures
identified in the EIA. The plan relates anticipated project activities to sensitive environmental
factors, outlining policies and procedures for the protection of the environment. The outcome will
minimize the risk of costly, time-consuming environmental issues, while maximizing productivity,
bottom-line performance and goodwill.
The main elements of the EMP are:
i. Environmental mainstreaming tools and Guided Self-Regulation (GSR) element;

ii. Legislative and contractual requirements and conditions that need to be observed and
complied with;
iii. An administrative setup (i.e. safety, health and environment unit) to be responsible for
environmental management with well-defined organization structure, manpower
requirements, and responsibilities of personnel;
iv. Environmental monitoring requirements and compliance requirements;
v. Monitoring programmes during operation phase (i.e. surface water, effluent, noise quality);
vi. Environmental records and reporting requirements;
vii. Key environmental management action plan for the protection of environmental
component identified; and
viii. Actions required and the reporting sequence for emergency responses during accidents or
abnormal operations of the plant.
9.1.1 Objective of the EMP

The environmental management objectives for the project is to provide a set of procedures to
protect and sustain the environmental qualities during the operational phase in compliance with
the relevant environmental quality standards and regulations stipulated by the DOE.
REPORT NO: AMR.2019.KWSB.EIA Chapter 9-Environmental Management Plan (EMP) l 9-1

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The environmental management shall be prepared to cover all aspects relevant to the operation
phases; environmental monitoring as well as auditing and implementation responses to identified
problems. Environmental monitoring aspects will basically include ambient air, effluent discharge,
and noise level during operation phases.
Thus, an Environmental Officer (EO) shall be positioned in the organization to oversee the
implementation of the mitigation measures and to liaise with relevant agencies pertaining to
matters related to the safety, health and environment.
The EMP shall serve as a reference document for environmental management by the Project
Proponent, Contractors and environmental Consultants undertaking the development of the project.
EMP is the key outcome of the EIA process which:
 Identifies potential impact areas of the project;

 Monitoring and auditing programme for the potential impacts framework; and
 Establishes reporting and mitigating (including emergency) response procedures.
9.1.2 Submission and Format of the EMP

During the post submission stage of EIA report, an EMP which translates the pollution prevention
and mitigation measures (P2M2) recommended in the EIA report and the Conditions of Approval
(COAs) into an action by the Project Proponent (i.e. KWSB), main contractor, and environmental
consultant (i.e. AMR) and shall be submitted to DOE state of Kedah for further evaluation.
The format of the EMP is as follows:
 Chapter 1: Introduction
 Chapter 2: Policy
 Chapter 3: Organizational Structure
 Chapter 4: Training Requirements
Provide information on:
a. Plan for staff training in order to develop competency t discharge responsibilities
on the environmental requirements and compliance. The training areas shall
include maintenance and performing monitoring of all Pollution Prevention and
Mitigating Measures (P2M2) wherever relevant.
 Chapter 5: Environmental Requirements

Provide information on:
a. EIA Conditions of Approval (COAs);
b. Land Disturbing Pollution Prevention and Mitigation Measures (LD-P2M2);
c. Pollution Prevention and Mitigation Measures (P2M2) to be implemented;
d. Water pollution control;
e. Control of air pollution and noise;

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f. Material and waste management;

g. Scheduled waste management;
h. Emergency response plan;
i. Abandonment and closure plan;
j. Mainstreaming tools and Guided Self-Regulation (GSR) element; and
k. Declaration and checklist.
9.1.3 List of Requirement for Environmental Compliance

The project proponent for this project shall ensure the project comply with all applicable laws,
regulations, guidelines and approval conditions issued by authorities for this project. The related
laws and regulations to be complied are as follows but not limited to:-
i. Environmental Quality Act 1974 (Act 127);

ii. Environmental Quality (Prescribed Activities) (Environmental Impact Assessment) Order,
2015;
iii. Environmental Quality (Scheduled Wastes) Regulations, 2005;
iv. Environmental Quality (Sewage) Regulations, 2009;
v. Environmental Quality (Licensing) Regulations, 1977;
vi. Local Government Act, 1976;
The relevant environmental under the implementation of this project are discussed in the following
sections. These requirements will form the basis for the implementation of the environmental
monitoring programme. In the event that local regulations and/or guidelines are not available for
certain environmental requirement, regulations and/or guidelines used in other develop countries
will be used as reference.
9.1.3.1 Ambient Air Quality

The relevant legislations and guidelines with respect to the management of air quality for plant
activities are as follows:
 Malaysia Ambient Air Quality Standard (MAAQS), 2015;

 Environmental Quality Act, 1974 (Section 22) – Restrictions on pollution of the atmosphere;
(22) Restrictions on pollution of the atmosphere

(1) No person shall, unless licensed, emit or discharge any environmentally hazardous
substances, pollutants or wastes into the atmosphere in contravention of the acceptable
conditions specified under section 21.
(2) Without limiting the generality of subsection (1), a person shall be deemed to emit or
discharge wastes into the atmosphere if -
a) He places any matter in a place where it may be released into the atmosphere;
b) He causes or permits the discharge of odours which by virtue of their nature,
concentration, volume or extent are obnoxious or offensive;

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c) He burns any wastes of the trade, process or industry; or

d) He uses any fuel burning equipment not equipped with any device or control equipment
required to be fitted to such equipment.
(3) Any person who contravenes subsection (1) shall be guilty of an offence and shall be liable
to a fine not exceeding one hundred thousand ringgit or to imprisonment for a period not
exceeding five years or to both and to further fine not exceeding one thousand ringgit a day
for every day that the offence is continued after a notice by the Director General requiring
him to cease the act specified therein has been served upon him.
9.1.3.2 Water Quality

The relevant legislations and guidelines with respect to the management of water quality for STP
 Environmental Quality (Sewage) Regulations, 2009;
 Environmental Quality Act, 1974 (Section 25) – Restrictions on pollution of inland waters;
and
(22) Restrictions on pollution of inland waters
(1) No person shall, unless licensed, emit or discharge any environmentally hazardous
substances, pollutants or wastes into any inland waters in contravention of the acceptable
conditions specified under section 21.
(2) Without limiting the generality of subsection (1), a person shall be deemed to emit or
discharge wastes into the atmosphere if -
a) He places any wastes in or on any waters or in place where it may gain access to any
waters;
b) He places any waste in a position where it falls, descend, drains, evaporates, is washed,
is blown or percolates or is likely to fall, descend, drain, evaporate or be washed, be
blown or percolated into any waters, or knowingly or through his negligence, whether
directly or indirectly, causes or permits any wastes to be placed in such a position; or
c) He causes the temperature of the receiving waters to be raised or lowered by more than
the prescribed limits.
exceeding five years or to both and to further fine not exceeding one thousand ringgit a day
for every day that the offence is continued after a notice by the Director General requiring
him to cease the act specified therein has been served upon him.
 Environmental Quality Act, 1974 (Section 29) – Prohibitions of discharge of waste into
Malaysian Waters; and
(29) Prohibition of discharge of wastes into Malaysian waters
(1) No person shall, unless licensed, discharge environmentally hazardous substances,
pollutants or wastes into the Malaysian waters in contravention of the acceptable conditions
specified under section 21.
to a fine not exceeding five hundred thousand ringgit or to imprisonment not exceeding five
years or to both.
 National Water Quality Standards (NWQS) for Malaysia.

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9.1.3.3 Noise Quality

The relevant legislations and guidelines with respect to the management of noise levels for plant
 The Planning Guidelines for Environmental Noise Limits and Control; and
 Environmental Quality Act, 1974 (Section 23) – Restrictions on noise pollution.
(23) Restriction on Noise Pollution
(1) No person shall, unless licensed, emit or cause or permit to be emitted any noise greater in
volume, intensity or quality in contravention of the acceptable conditions specified under
section 21.
exceeding five years or to both and to a further fine not exceeding five years or to both and
to a further fine not exceeding five hundred ringgit a day for every day that the offence is
continued after a notice by the Director General requiring him to cease the act specified
therein has been served upon him.
9.1.3.4 Solid Waste Management

Solid waste is an unwanted solid materials generated from industrial, commercial and domestic
activities. This unwanted need to have a systematic management collection, storage, treatment
and disposal. General waste is controlled under the Local Government Act 1976 and Refuse
Collection, Removal and Disposal By-Laws under the Act. These acts enable State Authorities to
prohibit disposition of waste in streams, watercourse and public drain. The by-laws specify that
commercial and industrial waste may be collected and disposed of on a fee basis prescribed by
local authorities. Ignoring the by-laws is an offence.
9.1.3.5 Scheduled Waste Management

The relevant legislations and guidelines with respect to the management of scheduled wastes (i.e.
sludge) for the STP activities are as follows:
 Environmental Quality Act, 1974 [Section 18(1)] – Prescribed Premises to be licensed;
(18) Prescribed premises to be licensed
(1) The Minister after consultation with the Council may by order prescribe the premises
(hereinafter referred to as prescribed premises) the occupation or use of which by any
person shall, unless he is holder of a licensed issued in respect of those premises, be an
offence under this Act.
(1A) The Minister, after consultation with the Council, may by order prescribe the vehicle or
ship used for the movement, transfer, placement or deposit of wastes (hereinafter referred
to as prescribed conveyance) the use of which by any person shall, unless he is the holder
of a licensed issued in respect of the prescribed conveyance, be an offence under this Act.
(2) The provisions of subsection (1) do not apply to a person:
a) Who, on the date of the coming into operation of this Act, is the occupier of prescribed
premises, and within the prescribed period after that date makes application for a
license in respect of those prescribed premises;
b) Who, where by virtue of any order made by the Minister from time to time amending

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any previously prescribed premises become prescribed premises, is, consequent upon
the order, the occupier of any prescribed premises, and who within the prescribed
period after the publication of the order in the Gazette makes application for a license
in respect of those prescribed premises;
c) Who has made application for the transfer to him of a license in respect of any
prescribed premises and made the application within the prescribed period after he
became the occupier of those prescribed premises, until his application has been finally
determined.
(3) Any person found guilty of an offence under subsection (1) or (1A) shall be liable to a fine
not exceeding fifty thousand ringgit or imprisonment for a period not exceeding two years or
to both and to a further fine of one thousand ringgit for every day that the offence is
continued after a notice by the Director General requiring him to cease the act specified has
been served upon him.
 Environmental Quality (Scheduled Wastes) Regulations, 2005;

 Environmental Quality Act, 1974 (Section 34B) – Prohibition against placing, deposit, etc.
of scheduled wastes;
(34B) Prohibition against placing, deposit, etc. of scheduled wastes
(1) No person shall-
a) Place, deposit or dispose of, or case or permit to place, deposit or dispose of, except at
prescribed premises only, any scheduled wastes on land or into Malaysian waters;
b) Receive or send, or cause or permit to be received or sent any scheduled wastes in or
out of Malaysia; or
c) Transit or cause or permit the transit of scheduled wastes, without any prior written
approval of the Director General.
(2) The Director General may grant the written approval either subject to conditions or
unconditionally.
(3) For the purpose of this Act, an act of receiving or sending, or transit of any scheduled
wastes with an approval obtained through falsification, misinterpretation or fraud or which
does not conform in a material way with the relevant documents in such form as may be
prescribed, shall be an offence.
 Environmental Quality (Scheduled Waste) Regulations, 2005 (Regulation 4) – Disposal of

scheduled wastes;
4. Disposal of scheduled wastes
(1) Scheduled wastes shall be disposed of at prescribed premises only.
(2) Scheduled wastes shall, as far as is practicable, be rendered innocuous prior to disposal.
 Environmental Quality (Scheduled Waste) Regulations, 2005 (Regulation 5) – Treatment of

scheduled wastes;
5. Treatment of scheduled wastes
(1) Scheduled wastes shall be treated at prescribed premises or at on-site treatment facilities
only.
(2) Residuals from treatment of scheduled wastes shall be treated or disposed of at prescribed
premises.

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 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 9) – Storage of

scheduled wastes;
9. Storage of scheduled wastes
(1) Scheduled wastes shall be stored in containers which are compatible with the scheduled
wastes to be stored, durable and which are able to prevent spillage or leakage of the
scheduled wastes into the environment.
(2) Incompatible scheduled wastes shall be stored in separate containers, and such containers
shall be placed in separate secondary containment areas.
(3) Containers containing scheduled wastes shall always be closed during storage except when
it is necessary to add or remove the scheduled wastes.
(4) Areas for the storage of the containers shall be designed, constructed and maintained
adequately in accordance with the guidelines prescribed by the Director General to prevent
spillage or leakage of scheduled wastes into the environment.
(5) Any person may store scheduled wastes generated by him for 180 days or less after its
generation provided that:-
a) The quantity of scheduled wastes accumulated on site shall not exceed 20 metric
tonnes; and
b) The Director General may at any time, direct the waste generator to send any
scheduled wastes for treatment, disposal or recovery of material or product from the
scheduled wastes up to such quantity as he deems necessary.
(6) A waste generator may apply to the Director General in writing to store more than 20 metric
tonnes of scheduled wastes.
(7) If the Director General is satisfied with the application made under sub regulation (6), the
Director General may grant a written approval either with or without conditions.
 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 10) – Labelling

of scheduled wastes;
10. Labelling of scheduled wastes
(1) The date when the scheduled wastes are first generated, name, address and telephone
number of the waste generator shall be clearly labelled on the containers that are used to
store the scheduled wastes.
(2) Containers of scheduled wastes shall be clearly labelled in accordance with the types
applicable to them as specified in the Third Schedule and marked with the scheduled waste
code as specified in the First Schedule for identification and warning purposes.
(3) No person allowed to alter the markings and labels mentioned in sub regulations (1) and (2)
 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 15) – Conduct of

training.
15. Conduct of training
Every waste generator shall ensure that all his employees involved in the identification,
handling, labelling, transportation, storage and spillage or discharge response of scheduled
wastes attend training programme.

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9.1.3.6 Environmental Auditing and Review

The general guideline for the EMP assigned the requirement for an environmental auditing focusing
on the implementation of the EMP and other environmental management elements in the
implementations of the project. The environmental audit will be conducted on an annual basis and
will undertake the following tasks:
i. Carry out environmental compliance audits;

ii. Verify implementation of corrective and preventive actions;
iii. Interpret audit findings; and
iv. Prepare a comprehensive environmental auditing report.
From the environmental auditing report, a management review should be conducted on an annual
basis. This practice is required to inspect the effectiveness and performance of the mitigation
measures and also to review the EMP and the monitoring and auditing programs if deemed
necessary.
9.1.3.7 Reporting
The following documents shall be made available to all parties involved in the Project
implementation for the records of environmental performance at the Project site throughout the
operational phase of the project.
i. Environmental Management Plan (EMP) Report;

ii. Environmental Monitoring Programme;
iii. Annual Environmental Monitoring Programme; and
iv. Environmental Audit Report.
9.2 Proposed Monitoring Programme

Monitoring Programme is an essential component in the overall EMP. It comprises of three (3)
types of monitoring i.e. Performance Monitoring (PM), Compliance Monitoring (CM) and Impact
Monitoring (IM). The monitoring programme will be periodically reviewed and revised by
accredited laboratory when necessary to take into consideration the changes made during project
development. KWSB will have the following facility to be built at the site in Pantai Tengah,
Langkawi. The proposed monitoring programme shall consider the facility during the operation
phase.
9.2.1 Performance Monitoring

Performance Monitoring (PM) is a proactive and preventive monitoring of processes to ensure the
Sewage Treatment System are optimally operated and maintained during the operation phase. PM
should be incorporated as a Standard Code of Practice (SOP) which must be implemented and
strictly enforced. The performance monitoring shall be conducted by KWSB in accordance to the
technical guidance published by the DOE as follow:

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i. Technical Guidance on Performance Monitoring of Industrial Effluent
Performance monitoring typically forms an integral part of preventive maintenance procedure

adopted in an industry to ensure smooth and uninterrupted operation of pollution control and
treatment system. Additionally, preventive maintenance helps detect early onset of deteriorating
performance of the control system hence avoids unnecessary plant shutdowns and costly
enforcement penalties. Preventive maintenance procedure can specify action levels at which
corrective actions are to be initiated.
9.2.1.1 Performance Monitoring of Sewage Treatment System

Monthly sampling and testing are recommended for major wastewater parameters i.e. Chemical
Oxygen Demand (COD), Biochemical Oxygen Demand (BOD) as well as Ammoniacal Nitrogen
(NH3-N). Daily attention is required on Dissolved oxygen in Aeration tank as it plays major roles in
providing the optimum condition for the processes. The overall performance monitoring plan for
the wastewater parameters are summarized in Table 9.1 below.
Table 9.1: Performance Monitoring Plan for Sewage Treatment Plant (Biological Treatment in
Aeration System)
Performance
Unit Operation or Parameter Sample Reference Monitoring
Monitoring
Process to Monitor Frequency Range Method
Control
Aeration and also MLSS Weekly 3000-4000 MLSS analysis Conduct MLSS
AO Tank mg/l analysis correctly.
(AMBBR)
SV Daily 15 – 40% Settleability If SV>40%,
Test (SV) increase wasting
sludge. If less than
SV<15%, reduce
wasting sludge.
DO Daily 2 – 6 mg/l Online sensor If DO reading is

below the target,
increase air flow of
blower.
Flowrate Daily Follow design Flowmeter Should be

2 peak flows
Clarifier TSS Weekly Below 50 TSS analysis If TSS> 50mg/l,

(both Intensive and mg/l allow bottom settled
Secondary) sludge to be
removed

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Additionally, system maintenance needs to be carried out on a regular basis in order to ensure
that the system is under control. Daily check, periodical mixer and motor greasing, pumps‟
performance checking, as well as DO probe cleaning are among the minor maintenances steps to
be taken to ensure that the system is in good condition.
9.2.2 Compliance Monitoring

Compliance monitoring (CM) will be conducted to ensure the emission and discharge from the
project complies with the local regulations and relevant standards. The objectives of the
compliance monitoring are as follow:
i. To provide a baseline to facilitate the identification of impacts due to the operational

activity;
ii. To provide an early indication that any of the environmental mitigation measures or
practices are failing to achieve expected performance; and
iii. To demonstrate environmental compliance to local environmental requirements.
The summary of the proposed compliance monitoring during construction and operation phase is
shown in Table 9.2 below.
Table 9.2: Summary of Proposed Compliance Monitoring

Number of Sampling
No. Monitoring Components Monitoring Stations
Stations Frequency
During Operation Phase
1. Ambient Air Quality 2 A1 and A2 Quarterly
2. Surface Water Quality 2 SW1 and SW2 Quarterly
3. Wastewater Quality 3 WW1, WW2 and WW3 Quarterly
4. Noise Quality 4 N1, N2, N3 and N4 Quarterly
The sampling locations, parameters to be measured, frequencies and duration of the monitoring as
well as the assessment criteria and reporting requirements are described in this sub-section. The
future monitoring location shall be based on the location identified during the baseline study as
shown in Table 9.3 and Figure 9.1 until 9.3. Meanwhile, Table 9.4 show the proposed
compliance monitoring programme for this project during construction and operation phase,
respectively but not limited to the proposed method.
Table 9.3: Location of Monitoring Stations

Station Coordinate Description
Ambient Air Quality
A1 Latitude: 6°16'40.84"N
Near guard house
Longitude: 99°44'7.40"E
A2 Latitude: 6°16'43.65"N Within the nearest residential area from the propose
Longitude: 99°44'8.04"E project site

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Table 9.3: Location of Monitoring Stations

Station Coordinate Description
Surface Water Quality
SW1 Latitude: 6°16'44.41"N Upstream from the confluence of sewer water and Sg.
Longitude: 99°44'7.59"E Tasek Anak
SW2 Latitude: 6°16'40.16"N Downstream from the confluence of sewer water and Sg.
Longitude: 99°44'2.87"E Tasek Anak
Wastewater Quality
WW1 Latitude: 6°16'43.31"N At the outlet of KytoWater's sewage treatment plant
Longitude: 99°44'7.95"E (upgrading plant)
WW2 Latitude: 6°16'42.99"N At the outlet of Indah Water's sewage treatment plant
Longitude: 99°44'9.30"E (existing plant)
WW3 Latitude: 6°16'43.12"N At the mixing point of KytoWater and Indah Water
Longitude: 99°44'8.22"E sewage treatment plant
Noise Quality
N1 Latitude: 6°16'40.58"N
Near guard house
Longitude: 99°44'7.98"E Near blower room
Near dryer area
Near water treatment

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Table 9.4: Proposed Compliance Monitoring (CM) Programme During Operation Phase
Environmental Frequency/ Monitoring Recommended
No. Compliance Parameters Methods
Component Year Location Limit
1. OPERATION PHASE
1.1 Ambient Air Quality Malaysia Ambient Air Quarterly A1 Particulate Matter < 100@24-hrs Method IO-2.2
Quality Standard, A2 10µm (PM10)
2015 Particulate Matter < 35@24-hrs Method IO-2.2
2.5µm (PM2.5)
Sulphur Dioxide 250@1-hr ISC 704C
Nitrogen Dioxide 280@1-hr ISC 406
Ozone (O3) 180@1-hr ISC 411
Carbon Monoxide 30@1-hr In house method AMR-AA01
Manufacturer‟s Measurement
Procedures (Dräger)
1.2 Surface Water Class III of National Quarterly SW1 Ammoniacal Nitrogen 0.9 APHA 4500 NH3-C
Water Quality SW2 Biochemical Oxygen 6.0 APHA 5210 B
Standard (NWQS) Demand (BOD)
Chemical Oxygen 50.0 APHA 5220 C
Demand (COD)
Dissolve Oxygen (DO) 3.0-5.0 APHA 4500 O- G
pH 5.0-9.0 APHA 4500 H+ B
Total Suspended Solid 150.0 APHA 2540 D
Temperature Normal +2°C APHA 4500 H+ B
Total Coliform 50,000 APHA 9221 F
Iron 1.0 APHA 3111 B
Manganese 0.1 APHA 3111 B
Oil & Grease N APHA 5520 B

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Table 9.4: Proposed Compliance Monitoring (CM) Programme During Operation Phase
Environmental Frequency/ Monitoring Recommended
No. Compliance Parameters Methods
Component Year Location Limit
1.3 Wastewater Quality Standard A, Quarterly WW1 Temperature 40 APHA 4500-H*B
Environmental Quality WW2 pH value 6.0 – 9.0 APHA 4500-H*B
(Sewage) WW3 BOD5 at 20°C 20 APHA 5120 B
Regulations, 2009 COD 120 APHA 5220 C
Suspended Solids 50 APHA 2540 D
Oil and Grease 50 APHA 5220 B
Ammoniacal Nitrogen 10 *HACH 8155
Nitrate – Nitrogen 20 APHA 4500-NO3
1.4 Noise Quality The Planning Quarterly N1 LAeq, Lmax, Lmin ≤65 dBA
Guidelines for N2 (day time)
Environmental Noise N3 ≤55 dBA BS 4142:1997
Limits and Control, N4 (night time)
Second Edition, 2007

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SW
1 LEGEND
Site Boundary
WW1
WW2
Site Boundary
WW3
Sg. Tasek Anak
SW2
Scale: 1:20
Confluence
60 m
Source: Google Earth

Figure 9.1: Location for Water Quality and Wastewater Monitoring Stations

Upgrading from 10,000 Population Equivalent (PE) to 30,000 Population Equivalent (PE) Sewage Treatment Plant (STP) at Lot 229, Pantai
Tengah, Langkawi, Kedah for KytoWater Sdn. Bhd.
LEGEND
Site Boundary Site Boundary
A1 Residential
Area
Scale: 1:30
90 m
A2

Figure 9.2: Location for Air Quality Monitoring Stations

Upgrading from 10,000 Population Equivalent (PE) to 30,000 Population Equivalent (PE) Sewage Treatment Plant (STP) at Lot 229, Pantai
Tengah, Langkawi, Kedah for KytoWater Sdn. Bhd.
N2 Site Boundary LEGEND

N3
Site Boundary
N1
Scale: 1:20
60 m
N4

Figure 9.3: Location for Noise Quality Monitoring Stations

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9.2.3 Impact Monitoring

Impact monitoring (IM) will be only conducted to monitor the impact from final discharge of STP
towards the nearby sensitive receptors on a case to case basis when required. This is because the
P2M2 is clearly identified and operation procedures are adequate.
9.3 Environmental Auditing

The audit report will be submitted on an annual basis to DOE during the operational phases to
evaluate the degree of compliance with the regulatory environmental requirements. It shall be
carried out by DOE registered Environmental Auditor. The proposed environmental auditing for this
project is shown in Table 9.5. The audit report should include the following:
i. Compliance with all monitoring requirements imposed by DOE;

ii. Compliance with all the standards, criteria and guidelines as imposed by DOE and other
authorities;
iii. Compliance with all the proposed plans submitted to relevant Government Departments;
iv. Compliance with mitigation measures; and
v. Compliance with any other conditions imposed by the government.
Table 9.5: The Proposed Environmental Audit

Regulation Phase Frequency Reference Certified Person
Section 33A, Operational Phase Yearly Environmental DOE Registered
Environmental Audit Guidance Auditor
Quality Act, 1974 Manual, 2011
(Act 127)
9.4 Mainstreaming of Environmental Agenda and Self-Regulation Culture

Self-regulation has been adopted by the DOE as a long-term goal to be achieved and a culture to
be inculcated within the regulated sectors through mainstreaming of environmental agenda.
Environmental mainstreaming has been integrated into all the recent regulations of the DOE. The
implementation of environmental mainstreaming to promote and instil self-regulations in industrial
pollution control has been translated into regulatory requirements on performance monitoring of
pollution control measures, scheduled reporting, record keeping, competent persons and
involvement of environmental professionals playing specific roles. This optimal operation of
pollution control systems, systematic management of performance monitoring data and improved
regulatory compliance on a sustained basis. On a wider perspective, self-regulation which
complements the existing command and control approach of the DOE, would result in cultivating
environmental ownership and excellence in environmental commitment from the regulated sectors.
9.4.1 General Considerations

Legal responsibility rests on the shoulders of the project proponent who shall be totally committed
towards ensuring regulatory compliance of the project with the EIA procedure at all stages of
project planning and implementation. The project proponent is the key driver for ensuring the

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success self-regulation approach in environmental management through the mainstreaming of

environmental agenda throughout the project implementation phases. The project proponent shall
ensure top-down organizational commitment to environmental regulatory compliance to all
personnel, at all levels of the organization, including the registered EIA consultant, the
Environmental Officer (EO), the contractors and other parties involved in the project
implementation.
9.4.2 Roles and Core Duties of Different Players in EIA Project Implementation
9.4.2.1 Project Proponent
The project proponent (PP) is not only legally responsible for ensuring regulatory compliance, but
is the driver for mainstreaming the environmental agenda in all stages of project implementation.
The major roles and responsibilities of the PP include the following:
i. Formulating an Environmental Policy (EP) of the company with respect to the EIA project,
which shall be communicated to the stakeholders, consultants, contractors and other
parties involved in the project planning and implementation.
ii. Establishing an organizational structure which clearly shows the emplacement of a
Registered EIA Consultant and an Environmental Officer (EO), where they are charged with
specific responsibilities to ensure environmental aspects are taken into consideration and
pollution prevention and mitigation measures (P2M2) are integrated into every stage of
project planning and implementation.
iii. Allocating sufficient funds for all steps in the EIA process and every stage of project
planning and implementation with itemized budget required for water quality monitoring,
air quality and noise monitoring, for comprehensive site survey and investigation of the
specific existing site conditions, for implementation of Environmental Management Plan
(EMP) including temporary pollution prevention and mitigation measures (P2M2). P2M2
shall be those which can be described as state of the art technologies, best available
technologies (BATs), or industry best practices.
iv. Appointing an EO, at the stage of post submission of EIA Report to be charged with
responsibilities to execute environmental quality control and performance monitoring
functions during the operation phases of the project implementation. Service of an EO can
also be obtained from an Environmental Officer Service Provider, Service of EO from EO
service provider is allowed during construction stage only. However, at the operational
stage, PP shall employ his own EO.
v. Setting up a “mini laboratory”, wherever appropriate, to facilitate the implementation of
environmental performance monitoring program. This mini laboratory shall be adequately
equipped with relevant resources including staff and portable analytical testing equipment.
vi. Ensuring the EMP including temporary and permanent P2M2 are implemented and
maintained according to industry‟s best practices.

KytoWater Sdn. Bhd.
9.4.2.2 Environmental Consultant

The registered EIA Consultant is the key person who is entrusted with the responsibilities for
ensuring environmental impacts from a project are correctly identified, assessed, and mitigated.
The roles and core duties of the EIA Consultant include the following:
i. Preparing the Terms of Reference (TOR) for EIA study of a project proposal;
ii. Performing quality control (QC) to ensure the quality of EIA report meets the requirements
of DOE and hence, is fit for submission;
iii. Preparing and defending the EIA report of a project;
iv. Setting up Public Display and Engagement Meetings; and
v. Preparing the Environmental Management Plan (EMP).
9.4.2.3 Environmental Officer

The EO is the main project personnel responsible for ensuring regulatory compliance at the project
implementation stage (post submission of EIA report). The roles and core duties of the EO include
the following:
i. Implementing the EMP, and installing the temporary and permanent P2M2.
ii. Preparing Environmental Performance Monitoring Document (EPMD). EPMD describes in
detail how EIA approval conditions are going to be complied and how performance
monitoring of the various P2M2 will be conducted to ensure the optimal functionality of the
P2M2 is maintained. The details shall include, among others: performance monitoring
equipment/instruments, sampling protocols and analysis, monitoring parameters, sampling
frequency, preventive and corrective maintenance procedure for the P2M2, discharge
compliance, record keeping, etc. EPMD also includes CM and IM wherever relevant.
iii. Performing or supervising the conduct of PM program as specified in EPMD.
iv. Preparing Performance Monitoring Report (PMR). PMR discusses the results of the PM
conducted as described in the EPMD. Wherever relevant, PMR shall include data
interpretation and assessment of the effectiveness of the P2M2 by making comparison of
the PM parameters with their recommended ranges (or standards). Statistical techniques
and graphical presentation of the PM parameters should be used wherever appropriate.
PMR shall also make some definitive conclusions on the overall performance of the P2M2
and suggest improvement measures to be taken if necessary. PMR shall be submitted to
the Environmental Performance Monitoring Committee (EPMC) as established by the PP for
the EIA project and maintained for the inspection of the DOE officers.
v. Communicating the status of environmental regulatory compliance of the project during
operation phases to the PP.
vi. Maintaining a detailed record of major upset conditions encountered, if any, for the
duration of the project construction and operation phases. The date of occurrence, nature
and causes of upset conditions, and the corrective actions taken shall be recorded. Upset
conditions refer to failures of P2M2 which result in non-compliance with the EIA approval

KytoWater Sdn. Bhd.
conditions or discharge/emission standards, or pollution that affects the immediate

neighbourhood or seriously threaten the environment or public health and safety.
vii. Acting as an environmental advisor to the PP in advising him to undertake additional
efforts, if any, to further ensure effective implementation EMP including temporary P2M2
on a sustained basis.
9.4.3 Mainstreaming Tools or Elements

Environmental Mainstreaming refers to the integration of environmental concerns, aspects and
considerations in all business processes, at all stages of decision making, at all levels of
organizational hierarchy, and at all phases of the operation of the STP. In order to facilitate the
compliance of EIA conditions, all aspects of environmental mainstreaming tools as per Appendix
9.A shall be implemented without fail.
With a lofty goal to develop an industrial society and those involved in development projects that
have an intrinsic culture of pride in environmental excellence (EE), the DOE has embarked on a
program entitled “Guided Self-Regulation”. To assist the regulated community to achieve the state
of self-regulation, the DOE has formulated in the organizations and industrial premises. The
Environmental Mainstreaming Tools (EM Tools) include:
i. Environmental Policy (EP);

ii. Environmental Budgeting (EB);
iii. Environmental Monitoring Committee (EMC);
iv. Environmental Facility (EF);
v. Environmental Competency (EC);
vi. Environmental Reporting and Communication (ERC); and
vii. Environmental Transparency (ET).
The EM tools are briefly explained in the following sections.
9.4.3.1 Environmental Policy (EP)

The EP of successful organizations (i.e. KWSB) uses strong and unequivocal statements to convey
their environmental commitment to their employees, clients, stakeholders and the public. The EP is
disseminated to all relevant parties and translated into action in the organization‟s work
procedures, materials purchasing policy, business decision making process and cascades down to
the supply chain.
9.4.3.2 Environmental Budgeting (EB)

Sufficient budget must be set aside solely for the purpose of taking measures to comply with the
environmental regulatory requirement and other environmental-related efforts.

KytoWater Sdn. Bhd.
9.4.3.3 Environmental Monitoring Committee (EMC)

The success of an organization to comply with the environmental requirement is contingent upon
the relevant personnel in different departments in the organization playing their role in an effective
manner. To promote collective responsibility to be environmentally compliant, two (2) monitoring
committees are set up: one (1) at the working level, the other at the policy level. At the working
level, the committee known as the Environmental Performance Monitoring Committee (EPMC) is
chaired by a senior official of the organization and it meets on a monthly basis, or at a minimum,
once in a quarter. At the policy level, the committee is known as the Environmental regulatory
Compliance monitoring Committee (ERCMC), which meets at a minimum, once a year. The chief
executive officer or chairman of the organization chars the ERCMC.
9.4.3.4 Environmental Facility (EF)

The primary components of the EF include sewage treatment system and associated support
facilities such as laboratory, performance monitoring equipment, on-line instrumentation system
and waste management infrastructure shall be implemented for the project. The above form an
integral part of the company‟s overall infrastructural planning, which cannot be compromised.
9.4.3.5 Environmental Competency (EC)

The relevant personnel involved in discharging various environmental responsibilities within an
organization need to possess the required competencies. The personnel include those who have
been assigned the task to perform DOE-regulated functions: to manage waste and supervise the
operation of best management practices and sewage treatment system. The organization must
draw up a comprehensive training program to produce competent persons and trained support
staff to ensure full compliance with the DOE requirements in the regulated activities.
A competent person or certified environmental professional is a person who has been certified by
the Director General of the DOE to be competent to supervise the operation of the sewage
treatment system. The individual needs to go through the certification process and comply with all
the requirements before he/she can be certified competent. KWSB shall ensure the personnel
to be certified as a competent person in each respective field.
KWSB had appointed two (2) competent persons to supervise the operation of the upgraded STP
on a full-time basis. The details of the competent persons are listed in Table 9.6.
Table 9.6: List of KytoWater Sdn. Bhd. Competent Person

No. Name Field Validity
1. Muhammad Bin Ajmi Certified Environmental Professional in Sewage 21/02/2018-
Treatment Plant Operation (CePSTPO) 21/02/2019
2. Mohd Hazrul Aizat Bin Zulkepli Certified Environmental Professional in Sewage 21/02/2018-
Treatment Plant Operation (CePSTPO) 21/02/2019

KytoWater Sdn. Bhd.
9.4.3.6 Environmental Reporting and Communication (ERC)

A formal communication channel for KWSB shall be established for reporting environmental
concerns and system upsets which warrant prompt actions to be instituted. Internal reporting can
be initiated to report on a regular basis the regulatory compliance status of the organization to the
Chief Executive Officer (CEO) and various heads of the department within the organization.
Updates of new environmental requirements and their implication can be disseminated to the
relevant company personnel. ERC requires systematic analysis of PM data, which must be
summarized in appropriate format for easy understanding and communication and maintained for
management review purposes.
9.4.3.7 Environmental Transparency (ET)

To foster rapport with the immediate neighbours, promote green image, and improve public
confidence, companies are encouraged to be more transparent in their environmental compliance
and achievement. Compliance status can be displayed on company website or billboard located at
the boundary or entrance to the company‟s premise, or communicated to the immediate
neighbours through issuance of fliers on a scheduled basis.
An Environmental Sustainability report (ESR) can be prepared for the company to showcase its
success in managing the environmental concerns of the company and minimizing the
environmental footprint of its business. The corporate image of the organization is markedly
enhanced through environmental transparency. Therefore, the public can access the information
related to environmental matters through the website, yearly environmental sustainability report
and etc.
9.5 Emergency Response Plan (ERP) in Operation of STP

9.5.1 Introduction
The Emergency Response Plan (ERP) is prepared to respond rapidly to an emergency situation
impacting the STP; the major objectives are:
1. Prevent possible financial losses resulting from a damaged STP or equipment/facility

affected by any form of accident/incident;
2. Ensure the safety of the workers / operators in charge of the STP operations.
The STP emergency response plan details the procedures to be followed in case of emergency. The
analysis of the potential emergency situations will also help to take measure to prevent these
incidents to happen. The ERP is therefore a comprehensive action plan with formalised procedures
to respond to any emergencies.

KytoWater Sdn. Bhd.
9.5.2 Causes of Emergencies

Causes of emergencies may include the followings:
 Natural disasters
 Faulty maintenance
 Negligent operation and accidents
A discussion of each cause and its relationship to the operation of a sewage treatment facility is
included in the section.
9.5.2.1 Natural Disasters

Natural disasters which are most likely to affect the operation of the sewage treatment facility to
the extent of reducing the efficiency of the plant can be associated with one of the following:
 Flood
 Earthquake
 Tsunami
 Fire
The treatment plant should be prepared to ensure continued operation under emergency
conditions imposed on that system by the disaster
9.5.2.2 Faulty Maintenance

Equipment must be maintained or it will cease to perform the task efficiently. The manner in
which the equipment is maintained will generally determine how well it will perform its intended
function and for how long. Good maintenance will result in equipment performing throughout its
design period; however, poor maintenance or faulty maintenance will shorten the expected life of
equipment.
Unexpected breakdown due to faulty maintenance can greatly affect the continued operation of a
sewage treatment plant. Although the breakdown can possibly be repaired during a regularly
scheduled repair program and probably does not represent an emergency, it is the effect on the
continued satisfactory operation of the plant that can lead to the emergency condition.
9.5.2.3 Negligent Operation

All operations, regardless of application, large or small, require certain procedures to be followed
for satisfactory performance. To improperly follow established procedures constitutes negligent
operation.
Negligent operation may not be as readily noticeable as faulty maintenance, but the emergency
condition resulting from it could possibly be more severe because negligent operation could effect
more units of operation before being discovered.

KytoWater Sdn. Bhd.
It is therefore imperative that sound operating procedure be developed and maintained to ensure
the satifactory operation of the sewage treatment plant. It is also important to have a competent
personnel to run and monitor the plant.
9.5.2.4 Accidents
Accidents result in personal injury and property damage, both of which have a direct bearing on a
plant‟s operation.
9.5.3 Effects of Emergencies

The following events are the effects related to causes of emergencies in STP:
 Power failures
 Fires
 Hydraulic overloading, ruptures and sewer blockages
 Sewer overflows
 Intentional or accidental release of chemical substances
 Construction accidents
 Equipment failure
 Process upsets
 Personnel injury
a. Power failure – Power failures may be caused by an interruption of service originating at

the power utility company; storm damage and/or vehicle accidents resulting in downed power
lines; vandalism; or equipment malfunction at the wastewater treatment facility or remote pump
stations. To ensure the reliability of back-up power, the following items should be done: perform
regular preventative maintenance on the generator unit; regularly exercise generators under
load; always ensure an adequate supply of fuel is on hand (this applies to portable generators as
well); ensure all generator related alarms are functioning.
b. Hydraulic overloading – Hydraulic overloading is considered as any amount of flow that

exceeds the design capacity of the plant to effectively treat that amount of flow. Hydraulic
overloading is most often associated with storm events. Hydraulic overloading can have many
serious consequences: decreased plant performance; short term and/or long term effluent
quality violations; mechanical breakdowns; overflows; and grit and sludge accumulation from the
scouring of sewer lines.
c. Blockages, ruptures, overflows and construction accidents – Blockages and ruptures

could occur at any time. A blockage is typically caused by grease build-up or root penetration
resulting in an interruption of flow, often resulting in an overflow from a manhole or within a
business or residential basement. A blockage may also be caused by an object making its way
into the sewer system and lodging within a pipeline. Physical settlement of the pipeline can cause
a misalignment of joints, resulting in a blockage. Sand or sludge accumulation can form an

KytoWater Sdn. Bhd.
impenetrable blockage in slow moving areas of the sewer system. Overflows can occur at pump
stations or low lying manholes due to the failure of the pumping system or being overwhelmed by
rainfall.
d. Equipment failure - Wastewater treatment plant environments are subject to moisture,

corrosion, dust, gases, heat and chemicals. Equipment can and will break down. Developing and
practicing a sound maintenance program will ensure the reliability of critical equipment. A reactive
or corrective maintenance program, on the other hand, is basically a “run it until it breaks”
philosophy. This approach can lead to serious equipment failure at the worst possible time, often
resulting in process failure, permit violations or environmental disaster such as sewer overflows.
e. Process upsets - Most treatment plants are biological in nature and thus depend upon
the activity of bacteria to treat the wastewater. Since they are living organisms, their survival and
health are subject to environmental conditions. Toxic chemicals, extreme pH swings, high
strength wastes, inadequate aeration and equipment malfunction can all have a detrimental effect
on these organisms. All of these situations can lead to a process upset and adversely effect
effluent quality.
9.5.4 Emergency Action Procedure

The overall purpose of an Emergency Response Plan (ERP) is to provide a wastewater system with
a standardized response and recovery protocol to prevent, minimize, and mitigate injury and
damage resulting from emergencies or disasters. The ERP also provides a description of how a
wastewater system will respond to potential threats, as well as additional emergency response
situations. Specific Action Plans (APs) should also be included in the ERP, which will be used to
respond to events and incidents.
1. Before beginning any emergency planning, wastewater system managers would be well
advised to be familiar with local, state, and federal regulations that may affect the
system‟s emergency planning program.
2. The goals of an Emergency Response Plan are to document and understand the steps
needed to
 Rapidly restore wastewater service after an emergency.
 Minimize wastewater system damage
 Minimize impact and loss to customers
 Minimize negative impacts on public health and employee safety
 Minimize adverse effects on the environment
 Provide emergency public information concerning customer service
 Provide wastewater system information for first responders
 Ensure effective communication between all those involved

KytoWater Sdn. Bhd.
3. In Emergency situation:
 ERP tells how to report the incident and to notify it to the responsible authorities;
 Measures taken to prevent or minimize the recurrence of incidents.
 Update the ETP emergency response plan: contact list to be updated yearly (or as
soon as there is a change in the contact information) at least and overall document
to be reviewed if there is any change in the ETP.
 Practice the ETP emergency response; an ETP emergency response drill should be
conducted once a year.
4. As part of ERP procedures, it is necessary to provide essential maps and plans of the entire
treatment plant grounds in a secure location and keep back-up copies of sensitive
documents in an off-site secure location.
5. Establish a Chain of Command Structure having clear lines of authority and the
delegation of responsibilities will help to avoid confusion when an incident occurs.
6. Designate one person to be at the top of the chain of command.

 Usually the plant supervisor or Chief Operator.
 This person will manage the emergency, make the decisions and ensure that the
appropriate people are contacted.
 This person should be reachable and able to respond at any time. If not, a back-
up person should be designated in their absence.
 Designate other responsible people to be in the chain of command and be very
specific as to their assigned duties.
 In the event that the top person will be unavailable for any length of time,
someone else should be designated during his/her absence.
 Emergency contact list should be posted at every phone location
7. Develop an evacuation plan for STP facility and post the procedures in highly visible places.
The conditions under which an evacuation would be necessary should be determined.
8. Emergency Response Procedures for Specific Events will have its own specific action plan,
depending upon the severity and its potential impact.
The following are some examples of response issues for events that may occur:
9.5.4.1 Natural Disaster (Flood)

Natural disaster such as flood, earthquake or tsunami may potentially occur at the STP area It is
noted that such emergencies usually develop gradually and there is usually adequate time to
respond in order to prevent the condition from worsening.

KytoWater Sdn. Bhd.
1. First Responder Actions

When personnel gauge that there is a potential for the site to be adversely affected by natural
disasters, the following procedures should be adopted:
 Assess the condition of the site;
 Raise concerns with Incident Leader; and
 Wait for further instruction from Incident Leader.
2. Emergency Response Team (ERT)

The Incident Leader shall take the following steps:
 Assess the situation and decide if the situation warrants activation of the ERP;
 Instruct ERT members to perform specific tasks such as constructing a dike around low
areas, etc. as required; and
 Instruct the necessary call out if assistance from external emergency services is required.
9.5.4.2 Fire Hazards

1. Before the Emergency
Know the location of the nearest Fire Department and know how to contact them.
Know the nearest water sources.
2. Identify the Emergency

Workers at site must act as an observer to detect any occurrence of fire episodes. Alert all workers
when someone actually sees smoke of fire. Operation Commander should be notified immediately
so that the Fire Department can be called.
3. Take appropriate action

The affected area must be evacuated immediately.
Should you decide to fight a small fire yourself (Using Fire Extinguisher), be sure to aim the charge
of the extinguisher at the base of the fire.
4. Caution!!! Never use water fire extinguisher on an electrical fire.

Any damage or injuries should be reported to the command post. Other necessary action will be
determined by the Operation Commander or his deputy.
A supervisor will be responsible for securing sensitive items or materials. A separate manual list of
materials should be taken into consideration. These lists will be made available to the fire
department and others as necessary.
Do not re-enter the site until instructed to do so. In case of any injuries, arrange for medical
facilities including place for treatment or causalities.

KytoWater Sdn. Bhd.
5. End of Crisis
Designated officers will develop a follow-up plan for each type of crises and hold a debriefing to
discuss problems or improvement action plans. Written documentation of the particular crisis will
be prepared for future use.
Ensure that accurate log of events is kept and that evidence and records are preserved for use in
investigations.

KytoWater Sdn. Bhd.
Fire Discovered
Alarm Raised
Communicate Fire Fighting Team
Put out fire using fire Put out fire using fire
extinguisher extinguisher
Area Evacuated if fire Communicate

unable to be contained/
Extinguished
Discuss with PM on
next course of action Project Manager
Call for emergency Decide if evacuation

service (fire station) is necessary
If evacuation is Give Evacuation

necessary, ensure instruction
personnel are
evacuated
Liaise with Bomba
Arrange for foods and Arrange for Medical

drinks facilities
Submit written
report to authority
Figure 9.4: Emergency Response Procedure Flow Chart-Fire

KytoWater Sdn. Bhd.
9.5.4.3 Sewage Overflow

Failure at any point within the sanitary sewer system can cause sewage to overflow onto public
and/or private property and/or waterways, thereby increasing the risk of a possible public health
hazard and contamination of the environment.
The first crew responding to a sewer overflow must protect public health and the environment
from the effects of the spilled sewage. The ERT shall be notified immediately.
1. Take appropriate action

The site personnel will investigate every reported sewer overflow.
Visual Inspection
1) Unusual Discharge
If the sewage discharge has an unusual colour or odour, the site personnel should contact the Fire
Department to alert them of the condition and await their instruction. The site personnel should
also contact the Plant Manager to have a sample taken.
2) No Obvious Sewage Spill

The site personnel will do a visual inspection of the site and the upstream manholes to determine
the nature and potential cause of the problem. The site personnel will contact the reporting party
to obtain further information if necessary. If the problem is not sewer related, the site
investigation information will be sent to the Public Work Department to redirect to the appropriate
personnel.
3) Obvious Spill
In the case of an obvious sewage spill, the site personnel will follow the Sewage Overflow
Response Procedures.
2. End of Crisis
The emergency will be considered over when determined by the proper authorities.

KytoWater Sdn. Bhd.
Site Personnel
Stop the sewage overflow /
plant operation
Communicate Plant Manager
Call for external assist if

Contain the spillage sewage required
Contain / Capture the sewage
Conduct the investigation and

fix the breakdown, Plant only
allowed continuing the
operations once the
breakdown being fixed
Report to DOE Compliance to

EQA 1974
Figure 9.5: Emergency Response Procedure Flow Chart – Emergency Overflow

KytoWater Sdn. Bhd.
9.5.4.4 Power Failure

There is a potential for power failure due to unforeseen circumstances. Power failure can interrupt
the entire STP operation, which is currently running 24 hours a day. The generator can only
support the operation at the treatment plant for two hours after power failure.
1. First Responder Actions

In the event of power failure, the first responder shall adopt the following procedures:
 Notify the situation to the immediate supervisor and/or Incident Leader; and
 Wait for further instruction from Incident Leader.
2. Emergency Response Team (ERT)

The Incident Leader shall adopt the following procedures:
 Assess the situation and determine whether it is internal or external power supply
interruption;
 If it is internal interruption, notify the person in charge to evaluate the situation; and
 If it is due to external appropriate authority for further information e.g. Tenaga Nasional
Berhad (TNB) for power supply interruption.
9.5.4.5 Breakdown of Plant Facility

When plant breakdown is detected at the STP, the following steps should be taken:
 If plant breakdown is detected, the operator at the raw sewage pumping station (RSPS)
should immediately shut down the raw water intake pump sets to prevent additional flow
of raw water into the STP.
 The operator to immediately switch-on the „stand-by‟ power generators to allow continuous
treatment of the sewage and sludge.
 Once the power supply resumes, the plant operator should restart the treatment process in
the correct sequence to prevent the production of treated water that do not comply with
the desired treated water quality standards.
 The person who discovers the plant failure must inform the incident to the Plant
Emergency Management Officer immediately.

KytoWater Sdn. Bhd.
9.6 Protection Measures

This section gives several measures required to protect sewage treatment facilities from
emergencies.
9.6.1 Warning Devices

A sewage treatment plant requires a warning system to warn the man on duty of impending or
existing emergencies.
For example, the SCADA system quickly notifies an operator that a batch of product is showing a
high incidence of errors. The operator pauses the operation and views the SCADA system data via
an HMI to determine the cause of the issue. The operator reviews the data and discovers that
certain equipment was malfunctioning. The SCADA system‟s ability to notify the operator of an
issue helps him to resolve it and prevent further loss of product.
There are also other types of warning devices available, but generally they can be classified as
follows:
1. Alarms- which may be audio visual

2. Indicating Lights-tell the operator which equipment is required to run, equipment running,
power on and off, etc
3. Indicators – mechanical (gauge), electrical (counters, indicators, recorders) or electro-
mechanical (flow and/or pressure recorders).
9.6.2 Standby or Duplicate Facilities

Standby facilities refer to equipment installed for use when the primary equipment fails. It is a
substitute piece of equipment. A diesel generator is an example of a standby emergency source of
electrical power should the primary source fail.
Duplicate facilities refer to repetition of installation of equipment such as: two screens, two
clarifiers, two digester, two chlorinators etc. In the case of duplicate facilities, both are generally
in use at all times. In some instances, such as the grit removal equipment, the unit is used
alternately.
The necessity of having standby equipment is quite obvious. Since an entire plant‟s operation is
wholly dependent upon electrical power, a standby source would be required should the primary
source fail- that is, if the function of the sewage treatment plant is to remain unaltered. It is
necessary for the assurance of continued plant operation such as an aerator, blower, pump,
clarifier mechanism etc break down. Under this condition, the flow can be channelled through the
duplicate facility with little loss of treatment efficiency.

KytoWater Sdn. Bhd.
9.6.3 Adequate Preventive Maintenance

Always maintain good records on all equipment purchased. Such things as date of purchase,
equipment manufacturer, local service representative‟s name and phone number, instruction
manuals, service instructions, etc. should be filed on each piece of equipment for handy reference.
All preventive maintenance performed by waste treatment plant personnel should always be done
in accordance with equipment manufacturer‟s recommendations.
Detailed ERP Action Plans need to be established for the STP, and staff training on ERP must be
executed formally. The ERP should be updated from time to time as may be required and form
part of the EMP document
Table 9.7: Example of A typical Emergency Response for a Sewage Treatment System
No. Treatment Emergency Response
System
Category
1. Pumping Station Equipment failure  Analyse situation to determine proper course
of action.
 Implement preventive measures as required.
 Dispatch a pretrained crew properly equipped
 Provide portable lighting if at night.
 Pump flow around trouble area utilizing
portable pumps.
Equipment failure  Check spare parts inventory
 Use original equipment quality replacement
parts.
 Always use appropriate lifting and hoist
equipment.
 Check impellers for blockage
 Check for bearing seizure due to overheating
or insufficient lubrication.
 Check for loose couplings
 Always lubricate before start.
Power Loss  Determine if the power loss is local or area-
wide.
 If loss is local, check out all electrical circuits
for shorts or system overloaded.
 If the loss is area-wide, contact the power
supplier and coordinate repair and start-up
operations with them.
Explosions  Determine immediately the cause of explosion
and take action to prevent additional
explosion.
 Notify the police and fire department.
2. Pre-treatment Clogged Screens  Bypass the units until the units are operating
again.

KytoWater Sdn. Bhd.
Table 9.7: Example of A typical Emergency Response for a Sewage Treatment System
No. Treatment Emergency Response
System
Category
 Check cutler for dull blades and replace as
required.
 Check the capacity to be certain units are not
hydraulically overloaded.
 Manually keep the screen clean until problem
is corrected.
3. Primary Stoppage of sludge collection  Analyse the situation to determine if repair
Treatment mechanism can be made without draining the tank.
 Check to see if there is any debris entwined
around the sludge collector machine.
 Check tank bottom for excessive deposits of
sand, rock and other inorganic material.
 Stir media manually to lessen or remove
accumulations.
 If applicable, check all drives, chains and
sprockets for malfunction.
 Check out the electrical circuit for shorts and
system overloaded.
4. Secondary Rapid sludge removal system  Analyse the situation to determine if repair
Treatment malfunctions can be made without draining the tank.
 Open and adjust all suction ports to obtain
optimum sludge removal.
 Backwash system to eliminate clogged
condition.
Clogged diffuser tubes or  Replace the clogged unit as soon as possible.
clogged sprayer in aeration  Clean the clogged unit immediately upon
equipment removal.
 Check air lines for dirt and trapped water.
Source: USEPA

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ENVIRONMENTAL IMPACT ASSESSMENT (EIA)

Upgrading from 10,000 Population Equivalent (PE) to 30,000 Population Equivalent

9.1 Environmental Management Plan

The main elements of the EMP are:

i. Environmental mainstreaming tools and Guided Self-Regulation (GSR) element;

9.1.1 Objective of the EMP

REPORT NO: AMR.2019.KWSB.EIA Chapter 9-Environmental Management Plan (EMP) l 9-1

 Identifies potential impact areas of the project;

9.1.2 Submission and Format of the EMP

The format of the EMP is as follows:

 Chapter 5: Environmental Requirements

REPORT NO: AMR.2019.KWSB.EIA Chapter 9-Environmental Management Plan (EMP) l 9-2

f. Material and waste management;

9.1.3 List of Requirement for Environmental Compliance

i. Environmental Quality Act 1974 (Act 127);

9.1.3.1 Ambient Air Quality

 Malaysia Ambient Air Quality Standard (MAAQS), 2015;

(22) Restrictions on pollution of the atmosphere

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c) He burns any wastes of the trade, process or industry; or

9.1.3.2 Water Quality

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9.1.3.3 Noise Quality

9.1.3.4 Solid Waste Management

9.1.3.5 Scheduled Waste Management

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 Environmental Quality (Scheduled Wastes) Regulations, 2005;

 Environmental Quality (Scheduled Waste) Regulations, 2005 (Regulation 4) – Disposal of

 Environmental Quality (Scheduled Waste) Regulations, 2005 (Regulation 5) – Treatment of

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 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 9) – Storage of

 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 10) – Labelling

 Environmental Quality (Scheduled Wastes) Regulations, 2005 (Regulation 15) – Conduct of

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9.1.3.6 Environmental Auditing and Review

i. Carry out environmental compliance audits;

i. Environmental Management Plan (EMP) Report;

9.2 Proposed Monitoring Programme

9.2.1 Performance Monitoring

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i. Technical Guidance on Performance Monitoring of Industrial Effluent

Performance monitoring typically forms an integral part of preventive maintenance procedure

9.2.1.1 Performance Monitoring of Sewage Treatment System

DO Daily 2 – 6 mg/l Online sensor If DO reading is

Flowrate Daily Follow design Flowmeter Should be

Clarifier TSS Weekly Below 50 TSS analysis If TSS> 50mg/l,

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9.2.2 Compliance Monitoring

i. To provide a baseline to facilitate the identification of impacts due to the operational

Table 9.2: Summary of Proposed Compliance Monitoring

Table 9.3: Location of Monitoring Stations

Ambient Air Quality

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Table 9.3: Location of Monitoring Stations

Surface Water Quality

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Sg. Tasek Anak

Source: Google Earth

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Site Boundary Site Boundary