Document No.

: PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

GEC/ Contractor: Area/ Contract No.: Contract Title:

KEO International Roads and Infrastructure in Al Ebb and
DN099-P05
Consultant Leabaib
Document No.: Document Title: Transmittal No.: Date of Submittal:
DN099-P05-TRI-KEO-
DN099-P05-TRI-CON-MNP-A10012 Construction Environmental Management Plan 31-Dec-2019
TML-00057

Comment Category
Section Reference Reviewer Position Comment Response Responder Position
No. (R/S)
This submission is REJECTED since the
contractor had developed the CEMP by
themselves. Rev: 00
As per the MME Environmental Permit Noted & TriConstruct
(2017/29368 – Renewed under Ref assigned Qatar
(2018/29930)), clause 24, the CEMP should be Design Consortium
developed by an Environmental Consultant. (QDC) to prepare
Environmental Therefore, this submission is REJECTED. CEMP. HSE
1 General MK R AM
Specialist Manager
DN099-P05 - CEMP
Prepared by Qatar
Design Consortium
(QDC) Submitting for
Approval.

Rev01 Comments
Contractor to undertake a QA/QC check on the QA/QC has been
Environmental HSE
2 General MK whole document. Different sections showing R check done and AM
Specialist Manager
Error Reference Source not found. corrections made.

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Reference to Table 2-2 (Projects Milestone),

contractor has not submitted any permit
application to the GEC up to date.
Contractor to submit ASAP the
environmental permit applications for the
construction activities to avoid any delay in
work progress. It is the contractor
responsibility to ensure proper planning for
submissions prior to the start of the Permit Applications
construction activities. As per the will be submitted
environmental permit for the project, no immediately by the
Section 2.3 activities to proceed onsite unless the contractor. Some are
Environmental HSE
3 (Project MK
Specialist
relevant environmental permit is issued. R already done. Status AM
Manager
Schedule) The same also applies to the site offices and of the permits
laydown area. Any failure to comply with applied are updated
the environmental permit condition will in Table 3-8 and
have its legal implication on the contractor. Appendix F.

Rev 02:
Contractor to Proceed ASAP with
submission of Environmental Permit
Requests. Note on Appendix F, Dewatering
permit is required for the project. Appendix
F to be amended in the final copy of the
CEMP.
Table 2-3 is showing the estimated Permit application
will be submitted by
Section 2.4 quantities for the excavated material.
Environmental the Contractor. HSE
4 (construction MK Contractor to confirm the plan for the R AM
Specialist Amended accordingly Manager
activities) storage of the material. Currently, the in Section 2.4. The
contractor has not applied for any storage laydown area for

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

or laydown permit for the storage of stockpiling has been

material. Any material storage onsite will furnished in Figure 2-
require an environmental permit. 11
This section refers to the production of daily
quantity of 1200 MT/Day. The contractor to
revise the below statement "The
contractor has a haulage permit for the
Section 2.5 Environmental Amended accordingly HSE
5 MK quantity to remove from the site", since no R AM
(Open Trench) Specialist in Section 2.5 Manager
haulage permit is in place. Contractor to add
a statement with commitment to have all
the required environmental permits in-place
prior to any related construction activities.
(Section 2.7 corrected
to section 2.6.2)
Additional details is required for the micro- Additional details
tunneling works, including more included as suggested
information on the separation plant and in Section 2.6. A
Section 2.6 / Environmental how it operates, disposal of material and if Permit Application for HSE
6 MK R AM
Section 2.7 Specialist any additives being used for the operation. microtunelling, Manager
Environmental permit is required for this lagoon is submitted
activity including providing the details of the for approval. Further,
separation plant. permit requirement is
highlighted in Table
3.8
Dewatering Management Plant is required (Section 2.8 and
along with Dewatering Method Statement Section 7.9)
Dewatering method
prior to any dewatering works.
Environmental statement along with HSE
7 Section 2.8 MK R AM
Specialist Dewatering Manager
Rev 02: management plan
The provided information under Appendix V (DMP) and the same
IS NOT the dewatering permit and does not has been furnished in

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

include the dewatering method statement. Appendix V of this

Contractor to submit Dewatering CEMP. The same has
Management Plan following the PWA been addressed in
procedures included under Appendix Q of Section 2.7 of the
CEMP.
this CEMP. Table 3.8 must be amended
accordingly. Dewatering permit is REQUIRED
for the project.
(Section 2.10 )
Environmental Permit is required for the Environmental Permit
site office along with the laydown area. No application submitted
already for the Site
Environmental work onsite unless the environmental HSE
8 Section 2.11 MK R office. Permit AM
Specialist permit is issued. Contractor to submit the requirements and
Manager
environmental permit application ASAP. their Status has been
This is urgent. updated in Table 3-8
and Appendix F.
The list of the environmental permits (Section 3-5)
required by the contractor, must be The permit
submitted ASAP. The table to be revised to applications were
include the link with the project milestone already submitted for
few requirements,
Environmental and submission. Proper planning must be in- HSE
9 Table 3-8 MK R and the others will be AM
Specialist place by the contractor to confirm the submitted ASAP. The
Manager
issuance of the needed environmental status of the permits
permit prior to the start of the relevant has been modified in
construction activities. This table needs to table 3-8 and
be revised. Appendix F
The environmental policy to be provided The environmental
and signed by the contractor in the and sustainability
Environmental HSE
10 Section 4.1 MK
Specialist
contractor letterhead. The policy MUST be R policy signed by the AM
Manager
signed by the contractor's Project Director. Project Director in
the letter head of the

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Rev 02: Contactor has been

The policy is dated 2018, prior to the start of provided in Appendix
the project. The Policy Must be signed by N.
the Project Director and not more that 12
moth old. The policy has to be reviewed
annually following the ISO 14001
requirements.
the second paragraph is TOTALLY WRONG.
The contractor is the responsible entity for
FULL Compliance against the environmental
Environmental HSE
11 Section 4.2.1 MK
Specialist
permit conditions and is responsible for R Amended accordingly AM
Manager
obtaining the relevant permit prior to any
work onsite. This section MUST be
amended.
The roles and responsibilities must be
amended for the SC role for the following
items:

Coordinating with the MME on all

environmental matters pertaining to the
Project. The SC Roles is review and confirm
Environmental compliance of the contractor. PWA is HSE
12 Section 4.4 MK R Amended accordingly AM
Specialist undertaking the direct communication with Manager
MME.

· Acting as a main point of contact between

the appointed Contractor and the
engineering design team on all
environmental issues. This the role of the
contractor. The SC review and approve the

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

related environmental aspects in relation to

the environmental permit.
The roles and responsibilities of the project
contractor must be amended to include
reference to FULL Compliance against the
environmental permit(s) conditions and
Environmental undertaking internal audits to confirm Ammended HSE
13 Section 4.5 MK R AM
Specialist compliance against such conditions. It is the accordingly Manager
contractor responsibility to confirm the time
submission of the required environmental
permit applications prior to the start of the
related construction activities.
The contractor to expand in this action and
provide roles for the Project Director and
Construction Team including construction (Section 4.5.1 - 4.5.6 )
Manger / Director. Roles of the Project
Contractor to confirm the name of the Manager,
environmental specialist. This position is Construction
one of the Key Personal. Manager has been
Environmental HSE
14 Section 4.5 MK
Specialist
R furnished. Mr Sachin AM
Manager
Rev 02: R Kamle is the
The contractor has to submit the CV's for contractors
the staff name mentioned under Figure 4.1. Environmental
The names provided under this figure is Manager (mentioned
in Figure 4-1)
different than the names provided for the
GEC approval. Contractor to provide
justification and explanation.
Amended
Contractor to provide more details in this
Environmental accordingly. The HSE
15 Section 5 MK section to include the direct impact on the R AM
Specialist baseline parameters Manager
project (related to PK5) with regards to the are reviewed to

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

exceeding parameters from baseline.The include only the

baseline for ecology needs to be revised locations within the
since it is outdated (8 years old survey). proposed project
Additional baseline monitoring is required area (Package 05) .
Fresh Baseline survey
at the sensitive receptors prior to the start
for air, water, soil and
of any construction works onsite. The SC
ecological survey
must be notified (48 hrs. prior to before the start of
monitoring) to witness the baseline the construction
monitoring. activity is
recommended
Rev 02: (Figure 5.8) and
Contractor to confirm the completion of section 5.10.
baseline works including the ecological
survey prior to start of work. Data to be
provided in the first environmental monthly
report.
Contractor to update the following
submission of the CEMP to include the
discussion on the impact of banning Included in section
crushing new standing instruction. 2.10.4. No crusher is
proposed within the
construction site. The
crusher will be
Environmental HSE
16 General MK
Specialist
R located far away (>6 AM
Manager
kms) from the
construction site and
permit application
already submitted for
Rev 02: the same (Table 3-8).
Contractor to update and confirm full
compliance with PWA requirements under

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Circular (2019/67).
Hazardous waste will
not be stored at site
Contractor to request for the hazardous waste for longer duration.
Environmental HSE
17 General MK storage permit. This needs to be done ASAP R Will be removed on AM
Specialist Manager
prior to storage of any hazardous waste onsite. weekly basis by
approved waste
handler
Contractor to confirm full compliance against
item 3 stating "Times of construction activity
Environmental will be restricted to the agreed and approved Will be Complied by HSE
18 Table7-8 MK R AM
Specialist operational hours 6 am – 5 pm Saturday to the Contractor. Manager
Thursday. Construction work on a Friday to be
approved by the Supervision Consultant "
The baseline test
results (EIA) did not
observe any
contaminations as
Contractor to confirm and link this section with
Environmental per the Dutch Stds. HSE
19 Section 7-4 MK the findings of the baseline. Additional baseline R AM
Specialist However, fresh Manager
will be required.
baseline has been
recommended before
start of the
construction.
Frequency against the sampling of sediments,
Environmental HSE
20 Section 7-5 MK soil quantity and slurry to be provided and R Amended accordingly AM
Specialist Manager
linked with table 7-12.
Frequency against the sampling of soil from Frequency and
stockpile to be provided and linked with table 7- number of samples
Environmental 12. The location planned for the stockpile needs are furnished in Table HSE
21 Section 7-7 MK R AM
Specialist to be provided in the following CEMP 7-13. The Stockpile Manager
submission. locations is 6.5 kms
away from the

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Rev 02: project site is

Soil Sampling needs to be collected on regular furnished in Figure 2-
volumes, contractor to propose the frequecny 11
accordingly.
The Dewatering Management Plan MUST be
developed as per the project's approved EIA.
Below is the extract from the approved EIA for Dewatering method
the minimum requirements of the Dewatering statement along with
Management Plan (within the Plan itself) Dewatering
management plan
(DMP) and deep well
Environmental permit issued by HSE
22 Section 7-9 MK R AM
Specialist Ashghal has been Manager
furnished in Appendix
V of this CEMP. The
same has been
mentioned in Section
Rev 02: 2.7 of the CEMP.
Contractor to revise following comment 7
above.

COSHH assessment for the chemicals(Diesel,

Environmental Furnished in HSE
23 General MK petrol, engine oil,...) shall be developed R AM
Specialist Appendix U Manager
attached to the document or reference to the
relevant document shall be given(if any).
Contractor to confirm full compliance against
this table along with the GCC parameters for
deep well injection.
Environmental Will be Complied by HSE
24 Table 7-21 MK R AM
Specialist the Contractor. Manager
Rev 02:
Contractor to conduct a complete baseline
water sample againist the GCC parameters.
25 General MK Environmental Contractor to add the relevant data for the R Section 7.9 AM HSE

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Specialist baseline groundwater quality from the EIA and The groundwater Manager
discuss the potential contamination as per the baseline conditions
EIA provided details. The latest water quality are discussed in
data for the deep well must be added to the section 5.4 of this
report and discussed in details. CEMP. However, the
contractor will
conduct (before the
start of dewatering
activity) and furnish
the latest
groundwater quality
of the deep well .
This section MUST discuss the rainy season
Rainy season
management and he set of measures taken by
management plan
the contractor in this regards.
Environmental provided in Appendix HSE
26 Section 7-10 MK R AM
Specialist W, the same has Manager
Rev 02:
been mentioned in
The paragraph related to Rain Season Plan is not
brief in section 7.9
complete in Page 141. Contractor to amend.
Contractor to conduct baseline monitoring
The contractor will
for Air, Noise , Ecology , Soil and conduct a basline for
Groundwater following the EIA sensitive Air, Noise, Ecology,
Receptors and update the table accordingly. Soil and Groundwater
Clear dates to be provided based on the in the sensitive
Environmental construction work and project schedule receptors identified HSE
27 Table 8-1 MK R AM
Specialist near sensitive Receptors. in the EIA. The dates Manager
of the construction
Rev 02: work and the
The baseline monitoring results must be sensitive receptors
are furnished in
submitted in the first environmental
Figure 5-8
monthly report.
28 Table 8-1 MK Environmental The monitoring equipment for each aspect R Furnished accordingly AM HSE

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

Specialist must be provided in the following CEMP Manager

submission.
Contractor to provide a clear plan for the
Environmental planned internal audit and the role of the HSE
29 Section 9.2 MK R Modified accordingly AM
Specialist referred environmental consultant indicated Manager
in this section.
The incident reporting must be reported to
MME within 24/48 hrs. from the incident.
Environmental HSE
30 Section 9.5 MK
Specialist
Contractor to refer to minor and major R Amended accordingly AM
Manager
incident classification, as per MME and QCS
and provide clear reporting procedure.
The notification section MUST include the
Environmental emergency contact details from the HSE
31 Section 9.6 MK R Amended accordingly AM
Specialist contractor / consultant and PWA and MME. Manager
This section needs to be revised.
The incident reporting must be reported to
MME within 24/48 hrs. from the incident
Environmental and not 7 days. Contractor to refer to minor HSE
32 Section 9.7 MK R Amended accordingly AM
Specialist and major incident classification, as per Manager
MME and QCS and provide clear reporting
procedure.
Contractor to add a statement to expand
Environmental HSE
33 Section 10.1 MK
Specialist
and add more training topics following the R Amended accordingly AM
Manager
work progress and the site need.
Contractor to ensure that the complaint
register is always available with the security
Environmental guard to record any complaint received Contractor will HSE
34 General MK R AM
Specialist onsite. Any complaint must be recorded and comply Manager
reported accordingly. Training section must
include topic for environmental complaints

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

and contractor must report the evidence for

the reporting to the SC and PWA
accordingly. Reference to Appendices to be
revised.

Following the PWA CEMP approval

Template, The Contractor has to submit
separately the CV for the construction
environmental manager. If the CV is Contractor will send
Environmental submitted under different plan / submittal, the CV of the Env HSE
35 General MK R AM
Specialist please refer to the relevant submission plan Manager in a Manager
in the response to this comment. separate submittal

Rev 02:
Contractor to Check comment number 14
and comply accordingly.

Contractor to check all the appendices and

confirm its proper cross reference in the
Environmental CEMP and provide the template for the Checked and HSE
36 General MK R AM
Specialist Monthly Environmental Report and add the corrected Manager
relevant templates and checklists from the
Environmental Guidelines and Procedures
from PWA.
Rev 02 Comments:

Environmental Contractor to proceed with the HSE

37 General MK R AM
Specialist development and submission of the CEMP Manager
Presentation to PWA. The CEMP status will

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 Document No. : PWA-RPD-QM-FM-028

Document Review Comment Sheet Revision No. : 04

Issue Date : 20 Jan. 2019

be approved once the PWA presentation is

completed and PWA approval on the CEMP
is provided.
Abbreviation:

R - Requirement
S - Suggestion

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