response afi apr '12 (english)

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PT. PULAU SAMBU KUALA ENOK

ISO 14001 : 2004 AREA FOR IMPROVEMENT

RE-NEWAL AUDIT BY AJA-EQS DATED 23 - 24 APRIL 2012Page 1 of 5 Date: 23-24 April 2012

Area For

ImprovementDetails of Area For Improvement

Investigation (Root

Cause)Details of Corrective Action

P.I.C (Effective

Date)(1) The following need to be made clear in the

procedure or system of practice to ensure

consistency in implementing the EnvironmentalManagement System:

Currently the legal register need to be continually

reviewed and updated since it have yet to include

the applicable legal requirement such as PP 18,

1999 related to handling of hazardous waste and

thus the evaluation of compliance have yet to

include evaluating the licence of hazardous waste

transporter, acquiring permit to temporary store

hazardous waste and not to store hazardous waste

more than 90 days. Currently the format used to evaluate legal

compliance need to be reviewed to include the

specific legal requirements and its description

where applicable (ie PP 18, 1999 related to

control of hazardous will include requirements to

have permit to transport, collect, stored and

managed the waste, PerMenLH 08 2009 related

to waste effluent for turbine,PerMenLH 13 2008

related to waste effluent for coconut

industry,HO requirements covering noise,vibration and smell (KepMenLH 48, 49, 50 1996

etc). In addition it will not be appropriate to state

in percentage the level of compliance referencing

to the specific legal requirements. The legal

compliance evaluating shall be carried out

periodically covering the acquired period (ie Jan-

Jun 2012 or Jan Dec 2012 etc).

Currently up date legal register, forPP 18,th 1999 has not registered in

the legal register so that the

evaluation of compliance is not

still done.

Understanding still not right of

legal compliance (still base on the

percentage of compliance),including some related legal in

addition to the frequency of the

evaluation period has not been

established.

MR/KB will include PP 18, th1999 in legal register and will

consistently evaluate legal

compliance periodically.

MR/KB will change the format

of the evaluation of legal

compliance by adding NA inthe field of compliance and

eliminate the percentage (%)

and giving description of the

item into column that has notobeyed (comply).

Enter the legal into the the

evaluation of legal compliance

,ie, PP 18,th 1999, PermenLH

no 08, 2009, KepmenLH no 48,49, 50.Establish period of the

evaluation of legal compliance ,

(Jan-Dec in every year).

MR/KB ESD(May 2012)

MR/KB ESD

(May 2012)


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Area For

ImprovementDetails of Nonconformance Investigation (Root Cause) Details of Corrective Action

P.I.C (Effective

Date)(1) The company need to ensure the air emission

analysis will be based on the applicable legal

requirements for boiler (PerMenLH 07 2007),

turbine (PerMenLH 21 2008) and genset

(KepMenLH 13 1995) as currently result fromSucofindo were all based on KepMenLH 13

1995).

The company need to make clear the control over

the sludge from the waste treatment plant in the

environmental aspect identification and havingclear to handle the sludge.

Although the company did have records to

demonstrate maintenance of the fire protection

equipment, it need to include checking of the

alarm system functionality to ensure it is inoperating condition.

Still lack proper understandingof legal requirements, the

analysis of air emissions

reference (not specific), all the

analysis of air emission refer toKepmenLH 13, 1995.

The identification of

environmental aspects

(EA,HIRADC) and WorkInstruction (WIN-EHS-446-06)

doesnt include the handling of

sludge that processing from theresult of WWTP.

Checking the alarm system

functions only with indicator

lights on, when the call point on

functioned the light will turnon.

MR/KB ESD will conduct airemission testing by an

indepence party (PT.

Sucofindo) to refer the

specifications of the relevantlegal test for boiler

(Permenlh no 7 th 2007),

turbine (permenlh no 21 th

2008) and genset based on(kepmenlh no 13 th 1995).

Revised EA,HIRADC ESD

by adding to the

environmental aspect of theprocess if WWTP sludge

handling and treatment in

control measure, and revisedthe Work Instruction (WIN-

EHS-446-06) by adding the

sludge handling.

MR/KB will review the

system of evacuation in

emergency response

procedure.

Coordinate with all

departments, the

evacuation system in eachdepartment and reporting

in accordance with the

emergency scenario.

MR/KB ESD(Sep 2012)

MR/KB ESD

(Jun 2012)

KB ESD/KB LST

(May 2012)

KB ESD/KB LST(May 2012)


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RE-NEWAL AUDIT BY AJA-EQS DATED 23 - 24 APRIL 2012

Page 3 of 5 Date: 23-24 April 2012

Area For


P.I.C (Effective

Date)(1) The company did carried out emergency

evacuation drill in July 2011 but nevertheless the

report which include the scenario did not include

the method of evacuation so as to ensure the

evacuation system will conform to the emergency

response procedure.

Based on UKL/UPL requirements, the company

will need to report 6 monthly its monitoring

results and for any changes in the companys

operation to the relevant authority. Currently the

analysis of the waste effluent from the turbine

plant have yet to be reported.

The program is still in generalevacuation system, not

specifically the evacuation

system (scenario) for each

department in evacuationtraining.

Frequency analysis of turbine

exhaust waste not meet the

UKL/UPL. Its analyzed only

once a year so that reportingdata to BLH Tembilahan also

once a year.

MR/KB will review thesystem of evacuation in

emergency response

procedure.

Coordinate with all

departments, the evacuation

system in each departmentand reporting in accordance

with the emergency scenario.

MR/KB will apply the

analysis of waste waterturbine to an independent

body once in every 6 month

and reported results in

accordance with the timeperiod of to BLH

Tembilahan.

MR/KB ESD(Jun 2012)

MR/KB ESD

(Sep 2012)


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Area For


P.I.C (Effective

Date)(1) The company have started its turbine

operation in 2008. Currently the waste

effluent from the turbine will be discharge

into the neutralizer tank/pit whereby the

regeneration output (ie HCL, and NaOH)

will be discharge into the same tank. The

company need to ensure that before

discharging the waste effluent to the main

water stream, it need to comply against the

PerMenLH 08 2009 related to the

regeneration effluent. Currently the system

effluent from the neutralizer tank/pit.

Disposal of liquid waste toneutralizer regulated in Work

Instruction WIN-EHS-446-06

waste water management but not

described in the Work Instruction clearly the method of

waste water discharge into the

main water source and record

time of disposal.

MR/KB will revise the WorkInstruction WIN-EHS-446-

06 (waste water

management) of the WWTP

treatment process include theturbine discharge waste water

into the stream of the main

source.

MR/KB ESD/KBTBN

(Jun 2012)

Page 5 of 5 Date: 23-24 April 2012


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RE-NEWAL AUDIT BY AJA-EQS DATED 23 - 24 APRIL 2012Area For


P.I.C (Effective

Date)(1)

The company need to ensure that specific

training to the conducted especially relatedto chemical handling, MSDS spillage

control, applicable legal requirement for the

those personnel involved in handling

chemical (ie lab, warehouse, PEB, waste

water treatment, turbine etc).

Method of Training system have

not included some specific

training before work andpersonnel involved in handlingchemicals such as MSDS and

spill drill in lab, warehouse,

PEB, WWTP, Turbine).

PSN dept will coordinate with

all department to ensure that

specific training to be donebefore the personnel work ie,MSDS and applicable legal

requirement.

MGR PSN/KB

DEPT

(Jun 2012)

Definition:

Prepared by: Approved by:

Herik Kenneth JM

MR/Date AGM OPN/Date

MR : Management Representative

MGR : Manager

KB : Department Head

LST : Electrical Department

TBN : Turbine Department


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