CHAPTER 15 1/CHAPTER 15... · CHAPTER 15 ENVIRONMENTAL AND SOCIAL MANAGEMENT ... 15-13 15.4.5 Managing Changes ... start-up and operations,

CHAPTER 15

ENVIRONMENTAL AND SOCIAL MANAGEMENT

SYSTEM

Quantum Power Ghana Gas Limited 15-i Knight Piésold Consulting

Environmental and Social Impact Assessment

TABLE OF CONTENTS

15 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM ................................................ 15-1

15.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM OVERVIEW ............................. 15-1

15.2 QUANTUM POWER GHANA GAS LIMITED VISION, POLICY AND STRATEGIES ................ 15-3

15.2.1 Quantum’s Vision ...................................................................................................................... 15-3

15.2.2 Quantum’s Integrated Sustainability Policy (Environment, Health and Safety) ........................ 15-3

15.2.3 Objective ................................................................................................................................... 15-5

15.2.4 Implementation ......................................................................................................................... 15-5

15.2.5 Quantum Power Strategies....................................................................................................... 15-5

15.3 FRAMEWORK FOR IMPLEMENTATION OF THE ENVIRONMENTAL AND SOCIAL

MANAGEMENT PLANS ........................................................................................................... 15-7

15.3.1 Purpose of the Provisional Environmental and Social Management Plans ............................. 15-7

15.3.2 Contents of the Provisional Environmental and Social Management Plans ............................ 15-7

15.3.3 Roles and Responsibilities ........................................................................................................ 15-7

15.3.4 Stakeholder Engagement ......................................................................................................... 15-9

15.4 KEY COMPONENTS FOR THE IMPLEMENTATION OF THE ENVIRONMENTAL AND SOCIAL

MANAGEMENT SYSTEM ...................................................................................................... 15-10

15.4.1 Training ................................................................................................................................... 15-10

15.4.2 Responses to Incidents .......................................................................................................... 15-11

15.4.3 Audit and Inspection ............................................................................................................... 15-12

15.4.4 Reporting ................................................................................................................................ 15-13

15.4.5 Managing Changes ................................................................................................................. 15-13

15.4.6 Communication to Stakeholders ............................................................................................. 15-14

LIST OF TABLES

Table 15-1: Quantum Project HSE Organisation...................................................................... 15-7

Table 15-2: EPC Contractor HSE Organisation ....................................................................... 15-8

Table 15-3: Environmental Incident Categories ..................................................................... 15-11

LIST OF FIGURES

Figure 15-1: Environmental and Social Management System Implementation Process ......... 15-2

Quantum Power Ghana Gas Limited 15-1 Knight Piésold Consulting


15 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM

This chapter presents the framework for implementation of the Project Environmental and

Social Management System (ES-MS). This includes environmental and social monitoring,

documenting compliance (e.g. record-keeping), as required to measure the effectiveness of the

mitigation measures, reporting on environmental and social performance, and the process for

defining and implementing procedures for corrective action when necessary.

In the course of the ESIA, impacts (both positive and negative) to the physical, natural and

socio-economic environments have been identified. In order to avoid, minimise and reduce

negative impacts, and to ensure opportunities for the enhancement of positive impacts are

realised, provisional Environmental and Social Management Plans (ESMPs) have been

prepared.

The ES-MS framework enables implementation of the ESMP, which details the actions that will

be taken to mitigate and manage environmental and social impacts based on the activities

described in the Chapter 2: Project description; Chapters 8-10: Environmental and Socio-

economic Baseline chapters; and Chapters 11-13: Impact Assessment chapters of this ESIA.

Implementation of the ESMP provides tools for auditing the Project’s mitigation and monitoring

activities, and communicating monitoring outcomes to stakeholders1.

The provisional ESMPs are contained in Volume Three of this ESIA. These include:

Annexure A: Provisional Environmental and Social Management Plans

Annexure B: Provisional Emergency Response Plan

To provide a vehicle for the integrated management of all the ESMPs, an Environmental and

Social Management System (ES-MS) will be implemented by Quantum Power. In this regard,

the ES-MS is a key component of this ESIA.

15.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM OVERVIEW

IFC Performance Standard 1 requires that an ES-MS be developed to support an organisation’s

overall management systems to address environmental and social impact management

effectively. The overarching management system is the Project’s Management System that:

enables the Project to manage activities in a healthy, safe and environmentally and socially

responsible manner;

establishes a common set of objectives and expectations;

provides a structure to organise processes, programmes and procedures that enable the

Project to carry out these objectives and expectations;

is designed to identify, evaluate and control Project risks in a way that prevents or

mitigates incidents that could impact people, the environment or assets; and

applies to the entire asset life cycle: starting with design or acquisition, continuing through

construction, installation, start-up and operations, and on through abandonment or

divestiture.

1 A Stakeholder Engagement Strategy has been developed to describe its engagement strategies with identified project stakeholders.



The key steps or processes of the ES-MS are illustrated in Figure 15-1, and each of the steps is

further detailed below.

Figure 15-1: Environmental and Social Management System Implementation Process

The main elements of an ES-MS comprise the following four phases.

Planning: Establishing the objectives and processes necessary to deliver results in

accordance with the Quantum Powers’ Environmental and Social Policy.

Doing: Implementing the processes through defining mitigation measures and assigning

responsibilities for undertaking or implementing such mitigation measures.

Checking: Monitoring and measuring these processes against the policy, objectives and

targets, legal and other requirements (such as those of Ghana and the IFC), and reporting

of the results.

Acting: Taking actions to continually improve performance of the ES-MS through the

training of personnel and auditing of results.

An ES-MS is therefore implemented to:

Assist management in establishing priorities for environmental and social impacts;

Provide a mechanism for ensuring that measures identified in the ESIA and listed in each

management plan, are implemented;

Ensure that changes in Ghanaian legislation are tracked and adhered to at all times;

Provide a framework for compliance auditing and inspection programmes;

Ensure environmental and social issues continue to be integrated into business decisions;

Provide a framework for mitigating impacts that may be unforeseen or unidentified until

construction or operation is underway;



Encourage and achieve appropriate environmental and social performance and awareness

from all employees and contractors;

Provide assurance to regulators, stakeholders and lenders that their requirements with

respect to environmental, social and health performance are being managed; and

Provides the opportunity to certify the system to international standards, such as ISO

14001, if so desired.

The ESIA has essentially undertaken most of the initial planning aspects required by an ES-MS

by identifying environmental and social impacts and formulating management plans. Further

elements of an ES-MS related to planning and those related to doing, checking and acting, are

described in this chapter.

15.2 QUANTUM POWER GHANA GAS LIMITED VISION, POLICY AND STRATEGIES

The development of the ES-MS has been guided by the vision statement and environmental

policy of Quantum Power. These Policies are high-level corporate statements of intent and

establishes the principles to be followed in the management of environmental and social issues.

The policies therefore constitute the documents against which all related activities should be

judged.

15.2.1 Quantum’s Vision

The vision of Quantum Power is as follows:

Quantum Power’s primary focus is on the development of a Liquefied Natural Gas

Facility and associated infrastructure to import, re-gasify and distribute gas to

independent power producers in the Tema/ Kpone area. Their vision is to be a leading

supplier of natural gas in Ghana that creates value for its shareholders, employees and

their business in a manner that is sustainable and that does not harm the environment or

people.

15.2.2 Quantum’s Integrated Sustainability Policy (Environment, Health and Safety)

Quantum Power Ghana Gas Limited’s Integrated Sustainability Policy is defined in Box 15-1

and is designed to reflect the environmental needs and responsibilities of the company’s

activities. Additionally, the company will continue to address hazard control, accident

prevention, training and employee participation in all aspects of its operations.

In particular the Integrated Sustainability Policies indicate Quantum’s commitment to continual

environmental improvement, health and safety responsibilities, the prevention of pollution,

conformance to legislation and other requirements in relation to its environmental aspects.



INTEGRATED SUSTAINABILITY POLICY (ENVIRONMENT, HEALTH AND SAFETY)

Quantum Power Ghana Gas Limited (QPRGG) is a developer, owner and operator of

electricity generation assets and power-related infrastructure throughout Africa. QPRGG is

committed to the implementation of a management system which will minimise negative

and advance positive impacts on the environment. The company recognises that the work it

undertakes could have an impact on the safety and health of its employees. To this end,

QPRGG is firmly committed to and will:

Establish procedures to promote continuing improvement of compliance with all

applicable Environmental, Health and Safety (EHS) laws and regulations.

Establish procedures to continue efforts to strengthen and improve knowledge of

environmental issues within the company.

Monitor and report on health and safety objectives by including health and safety

targets in the Key Performance Indicators.

Seek optimal operation of the Company’s Facilities to minimise generation of

hazardous waste at the point of generation, and to reduce or eliminate pollution

sources with continual improvement.

Promote cooperation and understanding with the public, clients, and governmental

agencies in developing economically feasible and environmentally sound

operational objectives.

Establish procedures for reporting all noncompliance’s in accordance with

applicable governmental reporting requirements, evaluate causes of

noncompliance, and implement corrective actions.

Establish procedures for periodic review of environmental compliance with all laws

and regulations, as well as with the ISO 14001 Environmental Management

System.

Establish procedures to ensure that all employees, contractors and sub-contractors

are knowledgeable of, and understand and comply with the policy.

Promptly correct any practice or condition not in compliance with this policy.

Review policy annually in line with QPRGG’s business operations.

Management at all levels of QPRGG is responsible for ensuring that this policy is adhered

to by all employees and subcontractors.

Don Ackah

Chief Executive Officer

Effective date: 1st January 2015

Box 15-1: Integrated Sustainability Policy



15.2.3 Objective

Quantum Power recognises that maintenance of environmental quality is vital to the Company’s

existence, progress, and continued development. The Company will maintain high

environmental standards and will adhere as far as practicably possible to international best

practise limited only by technical and economic feasibility. The Company will take positive

action to protect the safety of its workers, conserve natural resources, and minimize the impact

of its activities on the environment through diligent application of appropriate technology and

responsible conduct at all stages of the LNG Project.

The purpose of Quantum’s Integrated Sustainability Policy is to provide a measurable

framework for the performance of the Company’s activities in an environmentally responsible

manner, ensuring compliance by the Company and its employees with all applicable

environmental regulations and commitments.

15.2.4 Implementation

Quantum Power will:

Evaluate, plan, construct, and operate all projects and facilities to reduce adverse

environmental impacts and to meet or exceed applicable environmental laws, regulations,

and standards. In the absence of applicable regulations, the Company will apply cost

effective best management practices to protect the environment.

Require managers of all projects and operations to adhere to the Company Environmental

Policy and to identify, evaluate, and minimize risks to the environment.

Continuously review environmental achievements and technology to seek and implement

methods for further improvement.

Require all operations to have site-specific emergency response plans as well as adequate

management plans to mitigate impacts which meet or exceed all applicable regulations.

Conduct regular audits of environmental performance and emergency response plans to

verify compliance with the Company’s policy and applicable regulations. Identify revisions

or improvements to current practices in order to minimize environmental impacts. Report

findings quarterly to the Board of Directors.

Educate employees in environmental matters and responsibilities relating to performance of

their assigned tasks. Entrust all employees to maintain necessary environmental

performance for their activities.

Foster communication with shareholders, the public, employees, and government to

enhance understanding of environmental issues affecting the Company’s activities.

Work pro-actively with government and the public to define environmental priorities.

Participate in the development of responsible laws for the protection of the environment.

Allocate sufficient resources to meet the Company’s environmental goals. Annually assess

the projected costs of decommissioning and reclamation while funding off balance sheet an

appropriate amount to ensure that there is sufficient cash reserves to pay for these costs

upon closure.

15.2.5 Quantum Power Strategies

The Environmental and Social and Health Policies provide a set of strategies. These include:



Legal Compliance

Evaluate, plan, construct, and operate the Project and associated facilities to reduce

adverse environmental impacts and to meet or exceed applicable environmental laws,

regulations, and standards. In the absence of applicable regulations, the Company will

apply cost effective best management practices to protect the environment.

Employee Awareness

Require managers of all operations to adhere to the Company Environmental Policy and to

identify, evaluate, and minimize risks to the environment.

Educate employees in environmental matters and responsibilities relating to performance of

their assigned tasks. Entrust all employees to maintain necessary environmental

performance for their activities.

Emergency Responses

Require all operations to have site-specific emergency response plans as well as adequate

management plans to mitigate impacts which meet or exceed all applicable regulations.

Interaction with Stakeholders

Foster communication with shareholders, the public, employees, and government to

enhance understanding of environmental issues affecting the Company’s activities.

Work pro-actively with government and the public to define environmental priorities.

Participate in the development of responsible laws for the protection of the environment.

Occupational Health and Safety

Safe and healthy working conditions.

Arrangements for the operation, design and maintenance of safe systems of work.

Properly maintained and guarded machinery.

Information, instruction, training, and supervision appropriate to the company’s activities.

Arrangements for consultation with employees and their representation health and safety

matters.

Continuous Assessment

Continuously review environmental achievements and technology to seek and implement

methods for further improvement.

Conduct regular audits of environmental performance and emergency response plans to

verify compliance with the Company’s policy and applicable regulations. Identify revisions

or improvements to current practices in order to minimize environmental impacts. Report

findings quarterly to the Board of Directors.

Allocate sufficient resources to meet the Company’s environmental goals. Annually assess

the projected costs of decommissioning and reclamation while funding off balance sheet an

appropriate amount to ensure that there is sufficient cash reserves to pay for these costs

upon closure.

The management plans should support the commitments made in Quantum Power’s Vision,

Environmental Policy statements and associated strategies.



15.3 FRAMEWORK FOR IMPLEMENTATION OF THE ENVIRONMENTAL AND SOCIAL

MANAGEMENT PLANS

15.3.1 Purpose of the Provisional Environmental and Social Management Plans

To ensure that identified and unforeseen or unidentified impacts are detected and resolved a

set of management plans have been developed. The management plans will be supplemented

with additional requirements as detailed design proceeds and as contractors are selected.

Contractors will be required to develop their working methods and procedures in accordance

with the management plans.

The management plans are an integral part of the ES-MS and act as the main vehicle for

converting the Vision, Policy and Strategies into action.

15.3.2 Contents of the Provisional Environmental and Social Management Plans

Each of the management plans included in Volume Three provides:

A description of the impacts, actions and direct responsibility for managing the impact;

Monitoring requirements, including targets and performance indicators; and

Reporting requirements.

The formulation of each plan covers the planning process of the ES-MS while the

implementation of each plan will cover the implementation and operations processes.

15.3.3 Roles and Responsibilities

To implement the Management Plans, roles and responsibilities for implementation need to be

defined. These roles and responsibilities are discussed below.

The successful implementation of the ES-MS requires a commitment from Quantum Power as

well as their employees and contractors. Within these structures roles and responsibilities for

the implementation of the Management Plans need to be defined as presented in Table 15-1.

Table 15-1: Quantum Project HSE Organisation

Role Responsibility

Project Director Oversee and coordinate all activities pertaining to the Project;

ultimately responsible for HSE.

HSE Manager Ensure that the Project and all its contractors operate in accordance

with applicable regulatory environmental requirements and the

Tema LNG Project ESMP (and associated plans); liaise with

regulators on the Project’s behalf; oversee programs associated with

environmental initiatives.

Site Manager Manage, monitor, report, and ensure the efficient working conditions

of all site activities by the Project staff and by EPC contractors;

assist the HSE Manager with matters related to HSE compliance

and enforcement including implementation of ESMP.



Community Relations

Manager

Liaise with the communities on the Project’s behalf, including in

relation to works being carried out by contractor and subcontractor;

oversee programs associated with social and community

development initiatives; maintain the Project’s grievance procedure.

Environmental and

Social Inspector

Monitor and report on the compliance and performance of the

Project with respect to environmental and social commitments; carry

out regular on-site inspection; monitor compliance and performance

of EPC contractors and any subcontractors.

Similarly specific roles and responsibilities need to be defined for contractors and

subcontractors as shown in Table 15-2.

Table 15-2: EPC Contractor HSE Organisation

Role Responsibility

EPCM Project Director Oversee and coordinate all activities; ultimately responsible for HSE

compliance of the EPC contractor.

EPCM Site Manager Ensure that all work by the EPC contractor and by all subcontractors

is done in compliance with applicable regulatory environmental

requirements and the Tema LNG Project HSE plans. Responsible

for coordination with project Community Relations Manager for all

community relations issues including upcoming works.

EPCM Contractor HSE

Manager

Ensure that the EPC contractor organisation operates in accordance

with applicable regulatory environmental requirements and the

Tema LNG Project HSE plans.

During construction, and to a lesser extent operations, contractors will be the key implementers

of mitigation measures as defined in management plans and will also be responsible for

ensuring compliance with the Project policies and commitments.

Under their contracts, contractors will be responsible for managing the potential environmental,

socio-economic, safety and health impacts of all their contract activities including those of their

subcontractors.

Contractors must as part of their obligations:

Demonstrate compliance with the Environmental Policy through the development and

approval of detailed environmental, social and health plans, procedures and standards;

Demonstrate commitment to the ESIA and its management plans in their management

structure;

Identify individuals responsible for overall environment, social, safety and health

management; and

Undertake regular environmental, social, health and safety inspections and provide reports

to allow for the monitoring and evaluation of performance.



Although the contractors will have the primary roles in delivering on the measures set out in the

ESIA and management plans, Quantum Power will have the ultimate accountability for ensuring

the measures are delivered. This accountability may be delegated to the other where

applicable.

15.3.4 Stakeholder Engagement

Quantum Power will continue to engage with stakeholders throughout the life of the Project.

During construction, communication with local communities and other local stakeholders will be

undertaken by the community liaison function who will work closely with the relevant

contractors.

The objectives of the Stakeholder Engagement Strategy outlined in Annexure C of Volume Two,

are as follows:

To ensure understanding by facilitating an open, culturally appropriate and inclusive

approach to engagement that provides timely and accurate information in an accessible

and transparent way to all stakeholders, regardless of their status.

To manage expectations and concerns by providing a mechanism which not only provides

stakeholders an opportunity to freely provide comment and feedback but also allows

Quantum Power to respond to this feedback, thereby addressing concerns.

To manage risks through building sustainable relationships. Engagement will allow

Quantum Power to understand stakeholder interests and issues and work with

stakeholders to find mutually acceptable ways to achieve or address these.

To create value where engagement allows for partnerships to be developed for the mutual

benefit of both Quantum and the stakeholders. This includes but is not restricted to

corporate social investment activities. This relates also to seeking mutual benefit through

design and operations by considering stakeholders and seeking their benefit in all Project

activities.

15.3.4.1 Grievance Procedure

It is intended that the stakeholder engagement measures outlined above, and the mitigation

and management measures outlined in all other management plans, will work proactively

towards identifying and addressing issues before they become grievances. However, when

grievances are reported they need to be addressed in a consistent and verifiable manner. This

will be done through the implementation of a grievance procedure.

This procedure focuses on the recording and processing of complaints and grievances and not

of incidents, which should be dealt with through the ES-MS. The definitions of both a grievance

and an incident are presented in below. Although their definitions may differ, there are clear

links that need to be established between this grievance procedure and the incident reporting

system. The definitions are as follows:

A grievance is when a complaint linked to the operation is raised with the expectation that

the complaint will be addressed.

An incident is any occurrence that has caused, or has the potential to cause, a negative

impact on people, the environment or property (or a combination thereof). It also includes

any significant departure from standard operating procedures.



In some cases, grievances may be linked to actual incidents, in which case the incident also

needs to be reported.The grievance procedure for the QuantumPower should be followed for all

grievances relating to the Project as a whole. The grievance procedure is divided into six key

steps:

Step 1: Receive and log grievance.

Step 2: Acknowledge grievance.

Step 3: Assess and prioritise grievance and forward to relevant function.

Step 4: Investigate and resolve grievance.

Step 5: Sign off on grievance.

Step 6: Monitor.

15.4 KEY COMPONENTS FOR THE IMPLEMENTATION OF THE ENVIRONMENTAL AND

SOCIAL MANAGEMENT SYSTEM

Mitigation, monitoring and management measures are contained throughout this ESIA and in all

management plans. These measures all represent the doing and checking processes of the ES-

MS framework.

In addition to these commitments, other key components of the ES-MS include training, audits

and inspections and reporting. These measures all represent the doing (training), checking

(audits and inspections) and acting (reporting) processes of the ES-MS framework.

15.4.1 Training

The key components of training requirements are to ensure that all site personnel, including

contractors understand the:

Environmental and social requirements of the proposed Project and how these will be

implemented and monitored on site;

Contents and relevant requirements of Project actions contained within the applicable

management plans;

Environmental and social sensitivities of the Study Area;

Procedures to be followed in the event of noncompliance with the environmental, social

and health requirements; and

Procedures for responding to the media, unauthorised visitors to the site, and enquiries

from the public.

They must also:

Know how to deal with unforeseen environmental and social incidents; and

Be aware of their roles with respect to environmental, social and health issues.

15.4.1.1 Project Training Programme

One of the most important mechanisms for the enhancement of the Project’s environmental and

social performance will be the continued implementation of a training programme for all Project

personnel including the personnel of contractors and subcontractors.



Training will include:

Induction training for all staff including modules on: health and safety, environmental

awareness, accommodation rules, worker code of conduct, stakeholder engagement,

grievance mechanisms and cultural heritage awareness;

Toolbox training for specific tasks; and

Training for individuals involved in tasks with specific responsibilities.

Refresher training programmes will also be implemented to ensure continual improvement

in environmental awareness for all Project personnel.

Training will be provided at each stage of the Project, from initial establishment of logistical

facilities through to construction and operation. The training function will assist managers in

developing and co-ordinating training programmes as required.

Training records will be maintained by the training function and an assessment of the

effectiveness of the training programmes will be included as part of the internal audit

procedures.

15.4.1.2 Contractor Training Programme

Contractors will be responsible for ensuring that all their personnel are aware of their

environmental, social and health responsibilities. They will develop and implement training

programmes to the satisfaction and approval of the Project Sponsors.

Training will include:

Induction training for all staff prior to carrying out any work on site. This will include

modules on: health and safety, environmental awareness, accommodation rules, worker

code of conduct, stakeholder engagement, grievance mechanisms and cultural awareness;

Toolbox training for specific tasks;

Training for individuals involved in tasks with specific responsibilities; and

Training programmes organised by the Project Sponsor as required.

The contractor will keep auditable records of training given. Assessment of the effectiveness of

the training programme will be included as part of the ESH-MS audit procedures.

15.4.2 Responses to Incidents

The reporting and investigation of all potential and actual incidents that could have a

detrimental impact on human health, the natural environment or property is required so that

remedial and preventive steps can be taken to reduce the potential or actual impacts as a result

of all such incidents.

For Quantum Power, environmental incidents can be classified in three categories, with each

category having specific reporting and follow-up requirements, as defined in Table 15.1, below.

Table 15-3: Environmental Incident Categories

Classification Category 1 Category 2 Category 3



Identification

An incident resulting

in a breach of RoD

conditions,

environmental

regulations and/or

Quantum standards;

an incident that is

reportable to the

government by law

or other statute, or

has caused

significant

environmental harm

or injury to people,

animals, or property.

This category

incident also includes

incidents whose

impacts have

extended onto

publicly accessible

land and which have

the potential to

adversely impact on

surrounding

communities,

livestock or wildlife.

An incident with

potential to breach

RoD conditions or

environmental

regulations or

standards, but which is

not reportable to the

government (though

voluntary disclosure

may be undertaken at

the discretion of site

management).

Has the potential to

cause significant

environmental harm or

injury to people or

animals and/or has

impacted on publicly

accessible land in

some measure. This

includes incidents that

have interfered with

the public domain

outside the

QuantumPower

Project area, but which

are not reportable by

law to Government.

An incident with little

potential to breach RoD

conditions or

environmental regulations

or standards and which is

not reportable to the

government and/or the

management committee.

Reporting Immediately

reportable to the

QuantumPower

board of directors.

Reportable to all

management

associated with site

operations of the

project.

Reportable only to the

environmental site officer.

Follow up Formal investigation

will be required.

Formal investigation

required.

Informal investigation

actions required.

The actions resulting from any formal or informal investigations will be used to update the

applicable management plans. The Audit programme should be revised to audit areas or

aspects where incidents occur more regularly to ensure that the potential for such incidents

recurring are minimised.

15.4.3 Audit and Inspection

An audit programme detailing the aspects to be audited, the area, and the frequency of audits

will be established. The audits will be based on appropriate protocols prepared by the

environmental and social functions.

Regular environmental and social audits and random spot checks will be undertaken by

selected audit team members throughout all phases of the Project. The audit and inspection

frequencies will be defined, and may be increased or decreased according to the findings and



degree of confidence in the audit programme. Audits will also assess compliance with agreed

objectives and targets as well as the effectiveness of the management plans and their

implementation.

Audit findings will be reviewed by the applicable management functions and where corrective

actions are deemed necessary; the relevant management plans will be updated.

15.4.4 Reporting

The proposed Project will develop a system of internal reporting that allows for appropriate

reporting on the effectiveness of the ES-MS. Public reports will also be prepared on a range of

issues of interest or concern to local communities.

During the construction phase, contractors are required to take all appropriate measures in its

ES-MS and related plans and procedures to identify and document incidents of environmental,

social and health non-conformance. These records should be produced at no less than weekly

frequency, identifying the category of non-conformance, its potential severity and its frequency

to be demonstrated. The resultant records will be addressed in the appropriate management

meetings to initiate corrective actions required.

Quarterly Reporting

Project Environmental and Social Quarterly Report will be prepared and submitted to the

Environmental Protection Agency (EPA). The structure, content and format will be agreed with

the authority prior to the commencement of work. This quarterly report will document key

information on the Project’s performance against the ESMP requirements.

Incident Notification and Reporting

Contractors will notify the Project immediately following any environmental or social incident.

Project will ensure that all environmental and social incidents are appropriately documented,

that the relevant parties are notified, and that reporting requirements around the incident are

met.

These records are intended to facilitate the purposeful reduction of incidents of non-

conformance, leading to a consequential reduction of the root causes of such incidents.

All management plans include a monitoring plan detailing parameters that will be monitored.

The results from this data will be reviewed and published annually. The report will review

performance over the previous year and will set targets for subsequent years.

15.4.5 Managing Changes

Changes in the Project may occur due to unanticipated Project developments. Wherever

possible, the environmental and social mitigation measures that have the potential to impact

design have been passed to the relevant design contractors during the ESIA process. As the

ESIA progressed, certainty regarding the nature and magnitude of impact sources became

clearer and the relevant changes were made to the ESIA Report. Adaptive changes may also

occur during Project commissioning and operations.

The Project will implement a formal procedure to manage changes that will apply to all Project

activities. The process for dealing with Project changes and uncertainty recognises three levels

of change/uncertainty:



Level One: Minor Significance, where the change or uncertainty is largely deemed to be

immaterial to the ESIA findings, and does not affect the Project’s ability to meet

environmental and social performance requirements outlined in the ESMP. This change

may require additional but limited environmental or social study or survey activities.

Level Two: Moderate Significance, where the change or uncertainty is deemed to be

material to the ESIA findings, but is within the boundaries of the defined Project base-case

covered by the ESIA. This may require minor changes to the ESMP and additional surveys

or environmental and social assessments.

Level Three: Higher Significance, where a future significant change or uncertainty leads

to a departure from the base-case, or a key aspect of it. An addendum to the ESIA, or a

new ESIA and formal submission and approval process, is then required.

The above mentioned process will ensure that the Project is able to adapt to changes whilst

meeting the relevant environmental and social performance requirements.

15.4.6 Communication to Stakeholders

As noted during the various phases of the stakeholder consultation programs, the Project is

committed to engaging with and reporting to all stakeholders. As part of the project financing, an

independent environmental and social consultant is anticipated to be hired by the project

lenders. Their auditing reports will be shared with stakeholders in a transparent manner, as they

become available.

Documents

CHAPTER 15 1/CHAPTER 15... · CHAPTER 15 ENVIRONMENTAL AND SOCIAL MANAGEMENT ... 15-13 15.4.5 Managing Changes ... start-up and operations,