REPORT Central Térmica de Temane Project - Operational Environmental and Social Management Plan (o-ESMP) Moz Power Invest, S.A. and Sasol New Energy Holdings (Pty) Ltd Submitted to: World Bank Group Submitted by: Golder Associados Moçambique Limitada 6th Floor, Millenium Park Building, Vlademir Lenine Avenue No 174 Maputo, Moçambique +258 21 301 292 March 2019 March 2019 Distribution List 1 x electronic copy World Bank Group 1 x electronic copy SNE, EDM and TEC 1 x electronic copy e-projects library projectreports@golder.co.za 1 x electronic copy Golder project folder i March 2019 Table of Contents 1.0 INTRODUCTION ......................................................................................................................................... 1 1.1 Scope of the o-ESMP ........................................................................................................................ 3 1.2 Objectives of the o-ESMP ................................................................................................................. 3 1.3 Details of the Proponent .................................................................................................................... 3 1.4 Gas to Power Plant and Key Infrastructure during operation ........................................................... 7 1.5 Safety, Health and Environmental (SHE) Policy ............................................................................. 10 1.6 Community Engagement Principles ................................................................................................ 10 1.7 Purpose of this Document ............................................................................................................... 11 2.0 ENVIRONMENTAL MANAGEMENT STRUCTURE ................................................................................ 11 2.1 Organisational Structure and Responsibility ................................................................................... 11 2.2 Liaison, Co-ordination and Reporting ............................................................................................. 14 2.3 Environmental and Social Management System (ESMS) .............................................................. 14 3.0 ACTIVITY AND IMPACT MANAGEMENT PLAN .................................................................................... 15 3.1 Background to Environmental Impact Mitigation and Management ............................................... 15 3.2 Environmental Management Requirements .................................................................................... 16 3.3 Administration and General Issues ................................................................................................. 17 3.4 Employment and Labour Management ........................................................................................... 23 3.5 Community, Stakeholder and Government Liaison ........................................................................ 25 3.6 Office Management ......................................................................................................................... 35 3.7 Mosquito / Vector Control ................................................................................................................ 36 3.8 Medical Services and Facilities ....................................................................................................... 38 3.9 Water and Effluent Management .................................................................................................... 42 3.10 Waste Management ........................................................................................................................ 46 3.11 Business Services ........................................................................................................................... 52 3.12 Commissioning and Initial Start-up, Start-up following Shutdowns ................................................ 53 3.13 Operation CTT................................................................................................................................. 54 3.14 Maintenance of CTT & Transmission Line ...................................................................................... 59 3.15 Hazardous Materials / Spill Management ....................................................................................... 63 3.16 Upset Condition Management......................................................................................................... 66 ii March 2019 3.17 Land Use Controls .......................................................................................................................... 67 3.18 Corporate Social Investment ........................................................................................................... 68 3.19 Decommissioning ............................................................................................................................ 69 4.0 PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION ................................................. 71 4.1 Environmental Monitoring Strategy ................................................................................................. 71 4.2 Site Inspection and Audits ............................................................................................................... 81 4.2.1 Site Inspections ........................................................................................................................... 81 4.2.2 Audits .......................................................................................................................................... 81 4.3 Reviews ........................................................................................................................................... 82 4.4 Corrective and Preventive Action .................................................................................................... 82 5.0 COMPETENCY, TRAINING AND AWARENESS CREATION ................................................................ 83 6.0 CONTINGENCY AND DECOMMISSIONING PLANNING ....................................................................... 83 7.0 EMERGENCY PREPAREDNESS AND RESPONSE .............................................................................. 84 8.0 REPORTING REQUIREMENTS ............................................................................................................... 84 9.0 DOCUMENT CONTROL ........................................................................................................................... 84 TABLES Table 1: Proponent details .................................................................................................................................... 3 Table 2: Objectives of mitigation measures for adverse environmental impacts ............................................... 15 Table 3: Air Quality Monitoring programme ........................................................................................................ 72 Table 4: GHG emissions monitoring programme ............................................................................................... 73 Table 5: Groundwater Monitoring programme ................................................................................................... 74 Table 6: Noise Monitoring programme ............................................................................................................... 75 Table 7: Environmental Risk Monitoring Plan .................................................................................................... 75 Table 8: Social Welfare Monitoring programme ................................................................................................. 76 Table 9: Soil, Land use and Land Capability Monitoring Program ..................................................................... 77 Table 10: Surface water Monitoring programme ................................................................................................ 78 Table 11: Ecological Monitoring programme ...................................................................................................... 79 Table 12: Visual Intrusion Monitoring programme - CTT plant .......................................................................... 80 Table 13: Minimum auditing requirements for the operational phase of the CTT and associated infrastructure ............................................................................................................................................................................ 81 FIGURES iii March 2019 Figure 1: Project Location ..................................................................................................................................... 2 Figure 2: CTT Head Office operational phase organogram ................................................................................. 5 Figure 3: CTT plant operational phase organogram ............................................................................................ 6 Figure 4: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) ........... 7 Figure 5: CTT Key Infrastructure .......................................................................................................................... 8 Figure 6: Conceptual layout of CTT plant site ...................................................................................................... 9 iv March 2019 ABBREVIATIONS AND DEFINITIONS Acronym or Description Abbreviation ARA-Sul Mozambique Regional Water Administration (Administração Regional das Águas do Sul) – southern area BTEX Benzene, Toluene, Ethylbenzene and Xylene Compressor A device that uses external energy to impart internal energy into the sales gas in order to raise sales gas pressure by creating a greater differential pressure between export point to delivery point and so allowing the gas to flow through the pipeline (gas pumping device) Contractor Construction and service provider personnel appointed by CTT to work on the project CPF Central Processing Facility CPF Complex Consists of original producing assets of the Central Processing Facility under the expansion introduced in the NATGAS 183 project, the CPF Facilities Upgrade Project and the Liquids Processing Facility and 5th Gas Train CSI Corporate Social Investment Drain system: Closed Essentially for containment of process liquids. These liquids are all re-directed Drain System back into the liquid separator. These liquids are also known as “spill back” liquids DRP Decommissioning and Rehabilitation Plan EC Electrical Conductivity Effluent A liquid or waste water flowing out of a reservoir or sewer or purification works that may contain particulates, sediment, chemicals or waste matter ESIA Environmental and Social Impact Assessment EIS Environmental Impact Study ESMP Environmental and Social Management Plan. (c-ESMP – construction ESMP; o-ESMP – operations ESMP and d-ESMP – decommissioning ESMP) ESMS Environmental and Social Management System Environmental Consultant An independent environmental consultant with experience in the environmental management of industrial projects Environmental and Social (i) Defines the measures to be taken during the life of a project, including Management Plan (ESMP) design, construction, operation and decommissioning to prevent and/or manage adverse environmental and social impacts; (ii) defines the actions needed to implement these measures; (iii) describes how this will be achieved v March 2019 Acronym or Description Abbreviation (iv) describes how this will be monitored, (v) defines inspection and auditing schedule Environmental and Social A systematic, documented and objective evaluation of the environmental Management Plan Audit performance of a project by objectively obtaining and analysing evidence to determine whether the implementation of the ESMP conforms to its requirements Environmental and Social The part of the overall management system that includes organisational Management System structure, planning activities, responsibilities, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining an environmental policy ESO Environmental Site Officer Glycol A chemical used during pigging that has an affinity for water Government The National Government of Mozambique Hazardous waste Waste bearing risk characteristics for being flammable, explosive, corrosive, toxic, infectious or radioactive, or for showing any other characteristic that constitutes hazard for the life and health of mankind and other living creatures and for environmental quality HIV/AIDS Human Immunodeficiency Virus / Acquired Immunodeficiency Syndrome HP High Pressure IBRD International Bank for Reconstruction and Development km Kilometres km2 Square kilometres LOCSA CTT Liaison Officer – Community and Stakeholder Affairs LP Low Pressure Liquid Separator A device or vessel that can contain combined condensate and water for a sufficient retention time that allows both liquids to separate physically. The use of demulsifiers may be required to break the emulsion depending on the quantity of combined liquid intake M Metres MSDS Material Safety Data Sheet MICOA Ministry for the Co-ordination of Environmental Affairs, Mozambique MITADER Ministry of Land, Environment and Rural Development (replaces MICOA) vi March 2019 Acronym or Description Abbreviation Non-hazardous waste Waste with no risk characteristics, including but not exclusive to paper or paperboard, plastic, glass, metal, domestic rubbish, metal scrap and organic matter. Also known as domestic waste. NOx Oxides of Nitrogen NTS Non-Technical Summary OHSAS Occupational Health and Safety Assessment Specification Open Drain System Essentially for the direction of storm water and non-contaminated utility water Operations All operations related to the CTT plant, gas pipeline, water pipeline and Transmission line PAC Public Affairs Coordinator Pipeline Essentially a transmission device that maintains containment of product (i.e. refined gas or water) from source to end point. For CTT, this refers to an underground pipeline which carries gas or water to the CTT plant PPE Personal Protection Equipment PPZ Partial Protection Zone PSA Production Sharing Agreement POC Potentially Oil Contaminated: Liquids that may contain hydrocarbons cannot be allowed to flow into the open drain system. These liquids are directed through the POC system into the closed drain system and pumped back into the liquid separator Pigging The method used for cleaning flow lines and export lines and also displacing liquids from the said lines. Pigs are also used as internal condition monitoring devices within pipelines PS Performance Standard RPIP Resettlement Planning and Implementation Plan CTT Central Térmica de Temane SEPI Sasol Exploration and Production International (Pty) Ltd. SES Senior Environmental Specialist Sewage Treatment Plant A self-contained processing unit that is capable of removing suspended solids and bacteria from water to render it more suitable for any particular service / discharge. In this document it refers the plant that treats domestic sewage vii March 2019 Acronym or Description Abbreviation SHE Safety, Health & Environment VOC Volatile Organic Compounds WHO World Health Organisation viii March 2019 1.0 INTRODUCTION The Mozambican economy is one of the fastest growing economies on the African continent with electricity demand increasing by approximately 6-8% annually. In order to address the growing electricity demand faced by Mozambique and to improve power quality, grid stability and flexibility in the system, Moz Power Invest, S.A. (MPI), a company to be incorporated under the laws of Mozambique and Sasol New Energy Holdings (Pty) Ltd (SNE) in a joint development agreement is proposing the construction and operation of a gas to power facility, known as the Central Térmica de Temane (CTT) project. MPI’s shareholding will be comprised of EDM and Temane Energy Consortium (Pty) Ltd (TEC). The joint development partners of MPI and SNE will hereafter be referred to as the Proponent. The Proponent proposes to develop the CTT, a 450MW natural gas fired power plant. The proposed CTT project will draw gas from the Sasol Exploration and Production International (SEPI) gas well field via the phase 1 development of the PSA License area, covering gas deposits in the Temane and Pande well fields in the Inhassoro District and the existing Central Processing Facility (CPF). Consequently, the CTT site is in close proximity to the CPF. The preferred location for the CTT is approximately 500 m south of the CPF. The CPF, and the proposed site of the CTT project, is located in the Temane/Mangugumete area, Inhassoro District, Inhambane Province, Mozambique; and approximately 40 km northwest of the town of Vilanculos. The Govuro River lies 8 km east of the proposed CTT site. The estimated footprint of the CTT power plant is approximately 10 ha once built, although during construction approximately 20 ha will be required to accommodate the plant footprint as well as the construction camp and contractor’s laydown areas adjacent to the plant site (see Figure 1). Associated infrastructure and facilities for the CTT project will include: 1) Electricity transmission line (400 KV) and servitude; from the proposed power plant to the proposed Vilanculos substation over a total length of 25 km running generally south to a future Vilanculos substation. [Note: the development of the substation falls outside the battery limits of the project scope as it is part of independent infrastructure authorised separately. Environmental authorisation for this substation was obtained under the STE/CESUL project. (MICOA Ref: 75/MICOA/12 of 22 nd May 2012)]; 2) Piped water from one or more borehole(s) located either on site at the power plant or from a borehole located on the eastern bank of the Govuro River (this option will require a water pipeline approximately 11km in length); 3) Access road; over a total length of 3 km, which will follow the proposed water pipeline to the northeast of the CTT to connect to the existing Temane CPF access road; 4) Gas pipeline and servitude; over a total length of 2 km, which will likely start from the CPF high pressure compressor and run south on the western side of the CPF to connect to the power plant; 5) Additional nominal widening of the servitude for vehicle turning points at points to be identified along these linear servitudes; 6) A construction camp and contractor laydown areas will be established adjacent to the CTT power plant footprint (construction phase only); and 7) Transhipment and barging of equipment to a temporary beach landing site and associated logistics camp and laydown area for the purposes of safe handling and delivery of large oversized and heavy equipment and infrastructure to build the CTT. There are 3 beach landing site options, namely SETA, Maritima and Briza Mar. The SETA site is considered to be the preferred beach landing site (construction phase only); 1 March 2019 8) Temporary bridges and access roads or upgrading and reinforcement of existing bridges and roads across sections of the Govuro River where existing bridges are not able to bear the weight of the equipment loads that need to be transported from the beach landing site to the CTT site. Some new sections of road may need to be developed where existing roads are inaccessible or inadequate to allow for the safe transport of equipment to the CTT site. The northern transport route via R241 and EN1 is considered as the preferred transport route (construction phase only). Figure 1: Project Location 2 March 2019 1.1 Scope of the o-ESMP The facilities, infrastructure and activities that are covered by the o-ESMP include the following:  Gas to Power Plant with installed capacity of approximately 450MW;  Gas pipeline (±1-2 km) that will feed the Power Plant with natural gas from the CPF;  400kV Electrical transmission line (± 25 km in length) with a servitude of 100m that will include a fire break (vegetation control) and a maintenance road to the Vilanculos sub-station. The transmission line will have a partial protection zone (PPZ) of 100m width (i.e. 50m on either side of centre line). The transmission line servitude will fall inside the PPZ;  Water supply pipeline to one or more borehole(s) located either on site or at borehole(s) located east of the Govuro River;  Paved access road to the CTT site and gravel maintenance roads within the transmission line and pipeline servitudes. 1.2 Objectives of the o-ESMP This document is the operational Environmental and Social Management Plan (o-ESMP) for the CTT project. It covers the management of the operational phase of the CTT. This o-ESMP is derived from the ESIA and supporting specialist studies. The o-ESMP is intended to achieve the following objectives:  Provide a management plan for the operational activities of the CTT facilities in compliance with Mozambican legislative and regulatory requirements, as well as International standards and best practice.  Ensure that measures stipulated in this document are in place and executed fully to appropriately manage impacts in order to reduce negative impacts and enhance positive impacts/benefits arising from the operation of the CTT;  Provide requirements for assessment, monitoring and auditing, during operations. 1.3 Details of the Proponent Moz Power Invest, S.A. (MPI), a company to be incorporated under the laws of Mozambique and CTT New Energy Holdings (Pty) Ltd (SNE) in a joint development agreement is proposing the construction and operation of a gas to power facility, known as the Centr al Térmica de Temane (CTT) project. MPI’s shareholding will be comprised of Electricidade de Mozambique E.P. (EDM) and Temane Energy Consortium (Pty) Ltd (TEC). Table 1: Proponent details MPI SNE Moz Power Invest S.A. (MPI) Sasol New Energy Holdings (To be incorporated) (Pty) Ltd (SNE): EDM TEC Hubert Naude Business Development Manager Electricidade De Moçambique (EDM) Temane Energy Corporation: Tel: +27 (0)10 344 5432 Fax: +27 (0)11 522 1175 Pedro Nguelume Globeleq Email: hubert.naude@sasol.com Project Director Ian Potgieter Tel: + 258 84 46 46 853 Business Development Manager 3 March 2019 MPI SNE Fax: + 258 21 32 82 33 Tel: +27 (0) 12 443 6511 Email: pnguelume@edmdipla.co.mz Email: ian.potgieter@globeleq.co.za Dr. Aly Sicola Impija Jonathan Frick EDM Board Member Business Development Manager Tel: +258 2135 36 15 Tel: +27 (0) 21 180 4595 Fax: +258 2149 1040 Email: jon.frick@globeleq.co.za Belarmina Mirasse EleQtra Environmental Manager Lauren Thomas Tel: +258 2135 3615 Developer Fax: +258 2135 3694 Tel: +258 85 363 7639 Email: Email: Lauren.Thomas@eleqtra.com mailto:belarmina.Mirasse@edm.co.mz 4 March 2019 Operational Phase Organogram: General Manager Office Administrator SHE Manager O&M HR Manager Financial Manager Manager HR Administrator 4x Procurement Commercial IM/IT Accountants & Supply chain Personnel based at operating site Total staff at Head Office = 12 Figure 2: CTT Head Office operational phase organogram 5 March 2019 OEM Contracts O&M Manager SHE Manager Manager Accountant Office Administrator Maintenance Procurement & Operations Manager Manager Supply Chain Shift Coordinator Store man [3] Shift Supervisor Mechanical Electrical Engineer Trainer General Workers [4] Engineer Control Room Operator [4] SHE Officer Electrical Artisan [4] [2] Rotating Equipment Fitter [2] Power Plant Operator [5] Control Systems Technician [2] Mechanical Fitters [6] 4xShifts Owner Appointed Personnel Maintenance Assistants [6] To transition to owner after 1 year Total Staff at site = 85 Helpers [4] To transition to owner after 3-5 years Figure 3: CTT plant operational phase organogram 6 March 2019 1.4 Gas to Power Plant and Key Infrastructure during operation The Central Térmica De Temane (CTT) project will produce electricity from natural gas in a power plant located 500m south of the CPF. The project will consist of the construction and operation of the following main components (Figure 5):  Gas to Power Plant with installed capacity of approximately 450MW;  Gas pipeline (±1-2 km) that will feed the Power Plant with natural gas from the CPF;  400kV Electrical transmission line (± 25 km in length) with a servitude of 100m that will include a fire break (vegetation control) and a maintenance road to the Vilanculos sub-station. The transmission line will have a partial protection zone (PPZ) of 100m width (i.e. 50m on either side of centre line). The transmission line servitude will fall inside the PPZ;  Water supply pipeline to one or more borehole(s) located either on site or at borehole(s) located east of the Govuro River;  Paved access road to the CTT site and gravel maintenance roads within the transmission line and pipeline servitudes; Figure 4: Examples of gas to power plant sites (source: www.industcards.com and www.wartsila.com) The final selection of technology that will form part of the power generation component of the CTT project has not been determined at this stage. The two power technology options that are currently being evaluated are:  Combined Cycle Gas Turbine (CCGT); and  Open Cycle Gas Engines (OCGE). Once a technology and vendor is selected this ESMP must be updated accordingly. 7 March 2019 Figure 5: CTT Key Infrastructure 8 March 2019 Figure 6: Conceptual layout of CTT plant site 9 March 2019 1.5 Safety, Health and Environmental (SHE) Policy The CTT shall implement a Safety, Health and Environmental Policy declaration that sets the framework for an integrated management system for the Operations. All visitors, contractors and employees are required to comply with the requirements of the policy declaration. CTT management and staff shall fully subscribe to the SHE policy declaration and shall demonstrate commitment to the policy by:  Developing and implementing an integrated management system that will comply with the requirements of the OHSAS 18001 Occupational Health & Safety, and ISO 14001 Environmental Management Systems;  Subjecting itself to third party audits conducted by an internationally recognised certification body as part of their drive towards continual improvement;  Accepting and complying with Corporate Governance requirements, Mozambican SHE - related legislation, all Financing obligations (including WB/IFC PS) and any appropriate, recognised, industry codes of practice;  Engaging with the Mozambican Government regarding the implementation framework for any new legislation that affects the CTT and its activities;  Influencing suppliers and contractors to conform as a minimum to the Mozambican SHE - related legislation and to respect and adhere to the CTT codes of practice;  Sharing and communicating relevant information about safety, health and environmental performance with interested and affected parties, employees and authorities in an open and transparent manner, and making this declaration available by displaying it in all office buildings and in the induction training;  Minimising risks associated with its activities which may impact on the health and safety of its employees, communities and the environment;  Enhancing the general awareness of its employees and contractors to ensure understanding of all the SHE risks and impacts associated with their work activities;  Preventing pollution, accidents, injuries and ill health through setting and reviewing objectives and programmes;  Responding effectively to safety, health and environmental emergencies;  Providing appropriate resources to implement the above commitments;  Reviewing such a declaration of intent on an acceptable basis or as and when required by CTT SHE Governance structure. 1.6 Community Engagement Principles CTT shall engage communities based on the following principles:  Community involvement and ownership;  Strengthen community leadership;  Targeted impacts-driven interventions;  Addressing key community priorities;  Strategic research informed interventions;  Monitoring and evaluation; and 10 March 2019  Building capacity through partnership. 1.7 Purpose of this Document This document is the operational Environmental and Social Management Plan (o-ESMP) for the CTT project. It covers the management of the operational phase of the CTT. This o-ESMP is derived from the ESIA and supporting specialist studies. 2.0 ENVIRONMENTAL MANAGEMENT STRUCTURE 2.1 Organisational Structure and Responsibility The overall organisational structure for environmental and social management for the CTT facility has not yet been finalised, however the following principal roles and responsibilities of each key party within this structure is expected as follows: All parties All parties shall comply with all the requirements of the CTT operations ESIA and ESMP and shall, in accordance with accepted industry standards and the World Bank, employ such up to date techniques, practices and methods that will ensure compliance to the requirements and, in general, minimise environmental damage, control waste, avoid pollution, prevent loss or damage to natural resources and minimise effects on surrounding landowners, occupants and the general public. All parties shall prevent or minimise the occurrence of accidents which may cause damage to the environment, prevent or minimise the effects of such accidents and shall return the environment to a state as close to the condition existing prior to any such accident as possible. All parties shall take proactive steps to ensure that the requirements in the ESMP are met during operation. These shall include, but not be limited to, the following:  Employment of competent and dedicated members of staff to oversee the implementation of the ESMP.  Instruction of staff about the relevant environmental aspects and the specific measures that each employee will implement to meet the environmental protection and management standards defined by the ESMP. This will also require adequate oversight of the implementation and management of the Resettlement Policy Framework (RPF). The Sponsor will be responsible to ensure that the RAP/ARAP/LRP is implemented according to requirements of MITADER as well as the WBG requirements (PS5). Operations Manager: The Operations Manager shall ensure that all parties comply to all the CTT requirements of the ESIA and ESMP and shall, in accordance with Mozambique Legislation, accepted standards of the international petroleum, oil and gas industry and the World Bank, employ such up to date techniques, practices and methods of Operations that will ensure compliance to these requirements and, in general, minimise environmental damage, control waste, avoid pollution, prevent damage to natural resources and minimise effects on surrounding landowners, occupants and the general public. Ensure the provision of sufficient and suitable resources both on and off-site to ensure that pollution is prevented, waste minimised and the rights of the environment protected. Ensure compliance to all applicable environmental legislation and commitments at all times. Ensure the implementation of an environmental management system to achieve all of the above. Assume responsibility for all decisions on all environmental matters. 11 March 2019 The Operations Manager shall establish systems and approaches to prevent or minimise the occurrence of accidents which may cause damage to the environment, prevent or minimise the effects of such accidents and shall return the environment to a state as close to the condition existing prior to any such accident as possible. The Operations Manager shall take proactive steps to ensure that the standards in the ESMP are met during operation. These shall include, but not be limited to, the following:  Employment of competent and dedicated members of staff to oversee the implementation of the ESMP; and  Instruction of staff about the relevant environmental sensitivities and the specific measures that each employee will implement to meet the environmental protection and management standards defined by the ESMP. The Operations Manager shall ensure the availability of sufficient and suitable resources to ensure the aforementioned. This will also require adequate oversight of the implementation and management of the Resettlement Policy Framework (RPF). The Sponsor will be responsible to ensure that the RAP/ARAP/LRP is implemented according to requirements of MITADER as well as the WBG requirements (PS5). Production Manager: The Production Manager shall be responsible for: Monitoring; defining CTT contingency measures; achieving continual improvement; and tracking all issues related to environmental management and performance for CTT operations. The Production Manager shall support the Operations Manager and SHE Manager in environmental management. He/she shall be responsible for meeting the standards of operation to ensure environmental performance and compliance. The Production Manager shall assume the responsibilities of the Operations Manager in the absence of the latter. SHE Manager: CTT The SHE Manager is responsible for providing overall governance for SHE matters relating to CTT’s operations, including the management of resources such as the SES by providing guidance and support and monitoring progress against established work plans to meet defined environmental targets and objectives. He/she will ensure strategic planning with regard to medium and long-term environmental and social management for CTT operations by:  Ensuring compliance with the approved ESMP for CTT’s operations  Ensuring that the ISO 14001 standard requirements are in place  Ensure that the environmental parameters are monitored as per the o- ESMP requirements.  Ensuring accurate and timeous reporting on environmental performance, analysing trends and ensuring that measures are in place to address deviations.  Ensuring that all environmental incidents are reported and investigated and that measures are in place to prevent recurrence.  Chairing the environmental task team meetings and ensuring that actions are allocated to responsible persons and that close-out is monitored in CTT’s ESMS  Ensuring that a regular meeting platform is created where environmental performance is discussed at employee and management level  Ensuring that the environmental audit and inspection programme is carried out  Periodically reviewing the CTT SHE Strategy 12 March 2019  Investigate Health and Safety incidents and near misses  Monitor Health and Safety Performance  Compile and verify regular environmental performance reports produced for CTT management and external stakeholders such as MITADER or Lenders (the Resettlement Policy Framework (RPF) and any tools such as the RAP/ARAP/LRP.).  Conduct regular site visits, environmental audits and inspections (encompassing Environmental, Social, Health and Safety aspects).  Review environmental performance, ensuring that action plans are in place to address non-compliance and that issues are investigated and reported to the appropriate levels within the organisation.  Initiate, co-ordinate and manage all environmental related communication with the Government (local, provincial and national) on environmental matters.  Liaising with the CTT Operations, and Public Affairs/CSI Manager.  Providing advice and support to the CTT Operations Manager and Senior Environmental Specialist (SESS) and public affairs or CSI officers as required.  Keeping abreast of local, regional and national developments in the environmental field  Ensuring that the independent environmental monitoring activities are regularly conducted, the reports analysed and measures put in place to address trends. Senior Environmental The SES will act as a guide and advisor to employees and contractors on and Social Specialist environmental issues associated with CTT’s operations. This will be achieved (SESS): CTT by ongoing inspections / auditing of Operations, identification of problem areas and provision of actions plans to ensure environment protection. The SES will ensure compliance to the requirements of the ESMP by all parties, as well as with any other requirements related to environmental issues as they become known. Specific responsibilities of the SES will be as follows:  To thoroughly familiarise him/herself with existing information regarding operations area and the ESMP.  Ensure the protection of the biophysical and social environment.  Maintain CTT’s ISO14001 Environmental Management System and ensure that CTT retains its certification  Perform all of the day-to-day tasks necessary to monitor performance with regard to the requirements of the ESMP and any other relevant requirements and / or commitments.  Update the ESMP based on requirements of operations, the Government or internal CTT requirements.  Monitor the impact of operations on the environment with particular emphasis on areas of environmental sensitivity.  Audit compliance by employees, contractor(s) and suppliers with this environmental standard.  To liaise with the Operations Manager and SHE Manager in the case of incidents, non-compliance or any matter where the course of action is unclear.  Prepare environmental audit reports documenting the effectiveness of environmental management, problem areas, remedial actions proposed and taken and compliance/non-compliance by the Contractor(s) with the Operations standard. 13 March 2019  Verify the accuracy of the information contained in the ESMP and to bring any errors, omissions, oversights to the attention of all parties as necessary.  Compile regular environmental performance reports which include trend analysis and which identify areas and actions for improvement.  Commission and oversee the execution of regular independent environmental monitoring activities. The SES should have adequate and relevant training in environmental management and will be required to be able to evaluate the effectiveness of specified management measures and be familiar with environmental management techniques. He / she should be able to propose solutions to problems identified as regards the implementation of the plans. The SES will liaise closely with the Operations Manager, the Production Manager, the SHE Manager, and the environmental supervisors of all appointed contractors. The SES will be based on site. Environmental Site The ESO is responsible for assisting the SESS in day to day environmental Officer (ESO): CTT management responsibilities at the CTT. Safety The Safety Practitioner shall assist the SES in the environmental Practitioner/Officer: management on the Plant, with a specific focus on health a safety issues, CTT including emergency response and contingency planning. The Safety Practitioner shall also undertake the inductions on site which include environmental aspects, as well as assisting the SES with the environmental awareness and training associated with ISO14001. The Safety Practitioner will liaise closely with the Operations Manager, the Production Manager and the SHE Manager. The Safety Practitioner will be based at site. Public Affairs To design and manage effective information dissemination and constructive Coordinator (PAC): engagement with District Government and community leaders in the CTT CTT zone of influence CTT Liaison Officer – CTT Liaison Officer – Community and Stakeholder Affairs (LOCSA). The CTT Community and officer responsible for all ongoing communications with communities and Stakeholder Affairs stakeholders affected by CTT’s operations in Mozambique. (LOCSA) The core competencies and job descriptors of the LOCSA/CLO need to reflect the substantive role of CLOs (or other project social specialists) in implementing the social management plans and social aspects of the mitigation measures beyond purely communications in a manner more comparable to the role of the ESO. Environmental An individual or company appointed for specific expertise to undertake Consultant monitoring, auditing and / or to provide CTT with independent advice, as required. 2.2 Liaison, Co-ordination and Reporting The structure for all communication, correspondence and reporting between Operations stakeholders will be as per the overall Operations organisational structure (for environmental and social responsibilities) will need to be finalised prior to construction of the project and must be updated here. 2.3 Environmental and Social Management System (ESMS) There are three main tools for environmental and social management at the CTT: 14 March 2019  The Environmental and Social Impact Assessment / Study (ESIA);  The Operational Environmental and Social Management Plan (o-ESMP); and  The Environmental and Social Management System (ESMS). In addition, the ESMS will include the construction ESMP and decommissioning ESMP’s. The ESMP is intended to guide impact management and mitigation associated with the CTT. It converts ESIA mitigation measures into actions and allocates responsibility and deadlines to those actions. The ESMS confirms management commitment to the ESMP and describes how the requirements of the ESMP will be achieved. It sets the management framework in terms of environmental organisational structure, reporting, review and monitoring, training and public disclosure. The Operations Manager, in conjunction with the SHE Manager is to ensure that a suitable management system is implemented to ensure compliance (and be able to demonstrate compliance) to the ESMP. A comprehensive ESMS aligned to IFC ESMS Implementation Handbook – General (2015) and ISO 14001:2015 standards will be developed and implemented, inclusive of the following system elements: 1) Policy; 2) Identification of Risks and Impacts; 3) Management Programmes; 4) Organisational Capacity and Competency; 5) Emergency Preparedness and Response; 6) Stakeholder Engagement; 7) External Communications and Grievance Mechanisms; 8) Ongoing Reporting to Affected Communities; and 9) Monitoring and Review. 3.0 ACTIVITY AND IMPACT MANAGEMENT PLAN This section presents specific environmental management requirements for the operational phases of the CTT and associated infrastructure. 3.1 Background to Environmental Impact Mitigation and Management For environmental management to be effective the primary focus of this management must be placed on managing activities so as to prevent or minimise the occurrence of negative impacts. Environmental management measures can be varied and the measures themselves may have a variety of objectives, however the first priority is always to prevent adverse impacts, thereafter management measures with other objectives should be considered. The various objectives for management measures should be remembered when using this Environmental Management Plan. First priority is avoidance of negative impacts; the objectives are listed in decreasing order of priority. Table 2: Objectives of mitigation measures for adverse environmental impacts Avoidance Avoiding activities that could result in adverse impacts. Avoiding resources or areas considered as sensitive. Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence having negative environmental impacts. 15 March 2019 Preservation Preventing any future actions that might adversely affect an environmental resource. Typically achieved by extending legal protection to selected resources beyond the immediate needs of Operations. Minimisation Limiting or reducing the degree, extent, magnitude or duration of adverse impacts. This can be achieved by scaling down, relocating, redesigning elements of Operations. Rehabilitation Repairing or enhancing affected resources, such as natural habitats or water sources, particularly when previous development has resulted in significant resource degradation. Restoration Restoring affected resources to an earlier (and possibly more stable and productive) state, typically ‘background / pristine’ condition. Compensation Creation, enhancement or protection of the same type of resource at another suitable and acceptable location, compensating for lost resources. 3.2 Environmental Management Requirements The management requirements presented in this section have been compiled based on activities required during the operational phase of the CTT. While specifications have been listed under activities, the requirements are not necessarily mutually exclusive to the activity under which the specification or requirement is listed. Should any specification be applicable to any other activity, listed or otherwise, the intent remains. For each activity identified, the following items are specified in the management plan: Ref.: A reference number for the specified management requirement / specification. Management requirements: Detail on the management requirements / specifications required. Responsible party: The person that will assume overall responsibility for ensuring that the requirement / specification is met. Scheduling: The date by which the requirement shall be achieved. Should the requirement be applicable throughout the life of Operations or a period thereof, the date will be indicated as ‘ongoing’. Compliance/Performance indicator(s): Indicates means to determine if the requirement has been met and verified. Additional monitoring requirements are specified under Section 4. Note that the number of incidents, audit findings etc. shall also be used as indicators of performance. 16 March 2019 3.3 Administration and General Issues Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification 3.3.1 Release of Relevant SHE requirements extracted from the Supply Chain (SC) At the time of release of Inclusion of ESMP as contracts ESMP will be included as part of tender Manager requests for quotation. part of relevant tenders At the time of contract (RFT) and contracts. documentation and form part of contracts when the scope of the work to be conducted or service preparation. to be provided can impact on the environmental performance of the CTT. 3.3.2 Procurement of The CTT will develop its own Local Content SC Manager Ongoing Local suppliers in goods and Policy (taking into consideration any relevant service provider list services Mozambican laws relevant at that time), focused Register and on stimulating economic growth throughout the percentage of value chain and creating opportunities for those procurement in who do not work at the CTT plant. In line with communities, the District CTT’s local content policy, which will cover a and Province, and range of categories, from highly specialised to nationally the commoditised. Local content is an integral part of tender evaluation criteria in major projects. Thus, goods and services should be procured whenever possible and whenever these meet established requirements in communities and the District and Province. The Local Content Plan shall prohibit the purchase of bushmeat or other local wildlife products in any quantity, as well as any bulk purchases of local fish (to 17 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification avoid increasing local fishing pressures in the BANP or other sensitive marine habitats). 3.3.3 Procurement of CTT shall build capacity in the local area for SC Manager Ongoing Goods and services goods and provision of goods and simple services to the CSI Manager purchased locally as a services CTT complex. result of CTT capacity building 3.3.4 Compliance to In all cases, the requirements of Mozambican Operations Manager Ongoing Legal update system legislation legislation will be met. SHE Manager Legal register SES Audit findings Absence of legal warnings / prosecutions / fines. 3.3.5 Legal register Develop, annually review and where necessary Operations Manager Register updated on a Legal register update a legal register identifying all SHE Manager regular basis. document. environmental legislation relevant to the SES Permit / licence register. operation. This register shall describe the ESO relevance of applicable legislation to Operations as well as any permits / licenses that may be required. A register of all permits and licences (and associated conditions) issued to CTT for Operations shall be maintained, with copies of the permits held in Document Control. The register should include date of issue and date of expiry. 18 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification 3.3.6 Environmental Implement an environmental management Operations Manager Ongoing Maintain ISO14001 management system for Operations that is compliant with the SHE Manager certification requirements of ISO 14001 and IFC/WBG. SES system Conduct regular surveillance audits to ensure ESO compliance with EMS requirements. 3.3.7 Personnel An appropriate environmental and social ESO Ongoing Environmental and management awareness programme shall be implemented on Safety Practitioner social awareness site so as to ensure that all employees and programme contractors are aware of their environmental and CTT induction social responsibilities. programme includes The site induction programme shall address the environmental and key environmental and social aspects associated social requirements with CTT’s operations. 3.3.8 Disturbance of A “Chance Find Procedure” has been developed ESO Ongoing As per requirement. archaeological or as a management tool for cultural heritage Chance Find Procedure developed and available cultural sites (e.g. impacts, in accordance with the guidelines set Inclusion in training / graves) / out in IFC Performance Standard 8 and must be induction programme(s). collecting consulted and implemented as needed. Records on process specimens or followed artefacts Should any archaeological or cultural sites be discovered this shall be reported to the SES and LOCSA who shall determine a course of action based on the Chance Find Procedure, consultation with local, provincial and national government, as necessary. Records shall be 19 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification kept to document the process followed and measures taken. 3.3.9 Collecting or All employees shall be prohibited from collecting Safety Practitioner Ongoing Absence of complaints. harvesting fruits, or harvesting fruits, vegetables, grains and any SHE vegetables, grains other plant material outside of the battery limits and any other of the CTT. plant material 3.3.10 Hunting / No employee or contractor may hunt, harass, Safety Practitioner Ongoing Absence of complaints. harassing / poach or keep wild animals. ESO poaching / keeping wild animals 3.3.11 House-keeping At all times the CTT complex, will be maintained Production Manager Ongoing Absence of litter on site. in tidy order. No littering will be permitted. Where ESO Containers with lids necessary, open containers shall be covered with lids or netting to prevent the occurrence of wind-blown litter. 3.3.12 HIV/Aids, sex The presence of sex-workers inside the CTT SHE Manager Ongoing Absence of sex workers worker complex boundary is prohibited. on site. Reduction in sex management The presence of sex-workers outside of the CTT workers in communities and campsite must be actively discouraged: from numbers present Communicate and coordinate with District health during construction. personnel to align with and supplement existing Number and nature of 20 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification programs to prevent or reduce sexually communication and awareness initiatives transmitted diseases. Implement a concerted Visual observations. program of information provision and awareness Number of CSI projects creation to prevent or reduce sexually focusing on prevention transmitted diseases. Work with health centres, or treatment of sexually churches, health workers and other respected transmitted diseases. community leaders to ensure awareness Number of condoms distributed messages have credibility. Develop awareness Annual survey amongst materials in the local language that can be men, women and displayed on notice boards and distributed in church leaders in terms communities. of whether condoms Condoms must be distributed free of charge to were used and if not, the reasons employees, contractors and visitors and should Number of people be readily available. provided with voluntary counselling and testing Number of communication/awarene ss initiatives in the communities Increase or decrease in the percentage of people with HIV/AIDs or other sexually transmitted diseases in the communities, and number of people treated Increase or decrease in 21 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification the number of people on the antiretroviral program, and how long they stay on the program. 3.3.13 Diseases Continue with mitigation measures currently Doctor Ongoing Health indicators to undertaken in coordination with District monitor selected and agreed with District authorities and with the specialist advice of a Government health impact assessment professional and Monitoring of health following international guidelines, develop a set indicators of defendable indicators and a monitoring Improvement in health program for monitoring health in affected indicators annually communities. 3.3.14 Site lighting No lighting at the plant shall be directed away Operations Manager Ongoing Absence of complaints from the site so as to cause a disturbance to SHE Manager from surrounding communities. surrounding inhabitants. Periodic inspections of lighting effects 3.3.15 Advertising and / CTT shall ensure that road-side advertising is SHE Manager Prior to erecting any Government approvals or signage on well considered so as to cause minimal visual Communication road-side advertising for roadside advertising. pollution as well as negligible driver distraction. roads Manager CTT shall ensure that it has obtained all relevant Government approvals for the erection of signage along public access routes. 22 March 2019 Ref. Activity Requirements / specifications Responsibility Completion Date or Compliance Scheduling indicator(s) or verification 3.3.16 Bush fire A procedure for the prevention and control of SHE Manager Ongoing Implementation of a fire prevention and bush fires shall be prepared. The procedure prevention and fire shall include, but not be limited to, the following: management emergency ▪ Sources of fire risk management procedure. ▪ Measures to comply with any requirements of local authority fire departments ▪ Measures to minimise the risk of accidental bush fires caused by any activity related to the works Measures to control an accidental bush fire. 3.4 Employment and Labour Management Labour and employee management will include compliance with Mozambican laws, ILO Labour Standards and World Bank OP 4.03/PS2, including adequate contracts, minimum wages, health care, adequate disability/ fatality insurance, etc. Additionally, the labour and/or employment contracts and policies will include guidance for employees and contractors in terms of community relations requirements, and guidelines for contractors (and subcontractors) on child and forced labour. These will also include codes of conduct with sanctions against adverse behaviour (drug and alcohol use, disregard for safety rules on and off site) and against Gender-based violence, sexual harassment and abusive behaviour. Codes of Conduct will need be signed by all workers and employees in order to avoid and sanction misbehaviour of workers, including sexual harassment, gender-based violence and sex with minors, drug abuse, hunting, wildlife capture, improper waste disposal, etc. CTT will provide Worker’s /Employee manuals and training protocols to inform workers/employees of their rights and responsibilities, including grievance redress and channels for communication. 23 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.4.1 Employment Employment shall be undertaken and managed HR Manager Ongoing Statistics reflecting according to Mozambican labour law and CTT’s percentage approved labour agreement with the Mozambican Mozambican Government and a specific Project employees. Labour Agreement with the Union, which support Training records. localisation of labour (taking into consideration CSI Projects supporting World Bank Group policies and standards on education and training labour). of Mozambicans. In particular, employment and skills development of Mozambican employees is an important success factor and therefore local labour shall be utilised as far as possible and within the constraints of Mozambican law. This shall be complimented with applicable skills training. Directly affected communities should be given special consideration in terms of the benefits arising from the project. The local resident status of applicants should be verified in consultation with a community representative. Where feasible, promote the creation of employment opportunities for women and youth. 3.4.2 Employee CTT shall ensure proper supervision / HR Manager Ongoing Inspection findings. supervision and management of employees, including after-hours Audit findings. training where employees are resident on site. 24 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification Employees shall all receive adequate training based on the activities they undertake and the associated SHE risks. Training shall also comply with any Mozambican legal requirements. 3.5 Community, Stakeholder and Government Liaison A key management principle during the operational phase of the CTT shall be that of respect of the rights of the surrounding community and the land and resources that belong to them. The Operations area is characterised by the following socio-economic conditions, which shall at all times be taken into consideration:  Subsistence living;  Extreme poverty;  Strong dependence on local natural resources;  Limited access to health and education facilities, access roads (basic services); and  Very limited employment opportunities. All communication shall be in accordance with the CTT Stakeholder Engagement Plan, and as set out, in general, in the specifications below. Note that this section does not contain specifications for liaison in respect of compensation, which is covered under the RPF for this project. Furthermore, the RPF will refer to specific tools (RAP/ARAP/LRP) that may be required to be implemented in certain instances. 25 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.5.1 General Access over land, the integrity of fences Operations Manager Ongoing Number of complaints (boundaries), control of bush fires, littering, dust ESO registered control, noise abatement, harassment of Number of complaints domestic and wild animals, sedimentation and resolved contamination of ground and surface water, Number of grievances damage to the landscape and vegetation and all registered such environmental matters, shall be controlled Number of grievances in the best interests of CTT, the environment and resolved the communities in the project zone of influence. Number of compliments received Monitoring records Audit findings 3.5.2 Respect for local There shall be strict induction training for project Public Affairs Ongoing in standard Included in standard people workers and information dissemination to Coordinator and staff induction training induction training for communities, so that both groups are clear as to At least annually for staff, visitors and ad hoc what to expect of the other. communities contractors to CTT Evidence of annual communication initiative in each community 3.5.3 Compliments and A Compliments and Complaints Register shall Public Affairs Number of complaints complaints be developed and widely communicated to Coordinator and staff registered register (paper communities as an instrument to air their views. Number of complaints copies in The Register shall be kept in the community by resolved communities, the village leader or appointed designate, should Number of compliments 26 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification electronic be inspected monthly by a CTT Community received database at CTT) Liaison Officer, and if complaints have been Nature of complaints registered, follow up and close out on these. All analysed and corrective issues raised by external parties shall be logged actions taken for trends in these registers and should include, but not be in complaints limited to: Annual independent ▪ The name of the communicator community and ▪ Contact details of the communicator stakeholder perceptions ▪ Nature of the communication survey Any action taken or that needs to be taken to address the issue raised. 3.5.4 Grievance A formal Grievance Redress Mechanism Public Affairs Ongoing Number of grievances procedure (Procedure) shall be developed as required by Coordinator and staff registered IFC Performance Standard 1, and wide Number of grievances communication to communities of the existence resolved of this instrument to register grievances when Nature of grievances they believe they have suffered damages that analysed and corrective require compensation as a result of CTT’s actions taken for trends activities. in grievances 3.5.5 Communication Development of an integrated public affairs, Public Affairs Success evaluated and Plan developed and with stakeholders communication and CSI program for the CTT Coordinator and staff updated monthly annually evaluated and zone of influence Annual independent updated community and Annual increase in district/provincial positive perceptions by 27 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification stakeholder perception communities and survey District/provincial stakeholders Number of compliments and complaints registered Number of complaints resolved 3.5.6 Communication All communication and awareness programs to Public Affairs Ongoing Number of complaints with stakeholders communities shall be done in a good mix of Coordinator and staff registered written, visual and verbal methodologies. In all Number of complaints cases, not only CTT and its community liaison resolved officers should provide this communication, but Number of grievances the support of respected people in the registered communities (church leaders, school principals Number of grievances and educators, health workers, heads of women, resolved youth and other organisations) shall be enlisted Number of compliments to give more credibility to the messages and to received carry the messages further and more Annual independent consistently over time. This will require train the community and trainer sessions for the leaders. stakeholder perceptions survey 3.5.7 Management of Community leaders and residents may have Public Affairs Ongoing Number of complaints expectations expectations that CTT will play a supporting and Coordinator and staff registered 28 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification developmental role within the area and that LOCSA and staff Number of complaints Operations will have other positive economic resolved benefits. In order to maintain realistic Number of grievances expectations, CTT shall maintain close registered communication with local communities and Number of grievances government with the objective of clarifying roles, resolved responsibilities and involvement throughout the Number of compliments Operations phase and ensuring that CTT’s role received is widely understood. The Corporate Social Annual independent Investment (CSI) programme shall play a critical community and role in managing expectations. stakeholder perceptions survey 3.5.8 Management of One or more Community Development Officers Public Affairs Ongoing Opportunities for CSI expectations shall be employed to support the CTT CSI Coordinator and staff, projects including local programme, identification of opportunities LOCSA and staff procurement identified. including procurement, obtaining community Community inputs into inputs into plans, and ongoing information forthcoming CSI plans provision. obtained Number of communication initiatives inform communities about current CSI projects 29 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.5.9 Communication / CTT shall employ a Public Affairs Coordinator LOCSA and staff Ongoing Number of complaints liaison (PAC) and two LOCSAs who are actively registered involved in the Operations area. These persons Number of complaints shall liaise with the local communities and resolved District authorities regarding CTT’s activities. In Number of compliments this task, the LOCSA shall ensure the received involvement of the SES on any environmental Number of grievances matters. Similarly, the SES will ensure that the registered LOCSA is informed of and involved with any Number of grievances environmental issues that might relate to the resolved community, government etc. Annual independent community and stakeholder perceptions survey 3.5.10 Communication / The SES, PAC and or LOCSAs shall hold LOCSA and staff Ongoing Number of complaints liaison regular meetings with surrounding community SES registered leaders often with communities themselves in Number of complaints order to inform them of any activity that may resolved affect them in any way. Records of all meetings Number of grievances shall be kept. registered Number of grievances resolved Number of compliments received Annual independent 30 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification community and stakeholder perceptions survey Records of meetings 3.5.11 Communication / Build the capacity and status of Community LOCSA and staff liaison Interface Forums to support ongoing communication in communities and to facilitate contributions to the CTT CSI Programme. Where such Forums no longer exist, re-establish them in a participatory process with communities and build their capacity in respect of their mandate as Interface Forums. 3.5.12 Access to private / The property and rights of all persons shall be Operations Manager Ongoing Absence of complaints government respected at all times. or formal grievances property CTT personnel and its contractors shall not gain Number of compliments access to land outside of its approved areas of operation without prior consultation with community leaders and, where considered necessary by the LOCSA, the affected families themselves. No activities that cause damage may be undertaken without prior approval by the regulatory authority, and prior communication with an agreement on appropriate compensation by the affected person/s. 31 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.5.13 Population influx Ongoing communication, including national Public Affairs Ongoing Number of coverage from time to time and information Coordinator, LOCSAs communication meetings in all affected villages, explaining the and staff initiatives nationally, in negative impacts of population influx, and the Province and District harnessing their support to reduce influx of work and in the communities, and opportunity seekers, communicating the at least annually following CTT policies inline with the CTT influx Survey amongst village management plan: leaders on increase in ▪ All ad hoc unskilled employment will be, number of new arrivals without exception, from local villages, Google or satellite verified by community leaders imagery survey of ▪ No hiring on site for job seekers and no increase in size of towns procurement at the gate Reduction in percentage ▪ Maximising local content in increase of towns procurement i.e from local people and Compliance with Influx towns. Management Plan Communication and coordination with local leaders and District Government in terms of curbing influx and obtaining their support and suggestions in this regard. 3.5.14 Reporting CTT shall report on environmental, social and SHE Manager Bi-annually Content of Bi-annual health and safety performance for the Operation report in keeping with the environmental and social reporting schedule detailed in the ESMP approval conditions letter. 32 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.5.15 Reporting CTT shall advise key Government stakeholders SHE Manager Periodically Proof of notification in and community leaders about the availability of stakeholder meeting key environmental and social performance records and other reports and shall assist stakeholders and in correspondence particular communities to fully understand these Number of reports. communication initiatives and methods to communicate the contents Interim evaluation tool to assess degree of comprehension of information 3.5.16 Government CTT shall actively seek to participate with the Operations Manager Ongoing Minutes of meetings liaison Government on task teams and forums that Government Liaison Number of complaints relate to the operation of the CTT and Manager/SHE Manager registered associated activities and their influence on the LOCSA Number of complaints communities and the environment. This should SES resolved include consideration of forums that address the Number of compliments following issues in relation to CTT’s activities in received Mozambique: Annual independent ▪ Resource use and exploitation community and ▪ Management of exclusion zones stakeholder perceptions ▪ Land use planning and zoning 33 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification ▪ Community needs, comments, issues and concerns. 3.5.17 Corporate Social Develop a CSI program in a transparent process Operations Manager Investment (CSI) through consultation with local communities, District government, NGOs and other stakeholders in which criteria are developed for projects and beneficiaries, and priorities are agreed upon in an open process. Establish, maintain, fund and support through a constructive and professional process a CSI Advisory Committee on which is represented representatives of communities it its zone of influence, government, NGOs and other stakeholders to: ▪ Build stakeholder capacity and understanding in CSI allocation, spending and management and in the process build trusting relationships and partnerships with stakeholders ▪ Support the company in developing a CSI strategy and plan for CTT in Mozambique ▪ Reach agreement on sustainability capitals to pursue for selected periods 34 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification of time, and on transparent criteria for allocation of funding ▪ Participate in and advise the company on annual CSI spending ▪ Support the company in annual review against agreed criteria of the success or otherwise of measures implemented. ▪ Publicise the agreed CSI plan and obtain feedback. 3.6 Office Management Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.6.1 Electricity Offices shall be electrified. Fires (cooking or Operations Manager Ongoing Electrification of offices heating) are prohibited except in the case of and accommodation barbeques). 3.6.2 Food usage Should there be a kitchen or canteen on site at Operations Manager Ongoing Waste disposal records. CTT, then left-over food shall be minimised to Catering contractor Kitchen waste disposal prevent the establishment of pests SES records (cockroaches, mice and rats). Composting records No left-over food shall be provided on an ad hoc basis to local communities. 35 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification The alternatives of minimising and/or using left- over food shall be investigated as an option. 3.6.3 Air conditioner Employees shall be encouraged and educated to Operations Manager Ongoing Awareness programmes usage use energy efficiently. ESO 3.6.4 Local economic Only use the local Inhassoro facilities to CTT management Ongoing Accommodation improvement accommodate the CTT staff, service providers, HR Manager payments to local contractors or consultants where possible establishments 3.7 Mosquito / Vector Control Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.7.1 Mosquito control Implement and maintain a programme to Doctor Ongoing Vector control minimise malarial incidence among employees, LOCSAs programme contractors and visitors. .Prevent ponding at all implemented and CTT activities in the rainy season. maintained Work with village leaders to prevent the Communication with establishment of informal settlements with bad village leaders drainage and lack of sanitation. Tracking of and reduction in incidence of malaria among workers and in communities 36 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.7.2 Pesticide & The disposal of waste pesticide and pesticide Doctor Ongoing Waste disposal records larvicide containers will be as per the waste management Procedure for medical management and plan. A procedure for medical waste storage and waste disposal medical waste disposal shall be developed in accordance with these requirements. 3.7.3 Permissible Diesel shall not be used as a dispersant during Doctor Ongoing Procedure(s) for fogging dispersants ‘fogging’ Operations. 3.7.4 Personnel CTT shall ensure that the training of personnel Doctor Ongoing Records of training management who undertake spraying complies with relevant Government Mozambican legislation and authorisations authorisations If an external service provider is used the Records of medical relevant permissions from the authorities shall check ups be obtained All personnel responsible for spraying pesticides shall wear appropriate PPE and receive annual medical check-ups. A Pest and Pesticide Management plan must be compiled and approved by the SHE Manager prior to use of any chemicals. 3.7.5 Storage of All pesticides shall be appropriately stored Production Manager Ongoing Inspections pesticides according to regulatory requirements based on their MSDS, including temperature control and containment. 37 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.7.6 Community Extend specific community-based malaria and CTT management and Ongoing communicable diseases awareness vector controls as part of the recommended LOCSAs (& CPF strategy communicable diseases strategy. Ideally this management) should be performed in partnership with the CPF. Awareness and education programmes in the workforce on how to prevent and effectively treat malaria 3.8 Medical Services and Facilities Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.8.1 Health Prepare and implement a programme and Doctor Ongoing Implementation of management - procedure(s) to minimise the spread of HIV procedures and HIV infection. A typical programme would include, programmes. among other things, the implementation of the Increase or decrease in following: the percentage of ▪ See also for sex workers and reduction people with HIV/AIDs or in population influx other sexually ▪ An HIV / Aids training course and on- transmitted diseases in going education on transmission of HIV the communities, and / Aids and STDs to employees, through 38 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification workshops, posters and informal number of people information session, as well as to treated communities Increase or decrease in ▪ Encouragement of employees and the number of people on community members to determine their the antiretroviral HIV status program, and how long ▪ Supply of condoms to employees they stay on the ▪ Distribute condoms in the communities, program to both men and women and to church Number of CSI projects leaders, and explain their use where focusing on prevention necessary or treatment of sexually ▪ Continue to promote voluntary transmitted diseases. counselling and testing Number of people ▪ Continue to support treatment and provided with voluntary ongoing antiretroviral programme counselling and testing ▪ Other CSI projects focused on Number of reduction in and treatment of HIV/AIDs. communication/awarene ▪ Evaluate opportunities for the ss initiatives in the empowerment of women and girls in the communities area to support livelihoods and reduce Increase or decrease in vulnerability of transactional sexual the percentage of relationships people with HIV/AIDs or other sexually transmitted diseases in the communities, and 39 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification number of people treated Increase or decrease in the number of people on the antiretroviral program, and how long they stay on the program. 3.8.2 Medical waste Medical waste shall be stored, separately from Doctor Ongoing Inspection records. storage other waste, prior to incineration or disposal at Audit findings. another appropriate facility (via a waste contractor) as per the requirements laid down by the World Health Organisation and any Mozambican regulations on the management of biomedical waste. 3.8.3 Medical waste Medical waste shall be disposed of at the CPF Doctor Ongoing Waste disposal records. disposal on-site incinerator or another appropriate facility (via an accredited/licensed waste contractor). Records shall be kept of all medical waste disposed. 3.8.4 Community Health Develop a Community Health Information CTT Ongoing Community Health System (CHIS) to collect and monitor key Information System community health indicators in a longitudinal records fashion. This may require specific Health 40 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification Systems Strengthening (HSS) in the local health facilities so that they can be used as a reliable source of information, and potentially support of Community Health Agent/ Agent Polyvalent Communitaire (CHA/APE) in the respective communities. There may be a need to support better diagnostics for TB in the study area and reporting on the District Health Information System (DHIS2). Occupational Develop workplace health strategies as part of CTT management At start-up Health strategies health and safety the occupational health plan or organisational Ongoing Preventable disease health plan, to include: programmes  Develop a vaccine preventable disease programme for all employees, contractors and visitors based on risk for travellers and at-risk occupations  Develop and/or extend outbreak preparedness policies and programmes to reduce the impact of any suspected or confirmed outbreak at the local level 41 March 2019 3.9 Water and Effluent Management Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.9.1 Water provision Water for Operations shall be obtained from SES Ongoing Groundwater monitoring groundwater boreholes. (Operations shall have programme (volumes; no detrimental impact on water volumes water levels). (groundwater) available to existing users in the Communication with area. community / complaints Water shall not be abstracted from surface water recorded in resources. Communications The relevant permits for the abstraction of Register. groundwater shall be obtained from the Government approvals regulatory authority prior to their use. (ARA-SUL). 3.9.2 Water provision No seepage fields, ‘soakaways’ or evaporation SHE Manager Ongoing As per requirement. ponds shall be developed (in addition to that SES currently assessed) without the approval of the SHE Manager and SES and based on a specialist evaluation commensurate with the level of risk involved. 3.9.3 Water provision All final effluent discharged from the final effluent Production Manager Ongoing Monitoring records. sumps shall meet the Mozambican standards or ESO World Bank Group effluent standards, whichever is more strigent. No effluent or potentially contaminated storm water may be released from site other than from the final effluent sump, with the exception of the 42 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification clean storm water. 3.9.4 Storm water Rain water falling off-site shall be prevented from Production Manager Ongoing Storm water management entering the site. Measures to prevent storm ESO management system water ingress onto site shall typically include design as per storm water diversions, drainage channels etc. requirements. On-site, clean and contaminated water shall be Maintenance of the kept separate. Clean storm water may be storm water released into the surrounding environment management system without treatment. Potentially contaminated storm water shall be collected for treatment in the industrial effluent treatment plant. Appropriate use of soak-ways, seepage fields and vegetation filters will be put in place to prevent contamination of water resources. Water quality analysis on water bodies in the receiving environment. 3.9.5 Open drain Rainwater collected within bunded areas (e.g.: Production Manager Ongoing Monitoring records. system diesel tanks, stores) may be released to clean ESO Procedure for release of (i.e. open) storm water drains if it meets the liquid from bunded minimum discharge standards. If not, the areas. contents shall be redirected via the closed drain system to the POC, where it shall either be treated or routed to an incinerator or disposed of 43 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification at another appropriate facility (via a waste contractor). A procedure shall be developed describing the strategy for release of any liquid within the bunded area. This should include requirements concerning appropriate disposal and where required, sampling requirements prior to release. 3.9.6 Final effluent The final effluent may be disposed of by Production Manager Ongoing Monitoring records disposal irrigation onsite if the water quality meets the ESO Procedure of Final specifications required in terms of Mozambican Effluent Irrigation law. 3.9.7 Effluent All kitchen waste-water shall be discharged Catering contractor Ongoing Grease / oil traps management through grease / oil trap(s) into the sewage ESO installed. (kitchen and other treatment plant. Cleaning and maintenance shall Records of oil and wash water) be in accordance with an appropriate grease disposal. maintenance schedule. Inspection reports. Collected grease and oil shall be disposed of via Records of products an incinerator or disposed of at another used and alternatives appropriate facility (via a waste contractor). considered. Efforts shall be made to avoid odours from the Purchasing procedure grease traps. reflecting approach to Care should be taken to use efficient and product selection. environmentally friendly cleaning materials. 44 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.9.8 Effluent Laundry water shall only be discharged to the Cleaning contractor Ongoing Drainage design to management sewage treatment plant. ESO sewage effluent (laundry water) Kitchen and laundry staff shall be trained to treatment plant. avoid the excessive use of detergents. Where Records of products practical, environmentally friendly cleaning used and alternatives materials shall be used in preference to standard considered. materials. Purchasing procedure reflecting approach to product selection. 3.9.9 Sewage Toilet facilities shall be properly maintained to Operations Manager Ongoing Inspection records. management minimise the risk of leakage of un- or partially Production Manager Audit findings. treated sewage. ESO Monitoring records. Effluent streams must comply with the Mozambican and IFC discharge water quality standards for treated effluents. Continuous analysis of quality of the effluent streams prior to irrigation to determine compliance to discharge standards. Non-compliant effluent should be discharged to the evaporation pond. Water quality analysis of groundwater in the receiving environment. 3.9.10 Shower water Shower water shall only be discharged to the Operations Manager Ongoing Effluent design sewage treatment facility. ESO Education programme 45 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification CTT shall educate employees and contractors to minimise water use during showering and general use of ablution facilities. 3.10 Waste Management Waste management at the CTT complex shall comply with the requirements of the Waste Management Plan. As per the Mozambican general waste regulations, non-hazardous waste is defined as waste with no risk characteristics, including but not exclusive to paper or paperboard, plastic, glass, metal, rubbish, metal scrap, and organic matter. Hazardous waste is defined as waste bearing risk characteristics for being flammable, explosive, corrosive, toxic, infectious or radioactive, or for showing any other characteristic that constitutes hazard for the life and health of humans and other living creatures and for environmental quality. The approach to waste management is to minimise waste production, re-use and recycle where possible and disposal as the final option. Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.10.1 Overall waste CTT shall prepare a Waste Management Plan for SHE Manager Ongoing (review Documented waste management plan Operations at the CTT complex that defines, but annually) management plan. shall not be restricted to, the following: Government approval ▪ Waste minimisation strategy ▪ Waste collection strategy ▪ Waste separation strategy ▪ Waste transport strategy ▪ Waste disposal strategy 46 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification ▪ Waste recycling strategy. This plan shall be submitted to the relevant authorities for approval and renewed as per the regulatory requirements in Decree 83/2014 and Decree 94/2014, as amended. 3.10.2 Legal Compliance A procedure shall be developed which provides SHE Manager Review annually Documented procedure details of all aspects of waste management and demonstrates compliance with Mozambique waste management legislation (Decree 83/2014 and Decree 94/2014). 3.10.3 Waste storage Where markets exist (or could be created) for the ESO Ongoing Disposal records. and transport – re-use or recycling of waste materials these general materials shall be separated from the waste stream at their point of generation and stored separately for collection by the recycling agent. No material may be provided to communities where the material could present a health or safety risk. Old chemical drums may only be released for recycling if crushed prior to release to prevent the containers being used as water vessels. 3.10.4 Waste storage A clear distinction shall be made between ESO Ongoing Documented and and transport – hazardous and non-hazardous waste streams, implemented waste general with separation occurring at source. Wastes shall management strategy. 47 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification be placed in separate containers and transported Provision of separate to the disposal facilities separately. containers for non- hazardous and hazardous waste. 3.10.5 Waste storage In all cases, waste shall be contained. Storage ESO Ongoing As per requirement. and transport – and disposal areas shall be contained / controlled general to prevent scavenging by persons and / or animals. Wind-blown litter shall be prevented. 3.10.6 Waste storage Waste containers shall bear labels that identify the ESO Ongoing As per requirements. and transport – contents. Where applicable this labelling shall general meet the Mozambique legal requirements for the labelling of hazardous substances. Containers shall be lined or constructed of materials that are compatible with the wastes to be stored. Containers shall be in good condition, free from corrosion, leaks or ruptures. 3.10.7 Waste storage Waste containers shall be stored above ground on ESO Ongoing As per requirement. and transport – an impermeable surface (where the risk of leaks general and resultant contamination is such that this is required) and under cover or covered by lids. 3.10.8 Waste disposal All waste materials should be handled and ESO/SES, Production Ongoing Documented and disposed in compliance with the Waste Manager implemented waste Management Plan. management strategy. 48 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification Waste disposal records. 3.10.9 Disposal off-site Where off-site disposal is the only remaining SHE Manager Ongoing As per requirements option (i.e. only for non-combustible hazardous SES waste not permissible in the on-site landfill, then this must be done in such a manner that it does not create risks of non-compliance with legislation or company policy (including Responsible Care). This is particularly important in the context of the environment in which the Operations exist, which is characterised by lack of both waste disposal facilities and the capacity for transportation of waste (especially hazardous waste). The following requirements will therefore apply to the off-site disposal of waste: ▪ Transportation shall be undertaken by CTT or by an accredited/licensed contractor familiar with the requirements for the transporting of hazardous wastes, and shall meet the regulatory requirements for such transport including the Road Code ▪ CTT / the transportation contractor shall have in place the means to respond appropriately to spillages of waste 49 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification anywhere along the transport route within a time limit acceptable to CTT ▪ The frequency of waste collection and the interim measures for the storage of waste on site must be appropriate, such that the system as a whole does not pose an unacceptable risk to either the environment or health and safety ▪ Storage of waste must be on a contained area underlain by an impermeable substratum, and covered to protect from water ingress ▪ Certificates of safe disposal must be provided for all waste removed from site. Such certificates may only be issued by a recognised waste disposal operator ▪ The site at which waste is disposed must comply with the CTT and its shareholders’ requirements. As such it must be audited on at least an annual basis ▪ No waste is to be disposed of off-site, except with the written approval of the SES who shall ensure that all necessary approvals have been obtained and all risks identified and managed 50 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification ▪ Where possible, suppliers shall be encouraged to take back unused products and the containers of used products An inventory of all waste stored on site for future off-site disposal shall be maintained. 3.10.10 Disposal off-site CTT shall endeavour to ensure that suppliers of SC Manager Ongoing Certificates of safe potentially hazardous substances (chemicals, disposal from the batteries, etc.) shall remove used products and suppliers their containers when making their next deliveries of these substances. Certificates of safe disposal of the wastes must be provided by the supplier. 3.10.11 Disposal off-site Records shall be kept of all waste disposed to the Production Manager Ongoing As per requirements incinerator, landfill and any off-site disposal if ESO applicable (including sales to scrap dealers). These records should reflect date of disposal source of waste disposed, quantity of waste, responsible party for the waste being disposed and responsible party for the waste receiving facility. These quantities shall be disclosed in the 6-monthly reporting to the Government. 3.10.12 Disposal in open No waste shall be disposed of in open fires. Operations Manager Ongoing As per requirements fires 51 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.10.13 Composting of All compostable organic waste from the kitchen, Catering contractor Ongoing As per requirements. organic waste and garden waste, shall be disposed of by ESO Composting facilities. composting in a dedicated facility. Alternatively, compostable waste shall be incinerated or disposed of at another appropriate facility (via a waste contractor) when composting is not viable. 3.10.14 Fluorescent tubes Fluorescent tubes shall be crushed and stored at Maintenance Manager Ongoing As per requirements the hazardous storage facility(s) until sufficient ESO, Catering volumes are obtained and are transported off-site contractor by an approved service provider. 3.11 Business Services Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.11.1 Environmental CTT shall track and record all expenditure on SHE Manager Ongoing Expenditure records. expenditure environmental or environmentally related items. Sustainable Development Data reporting tables 52 March 2019 3.12 Commissioning and Initial Start-up, Start-up following Shutdowns Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.12.1 Water flushing of Water volumes used for flushing should be Production Manager Ongoing As per requirement. lines minimised. SES Pump testing Water flushing shall not be used during normal Record of evaluation of using water operations. proposed additives and Effluent from flushing of lines or pressure testing required treatment shall be routed to the industrial effluent treatment options. plant or the incinerator or disposed of at another appropriate facility (via a waste contractor). Should any additives be used, the ability of the treatment plant to remove / treat these additives to ensure no environmental risk shall be determined prior to the use of the additives. This may include bioassay testing by specialists competent to conduct such tests. 3.12.2 Initial ‘loading’ of Care shall be taken during the initial loading Maintenance Manager Ongoing Document specifying machinery and (filling) of machinery and equipment to prevent Production Manager approach to initial equipment with spills / accidents etc. due to the relatively higher loading and indicating fuel, lubricants, volumes / quantities of materials involved. An precautionary chemicals action plan shall be prepared detailing the measures, safety approach to initial loading and precautions / safety measures and measures to be put in place. responses plans to be initiated in the event of an accident. 53 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.12.3 Building explosion Risk assessments, hazardous area classifications, Proponent, Design/ At start up Industry standards due to natural gas ventilation studies and plant audits Project team. leaks accumulated in buildings 3.12.4 Flammable Detailed commissioning plan and risk assessment Maintenance Manager At start up Industry standards vapour dispersion, Production Manager ignition and flash fire or explosive effects due to uncontrolled loss of containment of natural gas 3.13 Operation CTT Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.13.1 (External) Products used for external cleaning shall be Maintenance Manager Ongoing MSDS for products cleaning / painting ‘environmentally friendly’ products as determined ESO used. of piping and by MSDS specifications. Effluent monitoring equipment records. 54 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification All effluent shall be routed to the industrial effluent treatment plants. If uncertain as to treatment capabilities, the precautionary principle shall be applied and either the chemical shall not be added to the effluent stream or the effluent shall be tested to ensure appropriate quality (specifically for the pollutant / contaminant) of concern, prior to release. 3.13.2 Air emissions Installation of probes in stacks to allow for Design team Ongoing Monitoring records management continuous monitoring of stack emissions to detect Operations Manager any plant inefficiencies. Maintenance Manager SHE Manager ESO 3.13.3 Air quality NO2 emissions reduction for Gas engines: Design team Ongoing Monitoring records management  Increase stack height (where possible); or Operations Manager  Control Technologies: Maintenance Manager ▪ Low NOX burners; SHE Manager ▪ Homogeneous Charge Compression Ignition (HCI); and ▪ Flue-Gas Recirculation (FGR). NO2 emissions reduction for Gas Turbines:  An increase in stack height (where possible); and  Control Technologies: 55 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification ▪ Selective catalytic reduction (SCR); ▪ Selective non-catalytic reduction (SNCR); ▪ Catalytic combustion; and ▪ Wet Low Emissions (WLE). 3.13.4 General CTT If ambient noise monitoring shows that these limits CTT Ongoing Monitoring records. operational noise are exceeded, and community complaints indicate Production Manager Records of action taken that noise levels from Operations need to be Design Team as necessary. reduced, CTT shall initiate the action required to Minimal/no complaints achieve the reduction in noise levels to meet the Operations standards. For Gas Engines: 1) Alternative placement and/or design of cooling system 2) Cladding of buildings designed for optimum noise reduction 3) Minimisation of openings in façades For Gas Turbines: 1) Selection of system elements with minimum noise emission in mind 2) Cladding of buildings designed for optimum noise reduction 3) Minimisation of openings in façades 56 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.13.5 Decline in Use recycled water or rainwater for vehicle CTT operations Ongoing Monitoring records. groundwater washing, dust settlement, and toilet flushing. manager Records of action taken levels Recycling of washing and cleaning water where as necessary possible. Water storage and delivery facilities should be safe and leakage free to reduce water wastage. Raising awareness and promotion of behavioural change within the plant area about water use. Monitoring of abstraction boreholes. 3.13.6 Death or injury to Selected on-site environmental staff should be Environmental Manager Ongoing Training records fauna trained in snake handling and be familiar with No carcasses of fauna capturing and removing other fauna taxa; and killed by employees on A low speed limit (recommended 20-40 km/h) site should be enforced on site to reduce wildlife collisions. 3.13.7 Visually intrusive  To reduce the visual intrusion of the Project engineer, site At design stage Monitoring records. operational power buildings, where feasible roofing and environmental manager Records of action taken plant cladding material should not be white, shiny as necessary. infrastructure (e.g. bare galvanized steel that causes glare) Minimal/no complaints or brightly coloured  Buildings and workshops exteriors should also be painted in colours that are complementary to the surrounding 57 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification landscape, such as olive green, light grey, blue-grey, or variations of tan and ochre  Retain existing trees wherever possible, as they already provide valuable screening (Biodiversity study lists species that should be avoided as far as possible)  Appropriate landscaping using indigenous vegetation should be introduced within the permanent camp facility as well as entrance areas to other facilities, in order to create a more welcoming overall appearance 3.13.8 Light pollution at  Identify zones of high and low lighting Project engineer, SHE At design stage Monitoring records. night at the CTT requirements, focusing on only illuminating Manager At start up Records of action taken plant areas to the minimum extent possible to as necessary. allow safe operations at night and for security Minimal/no complaints surveillance  Plan the lighting requirements of the facilities to ensure that lighting meets the need to keep the site secure and safe, without resulting in excessive illumination  Reduce the heights of light post where possible and develop a lighting plan that focusses on illuminating the required areas through strategically placed individual lights rather than mass light flooding 58 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification  Utilise security lights that are movement activated rather than permanently switched on where feasible, to prevent unnecessary constant illumination  Fit all security lighting with ‘blinkers’ or specifically designed fixtures, to ensure light is directed downwards while preventing side spill. Light fixtures of this description are commonly available for a variety of uses and should be used to the greatest extent possible  Eliminate any ground-level spotlights as these invariable result in both direct glare and increased sky glow, and cannot be effectively mitigated 3.14 Maintenance of CTT & Transmission Line Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.14.1 Transformers Transformers shall be free of polychlorinated Maintenance Manager Ongoing No PCBs on site. biphenyls (PCBs) and shall be bunded and Electrical technician Inspection schedule & regularly inspected and maintained. records 59 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.14.2 Gas turbines / All gas turbines and generators shall comply with Production Manager Ongoing All new gas engines to generators the relevant Mozambique air emissions standard Maintenance Manager include low-NOx and/or or the standards set out in the project burners. financing agreements; or the relevant IFC Air emission and noise standard specifications for generators. 3.14.3 Gas turbines / All noise generating equipment shall be checked Maintenance Manager Annual Assessment and generators / other to ensure that it is functioning optimally with ESO/SES monitoring reports noise generating respect to noise emissions and that emissions do equipment not exceed the original design specification (cooling fans) 3.14.4 Vehicle and All equipment and machinery shall be maintained Maintenance Manager Ongoing Maintenance and equipment in good working order so as to prevent oil, fuel or service records. maintenance other such leaks as well as elevated emission levels. 3.14.5 Vehicle and All reasonable precautions shall be taken to Maintenance Manager Ongoing Inspection records. equipment prevent fuel and lubricant spills. The following ESO maintenance shall be complied with: ▪ No overfilling of diesel bowsers and equipment tanks ▪ Initial and regular subsequent inspections to verify that no leaking or defective equipment is brought onto site 60 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification Any oils or lubricants discharged during routine vehicle servicing on site shall be captured using drip trays, containers or other appropriate containment measures. 3.14.6 Vehicle washing A wash bay(s) shall be designed and constructed Maintenance Manager Complete Wash bay(s) at which all vehicles and equipment and high- constructed as per pressure washing shall take place. The wash bay requirement. shall be constructed so as to capture all runoff. All Vehicle and equipment wash bay effluent shall be directed to the industrial washing procedure. effluent treatment plant for further treatment Wash bay Operating before release. CTT shall strictly prohibit the washing Procedure of vehicles or other machinery, or the changing of lubricants, in rivers, streams, ponds, or other waterways. 3.14.7 Pigging Any effluent produced from pigging shall be Production Manager As per procedure As per requirement. diverted into the closed drain system. Further Record of evaluation of containment and treatment of spillage shall be via treatment options the POC System. should glycol inhibitors A procedure shall be compiled indicating methods be used. and frequency of pigging. Procedure. 3.14.8 New infrastructure The SHE Manager shall be consulted during the SHE Manager Ongoing SHE Manager and SEPI within CTT design of any new infrastructure. The design shall SPI Interface Manager Interface Manager to be in accordance with Mozambican legislation and approve, in writing, the best practices internationally. establishment of new 61 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification Prior to development, the relevant authorities shall infrastructure. be notified of any changes to infrastructure within Government approvals the plant area and authorisation shall be obtained and this ESMP be updated, where required. 3.14.9 Establishment of Continue to implement the alien invasive plant CTT Environmental Ongoing Site cleared of or limited Alien Invasive species control programme, with regular team alien invasives present plants monitoring informing any revisions to overall strategy, priority sites, control methods and follow- up treatments 3.14.10 Maintenance of Regular clearence of vegetation to shrub height CTT / Transmission line Ongoing Only maintenance track Transmission Line will be required to ensure access to the Environmental Team cleared of vegetation servitude maintenance track to facilitate inspections of the Records of mortalities transmission line. Only the vegetation encroaching (birds, bats etc) on the maintenance track should be cleared. The ECO shall relocate slow-moving wildlife (snakes, tortoises, etc.) to safe areas outside the project work zones (during maintenance of transmission line servitudes and maintenance roads), inlcuding other right of ways (ROWs). Bird flight diverters shall be installed and maintained along the transmission line to reduce collisions, prioritizing areas with higher presence 62 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification of vultures and other vulnerable bird species (and bats), with at least 3 meters between the conductors. 3.14.11 Maintenance of The PPZ around the transmission line and CTT CTT Security Team Ongoing No encroachment into Right of Way must be enforced and maintained, by co-operative Operations Manager PPZ agreements with the relevant local community and SHE Manager No grievances from leaders/chiefs and government departments. (changes to communities Any change shall be certified by the Operations alignements) Manager and SHE Manager. If there is an economic loss or displacement requiring compensation, then this will be handled in accordance with the process set out in the RPF. 3.15 Hazardous Materials / Spill Management Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.15.1 General CTT shall comply with all applicable laws, SHE Manager Ongoing Disposal records regulations, permit and approval conditions and Audit findings. requirements relevant to the storage and use of hazardous materials. All unused product which is not returned to the supplier shall be treated as 63 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification waste and managed in accordance with the CTT Waste Management Plan. 3.15.2 Storage and A comprehensive inventory of all hazardous SHE Manager Ongoing Inventory. handling of materials and volumes / quantities on site must be Stores Supervisor hazardous kept updated and maintained. ESO materials on site 3.15.3 MSDS usage and MSDS contents shall be used as a mandatory SHE Manager Ongoing MSDS’s available for all availability on site requirement for the appropriate storage and SC Manager hazardous materials on handling of all materials and for assisting to make site. an assessment of the possible risk associated with any materials. Where necessary, the SES shall be consulted as to the environmental risk associated with the use of any material. MSDS’s shall be available for all hazardous materials on site and a summary of requirements shall be immediately available in areas where such materials are stored or used. 3.15.4 Storage facilities Proper storage facilities shall be provided for the SC Manager Ongoing Storage areas as per for hydrocarbon storage of oils, grease, fuels, chemicals and any requirement. products and other hazardous materials. chemicals These storage facilities (including any tanks) shall consist of an impermeable surface and shall be surrounded by a bund wall in order to fully contain accidental spillages, 64 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.15.5 Health and Workers shall be made aware of the health and Occupational Health Ongoing Training records. environmental environmental risks associated with any Practitioner Regular inspections risks of hazardous hazardous substances used and shall be provided Health and safety substances with appropriate protective clothing (PPE) / meetings minutes equipment in case of spillages or accidents. 3.15.6 Purchasing Business-related non-stock items may not be SC Manager Ongoing MSDS for non-stock purchased and brought to site without prior items. approval of the Procurement & Supply Approval of P&S Department. Manager for purchase of all non-stock items. 3.15.7 Expertise, The necessary tools, materials and expertise must SHE Manager Ongoing Register of tools equipment and be readily available to deal with spills of oils, fuels, available for handling procedures to lubricants and other hazardous materials. spills. deal with spills Spill clean-up kits shall be available on site. The Procedure for spill capacity and number of spill kits for each area Training records shall be based on the risk associated with a spill (volume / quantity and severity). An Oil Spill Management Plan shall be be written for the prevention and management of major spills outside of the boundary fence of the CTT. The procedure shall contain: ▪ Guidance to employees regarding safe working practices and spill avoidance ▪ Actions to be taken in the event of a spill. 65 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification ▪ Ongoing training requirements for employees, equipment operators and for emergency spill response teams. 3.15.8  Storage of new and used oils in bunded SHE Manager Ongoing Register of tools Spillages of areas. available for handling chemicals and  No co-handling of reactive liquids or solids. spills. oils, poor  Creation and monitoring of an inventory of Procedure for spill housekeeping; chemicals held on site. Training records Vehicle and  Storage of hazardous or toxic substances equipment securely and controlled use thereof. maintenance  Vehicle and equipment maintenance limited to designated areas only. 3.16 Upset Condition Management Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.16.1 Effluent No untreated effluent (or effluent outside of Production Manager Ongoing Monitoring records. management specification) shall be released from site. ESO Untreated effluent shall be held on site in existing facilities until such time as treatment is possible. 66 March 2019 3.17 Land Use Controls Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.17.1 General The operation of the CTT complex and associated Operations Manager Ongoing Records of meetings / activities may influence development in the local communication with the area, bringing about changes in what was Government. previously a rural environment. Without proper Aerial photographs / management this could lead to conflict between satellite imagery to the rural and industrial land uses. CTT shall identify changes in ensure liaison with the Government to encourage activities around the suitable planning of land use and land zoning Plant around the CTT site. 3.17.2 PPZ boundary CTT shall approach the relevant Mozambique Operations Manager Prior to beneficial Formal agreement with authorities to motivate for an extension of the PPZ operation of the CTT the Mozambique boundary, within which no building infrastructure or Government settlement should be permitted. 67 March 2019 3.18 Corporate Social Investment Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.18.1 CSI policy Implement the intent of the “Corporate Social Public Affairs Ongoing As per requirement Responsibility Policy for the Mineral Resources Coordinator and staff Extractive Industry”. 3.18.2 Community The capacity and status of Community Interface Public Affairs Ongoing As per requirement interface forums Forums shall be built up to help facilitate Coordinator and staff contributions by community members. Where such forums no longer exist, they should be re- established in a participatory process with communities. They can play a critical role in community development in the villages providing they are empowered to do so. Capacity building would need to start at ‘how to run a committee’. 3.18.3 CSI awareness CTT shall publish and create awareness of the Public Affairs Ongoing Information campaign many CSI projects the company has already Coordinator and staff records established and the local benefits derived from these projects. Use shall be made of a good mix of verbal, visual and written information. In villages, the information campaign should be rolled out to the entire population of the village and not only to village leaders. 3.18.4 CSI local Evaluate opportunities to create local economic CTT management Ongoing As per requirement management development initiatives associated with 68 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification agriculture, farming and getting goods to market as well as other entrepreneurial activity. This should have the objective of supporting local food security and generating sustainable improvements in livelihoods 3.18.5 Allocation of CSI Once the system of setting aside funds for local Public Affairs Ongoing As per requirement. funds communities is established, CTT should work Coordinator and staff Records of fund closely with District Government to coordinate allocations in wise application of these funds in tandem with consultation with District CTT’s CSI program. Government 3.19 Decommissioning Any additional development activities for Operations must be conducted in terms of the construction and operational ESMP for the CTT and associated facilities. These documents will need to be updated as necessary to reflect the additional Operations activities and associated management requirements. Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification 3.19.1 General An Environmental and Social Impact Assessment Operations Manager Authorisation required As determined in the (ESIA) shall be prepared for the decommissioning SES prior to start of ESIA and DRP. of the CTT complex and all other infrastructure, decommissioning including the Transmission line (as applicable), 2 years before project closure, in accordance with 69 March 2019 Ref. Activity Requirements / specifications Responsibility Scheduling Compliance indicator(s) or verification relevant laws, and industry best practice. The ESIA shall be used as a basis for updating and expanding on the Decommissioning and Rehabilitation Plan (DRP), which must be approved by MITADER prior to decommissioning. 70 March 2019 4.0 PERFORMANCE ASSESSMENT, REVIEW & CORRECTIVE ACTION The assessment of performance has three key aims: i) Confirmation of compliance to the requirements as set out in the ESMP and RPF; ii) Measurement of environmental performance (degree of success of the ESMP and its specifications) and iii) Ensuring that any deficiencies in the ESMP are identified and remediated. These aims shall be met by making use of four important tools:  Monitoring, auditing / inspections, non-conformance / incident identification and close-out, and management review.  Corrective action will be critical in ensuring that any identified problem areas are effectively addressed.  Specifications for monitoring, non-conformance identification, auditing and review are provided in the sections that follow. CTT shall produce procedures for monitoring, auditing and inspections, management review, non-conformance / incident reporting and corrective action that will address the requirements of this section. 4.1 Environmental Monitoring Strategy A monitoring1 strategy must be defined to ensure that the effectiveness of management and mitigation measures can be tracked and corrective action (see section 4.4) identified as necessary. Note that monitoring shall be intended to evaluate the effectiveness of environmental, social and health and safety management, independently of whether the specifications in the ESMP have been complied with. Proper monitoring will enable any impacts of Operations on the environment to be detected as early as possible and corrective action implemented as required. Where monitoring is specified as a requirement, the responsible party will develop a monitoring, measurement and reporting procedure that will outline:  The monitoring objectives;  A detailed description of the required monitoring measures, including responsibilities, parameters to be measured, methods to be used, sampling locations, frequency of measurement, detection limits and the definition of thresholds that will signal the need for corrective actions (see section 4.4); and  The approach to the analysis of results and the identification of activities and impacts requiring corrective action. Reporting requirements, with defined responsibilities, to ensure early detection of conditions that require corrective action and approach to initiating corrective action. The monitoring requirements outlined below will therefore need to be updated as required upon finalisation of the abovementioned plans, as well as additional parameters and monitoring criteria added for plans that still require further development. 1 Monitoring is a process of surveillance, based on specified approaches and schedules, used to detect whether any changes have occurred in the predefined, quantifiable properties of the particular environment under consideration. 71 March 2019 Table 3: Air Quality Monitoring programme Objective Detailed Actions Monitoring Location Frequency / Responsibility Duration PM10 emission limit Iso-kinetic testing. All stacks Bi-annual CTT compliance Environmental Section NO2 emission limit compliance Flue gas analyser & iso-kinetic testing All stacks Continuous / Bi- CTT annual Environmental Section SO2 emission limit compliance Iso-kinetic testing. All stacks Bi-annual CTT Environmental Section PM10 ambient air quality Ambient air quality monitoring (E-sampler / Continuation of SEPI 2014 monitoring Bi-annual CTT guideline compliance Passive PM10) program (jointly SEPI/CTT) or Environmental alternatively CTT adopts its own Section monitoring programme. NO2 ambient air quality Ambient air quality monitoring (Radiello) Bi-annual CTT guideline compliance Environmental Section SO2 ambient air quality Ambient air quality monitoring (Radiello) Bi-annual CTT guideline compliance Environmental Section 72 March 2019 Table 4: GHG emissions monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility Reduce gas consumption of Calculate average consumption of gas engines / Gas to energy plant Monthly Operations gas engines turbines based on consumption of natural gas and manager electricity produced (i.e. product unit intensity). Monitor stack emissions to ensure compliance with relevant regulations and determine efficiency of gas Gas to power plant engines. Continuous Operations manager Reduce diesel consumption of Calculate average consumption of vehicles based Gas to power plant Monthly Fleet manager fleet vehicles on diesel consumption and distance travelled. Reduce diesel consumption of Calculate average consumption of diesel generators Gas to power plant Monthly Operations diesel generators based on diesel consumption and running time. manager Reduce diesel consumption of Calculate average consumption of generator and Site of abstraction Monthly Head electrician generator and water pump sets water pump sets based on diesel consumption and running time. 73 March 2019 Table 5: Groundwater Monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility To assess compliance of the Monitoring of treated effluent to determine Sewage treatment plant Continuously CTT treated effluent to discharge compliance to the effluent standards as stipulated in discharge point, oily water Environmental standards terms of the Mozambican and IFC standards for management system Section discharge and irrigation. Non-compliant effluent should be discharged to an evaporation pond. To assess groundwater levels Installation of continuous flow and water level Continuous monitoring of Continuous CTT at abstraction boreholes equipment at abstraction boreholes groundwater levels and Environmental abstraction rates at boreholes Section W5A and T9 (as well as any other identified/new monitoring boreholes in the vicinity of abstraction points) To assess compliance of the Monitor the stormwater runoff from site activities. At stormwater discharge points At all times CTT stormwater discharge quality Stormwater should be tested and treated to remove around the plant area. Environmental contaminants before being released into the Section environment. IFC Environmental and the Mozambican standards for treated effluent must be complied with. To assess the impact of water Monitor groundwater levels at monitoring points Continuous monitoring of Continuous for CTT supply, if any, on the local near abstraction boreholes and other sensitive groundwater levels and W5A and T9. Environmental groundwater receptors i.e. affected community wells/boreholes. abstraction rates at boreholes Monthly for Section W5A and T9. monitoring Install/include dedicated boreholes. monitoring boreholes near abstraction points. 74 March 2019 Objective Detailed Actions Monitoring Location Frequency Responsibility To assess water quality of Monitoring of groundwater quality Install dedicated monitoring Monthly for 1st CTT aquifers boreholes at the CTT plant – year thereafter Environmental location of boreholes will quarterly Section depend on infrastructure layout i.e. evaporation pond, chemical storage areas, waste disposal areas, etc. Table 6: Noise Monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility Monitoring of ambient noise Sampling noise measurements during day- and At selected points around the Every two years ESO or levels night-time perimeter of the CTT operation independent consultant Maintenance of a complaints 1) Discussion at regular meetings - Environmental ESO register 2) Identification of source of noise management LOCSA 3) Remedial steps meetings 4) Feedback to management and complainant Table 7: Environmental Risk Monitoring Plan Objective Detailed Actions Monitoring Location Frequency Responsibility Monitoring and alarming of gas Identification of confined spaces and installation of Confined spaces such as Ongoing Production levels in confined plant spaces gas detection and alarming devices. Monitoring of turbine enclosures and engine Manager the effectiveness of ventilation systems rooms Safety Practitioner 75 March 2019 Objective Detailed Actions Monitoring Location Frequency Responsibility Monitoring of effectiveness of Installation of sampling and measurement Site boundaries Ongoing Production dirty water treatment processes protocols Manager to prevent egress from the plant Safety Practitioner Table 8: Social Welfare Monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility Assess the client’s community Monitor community development indicators Project area Quarterly Social manager development initiatives Assess livelihood options for Monitor social behaviours and activities within the Project area Quarterly Social manager vulnerable groups such as project area women, elderly and children. Engage and consult with Monitor the stakeholder engagement and Project area Quarterly Social manager stakeholders during the project consultation accordingly to avoid interruptions operation phase during the operation phase 76 March 2019 Table 9: Soil, Land use and Land Capability Monitoring Program Aspect Monitoring Requirements Locations Parameters Frequency Responsibility Soil Quality Visual verification; and Along the perimeter of the pH and salinity values; Bi-annually CTT sampling of soils for analysis. newly developed project Content of major plant Environmental infrastructure. nutrients; Section Organic matter content; Metals and hydrocarbons Soil Stockpiles Visual verification; All stockpiled soils. Volume of soil stockpiled. Annually CTT Sampling of stockpiled soil Minimum of one sample per Height of stockpile Environmental 50m2 of stockpile taken at Type of soil stockpiled. Section regular intervals from both pH and salinity values; the surface 1m and the Content of major plant core of the stockpile. nutrients; Organic matter content; Heavy metals and hydrocarbons. Soil erosion Visual assessment All infrastructure. Evidence of erosion. Monthly, and CTT Surface water monitoring. Streams and rivers near the weekly during Environmental soils with high erodibility. Section Land use Land use Project Area Satellite imagery to be utilized 2 Years CTT to evaluate Land use. Environmental Section 77 March 2019 Table 10: Surface water Monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility To assess compliance of the Monitoring of treated effluent to Sewage treatment plant Continuously CTT treated effluent to discharge determine compliance to the effluent discharge point, oily water Environmental standards standards as stipulated in terms of the management system Section Mozambican and IFC standards for discharge and irrigation. Non-compliant effluent should be discharged to an evaporation pond. To assess compliance of the Monitor the stormwater runoff from site At stormwater discharge points At all times CTT stormwater discharge quality activities. Stormwater should be tested around the plant area. Environmental and treated to remove contaminants Section before being released into the environment. IFC Environmental and the Mozambican standards for treated effluent must be complied with. To assess the impact of water Comply with the recommendations of the At perimeter boreholes and at Monthly CTT supply, if any, on the local Specialist Study, Geohydrology Impact T9 and W5A. Environmental groundwater Assessment, with regard to the Section monitoring of water levels in the water supply boreholes. To assess the impact of Water quality analysis of the boreholes Perimeter of the evaporation Monthly CTT spillages/leakage from the in the vicinity of the evaporation pond to pond. Environmental evaporation pond on the Section determine existence of pollution impacts. receiving environment 78 March 2019 Objective Detailed Actions Monitoring Location Frequency Responsibility Implement remedial actions if impacts are noted. Table 11: Ecological Monitoring programme Objective Detailed Actions Monitoring Location Frequency Responsibility Assess the extent of alien  Monitor the type of alien species, All areas where vegetation Annually CTT species establishment and extent and density of infestations; clearing and earth works has (wet season) Environmental effectiveness of control and occurred. Section treatments  The effectiveness of control and mechanical control treatments. Assess success of Monitor vegetation basal cover and All areas where rehabilitation Annually CTT rehabilitation species composition, and take corrective has occurred. Priority sites (wet season) Environmental measures as required include: Section a) coastal dunes at the selected beach landing site; and b) Govuro River crossing point. Access the effectiveness of  Monitor the number of Bird and Bat Along Transmission line Monthly inspections CTT bird and bat diverters mortalities caused by the Environmental Transmission line. Section 79 March 2019 Objective Detailed Actions Monitoring Location Frequency Responsibility  Take note of hotspots for mortalities and adjust bird and bat diverters as required. Table 12: Visual Intrusion Monitoring programme - CTT plant Objective Detailed Actions Frequency Responsibility To improve the appearance or  Conduct periodic inspections of the power plant and associated Periodically during Plant operations otherwise reduce the visual infrastructure under construction, to ensure that visual improvement operation as required, manager, site intrusion caused by the power measures are implemented where practical. Additional measures such environmental plant complex as tree planting as effective screening of the CTT plant should be manager considered (not beneath transmission line) Light pollution at night at the  Conduct periodic night-time visual inspection of the operating power Annually, in the event of Plant operations CTT plant plant from immediate surroundings and nearest settlements / stakeholder complaints manager residences, to determine whether undue light pollution is occurring site environmental manager 80 March 2019 4.2 Site Inspection and Audits Mozambican regulations updated in 2015 require that regular internal and external inspections and audits must be conducted to evaluate compliance with the requirements of the ESMP. Section 4.2.1 defines the site inspection requirements and associated responsibilities for the Operations phase of the CTT complex. Section 4.2.2 defines the auditing requirements for the Operations phase of the CTT complex. 4.2.1 Site Inspections The ESO will undertake regular inspections of all works so as to identify any Operations activities or components that are causing, or may cause, a potential environmental, social and health and safety impact. Inspections will be ongoing and will form part of the day-to-day function of the ESO. The ESO will immediately bring any identified non-conformances to the attention of the responsible party for rectification. Any potential problem areas will be logged and managed as per the requirements of Section 4.4 (non-conformance and preventative action). 4.2.2 Audits The main goals of an ESMP audit are to evaluate compliance with stipulated ESMP requirements, to identify any non-conformance and to assess whether objectives and targets have been achieved. An audit programme and procedure shall be developed by CTT to ensure that the audits are sufficiently comprehensive and scheduled. Auditing must consider the results obtained from monitoring and inputs from PAPs and stakeholders to assess whether objects and targets have been met, and whether there is any non-conformance with stipulated ESMP and legal requirements. The audit must also assess whether ESMP and RPF implementation has been undertaken according to planned arrangements and that the ESMP itself is being appropriately updated based on Operations requirements and impacts identified. The audit shall confirm that any identified corrective action has been undertaken and assess the effectiveness of that action. CTT shall develop a procedure for conducting ESMP audits that shall incorporate details of:  Audit approach  Scheduling  Reporting and  Responsibilities. Table 13 defines the minimum requirements in terms of audit types and frequency that shall be conducted during the operational phase of the CTT complex operations. Table 13: Minimum auditing requirements for the operational phase of the CTT and associated infrastructure Nature and scope of Conducted by Reported to Frequency of audit audit Internal ESMP ESO Operations Manager Entire operations to be compliance audit – all SHE Manager covered annually. Operations components External ESMP Independent consultant SES Independent audit compliance audit – appointed by CTT SHE Manager annually as per - all Operations Operations Manager Government regulations components 81 March 2019 Nature and scope of Conducted by Reported to Frequency of audit audit MITADER (with action plan of how to address findings) Government audit MITADER SES As requested by As per the requirements SHE Manager Government of Government. Operations Manager Note: It is in the nature of environmental auditing to be conservative. Wherever latitude exists in interpretation, the auditor will take the most conservative (worse-case) stance. Credit will only be given for management actions that demonstrably comply with the Operations standard. Records should be kept of all actions taken to meet the requirements of the ESMP. Similarly records and motivations must be kept of all changes / modifications to the ESMP. 4.3 Reviews Site management at the CTT complex shall establish an environmental committee. This committee shall meet on at least a monthly basis to review environmental performance, including incidents/non-conformances reported, corrective actions implemented, monitoring results, ESMP compliance, internal and external audit findings and remedial actions taken. Management actions and planning shall be specified based on the results of the review. The monthly meeting shall be documented. In addition, a management review meeting shall be held on at least an annual basis to review the status of Environmental Management and ESMP implementation and to ensure the continued effectiveness of the ESMP as well as its appropriateness. The review meeting shall be attended by senior management. The meeting shall be documented. The management review should:  Review ESMP objectives and evaluate the need for new or revised objectives, as appropriate;  Set new objectives as appropriate;  Evaluate environmental performance and the effectiveness of the ESMP by reviewing monitoring and audit results;  Evaluate changing circumstances and how these may influence and be reflected in the ESMP. This could include changes to permits, contracts, loan agreements etc;  Examine the results of any action items from the previous management review meeting; and  Examine the remedial actions taken to address non compliances and close out of any external audit findings. 4.4 Corrective and Preventive Action The need for setting corrective action will arise from deviations from:  A predetermined baseline or limit (as detected through monitoring) or  ESMP requirements. 82 March 2019 In this regard, CTT shall establish an incident and non-conformance reporting procedure. The procedure shall include details for:  Ensuring the recording of incidents / non-conformances  Reporting channels for incidents / non-conformances  The identification of corrective and preventative action measures. Corrective actions shall be identified based on incident / non-conformances reported and on the results of ESMP monitoring, internal or external ESMP audits and/or management review. Corrective action should result in:  The implementation of a specific action(s) to remedy the identified deficiency(ies) or  A change to the targets or objectives set in the ESMP and  Corrective actions implemented shall be documented. Should it be considered by Government Authorities that operational activities are causing unacceptable environmental damage; the SES and Operations Manager through the Corporate Affairs Department will immediately consult with the Government and agree on the remedial measures to be taken. Such agreed measures shall be undertaken immediately to prevent further damage and to repair any damage that may have occurred. 5.0 COMPETENCY, TRAINING AND AWARENESS CREATION Those persons who are involved in activities that could result in an environmental impact(s) must receive appropriate environmental awareness training (and must also possess the necessary skills so as to successfully and responsibly undertake their tasks). All employees must be made aware of CTT’s undertaking to conduct the proposed activities in a manner that is respectful to local people, their land and resources and sensitive biophysical habitats. Training shall take the form of, but not be limited to: induction training, use of educational posters and toolbox talks. During these training sessions, the following principles should be presented / discussed:  ESIA and ESMP commitments;  Restrictions and procedures for operations;  Restrictions and procedures for collection, treatment and disposal of waste and hazardous substances;  Statement and clarifications of CTT’s communications policies;  Firefighting procedures;  Procedure for emergency preparedness and response;  Procedures for incident reporting and handling; and  Need to refrain from destruction of animals and plants, indiscriminate defecation, waste disposal and/or pollution of local soil and water resources. 6.0 CONTINGENCY AND DECOMMISSIONING PLANNING CTT shall undertake and submit full decommissioning proposals at least 2 years in advance of decommissioning, in accordance with the requirements of CTT’s Framework Decommissioning and Rehabilitation Plan (yet to be developed). 83 March 2019 7.0 EMERGENCY PREPAREDNESS AND RESPONSE CTT shall develop an Emergency Response Plan for the CTT activities. These plans shall identify the potential for, and response to accidents and emergency situations in accordance with Mozambique law and recognised international standards. The plans shall also address measures to prevent such situations and to mitigate environmental impacts that may be associated with them (SHE Manager). The emergency plans shall include the establishment of a network of communication between CTT, employees, contractors, available emergency services including police, traffic police, fire departments, community associations, specialist services etc. that may be available. The emergency plan(s) shall be tested on a regular basis through the use of drills and mock emergencies so as to identify and rectify any shortcomings (Production Manager and SHE Manager). 8.0 REPORTING REQUIREMENTS All reporting shall be as per CTT reporting structures and as specified elsewhere in the ESMP, or as per legal requirements. In addition to all reporting requirements identified in the ESMP, records shall be kept of all monitoring results, monitoring reports, incident records, audit reports (encompassing environmental, social and health and safety aspects) and management reviews. Minutes of all environmental Operations meetings shall be maintained. Where monitoring reports are prepared by independent specialists, the recommended actions in the reports shall be recorded, assessed and acted upon. All reports shall be managed as per the requirements of Section 9.0. 9.0 DOCUMENT CONTROL The ESMP forms the basis for environmental management on site. Based on the results of the performance assessment and review process (Section 4), the ESMP may be modified as the Operations progress. Modifications shall only be permitted by the SHE Manager and shall be approved by MITADER and receive non-objection from the World Bank. A single master copy of this ESMP shall be retained in the document control system. All changes to the ESMP shall be made as per the CTT Document Control Procedure to which all affected parties shall comply. This procedure should define document modification, distribution, retention and management of ESMP revisions. The SHE Manager shall ensure that any modifications are communicated, explained to and discussed with all affected parties (i.e. the authorities, contractors, employees, Operations Manager and any affected party who requests this information). 84 March 2019 Signature Page Golder Associados Moçambique Limitada NUIT 400196265 Directors: G Michau, RGM Heath Golder and the G logo are trademarks of Golder Associates Corporation g:\projects\18103533 - sasol mgip esia\6. deliverables\drafts\oemp\18103533-321207-27b_rep_ctt_operation esmp_final_29112018_golder revision.docx 85 golder.com