PROJECT TITTLE Environmental Management Plan

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VICS CONSTRUCTION COMPANY

PROJECT TITLE:

DOCUMENT TITLE:
ENVIRONMENTAL MANAGEMENT & POLLUTION PREVENTION PLAN

DOCUMENT NUMBER :
Document Type
Country and Facility And Equipment Sequence
Code Originator Discipline Subtype Location Number

Approve
Rev. Date Description By Checked
d

M10 – PHASE 1

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PROJECT TITTLE Environmental Management Plan
ENVIRONMENTAL MANAGEMENT PLAN

1 ENVIRONMENTAL MANAGEMENT PROGRAM................................................4

1.1 OBJECTIVES..........................................................................................................4
1.2 KEY PRINCIPLES...................................................................................................4
1.3 ABBREVIATIONS AND DEFINITIONS......................................................................6
1.4 POTENTIAL ENVIRONMENTAL IMPACTS...............................................................6
2 ENVIRONMENTAL MANGEMENT PLAN (EMP)............................................9
2.1 SCOPE...................................................................................................................9
2.2 OBJECTIVES..........................................................................................................9
2.3 ENVIRONMENTAL MANAGEMENT PROTOCOLS..................................................10
2.3.1 General..........................................................................................................10
2.3.2 Risk Management...........................................................................................10
2.3.3 Implementation Strategy................................................................................11
2.4 REPORTING PROCEDURE....................................................................................11
2.4.1 Reference Document and Control..................................................................11
2.5 ORGANIZATION...................................................................................................12
2.6 ASSESSMENT AND EVALUATION........................................................................12
2.7 TRAINING...........................................................................................................12
2.8 EXPECTATIONS...................................................................................................14
2.9 PROCEDURES......................................................................................................14
3 WASTE MANAGEMENT PLAN (WMP)............................................................15
3.1 OVERVIEW..........................................................................................................15
3.2 WASTE MANAGEMENT.......................................................................................15
3.3 WASTE MANAGEMENT PHILOSOPHY.................................................................15
3.4 WASTE MINIMISATION.......................................................................................15
3.5 GENERAL WASTE MANAGEMENT CONTROLS....................................................16
3.6 TASKS.................................................................................................................17
3.7 REPORTING.........................................................................................................18
3.8 WASTE STEAMS..................................................................................................18
3.9 ROLES & RESPONSIBILITIES...............................................................................19
3.10 LIST OF WASTE MANAGEMENT SITES...............................................................19
3.11 WASTE REDUCTION/MINIMISATION STRATEGIES..............................................19
3.12 PACKAGING, TESTING, LABELLING, STORAGE AND TRANSPORTATION OF
WASTE 20
3.13 RECORDKEEPING................................................................................................20
3.14 MONITORING OF WASTE MANAGEMENT ACTIVITIES........................................21
4 SPILL RESPONSE PLAN (SRP)...........................................................................22
4.1 OIL SPILL MANAGEMENT & CONTINGENCY......................................................22
4.2 GENERAL OIL SPILL MANAGEMENT GUIDELINES..............................................22
4.2.1 Oil & Fuel Spills............................................................................................22
4.2.2 Hazardous Chemical Spills............................................................................23
4.3 REPORTING.........................................................................................................24
4.3.1 Oil Spill to Water...........................................................................................24
4.3.2 Oil Spill to Land.............................................................................................24

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PROJECT TITTLE Environmental Management Plan
4.3.3 Chemical Spill to Water.................................................................................25
4.3.4 Chemical Spill to Land..................................................................................25

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PROJECT TITTLE Environmental Management Plan

1 ENVIRONMENTAL MANAGEMENT PROGRAM

1.1 Objectives
Protection of the environment is of principal concern to VCC, thus making the
environmental aspect of the Health, Safety and Environmental (HSE) Plan an essential
part of the PROJECT. The objective of this document is to:

 Identify the legislative and regulatory requirements governing environmental

matters.

 Identify the client requirements for managing environmental matters on the

PROJECT.

 Summarise the project environmental management structure and processes to be

implemented by VICS Construction Company and its sub-contractors during the
implementation/execution of the PROJECT.
Through this plan, VICS Construction Company will provide best practice in
environmental matters and ensure that the standards for environmental protection are
maintained at the highest levels during the execution of PROJECT. It will ensure the
systematic planning and implementation of all aspects of the work scope relating to
environmental management. This includes FEED, detailed design, procurement and
construction management (e.g. management of design office, fabrication, installation and
commissioning). The Environmental Management Plan will, by stating systematic
principles and responsibilities, and referencing procedures and requirements, ensure that
all activities are organised and managed in a consistent manner and in accordance with
project requirements and environmental goals, as defined by the Environmental
Management Program adopted by the Project.
The Environmental Management and Regulatory Compliance Program is established to
ensure compliance with all laws and regulations associated with each project.
There are four major plans included;

 Environmental Management Plan

 Regulatory Compliance Plan

 Waste Management Plan

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PROJECT TITTLE Environmental Management Plan
 Spill Response Plan
This Environmental Management and Regulatory Compliance Program will apply to all
sites under the management of the PROJECT Project Team and to subcontractors that
provide services to PROJECT.

1.2 Key Principles

Environmental excellence is a primary management objective and the responsibility of
every PROJECT team member. VICS Construction Company is dedicated to continuous
efforts to make its operations compatible with minimizing our impacts on the
environment. The VCC Project team is committed to achieving environmental excellence
in all of its business practices and operations through the key principles outlined below:

 Commitment - Management at all levels will be actively committed to the

achievement of environmental excellence in the conduct of our business in
accordance with VICS Construction Company Corporate Environmental Policy.
Through communication with our project team members, it is our goal to ensure that
the commitment to environmental excellence is reflected in our day to day work.

 Organization - A project team-wide organizational structure and culture will be

established that recognizes and encourages the full and active participation of all
employees in the systematic identification, assessment and management of
environmental issues.

 Accountability - Responsibility for the protection of the environment is a matter

of corporate policy and is a matter of law, with potentially severe consequences for
failure to comply. Management at all levels is responsible for ensuring that
operations are conducted in accordance with this policy and that appropriate
environmental programs, procedures and systems of work have been developed and
implemented for the project.

 Management Systems and Standards – The PROJECT team will develop,

implement and continuously improve the project environmental management
systems and develop environmental management standards using company
documented standards where available, ensuring that they reflect best industry
practices.

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PROJECT TITTLE Environmental Management Plan
 Risk Management – The PROJECT team will ensure that potential environmental
risks associated with all our designs and activities are assessed as early as is
practicable in order to minimize and manage adverse effects and to identify
opportunities for improvement.

 Legislative Compliance – The PROJECT team will operate to standards that will
comply with the requirements of applicable local and appropriate national and
international legislation and codes of practice and will strive beyond compliance and
recognize these principles as a valued way of life.

 Training - Health, safety, and environmental managers and staff will be qualified
by reason of education or experience to discharge their responsibilities and will
participate in a program of continuing professional development. In addition, the
project team is committed to provide training and development on environmental
matters that is appropriate to each employee's job duties and responsibilities. The
project team will be proactive in the management of third party contractors to ensure
they are fully aware of the environmental issues and to ensure that their actions are
aligned with project environmental standards.

 Environmental Aspects – The project team will continuously evaluate the

environmental aspects of the project activities through all of its phases. The goal will
be to develop and provide products and services that have minimal environmental
impact and are safe in their intended use, efficient in their consumption of energy and
natural resources and can be recycled, reused or disposed of safely.

 Continuous Improvement – The PROJECT team believes that effective

environmental management is good business and is committed to continuous
improvement of environmental management practices.

 Monitor, Audit and Review - Effective management requires on-going assessment

and review, accordingly, an on-going assessment, self-evaluation and audit program
shall be implemented and maintained for the project activities. The objective of this
program is to provide management with verification that operations are in
compliance with laws, regulations, Company policies and standards and to facilitate
the spread of best practices throughout the project operations.

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PROJECT TITTLE Environmental Management Plan
The plan will be distributed as a controlled copy to the Client, VICS Construction
Company, Government Agencies, the Project Manager, the HSE Manager and or
Environmental Coordinator, and will be freely available to all PROJECT Team members
and Subcontractors.

1.3 Abbreviations and Definitions

ALARP As Low As Reasonably Practicable
VCC VICS Construction Company
DPR Department for Petroleum Resources
EI Environmental Impacts
EIA Environmental Impact Assessment
EMP Environmental management Plan
EIS Environmental Impact Statement
FEED Front End Engineering Design
HSE Health, Safety and Environment
RCP Regulatory Compliance Plan
SEA Strategic Environmental Assessment
SIA Socio-Economic Impact Assessment
SRP Spill Response Plan
WMP Waste Management Plan

1.4 Potential Environmental impacts

An Environmental Impact Statement (EIS) will be prepared for PROJECT which
provides an initial assessment of potential or actual environmental impacts associated
with the project and the development as a whole, and may contain environmental or
engineering commitments. Similarly, a preliminary other (or Public) Environmental
Review may exist, which shall be use as the basis for further environmental studies.
The Environmental Plan shall cover how the project intends to manage those impacts
identified in the EIS, and any further potential impacts and risks that arise or are
identified during project activities.
Potential Environmental Impacts (Hazards) may also be identified via Project Risk
studies (eg HAZID, HAZOP and Job Hazard Analysis) Consultation, etc, or by review of
the Project Hazard Register. Note; if a Hazard Register does not exist, or does not

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PROJECT TITTLE Environmental Management Plan
address Environmental Hazards, then the Project should develop a register to assist in
managing this aspect.
The Environmental Plan for PROJECT shall cover how the project intends to manage
those impacts identified in the EIS, and any further potential impacts and risks that arise
or are identified during project activities.
In the absence of an existing EIS then sufficient environmental data must be gathered
and-or be derived and documented, to provide the environmental context in which the
project is to be developed, and to identify and quantify where possible, the project risks
and impacts:

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PROJECT TITTLE Environmental Management Plan

2 ENVIRONMENTAL MANGEMENT PLAN (EMP)

The EMP will define the set of procedures to ensure that all aspects of the environment
are taken into consideration during the course of the project.
It will document how management of environmental and socioeconomic aspects are to be
achieved for each site on the PROJECT project.
It communicates the implementation of mitigation measures for risks identified in the
Environmental and Socioeconomic Impact Assessment (SIA).
Social and economic analysis shall be carried out to assess effects of proposals on quality
of life, cultural, social and economic needs, values of affected communities or
individuals, human health and environmental risk.

1.5 Scope
The scope of the EMP will cover the areas, populations and ecosystems which have the
potential to experience environmental impacts due to the VICS Construction Company
work processes.
Integrating social, economic and environmental concerns early on in the planning of the
project will evade impacts, remediation costs, delays and reduce risk associated with the
project.

1.6 Objectives
The purpose of the EMP is to describe the methods, processes and actions used to comply
with the appropriate laws and regulations and also describe the measures taken to
adequately mitigate these impacts. The tasks include:

 Identification of environmental impacts: This includes a list of all the factors of

potential adverse effects on the environment including the topography, terrestrial,
aquatic and ecological areas;
 Identification of human impacts: Effects of all activities on the employees and
individuals living in the immediate environment;
 Identification of potential synergistic effects: Effects on current and proposed
projects;
 Strategic Environmental Assessment (SEA): Evaluation of all policies, plans or
programs to ensure environmental issues are taken into consideration during the
planning of the project;

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PROJECT TITTLE Environmental Management Plan
 Environmental Impact Assessment (EIA): Evaluation of the environmental effects
of the planned work activities;
 Socioeconomic Impact Assessment (SIA): Evaluation of the social and economic
impacts of the project directly and indirectly on the immediate community; and
 Mitigation measures: Steps taken to reduce or eliminate adverse effects on the
environment (social, economic and ecological).

We will ensure that environmental excellence is vigorously pursued and that measurable
benefits and the highest level of standards are met throughout the project lifecycle

1.7 Environmental Management Protocols

1 .7 .1 General
This section outlines the environmental management protocols to manage, mitigate and
prevent potential impacts associated with the design, fabrication, installation and
commissioning of PROJECT.
The environmental management protocols stipulated in this plan will be consistent with
Client’s and VICS Construction Company’s environmental commitment of “no damage
to the environment”. They will also be set in the context of specific environmental
management system and targets and the industry’s environmental standards and practices.
PROJECT believe that all environmental incidents are preventable. We understand the
ecological significance of the environments and the anthropological and cultural
importance of the region and are committed to achieving positive social impact. We also
understand that design decisions made now will influence emissions, discharges and
wastes for the life of the project. While understanding budget restrictions there are some
pre-investment decisions that are good business and may save future operational costs.
VCC will incorporate these into designs and procedures as appropriate; where a
significant cost of adopting such good practice is identified, the issue will be raised with
the Client and alternatives discussed, relative to base case compliance.
Resources will be made available to ensure environmental integrity is maintained at the
highest standard in design products and at places of work. We are committed to

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PROJECT TITTLE Environmental Management Plan
undertaking the PROJECT so that at no time will any individual or the environment be
endangered.

1 .7 .2 Risk Management
To meet the requirements of MPN, DPR, other Government agencies and regulatory
authorities; the management of environmental issues will be carried out in such a way
that all stakeholders will be left with no doubt that hazards to the environment have been
identified and appropriately managed. This will be achieved by:

 Setting and documenting clear and measurable environmental targets, goals,

standards and performance objectives at the outset;

 Defining clear accountabilities and responsibilities;

 Rigorously identifying, assessing and eliminating/preventing/mitigating

environmental risks;

 Assessing constructability, operability and decommissioning at the design stage to

minimise environmental risk;

 Identifying environmental values and enhancing options and solutions;

 Utilizing the best available tools and human resources;

 Meeting the current and anticipated future legislative requirements; and

 Achieving clarity, transparency and auditability.

1 .7 .3 Implementation Strategy
VICS Construction Company will implement this Environmental Plan throughout
PROJECT in accordance with the project Environmental Management System. In
following this plan, fit for purpose systems, practices or procedures will be utilised and
documented, or developed (where they don’t currently exist) to ensure best practice and
that environmental risks and effects are as low as reasonably practical (ALARP).
The EMP is an integral part of the Project planning and organisation and will be
championed and controlled by the management team; those with discipline responsibility
for environmental affairs are outlined in the plan, however this does not relieve line

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PROJECT TITTLE Environmental Management Plan
managers and specific discipline engineering groups or subcontractors, whose designs or
activity may impact the environment, from their responsibilities.

1.8 Reporting Procedure

All data relating to environmental policies, regulations and control shall be properly
documented and periodical reports (monthly) would be given to the Client.
All environmental management documentation generated on PROJECT, whether hard
copy or electronically generated, will be controlled in accordance with the Project
Document Control Procedure. All electronically stored information will be backed up
daily and stored in a separate and safe location

1 .8 .1 Reference Document and Control

The EMP shall define the link between Environmental and Socioeconomic Assessment;
the Waste Management Plan and the Spill Response Plan. It encompasses the different
sections of the environmental issues associated with the project. It will also define how
the Plan is to be implemented.

1.9 Organization

Description of the VICS Construction Company’s environmental and socioeconomic

organisation, including identification of staffing, facilities and equipment.

Procedures for managing change of personnel responsible for tasks.

Description of VICS Construction Company’s measures for ensuring roles and

responsibilities are clearly defined, documented and communicated to the relevant
parties.

Discussion of the endorsement process for deliverables during each stage of the project.

Procedure for creating environmental awareness within the construction personnel.

1.10 Assessment and Evaluation

A mechanism shall be put in place to:

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PROJECT TITTLE Environmental Management Plan
 Evaluate the effectiveness of the environmental and socioeconomic mitigation
measures.

 Monitor and enforce compliance with the EMP.

 Ensure data collected is used to implement remedial action and improve

performance (shall include compliance indicators to be measured frequently).

 Document, report and investigate incidents of non-compliance (lessons learned

shall be recorded)

1.11 Training
The PROJECT HSE Training Coordinator will ensure that all personnel working on the
Project have received adequate training to enable them to perform their work
functions/tasks in a safe and efficient manner. All new staff, both PROJECT and
subcontractor personnel, will receive induction training covering relevant Project
environmental requirements at the commencement of their work.
PROJECT HSE will be responsible for the development of a site-specific training matrix.
This training matrix will include, as a minimum, training needed for individual work
functions and tasks. All training courses, together with records of personnel attendance,
will be fully documented with a view to implementing further refresher courses where
appropriate. These records will be maintained at site, and copied to PROJECT office.
Table 1 outlines typical requirements of environmental awareness training.

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PROJECT TITTLE Environmental Management Plan
TABLE 1: TYPICAL ENVIRONMENTAL AWARENESS TRAINING

Classification Offices Onshore sites Offshore sites

All personnel, Environmental Environmental Environmental

including Visitors induction (as part of induction (as part of induction (as part
the HSE induction) the HSE induction) of the HSE
induction)

Management Corporate and Project Project Project

Environmental Environmental Environmental
Management Systems Management Management
and Project Systems and Systems and
Environmental Plan Environmental Plan Environmental
implementation implementation Plan
training training implementation
training
Discipline Leads Environmental Plan Environmental Plan Environmental
awareness training awareness training Plan awareness
training

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Classification Offices Onshore sites Offshore sites

Select employees Project Environmental Project Project

eg HSE Management Systems Environmental Environmental
Advisors / Focal and Environmental Management Management
points / Champions / Plan awareness Systems Systems
Representatives training Environmental Plan Environmental
awareness training Plan awareness
Local Spill training
management, Local Spill
chemical handling management,
and storage chemical handling
management and storage
management

PROJECT HSE will operate a staff competency assurance system which sets a
benchmark for the level of competency required for the environmental management of
the MPN PROJECT.

1.12 Expectations
 VICS Construction Company will ensure that all environmental legislations are
adhered to.

 Performance indicators shall be developed to monitor performance

 Targets shall be established

 Measures to achieve desired results shall be well defined.

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1.13 Procedures
The site-specific baseline data collection process shall be described for work sites where
an EIA or SIA has been carried out.
Mechanism for obtaining endorsement for deviation from specifications or for changing
procedures/designs is necessary.
There shall be provisions for incorporating improvements into the environmental
management system.
Programs to mitigate environmental or socioeconomic impact shall be site-specific.

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PROJECT TITTLE Environmental Management Plan

2 WASTE MANAGEMENT PLAN (WMP)

During the course of activities for the project, waste will be generated from the use of raw
materials and construction materials on the work sites; therefore, there is a need for the
development of a WMP to comply with the applicable standards for waste minimisation,
mitigation and management, including treatment and disposal.

2.1 Overview
Waste is an issue of major concern for sustainable resource use. Degradation of areas of
operation has put a strain on agriculture, fishing and economic stability of local
communities. These activities have eroded the livelihoods of many individuals.
Legislation requires that operations be conducted with proper environmental practices.
There are numerous ways the waste issue can be combated, but the waste hierarchy
should be followed for optimum results.
The volume of waste generated should be reduced during the course of the project to
mitigate the cost implication of management, treatment and disposal.

2.2 Waste Management

Management of fabrication, installation and commissioning waste will be achieved by
implementation of the Waste Management Plan that includes best practice waste
minimisation ideals, assessment of potential contractors regarding their regulatory
certification-license, proposals for the management of waste materials, reducing the
amount of waste sent to landfill, and treating liquid waste.

2.3 Waste Management Philosophy

The following provides a framework for the management of wastes generated during the
implementation of the project.

 All personnel will be made aware of, and site personnel trained, to implement the
Waste Management Plan;

 A waste tracking system will be implemented to provide an inventory of all waste

materials generated during the project, their characteristics, quantities and fate;

 Wastes will be eliminated, minimised, reused and recycled, where safe to do so.

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2.4 Waste Minimisation
The initial thrust of waste management will focus on waste elimination, followed by
waste minimisation and will include the following measures:

 limiting waste creation through the tendering process by encouraging suppliers to

implement waste management responsibility;

 waste reduction at the source by ordering to size and purchasing in bulk;

 separating and segregating waste at the site of their generation;

 reuse and/or recycling of materials, where safe to do so;

 incentive schemes to encourage recycling by personnel, where safe to do so;

 Making wastes available to personnel and others for reuse (where legal and safe to
do so, ensuring no liability).

2.5 General Waste Management Controls

The following provide a guideline framework for the management of wastes generated
during the implementation of the project.
Solid Wastes
Solid waste management during design, fabrication, installation and commissioning will
include the following actions:

 General wastes will be segregated at the facility and disposed via a licensed
contractor and to a licensed facility;

 Designated waste collection and storage areas will be identified and marked;

 Designated collection bins will be provided to facilitate waste segregation;

 Loose waste and bins will be kept covered;

 Wastes will be progressively removed from the facility and not allowed to
stockpile;

 Disposal of prescribed wastes will be undertaken via a licensed contractor and to a

licensed facility;

 Waste collection areas will be inspected daily to confirm that waste is contained
satisfactorily.

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PROJECT TITTLE Environmental Management Plan
 Special attention will be given to hazardous wastes including eg clinical wastes,
putrescible wastes and radioactive wastes
Liquid Wastes
Liquid waste management during design, fabrication, installation and commissioning will
include the following actions:

 Produced, cooling, drainage, sewage (black), domestic (grey) waters etc will be
handled via engineering design

 All other waste liquids will be stored in bunded areas pending their disposal;

 Hydrotest water will be reused, whenever possible;

 Drainage systems will be designed to segregate stormwater runoff from non-

hazardous and hazardous areas;

 Potentially contaminated stormwater will be treated (e.g. by oil/water separators);

 Slops water will be monitored for oil-in-water content;

 Sewerage will be treated in a certified sewerage plant. Any sewerage discharge to

sea will comply with required standards;

 Special attention will be given to hazardous wastes

Gaseous Waste Emissions
Gaseous waste management during design, fabrication, installation and commissioning
will include the following actions:

 Regular maintenance of equipment and machinery will be undertaken to minimise

NOX, SOX, CO2, CO emissions;

 Low sulphur diesel will be used where available;

 Design will evaluate surplus gas use or re-injection during normal operations

 The sources of Greenhouse gases will be identified and reduction evaluated where
practical during design (i.e. Waste Heat Recovery, Energy efficiency, etc, will be
evaluated);

 Fuel and flare, purge and pilot, elimination or minimisation strategies will be
evaluated to reduce Greenhouse gas emissions.

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PROJECT TITTLE Environmental Management Plan
 Fugitive emissions will be reduced by selection of appropriate valves and seals
and minimising the number of flanges.

2.6 Tasks
Waste shall be properly collected and segregated at each work site in order to reduce the
management costs and human and environmental impacts. A strategy for collection and
disposal will be established on a site-by-site basis so the waste can be managed
effectively. The following shall be taken into consideration:
- Collection of waste generated
- Classification of waste stream (hazardous waste, construction waste, household
waste)
- Segregation of waste on site
- Measurement of waste volumes
- Calculation of waste aggregates
- Disposal Routes
i) Collection by waste disposal contractor
ii) Collection by local authority
iii) Return to manufacturer
iv) Incineration
v) Transfer to landfill sites
vi) Treatment
- Transportation by waste contractor

2.7 Reporting
Data on all waste streams and calculation methodology related to the project shall be
accurately documented and supplied on a monthly basis by Delta Afrik and all
subcontractors.
Hazardous waste and construction waste will be recorded separately.

2.8 Waste Steams

A table using the format below shall be produced showing the various types of waste to
be generated, projected frequencies of generation, quantities when generated and the
preferred treatment and disposal methods for each waste.
TABLE 2: Summary of waste

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PROJECT TITTLE Environmental Management Plan
MANAGEMENT OF SPECIFIC WASTES

Type of Frequency Volume Treatment Disposal

Waste EXAMPLE Method

Waste oil As needed 2.5 bbls Recycle Collection by 3rd party

facility

Human Daily 600m3 Wastewater/sewage Collection by 3rd party

treatment facility

Solid waste Daily EXAMPLE

1000m3 segregation Collection by 3rd party
facility

Hazardous As needed 7 12v Hazardous Waste Collection by 3rd party

waste Lead Disposal facility
Acid
Batteries
The different types of waste would require varied management depending on the risk
associated with exposure.

- Hazardous waste shall be handled with care and properly collected so that
disposal does not cause potential impacts to humans or the environment.

- A human and ecological risk assessment shall be carried out periodically to ensure
minimal or zero impact to the environment.

- Environmental Impact Assessment (EIA) shall be carried out on all sites of the
project to mitigate impact to the environment

- Municipal waste from living quarters should be separated on site and transported
for recycling purposes.

- Construction waste could be reused or transported to be used as a resource for

other industries.

2.9 Roles & Responsibilities

The roles of each individual with regards to waste management are defined as follows:

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VICS Construction Company/PROJECT Environmental Coordinator:

- Establish a Project Waste Management Plan (WMP) to ensure waste is handled

appropriately.

- Ensure adequate waste transport and disposal system is in place

- Ensure adequate site training

- Perform periodical audits and reviews to ensure compliance to waste regulations.

Subcontractor:

- Implement the Waste Management Plan

- Develop waste minimisation strategies

- Ensure waste is collected, managed and disposed effectively

- Produce accurate data on waste

Employees:

- Ensure minimal waste generation from work sites.

- Waste segregation.

- Complying with the requirements of waste management plan.

2.10 List of Waste Management Sites

This will cover the location and engineering standards for the waste facilities to be used.
This document shall include the list of disposal sites such as landfills, solid waste
facilities or recycling facilities, depending on the waste material to be disposed of.

2.11 Waste Reduction/Minimisation Strategies

Established steps to be taken to minimise the amount of waste generated shall include, but not
be limited to:

- Reuse of waste raw materials.

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PROJECT TITTLE Environmental Management Plan
- A sustainable recycling methodology shall be established to reduce the amount of
waste requiring disposal.

- Reduce the amount of packaging used for raw materials.

- Create awareness on waste minimisation strategies among workers.

The process used to minimise the need for and use of hazardous substances that have
adverse effects on the environment shall:

- Limit the use of hazardous substances in order to comply with strict environmental
laws.

- Only registered and authorised substances should be used during the project.

- Banned substances should not be used in the execution of the job therefore details
of each substance shall be provided.

- Education and awareness shall be provided on the toxicity of hazardous substances

- Proper waste container labelling as described below.

2.12 Packaging, Testing, Labelling, Storage and Transportation of

Waste

A depot shall be provided to collect and store the waste in anticipation of

transfer to disposal sites.
Methods used to handle waste safely from site through different disposal routes shall be
properly defined.
Hazardous waste shall be labelled and package properly to prevent risk of exposure when
handled.
Eco-toxicology datasheets shall be provided for all chemicals so that information on the
potency of chemicals is available.
Employees handling the substances shall have access to toxicological information and
have proper verifiable training.
Methods to be used for transportation shall be established to ensure safety.

2.13 Recordkeeping
A system or database of information shall be developed and periodically updated to
enable tracking the amount of waste type generated and how it is managed and disposed.

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PROJECT TITTLE Environmental Management Plan
A waste manifest system shall be utilised.
Operating waste disposal sites will maintain a database of information on the amount of
waste received and the final destination within the facility.
A Plan to include information on its software packages and sample waste tracking form
upon request

2.14 Monitoring of Waste Management Activities

Description of a monitoring system to record waste generated, waste volume
compositions, water treatment, effluent quality, types and quantities of waste recycled
etc. shall be provided.
Soil and water resources shall be monitored to mitigate impacts
When operating in multiple locations, the WMP shall take into consideration any site
specific modifications to fit into the overall plan.

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SPILL RESPONSE PLAN (SRP)

The Spill Response Plan is developed to ensure prevention, control and counter-
measures are in place should any release occur on the worksites during the project.
VICS Construction Company and subcontractors shall report immediately to MPN any
spills. They shall supply spill summaries on a monthly basis.
A description of methods, processes and actions that the subcontractors intend to use to
prevent, respond and mitigate environmental impacts of spills of all substances shall be
provided.
A contingency plan shall be developed to coordinate all aspects and levels of response to
oil spills.
Emergency response actions to be undertaken in event of a spill shall be provided by the
subcontractor.
Notification procedures shall also be provided.
If necessary, utilization of an appropriate spill response company or agency shall be
considered for major events.
Subcontractor shall promptly report major spills to VICS Construction Company and
maintain a log of all spills and response actions taken.
A list of all spill response equipment to be provided on the work site shall be provided by
VICS Construction Company.

2.15 Oil Spill Management & Contingency

A Comprehensive Oil Spill Management and Emergency Procedures will be developed
by PROJECT, unless the MPN has procedures in place. These procedures require
approval from DPR and they should stipulate systematic reporting and response measures
to be undertaken for various levels of accidental spills. The following general oil spill
management guidelines provide a basic framework for the prevention and management of
spills during the Develop, Execute and Operate Phases of the project.

2.16 General Oil Spill Management Guidelines

2 .1 6 .1 Oil & Fuel Spills

Oil and fuel management during design, fabrication, installation and commissioning will
include the following actions:

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 All oils and fuels will be stored in bunded areas;

 The integrity of the fabrication facility and associated equipment will be regularly
inspected, audited and maintained on an ongoing basis to avoid oil leakages or
spills;

 Personnel will be trained in all offloading and fuel handling procedures;

 Subsea equipment (e.g. flowlines) will be designed to be resilient and have external
coating in accordance with industry standards to protect against damage from
snagging or dropped objects;

 The design will include level indicators, overflow detectors, bunds or coamings and
drainage systems to prevent and contain fuel spills;

 Breakaway couplings will be used on offloading hoses and export hoses will be
flushed back to tanks following offloading activities;

 Unique couplings will be installed on fuel hoses to ensure correct use of lines;

 Marine refuelling procedures will state specific thresholds of sea conditions where
fuelling can and can not take place;

 Adverse weather (e.g. Cyclone) response strategies will be developed to protect the
environment against accidental discharges;

 The location of the facility will be notified to the DPR (so it can be marked on
maps/official marine charts) to minimise the potential for collision. Facilities will
have appropriate navigation and or aircraft warning lights. Offshore facilities will
have collision radar equipment to detect nearby vessel movement;

 Bunding and spill response equipment will be readily available to contain small
leaks and spills, and personnel made familiar with its use and associated waste
disposal;

 Ensure Stocks of spill response equipment are available from the subcontractors.

 The availability of Real-time oil spill trajectory models from the operating
company should be established;

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 All spills greater than one barrel (160 litres) will be recorded and reported
internally, to the MPN.

2 .1 6 .2 Hazardous Chemical Spills

Hazardous chemical management during design, fabrication, installation and
commissioning will include the following actions:

 Chemicals will be selected based on the least potential for environmental impact.

 All appropriate personnel will be trained in chemical handling and storage

procedures;

 Material Safety Data Sheets (MSDS) will be readily available for all chemicals at
the facility and at the worksite;

 All hazardous chemicals will be stored within bunded areas (onshore this typically
will have a volume of at least 110% of the volume of the largest vessel Offshore
this may not be practical or safe.);

 Surface runoff will be excluded from the bunded areas;

 Any materials within the bunded areas (including spillage and direct rainfall) will
drain to a sump from where it can be inspected and disposed of or treated in an
appropriate manner;

 No contaminated stormwater will be released directly into the environment;

 The bunds and sumps will be regularly inspected.

 Any actions required to repair damaged storage containers and remove spillage
from the bunded area will be undertaken as soon as practical;

 Spill trays will be provided to capture any spillage from chemicals, fuels and oils
usage areas. All materials in the spill trays will be decanted into an appropriate
waste storage container for later disposal at an approved waste disposal facility.

 Drainage systems and storage bunding will be designed to retain spilled material
and reduce the likelihood of escape.

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2.17 Reporting
VICS Construction Company shall report spills at work sites to DPR in compliance with
the regulations while all documentation of the spills will be provided by the
subcontractor.
The following criteria shall be used to determine a reportable spill on worksite:

2 .1 7 .1 Oil Spill to Water

Includes petroleum derived liquids (crude oil, condensate, gasoline, diesel fuel) and
petroleum derived solvent (toluene, xylene etc.).

i. Volume of each spill: Any spill volume greater than one (>1) barrel of oil
(160 litres) requires immediate report to DA
ii. Spill directly to water or reaching surface water (streams, creeks, rivers,
lakes, ponds, ocean)
iii. Excludes off premise, non-marine transportation spills where the product
is in custody of third party carrier.

2 .1 7 .2 Oil Spill to Land

i. Any spill volume greater than one (1) barrel of oil (160 litres).

ii. Spill must have contact with soil. Excludes spills inside containment or
collection areas.

iii. Include spills from tank bottoms and underground storage tanks.

iv. Report the total volume in barrels or litres of oil spilled to land regardless of
amount recovered.

v. Excludes off property transportation spills when product is in custody of third

party.

2 .1 7 .3 Chemical Spill to Water

i. Any spill volume greater than 100 kilograms (kg).

ii. Spills directly to water or reaching surface water.

iii. Include spills of all non-petroleum derived chemicals (methanol, sulphuric

acid, caustic, stimulation acid, etc.)

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iv. Excludes spills of insoluble solids to water that have no environmental
impacts (e.g. plastic pellets).

v. Exclude off property, non-marine transportation spills

2 .1 7 .4 Chemical Spill to Land

i. Any spill volume greater than 100 kilograms (kg).

ii. Spill must contact the soil to be reportable.

iii. Include spills of all non-petroleum derived chemicals.

iv. Include spills or leaks from tank bottoms and underground storage tanks

v. Report the total mass in kilograms of chemicals spilled to land regardless of

mass recovered.

vi. Exclude spills of insoluble solids to land without environmental impacts.

vii. Exclude off premise transportation spills.

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PROJECT EPCM-1 Regulatory Compliance & Environmental Management Plan

PROJECT EPCM-1 Regulatory Compliance & Environmental Management Plan 5/4/2007

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