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Waste Management PlanTable of Contents1SOLID WASTE31.1Introduction31.2Waste management31.2.1Proposals for Minimisation31.2.2Waste segregation and management41.2.3Disposal and Treatment Options51.2.4Duty of Care Compliance61.2.5Landfill71.2.6Waste Disposal Categorization101.2.7Training and Communication101.2.8Monitoring101.3Updating the Waste management plan101.4Review and Audit of Waste Plan102WASTEWATER121 SOLID WASTE1.1 Introduction The construction of camps and infrastructure will generate significant quantities of waste i.e. materials that have been used for their original purpose and are deemed no longer useful. This Waste Management Plan (WMP) has been produced for the development of the Tonkolili Iron Ore Project, comprising mine, transport corridor and Pepel port developments and will be expanded in line with project developments. This is to ensure that all construction waste is managed, stored and disposed of in an appropriate manner by appropriate contractors in accordance to all relevant legislation. This WMP is a live document and will be updated periodically as necessary. The purpose of the WMP is to enable the issue of waste production to be dealt within a structured and auditable manner from the commencement of the project during the design stage, through construction to its operation and monitoring and beyond. This ensures that the aim of waste minimisation is emphasised from the outset of the project, in addition to ensuring that the waste produced during the construction phase is dealt with in accordance with international best practice and principles outlined within the Waste Hierarchy (reduction, reuse, recovery and recycling). Surplus or waste materials arise from either the materials imported to site or those generated on site. Imported materials are those which are brought to the project for inclusion into the permanent works. Generated materials are those which exist on the project such as topsoil, sub-soil, stabilized fill, trees and materials from demolition works etc.African Minerals Limited (AML) assumes direct responsibility for waste that it generates at its sites, such as Tonkolili mine and Pepel port and exerts contractual control on the responsibility to ensure that appropriate waste management practices are implemented within all the project areas.1.2 Waste management 1.2.1 Proposals for MinimisationWaste will arise from the project from demolition and site clearance, refurbishment, excavation and any unavoidable construction waste and camp and office operation, where typical domestic waste will be generated. The proposed scheme will require specific construction materials to be imported to the site. Actions to be taken to facilitate resource efficiency throughout the project and therefore minimise the waste produced are detailed below: Excavated soils will be stored in segregated piles for subsequent reuse on the site. The soils will be reused as deposition material for infilling or landscaping. Any surplus soils or clay will be removed from site for direct beneficial use elsewhere; Concrete waste will be source segregated or reused directly in construction activities; Masonry and wood will be source segregated for subsequent separation and reused directly in construction activities; Packaging waste will be source segregated for storage and possible future recycling; Hazardous wastes including any contaminated soil materials will be identified, removed and kept separate from other Construction and Demolition (C&D) waste materials to avoid further contamination and will be disposed of in accordance with International Best Practice; and Other C&D waste materials will be collected in receptacles with mixed C&D waste materials, for subsequent separation and disposal at facilities to be designed, constructed and operated by AML, as there are no licensed facilities with any international standard in the country, let alone in proximity to the work sites.1.2.2 Waste segregation and management The best techniques for managing waste accrued by construction, demolition and refurbishment continue to be formulated and implemented to ensure appropriate segregation of materials for recycling and disposal. The basic principle being rolled out and adopted across the mine site, Pepel and all contractor sites is one of: Primary segregation by cleaners during cleaning of cabins and offices Primary segregation by the use of labelled and colour coded bins for various waste streams, supported by training Primary segregation in all canteens, separating food items, food scraps and cans and bottles etc Secondary segregation by a Waste Team at each site, with responsibility for segregation and management of all wastes on site Establishment of Waste Stations (especially at the mine site and Pepel) at each site, where waste is segregated and longer term storage takes place Construction of comprehensive Waste Facilities at the two main AML sites, to include waste reception facility; composting area for organic waste; hazardous waste long term storage; landfill site and supporting infrastructure such as leachate control Establishment of business operations that include recycling by re-selling plastic and glass bottles and aluminium cans, with a percentage of the income for the local business re-invested in community development, with a preference for environmental programmes such as clean village initiatives and tree planting and nursery development Waste oil at the mine site location and from contactors is currently given to the suppliers for recycling or to an oil recycling facility in Freetown. The two main recycling facilities were inspected by AML Environmental Department from a Duty of Care perspective and one was ruled out due to poor environmental performance. The other recycler is supplied with occasional waste oil from AML construction operations and investigations continue to review possible options for used oil. Segregation sites are being utilised at Pepel project site and will be implemented in all project sites of the Company. At the segregation locations, the separation of materials is/will be facilitated for possible recycling and reuse. Recycling and waste bins are kept clean and clearly marked to avoid contamination of materials. Skips or other storage for segregation of waste currently used are: Mixed Inert (e.g. concrete and rubble) Hazardous (e.g. asbestos, hydrocarbon contaminated items like hydraulic hoses) Mixed non-hazardous (biodegradable waste) Metal (e.g. copper and iron) Wood (e.g. fencing/hoarding) Plastic (e.g. containers) WEEE (Waste electrical/electronic equipment e.g. cables) Waste OilsThis area will be for short term storage and waste will be removed regularly, often daily, depending on the phasing of the project. All waste water is routed to cess pits, that either drain through a leach field or are pumped out when full and the material deposited in shallow pits in the bush, away from community use, valuable sites or water features and then covered to prevent disease transmission.At Pepel and the Tonkolili Mine site and most of the contractor camps (eventually all) proprietary package wastewater treatment units have been purchased through which all wastewater is treated via aerobic digestion (see below). Figure 11 Waste segregation binsFigure 12 Canteen primary segregationFigure 13 Waste segregationFigure 14 Temporary waste segregation at Pepel1.2.3 Disposal and Treatment OptionsIt is understood that there is currently no appropriate waste management facility in-country with most waste simply being discarded in unregulated dumping areas around cities or burnt in make shift pits. In line with its principles of Environmental good governance and social and community development, AML continues to investigate opportunities to benefit and develop communities that it interacts with. AML is in the process of establishing several Waste Businesses in nearby communities which will be given free of charge certain agreed waste items (initially plastic and glass bottles, aluminium cans and tins). These businesses will trade in these commodities, all of which have a re-sale value in the country, and will re-invest a percentage back into positive community development. To further reinforce the linkages between waste, the environment, community health and sustainability the focus of the re-investment will initially be on aspects like: Assistance with cleaning villages including training and garbage control Water and sanitation awareness to reduce water borne disease transmission Awareness and assistance towards establishment of wood lots for charcoal and firewood Tree nursery and other plant propagation assistanceQuantities of waste oil generated from vehicle and plant servicing have been given to community groups such as farmers in the area, along with diesel to help their farming effort. Oil has also been supplied to oil recycling businesses in Freetown.Some of the key waste management measures on-site are listed in Table 11 below.Table 11 Anticipated Principle Waste Stream Generated from Construction ActivitiesWASTE STREAMMANAGEMENTWaste OilManaged through take back scheme if available. Otherwise recycled to oil recyclers in Freetown temporarily and farmers in the local community; longer term initiatives being considered. PlasticsRe-usable plastics returned to local community. Unusable/contaminated plastics to landfill. Businesses being established by AML, with profit percentage re-invested in community development. ConcreteCrushed and re-used on siteMetalsRe-used on site or returned to local community where possibleBiodegradable WastesLocalised composting, local pig farm for food wasteHazardous Wastes (exc oil)Incinerated using Turbo-burner, residual ash landfilledWaste electricalRe-used / recovered were possible, residual landfilledThese recommendations should be considered a pragmatic approach driving towards sound waste management practice in the absence of in-country facilities, and should remain under constant review as more permanent infrastructure is procured and developed on-site.1.2.4 Duty of Care ComplianceLocal waste management operators and facilities to be used for both recycling, recovery and disposal will be identified at the outset of the project. Given the lack of developed infrastructure in-country, these should be subject to appropriate due diligence by AML or its agents, before the commencement of construction works. Local oil recycling companies in Freetown were visited and their HSE performance was evaluated. Out of the two companies inspected in detail, one had virtually no standards and contamination was evident, whereas the other was reasonable and therefore it was agreed that the oil will be supplied to them for re-cycling.1.2.5 Landfill Even following rigorous waste segregation a volume of mixed waste items remains, which can be characterised as segregated domestic waste, i.e. without any hazardous, special or medical bio hazard waste categories. Typical options worldwide for dealing with such waste are incineration or landfilling. Incineration requires a proprietary, site and waste-specific incinerator to be procured, installed and operated. It is essential that this equipment has proven performance, which includes designs that ensure very high temperatures are achieved in the chambers to thoroughly combust plastic materials, to inter alia avoid the generation and emission of dioxins and other poisonous gases and particulates. In the initial phases of the project, the most practical and cost effective manner to treat the residual domestic-type waste is by construction of landfill sites at key sites. At a later date and particular when finances allow from operational revenue, the waste plans will be reviewed and incinerators will be considered, along with their environmental comparison (landfill versus incineration) and operating factors. AML commissioned consultants to design landfill sites to meet Best Practice performance. International standard municipal landfill sites include mechanisms to treat the leachate that can be generated by the composting material, which includes plastic degradation products as well as organic waste and other items. As all AML waste will be segregated to leave only inert plastics and other non-hazardous waste and predominantly non-compostable waste one can expect leachate to be minimal and mainly generated due to high rainfall in the wet season. For this reason we have included leachate control and treatment in the designs, making use of the temperature in the country to achieve good biodegradation of leachate products. Following a review of the assumptions and designs that the consultants produced it was evident that they were far too conservative and assumed a much greater quantity of waste (20,000T over a 2 year period) as well as no segregation. This review allows for a significant modification of the design, as the quantities are vastly reduced and the quantity and strength of the leachate generated are considerably less. The initial design of the leachate treatment system is presented below, but has been modified; new designs can be included in the next version of the ESMP if they are required. Please see separate reports attached Landfill Engineering Specification and Basis of Design. It is important to note that the assumptions of the consultants have been over-estimated, as they assumed larger quantities of waste than will actually be generated and no segregation, which is not the case. AML undertakes careful primary and secondary segregation of all its waste streams and therefore removes food waste to pigs and biodegradable waste to compost facilities, therefore the leachate will be much weaker in organic loadings than has been assumed in the consultants designs. 151.2.6 Waste Disposal CategorizationUnder international best practice waste is classified as Inert, Non-Hazardous and Hazardous. Hazardous Waste cannot under any circumstances be re-used on site. Responsibility for the basic classification of waste rests with the producer and landfill operator (if applicable).1.2.7 Training and CommunicationIn accordance with our intentions to develop a culture of promoting best practice and increasing knowledge and awareness, education on the issues surrounding our waste management plan as well as the procedures to be followed will eventually be given to all operatives in their site induction and Tool Box talks. Tool Box talks should be carried out every month on waste issues and all subcontractors will be involved.1.2.8 MonitoringAML self monitors waste management across its construction operations, including those of its contractors, through both the Environmental Department and HSE Department and incident reports and corrective actions are raised as and when required. Additional 3rd party monitoring was conducted throughout the project sites by an Independent company contracted by AML. AML is designing auditing schedules to allow compliance evaluations to be undertaken. Waste records will be maintained for the 2 main AML sites currently working and the data will be entered in the Information system.1.3 Updating the Waste management planThis plan will be updated as often as necessary, at least annually. Updates to the plan will give a current picture of how work is progressing against the waste estimates contained in the plan. Therefore, for waste that is re-used or recycled on site, the WMP will be updated to describe how much of the estimated volume or tonnage has been processed. 1.4 Review and Audit of Waste Plan This section of the WMP is a post construction review and is designed to ensure the WMP is monitored throughout the lifetime of the project and then signed off at its closure. The aim is to: Highlight the benefits of completing the WMP; and Identify the amounts of waste reduction and resource efficiency achieved.This is achieved by adhering to the principles outlined at the beginning of the WMP, in addition to realising the cost benefits associated with the WMP if it has been carried out correctly.At the end of the project AML will be responsible for reviewing, revising and refining the WMP as necessary within three months of completion to identify if lessons could be learned for the next time a similar project is undertaken. This review should identify and conclude the following: An explanation of any deviation from the original plan; A comparison of the estimated quantities of each waste type against the actual quantities generated; An action plan to address the lessons that have been learnt from the project that could be implemented for the next project; and An estimation of the cost savings (if any) that have been achieved through the measures undertaken to minimise, reuse, recycle or recover waste arising rather than just sending it to landfill.2 WASTEWATER Waste waters from AML construction and operation activities (principally camps) will be treated to avoid polluting surface or groundwater. The treatment typically involves import and operation of packaged waste water treatment works (WWTW). These units provide a combination of aerobic and anaerobic digestion of organic matter and are designed to produce an effluent quality that is compliant
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