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of ( Government approved ) final disposal sites will be documented , and the documentation kept for a minimum of ten years .
Structure and Responsibility
● All personnel working at the plant must be aware of their environmental responsibilities under the relevant national and international legislation , and all EPC contractors and operational staff members and contractors will undergo the Induction / Orientation Programme , which will include a section on Environmental Awareness .
● Each Supervisor is responsible for the management of environmental issues in their respective sections .
● The EPC contractor ( during the construction phase ) and the Plant Management ( during the operation phase ) will be responsible overseeing the waste management system and finding efficient ways to minimise the waste produced .
● The EPC contractor ( during the construction phase ) and the Plant Management ( during the operation phase ) will be responsible for the co-ordination of the Environmental Management System .
● The EPC contractor ( during the construction phase ) and the Plant Management ( during the operation phase ) will have the overall responsibility for environmental performance at the site and will be required to assign dedicated resources to coordinate all aspects of the Environmental Management System .
Document Control
Documentation and records system is central to the implementation of the EMS . The KNO has developed and operated a very effective and sophisticated documentation system which will be replicated by the Project following relocation of the process plant . The documentation system will include :
● Plant Operations manuals ( KNO Plants 4 , 5 and 6 operations manuals reflect conditions at the relocated plant ).
● Compliance and monitoring records and reporting based on KNO format .
● Incident reporting based on KNO format updated to Training Materials . ( The Plants 4 , 5 and 6 training manuals updated to reflect conditions at the relocated Plant )
● Training records .
● Project records – building on Plants 4 , 5 and 6 project records .
● Materials Management Systems .
This document describes the different types of records systems for environmental management at the site .
Emergency Procedures
Specific emergency procedures will be developed by the EPC Contractor ( for the construction phase ) and the Project Company ( for the operation phase ) prior to the commencement of these phases . These procedures govern any emergency incidents at the Project site such as spills , fires , gas leaks etc . Emergency Response procedures should cover all anticipated emergency incidents .
Reporting
Full and detailed logs of the following incidents will be recorded :
● Environmental limits breaches .
● All major incidents .
In addition , all regulatory reporting and a full comprehensive annual EHS report will be included in the financial statements of the Project Company .
Auditing and Management Review
Auditing is an important component of the Environmental Management Systems consistent with ISO 14001 . The audit of the EMS will be undertaken annually and will cover :
Verification of ongoing conformance with all applicable laws and regulations , confirmation of the continued efficacy of management systems to ensure compliance with the applicable environmental standards , and identification of actual and or standard potential environmental risks .
58 VOL 90 APRIL-JUNE 2022