Mako Gold Project - Resolute Mining€¦ · 3.7.1 Assessment of Risk and Priority ... 151 18...
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[Type text] Environmental and Social Management and Monitoring Plan Prepared by Earth Systems SARL for Mako Exploration Company SA FINAL December 2015 MAKO GOLD PROJECT
Transcript of Mako Gold Project - Resolute Mining€¦ · 3.7.1 Assessment of Risk and Priority ... 151 18...
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Environmental and Social Management and Monitoring Plan Prepared by Earth Systems SARL for Mako Exploration Company SA
FINAL
December 2015
Chapter 9 | Biological Impacts and Management Measures
MAKO GOLD PROJECT
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL
EARTH SYSTEMS
Environment | Water | Sustainability
Australian Business Number 42 120 062 544
RECORD DISTRIBUTION
Copy No. Company / Position Name
1 Toro Gold / Mako Exploration Company Paul Cannon
DOCUMENT REVISION LIST
Revision Status/Number Revision Date Description of Revision Approved By
Rev0 April 2015 Draft Nigel Murphy
Rev1 August 2015 Draft Nigel Murphy
Rev2 August 2015 Draft Nigel Murphy
Rev3 August 2015 Draft Nigel Murphy
Rev4 November 2015 Revised Nigel Murphy
Rev5 December 2015 Final Nigel Murphy
This report is not to be used for purposes other than that for which it was intended. Environmental conditions change with time.
The site conditions described in this report are based on observations made during the site visit and on subsequent monitoring
results. Earth Systems does not imply that the site conditions described in this report are representative of past or future
conditions. Where this report is to be made available, either in part or in its entirety, to a third party, Earth Systems reserves the
right to review the information and documentation contained in the report and revisit and update findings, conclusions and
recommendations.
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CONTENTS
TERMS AND DEFINITIONS ...........................................................................................
LIST OF ABBREVIATIONS .............................................................................................
1 INTRODUCTION .................................................................................................. 1
1.1 General Background ........................................................................................................................... 1
1.2 Structure ............................................................................................................................................ 1
1.2.1 Overview of Management Plans and Procedures ................................................................... 2
1.3 Presentation of the Project................................................................................................................ 4
1.3.1 Project Proponent ................................................................................................................. 4
1.3.2 Project Overview ................................................................................................................... 4
1.4 Report Author .................................................................................................................................. 10
2 LEGISLATIVE REQUIREMENTS, GUIDELINES AND COMMITMENTS ..................... 12
2.1 Toro Gold Environmental and Social Commitments .......................................................................... 12
2.1.1 Environmental and Social Performance Framework ............................................................. 14
2.1.2 Environmental and Social Design Criteria ............................................................................. 14
2.2 Legislative Requirement and Guidelines ........................................................................................... 14
2.2.1 Mining Convention Agreement ............................................................................................. 14
2.2.2 Relevant Legislation and Guidelines ..................................................................................... 15
2.3 International Standards ................................................................................................................... 20
2.3.1 IFC Performance Standards .................................................................................................. 21
2.3.2 World Bank General Environmental Health and Safety Guidelines ........................................ 21
2.3.3 International Cyanide Management Code ............................................................................. 22
2.3.4 UN Guiding Principles on Business and Human Rights .......................................................... 22
2.3.5 International Union on the Conservation of Nature Guidelines .............................................. 22
2.3.6 Extractive Industries Transparency Initiative ......................................................................... 23
2.4 Project Discharge Standards ............................................................................................................ 23
2.5 International Conventions, Treaties and Agreements ....................................................................... 40
3 ESMMP FRAMEWORK ........................................................................................43
3.1 Purpose of the ESMMP .................................................................................................................... 43
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3.2 Responsibilities and Human Resources ............................................................................................ 44
3.2.1 Responsibilities - Internal Parties ......................................................................................... 44
3.2.2 Responsibilities - External Parties ........................................................................................ 45
3.3 Capacity Building ............................................................................................................................ 46
3.3.1 Project Capacity Building ..................................................................................................... 46
3.3.2 External Capacity Building ................................................................................................... 48
3.4 Monitoring Systems ........................................................................................................................ 48
3.5 Reporting Systems .......................................................................................................................... 49
3.5.1 Data Management .............................................................................................................. 49
3.5.2 Project Reporting Commitments .......................................................................................... 50
3.5.3 Incident and Project Grievances Reporting .......................................................................... 52
3.6 Auditing and Facility Inspections ..................................................................................................... 52
3.7 Emergency Preparedness and Response .......................................................................................... 53
3.7.1 Assessment of Risk and Priority ............................................................................................ 53
3.7.2 Emergency Preparedness and Response Planning ............................................................... 54
3.7.3 Spill management ............................................................................................................... 54
3.8 Continuous Improvement ................................................................................................................. 55
4 PROJECT DEVELOPMENT AREA ........................................................................ 56
4.1 Objectives ....................................................................................................................................... 56
4.2 Context ........................................................................................................................................... 56
4.2.1 Pre-construction and Construction Phase ............................................................................ 56
4.2.2 Operations Phase ................................................................................................................ 56
4.2.3 Decommissioning and Closure Phase ................................................................................... 57
4.3 Management and Mitigation Measures ............................................................................................ 57
4.3.1 Pre-construction and Construction Phase ............................................................................. 57
4.3.2 Operations Phase ................................................................................................................ 58
4.3.3 Decommissioning and Closure Phase .................................................................................. 58
4.4 Monitoring Measures ...................................................................................................................... 59
5 OPEN PIT, MINING AND WASTE ROCK ............................................................... 60
5.1 Objectives ....................................................................................................................................... 60
5.2 Context ........................................................................................................................................... 60
5.2.1 Pre-construction and Construction Phase ............................................................................ 60
5.2.2 Operations Phase ................................................................................................................. 61
5.2.3 Decommissioning and Closure Phase .................................................................................. 62
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5.3 Management and Mitigation Measures ........................................................................................... 62
5.3.1 Pre-construction and Construction Phase ............................................................................ 62
5.3.2 Operations Phase ................................................................................................................. 63
5.3.3 Decommissioning and Closure Phase .................................................................................. 66
5.4 Monitoring Measures ....................................................................................................................... 67
6 MINERAL PROCESSING AND TAILINGS MANAGEMENT ....................................... 70
6.1 Objectives ........................................................................................................................................ 70
6.2 Context ............................................................................................................................................ 70
6.2.1 Pre-construction and Construction Phase ............................................................................. 70
6.2.2 Operations Phase ................................................................................................................. 71
6.2.3 Decommissioning and Closure Phase ................................................................................... 72
6.3 Management and Mitigation Measures ............................................................................................ 72
6.3.1 Pre-construction and Construction Phase ............................................................................. 72
6.3.2 Operations phase ................................................................................................................. 73
6.3.3 Decommissioning and closure phase .................................................................................... 78
6.4 Monitoring Measures ...................................................................................................................... 80
7 WATER SUPPLY................................................................................................. 84
7.1 Objectives ....................................................................................................................................... 84
7.2 Context ........................................................................................................................................... 84
7.2.1 Pre-construction and Construction Phase ............................................................................ 84
7.2.2 Operations Phase ................................................................................................................ 84
7.2.3 Decommissioning and Closure Phase .................................................................................. 85
7.3 Management and Mitigation Measures ........................................................................................... 85
7.3.1 Pre-construction and Construction Phase ............................................................................ 85
7.3.2 Operations Phase ................................................................................................................ 86
7.3.3 Decommissioning and Closure Phase .................................................................................. 86
7.4 Monitoring Measures ....................................................................................................................... 87
8 POWER SUPPLY ................................................................................................ 89
8.1 Objectives ....................................................................................................................................... 89
8.2 Context ........................................................................................................................................... 89
8.2.1 Pre-construction and Construction Phase ............................................................................ 89
8.2.2 Operations Phase ................................................................................................................ 89
8.2.3 Decommissioning and Closure Phase .................................................................................. 89
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8.3 Management and Mitigation Measures ........................................................................................... 90
8.3.1 Pre-construction and Construction Phase ............................................................................ 90
8.3.2 Operations Phase ................................................................................................................ 90
8.3.3 Decommissioning and Closure Phase .................................................................................. 92
8.4 Monitoring Measures ...................................................................................................................... 92
9 ROADS AND TRANSPORT ................................................................................. 94
9.1 Objectives ....................................................................................................................................... 94
9.2 Context ........................................................................................................................................... 94
9.2.2 Pre-construction and Construction Phase ............................................................................ 96
9.2.3 Operations Phase ................................................................................................................ 96
9.2.4 Decommissioning and Closure Phase .................................................................................. 96
9.3 Management and Mitigation Measures ........................................................................................... 96
9.3.1 Pre-construction and Construction Phase ............................................................................. 97
9.3.2 Operations Phase ............................................................................................................... 102
9.3.3 Decommissioning and Closure Phase ................................................................................. 104
9.4 Monitoring Measures ..................................................................................................................... 104
10 ACCOMMODATION FACILITIES ......................................................................... 109
10.1 Objectives ...................................................................................................................................... 109
10.2 Context .......................................................................................................................................... 109
10.2.1 Pre-construction and Construction Phase ........................................................................... 110
10.2.2 Operations Phase ............................................................................................................... 110
10.2.3 Decommissioning and Closure Phase ................................................................................. 110
10.3 Management and Mitigation Measures .......................................................................................... 111
10.3.1 Pre-construction and Construction Phase ........................................................................... 111
10.3.2 Operations Phase ............................................................................................................... 111
10.3.3 Decommissioning and Closure phase.................................................................................. 113
10.4 Monitoring Measures ..................................................................................................................... 113
11 BORROW AREAS AND QUARRIES ..................................................................... 116
11.1 Objectives ...................................................................................................................................... 116
11.2 Context .......................................................................................................................................... 116
11.2.1 Pre-construction and Construction Phase ........................................................................... 116
11.2.2 Operations Phase ............................................................................................................... 117
11.2.3 Decommissioning and Closure Phase ................................................................................. 117
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11.3 Management and Mitigation Measures .......................................................................................... 117
11.3.1 Pre-construction and Construction Phase ........................................................................... 117
11.3.2 Operations Phase ............................................................................................................... 118
11.3.3 Decommissioning and Closure Phase ................................................................................. 118
11.4 Monitoring Measures ..................................................................................................................... 118
12 LAND MANAGEMENT AND LIVELIHOOD RESTORATION ................................... 120
12.1 Context .......................................................................................................................................... 120
12.2 Management and Mitigation Measures .......................................................................................... 120
12.2.1 Land clearance ................................................................................................................... 120
12.2.2 Land acquisition and livelihood restoration ........................................................................ 121
12.2.3 Decommissioning and Closure Phase ................................................................................. 124
12.2.4 Livelihood Improvement Programmes ............................................................................... 125
12.2.5 Vulnerable Groups .............................................................................................................. 125
12.2.6 Gender ............................................................................................................................... 125
12.3 Monitoring Measures ..................................................................................................................... 126
13 COMMUNITY ENGAGEMENT ............................................................................ 128
13.1 Objectives ...................................................................................................................................... 128
13.2 Context .......................................................................................................................................... 128
13.3 Management and Mitigation Measures .......................................................................................... 128
13.3.1 Ongoing Public Disclosure and Consultation ....................................................................... 128
13.3.2 Community Awareness and Education Programme ............................................................ 129
13.3.3 Grievance Management ..................................................................................................... 130
13.4 Monitoring Measures ..................................................................................................................... 131
14 COMMUNITY SAFETY AND HEALTH.................................................................. 132
14.1 Objectives ...................................................................................................................................... 132
14.2 Context .......................................................................................................................................... 132
14.2.1 Disease transmission and HIV/AIDS .................................................................................... 132
14.2.2 Water and Sanitation .......................................................................................................... 132
14.2.3 General Community Health and Safety ............................................................................... 133
14.3 Management and Mitigation Measures .......................................................................................... 133
14.3.1 Pre-construction and Construction Phase ........................................................................... 133
14.3.2 Operations Phase ............................................................................................................... 135
14.3.3 Decommissioning and Closure Phase ................................................................................. 135
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14.4 Monitoring Measures ..................................................................................................................... 135
15 IN-MIGRATION................................................................................................. 137
15.1 Objectives ...................................................................................................................................... 137
15.2 Context .......................................................................................................................................... 137
15.2.1 Pre-construction and Construction Phase ........................................................................... 137
15.2.2 Operations Phase ............................................................................................................... 138
15.2.3 Decommissioning and Closure Phase ................................................................................. 138
15.3 Management and Mitigation Measures .......................................................................................... 138
15.3.1 Pre-construction and Construction Phase ........................................................................... 139
15.3.2 Operations Phase ............................................................................................................... 140
15.3.3 Decommissioning and Closure Phase ................................................................................. 140
15.4 Monitoring Measures ..................................................................................................................... 140
16 BIODIVERSITY MANAGEMENT ......................................................................... 142
16.1 Objectives ...................................................................................................................................... 142
16.2 Context .......................................................................................................................................... 142
16.2.1 Pre-construction and Construction Phase ........................................................................... 142
16.2.2 Operations Phase ............................................................................................................... 143
16.2.3 Decommissioning and Closure Phase ................................................................................. 143
16.3 Management and Mitigation Measures .......................................................................................... 143
16.3.1 Pre-construction and Construction Phase ........................................................................... 144
16.3.2 Operations Phase ............................................................................................................... 146
16.3.3 Decommissioning and Closure Phase ................................................................................. 146
16.4 Monitoring Measures ..................................................................................................................... 146
17 ESTIMATED COSTS .......................................................................................... 151
18 REGISTERS OF ENVIRONMENTAL AND SOCIAL MANAGEMENT AND
MONITORING MEASURES ................................................................................ 159
18.1 Summary of Environmental Management and Monitoring Measures ............................................. 159
18.2 Summary of Physical Management and Monitoring Measures ....................................................... 167
18.3 Summary of Biological Environment Management and Monitoring Measures ................................ 207
18.4 Summary of Social Management and Monitoring Measures ........................................................... 219
19 REFERENCES ................................................................................................... 229
APPENDIX A ........................................................................................................... 231
Standard Operating Procedures (SOPs) .................................................................... 231
SOP01: Erosion and Sediment Control .................................................................................................... 235
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SOP02: Water Quality and Pollution Management .................................................................................. 237
SOP03: Hydrology and Water Management ........................................................................................... 242
SOP04: Emission and Dust Control ........................................................................................................ 244
SOP05: Noise and Vibration Management ............................................................................................. 248
SOP06: Waste Management ................................................................................................................... 252
SOP07: Hazardous Materials Management ............................................................................................. 257
SOP08: Blasting Management ............................................................................................................... 266
SOP09: Land Clearance and Soil Stockpiling .......................................................................................... 269
SOP10: Cultural Heritage Management .................................................................................................. 275
SOP11: Lighting and Visual Amenity Management.................................................................................. 277
APPENDIX B ........................................................................................................... 279
Chance Find Procedure ............................................................................................ 279
APPENDIX C ........................................................................................................... 280
Monitoring Maps ..................................................................................................... 280
Appendices APPENDIX A Standard Operating Procedures
APPENDIX B Chance Find Procedure
APPENDIX C Monitoring Maps
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TERMS AND DEFINITIONS
Term Definition
Acid and Metalliferous
Drainage (AMD)
Refers to the outflow of acidic water from metal mines or coal mines.
Baseline Refers to the biophysical and socio-economic state of the environment at a given time, prior to
development of a particular project.
Batter Receding slope – backward and upward slope on a face of a bank
Berm Dirt and rock piled alongside a haulage road or along the edge of a dump point. A safety measure
Biodiversity Diversity within and among flora and fauna in an environment.
Bio-indicators Bio-indicators are molecular tools used in ecology, physiology, environmental microbiology and other
disciplines, to detect stressors and other environmental conditions surrounding an organisms or cells.
Blast hole Holes into which explosive is added in order to fragment the rock
Blasting Blasting is a primary means of extracting minerals and ores at surface mining operations.
Borrow area A pit created to provide material (borrow) that can be used as fill at another site.
CALPUFF Advanced non-steady-state meteorological and air quality modelling system developed by Exponent
scientists.
Catchment An area in which rainwater is collected; a natural drainage area.
Chemical oxygen
demand
The amount of organic compounds in water.
Compensation The payment – in cash or kind – for an asset (e.g. land, house, trees) or livelihood income (cash or
kind) affected by the Project
Concentrate A metal-rich product resulting from a mineral enrichment process such as gravity concentration or
flotation
Consultation A process of communication with those potentially affected by a project, policy, plan or programme.
Contamination Pollution, including the presence of particles, chemicals and/or other undesirable substances.
Cultural heritage The legacy of physical artefacts and intangible attributes of a group or society that are inherited from
past generations, maintained in the present and bestowed for the benefit of future generations.
Culvert A drain or channel crossing under a road, sidewalk, etc.; sewer; conduit
Cumulative impact The effects of an action are added to or interact with other effects in a particular place and within a
particular time. It is a combination of these effects and the resulting environmental degradation that
should be the focus of the cumulative effects analysis.
Decibel (dB) describes the sound pressure level of a noise source. It is a logarithmic scale referenced to the
threshold of hearing
Decommissioning The shut down or closure of the mine
Dissolved Oxygen Refers to a relative measure of the amount of oxygen that is dissolved or carried in a given medium.
Electrical Conductivity Refers to a measure of a material's ability to conduct (transport) an electric current.
Endangered species An animal or plant in danger of extinction.
Environment The combination of elements whose complex interrelationships make up the settings, surroundings
and conditions of life of the individual and society as they are or are felt.
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Term Definition
Ephemeral Temporary/short lived.
Erosion Weathering of surface soil through the action of water and wind, or displaced in response to gravity.
Fauna The animals of a particular region, habitat, or geologic period.
Flora The plants of a particular region, habitat or geologic period.
Flyrock Fragments of rock projected outside the declared danger zone by a quarry blast.
Grievance Mechanism A way for socially responsible businesses to meet requirements of corporate responsibility-related
agreements or pacts, reduce risk while capacity-building or developing internationally, and assist larger
processes that create positive social change.
Groundwater Water that exists in the pore spaces and fractures in rock and sediment beneath the Earth’s surface.
Habitat The natural home or environment of an animal, plant, or other organism.
Hydrocarbon An organic compound consisting entirely of hydrogen and carbon.
Hydrology The science dealing with the occurrence, circulation, distribution, and properties of the waters of the
earth and atmosphere.
ICP-MS Inductively coupled plasma mass spectrometry is a type of mass spectrometry which is capable of
detecting metals and several non-metals at concentrations as low as one part in 1015.
Impact The consequence of an action or activity on the human or natural environment. Impacts may be
positive, negative or neutral.
IUCN Red List The IUCN Red List of Threatened Species (also known as the IUCN Red List or Red Data List) is the
world's most comprehensive inventory of the global conservation status of biological species.
LA90 A LA90 level is an A-weighted noise level which is exceeded for 90 percent of the measurement
period. An LA90 level is considered to represent the “background” noise level.
LAeq The equivalent steady-state A-weighted sound level (“equal energy”) which, in a specified time period,
contains the same acoustic energy as the time-varying level during the same period. It is considered to
represent the “average” noise level.
LAmax A LAmax level is the maximum A-weighted noise level during the measurement period.
Leachate The solution resulting from the dissolution of soluble substances from the downward percolation of
water.
Livelihood The full range of means that individuals, families, and communities utilise to make a living, such as
wage-based income, agriculture, fishing, foraging, other natural resource-based livelihoods, petty
trade, and bartering.
Nutrients Nutrients are the components in foods that an organism utilizes to survive and grow.
Open pit, open cut Surface mining in which the ore is extracted from a pit or quarry. The geometry of the pit may vary with
the characteristic of the ore body.
Ore Mineral bearing rock that contains one or more minerals, at least one of which can be mined and
treated profitably under current or immediately foreseeable economic conditions.
pH A measure of concentration of hydrogen ions (grams of atom/L) used to represent the alkalinity or
acidity of a solution. Measured on a logarithmic scale.
Piezometer A piezometer is either a device used to measure static liquid pressure in a system by measuring the
height to which a column of the liquid rises against gravity, or a device which measures the pressure
(more precisely, the piezometric head) of groundwater at a specific point.
PM10 Particulate matter less than 10 microns in diameter.
PM2.5 Particulate matter less than 2.5 microns in diameter.
Process water Means any water which, during manufacturing or processing, comes into direct contact with or results
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Term Definition
from the production or use of any raw material, intermediate product, finished product, byproduct, or
waste product.
Project Development
Area (PDA)
Includes physical footprint of main Project components (Mine Pit, Waste Rock Dump, Tailing
Management Facility etc.) and a buffer area. Excludes Water Storage Dam (WSD) and Project Access
Corridor.
Project Footprint Areas potentially directly affected by the Project including buffer zones.
Proponent The proposer, or applicant, of a project.
Protected area Clearly defined geographical space, recognised, dedicated and managed, through legal or other
effective means, to achieve the long term conservation of nature with associated ecosystem services
and cultural values. (IUCN Definition, 2008).
Quarry A type of shallow open-pit mine from which rock is extracted, usually for building purposes.
Rehabilitation The process by which lands disturbed as a result of mining activity are rehabilitated back to a
beneficial land use. Rehabilitation activity includes the removal of buildings, equipment, machinery
and other physical remnants of mining, closure of tailings impoundments, leach pads and other mine
features, and contouring, covering and revegetation of waste rock piles and other disturbed areas.
Riparian The terrestrial region around a body of water or along a river bank.
Risk The likelihood of occurrence of an adverse project effect.
Runoff Precipitation falling on the ground that is not absorbed and eventually reaches rivers, lakes or other
water bodies.
Run-of-mine Pad Run-of-mine is coal that is not graded according to quality or size
Sediment Solid material that has settled down from a state of suspension in a liquid. More generally, solid
fragmental material transported and deposited by wind, water or ice, chemically participated from
solution, or secreted by organisms, and that forms in layer in loose unconsolidated form.
Spoil Waste material brought up during the course of an excavation.
Stakeholder Someone who has an interest in the outcome of a project, or a decision affecting them.
Total Dissolved Solids Total Dissolved Solids (often abbreviated TDS) is a measure of the combined content of all inorganic
and organic substances contained in a liquid in: molecular, ionized or micro-granular (colloidal sol)
suspended form.
Total Suspended Solids A measure of the organic and inorganic solids dispersed in a water body.
Tributary The name given to a stream that flows into a larger stream of body of water.
Turbidity Turbidity is the cloudiness or haziness of a fluid caused by individual particles (suspended solids) that
are generally invisible to the naked eye, similar to smoke in air. The measurement of turbidity is a key
test of water quality.
UNESCO’s List of
World Heritage in
Danger
UNESCO’s List of World Heritage in Danger is designed to inform the international community of
conditions which threaten the very characteristics for which a property was inscribed on the World
Heritage List, and to encourage corrective action.
Vulnerable groups Groups that experience a higher risk of poverty and social exclusion than the general population
Waste rock Rock containing no target element, or an un-economic quantity of the target element
Waste Water Treatment
Plant
A treatment plant where various physical, biological or chemical processes are used to change the
properties of the wastewater (e.g. by removing harmful substances) in order to turn it into a type of
water (also called effluent) that can be safely discharged into the environment or for reuse.
Water quality The chemical, physical or biological characteristics of water relative to the requirements of biotic
species and/or to any human need or purpose.
Woodland Is a low-density forest forming open habitats with plenty of sunlight and limited shade. Woodlands may
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Term Definition
support an understory of shrubs and herbaceous plants including grasses.
Zoonotic Transmissible disease that can pass between animals and humans.
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LIST OF ABBREVIATIONS
Acronym Full Term
AMD Acid and Metalliferous Drainage
ANC Acid Neutralising Capacity
ANFO Ammonium Nitrate Fuel Oil
ARD Acid Rock Drainage
BAP Biodiversity Action Plan
BOD Biological Oxygen Demand
CEMP Construction Environmental Management Plan
CIL Carbon In Leach
CO Carbon monoxide
COD Chemical Oxygen Demand
DEEC Direction de l’Environnement et des Etablissements Classés
DMG Direction des Mines et de la Géologie
DO Dissolved oxygen
DPN Department of National Parks (Direction des Parcs Nationaux)
DREEC Division Régionale de l’Environnement et des Etablissements Classés
EITI Extractive Industries Transparency Initiative
ESIA Environmental and Social Impact Assessment
GRS Government of the Republic of Senegal
HDPE High-density polyethylene
HIV / AIDS Human Immunodeficiency Virus Infection and Acquired Immune Deficiency Syndrome
IFC International Finance Corporation
IFC PS International Financial Corporation Performance Standard
km kilometres
L litres
LEPP Local Economic Participation Plan
M metres
MEC Mako Exploration Company
Mt/y Million tonnes per year
NGO Non-governmental Organisation
NMD Neutral and Metalliferous Drainage
NO2 Nitrogen dioxide
NOx Nitrogen oxides
OHS&E Occupational Health, Safety and Environment
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Acronym Full Term
ORP Oxidation Reduction Potential
PDA Project Development Area
PM Particulate Matter
PNNK Parc National du Niokolo Koba (Niokolo-Koba National Park)
POI Plan d’Opération Interne (Emergency response plan)
PPI Plan Particulier D’Intervention (Local Authority Emergency Plan)
ppm Parts per million
ROM Run-of-mine
SO2 Sulfur dioxide
SOP01 SOP01: Erosion and Sediment Control Procedure
SOP02 SOP02: Water Quality and Pollution Management Procedure
SOP03 SOP03: Hydrology and Water Management Procedure
SOP04 SOP04: Emission and Dust Control Procedure
SOP05 SOP05: Noise and Vibration Management Procedure
SOP06 SOP06: Waste Management Procedure
SOP07 SOP07: Hazardous Materials Management Procedure
SOP08 SOP08: Blasting Management Procedure
SOP09 SOP09: Land Clearance and Soil Stockpiling Procedure
SOP10 SOP10: Cultural Heritage Management Procedure
SOP11 SOP11: Lighting and Visual Amenity Management Procedure
TDS Total Dissolved Solids
TMF Tailings Management Facility
TSS Total Suspended Solids
VOCs Volatile Organic Compounds
WAD Weak Acid Dissociable
WHO World Health Organisation
WRD Waste Rock Dump
WSD Water Storage Dam
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1 INTRODUCTION
1.1 General Background
This Environmental and Social Management and Monitoring Plan (ESMMP) for the Mako Gold Project (hereafter 'the
Project’) has been prepared by Earth Systems for Mako Exploration Company SA (MEC), a wholly owned subsidiary
of Toro Gold Limited (Toro Gold). It forms part of the Environmental and Social Impact Assessment (ESIA)
documents for the Project.
The ESMMP details the environmental and social commitments, management and monitoring requirements that
must be carried out by MEC (hereafter ‘the Company’) and its contractors throughout the life of the Project, in order
to achieve the following objectives:
1. The Company will strive to prevent or mitigate potentially adverse environmental or social impact that may
result from Project implementation;
2. The Company will maximise beneficial impacts and minimise unavoidable residual impacts to an acceptable
level for the receiving environment and communities;
3. The Company will meet environmental and social commitments and measures outlined in the ESIA Report
(Volume A) as well as relevant corporate policies and environmental management systems; and
4. The Company will comply with national legislation as well as relevant international environmental and social
standards and regulations.
The ESMMP incorporates the key findings and environmental and social management, mitigation, and monitoring
measures and strategies of the ESIA report (Volume A) based on currently available Project information for pre-
construction, construction, operations, decommissioning, and closure.
The ESMMP will be a dynamic document, reviewed and updated by the Company on a yearly basis during the pre-
construction and construction phase and every 3 years during Project operations to reflect changes to Project
activities, commitments, environmental and social conditions, regulatory requirements, and potential optimisation
of best management practices.
In line with the Government of the Republic of Senegal (GRS) requirements, this ESMMP is prepared in accordance
with Arrêté n° 9472 du 28 Novembre 2001 portant Contenu du Rapport d'étude d'impact and the approved Terms of the
Reference for the ESIA for the Project, and requires approval by the Direction of Environment and Classified
Establishments (Direction de l’Environnement et des Etablissements Classés) (DEEC) prior to Project construction.
1.2 Structure
The scope of this ESMMP includes:
Summary of legislative requirements as well as the Company’s policies and commitments with respect to
environmental and social management of the Project;
Overview of the ESMMP framework, including details on:
» The regulatory and institutional frameworks as well as the company organisational responsibilities for
effective implementation of environmental and social management and monitoring measures;
» Capacity building requirements for Project employees, government and external organisations involved in
the implementation of the ESMMP;
» Monitoring, reporting and auditing systems to assess the effectiveness of implementation;
» Approach to emergency response and continuous improvement; and
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» Budget for implementing the environmental and social management measures and monitoring
programme inclusive of capacity building requirements.
Environmental and social management and monitoring sub-plans for Project components, which provide:
» A summary of the environmental and social context of the Project and its potential impacts;
» A summary of proposed measures to avoid or mitigate adverse impacts as well as optimising positive
effects of the Project;
» Monitoring locations, monitoring protocols, and trigger values (Project guidelines) requiring corrective
actions; and
» Registers summarising the proposed environmental and social management and monitoring measures for
the Project.
Supporting Standard Operating Procedures (SOPs) providing general environmental and social management
measures to manage potential Project impacts.
1.2.1 Overview of Management Plans and Procedures
Legal obligations, commitments, and environmental and social risks and potential impacts from the Mako Gold
Project will be primarily managed through specific plans and procedures developed under a Project environmental
and social management framework for particular aspects and activities during all Project phases.
These management plans and procedures will be updated as further information becomes available or when site or
Project conditions change significantly. Furthermore, they will be regularly reviewed and updated during all relevant
phases of the Project based on the results of monitoring, feedback and audits.
Chapters 4 to 11 of this ESMMP detail specific impact management and monitoring measures for implementation as
part of the environmental and social management framework for the following Project components:
Project Development Area (PDA) (Chapter 4);
Open Pit, Mining and Waste Rock (Chapter 5);
Mineral Processing and Tailings Management (Chapter 6);
Water Supply (Chapter 7);
Power Supply (Chapter 8);
Roads and Transport (Chapter 9);
Accommodation Facilities (Chapter 10); and
Borrow Areas and Quarries (Chapter 11).
Chapters 12 to 15 provide social impact management and monitoring measures for the Project:
Land Management and Livelihood Restoration (Chapter 12);
Community Engagement (Chapter 13);
Community Health and Safety (Chapter 14); and
In-Migration (Chapter 15).
Chapter 16 (Biodiversity Management) outlines the management and monitoring of biodiversity aspects in relation
to the Biodiversity Action Plan (Volume C) and Offset Strategy developed for the Project.
This ESMMP will be used in coordination with the following thematic management plans, provided with the ESIA:
Biodiversity Action Plan (Volume C);
Local Economic Participation Plan (Volume D);
Livelihood Restoration Plan (Volume D);
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Stakeholder Engagement Plan (Volume C); and
Rehabilitation and Conceptual Mine Closure Plan (Volume E).
Standard Operating Procedures
A number of Standard Operating Procedures (SOPs) have been provided in Appendix A to facilitate the
implementation of general environmental and social management measures by the Company and its contractors for
the Mako Gold Project. These include:
SOP01: Erosion and Sediment Control;
SOP02: Water Quality and Pollution Management;
SOP03: Hydrology and Water Management;
SOP04: Emission and Dust Control;
SOP05: Noise and Vibration Management;
SOP06: Waste Management;
SOP07: Hazardous Materials Management;
SOP08: Blasting Management;
SOP09: Land Clearance and Soil Stockpiling;
SOP10: Cultural Heritage Management; and
SOP11: Lighting and Visual Amenity Management.
Construction Environmental Management Plan
A Construction Environmental Management Plan (CEMP) will be developed and implemented after final
engineering plans are completed. Where required, these specific management plans have been identified in the
ESMMP (e.g. Blast Management Plan, etc.) and will be prepared by the Company or its Contractors to include the
following details as a minimum:
Overall objectives and targets;
Assigned responsibilities and resources for implementation;
Key risks and sensitivities;
Specific competencies and training required, where relevant;
Proposed avoidance, management and mitigation measures; and
Monitoring, reporting and audit/review for improvement.
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1.3 Presentation of the Project
1.3.1 Project Proponent
Toro Gold entered into a Joint Venture with Kansala Resources in September 2009 and acquired 100% of the
Exploration Permit for the Mako Gold Project in 2011. MEC (a fully owned subsidiary of Toro Gold) is the proponent
of the Project, which comprises the development of an open pit gold mine and ore processing facility within the
Exploration Permit in eastern Senegal. Toro Gold currently has a number of exploration projects in Senegal and
Gabon, including its flagship Mako Gold Project.
MEC intends to apply for a Mining Convention from the Senegalese Government for the Mako Gold Project, which
requires a Feasibility Study and ESIA to be carried out and approved by the Ministry of Environment.
1.3.2 Project Overview
The Mako Gold Project will consist of the development of the Petowal gold deposit, located in the Kedougou region
of Senegal, approximately 650 km south-east of Dakar. The Petowal deposit is located in the western section of the
proposed Mako Mining Concession (refer to Figure 1-1). The preferred development scenario involves standard gold
extraction and processing methods, which include the mining of ore via an open pit, processing of ore through
gravity separation and carbon in leach (CIL), and construction of supporting infrastructure including a waste rock
dump (WRD), tailings management facility (TMF), water storage dam (WSD), power station and accommodation
camp.
The Project will be comprised of the following key components and is depicted in Figure 1-1:
Open pit mine (also referred to as the Mine Pit);
Run-of-mine (ROM) Pad, ROM Pad stockpile and primary crusher;
Process Plant;
Tailings Management Facility (TMF) and sediment pond;
Waste Rock Dump (WRD);
Ore Stockpile;
Water Storage Dam (WSD);
Pump station and raw water pipeline;
Power Station and reticulation;
Haul route and Project access infrastructure (including Main Access Road and WSD Access Road);
Mine Services Area (including office / workshops / warehouse); and
Accommodation camp(s).
The Life of Mine is anticipated to be approximately nine years, with a total estimated production of approximately
996 kilo ounces of gold (Toro Gold, 2015). High grade ore will be mined and processed over a six year period at a rate
of 1.8 Million tonnes per year (Mt/y), followed by a further two to three year period (when mining is complete) in
which low grade ore will be processed. Construction is currently scheduled to commence in Quarter 4 of 2015 and
production is expected to start in April 2017. Plant operations will cease in the third quarter of year 8 (Toro Gold,
2015 Pers. Comm.). Once mining has been completed in the area, the site will be fully rehabilitated.
The Project description is based on information provided in the Pre-Feasibility Study (PFS) completed in July 2014,
and updated as per the latest Design Feasibility Study (DFS) findings.
The Project workforce is expected to comprise:
Up to 221 staff during the peak pre-construction period;
Between 300 and 900 staff (in peak periods) during the construction period of 14 months;
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Up to 500 staff for a commissioning period of two months;
Up to 361 personnel at full production during operations (130 of which will require on-site accommodation);
Up to 150 workers during decommissioning and mine closure.
The majority of the Project workforce will be sourced locally and from within Senegal to be in accordance with the
Senegalese Mining Convention requirements. Construction activity will be undertaken primarily six days a week,
during daylight hours, although some night-time work may be required to achieve ore production by early 2017.
A more detailed Project description is provided in the ESIA (Volume A, Chapter 4).
Description of Pre-construction works
The programmed early works phase aims to enable site access, preliminary works for the Accommodation Camp(s)
and preparation of the WSD facility before December 2015, at which time full construction and manning the site will
commence.
Early works (from October to December 2015) will include the following principal activities:
Detailed design for Main Access Road, WSD and Accommodation Camp;
Award of earthwork contract(s), or hiring of equipment if self-managed by the Company;
Commencement of Main Access Road construction from the RN7 through the Wayako Valley;
Preparation, clearing and grubbing of the minor valley floor which forms the WSD facility;
Ordering of the demountable buildings which form part of the new accommodation camp;
Ordering owner mobile equipment; generators, pumps etc; and
Commencement of quarry activities (no blasting required) to generate aggregate for road building and civil
works.
In addition to the primary production fleet, a small pioneering fleet, comprising a single 50t back-hoe excavator and
two 40t capacity articulated dump trucks, may be deployed in order to establish the mining operation during pre-
production, including haul roads and initial bench development.
Description of construction works
Project construction activities will be carefully scheduled to a compressed timeline targeting a first gold pour in
Quarter 1 of 2017. Project construction will primarily involve the following activities:
Site clearance and preparation of areas to be developed, including vegetation clearing, grubbing, soil
stripping and stockpiling, and grading;
Bulk earthworks, including cut and fill or cut to spoil levelling of access roads, drainage channels, Process
Plant site, ROM Pad, TMF, new Accommodation Camp and Mine Pit area. Some blasting may be required for
sections of access road and occasional footings (such as for the Process Plant mill);
Erection of buildings and mine ancillary infrastructure and services;
Sourcing and transportation of construction material and workforce to and from worksites;
Project road infrastructure construction and upgrades;
Installation of drainage and erosion management facilities (ponds, culverts, channels etc.);
Security fencing of Project components, where required; and
Compaction of site areas.
Once site access has been established in the Pre-construction phase, activities will progress in the following
simplified sequence:
Construction of sediment retention pond downstream of the TMF (prior to the onset of the wet season);
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Clearing and grubbing of areas to be developed;
Bulk earthworks, including cut and fill or cut to spoil levelling of access roads, drainage channels, Process
Plant site, ROM Pad, TMF, Accommodation Camp and Mine Pit area. Some blasting may be required for
sections of access road and occasional footings (such as the mill);
Mobilise civil contractor(s) to commence critical path concrete pours in February (civil works completed by
September 2016);
Complete installation of the WSD and river abstraction system and commission before June 2016;
Mechanical contractor to mobilise by end of July 2016, to commence tank erection at Process Plant;
Mine contractor or owner fleet to commence pre-strip by August 2016;
Power Station installation to commence by December 2016. This will be an optimal owner-operated or
independently operated diesel Power Station; and
Process Plant commissioning expected to commence in February 2017, and last for two months..
Vegetation clearance will be conducted during the dry season and confined to the minimum area required for safe
operations to reduce the potential for dust, erosion and sediment transport. Any commercially valuable timber will
be salvaged from the Project Footprint where possible.
Construction material will include sand, fill, and gravel, which will be sourced from within the Project Footprint
(where suitability permits), with additional gravel, sand and fill sourced externally to meet demand as needed
(primarily from the existing quarry near the RN7).
Description of mining operations
Mining method and waste rock
The Petowal deposit will be developed as an open pit mine by conventional methods of drilling, blasting, loading and
hauling with standard industry equipment. Top hammers, down-the hole hammers or rotary drills will be used for
drilling and blasting (depending on the rock characteristics and the optimum blast hole size selected), with reverse
circulation drilling for grade control, and diesel-powered hydraulic excavators (120 t) and 90 t haul trucks as the
primary loading and hauling equipment. The pit will be mined at a rate of 24 million tonnes (Mt) of ore per annum,
producing 74 Mt of waste rock over the Project lifetime.
Mining overburden and waste rock will be disposed of via haul trucks out of the Mine Pit, either to the specifically
designed WRD facility adjacent to the Pit (refer to Figure 1-1), or to facilities requiring waste rock as construction
material (if suitable). The WRD will be constructed and managed to ensure the long-term geochemical and
geotechnical stability of the landform during operation and post-closure. It will be positioned upstream of the TMF
to capture seepage and potentially sediment laden surface water run-off from the catchment for re-use on-site
during operations.
Ore Processing and Tailings Management
The Project will use standard gold mining and processing techniques: open pit mining, followed by crushing and
milling of the ore, then leaching of the gold via a standard gravity / Carbon in Leach (CIL) processing plant
(comprising batch gravity with intensive cyanidation of concentrate and CIL on the batch gravity tails), and finally
elution and electrowinning. The amount of ore produced over the life of mine is expected at approximately 13.9 Mt
with a feed grade of 2.16 g/t of gold.
Ore processing facilities at the proposed mine site will include:
ROM Pad (with an approximate 200,000 m3 capacity);
Process Plant with built-in crushing circuit, conveyors, grinding and classification circuit, pre-leach thickening
circuit, leach and carbon adsorption circuit, cyanide destruction circuit, elution and goldroom;
Water and air services; and
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Reagent and hazardous materials storage facility and storage tanks.
Mined ore will be processed into gold concentrate for export using cyanide solution and additional reagents at the
Process Plant at an annual ore throughput of 1.8 Mt/y. The Process Plant is planned to operate on a 24 hours a day,
seven days a week, and 52-week a year basis.
The unit process operations will involve crushing and grinding, cyanide leaching and adsorption, cyanide
detoxification, carbon regeneration and tailings disposal, elution and electrowinning, and smelting. Further details
of the process are provided in Chapter 4 of the ESIA (Volume A).
The Process Plant will involve the following unit process operations:
Primary jaw crushing and partial secondary cone crushing of ROM ore to produce a crushed product size of
80% passing (P80) 143 mm;
A crushed ore surge bin and overflow dead stockpile with reclaim of crushed ore from the surge bin;
Single stage SAG milling in closed circuit with a pebble crusher and hydrocyclones to produce an 80% passing
125 micron grind size;
Pre-leach thickening to increase the slurry density feeding the CIL circuit to minimise CIL tankage, improve
slurry mixing characteristics and reduce overall reagent consumption;
A CIL circuit which will leach and adsorb gold and silver values from the milled ore onto activated carbon in six
stages of leaching with carbon in all stages for gold adsorption providing a total of 24 hours leach time;
A Zadra elution circuit treating loaded carbon, followed by electrowinning and smelting to produce doré;
An INCO-based1 SO2 / air cyanide destruction circuit to reduce the tailings cyanide concentration to be
consistent with the International Cyanide Management Code (ICMC) requirement of <50mg/l WAD cyanide on
discharge; and
Tailings transfer to the TMF.
Cyanide destruction at the Process Plant will consist of a whole ore cyanide destruction circuit using the air / SO2
process to reduce cyanide concentrations prior to discharge of tailings to the TMF.
Tailings from the Process Plant will be discharged into the TMF, which has been designed to permanently store 13.9
Mt of tailings at a production rate of 1.8 Mt/y. The establishment of the TMF will be staged, and designed to
ANCOLD and ICOLD standards.
Process water from the grinding and gravity circuits will be reused. Wash water from the CIL circuit will be returned
to the leach feed distribution box for reuse. Tailings from the cyanide destruction circuit will be pumped to the TMF
for storage and treatment while supernatant water from the TMF will be recovered and returned as process water
decant for reuse.
Reagents required for the above process includes quicklime, grinding media, flocculent, caustic soda (sodium
hydroxide), activated carbon, sodium cyanide, copper sulphate, sodium metabisulphite, leach aid, diesel and
hydrochloric acid.
Water storage dam
The Water Storage Dam (WSD) will provide the raw and clean process for Process Plant water requirements as well
as water for dust suppression and drinking. The WSD embankment will be constructed across the Kobokou Creek, a
Gambia River tributary in Wayako Valley. The facility will store surface water from the 56 ha upstream catchment
area and water abstracted from the Gambia River during the rainy season, at a rate ranging from 1.6 m3/s (seven
months pumping) to 2.95 m3/s (four months pumping) to meet Project requirements (Toro Gold, 2015c). The WSD
will have a maximum storage capacity of 1.04 million m3 and an embankment height of 21 m. Duty / stand-by water
pumps will be provided for raw water distribution from these tanks to the plant. Water will be recovered from the
WSD by a floating decant barge (Knight Piesold, 2015a).
1 This refers to the sulfur dioxide (SO2) and air process developed by INCO Limited in the1980’s.
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Mine services and ancillary facilities
The Mine Services Area will be constructed in the south-western portion of the PDA, comprised of the following
components (refer to Figure 1-1):
Mine management / services/ administrative office;
Mine warehouse;
Vehicle maintenance workshop for heavy and light vehicles;
Mine vehicle wash-down bay, with water management and oil/water separation;
Heavy / light vehicle diesel day storage tank (approximately 30 m3) and refuelling bay;
Boiler-maker workshop;
Mine staff mess;
Shift change building with showers and ablutions; and
Waste Management Area (Landfill Pit, Hazardous Waste Pit and Incinerator).
Administration and other buildings will be single storey, with final dimensions based on the number of staff
occupying them.
Power supply
The Power Station will supply all the electricity onsite for the Project, particularly the Process Plant, Mine Services
Area, accommodation camps, and water supply. The diesel fuelled Power Station will be operated continuously to
supply a base load of 9.8 MW for steady state operations. The maximum power demand from plant and
infrastructure will be 9, 729 kW and energy consumption per year for plant and infrastructure will be 75.7 GWhr/yr.
Main access road and road infrastructure
The Main Access Road to the PDA will be from the RN7 highway, passing through the Wayako Valley, as shown in
Figure 1-1. The first section of the road running from the RN7 to the Mako-Tambanoumouya road will be 7.1 km in
length and 9 m wide. The second section will run parallel to the Mako-Tambanoumouya road for a 1.3 km stretch
and will then head north-west for a further 4 km towards the PDA, in part following an existing exploration track.
Parts of the road (in steep sections) may be sealed (Toro Gold, 2015c).
There will also be a short access road of approximately 750 m leading from the Mako-Tambanoumouya road to the
WSD (see Figure 1-1).
The road between Mako and Tambanoumouya will be upgraded for use during the Pre-construction phase. There will
be limited ongoing use of this road by light vehicles during operations, where necessary.
Additional mine access roads both within the Mine Pit area to access higher areas as well as external permanent haul
roads will be established. These roads are predominantly cut into the slopes due to the steepness of the terrain
within the pit design areas, and the external permanent roads are a combination of cut and fill to provide a
reasonably consistent haul road profile limited to maximum gradients of +/- 10% percent.
Description of decommissioning, rehabilitation and closure works
The majority of mine related infrastructure, utilities and services will be decommissioned and either removed or
rehabilitated, while a number of assets may be transferred for government or community use (e.g. access roads) or
left in situ (e.g. buried pipelines), where practicable.
Rehabilitation of mining areas (i.e. Mine Pit, WRD) will be carried out progressively over the mine life, where
practicable, and upon closure. The Company’s overall closure objective will be to prevent or minimise adverse long-
term environmental, physical, social and economic impacts for the greater Project Area and to create stable
landforms that provide self-sustaining ecosystems.
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Detailed information on decommissioning and rehabilitation of various Project components is provided in the
Rehabilitation and Conceptual Mine Closure Plan (RCMCP, Volume E).
Accommodation facilities
During the pre-construction and construction phase, the existing camp used during the Exploration phase of the
Project will be used to accommodate staff who require on-site accommodation (i.e. expatriate and senior national
staff from outside the Kedougou Region). The camp is located between Linguekoto and Mako towards the Gambia
River (refer to Figure 1-1Figure 1-1) and can accommodate up to 70 staff (Toro Gold, 2015a).
Construction of the new Accommodation Camp will commence upon completion of the earthworks and following
delivery of the first phase of the buildings (Coffey, 2015). The preferred location for the new Accommodation Camp is
onsite on the northern side of the Mako-Tambanoumouya road, north-east of the WSD and approximately 7 km east
of the Process Plant, in the Wayako Valley (refer to Figure 1-1). It will be a purpose-built accommodation facility of
up to 130 beds primarily for expats, senior nationals, and essential skilled staff. Once the Accommodation Camp is
constructed, up to 200 beds will be available for use between the Exploration Camp and Accommodation Camp.
During the peak construction period however, it is anticipated that an additional 50 to 80 additional beds will be
temporarily supplied through demountable accommodation located adjacent to the new Accommodation Camp,
due to insufficient beds available at both camps for the workforce.
During the operations phase, it is expected that only the new Accommodation Camp onsite will be used for
accommodating Project staff, while the Exploration Camp may be used for accommodating Project visitors.
The majority of staff will either be hired from the local area (and therefore already have local accommodation), or be
expected to relocate to a community in the local area, and to Kedougou in particular. This approach is
recommended under the 2009 IFC / EBRD Public Guidance Note ‘Worker Accommodation: Processes and Standards’,
and is intended to create a wide range of economic opportunities (such as rental income) as well as aid in the
development of local businesses (e.g. restaurants, shops, etc.).
Table 1-1 shows the number of staff that will be housed on- and offsite during the construction and operations
phases.
Table 1-1 Total Staff and Accommodation Requirements
Project Phase / Location Total Staff / Total Beds
Construction Phase 900
On-site (New Accommodation Camp and existing
Exploration Camp) 200
On-site (temporary demountable accommodation) 50-80
Off-site (non-locals who lodge in Kedougou
region) 350
Off-site (locals) 300
Operations Phase 361
On-site (main Accommodation Camp) 130
Off-site 231
Source: Toro Gold, 2015.
The accommodation camp facilities will include power distribution, catering, maintenance, potable water supply,
telecommunications, ablutions, camp administration, medical and recreational facilities, and effluent and waste
management systems. The power for accommodation facilities will be supplied by diesel generators. Water will be
sourced from the Gambia River and treated for use in the accommodation camps. Separate accommodation units,
bathroom and ablution facilities will be provided for men and women.
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1.4 Report Author
The Company has engaged Earth Systems to prepare the ESIA documents, including this ESMMP. Earth Systems is
an international multidisciplinary environmental and social consulting firm registered in Australia with a head office
in Melbourne (Australia); additional Australian offices in Perth, Darwin and Brisbane; and international offices in
Dakar (Senegal), Bristol (United Kingdom), Vientiane (Lao PDR), Shanghai (China), and Auckland (New Zealand).
The contact details for Earth Systems, Toro Gold and MEC are provided as follows.
Earth Systems Pty Ltd (Head Office) Earth Systems SARL (Senegal Office)
Address:
AUSTRALIA
14 Church St,
Hawthorn, Melbourne,
Victoria 3122
Australia
Email: [email protected]
Web: www.earthsystems.com.au
Address:
SENEGAL
3ème
étage
Immeuble Serigne Saliou Mbacké
Route de l'Aeroport
Ngor, Dakar, Senegal
Email: [email protected]
Web: www.earthsystemsafrica.com
Toro Gold Ltd / MEC (Head Office) MEC (Senegal Office)
Address:
UNITED KINGDOM
Toro Technical Services
Egyptian House
170-173 Piccadilly
London W1J 9EJ
United Kingdom
Email: [email protected]
Tel: +221 33 868 30 57
Web: http://www.torogold.com
Address:
SENEGAL
Mako Exploration Company SA
8 Route du Méridien Président
Almadies
Dakar
Senegal
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Figure 1-1 Project Development Area and Mine Layout
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2 LEGISLATIVE REQUIREMENTS, GUIDELINES AND COMMITMENTS
2.1 Toro Gold Environmental and Social Commitments
Toro Gold and its wholly owned subsidiary MEC (the ‘Company’) are committed to meeting international standards
of best practice for social development, environmental protection, health and safety, security, and in support of
human rights. Toro Gold has developed an Environmental and Social Performance Framework (ESPF) (refer to
Section 2.1.1) and Environmental and Social Design Criteria to assist the company to operate according to
international standards (refer to Section 2.1.2).
Toro Gold’s business principles and commitments are outlined below with respect to social, environment, and
health, safety and security matters.
Social
Business principles:
Toro Gold will work with and listen to the concerns and interests of local communities and will seek to
ensure that they benefit from its presence on a long term basis.
Toro Gold will support human rights within its reasonable area of influence and undertake appropriate
Human Rights due diligence related to its activities.
Commitments:
Assess the social impacts of our operations in advance of commencement and work to avoid or mitigate
negative impacts and meet standards of international good practice.
Work in partnership with communities, Governments and other stakeholders to understand their priorities
and contribute to social development through economic growth.
Work to build good relationships with communities and to take community impacts into account
respecting their cultures and traditions.
Work to ensure that local communities benefit on an enduring basis through opportunities such as
employment, local supply and contracting, and training. Where appropriate seek to ensure that local
opportunities are prioritised throughout our supply chain.
Include appropriate conditions within sub-contractor and supplier agreements to seek to ensure their
consistency with these commitments.
Selectively invest in social projects that benefit local communities and support the Toro Gold business.
Support human rights through our work activities, including work conditions for employees, special
sensitivity towards dealing with indigenous populations, conducting security operations, and in seeking to
ensure that local communities benefit from our presence. In particular, support the UN Guiding Principles
on Business and Human Rights and the Voluntary Principle on Security and Human Rights.
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Environmental
Business principles:
Toro Gold will meet internationally accepted best practice and where necessary exceed local regulatory
standards to achieve that.
Toro Gold will work to minimise the environmental impact of its operations at all times and will work to
enhance the environment around its projects as far as is practicable.
Toro Gold will seek to implement a No Net Loss approach to biodiversity conservation at its operational
sites.
Commitments:
Assess the environmental impacts of our operations in advance of commencement and prevent or
mitigate any harmful effects.
Always comply with local regulation but apply international standards (IFC performance standards)
where these are more rigorous.
Work proactively with others, to contribute to biodiversity conservation through scientific, practical and
educational activity. In projects with biodiversity impacts, develop a biodiversity strategy, which will set
out an appropriate mitigation hierarchy and how we plan to achieve a ‘No Net Loss’ biodiversity
conservation.
Minimise the carbon footprint of our operations through appropriate investment in efficient technology.
Work to continuously improve its performance.
Health, Safety and Security
Business principles:
Toro Gold will provide secure work environments which are healthy and safe.
Toro Gold will treat all employees with fairness and respect and help them to develop their potential
through training.
Commitments:
Conduct all operations consistent with industry best practice with respect to Health, Safety and Security.
Apply rigorous standards, guidelines and management systems to hazardous activities and effectively
implement them with employees and contractors.
Develop a workplace culture which is conducive to a healthy and safe environment and prevents dangers
and abuses and train employees to that effect.
Work with contractors to ensure that the supply chain does not include forced or harmful child labour or
abusive labour practices.
Support the Voluntary Principles on Security and Human rights and include them in private security
contracts.
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2.1.1 Environmental and Social Performance Framework
The ESPF consists of a set of Performance Standards drawn primarily from the International Finance Corporation
(IFC) Performance Standards, and reference the ‘Voluntary Principles on Security and Human Rights’, the ‘UN
Guiding Principles on Business and Human Rights’, as well as the ‘Sustainable Development Framework’ of the
International Council on Mining and Minerals (ICMM) (refer to Section 2.3). The ESPF refers to a set of Operational
Guidelines, embodied in the Toro Gold ‘Exploration Code of Conduct’ to be used in field-based operations.
Chapter 3 of the ESIA (Volume A) provides further details on Toro Gold’s performance standards, and their
implication for the Mako Gold Project.
2.1.2 Environmental and Social Design Criteria
Environmental and social design criteria were developed during the feasibility process to provide guidance for the
design and development of the Mako Gold Project.
These design criteria are aimed at protecting the following priority environmental and social values in the Project
Area:
The Niokolo-Koba National Park (PNNK) (classed as a World Heritage site, UNESCO-MAB Biosphere
Reserve and national nature reserve);
Habitat of importance to endangered species, and threatened / unique ecosystems;
The aquatic environment of the Gambia River and its tributaries; and
Community land and water use.
Relevant environmental and social standards and guidelines considered critical for the Project design are discussed
in the ESIA, Chapter 3 (Volume A).
2.2 Legislative Requirement and Guidelines
2.2.1 Mining Convention Agreement
The Project is subject to a Mining Convention signed in March 2007 between GRS and Kansala Resources SA for
the Mako Permit (Convention Minière pour l’or et les substances connexes passée en application de la Loi 2003-36 du
24/11/2003 portant Code Minier entre le Gouvernement de la République du Senegal et Kansala Resource SA). The
Mining Convention covers both the exploration and operations phases of the Project, and defines the legal,
administrative, financial and fiscal conditions of the Project.
The Convention includes relevant provisions to the ESMMP, including:
Access to land and resources for exploration and mining (Article 34);
Protection of the environment and cultural heritage (Article 35), including specific provisions for:
» Taking the necessary measures to protect the environment;
» Informing relevant authorities of discoveries of cultural heritage objects and artefacts, and of leaving
national artefacts in situ for up to one month following notification of authorities (Article 35.7); and
» Conducting regular monitoring, following a pre-determined schedule, of water quality, soil and air in the
work zone and surrounding areas during the exploitation phase of the Project.
A rehabilitation programme to be implemented when the mining title expires, and the creation of a
rehabilitation fund (Articles 35.3 and 35.4).
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2.2.2 Relevant Legislation and Guidelines
An ESMMP is a requirement of Senegalese regulations as per Arrêté n° 9472 du 28 Novembre 2001 portant Contenu
du Rapport d'étude d'impact. It is also specified in the Terms of the Reference for the ESIA for the Project approved
by the DEEC.
Key Senegalese legislation relevant to Project permitting includes:
Mining Code (2003);
Environment Code (2001);
Water Code (1981);
Forestry Code (1998); and
National Domain (1964).
A list of relevant national laws, regulations and best practice guidance applicable to the environmental and social
management of the Project are presented in Table 2-1. Key legislation and regulations that apply to the Mako Gold
Project are summarised further below.
Table 2-1 Relevant national laws, regulations and guidelines
English Title French Title Date
Decreed
MINING
Mining Code Loi No. 2003-36 du 24 novembre 2003 portant Code Minier
2003
Decree No. 2004-647 (17 May 2004) – Application of the Mining Code
Le décret No. 2004-647 du 17 mai 2004 portant application du Code Minier
2004
Order No. 009249 of 14 June 2013 on the Organization of Artisanal Mining Activity in Senegal.
Arête N°009249 du 14 juin 2013 portant Organisation de l’activité d’orpaillage au Sénégal
2013
ENVIRONMENT
Environment Code Loi No. 2001-01 du 15 janvier 2001 portant Code de l’Environnement
1983, updated 2001
Decree No. 2001-282 (12 April 2001) – Application of the Environment Code
Le décret No. 2001-282 du 12 avril 2001 portant application du Code de l’Environnement
2001
Ministerial Order No. 9468 MJEHP-DEEC of 28 November 2001 defining public participation in the EIA
Arrêté ministériel n°9468 MJEHP/DEEC du 28 Novembre 2001 portant règlementation de la participation du public à l’étude d’impact environnemental
2001
Ministerial Order No. 9469 MJEHP-DEEC of 28 November 2001 defining the organisation and function of the Technical Committee
Arrêté ministériel n°9469 MJEHP/DEEC du 28 Novembre 2001 portant organisation et fonctionnement du Comité technique
2001
Ministerial Order No. 9470 MJEHP-DEEC of 28 November 2001 defining the conditions for granting approval for the conduct of Environmental Impact Assessments
Arrêté ministériel n°9470 MJEHP/DEEC du 28 Novembre 2001 fixant les conditions de délivrance de l’Agrément pour l’exercice des activités relatives aux études d’impact sur l’Environnement
2001
Ministerial Order No. 9471 of 28 November 2001 on the contents of the Terms of Reference for Environmental Impact Assessments
Arrêté ministériel n°9471 MJEHP/DEEC du 28 Novembre 2001 portant contenu des termes de référence des études d’impact
2001
Ministerial Order No. 9472 of 28 November 2001 on the contents of the Environmental Impact Assessment report
Arrêté ministériel n°9472 MJEHP/DEEC du 28 Novembre 2001 portant contenu du rapport de l'Etude d'impact environnemental
2001
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English Title French Title Date
Decreed
Interministerial Order No. 4862 of 14 July 1999 on the development of a POI in certain classified establishments and the development of a PPI in local collectives inside the perimeter of a classified establishment that requires a POI
Arrêté Interministériel n°4862 du 14 juillet 1999 rendant obligatoire l’établissement d’un Plan d’Opération Interne (POI) dans certains établissements classés et d’un Plan Particulier d’Intervention (PPI) dans les collectivités locales présentant à l’intérieur de leur périmètre territorial des installations classées soumises à l’élaboration d’un POI
1999
Forestry Code Loi No. 98-03 du 8 janvier 1998 portant Code Forestier 1998
Hunting and Fauna Protection Code Loi No. 86-04 du 24 janvier 1986 portant Code de la Chasse and de la Protection de la Faune
1986
Decree No. 86-844 (14 July 1986) to fix basis for fauna protection and management, supplemented by decree of application on 25 June 1998
Le décret d’application No. 86-844 du 14 juillet 1986 et les décrets d’application du 25 juin 1998
1986, updated 1998
Agro-forestry-pastoral Orientation Law La loi No. 2004-16 du 4 juin 2004 portant loi d’orientation agro-sylvo-pastorale
2004
Cattle-Run Regulation Le décret No. 80-268 du 10 mars 1980 portant organisation du parcours de bétail
1980
Water Code Loi No. 81-13 de 4 mars 1981 portant Code de l’Eau 1981
Wastewater Discharge Standard La norme sur les rejets des eaux (NS 05-061) 2001
Inter-ministerial decree No. 1555 (15 March 2002) applying wastewater discharge standard NS 05-061
L’arrêté interministériel No. 1555 de 15 mars 2002 portant application de la norme NS 05-061 sur les rejets des eaux usées
2002
Atmospheric Pollution Standard La Norme de rejets NS 05-062 – pollution atmosphérique 2004
Law No. 64-46 (17 June 1964) concerning the national domain
La loi No. 64-46 du 17 juin 1964 relative au domaine national
1964
Law No. 76-66 (2 July 1976) pertaining to the State Code
La loi No. 76-66 du 2 juillet 1976 portant Code du Domaine de l’Etat
1976
Civil Code and the Decree of 26 July 1932 Le Code civil et le décret de 26 juillet 1932 1932
Public Health Code Loi No. 54-418 du 15 avril 1954 portant Code de la Santé publique
1954
Reproductive Health Law Loi No. 2005-18 du 5 août 2005 relative à la santé de la reproduction
2005
Sanitation Code Loi n° 2009-24 du 8 juillet 2009 portant Code de l’Assainissement
2009
Hygiene Code Loi No. 83-71 de 5 juillet 1983 portant Code de l’Hygiène 1983
Labour Code Loi No. 97-17 du 1 décembre 1997 portant Code du Travail
1997
Monument and Site Preservation Law La loi no.71-12 du 25 janvier 1971 fixé le régime des monuments historiques et celui des fouilles et découvertes
1971
Decree No. 73-746 (8 August 1973) on the application of the Monument and Site Preservation Law
Le décret No. 73-746 du 8 août 1973 portant application de la loi no.71-12
1973
Local Communities Code La loi No. 96-06 du 22 mars 1996 portant Code des Collectivités Locales
1996
Mako Gold Project Environmental and Social Management and Monitoring Plan
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English Title French Title Date
Decreed
Law No. 96-07 (22 March 1996) transferring jurisdiction to local communities
La loi No. 96-07 du 22 mars 1996 portant transfert de compétences aux régions, aux
communes et aux communautés rurales
1996
Decree No. 96-1134 (27 December 1996) on the application of the law transferring jurisdiction of environmental matters and management to regions, communes and rural communities
Le décret No. 96-1134 du 27 décembre 1996 portant application de la loi portant transfert de competences aux regions, aux communes et aux communautés rurales, en matière d’environnement et de gestion des ressources naturelles
1996
Draft Standard on Management of Solid Waste Projet de Norme relative à la Gestion des Déchets Solides
In preparation since 2005
LAND ADMINISTRATION, COMPENSATION AND RESETTLEMENT
Constitution of Senegal, 7 January 2001 La constitution du Sénégal du 7 janvier 2001 2001
Decree of 26 July 1932 reorganizing the system of land ownership in the AOF
Décret du 26 juillet 1932 réorganisant le régime de la propriété foncière en AOF
1932
Law No. 64-46 (June 17, 1964) concerning the National Domain
La loi n° 64-46 du 17 juin 1964 relative au domaine national
1964
Decree No. 64-573 (July 30, 1964), Application of the Law on National Domain
Le décret No. 64-573 du 30 juillet 1964, fixant les conditions d’application de la loi n° 64-46 du 11 (sic) juin 1964 relative au domaine national
1964
Law No. 76-66 (July 2, 1976) pertaining to the State Code
La Loi n° 76-66 du 2 juillet 1976 portant Code du Domaine de l’Etat
1976
Decree No. 81-557 (21st May 1981) pertaining to the implementation of the State Code
Décret 81-557 du 21 mai 1981 portant application du code du domaine de l’État
1981
Civil Code and the Decree of July 26, 1932 Le Code civil et le décret du 26 juillet 1932 1932
Law No. 76-67 (July 2, 1976), Expropriation Applicable for Public Works
La Loi No. 76-67 du 2 juillet 1976 relative a l’expropriation pour cause d’utilité publique aux autres préfectures foncières d’utilité publique.
1976
Decree No. 77-563 (July 3, 1977) Expropriation Applicable for Public Works
Le décret No. 77-563 du 3 juillet 1977, portant application de la loi No. 76-67 du 2 juillet 1976 relative a l’expropriation pour cause d’utilité publique aux autres préfectures foncières d’utilité publique
1977
Law No. 96-07 (March 22, 1996) relating to the transfer of powers to regions, municipalities, and rural communities
La Loi 96-07 du 22 mars 1996 portant transfert des compétences aux régions, aux communes et aux communautés rurales
1996
Law No 96-06 (March 22, 1996) pertaining to the administration of local collectives
Loi 96-06 du 22 mars 1996 portant code des collectivités locales
1996
Decree 96-1130 (27th December 1996) pertaining to the implementation of the Law on the transfer of powers to regions, municipalities and rural communities in regards to management and utilisation of natural resources
Décret 96 1130 du 27 décembre 1996 portant application de la loi portant transfert de compétences aux régions, aux communes et aux communautés rurales, en matière de gestion des ressources naturelles
1996
Decree No 72-1288 (27 October 1972) pertaining to the conditions for allocation / disallocation of land in the national domain (community land)
Décret n° 72-1288 du 27 octobre 1972 fixant les conditions d’affectation et de désaffectation des terres du domaine national situées en zone de terroirs
1972
Decree No 91-938 (22 August 1991) permitting all occupants to be compensated
Décret 91-838 du 22 août 1991 permet à tous les occupants d’être indemnisés
1991
Mako Gold Project Environmental and Social Management and Monitoring Plan
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English Title French Title Date
Decreed
Decree No. 2010-439 (6 April 2010) repealing and replacing No. 88-074 (January 18, 1988), Price Scale for Land Applicable upon the Expropriation for Public Works
Décret n° 2010-439 du 6 avril 2010 abrogeant et remplaçant le décret n° 88-74 du 18 janvier 1988 fixant le barème du prix des terrains nus et des terrains bâtis, applicable en matière de loyer.
2010
Circular No. 2237/DGPA (October 7, 1974), Price Scale for Calculation of Compensation in Case of Destruction of Plantations and Cultivation or Delocalisation from the National Domain
La circulaire No. 2237/DGPA le 7 octobre 1974, barème de prix pour l’estimation des préfectures à payer en cas de destruction de plantations et de culture ou de déguerpissement du domaine national.
1974
Decree No. 81-683 of July 7, 1981 pertaining to the calculation for payment of premises for residential use
Décret n° 81-683 du 7 juillet 1981 portant fixation des éléments de calcul du loyer des locaux à usage d’habitation
1981
Mining Regulatory Framework
The Mining Code (2003) is the primary legislation regulating the mining industry in Senegal, covering both
exploration and mining activities. Sections of the code relevant to the environmental and social management of
mining projects include:
Title IX, Chapter 5 ‘Environmental Protection’ – Specifies the requirement for an environmental impact
study; for setting funds aside for rehabilitation and closure; and compliance with the Forestry Code (Art.
L44);
Title VIII, Article 55, ‘Equalisation and Support’ – Ensures that a portion of income from the mining
operation is set aside as a fund for the local communities (Community Equalization Fund);
Article 76 of the Mining Code requires the holder of the mining title to compensate owners or occupants
of land occupied by the mining title holder;
Article 81 covers compensation of third parties and the state;
Article 82 addresses the need for rehabilitation of mine sites;
The requirement for an EIA is in Article 83, which requires an EIA to be prepared when a permit of
exploitation or mining concession is requested. This is further elaborated in Article 26 of Decree No.
2004-647. Decree No. 2004-647 in article 93 stipulates compensation requirements for impacts; and
Article 84 requires a Mine Site Rehabilitation Fund to be established with terms and conditions fixed by
decree.
The objective of the Environment Code (2001) is to establish a set of principles to manage and protect the
environment against all forms of degradation. The Code defines procedures for environmental impact
assessment. The Code also defines key environmental terms and sets out the Government’s environmental
policies for five key areas: classified installations (any source, mobile or fixed, capable of posing a threat to the
environment; divided into two classes based on potential impact); water pollution; noise pollution; air pollution
and unpleasant odours; and soil and sub-surface pollution.
Senegal‘s Mineral Policy Statement (2003) provides for the abandonment of state monopoly over any mineral
resources and refocusing on regulating private mining companies. The policy statement limits to 20% the state‘s
participation in ventures and encourages participation of private investors, both domestic and foreign. The state
will also support the diversification of mineral production and the beneficiation (initial processing) of mineral
products before export in order to generate employment opportunities in the industry. The need for an ESIA prior
to mining operations is reiterated in the Statement.
Pursuant to the Mining Code 2003, the Decree N° 2009-1335 Mine Rehabilitation and Closure Fund / Décret N°
2009-1335 portant création et fixant les modalités d’alimentation et de fonctionnement du Fonds De Réhabilitation
Mako Gold Project Environmental and Social Management and Monitoring Plan
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Des Sites Miniers was established to provide the mechanisms and operating framework for a Mine Rehabilitation
Fund.
The main points relevant to the Mako Gold Project are:
All holders of an exploitation permit are required to carry out rehabilitation of mine sites when their
mining exploitation permit expires, unless it has been approved to be renewed;
The Permit Owner is required to establish a Mine Rehabilitation and Closure Fund, which will be used to
finance the rehabilitation requirements for the following year. Financial contributions will be provided
annually from exploitation profits of the permit owner from the date of first production for an amount
equal to the average annual cost for rehabilitation;
The amount should be at least equal to the cost for rehabilitation as approved in the latest version of the
ESMMP (taking into account any updates);
The exploitation permit owner should also provide a contingency budget equal to 5 times the average
annual cost for rehabilitation from the date of first production;
Fund is to be jointly managed by the permit owner and the Ministry for Mines and the Environment
through a formal agreement; and
Fund will be valid for the duration of the exploitation permit, taking into account the time required to
carry out post-mine closure and rehabilitation activities.
Water Framework
The Water Code (Code de l’Eau, Law No. 81-13 of 4 March 1981) establishes the main legal framework for the
management and use of water resources in Senegal. Article 9 (Title I) states that authorisation must be sought
from the Hydraulic and Sanitation Ministry before installing infrastructure to exploit groundwater or surface water
resources. Title II regulates the protection of water quality, including all discharges or deposits that may have an
impact on surface and sub-surface water bodies. Article 75 establishes that human consumption is the priority in
the allocation of water resources.
The Company will require permission from OMVG for development within the Gambia River basin and to abstract
water and discharge to the Gambia River, in accordance with the Convention relating to the Status of the River
Gambia / Convention relating to the Creation of the Gambia River Basin Development Organisation (Organisation
de Mise en Valeur du fleuve Gambie or OMVG).
Land and Forest Resources Framework
National legislation relevant to forestry, wildlife and Protected Areas include:
Law No. 93-06 of February 04, 1993 and its enforcement Decree No. 95-357 of 11 April 1995 put the
protection of forests under the authority of the Direction des Eaux et Forêts, Chasse et de la Conservation
des Sols (DEFCCS).
The Forestry Code (Law No. 98/03 of 8th January 1998 and Decree No. 98/164 of 20th February 1998).
The Hunting and Wildlife Protection Code (established by Law No. 86-04 of January 24, 1986 and Decree
No. 86-844 of July 14, 1986) regulates hunting and defines the types of offenses related to the
destruction of wildlife.
Decree No. 96-1134 of 27 December 1996 provides for the implementation of Law No. 96-07 of March 22,
1996 concerning natural resources. This gives the responsibility for wildlife protection to local authorities.
Senegal’s legislation relevant to the protection of biodiversity includes the following laws and conventions:
The Hunting and Wildlife Protection Code (established by Law No. 86-04 of 24 January 1986 and Decree
No. 86-844 of July 14, 1986) provides for a system of reserves to protect fauna (including the PNNK),
regulates hunting and defines the types of offenses related to the destruction of wildlife.
Law No. 98-03 of 8 January 1998 regarding the Forestry Code.
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Decree No. 96-1134 of 27 December 1996 provides for the implementation of Law No. 96-07 of March 22,
1996 concerning natural resources. This gives the responsibility for wildlife protection to local authorities,
particularly relating to the authority to create natural animal reserves.
A range of decrees relating to the establishment of the PNNK, including Decree No. 2002-271 of 7 March
2002 regarding the up-date of the Niokolo-Koba National Park (PNNK) boundary and periphery.
Land Acquisition and Compensation Regulatory Framework
The Company is committed to mitigating the impacts from land acquisition by providing compensation for loss of
land, assets and livelihood with appropriate stakeholder engagement. The requirement to provide compensation
under Senegalese law is described in the following:
Article 76 of the Mining Code (2003) states that the holder of a permit (including exploration permits) is
required to compensate the owners or occupants of land “for all loss suffered”. This is reiterated in Articles
89, 90, 92 and 93 of the Mining Code Application Decree No. 2004-647 of 17 May 2004 and includes
compensation of the State for any damages or losses resulting from mining operations.
Decree for application (64-573) of 30 July 1964 fixes the application conditions of Law No. 64-46 of June 17,
1964 relating to national property. Article 23 of the decree specifies that where reallocation of land occurs,
the new land holder must pay the previous landholder compensation equal to the value of built
improvements and planted crops estimated on the day that the new allocation is pronounced.
Decree No 91-938 (22 August 1991) amends Section 38 of Decree No. 64-573 of 30 July 1964 on the
application of the Law of the National Domain. It permits illegal / informal occupants subject to
displacement to be eligible for compensation.
Circular no. 2237/DGPA (October 7, 1974), Price scale for calculation of compensation in case of destruction
of plantations/cultivated land or delocalisation from the National Domain.
2.3 International Standards
The Company has adopted the IFC Performance Standards as an appropriate benchmark of international good
practice. These are supplemented as required by reference to the United Nations Guiding Principles on Business
and Human Rights and the International Council on Mining and Metals (ICMM) Sustainable Development
Framework, where relevant.
International agreements relevant to the Mako Gold Project are summarised in Table 2-2. Key international
standards and guidelines are further described below and in the ESIA (Chapter 3, Volume A).
Table 2-2 Relevant international environmental and social standards, safeguards and guidelines
Organisation Document Date Released
International Finance Corporation (IFC) Policy on Environmental and Social Sustainability and
associated IFC Performance Standards
2012
The World Bank / IFC General Environmental, Health and Safety Guidelines 2007
International Cyanide Management
Code
International Cyanide Management Code for the Manufacture,
Transport and Use of Cyanide in the Production of Gold
2014
International Union on the Conservation
of Nature (IUCN)
World Heritage Advice Note: Environmental Assessment;
World Heritage Advice Note: Mining and Oil/Gas Projects
2013
International Council on Metals and
Minerals (ICMM)
Sustainable Development Framework 2003
Extractive Industries Transparency
Initiative (EITI)
The EITI Standard 2013
Mako Gold Project Environmental and Social Management and Monitoring Plan
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USA and UK Governments Voluntary Principles on Security and Human Rights 2000
UN Guiding Principles on Business and Human Rights 2011
2.3.1 IFC Performance Standards
The IFC is the private lending arm of the World Bank Group and the largest multilateral source of loan and equity
financing for private sector projects in developing nations. The environmental and social policies and procedures
of the World Bank are widely regarded as de facto international standards for the environmental and social
management of resource development projects in countries with developing or absent regulatory frameworks.
The IFC Performance Standards were introduced to provide guidance for IFC clients to manage and improve their
environmental and social performance through a risk and outcomes based approach. Direction to IFC’s clients and
staff on the application of the Performance Standards is provided in the IFC Guidance Notes, a companion
document to the Policy on Environmental and Social Sustainability. The updated IFC Performance Standards (PS)
comprise the following:
PS 1: Assessment and Management of Environmental and Social Risks and Impacts;
PS 2: Labour and Working Conditions;
PS 3: Resource Efficiency and Pollution Reduction;
PS 4: Community Health, Safety and Security;
PS 5: Land Acquisition and Involuntary Resettlement;
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;
PS 7: Indigenous Peoples; and
PS 8: Cultural Heritage.
Implications of the above performance standards for the Mako Gold Project are discussed in the ESIA (Chapter 3,
Volume A).
2.3.2 World Bank General Environmental Health and Safety Guidelines
To support the Performance Standards, the IFC uses the World Bank “General Environmental, Health and Safety
Guidelines” of 2007 (EHS Guidelines) as a technical source of information during project appraisal. The EHS
Guidelines contain the industry best practices acceptable to the IFC. For IFC-financed projects, application of the
EHS Guidelines to existing facilities may involve the establishment of site-specific targets with an appropriate
timetable for achieving them. While implementation of the EHS Guidelines is not a mandatory condition in the
provision of financing, application of the guidelines is intended to ensure compliance with the IFC Performance
Standards.
The EHS Guidelines contain information on cross-cutting environmental, health, and safety issues potentially
applicable to all industry sectors, and should be considered together with the relevant industry sector guidelines.
Of specific relevance to the Mako Gold Project is an industry sector guideline developed for the mining sector, the
“Environmental, Health and Safety Guidelines for Mining” of 2007. The EHS Guidelines for Mining apply to
underground and open-pit mining, alluvial mining, solution mining, and marine dredging. The guideline addresses
industry-specific impacts and management techniques related to environmental impacts; occupational and
community health and safety; and mine closure and rehabilitation. The document also outlines sector-specific
performance indicators and monitoring methods related to the environment and occupational health and safety.
Where host-country regulations and standards differ from the levels and measures presented in the EHS
Guidelines, projects are encouraged to strive to achieve whichever is more stringent.
Mako Gold Project Environmental and Social Management and Monitoring Plan
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2.3.3 International Cyanide Management Code
The Project will be consistent with the International Cyanide Management Institute (ICMI) Cyanide Management
Code (Cyanide Code) Principles and Standards of Practice (2014) for cyanide transportation, including independent
auditing of procedures and Transportation Verification Protocols; and Cyanide Code Standards of Practice for
handling and storage of Cyanide and associated reagents.
2.3.4 UN Guiding Principles on Business and Human Rights
The Guiding Principles on Business and Human Rights were endorsed by the UN Human Rights Council in 2011.
The Principles cover three main aspects:
1. The State duty to protect human rights;
2. The corporate responsibility to respect human rights; and
3. Access to effective remedy through judicial, administrative, legislative or other appropriate means, where
abuses to human rights occur.
Of relevance to the Mako Gold Project is the need for businesses to establish or participate in effective
operational-level grievance mechanisms for individuals or communities who may be adversely impacted by the
business. Such grievance mechanisms perform the following two key functions:
i) Support the identification of adverse human rights impacts as a part of an enterprise’s ongoing
human rights due diligence; and
ii) Allow grievances to be addressed and for adverse impacts to be remediated early and directly by the
business, thereby preventing harms from compounding and grievances from escalating.
The Guiding Principles state that to ensure effectiveness in practice, grievance mechanisms should be:
Legitimate – enabling trust from stakeholder groups and being accountable;
Accessible – known to all stakeholders. Assistance should be provided to those who may face barriers to
access;
Predictable – providing a clear and known procedure with indicative time frames;
Equitable – aggrieved parties have reasonable access to sources of information, advice and expertise;
Transparent – up-dates on grievance progress provided, as well as sufficient information about the
mechanism’s performance;
Rights-compatible – outcomes and remedies accord with internationally recognised human rights;
A source of continuous learning – identifying lessons for mechanism improvement; and
Based on engagement and dialogue – stakeholder consultation and focusing on dialogues to address and
resolve grievances.
2.3.5 International Union on the Conservation of Nature Guidelines
The IUCN has two key guidance documents pertaining to World Heritage:
World Heritage Advice Note: Environmental Assessment; and
World Heritage Advice Note: Mining and Oil/Gas Projects.
These guidelines are of relevance to the Project due to the presence of the World Heritage-listed Niokolo-Koba
National Park (Parc National de Niokolo-Koba or PNNK) and associated 1 km buffer zone adjacent to the east of the
Project. The Advice Notes detail the IUCN’s position on projects located within and in proximity to World Heritage
sites, and provides guidance on the steps to be undertaken to ensure that projects do not impact upon the
Outstanding Universal Values of World Heritage sites. The Advice Note on Environmental Assessment also
Mako Gold Project Environmental and Social Management and Monitoring Plan
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presents eight World Heritage Impact Assessment Principles that must be implemented in undertaking an ESIA for
such projects.
The requirements of these advice notes have been taken into account by the Company and are presented in the
ESIA.
2.3.6 Extractive Industries Transparency Initiative
Senegal’s application to be a part of the Extractive Industries Transparency Initiative (EITI) was approved in
October 2013. Senegal will now implement the EITI Standard, which will ensure transparency in payments made
to the government by the extractives sector in the country. Senegal is required to publish its first EITI Report
within two years of becoming a Candidate (i.e. by October 2015). Validation will begin within three years of
becoming a Candidate (EITI, 2013). The Company will ensure that its activities are in line with the requirements of
the EITI.
2.4 Project Discharge Standards
The Project will consider and comply with:
Discharge and emissions guidelines for off-site releases of water, waste and potential airborne
contaminants; and
Ambient guidelines for the protection of environmental values (e.g. protection of aquatic fauna and
fisheries, drinking water, etc.).
A list of relevant national and international standards is presented in Table 2-3. Where standards or limits do not
exist in Senegalese Law, guidelines, standards or limits used by other countries (e.g. EU, USEPA, UK) or
organisations (e.g. WHO) are adopted in lieu.
Specific environmental criteria adopted for assessing discharge compliance by the Project are listed from Table 2-4
to Table 2-10.
Table 2-3 Relevant environmental standards and guidelines for the Mako Gold Project
Source Relevant Guidelines Year
WASTE / WASTEWATER DISCHARGE AND MONITORING
Senegal Interministerial Decree no 1555 Discharge Water Guidelines / L’arrêté interministériel No.
1555 de 15 mars 2002 portant application de la norme NS 05-061 sur les rejets des eaux
usées
2002
Waste Water Discharge Standard, NS 05-061 / La norme sur les rejets des eaux (NS 05-
061)
2001
Draft Standard on Management of Solid Waste / Projet de Norme relative à la Gestion des
Déchets Solides
In preparation
since 2005
IFC
Environmental Health and Safety Guidelines – Mining 2007
Environmental Health and Safety Guidelines – General – Environmental 2007
General EHS Guidelines: Wastewater and Ambient Water Quality. 2007
ICMI International Cyanide Management Code. 2009
AIR QUALITY
Senegal Atmospheric Pollution Standard, NS 05-062 / La Norme de rejets NS 05-062 – pollution
atmosphérique
2004
IFC Environmental Health and Safety Guidelines for Mining. 2007
Mako Gold Project Environmental and Social Management and Monitoring Plan
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Source Relevant Guidelines Year
General EHS Guidelines: Air Emissions and Ambient Air Quality. 2007
WHO Air Quality Guidelines – Global Update 2005
SOIL QUALITY
UK Soil Guideline Value 2009
AQUATIC FAUNA / FRESH WATERS
Senegal n/a n/a
United States National recommended water quality criteria; republication. United States Environmental
Protection Agency (USEPA)
2009
European
Union
Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008
on environmental quality standards in the field of water policy, amending and subsequently
repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC,
86/280/EEC and amending Directive 2000/60/EC of the European Parliament and of the
Council.
2008
European
Union
Directive 2006/44/EC of the European Parliament and of the Council of 6 September 2006
on the quality of fresh waters needing protection or improvement in order to support fish life
(E.U., 2006).
2006
DRINKING WATER
Senegal n/a n/a
WHO Guidelines for Drinking Water Quality, fourth edition 2011
European
Union
Council directive 9883/EC of November 1998 on the quality of water intended for human
consumption.
1998
NOISE AND VIBRATION
Senegal Environment Code (noise) / Code de l’Environnement 2001
UK British Standards (vibration) BS 6472:2008, 4866:2010 and 7385-2:1993 1993, 2008,
2010
IFC Environmental Health and Safety Guidelines for Mining. 2007
Table 2-4 Air quality standards adopted for the Mako Gold Project
Pollutant Averaging Period WHO Standard1 Senegal Standard2
Particulate Matter <10 µm (PM10) 24 hour 50 µg/m3 260 µg/m3
1 year 20 µg/m3 80 µg/m3
Particulate Matter <2.5 µm (PM2.5) 24 hour 25 µg/m3 -
1 year 10 µg/m3 -
Nitrogen dioxide (NO2) 1 hour 200 µg/m3 200 µg/m3
1 year 40 µg/m3 40 µg/m3
Sulfur doxide (SO2) 24 hour 20 µg/m3 125 µg/m3
1 year - 50 µg/m3
Mako Gold Project Environmental and Social Management and Monitoring Plan
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Pollutant Averaging Period WHO Standard1 Senegal Standard2
Carbon monoxide (CO) 1 hour 30 mg/m3 -
24 hour - 30 mg/m3
Ozone (O3) 8 hour 100 µg/m3 120 µg/m3
1. World Health Organization (WHO) Air Quality Guidelines (2005)
2. Senegalese Atmospheric Pollution Standard, NS 05-062 / La Norme de rejets NS 05-062 – pollution atmosphérique 2004
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Table 2-5 Ambient surface water quality standards adopted for the Mako Gold Project
Parameter
USEPA National recommended water criteria for freshwater (μg/L)
(2009)
EU Directive on the quality of fresh waters (2006) (μg/l)
EU Directive on Environmental Quality Standards in the field of
Water Policy (2008) (μg/L)3
International Cyanide Management Code (µg/L)
(2009)
Maximum (CMC**)
Continuous (CCC***)
Guideline Mandatory Annual Average Maximum
Aluminium (Al); pH 6.5-9.0 750 i 87
i,S - - - - -
Ammonia (NH3) Criteria are pH, temperature and
life-stage dependent. 5 25
t - - -
Arsenic (As) 340 a, d
150 a, d
- - - - -
Boron (B) 750,000b
- - - - -
Cadmium (Cd) 2 d,e
0.25 d,e
- - 0.08 - 0.25 f 0.45 - 1.5
f -
Chloride (Cl-) 860,000 230,000 - - - - -
Chlorine (Cl) 19 11 - 5 - - -
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Parameter
USEPA National recommended water criteria for freshwater (μg/L)
(2009)
EU Directive on the quality of fresh waters (2006) (μg/l)
EU Directive on Environmental Quality Standards in the field of
Water Policy (2008) (μg/L)3
International Cyanide Management Code (µg/L)
(2009)
Maximum (CMC**)
Continuous (CCC***)
Guideline Mandatory Annual Average Maximum
Chromium III (Cr3+
) 570 d,e
74 d,e
- - - - -
Chromium VI (Cr6+
) 16 d 11
d - - - - -
Copper (Cu)
Freshwater criteria calculated using biotic ligand model see “Aquatic Life Ambient Freshwater Quality
Criteria – Copper” 2007 EPA-822-R-07-001.
40 - - - -
Free cyanide 22 5.2 22n
Dissolved Oxygen See “Quality Criteria for Water”
1986. EPA 440/5-86-001.
50% of monitoring events are ≥
8 mg/L; 100% of
monitoring events are ≥
5 mg/L
50% of monitoring events are ≥
7 mg/Lo
- - -
Iron (Fe) - 1000c - - - - -
Lead (Pb) 65 d,e
2.5 d,e
- - 7.2 - -
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Parameter
USEPA National recommended water criteria for freshwater (μg/L)
(2009)
EU Directive on the quality of fresh waters (2006) (μg/l)
EU Directive on Environmental Quality Standards in the field of
Water Policy (2008) (μg/L)3
International Cyanide Management Code (µg/L)
(2009)
Maximum (CMC**)
Continuous (CCC***)
Guideline Mandatory Annual Average Maximum
Mercury (Hg) 1.4 d,hh
0.77 d,hh
- - 0.059 0.07 -
Nickel (Ni) 470 d,e
52 d,e
- - 20 - -
pH - 6.5 - 9.0 - 6.0 - 9.0p
- - -
Selenium - total (Se) l 5 - - - - -
Silver (Ag) 3.2 d,e
- - - - - -
Oil and Grease See “Quality Criteria for Water”
1986. EPA 440/5-86-001. g
- - - - -
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Parameter
USEPA National recommended water criteria for freshwater (μg/L)
(2009)
EU Directive on the quality of fresh waters (2006) (μg/l)
EU Directive on Environmental Quality Standards in the field of
Water Policy (2008) (μg/L)3
International Cyanide Management Code (µg/L)
(2009)
Maximum (CMC**)
Continuous (CCC***)
Guideline Mandatory Annual Average Maximum
Total Suspended Solids (TSS) See “Quality Criteria for Water”
1986. EPA 440/5-86-001. 25,000 - - - -
Turbidity (NTU) See “Quality Criteria for Water”
1986. EPA 440/5-86-001.t - - - - -
Zinc (Zn) 120 d,e
120 d,e
- 1,000 - - -
* Note that ambient water quality criteria apply to the receiving water downstream of the Project site, below a designated mixing zone(s). Selection of suitable mixing zone(s) will depend on the location of
discharge point(s).
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^ Relevant criteria are shaded in blue. As there are no existing GRS or World Bank / IFC ambient water quality guidelines, the European Union (EU) water quality standards have generally been selected as the
relevant criteria. While the EU water quality standards are generally more stringent than the corresponding USEPA criteria, they are more relevant to the Mako Gold Project as it is primarily owned by a United
Kingdom based company. Nevertheless, the USEPA criteria have been shaded where corresponding EU criteria are not provided.
** The Criteria Maximum Concentration (CMC) is an estimate of the highest concentration of a material in surface water to which an aquatic community can be exposed briefly without resulting in an unacceptable
effect.
*** The Criteria Continuous Concentration (CCC) is an estimate of the highest concentration of a material in surface water to which an aquatic community can be exposed indefinitely without resulting in an
unacceptable effect.
3 = With the exception of cadmium, lead, mercury and nickel (hereinafter ‘metals’) the EQS set up in this Annex are expressed as total concentrations in the whole water sample. In the case of metals the EQS refers
to the dissolved concentration, i.e. the dissolved phase of a water sample obtained by filtration through a 0.45 μm filter or any equivalent pre-treatment.
a = This recommended water quality criterion was derived from data for arsenic (III), but is applied here to total arsenic, which might imply that arsenic (III) and arsenic (V) are equally toxic to aquatic life and that
their toxicities are additive. In the arsenic criteria document (PDF, 74 pp., 3.2M) (USEPA, 1985), Species Mean Acute Values (SMAVs) are given for both arsenic (III) and arsenic (V) for five species and the ratios of the
SMAVs for each species range from 0.6 to 1.7. Chronic values are available for both arsenic (III) and arsenic (V) for one species; for the fathead minnow, the chronic value for arsenic (V) is 0.29 times the chronic value
for arsenic (III). No data are known to be available concerning whether the toxicities of the forms of arsenic to aquatic organisms are additive.
b – Criterion refers to the long-term irrigation for sensitive crops, refer to “Quality Criteria for Water” 1986. EPA 440/5-86-001 for further detail.
c = The derivation of this value is presented in the Red Book (EPA 440/9-76-023, July, 1976). The CCC of 20 mg/L is a minimum value except where alkalinity is naturally lower, in which case the criterion cannot be
lower than 25% of the natural level.
d = Freshwater criteria for metals are expressed in terms of the dissolved metal in the water column. See “Office of Water Policy and Technical Guidance on Interpretation and Implementation of Aquatic Life Metals
Criteria” October 1, 1993, by Martha G. Prothro, Acting Assistant Administrator for Water, available on NSCEP’s web site and 40CFR131.36(b)(1). Conversion Factors applied in the table can be found in Appendix A
to the Preamble-Conversion Factors for Dissolved Metals.
e = The freshwater criterion for this metal is expressed as a function of hardness (mg/L) in the water column. The value given here corresponds to a hardness of 100 mg/L. Criteria values for other hardness may be
calculated per the equation presented in the criteria document.
f = For cadmium the EU environmental quality standards values vary depending on the hardness of the water as specified in five class categories (Class 1: < 40 mg CaCO3/l,
Class 2: 40 to < 50 mg CaCO3/l, Class 3: 50 to < 100 mg CaCO3/l, Class 4: 100 to < 200 mg CaCO3/l and Class 5: ≥ 200 mg CaCO3/l).
g = A factor of 0.01 of the 96-hour LC50 as determined by using continuous flow with a sensitive resident species, should be employed for individual petrochemical components. Surface waters shall be virtually free
from floating non-petroleum oils of vegetable or animal origin, as well as petroleum-derived oils.
i = This value for aluminum is expressed in terms of total recoverable metal in the water column.
s = There are three major reasons why the use of the water-effect ratios might be appropriate.
t = Settleable and suspended solids should not reduce the depth of the compensation point for photosynthetic activity by more than 10 % from the seasonally established norm for aquatic life.
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1. The value of 87 µg/L is based on a toxicity test with the striped bass in water with pH = 6.5-6.6 and hardness <10 mg/L. Data in “Aluminium Water-Effect Ratio for the 3M Plant Effluent Discharge,
Middleway, West Virginia” (May, 1994) indicate that aluminium is substantially less toxic at higher pH and hardness, but the effects of pH and hardness are not well quantified at this time.
2. In tests with the brook trout at low pH and hardness, effects increased with increasing concentrations of total aluminium even though the concentration of dissolved aluminium was constant, indicating
that total recoverable is a more appropriate measurement than dissolved, at least when particulate aluminium is primarily aluminium hydroxide particles. In surface waters, however, the total recoverable
procedure might measure aluminium associated with clay particles, which might be less toxic than aluminium associated with aluminium hydroxide.
hh = This recommended water quality criterion was derived from data for inorganic mercury (II), but is applied here to total mercury. If a substantial portion of the mercury in the water column is methylmercury,
this criterion will probably be under protective. In addition, even though inorganic mercury is converted to methylmercury and methylmercury bioaccumulates to a great extent, this criterion does not account for
uptake via the food chain because sufficient data were not available when the criterion was derived.
l = The CMC = 1/[(f1/CMC1) + (f2/CMC2)] where f1 and f2 are the fractions of total selenium that are treated as selenite and selenate, respectively, and CMC1 and CMC2 are 185.9 mg/l and 12.82 mg/l, respectively.
O = When the oxygen concentration falls below 4 mg/L, Member States shall implement the provisions of Article 7(3). The competent authority must prove that this situation will have no consequences for the
balanced development of the fish population.
N = Free cyanide concentrations should not exceed 0.022 mg/L downstream of any established mixing zone.
P = Artificial pH variations with respect to the unaffected values shall not exceed ± 0.5 of a pH unit within the limits falling between 6.0 and 9.0 provided that these variations do not increase the harmfulness of other
substances present in the water.
T = In order to diminish the risk of toxicity due to the non-ionised ammonia, of oxygen consumption due to nitrification and of eutrophication, the concentration of total ammonium should not exceed the following:
≤0.2 mg/L NH4 (Guide) or ≤1 mg/L NH4 (Mandatory), in particular geographical or climatic conditions and particularly in cases of low water temperature and of reduced nitrification or where the competent water
authority can prove that there are no harmful consequences for the balanced development of the fish population, Member states may fix values higher than 1 mg/L.
9 = If Member States do not apply EQS for biota they shall introduce stricter EQS for water in order to achieve the same level of protection as the EQS for biota set out in Article 3 (2) of this Directive. They shall
notify the Commission and other Member States, through the Committee referred toin Article 21 of Directive 2000/60/EC, of the reasons and basis for using this approach, the alternative EQS for water established,
including the data and the methodology by which the alternative EQS were derived, and the categories of surface water to which they would apply.
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Table 2-6 Drinking water quality standards adopted for the Mako Gold Project
Parameter Units World Health Organisation
(WHO) - Drinking Water Guidelines (2011)
EU Directive on the water intended for
human consumption (1998)
Aluminium (Al) mg/L - 0.2i
Ammonium (NH4) mg/L - 0.5i
Antimony (Sb) mg/L 0.02 0.005
Arsenic (As) mg/L 0.01 A,T 0.01
Barium (Ba) mg/L 0.7 -
Beryllium (Be) mg/L - -
Boron (B) mg/L 2.4 1
Cadmium (Cd) mg/L 0.003 0.005
Chloride (Cl-) mg/L - 250i
Chlorine (Cl) mg/L 5 C -
Chromium - total (Cr) mg/L 0.05 P 0.05
Copper (Cu) mg/L 2 2
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Parameter Units World Health Organisation
(WHO) - Drinking Water Guidelines (2011)
EU Directive on the water intended for
human consumption (1998)
Colour TCU - Acceptable to consumers and no abnormal changei
Conductivity µS/cm - 2,500 at 20°Ci
Cyanide (CN) mg/L - 0.05
E. coli MPN**/100ml 0 0
Fluoride (F) mg/L 1.5 1.5
Iron (Fe) mg/L - 0.2i
Lead (Pb) mg/L 0.01 A,T 0.01
Manganese (Mn) mg/L - 0.05i
Mercury (Hg) mg/L 0.006 0.001
Nickel (Ni) mg/L 0.07 0.02
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Parameter Units World Health Organisation
(WHO) - Drinking Water Guidelines (2011)
EU Directive on the water intended for
human consumption (1998)
Nitrate (NO3) mg/L 50 (short term exposure) 50
Nitrite (NO2) mg/L 3 (short term exposure) 0.5
pH log units - 6.5 to 9.5i
Selenium (Se) mg/L 0.04 P 0.01
Silver (Ag) mg/L ID -
Sodium (Na) mg/L - 200i
Sulfate (SO4) mg/L - 250i
Thallium (Tl) mg/L - -
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Parameter Units World Health Organisation
(WHO) - Drinking Water Guidelines (2011)
EU Directive on the water intended for
human consumption (1998)
Total coliforms MPN**/100ml 0 0i
Total Dissolved Solids (TDS)
mg/L - -
Total organic carbon (TOC)
- - No abnormal changei
Turbidity NTU - Acceptable to consumers and no abnormal changei
Uranium (U) mg/L 0.03 P -
Zinc (Zn) mg/L - -
* Relevant criteria are shaded in blue. In general, the WHO guidelines have been shaded as these represent international standards for human
health and are applicable to developing and developed countries world-wide. Where WHO guidelines are not provided, the European Union
values have been shaded. There are no existing GRS drinking water quality guidelines.
** MPN = Most Probable Number.
ID = Insufficient data to set a guideline value based on health considerations.
A= Provisional guideline value because calculated guideline value is below achievable quantification level.
P = Provisional guideline value, as there is evidence of a hazard, but the available information on health effects is limited.
T = Provisional guideline value because calculated guideline value is below the level that can be achieved through practical treatment
methods, source protection, etc.
C = Concentrations of the substance at or below the health-based guideline value may affect the appearance, taste or odour of the water,
leading to consumer complaints.
I= Indicator values. Whereas, in the event of non-compliance with a parameter that has an indicator function, the Member State concerned
must consider whether that non-compliance poses any risk to human health; whereas it should take remedial action to restore the quality of
the water where that is necessary to protect human health.
Table 2-7 Discharge water quality standards adopted for the Mako Gold Project
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Parameter Unit
Discharge Water Guidelines GRS (2002)
Mining Discharge
Treated Sanitary Sewage Effluent
International Management Cyanide Code
General Non
Protected Protected IFC (2007)**
IFC (2007)**
ICMI (2009)
Arsenic (As) mg/L 0.3 (for loads
>3g/day) 1 0.5 0.1# - -
Biological oxygen demand (BOD5)
mg/L - 50 20 50 30 -
Cadmium (Cd)
mg/L - - - 0.05# - -
Chromium, trivalent (Cr(III))
mg/L 1 (for loads >10g/day)
1 0.5 - - -
Chromium, hexavalent
(Cr(VI)) mg/L
0.2 (for loads
>5g/day) 0.2 0.2 0.1# - -
Chemical oxygen demand
(COD)
mg/L
200 (for loads
≤100 kg/day); 100
otherwise
200 90 150 125 -
Copper (Cu) mg/L - 1 0.5 0.3# - -
Cyanide (free CN)
mg/L - - - 0.1 - 0.022c
Cyanide (WAD CN)
mg/L - - - 0.5 - 0.5
Cyanide (CN total)
mg/L 0.2 (for loads
>3g/day) 1 0.5 1 -
Faecal coliforms
MPN/ 100ml
2,000 -
Faecal streptococci
MPN/ 100ml
1,000 -
Flow m3
When the authorised daily maximum flow exceeds 1/10 of the nominal capacity of the river or if it exceeds 100m3/day, the decree also fixes a limit at the monthly average of the daily output as well as an instantaneous limiting value.
- - -
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Parameter Unit
Discharge Water Guidelines GRS (2002)
Mining Discharge
Treated Sanitary Sewage Effluent
International Management Cyanide Code
General Non
Protected Protected IFC (2007)**
IFC (2007)**
ICMI (2009)
Fluoride (F-) mg/L 25 (for
loads> 250 g/day)
100 20 - - -
Iron, total (Fe)
mg/L - - - 2.0# - -
Lead (Pb) mg/L - - - 0.2# - -
Mercury (Hg) mg/L - - - 0.002# - -
Nickel (Ni) mg/L - - - 0.5# - -
Nitrogen – total (N)
mg/L 30 (for loads
>50 kg/day) 20 10 - 10 -
Oil and grease
mg/L 15 (for loads
>150 g/day) 50 20 10 10 -
pH - 5.5 – 9.5 - - 6.0-9.0 6.0-9.0 -
Phenols mg/L 0.5 (for loads
>5 g/day) - - 0.5 - -
Phosphorus – total (P)
mg/L 10 (for loads
>15 kg/day) 10 5 - 2 -
Salmonella MPN/
5000ml 0 - - -
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Parameter Unit
Discharge Water Guidelines GRS (2002)
Mining Discharge
Treated Sanitary Sewage Effluent
International Management Cyanide Code
General Non
Protected Protected IFC (2007)**
IFC (2007)**
ICMI (2009)
Temperature (differential)
C
≤ 30C (if receiving
water body temperatur
e >30C, then a
difference
of 5C is allowed)
- - <3 degree
differential - -
Total coliforms
MPNa/100 ml
- - - - 400b -
Total suspended solids (TSS)
mg/L 50 40 30 50 50 -
Vibrio cholera
MPN/ 5000ml
0 - - -
Zinc (Zn) mg/L - - - 0.5# - -
* Relevant criteria are shaded in blue. The shaded values represent the most stringent criteria (IFC and/or GRS) for each parameter. Note that
discharge criteria apply to process wastewater, drainage (from active or closed Project areas), surface runoff from paved or unpaved areas, and
sanitary waste water (unless passing to a sewage treatment system), before it enters the receiving environment. Below a designated mixing
zone(s), ambient water quality criteria also apply (see Table 2.2). Selection of suitable mixing zone(s) will depend on the location of discharge
point(s).
** In addition to the criteria in this table, discharges to surface water should not result in contaminant concentrations in excess of local
ambient water quality criteria outside a scientifically established mixing zone. Receiving water-body use and assimilative capacity, including
the impact of outer sources of discharges to the receiving water, should be considered with respect to acceptable contaminant loadings and
effluent discharge quality as described in IFC (2007)
# Metal concentrations represent total metals.
a MPN is Most probable number.
b Not applicable to centralised, municipal, wastewater treatment systems which are included in EHS Guidelines for Water and Sanitation.
c Direct or indirect discharge of water from site should not result in a concentration of free cyanide in excess of 0.022 mg/L downstream of any
established mixing zones.
Table 2-8 Noise standards adopted for the Mako Gold Project
Receptor LAeq 1 hour dB(A)
Day-time (07:00 – 22:00) Night-time (22:00 – 07:00)
IFC/WBC EHS Guidelines – Noise Management 2007
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Table 2-9 Vibration standards adopted for the Mako Gold Project
1. Australia / NSW Department of Environment and Climate Change (2006) vibration criteria for human comfort and building damage.
Table 2-10 Airblast and blasting standards adopted for the Mako Gold Project
Residential; institutional; educational 55 45
Industrial; Commercial 70 70
Noise Pollution Standards Article R84 of Decree 2001-282
Residential; institutional; educational 60 40
Article 14 of Decree 2006-1252
Level of workers’ daily exposure to noise 85 85
Receptor Vibration Criteria (maximum Peak Particle Velocity (mm/s))1
Human Comfort Building Damage
Residential buildings during the day time 0.28 10
Residential buildings during the night time 0.20 10
Offices during the day 0.56 10
Receptor Airblast1 Ground-Vibration1
Sensitive site (more than 12 months or more than 20 blasts) 115 dB(L) for 95% of
blasts
120 dB(L) maximum –
unless agreement with
occupier that higher limit
may apply
5 mm/s for 95% blasts
10 mm/s maximum - unless
agreement with occupier that
higher limit may apply
Sensitive site (less than 12 months or less than 20 blasts) 120 dB(L) for 95% of
blasts
125 dB(L) maximum –
unless agreement with
occupier that higher limit
may apply
10 mm/s maximum - unless
agreement with occupier that
higher limit may apply
Non-sensitive site
(factory or commercial premises)
125 dB(L) maximum –
unless agreement with
occupier that higher limit
may apply
Vibrations should be kept
below specifications of
sensitive operating
equipment
25 mm/s maximum - unless
agreement with occupier that
higher limit may apply
Vibrations should be kept
below specifications of
sensitive operating
equipment
Structures (masonry, plaster, concrete, steel etc) 133 dB(L) maximum –
unless agreement with
occupier that higher limit
may apply
15 mm/s - light framed
structure at 4Hz
20 mm/s – light framed
structure at 15 Hz
50 mm/s – light framed
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1. Australian Standard AS2187.2, Explosives – Storage and use, Appendix J: Ground Vibration and Airblast Overpressure, 2006; which is based
on the US Bureau of Mines USBM RI-8507 and British Standard (vibration) BS 7385-2.
2.5 International Conventions, Treaties and Agreements
Senegal is a party to a number of international policies, conventions and agreements which have relevance to the
project and are listed in Table 2-11. The Company will develop the Mako Gold Project in accordance with these
commitments.
Table 2-11 International commitments observed by Senegal and relevant to the Mako Gold Project
Commitment Overview and Requirements Implications for Mako Gold Project
Additional Act No. 01/2000 of 14 December 2000 of UEMOA regarding the adoption of a Common Mining Policy
(Acte additionnel n°01/2000 du 14 décembre 2000 de l’UEMOA portant adoption de la politique minière commune)
Makes specific reference to the importance of environmental protection and coexistence between industrial and artisanal miners.
Project will need to consider environmental issues and social issues relating to industrial vs artisanal mining.
Regulation No. 18/2003/CM/UEMOA of 23 December 2003 regarding the UEMOA Mining Code
(Règlement n°18/2003/CM/UEMOA du 23 décembre 2003 portant code minier de l’UEMOA)
Contains requirements that mining companies carry out an EIA for exploitation, respect environmental regulations, put in a monitoring plan and develop a rehabilitation programme.
Requirement for an ESIA prior to commencement of exploitation activities, to contain monitoring plans and a rehabilitation programme.
ECOWAS Directive C/DIR.3/05/09 on the Harmonization of the Guiding Principles and Policies in the Mining Sector
Lists several requirements with regards to human rights, sustainable development and local community interests which relate to the operations of mining companies.
Activities need to consider and promote such issues as human rights, empowerment of women and community participation and consultation.
Convention on International Trade in Endangered Species (CITES)
Avoidance of trade in endangered species. No trade in endangered species to be undertaken as part of this Project.
United Nations Convention on Biological Diversity (CBD)
Identify processes and categories of activities which have or are likely to have significant adverse impacts on the conservation and sustainable use of biological diversity, and monitor their effects through sampling and other techniques.
Introduce appropriate procedures requiring environmental impact assessment of proposed projects that are likely to have significant adverse effects on biological
Pre-mining baseline study on biodiversity in areas of potential impact required as part of ESIA. ESIA needs to assess impacts and develop appropriate mitigation measures to address impacts on threatened species, with full stakeholder consultation. Also requires development of re-vegetation plan.
structure at 40 Hz
50 mm/s – reinforced
structure above 4Hz
Un-occupied structures (reinforced concrete or steel construction) n/a - use133 dB(L) 100 mm/s maximum - unless
agreement with owner that
higher limit may apply
Above-ground services (pipelines, power-lines, cables) Limit to be determined by
structural design
Limit to be determined by
structural design
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Commitment Overview and Requirements Implications for Mako Gold Project
diversity with a view to avoiding or minimizing such effects and, where appropriate, allow for public participation in such procedures.
United Nations Framework Convention on Climate Change and the Kyoto Protocol
Greenhouse gas (GHG) emissions from mining activities (including electricity generation) should be less than 100,000 tonnes of CO2 equivalent per year if 100% heavy fuel oil is used, and approximately 66,000 tonnes of CO2 equivalent per year if natural gas is used. If the project produces more than 100,000 tonnes CO2 equivalent per year, then annual quantification and monitoring of GHG emissions would be necessary to satisfy IFC Performance Standard 3, Clauses 10 and 11.
The Project is not expected to exceed emissions of 100,000 CO2 equivalent annually.
Under the Kyoto Protocol, Senegal has no restrictions on its greenhouse gas emissions because it is a Non-Annex 1 country. It is possible for Senegal to trade in Carbon Credits with Annex 1 countries.
Convention on the Protection of World Cultural and Natural Heritage
World Cultural and Natural Heritage refers to cultural and natural heritage sites of outstanding universal value. The Convention requires countries to conserve biodiversity, sustainably use the various components of biodiversity, and share benefits arising from the use of biodiversity fairly and equitably.
Five sites have been identified in Senegal: the Island of Goree; the Djoudj Bird Sanctuary; Niokolo-Koba National Park; Island of Saint-Louis; and Stone Circles of Senegambia. The sites are protected by law and have minimum exclusion buffer zones.
The Project exploration permit area lies adjacent to Niokolo-Koba National Park. It does not fall within either the park itself or the 1 km exclusion buffer.
Convention on Protection of Wetlands of International Importance (RAMSAR Convention)
Four wetlands in Senegal are listed under the RAMSAR Convention, none of which are located within or near the Project area.
The Project is not expected to significantly affect any RAMSAR-listed wetlands.
Montreal Protocol on substances which deplete the ozone layer
The Montreal Protocol stipulates that the production and consumption of compounds that deplete ozone in the stratosphere - chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and methyl chloroform - were to be phased out by 2000 (2005 for methyl chloroform).
No substances listed on the Montreal Protocol should be used in the development of the Project.
Stockholm Convention on Persistent Organic Pollutants (POPs)
Senegal is a signatory to the Stockholm Convention, which targets the reduction in manufacture, use and by-production of 21 organic pollutants that persist and bio-accumulate in the environment.
Target species include pesticides aldrin, dieldrin and DDT, also PCDFs, PCBs, PFOS, and dioxins and furans.
Electrical components, electronics, plastics, and heat exchange fluids should not be burnt. Some flame retardants and foams contain POPs and alternatives should be sought. Use non-POP insecticides to prevent mosquitos. Disposal of all wastes to be considered as part of an effective waste management program.
United Nations Convention to Combat Desertification
Desertification is the degradation of land in arid, semi-arid and dry sub-humid areas. It is caused primarily by human activities and climatic variations.
The Convention provides criteria for developing action programmes to combat desertification, through enabling local people to reverse land degradation.
Re-vegetation will need to be undertaken as part of the rehabilitation of the site to assist in local efforts to combat desertification. Local expertise should be involved in developing and implementing the re-vegetation plan.
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Commitment Overview and Requirements Implications for Mako Gold Project
Convention Concerning Basic Aims and Standards of Social Policy (International Labour Organisation Convention)
Protection of basic rights for workers including: fair treatment, non-discrimination, equal opportunity, safe and healthy working conditions.
The Company will need to respect workers’ basic rights and provide a safe and healthy working environment, in accordance with IFC Performance Standard 2 on Labour and Working Conditions.
Convention Relating to the Status of the River Gambia / Convention Relating to the Creation of the Gambia River Basin Development Organization (OMVG)
No project which is likely to bring about serious modifications of a number of riverine characteristics, including its navigation conditions, the agricultural and industrial exploitation of the river, the sanitary state of the waters, the biological characteristics of its fauna and its flora, as well as its water level, will be implemented without the prior approval of the contracting States.
The Company will require permission from OMVG to abstract water and discharge to the Gambia River.
Bonn Convention / Convention on Migrating Species of Wild Animals (CMS)
Intergovernmental treaty that aims to conserve terrestrial, aquatic and avian migratory species, their habitats and migration routes throughout their range, especially relating to endangered migratory species.
Government of Senegal has signed a Memorandum of Understanding under this convention covering the African Elephant, which encourages signatories to ‘Take steps to conserve and, when and where appropriate, to strictly protect the African Elephant and to conserve and sustainably use the habitats essential for its survival.
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3 ESMMP FRAMEWORK
3.1 Purpose of the ESMMP
The ESMMP brings together into a single document the Company’s legal obligations and other requirements
associated with the Mako Gold Project with the environmental and social commitments specified in the ESIA for
inclusion in the suite of management measures and monitoring programmes to be implemented during the
construction and operations phases.
To assist with the effective implementation of the ESMMP for this Project, the Company will adopt a formal
Environmental Management System (EMS) which is consistent with GRS legislation and aligned with the following
guidelines and international standards:
OHSAS 18001 Occupational health and safety management systems;
ISO 14001 Environmental management systems;
ISO 26000 Guidance on social responsibility;
IFC Performance Standards; and
Global Reporting Initiative Sustainability Reporting Guidelines.
This management system provides the Company with a procedural framework for implementing, achieving,
reviewing and maintaining the Company’s environmental and community policies and all environmental and social
management targets. This function of the ESMMP is represented schematically in Figure 3-1.
Targets set in this ESMMP will be used to guide the implementation of environmental and social management and
monitoring programmes until the next revision of the ESMMP, and facilitate continuous improvement in
environmental and social management. The targets are expected to be updated following public disclosure of the
Draft ESIA based on regulator and stakeholder feedback, and as required when a significant change arises or
following annual or biennial updates of the ESMMP.
The Company will ultimately be responsible for implementing the Project ESMMP throughout the life of Project,
and will ensure that contractors engaged during the course of the Project comply with this document for their
works (e.g. include contractual provisions for Contractors to have an appropriate EMS in place prior to CEMP
preparation).
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Figure 3-1 Schematic diagram of the ESMMP framework
3.2 Responsibilities and Human Resources
Implementation of the ESMMP will require appropriate staff, financial resources, equipment and support systems.
It is the responsibility of all the Company staff and contractors to comply with the requirements set out in the
ESMMP. The responsibility of Project contractors and suppliers will be defined through standard terms and
conditions of contracts that are consistent with the commitments of the ESMMP.
The key roles, responsibilities and other requirements for the implementation of the Project ESMMP are outlined
below.
3.2.1 Responsibilities - Internal Parties
The Company is responsible for setting up a suitably experienced and qualified team to implement ESMMP
responsibilities for the Project. The Occupational Health, Safety, and Environment (OHS&E) Manager, supported
by a team of environment and social advisors, will have the following responsibilities:
Complying with legal obligations and ESIA commitments by establishing and maintaining appropriate
management and monitoring systems;
Sustainability Policy
Planning
Management Review
Implementation and Operation
Checking and Corrective Action
Environmental Management System
Environmental and Social Management and Monitoring Plan
Updated regularly
Internal and External Auditing
Annual Sustainability Reports
Standard Operating Procedures (SOPs): - General SOPs - Emergency Preparedness and Response Plans - Monitoring Procedures - Rehabilitation Procedures
Environment and Social Performance Framework
Environmental and Social Impact Assessment
Rehabilitation and
Mine Closure Plan
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Ensuring the environmental and social management and monitoring described in the ESMMP are
implemented effectively;
Ensuring management measures and commitments contained in the ESMMP are included in Contractor
Contracts (as relevant) and that contractors fulfil their contractual environmental and social obligations;
Reviewing and approving the Construction Environmental Management Plan (CEMP) to ensure it is
adequate, complies with the ESMMP and any mining licence conditions, and up-to-date with any changes
in Project scope, legislation, or policies;
Proactively engaging and liaising with relevant Government Authorities, communities and other
stakeholders - including dissemination of Project updates and regular, meaningful, inclusive and
participatory consultations with affected communities;
Preparing and submitting reports regarding progress of implementation, performance of environmental
management measures and monitoring data, and relevant environmental information and data required
by regulators;
Ensuring the Company personnel and contractors receive appropriate training and awareness regarding
their environmental and social responsibilities; and
Monitoring the performance of the environmental and social management measures in the ESMMP.
Under the direction of the OHS&E Manager, the Environment Department will comprise a team of qualified
professionals responsible for the day-to-day implementation of rehab activities, compliance monitoring and the
Biodiversity Action plan. The Social Department will comprise a team of qualified professionals responsible for the
day-to-day implementation of the livelihood programme, community relations activities, and local participation
programme. Each department will be led by a coordinator who shall report to the OHS&E Manager on a daily
basis or as required for fulfilment of duties.
3.2.2 Responsibilities - External Parties
Government Authorities
The Project will require coordination with a number of institutional structures at all levels of Government. Key
responsibilities of such governmental institutional structures are summarised in Table 3-1 below.
The participation of external parties in the monitoring programme of the Project will be the subject of consultation
during Project permitting and subject to annual review thereafter. The Company will work with the existing
Regional Environmental Monitoring Committee (Comité Régional de Suivi Environnemental et Social, CRSE) to
enable GRS to conduct independent monitoring of the Project in the Kedougou Region. The CRSE will be used to
monitor current and future Company’s activity within the Kedougou Region across the construction, operations
and closure phases of the Mako Gold Project.
Plans for forest management will also be approved by the Directorate of Water, Forests, Hunting and Soil
Conservation prior to implementation.
Table 3-1 Overview of Government authorities
Relevant Authority Key responsibilities for the Mako Gold Project
Direction of Civil Protection (Direction de la
Protection Civile) (DPC)
Review of the emergency response plans, including the Plan
d’Opération Interne (POI)); and
Conduct of site audits.
Direction of Mining and Geology (Direction des
Mines et de la Géologie (DMG))
Monitoring of compliance to the Mining Code requirements; and
Participation with the CRSE to the monitoring of the ESMMP
implementation.
Direction of Environment (Direction de
l’Environnement et des Etablissements Classés
Environmental and social monitoring through:
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Relevant Authority Key responsibilities for the Mako Gold Project
(DEEC)) Validation of the ESMMP for the Project; and
Conduct of periodic monitoring site visits.
Regional Environment Service (Division Régionale
de l’Environnement et des Etablissements Classés
(DREEC))
Coordination of the environmental and social monitoring
committee; and
Conduct of periodic monitoring site visits.
Niokolo-Koba National Park Regional Service
(PNNK)
Monitoring of the implementation of management measures in the PNNK
at a local level through:
Biodiversity Action Plan; and
Relevant sections of the ESMMP.
Direction of National Parks (Direction des Parcs
Nationaux (DPN))
Monitoring of the implementation of management measures in the PNNK
at a national level.
Regional Environmental Monitoring Committee
(REMC) (Comité Régional de Suivi
Environnemental et Social (CRSE))
Monitoring of the implementation of the ESMMP of the Mako Gold
Project.
Directorate of Water, Forests, Hunting and Soil
Conservation
Approve plans for forest management.
Contractors
A CEMP will be developed in line with this ESMMP prior to construction and provide greater detail to meet
environmental and social management requirements.
In addition, the Construction Contractor(s) will:
Secure relevant permits and licences, as appropriate;
Prepare and maintain records and all required reporting data as stipulated by this ESMMP, for submission
to the Company;
Report regularly to the Company’s OHS&E Manager regarding environmental and community
performance;
Review and update the CEMP during construction if any significant changes occur; and
Ensure that all construction employees and subcontractors are fully informed of the CEMP and
understand the required measures for environmental and social compliance and performance.
3.3 Capacity Building
3.3.1 Project Capacity Building
Induction and Training
Company employees and Contractors will undertake an environmental and social induction, as appropriate for
their role and responsibilities, before commencing work. The programme will cover the following aspects:
Project legislative requirements and obligations under relevant corporate policies and commitments;
Anticipated impacts of the Project and mitigation measures to be employed;
Site layout and environmental sensitivities;
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Social sensitivities and cultural awareness;
Project operating procedures, environmental management procedures, and supporting documentation;
General health and safety aspects, including disease transmission prevention, proper hygiene and
sanitation, waste management, and the Emergency Response Plan (Plan d’Opération Interne, POI) and
Local Authority Emergency Plan (Plan Particulier d’Intervention, PPI) (to be developed);
Importance of biodiversity values and prohibition of hunting, trading or buying wildlife products or
harvesting and collecting forestry products (including timber and non-timber forest products);
Grievance management procedure; and
Incident and non-compliance reporting requirements and processes (including occupational near misses
and accidents, chemical and hydrocarbon spills, observed illegal activities such as logging or poaching,
wildlife or livestock collisions, fauna poisoning, accidental environmental release of contaminated water,
etc.).
During periodic site inspections, workers’ knowledge of general environmental, health and safety issues will be
examined to monitor enforcement and compliance with Project procedures and plans.
In addition, occupation-specific training will be implemented for applicable Company employees and contractors
to meet environmental and social commitments associated with their respective technical jobs. This training will
include:
Occupation-specific health and safety requirements, including proper handling, transporting and storing
of hazardous materials and dangerous goods as well as use of specific personal protective equipment
(PPE) and equipment;
Transport safety protocols (e.g. driver safety training, fatigue management, etc.);
Specific environmental (e.g. water quality sampling techniques) and social (e.g. household surveying)
monitoring requirements;
Standard operating procedures (SOPs) for various environmental management practices (e.g. erosion and
sediment controls, dust and noise controls, land clearance, blast management, etc.) and
operation/maintenance of specific machinery and equipment;
Stakeholder engagement and response to community complaints; and
Response to environmental incidents and emergencies, including specific environmental emergency
response procedures, first aid, fire-safety training, and cyanide specific and other chemical spill response
and clean-up procedures and neutralisation techniques.
Cross-cultural awareness will be a key consideration in the delivery of both the induction and training programme
by suitably qualified employees in a language and format understood by workers. Opportunities for ongoing
training for Company employees to improve environmental and social awareness and performance will be
provided. Records of training and competency levels will be retained in a database, including information on name
of trainer and attendees, date of training session, and the next scheduled refresher session (if applicable).
Employees who have undergone occupation-specific training will be periodically tested in relation to their
knowledge and competence skills, and will be subjected to re-training, if required. Records of examination results
and any re-training will be kept as part of the training database.
The overall environmental and social programme will be updated when required to reflect changes in the Project
scope, legislation, or other circumstances.
Recruitment
In accordance with the Company’s preferential local recruitment policy, nationals and locals employed for the
Project will be maximised as per the Local Economic Participation Plan (LEPP, Volume D).
The Company will recruit appropriately experienced and competent employees to ensure the necessary technical
knowledge and skills are available onsite to comply with environment and social requirements, objectives and
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commitments. External consultants who are suitably qualified to support site employees will be engaged where
there is a need for additional expertise.
Equipment and logistics
The Company will provide logistical and material support for the Government to undertake routine monitoring
missions of Project activities.
Refer to Chapter 17 for a preliminary list of equipment, logistics and resources required for the implementation of
the Project ESMMP.
3.3.2 External Capacity Building
Regional Environmental Monitoring Committee
The Company will support the Government of Senegal to conduct independent monitoring through the Regional
Environmental Monitoring Committee (Comité Régional de Suivi Environnemental et Social, CRSE). It is expected
that the CRSE will conduct an annual, independent audit of Project activities.
The Company proposes the following support to the CRSE:
1. Annual operating costs for the CRSE to conduct independent monitoring and compliance activities of the
Project in accordance with the approved ESMMP and ESIA;
2. Capacity building for CRSE staff employed in monitoring and compliance functions associated with
Company activities, including training and skills development;
3. Financial contributions to the CRSE in the Kedougou Region will cease once the Company no longer has
operating projects and is no longer actively undertaking mineral exploration in the Kedougou Region.
Contributions will however extend over a period of three years during the closure phase of the Mako Gold
Project. In consultation with the CRSE the Company will agree on the requirement for support and review
the support programme on an annual basis.
Capacity Building Workshops
If required, the Company will provide technically focussed workshops to assist relevant government
representatives responsible for Project regulatory compliance and monitoring to improve their core functions and
duties as necessary (e.g. in the areas of biodiversity, water resources, and community resource use).
Apprenticeship Programme
In partnership with local training and education providers, the Project will provide paid apprenticeships for local
and regional students. Apprenticeships will be based on Project skill requirements and will provide practical work
experience to students.
Plan and Budget for Capacity Building
A proposed budget for capacity building for local authorities, including the Regional Environmental Monitoring
Committee, has been proposed in Chapter 17. The final plan and budget for capacity building for the Project will be
determined in consultation with relevant agencies.
3.4 Monitoring Systems
The implementation of an appropriate monitoring strategy as part of the ESMMP is important to ensure that
existing management measures are effective, and to identify the need for improved or additional measures. The
objectives of the Project environmental and social monitoring programme are to:
Detect and analyse environmental and social trends or changes to develop an appropriate response,
where required;
Ensure relevant environmental legislation and licensing commitments of the Project are complied with;
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Measure the performance of environmental and social management measures to ensure impacts remain
at an acceptable level and there is ongoing improvement of Project’s operations; and
Provide early warning of potential impacts, determine the extent of anticipated impacts and identify any
unforeseen impacts associated with Project activities.
The environmental and social monitoring programme for the construction and operation phases includes the
following main categories of monitoring:
Construction monitoring: Routine construction monitoring including visual inspections and ‘toolbox’
meetings with Project personnel to ensure management measures are employed adequately during
construction works.
Operations monitoring: Routine operations monitoring including visual inspections, ‘toolbox’ meetings
with Project personnel. Monitoring is for operations and process control, cost control, technical efficiency
and safety reasons, as well as for environmental purposes. This will be primarily the responsibility of the
Mine and Process Department personnel.
Discharge (emission) monitoring: The monitoring of potential contaminants discharged or emitted from
the Project to the environment, measured at or near the point of discharge (e.g. discharge from sewage
treatment plant at the accommodation camp).
Ambient monitoring: The monitoring of background conditions and the receiving environments that may
be affected by Project activities. Ambient monitoring will be undertaken in upstream and downstream
surface waters, along with ambient dust and noise monitoring at nearby villages. While operational and
discharge monitoring will determine if environmentally significant releases have occurred, effects on
sensitive receptors within the receiving environment can only be determined by ambient monitoring.
Social monitoring: The monitoring of socio-economic indicators and feedback from Project affected
communities, to identify and quantify the direct and indirect impacts of the Project on the surrounding
community.
A fourth category, investigation monitoring, will also be carried out when necessary, to determine the
occurrence, nature and extent of impacts following an environmental incident (oil leakage, etc.) from the Project,
or to verify/refute third-party claims of environmental / social impact.
During the closure phase, post-closure monitoring will be undertaken to assess progress in achieving closure
completion criteria as specified in the Rehabilitation and Conceptual Mine Closure Plan (Volume E).
All relevant employees involved in monitoring activities (particularly for field monitoring) will be given appropriate
training, where required, by a competent person in the use of:
Monitoring techniques, including: use, calibration and maintenance of field monitoring equipment,
sample collection, labelling and transport;
Review and interpretation of field and laboratory monitoring results; and
Record keeping and reporting procedures, including using standard forms and databases.
Relevant environmental and social monitoring programmes summarised for each Project component are provided
in Chapters 4 – 16, respectively. These monitoring programmes will be revised as appropriate when Project
activities or conditions change significantly.
3.5 Reporting Systems
3.5.1 Data Management
The Company will establish relevant Project environmental management documentation on a web-based platform
readily accessible to employees, contractors and consultants. Key documents for inclusion are the Project ESIA
and ESMMP, associated management plans, CEMP and Standard Operating Procedures (SOPs), registers, forms,
and relevant legislation, guidelines and discharge standards.
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In addition, computer based databases will be developed and maintained by the Company to capture and analyse
Project related information collected from the environmental and social monitoring programmes, including:
Environmental management databases comprising the following information:
» Relevant legislation, regulations and guidelines for Project compliance as well as the Company’s
progress in meeting its obligations and environmental and social commitments;
» Field sampling information, including monitoring locations, description and map reference;
sampling frequency, date and time; measurement parameters and unit of measure; monitoring
results and comparison with relevant guidelines and standards; and quality assurance / quality
control information;
» Non-compliances and reported incidents/issues with corrective action required and
implementation data, and outcome of corrective actions;
» Site water balance, consumption and remaining water storage capacity;
» Waste inventory, including the quantities, locations and types of materials (e.g. hazardous
wastes and non-hazardous waste) for environmental management and rehabilitation/disposal
purposes;
» Hazardous materials and dangerous goods inventory, including type, source, quantity, storage
location and physical state of stored materials, relevant Material Safety Data Sheets (MSDS), and
transport records);
» Cultural heritage register;
» Contaminated soil and spill inventory;
» Nursery inventory, including the number and species of seedlings available for revegetation;
» Soil stockpile inventory, including location of temporary and long-term stockpiles and
approximate volume of material;
» Project workforce induction and training records.
Stakeholder management databases to document information on:
» Information obtained from Project stakeholder engagement activities;
» Contact details of Project affected people and other stakeholders;
» Logged community complaints and grievances through the Project grievance management
process;
» Outcome of investigations and agreed outcomes/actions with affected parties;
» Requests for community support and funding;
» Compensation and resettlement information for each Project affected person.
Supporting forms and templates used to capture relevant information for database recording will be prepared to
ensure data is captured consistently, accurately, and meaningfully.
3.5.2 Project Reporting Commitments
The Company commits to employing the following environmental and social reporting systems for the Mako Gold
Project:
Quarterly reporting; and
Annual reporting.
These are further discussed in the following subsections. In addition, significant results from the environmental
and social monitoring programme may be reported at weekly and monthly management meetings, where
required.
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Quarterly Reporting
The Company will prepare a quarterly operations report to summarise its environmental and social performance
and significant activities, incidents and event for that period. The report will include:
Brief presentation of the Company environmental and social management systems;
Discussion of the Company environmental and social management and monitoring programmes,
Discussion of ongoing Environmental and Social Investment Programme;
Discussion of environmental and social performance relative to commitments and guidelines against
continuous improvement targets and KPIs (with opportunities for improvement identified), non-
compliance issues and corrective actions (or lack thereof);
Progress against planned tasks and key highlights (e.g. targets achieved, preventative measures
implemented or processes changed);
Any significant incidents that have occurred including cause of incident and corrective actions; and
Results of ongoing stakeholder engagement;
A summary of water quality monitoring data; and
Any significant grievances.
Quarterly reporting will commence immediately following receipt of the Mining Concession and will continue
through construction, operations and post-closure phases. The report will be submitted to the following
Senegalese authorities on a quarterly basis:
DMG, Dakar and Kedougou;
DPN, Dakar and Kedougou;
DEEC, Dakar;
DGPRE, Dakar;
PNNK Conservateur, Kedougou; DREEC, Kedougou;
Governor, Kedougou; and
Prefect and Sub-prefect.
Annual Reporting
MEC will prepare an Annual Sustainability Report to summarise business and environmental and social
performance for each calendar year (either integrated or as a standalone report). The report will include:
Collation and evaluation of quarterly reports;
Detailed discussion of performance relative to licensing commitments with focus on:
» Longer lead indicators;
» Improvement projects; and
» Overview of significant findings of audits and facility inspections.
The Global Reporting Initiative (GRI) Sustainability Reporting Guidelines will be used to guide the preparation of
the report to the extent possible. The Annual Sustainability Report will be submitted to the Board of Directors,
made available on the company website, and sent to relevant authorities (same as for the quarterly report) as part
of the annual reporting commitments.
If required, the Project ESMMP will be updated according to the recommended improvements identified in the
Annual Sustainability Report.
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3.5.3 Incident and Project Grievances Reporting
An incident is any event that impacts on, or may potentially impact on the safety, health, environment or
community, or any activity resulting in regulatory non-compliance or breach of company policies, standards or
commitments. Project grievances include any complaints or disputes raised by local communities regarding
Project activities.
To assist with the management and reporting of environmental and community incidents, the Company will utilise
a computer-based event management system (e.g. INX InControl). These systems are designed for the efficient
and effective management and reporting of environmental and social-related incidents. The system will also allow
a reporting scheme that includes:
Description of the incident and its causes;
Risk rating of the incident;
Description of corrective and preventative actions;
Description of repairs, clean-up or other remedial measures; and
Actual or estimated costs of repair, clean-up or other remedial measures.
The following situations will constitute an incident:
Injury or property damage;
Near miss or hazard;
Cyanide and other chemical spills;
Spills of fuel or oil outside of primary containment areas greater than 50 L (environment incident);
Non-contained fires within operational areas;
Uncontrolled gas emissions;
Biodiversity incidents - e.g. uncontrolled access within exclusion zones, injured or dead animals within the
PDA; and
Community incidents - primarily related to community grievances, uncontrolled access within exclusion
zones.
Incidents will be classified according to their actual and potential safety, environmental or social impact using a
standard consequence matrix to ensure consistency. Incidents and significant near misses will be reported to the
Company’s OHS&E Manager within 24 hours of the occurrence of the incident, and presented at the first
management meeting following the incident, unless the severity of the incident (dependent on the risk ranking of
the event) requires immediate notification.
The Company will develop a comprehensive grievance management system. The system will be developed in
consultation with a multi-stakeholder forum. All logged community grievances filed will be recorded and
addressed at management meetings and summaries of grievance-related information will be prepared on a
regular basis for public disclosure.
More information on incident response procedures are provided in Section 3.7, Emergency Response.
3.6 Auditing and Facility Inspections
Regular audits of the Project ESMMP and associated management systems will be undertaken internally and
externally. The audits will assess:
Adequacy of the ESMMP and associated plans with respect to the scale and nature of anticipated impacts
and current development stage of the Project;
Workforce awareness, competence and compliance with the ESMMP and associated plans and procedures;
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Performance of managers and operators in implementing, maintaining and enforcing the ESMMP and
associated plans; and
Suitability of allocated resources, equipment and budget for implementation of the ESMMP.
All audit recommendations will be discussed with the relevant departmental managers, including the Operations
Manager, OHS&E Manager and Security Manager, where appropriate. Corrective actions will be documented and
progress towards resolution reported.
Independent external audits will be conducted during the construction phase and on an annual basis for the first
two years of operation. The frequency of subsequent operational audits will be based on the recommendations
from the initial audits. As part of the audit of the ESMMP, an independent external audit of the RCMCP (Volume E)
will also be conducted as key operational and closure milestones are reached. Changes to the RCMCP and the cost
provisions will incorporate any significant changes for the Project, and be reviewed and adjusted every three years.
These changes will be reported within the Annual Sustainability Report.
In addition, the Environment Department will undertake a site inspection of all Project facilities on a routine basis
using a visual inspection form to record observations onsite. The frequency of inspection will be informed by risk
but typically on a monthly basis. KPIs will be developed to enable environmental performance to be assessed
objectively and quantitatively across the operation.
If required, independent external audit reports will be submitted to the Ministry of Environment and Sustainable
Development (Ministère de l’Environnement et du Développement Durable) via the DEEC, as well as relevant
authorities in the Kedougou Region (including DREEC).
3.7 Emergency Preparedness and Response
3.7.1 Assessment of Risk and Priority
Where an event takes place that impacts on or may potentially impact on the environment, or triggers the specific
conditions or limitations of a license or permit to be exceeded, the event is classified as an environmental incident.
The following situations are environmental incidents which require an emergency response for the Project:
All hazardous chemical spills;
Uncontrolled release from TMF;
Breach of WSD;
All spills of fuel or oil greater than 500 litres within workshop areas and pits;
All spills of fuel or oil outside of primary containment areas greater than 500 litres;
All non-contained fires within operational areas; and
All uncontrolled gas emissions.
Emergency response to an incident prioritises actions undertaken according to the following sequence:
1. Protection and rescue of human life;
2. Minimisation of the area impacted by the incident;
3. Protection of the environment and property;
4. Rendering the area safe in which the emergency has occurred;
5. Restoration of all disrupted services; and
Decontamination and rehabilitation of the incident scene and surrounding area (if applicable).The Company will
undertake routine environmental and social risk assessments on a regular basis to review potential emergency
situations that may arise from the Project. The methodology to be used for the periodic risk assessments will be
consistent with that outlined in the ESIA and below.
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Depending upon the severity of an environmental incident, emergency response may also involve using or
notifying external agencies and groups, including the police, ambulances and medical clinics, government
authorities, and nominated representatives within the local community.
3.7.2 Emergency Preparedness and Response Planning
A Risk Assessment established for the Mako Gold Project based on the guidelines of the ‘Risk Assessment Guide’
published by DEEC (2007) is presented in Volume B of the ESIA. The Project risk assessment will be reviewed on an
annual basis to identify potential environmental emergency situations that may arise.
The risk assessment will form the basis for the preparation of Emergency Preparedness and Response Plans.
Project specific plans will be developed prior to construction and updated prior to the start of operations and will
include a POI in line with Senegalese guidelines and a Cyanide Spill Contingency Plan, and appropriate spill
prevention and response procedures in line with industry best practice, IFC General EHS Guidelines, and the ICMI
Cyanide Code. Key elements of the EPRP will include:
Emergency response procedures:
» Informing the public and emergency response agencies;
» Taking emergency response actions; and
» Reviewing and updating the emergency response plans to reflect changes, and ensuring that employees
are informed of such changes.
Communication procedure;
Functions and responsibilities;
Evacuation and shutdown procedures;
Risk management;
Emergency response equipment – procedures should be prepared for using, inspecting, testing and
maintaining the emergency response equipment; and
Emergency Response Training – employees and contractors should be trained on emergency response
procedures.
3.7.3 Spill management
Spills may pose environmental risk depending on the chemical constituents of the spill, the size of the spill and the
location of the spill. Spill management broadly covers the management of a range of liquids including fuel, oil,
process water, wastewater and chemical reagents. Spill ratings definitions fall within the following categories:
Contained within primary protection system (i.e. spills contained within first bund);
Contained within secondary protection area (i.e. spills contained by second bund or drainage control);
Contained within operational area (i.e. spills that occur away from fixed spill containment structures such as
bunds but within the operational area. Examples include the haul road and pit);
Contained within non-operational area (i.e. spills that occur away from fixed spill containment structures
such as bunds but not within the normal operational areas);
Off-site spill (i.e. spills that originate from activities not within the Project area. Example includes container
transport to site); and
Non-compliance discharge (i.e. all spills that originate from within the Project Area and escape this area.
Examples include spills that affect the river environment or flow down creeks beyond the Project Area).
Response to spills will be further specified in the Emergency Preparedness and Response Plans for the Project (to be
developed).
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3.8 Continuous Improvement
Continuous improvement of various management systems in place will be an ongoing effort to ensure the Project
is implemented appropriately and effectively. These efforts can seek ‘incremental’ improvement over time or
‘breakthrough’ improvement all at once.
Continuous improvement of social, environment, and health, safety and security matters associated with the
Project will be managed by the Company’s Environment Department and be based the ‘Plan-Do-Check-Act’ model
(Figure 3-2). The model broadly follows an iterative process for continuous improvement as follows:
Plan: Identify an opportunity and plan for change.
Do: Implement the change on a small scale.
Check: Use data to analyse the results of the change and determine whether it made a difference.
Act: If the change was successful, implement it on a wider scale and continuously assess your results. If the
change did not work, begin the cycle again.
Figure 3-2 Plan-do-check-act cycle
The Environment Department will develop a continual improvement plan which lists identified information gaps
and non-conformances as well as recommended improvement actions including estimated timing and cost for trial
and implementation. Each item will be prioritised according to their level of risk rating and assigned to a
responsible person for implementing and reviewing corrective actions within an agreed timeframe. Key
performance indicators (KPIs) will be developed following the SMART principles of continual improvement plans,
which are “Specific, Measurable, Achievable, Realistic and Timely”. KPIs will be reviewed and adapted as the
Project progresses.
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4 PROJECT DEVELOPMENT AREA
4.1 Objectives
The Company has developed a ‘Project Development Area’ (PDA) for the Mako Gold Project (refer to Figure 1-1)
covering approximately 541 ha of the 7,700 ha proposed Mako Mining Concession, to protect the health and safety
of communities and Project personnel and to minimise the area of potential environmental and social impacts.
The Company, with the assistance of applicable government authorities, will restrict non-Project related building
within the PDA and will restrict access during various activities that are considered hazardous to those in proximity
to the work (i.e. blasting).
4.2 Context
The PDA is a community health and safety initiative to avoid serious hazards (e.g. flyrock) and to minimise
nuisance level impacts (e.g. noise, dust, vibration, etc.). The Company, via stakeholder consultation with
applicable government authorities and communities, will restrict access to buffer areas around Project facilities
(Figure 1-1) during construction, operations, and decommissioning to minimise potential health and safety risks.
Government enforcement of the PDA will increase the area of Project-associated temporary impacts via access
restriction but will not increase the area of physical impacts from Project implementation.
Physical impacts for the Project Footprint (i.e. Project components) and management, mitigation, monitoring and
reporting for those impacts are discussed below in subsequent sections. This section considers the potential
effects of PDA establishment and management required to mitigate the potential impacts.
The general public will not be able to enter the PDA for safety and security reasons. Additional PDA access
restriction areas will include:
Flyrock Safety Exclusion Zone: Minimum 500 m exclusion zone around the perimeter of the Mine Pit,
which encompasses the majority of Project components (i.e. Badalla Valley components).
Accommodation Camp Restriction Zone: Minimum 50 m restriction zone around the perimeter of the
accommodation camp. Community structures (e.g. food and general goods stalls) will be prohibited from
establishment within this boundary.
Project component buffer zones: Project components that exist outside of the PDA (e.g. Water Storage
Dam) will have 30 m exclusion zones whereby installation of community structures will be prohibited.
Access Road buffer zones: Roads constructed for the Project will have a 30 m exclusion zone, whereby
installation of community structures will be prohibited during construction and operations.
4.2.1 Pre-construction and Construction Phase
The PDA area will be greatest during pre-construction and construction, as blasting activities will occur in
association with road construction (as opposed to only the Mine Pit during operations). PDA enforcement during
this phase may impact communities by restricting or prohibiting access to:
Agricultural lands and livestock grazing areas;
Artisanal mining areas; and
Areas currently utilised for timber collection and non-timber forest product (NTFP).
4.2.2 Operations Phase
The PDA area will remain the same throughout Project operations as blasting will be confined to the Mine Pit.
Potential impacts will be the same as for construction, whereby community access to agricultural areas, livestock
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grazing areas, artisanal mining areas, timber and NTFP collection, and current hunting / fishing sites may be
prohibited.
4.2.3 Decommissioning and Closure Phase
The PDA will be eliminated following Project decommissioning and will not be enforced following Project closure.
Former community agricultural areas, livestock grazing areas, artisanal mining areas etc., will be returned to
previous landholders, although it may not be feasible to use certain areas for livelihood purposes (e.g. WRD site).
4.3 Management and Mitigation Measures
The Project layout has been designed to minimise permanent impacts on settlement areas and existing
agricultural land and the PDA minimised to the extent practicable to provide for safety of local residents and the
workforce. In addition, the Company has committed to implementing the following mitigation and management
measures to minimise the impact of the PDA on land users:
The Company will undertake a comprehensive land and asset survey after finalising infrastructure sites, and
identify the ownership of any productive land that will be temporarily or permanently lost to the Project
PDA at the household level;
Land for inclusion in the PDA will be clearly defined and marked to avoid unnecessary exclusion;
The Company will compensate for any productive land and community land assets that will be temporarily
or permanently lost to the PDA (refer to the Livelihood Restoration Plan, Appendix D);
The Company will provide appropriate compensation for any loss of access to productive land and will
ensure continued access to productive areas located outside the PDA. Where practical, alternative access
routes will be provided; and
The Company will undertake regular public consultation to ensure the effectiveness of management and
mitigation strategies.
4.3.1 Pre-construction and Construction Phase
Fly Rock Exclusion from Blasting
The PDA will be developed to ensure health and safety of local residents and the Project workforce from blasting
during construction by ensuring a 500 m exclusion zone (minimum) is enforced from blasting activities. This will
require careful consideration during construction as blasting sites will vary according to Project need. Blasting will
potentially be required along various locations for the construction of the Main Access Road.
The Company will develop a Blast Management Plan that will incorporate the following (at a minimum):
Methods for denying access to the 500 m radius exclusion zone (e.g. manning road access points,
conducting surveys to ensure people are outside of the PDA, etc.);
Blasting conducted a specified times during the day (during daylight hours), with at least 24 hour notice
given to local villages;
Blast times and locations will be posted on boards in local villages;
Flyrock to be visually monitored to confirm that the exclusion zone is sufficient to protect sensitive
receptors (biological and social);
Engaging a blast contractor with relevant expertise and experience; and
Training Project staff on fly rock safety and conduct a public education programme regarding community
safety issues associated with blasting.
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Compensation for inaccessible lands
The Company has developed a LRP (Appendix D) that includes restoration measures for land / activities lost or
disrupted via development of the PDA. This is discussed in Chapter 12.
Community Infrastructure Development
Development of community infrastructure within 50 m of Project components and 30 m of Project road
infrastructure will be prohibited to reduce the likelihood for damage to village structures in proximity to
construction.
Access
The Company will ensure continued access to resources outside of the PDA through staged upgrades to road
infrastructure that do not prohibit access to areas outside the PDA.
Grievance Mechanism
The Project Grievance Mechanism will provide for continued stakeholder consultation, allowing local residents to
voice concerns regarding losses of access via PDA development during construction and appropriate
compensation, if necessary.
4.3.2 Operations Phase
The PDA will be more clearly defined during Project operations as blasting will be limited to the Mako Pit (Figure 1-
1). Mitigation measures employed for the PDA will be the same as for construction, including:
Enforcement of the fly rock exclusion zone for blasting in the Mine Pit (and all associated measures listed
above and provided in the Blast Management Plan);
Existing access roads / paths to resources outside of the PDA will be ensured; and
Stakeholder consultation will continue throughout operations, with the Grievance Mechanism provided to
ensure adequate response to community complaints / issues.
4.3.3 Decommissioning and Closure Phase
Stakeholder consultation will continue during decommissioning and post-closure to ensure that areas within the
PDA that were temporarily restricted from utilisation are restored, where feasible, to provide a similar value to the
community as per before PDA implementation.
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4.4 Monitoring Measures
Table 4-1 presents key monitoring measures related to the PDA. These will be incorporated into the detailed
monitoring programs prepared by the Company and its contractors for all phases of the Mako Gold Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and in the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 4-1 Register of Environmental Monitoring Measures – Project Development Area
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Fly Rock
Blast exclusion zone Construction,
Operations
Visual
observation for
unauthorised
people within
the PDA
Project
compliance
Zero incident
record for
blasts
Prior to each
blasting
event
Within 500 m of
any blast area
At key access
points (roads /
paths) near blast
sites
Communication and
notification
Construction,
Operations
Community
consultation
Grievance
register
Logged
complaints and
concerns
As required /
ongoing
Surrounding
communities
Blast
impact
Routine monitoring
of noise, airblast,
and ground vibration
impacts
Refer to SOP08: Blast Management (Appendix A) and Tables 2-8 to 2-10 for applicable
blast criteria.
Air Quality Air quality discharge
monitoring
Refer to SOP04: Emission and Dust Control (Appendix A), Table 2-4 for applicable air
quality criteria (Section 2.4), and Figure A1 (Appendix C) for monitoring sites.
Noise Noise emission
monitoring
Refer to SOP05: Noise and Vibration Management (Appendix A), Table 2-4 for applicable
noise criteria (Section 2.4), and Figure A1 (Appendix C) for monitoring sites.
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5 OPEN PIT, MINING AND WASTE ROCK
5.1 Objectives
Key management objectives associated with the Mako Gold Project open pit, mining and waste rock disposal
include:
Design, construction and operation of the Mine Pit, Ore Stockpiles and WRD facilities to ensure adequate
operational safety and compliance with relevant legislative requirements and environmental / social
commitments;
Provision of appropriate measures to manage or mitigate potential environmental and social impacts from
mining, ore stockpiling and waste rock disposal activities over the Project life; and
Development and implementation of an appropriate mine closure and rehabilitation plan that successfully
meets environmental and social permitting requirements, regulatory requirements, and is in-line with
community expectations.
5.2 Context
Anticipated environmental and social impacts from the mine site will vary according to the stage of mine
development. Site preparation for the Mine Pit and ancillary facilities will require land clearing and earthmoving
during construction and ongoing development of the open pit, pit void and WRD throughout the operations phase.
As such, the majority of potential impacts will occur during the operations phase. Mine closure and rehabilitation
may also pose a number of significant issues if not appropriately managed.
Key environmental and social sensitivities in proximity to the mining and waste rock disposal operation include: (i)
the protected PNNK (located approximately 2 km west of the Pit); (ii) local populations of IUCN listed species
found within and around the PDA including the West African chimpanzee (Pan troglodytes, Endangered); (iii) local
residential areas within 5 km of the PDA (in particular Tambanoumouya and Linguekoto); (iv) and downstream
water resources and aquatic habitat including Badalla Creek and the Gambia River.
Chapters 9-12 of the ESIA (Volume A) provide a detailed discussion of the potential impacts from open pit, mining
and waste rock disposal during all phases of the Project. The primary issues and impacts are summarised below.
5.2.1 Pre-construction and Construction Phase
Site preparation activities for the Mine Pit and WRD will require significant land clearance, earthworks, and soil
stockpiling for subsequent reuse in revegetation efforts (e.g. topsoil) and fill material (e.g. rock, subsoil) for various
Project components (e.g. TMF and WSD dam material, road fill, etc.), depending on suitability following detailed
geotechnical investigations. The primary direct impacts will include:
Petowal Mine Pit: The 35.4 ha Pit surface will be stripped of topsoil, where feasible. It is anticipated that
subsoil will also be excavated and transported for construction fill.
Waste Rock Dump: Topsoil will be stripped from the 77.3 ha WRD footprint, where feasible, to a maximum
depth of 0.5 m, permanently impacting the landform and temporarily impacting the site’s ability to support
native vegetation. In some areas it may not be feasible to clear vegetation or topsoil in advance of rock
disposal.
Potential indirect impacts may include:
Removal of approximately 113 ha of natural vegetation and habitat for terrestrial species (refer to Chapter
10 of the ESIA, Volume A);
Erosion and sedimentation associated with disturbed surfaces (refer to Chapter 9 of the ESIA, Volume A);
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Hydrocarbon spillage (refer to Chapter 9 of the ESIA, Volume A);
Soil compaction and erosion (refer to Chapter 9 of the ESIA, Volume A);
Particulate matter (dust) and vehicle exhaust emissions (refer to Chapter 9 of the ESIA, Volume A);
Noise (refer to Chapter 9 of the ESIA, Volume A);
Vibration (refer to Chapter 9 of the ESIA, Volume A); and
Hydrology (refer to Chapter 9 of the ESIA, Volume A).
During construction, surface water from seasonal streams will be diverted around the open pit and WRD footprints
at the onset of site preparations. Impacts are not expected to be significant as surface water will remain within the
Badalla catchment, discharging to Badalla Creek prior to its confluence with the Gambia River.
Potential Air Quality and Noise Issues for Mine Workers
Impacts to workers are expected to be negligible with the implementation of best practice dust and noise control
measures. Worker health and safety will be specifically addressed in the next phase of the Project as part of the
CEMP. Additionally, the Company will prepare an Occupational Health and Safety Plan prior to Project Operations,
which will identify appropriate controls to ensure the health and safety of its workforce during operations (refer
Vol B Hazard Assessment, Section 7).
5.2.2 Operations Phase
Open-pit mining
Development of the Mine Pit will permanently impact 35.4 ha of surface land. A portion of the ridge encompassing
the boundary of the Badalla and Kelendourou catchments will progressively be converted to a pit throughout
operations. Approximately 88.6 Mt of material will be excavated and transported to the ROM Pad / Process Plant,
Ore Stockpile, or WRD during development of the pit.
Excavation of the Petowal deposit may create geotechnical and geochemical instability during operations,
providing the potential for landslips and acid and metalliferous drainage (AMD) / neutral and metalliferous
drainage (NMD) generation and / or sulfate salinity generation within the Mine Pit. Geochemical testwork
conducted for wall rock indicates a very low probability of AMD generation, NMD generation, and sulfate salinity
generation (refer to ESIA Chapter 9).
Potential impacts of the Mine Pit development may include:
Surface and groundwater quality impacts from contaminated mine wastewater containing suspended
sediment, saline water, oils and grease, AMD / NMD, and nutrients (from blast residues) with associated
indirect impacts on downstream biological and community receptors;
Minor air quality impacts, including generation of particulate matter (dust) and diesel fuel combustion
emissions (e.g. SOx, NOx, etc.) potentially affecting local sensitive receptors (e.g. local communities and
PNNK), particularly during the dry season and ‘Harmattan’ wind conditions;
Safety hazards for local communities and the workforce from flyrock (the propulsion of material potentially
resulting from blasting activities); and
Noise and vibration (airblast) impacts from blasting and operating heavy equipment that may exceed
international criteria for noise, creating an intermittent nuisance for local residents in Tambanoumouya,
Linguekoto, Wassadou, Dalakoy and Kerekonko and employees in the Accommodation Camp; as well as
local livestock and terrestrial fauna found in and near the PNNK, particularly in the wet season.
Waste Rock Dump
During operations, approximately 74.6 Mt of waste material/rock will be gradually moved from the Mine Pit to the
WRD, permanently altering the landform. The morphology of a significant portion of the Badalla Creek Valley will
also progressively be transformed to a higher elevation landform throughout this phase.
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Deposition of waste rock on the WRD may create geotechnical and geochemical instability during operations,
providing the potential for landslips and AMD / NMD and / or sulfate salinity generation that has the potential to
impact downstream / down gradient surface or groundwater. Geochemical testwork conducted for waste rock
indicates a low probability of AMD generation, NMD generation, and sulfate salinity generation.
Potential impacts from waste rock disposal may include:
Erosion of the landform and suspended sediment transport to local receiving waters (i.e. Badalla Creek and
the Gambia River);
The introduction of hydrocarbons to receiving surface and groundwater from accidental spillage; and
Spread of invasive plant species to the disturbed land surface.
Ore Stockpile
Ore (in excess of that which can be processed immediately) will be stockpiled during operations in the western
footprint of the WRD (refer to Figure 1-1). Waste rock will initially be placed in this area and then lower grade ore
will be progressively stockpiled on the waste rock layer. Construction of the stockpiling area will require clearing
and grubbing, stripping of topsoil, and construction of cut-off drains, temporarily altering the landform for
approximately 6.31 ha of surface land.
The potential geotechnical and geochemical impacts from the ore stockpile is expected be the similar to that of
the WRD and require management strategies to avoid water quality impacts and geotechnical instability.
Dust generated from the mining operation will be low in metals due to the geology of the deposit. Silica and some
fibrous minerals such as actinolite are present within the waste and ore material and may be present in dust at
levels that could potentially affect the health of workers if exposure is high.
5.2.3 Decommissioning and Closure Phase
Key environmental and social issues related to the Mine Pit, WRD, and Ore Stockpile during the decommissioning
and closure phase will be less significant with the implementation of measures detailed in the Rehabilitation and
Conceptual Mine Closure Plan (RCMCP) (Volume E).
Impacts associated with WRD decommissioning will be similar to the pre-construction and construction phase
impacts while the WRD is rehabilitated, potentially including:
Erosion and sedimentation;
Noise; and
Dust emission.
The Mine Pit will remain, and will progressively fill with ground and surface water, permanently transforming the
Wooded Savannah Bamboo mosaic vegetative community to a pit lake.
5.3 Management and Mitigation Measures
5.3.1 Pre-construction and Construction Phase
The Company has minimised the footprints for the Mine Pit, WRD and Ore Stockpile to the extent practicable to
limit the area of impact to productive land. The Company will divert surface water around the pit and WRD
footprints at the onset of site preparations, to minimise erosion and sediment transport.
The Company has developed a series of Standard Operating Procedures (Appendix A) for implementation to avoid,
minimise, or mitigate anticipated impacts associated with land clearance / topsoil removal from the Pit and WRD
footprints. The SOPs provide key management measures for adoption during all phases of the Project to address
primary issues and risks, including:
Impacts from vegetation clearance (refer to SOP09: Land Clearance and Soil Stockpiling);
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Erosion and sedimentation associated with disturbed construction surfaces (refer to SOP01: Erosion and
Sediment Control);
Surface water quality and hydrology management (refer to SOP02: Water Quality and Pollution
Management and SOP03: Hydrology and Water Management);
Potential hydrocarbon spillage and handling/storage of hazardous materials and dangerous goods (refer to
SOP07: Hazardous Materials Management); and
Air quality, noise and vibration emissions (refer to SOP04: Emission and Dust Control, and SOP05: Noise
and Vibration Management, respectively).
The Company will prepare an Occupational Health and Safety Plan prior to Project Operations, which will cover
preventative measures for potential impacts on workers from air quality and noise emissions from the Project. As
part of this plan:
Dust and noise levels on site will be routinely monitored and controlled to ensure the operation applies with
applicable standards and workers are not significantly affected by dust and noise exposure;
Occupational health and safety standards for dust and noise will be consistent with international mining
standards and Senegalese legislative requirements;
Staff will be required to wear appropriate personal protective equipment (PPE) to ensure health and safety
risks are minimised;
Training will be provided to staff regarding the use of personal protective equipment (PPE); and
Regular health checks for staff will be conducted.
The Company has developed a separate Biodiversity Action Plan (Volume C) that identifies procedures for the
protection and management of biodiversity during Project construction, operations and closure.
5.3.2 Operations Phase
The exclusion of new settlement construction within the PDA will assist in ensuring that community health and
safety and dust / noise related impacts are adequately minimised for sensitive community receptors. The
Company management and mitigation measures to avoid or minimise potential operations phase impacts are
listed below.
Land and soil management
The Company will progressively rehabilitate the WRD from the bottom up during the Operations Phase. Lifts will
be progressively contoured on the outer WRD face and will be planted with species of native provenance.
Utilisation of erosion control blankets (e.g. Jute netting) and fibre rolls may be used, allowing the WRD batter
slopes to be constructed to 20º slopes. The WRD will be designed with an overall slope angle of 20 degrees for
geotechnical stability and operational safety, and incorporate features to minimise the effect of contaminant
leaching.
Development of the Mine Pit will permanently impact 35.4 ha of surface land. Measures for land acquisition,
management and compensation / restoration are provided in Chapter 11 and described in the Livelihood
Restoration Plan (Volume D).
If the geochemical risk is found to increase during operations, a geochemistry management plan will be developed
to ensure that potential impacts associated with mine material geochemistry post-closure are minimised.
Water management
The mine will function as a ‘zero-discharge’ operation. Surface water will not discharge to receiving waters during
operations, and runoff from the Mine Pit, WRD, Ore Stockpile and TMF will be contained by the TMF embankment
(refer to ESIA, Volume A, Chapter 4). Key measures of the water management system include:
Stormwater management infrastructure has been designed to accommodate peak flows from a 100 year
rainfall event; and
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Regular inspection of surface water management features to ensure their efficacy.
Water quality and AMD management
The Company will carefully manage potentially contaminated water from within the Mine Pit and contributing
drainage areas to prevent potential impacts to sensitive receptors downstream.
While the risk for AMD and salinity generation are low, the Company will routinely sample and analyse waste rock
and ore stockpile geochemistry to manage potentially acid forming material in the WRD and Ore Stockpile (i.e. by
encapsulating the material within non-acid forming or potentially acid consuming waste rock material). Ore
stockpiled for the Process Plant will be stockpiled to minimise felsic material surface exposure. Basalt and other
rock material will be placed on the bottom and outer perimeter of the stockpile footprint, where practicable.
The Company will adopt additional surface and groundwater quality management measures for the Pit, WRD, and
Ore Stockpile throughout the operations phase (refer to Chapter 9 of the ESIA, Volume A), including:
Reuse and recycle process water to reduce the requirement for raw water abstraction from the Gambia
River;
Use of erosion and sediment control measures as detailed in SOP01: Erosion and Sediment Control;
WRD to be progressively rehabilitated during operations using contoured batter slopes, native species
planting for groundcover, and erosion control blankets (e.g. Jute netting) and fibre rolls to minimise water
quality issues at the base;
Surface runoff to be diverted around the Project site; and
Adherence to proper handling and storage of hazardous materials onsite in fully bunded, weatherproof
areas, including appropriate emergency response and spill clean-up procedures (refer to relevant measures
specified in SOP07: Hazardous Materials Management).
During Project operations a routine water quality monitoring programme will be conducted of surface, ground and
discharge water. This will include multi-element testing of samples using ICP-MS to fully characterise water
quality.
Mine safety
The Company will conduct regular inspections of the Mine Pit, WRD and Ore Stockpile for structural integrity to
ensure the potential for landslips and other geotechnical and geochemical instability issues are adequately
managed. A safety berm and signage at key locations around the Pit rim perimeter will be installed to prevent falls
into the Pit.
To reduce WRD instability risks, drainage measures will be provided to direct surface water away from the WRD, to
reduce water infiltration and to reduce the level of the phreatic surface that develops. The WRD will be
constructed from the bottom up so that the toe support is provided to the sections of WRD located on steeper and
higher ground. An additional recommendation is that during the initial mining phase a further stability
and deformation investigation analysis is undertaken to refine the WRD stability analysis.
In addition, the Company has incorporated the following safety measures and mechanisms for managing mine
blasts, in addition to those specified in SOP07.21 and 08 (Appendix A):
Provision of 24 hour security guards and restricted access safeguards (e.g. perimeter security fencing and
authorised personnel only) to provide a high level of security for the explosives magazine and Process Plant;
(refer Figure 1-1);
The explosives magazine will comprise two separate containments for the secure storage of (i) high
explosives and (ii) accessories (i.e. initiators). Each containment will be surrounded by an earth barricade;
The magazine will be located a minimum of 800 m buffer distance from human settlement, land use areas,
and/or built structures. (Distance subject to review during detailed design when the quantities of explosive
has been confirmed);
Ammonium Nitrate Fuel Oil (ANFO) will be used as a low cost and high stability blasting agent. It will be
mixed, transported and loaded into blast holes using a specialised truck;
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A 500 m blast exclusion zone (minimum) will be enforced for all blasting activities for the Project;
To ensure people are outside the blast exclusion zone, the Company will deploy methods including: sirens,
amplified verbal warnings, the posting of sentries, the closure of access roads and pre-blast surveys; and
Appropriate handling and storage of explosives (refer to SOP07: Hazardous Materials Management) and
established procedures for initiating blasts (refer to SOP08: Blasting Management, Appendix A) will be
followed by appropriately trained staff.
The Company will develop a detailed Blast Management Plan that will further specify blasting procedures, training,
auditing, PPE and other requirements. Drill and blast procedures will be designed by blasting specialists to ensure
the safety of the mine workforce and surrounding local population, the control of flyrock, noise and vibration.
Air quality management
The Company will implement the following management and mitigation measures to minimise impacts to air
quality from Mine Pit and WRD development:
Limitation of clearing to the minimum required area to reduce the potential for dust generation;
Topsoil stripping conducted at times when soil moisture can be expected to be optimal to minimise dust
formation; and
Incorporation of source control procedures provided in SOP04: Emission and Dust Control, where
applicable.
The Company has been monitoring air quality with dust deposition gauges at key locations since mid-2013. The
Company will continue monitoring dust deposition throughout construction and operations. The Company will
consult with local villages and will address potential complaints regarding dust via the Project Grievance
Mechanism.
Noise management
The Company will implement measures documented in SOP05: Noise and Vibration Management and SOP08:
Blasting Management (Appendix A) during the operations, including:
Integration of physical barriers (such as vegetation, soil banks/berms and commercially-available acoustic
shields) with site components (e.g. stockpiles and constructed buildings) to strategically act as noise
barriers for potential sensitive receptors;
Commercial acoustic shielding (typically insulator material panels) placed around noise sources and will
adopt high frequency technology for fans, ducting and electrical systems; and
Vibration-proofing and noise-reduction measures applied for various noise sources within the Mine site,
including treatment measures provided in Table 5-1.
Table 5-1 Mine equipment noise controls
Equipment source Noise treatment measures
Hydraulic excavator Reversing vehicles will be fitted with “smart alarms” rather than tonal reversing horns.
Noise control options such as exhaust and radiator silencers will be fitted to mining equipment.
Limiting the operating hours of equipment during night time
Crawler bull-dozer
Rubber-tired loader
Jaw crusher Vibration insulating base, insulation
The Company will establish a stakeholder consultation programme covering all mine related activities as well as a
Project Grievance Mechanism to record and respond to noise complaints appropriately.
In addition, the Company may consider further noise reduction and mitigation options during the mine
establishment and operations as per the Leading Practice Sustainable Development Program for the Mining Industry:
Airborne Contaminants, Noise & Vibration (Australian Government, 2009), where required, including:
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Selecting low noise options;
Providing additional silencing of fixed and mobile site and mine ventilation fans;
Installing acoustic enclosures around site;
Providing bund walls for acoustical screening;
Incorporating buffer zones and landscaped setbacks;
Reducing the maximum instantaneous charge (MIC);
Using the minimum sub-drilling possible;
Using “smart” alarms to minimise complaints regarding mine vehicle reversing alarms; and
Minimising tonal components or impulsive or intermittent characteristics of noise where possible.
Blast, air blast and vibration management
The Company will implement measures specified in SOP08: Blasting Management during the operations,
including:
Use of electronic detonation to significantly reduce vibrations caused by the blast;
No explosive charge per blast hole will exceed the estimated maximum charge weight per delay (i.e. 285
kg);
Only one charge detonated per delay and every charge will be able to break and displace its burden with
reasonable ease;
Inter-row delays that are long enough to give good progressive relief of burden; and
Detonating cord trunklines are used only to fire pre-split blasts and that these trunklines have a core load of
only 5 g/m and are covered by at least 250 mm of sand or fine screenings.
The Company will also inspect and review any reported structure damage after each blast, with immediate
investigation and follow-up control measures implemented, if required.
5.3.3 Decommissioning and Closure Phase
General management measures that will be implemented during the decommissioning and closure phase for the
Mako Gold Project include:
Access to facilities that present safety risks to be removed (e.g. Mine Pit);
All equipment and vehicles to be removed from the site;
All chemicals, fuels and oils to be removed from the PDA, and appropriately disposed;
Buildings and structures to be demolished and the rubble transported to an appropriate disposal area;
Buildings / facilities with significant residual value to the Company may be sold for dismantling, relocation
and/or recycling;
Buried pipelines cleaned, sealed and left in-situ;
Power lines and above ground pipelines removed to an approved disposal area;
Footings / foundations to be removed;
Stormwater management systems (i.e. drainage channel and sediment pond below the TMF) will be
retained until they are no longer needed;
Design and implementation of a contaminated land survey conducted to identify any such areas and
appropriate clean up measures;
Compacted areas, including roads and building footprints to ripped and graded to blend into surrounding
contours and to ensure drainage patterns are similar to pre-mining conditions;
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Engineered erosion control measures to be established where needed;
All seeding and planting to be sourced from native stock of local provenance; and
Fencing to be removed, unless retained for public and livestock safety reasons.
The Company will implement the following specific decommissioning and closure strategies for the Mine Pit and
WRD (refer to the RMCP, Volume E):
Mine Pit: Rehabilitation and revegetation of Pit margins and temporary equipment access roads. A safety
berm will be constructed around the Pit void for public safety. Targeted species may be planted on pit
benches, pending the suitability of the material to support plant life. The 35.4 ha (surface area) Pit void will
be a permanent feature in the landscape.
WRD: The WRD will be graded to contours that align with adjacent topography. Where possible, the WRD
surface will be progressively revegetated to establish a Shrub savannah and grassland vegetative
community comprised of native species of local provenance. Rock-lined drains will be constructed, where
required, to ensure excess run-off is controlled and directed down to sediment traps or to the TMF.
In addition, the following management and mitigation measures will be undertaken during decommissioning and
closure to ensure the facilities fulfil closure success criteria:
Water quality in the Pit void monitored to ensure potential discharge will meet applicable discharge
standards and Badalla Creek / Gambia River surface water will meet applicable ambient water quality
guidelines;
Surface water quality monitored at the downstream compliance points (Badalla Creek and Gambia River) to
ensure applicable discharge and ambient water quality guidelines are met;
Analysis of TMF supernatant water wi to determine whether treatment is required before establishment of
a permanent discharge channel. Suitable remedial measures, frequency of treatment, and ongoing
requirements will be determined, if post-closure treatment is required;
Monitoring of planted / seeded vegetation for successful establishment. These will be maintained where
necessary;
Rehabilitated landforms monitored for maintenance requirements, particularly with respect to erosion; and
Monitoring of biodiversity as per the Project Biodiversity Action Plan (Volume C) to assess the effectiveness
of mitigation measures for rehabilitation. Monitoring will be undertaken in both dry and wet seasons to
allow comparisons to be made between seasons over time and in key areas such as chimpanzee nesting
habitat.
5.4 Monitoring Measures
Table 5-2 presents key monitoring measures related to the open pit and waste rock management. These measures
will be incorporated into the detailed monitoring programs of contractors (as applicable) for construction,
operation and decommissioning/closure of the Mako Gold Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 5-2 Register of Environmental Monitoring Measures – Open Pit, Mining and Waste Rock
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Water
quality
Surface and
groundwater
quality
monitoring
Pre-construction,
Construction
Visual checks for
sedimentation, oils
and grease (refer
to SOP2.10)
Key parameters:
Turbidity, TSS, DO,
temperature, electrical
conductivity (EC), and
pH (refer to SOP02.9)
Threshold limits
Weekly
Discharge
points (refer
to monitoring
sites shown
in Figure A2,
Appendix C)
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
provided in Table 2-5
to Table 2-7
Operations,
Decommissioning
Refer to
SOP02.13 and
SOP02.16
Key parameters:
Cyanide (including
free cyanide, weak
acid dissociable, and
total), salinity, total and
dissolved metals (full
suite), and nutrients.
Field parameters (e.g.
pH, EC, ORP, DO,
Temp. etc.)
Threshold limits
provided in Table 2-5
to Table 2-7
Monthly for
Operations
Once-off for
Decommissi
oning
Pit sumps
and Mine
water (refer
to monitoring
sites show in
Figure A2,
Appendix C)
Blast
impact
Mine blast
monitoring
Construction,
Operations
Routine monitoring
of noise, airblast,
ground vibration,
and flyrock
impacts (refer to
SOP08.12)
Blast analysis and
audits
Noise, airblast, ground
vibration, and flyrock
parameters
Threshold limits
provided in Table 2-4
to Table 2-10
Periodic
(e.g. when
there is a
change of
blast
location)
PDA (within
500 m of pit
or other blast
areas)
Blast
exclusion
zone
Construction,
Operations
Visual observation
for unauthorised
people within the
PDA
Project compliance
Zero incident record
for blasts
Prior to
blasting
Air quality Dust
monitoring
Construction,
Operations
Visual check (refer
to SOP04.16)
Excessive dust levels
(refer to Table 2-4) Daily
Near the
Mine Pit
(refer to
monitoring
sites shown
in Figure A1,
Appendix C)
Construction,
Operations
Monitoring using
dust gauges (refer
to SOP04.16)
Dust deposition rate
(refer to Table 2-4) Monthly
Mine
safety
Monitor
structural
instability (for
possible Pit
edge
subsidence
or Pit wall
collapse)
Operations
Conduct regular
inspection of Mine
pit edge,
maintaining a
safety berm and
signage around Pit
rim.
Project compliance
Verification of security
practices
Verification of safety
controls and
inspection records
Daily Mine Pit
Biodiversit
y
Threatened
species and
habitat (e.g.
nest sites)
Refer to Chapter
16 (Biodiversity
Management) and
Biodiversity Action
Plan (Volume C).
Camera trapping
and transect
monitoring
Reportable
incidents involving
Refer to Chapter 16 (Biodiversity Management) and
Biodiversity Action Plan (Volume C) for details on
monitoring parameters, frequency and sites.
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
wildlife
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6 MINERAL PROCESSING AND TAILINGS MANAGEMENT
6.1 Objectives
Key management objectives related to minerals processing and tailings management for the Mako Gold Project
will include:
Avoiding impacts to surface and groundwater quality and associated impacts to the receiving environment
and beneficial uses of the resource;
Ensuring the Process Plant and Tailings Management Facility (TMF) are constructed for ‘no discharge’ of
surface water to the receiving environment (as designed);
Ensuring that post-closure water quality for surface and groundwater discharge from the rehabilitated TMF
is compliant with applicable guidelines, legislative and licensing requirements; and
Minimising any long-term liabilities in relation to rehabilitating the Process Plant and TMF footprints by
creating natural ecosystems post-closure.
6.2 Context
The major issues associated with the construction, operations and decommissioning/closure of the Process Plant
and the TMF for the Mako Gold Project are summarised below. Key environmental sensitivities associated with the
TMF and Process Plant include Badalla Creek and the Gambia River, and proximity to local populations of
threatened wildlife.
6.2.1 Pre-construction and Construction Phase
While the primary potential impacts from mineral processing and TMF development will occur during operations,
significant construction impacts of the Process Plant and TMF embankment include:
Water quality impacts, including erosion and sedimentation and inadvertent hydrocarbons discharge from
construction vehicles and associated impacts to the receiving environment (including downstream water
use, and aquatic / terrestrial biodiversity values);
Air quality impacts, including dust and exhaust emissions from land clearing, general construction
activities, and Project traffic potentially affecting local communities;
Noise generation and associated nuisance to local communities and terrestrial fauna; and
General and hazardous waste generation, including inert construction material, domestic rubbish, metal
scrap, empty containers or packaging for general wastes; and hydrocarbons.
The TMF embankment will be constructed to a height of 22 m during Stage 1 and will be incrementally increased to
a final height of 48 m during mine operations. Construction of the dam will initially impact 31 ha of land for the
dam footprint (increasing to 67 ha for the final TMF embankment) and will require a significant volume of suitable
engineering material (clay rich material). This material may be sourced from the Mine Pit overburden or WRD
footprint, however it may require excavation from local borrow areas which would expand the area of physical
impact for TMF construction (refer to Chapter 9, Borrow Areas and Quarries).
Construction of the Process Plant and ROM Pad will require clearing and grubbing; stripping of topsoil for post-
closure rehabilitation; and import of foundation material (e.g. sand and gravel), temporarily converting 15.84 ha
(9.27 ha for the Process Plant inclusive of the Power Station, and 6.57 ha for the ROM Pad) of Wooded Savannah
to a built environment.
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6.2.2 Operations Phase
Process Plant
A number of key hazardous substances and reagents will be stored, handled and disposed of during Project
operations (refer to Table 6-1).
Table 6-1 Overview of hazardous substances for the Project
Reagent Type Use Form of transport Estimated usage
Copper Sulphate 1.1 t bags Used in Cyanide Detoxification
Circuit.
Delivered by truck in crystal
form on pallet. 540 kg/ day
Hydrochloric Acid 1000 L isotainers
at 33% m/v
Used in washing of carbon in
acid wash tank. Minor
quantities also used in water
treatment.
Delivered by truck. 413 L/ day
Sodium Cyanide
(NaCN)
Briquettes in 1 t
bulk bags,
approximately
98% (± 1%) NaCN
Reagent for extracting gold
from the ore. NaCN will be the
main reagent used for the
Project.
Delivered by truck. 1,296 kg/day
Sodium
Hydroxide
(Caustic Soda)
Bulk 1 t bags
Elution of gold from carbon.
Minor quantities also to be
used for water treatment.
Delivered by truck as crystals. 909 kg/ day
Sodium
Metabisulphite 1.1 kg bulk bag
Used in Cyanide Detoxification
Circuit. Delivered by truck as powder. 1,917 kg/ day
Sulphuric Acid 1 m3 isotainers Standby reagents in the
Cyanide Detoxification Circuit. Delivered by truck. 413 L/ day
Gold Room
Chemicals (for
smelting)
Nitre, Biocide,
Borax, Silica, Soda
Ash, Antiscalant –
all in 25 kg bags
Used in smelting. Delivered by truck. Only minor
quantities required
Diesel
Bulk deliveries as
part of general
supply
Used by Mine, Project vehicles
and site power generation.
Stored onsite in storage tanks
and supplier operated fuel
depot.
Delivered in bulk tankers.
24,000 m3 diesel
per annum (6,000
m3 for the mine
and 18,000 m3 for
the Power Station)
Ammonium
nitrate (for
blasting)
Not available For blasting. Not available. 0.8 kg/t
The primary environmental and social risks associated with operations of the Process Plant include:
The transport, storage, handling and use of hazardous and non-hazardous materials at the Process Plant
provide a potential source for contamination of surface or groundwater within the Badalla catchment. If
released, some of these materials are significant pollutants (e.g. cyanide), posing a risk to local communities
and regional biodiversity;
Fire, explosion or other major incident in the Process Plant which could result in mortality, serious injury or
significant environmental harm to the local and regional environment;
Dust and other air pollutants (e.g. CO, CO2, SO2, O3, VOCs, Dust) from the crushing and screening area and
in stack emissions;
Stormwater runoff from the Process Plant footprint may contain elevated levels of sediment and / or
hydrocarbons;
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Elevated continuous noise above the current background levels from the 24 hour operations of the Process
Plant; and
Localised light spillage and visual amenity impacts from the Process Plant.
Additional potential impacts from Process Plant operations (e.g. localised vibration) may occur during Process
Plant operations, with associated management measures provided in Appendix A.
Tailings Management Facility
During operations, tailings discharged from the Process Plant will be transported to the TMF by pipeline and sub-
aerially discharged onto the beach from an open end pipe or spigot. The TMF is designed and will be managed so
that it will not discharge to receiving waters during operations (zero discharge Project), therefore impacts to
downstream surface waters are not anticipated.
Tailings discharged to the TMF will likely be alkaline and may contain varying concentrations of cyanide, salinity,
heavy metals (e.g. copper, arsenic, cadmium, manganese and zinc) and nutrients (breakdown products of cyanide).
The TMF reservoir water, though within ICMI guidelines for cyanide concentration, will provide a potential source
for contamination of receiving waters via seepage through the TMF embankment and / or direct migration to
groundwater / aquifers. In addition, the supernatant water may be deleterious for local birds, if utilised for
drinking water.
Consequently, during Project operations, a routine water quality monitoring programme will be conducted of
surface, ground and discharge to ensure that contaminants are not migrating to groundwater aquifers and
potentially surface waters via springs (refer to below). In addition, the geotechnical stability of the embankment
and the water volume of the reservoir will be monitored to ensure failure or overtopping of the dam wall does not
occur. The facility has been designed to avoid such an event. Nevertheless, such an event possesses the greatest
potential risk to receiving waters and associated receptors.
6.2.3 Decommissioning and Closure Phase
The TMF will have an estimated water volume of between 15,000 m3 and 1,116,000 m
3 within the supernatant
pond, depending on the timing of closure with respect to the wet season, during the final 12 months of operation
(Knight Piesold, 2015c). Upon Project decommissioning / closure, the TMF will discharge from a constructed
spillway into Badalla Creek, a first-order tributary of the Gambia River upstream from the PNNK.
If unmitigated, discharge from the TMF post closure may impact downstream surface water quality. Potential
pollutants in discharge include: cyanide, metals (particularly Cu and Mn), AMD, nutrients, saline water and
suspended sediment.
Additional impacts similar to those identified during the pre-construction and construction phase (i.e. erosion and
sedimentation, noise, dust) are likely to occur from decommissioning activities (e.g. major earthworks, operation
of heavy plant and machinery, etc.) required for demolition and removal of infrastructure rehabilitation and
restoration (planting) of the TMF and Process Plant footprints.
Refer to the Rehabilitation and Conceptual Closure Plan (Volume E) for a preliminary assessment of potential
impacts during the decommissioning and closure of the Process Plant and TMF.
6.3 Management and Mitigation Measures
The Company will manage potential environmental and social issues associated with the construction, operations
and decommissioning/closure of the Process Plant and the TMF through adoption of leading practice design,
industry best practices, and management of risks associated with mineral processing and tailings management, as
are identified in the following sub-sections.
6.3.1 Pre-construction and Construction Phase
The Process Plant and TMF footprints have been minimised to the extent practicable to limit construction impacts
to surrounding land.
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The Company will implement management measures specified in applicable SOPs (Appendix A) to manage
potential impacts that may occur for the Process Plant and TMF, including:
Vegetation clearance (refer to SOP09: Land Clearance and Soil Stockpiling);
Land erosion, compaction and sedimentation (refer to SOP01: Erosion and Sediment Control);
Hazardous materials transport, handling and disposal (refer to SOP07: Hazardous Materials Management);
General wastes (refer to SOP06: Waste Management);
Dust, noise and vibration emissions (refer to SOP04: Emission and Dust Control, and SOP05: Noise and
Vibration Management, respectively); and
Cultural heritage (refer to SOP10: Cultural Heritage Management).
In addition, additional measures to be implemented for the Process Plant and TMF throughout the Project life are
also provided in Chapter 9 (Roads and Transport), with respect to transport safety measures and protocols for
Project traffic.
6.3.2 Operations phase
Storage and handling of hazardous materials
Process Plant
As part of SOP07: Hazardous Materials Management procedure, the Company will ensure all hazardous materials
and wastes (including reagents) for the Process Plant will be transported, handled and stored in accordance with
IFC General EHS Guidelines 2007 and SOP07: Hazardous Materials Management. Additionally, the Process Plant
design has integrated a closed drainage system to contain any spills/leaks.
The Company will adopt the following provisions for hazardous materials stored and handled at the Process Plant:
Hazardous wastes in the process circuit to be reused to the extent practicable, including process water, used
carbon (which will be recovered and reactivated) and spent electrolyte required for the electrowinning
process;
Primary containment (bunding) integrated for all hazardous materials storage, handling and transfer areas
in the Process Plant (refer to below) to ensure rainwater or spillage does not discharge into the receiving
environment. Secondary containment has been designed for potential discharges outside of primary
bunding;
All pipe work and pumps to be within bunds or routed above ground to allow the early identification of any
leaks;
Steel framed reagent storage shed constructed with concrete floor, sumps and appropriate layout and
facilities to isolate, separate and handle hazardous goods;
Plant areas subject to possible contamination from chemical or slurry spills to have concrete slabs and
bunds (with 110% holding capacity) installed;
Bunded areas equipped with sump pumps to recover any spilled material or rain falling on the slabs, for
reclaim to the process;
Site run-off and spillage exceeding the capacity of the bunds that are potentially contaminated with
cyanide and reagents will report to a lined event pond with a submersible pump for reclaim to the process
circuit (contaminated spillage will ultimately report to the TMF), or discharge to the TMF;
The distance for the tailings / return pipelines to the TMF has been minimised and the pipeline will follow an
alignment that runs down a continuous downhill slope to the TMF with no ‘dead legs’ in the line requiring
drain valves and scour pits to minimise potential for leakage; and
Routine monitoring of water quality discharge from the Process Plant to be conducted (refer to below).
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Consistent with the International Cyanide Management Code and Guidelines (Cyanide Code) (ICMI 2014), the
Company will implement the following measures for cyanide management at the Process Plant:
Materials handling, containment and bunding in all plant areas to conform to the Cyanide Code (ICMI 2014)
as well as well as Senegalese legislative requirements, in particular Law No. 2001-01 of 15 January 2001 on
the Environment Code;
Cyanide storage, handling, destruction, and disposal compliant with Cyanide Code (ICMI 2014) and be
conducted in a manner that avoids potential releases to receiving waters;
Cyanide will be purchased from a member of the International Council of Chemical Associations Responsible
Care Program compliant with the Cyanide Code (ICMI, 2014);
As a minimum, two people with rigorous cyanide and emergency specific training will always be present for
cyanide unloading, storage and automated mixing (to minimise human handling, exposure and error);
Cyanide destruction methodology will ensure residual cyanide from the CIL circuit in the Process Plant will
be less than 50 parts per million (ppm);
Preparation of a specific Cyanide Spill Contingency Plan as part of the Project Emergency Preparedness and
Response Plans (to be developed); and
Monthly water quality monitoring of tailings and supernatant water for cyanide concentrations (including
breakdown products of cyanide) to ensure Cyanide Code (ICMI 2014) compliance.
Additional measures to avoid or minimise potential impacts associated with the handling and disposal of
hazardous materials and wastes are provided in SOP07: Hazardous Materials Management and SOP06: Waste
Management, respectively (Appendix A). Specific transport requirements for hazardous materials, including
cyanide transport, are detailed in Chapter 9 (Roads and Transport).
Disposal of hazardous wastes
During Project operations, the Company is committed to ensuring the safe storage and disposal of residual wastes
and process residues from the Project, consistent with international best practice. Approximately 225 tonnes per
hour of solids process tailings and 225 tonnes per hour of process water will be generated from the Process Plant.
Tailings will be disposed of in the TMF. Approximately 50% of the process water will be entrained in saturated
tailings in the TMF, while the remaining will be recovered and returned to the Process Plant for re-use.
General safety
The Company will secure the facilities with a patrolled 2.1 m high security fencing topped with razor wire and a
gatehouse at the entrance of the plant manned by security personnel to restrict unauthorised access. These areas
will be under continuous camera surveillance.
The Company will incorporate the following key safety measures for the Process Plant:
Plant design accounts for seismic events;
Adequate lightning and surge protection to be provided for the Process Plant building structures and
sensitive equipment;
Fire protection and control system for the Process Plant and Power Station that will supply fire water at the
required pressure and flowrate in the event of a fire emergency;
Fire hydrants and hose reels provided at strategic locations throughout each facility and fuel storage areas
to ensure complete coverage in areas where flammable materials are present;
Provision of backup critical plant and equipment (e.g. process water pumps, emergency diesel-powered fire
water pump) with proper safety controls in place to ensure there is sufficient redundancy in the plant
system if there is a process failure or maintenance work is required;
Safety showers provided for workers accidentally exposed to hazardous chemicals;
Maintenance of the mechanical integrity and operability of the plant process systems (e.g. relief and vent
valves, shutdown systems, pumps, containment infrastructure, pressure tanks, etc.);
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Use of fire breaks to prevent bushfire risks;
Extensive camera surveillance installed (e.g. in the gravity circuit and goldroom areas) and entry points
monitored and alarmed to provide a high level of security;
Access to the goldroom within the plant will be restricted and strictly controlled. All personnel allowed into
the area will be accompanied and monitored by security staff. Persons leaving the area will be subject to a
comprehensive search; and
Built-in emergency warning system and plant shutdown mechanisms (e.g. statutory interlocks such as
emergency stops and thermal protection to be hardwired).
For operational safety of the TMF, independent audits of the TMF will be conducted by a suitably qualified
specialist on a regular basis to ensure structural integrity of the dam facility is maintained. The Company will
continually manage the TMF to ensure sufficient freeboard to accommodate for a maximum precipitation event.
An emergency spillway will be provided in the event that rainfall exceeds the 1 in 100 year storm event (i.e. greater
than the TMF design criteria), with appropriate scouring controls integrated into the design. Discharge under these
conditions is required in order to protect the integrity of the embankments from overtopping failure.
As described in Section 3.7, Emergency Preparedness and Response Plans for the Project will be developed in the
next phase informed by the Risk Assessment (refer to Volume B). These plans will include an Emergency Response
Plan, cyanide management processes in a Cyanide Spill Contingency Plan, and appropriate spill prevention and
response procedures in line with industry best practice, IFC General EHS Guidelines, and the ICMI Cyanide Code.
Chapter 14 (Community Health and Safety) provides additional measures to manage potential impacts associated
with the construction and operation of the TMF and Process Plant.
Dust and air quality management
The Company’s air quality management measures are provided in SOP04: Emission and Dust Control (Appendix
A). In addition, the Company has included the following dust suppression and air quality design and mitigation
measures for the Process Plant:
Optimised Process Plant design that resulted in the reduction of three conveyors from the preliminary
design;
The quick lime silo fitted with a dust collector;
Coarse spillage in the crusher area to be cleaned up by front end loaders and transported to the ROM pad
for drying or fed directly to the primary crusher;
Spillage in the crushing and screening area to be cleaned up by skid-steer loader and added directly onto
the mill feed belt via the clean-up hopper;
The gravity circuit area will be fully enclosed;
Water sprays and two dust collection systems installed for dust suppression in the crushing and screening
circuit and lime addition point, where feasible;
As required, the Company will further consider containing fugitive emissions within the Process Plant to the
extent practicable by either:
» Enclosing or covering all fugitive source emissions such as the conveyors, hoppers, bins;
» Watering roads or gravel sheeting in ore-handling areas to minimise windblown and traffic generated
dust; and
» Controlling a fugitive emission source from feed ore handling by employing air extraction and treatment
through a baghouse or cyclone.
The Company will routinely monitor fugitive dust emissions at the Process Plant.
The Company will manage and mitigate potential air quality impacts from the TMF, including:
Re-using suitable material from the open pit stripping to maintain the TMF embankment wall to the extent
practicable, to minimise the need for borrow pits and quarries (and associated air quality impacts); and
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Regular water spraying of exposed tailings when excessive dust generation is evident.
Water quality management
The TMF, Process Plant / ROM Pad, Mine Pit, WRD, ore stockpiles, (and additional Project components including
the Mine Services Area) will be located in the Badalla Valley (refer to Figure 1-1) to contain potential pollution
sources within the single catchment. Surface water flowing from upstream of Project facilities will be diverted
around the Project Footprint for discharge into the TMF. Runoff from within the Process Plant and TMF areas will
drain to the TMF (in some cases via a series of event pond or sediment control facilities). Additional secondary
containment downstream of the TMF will ensure zero discharge to receiving waters outside of the PDA during
operations.
Though the TMF dam will be constructed to minimise seepage, there is the potential for a minimal amount of
seepage to occur through embankment foundations or into groundwater. To monitor this seepage and
groundwater quality in general, a number of groundwater bores will be installed both up-gradient and down-
gradient of the TMF.
Wastewater and sewage from the Process Plant ablutions and mess facilities will be treated by a water treatment
plant within the Mine Services Area to meet applicable water quality discharge standards.
During Project operations, the Company will incorporate the following water quality monitoring measures:
Monthly water quality monitoring of tailings, supernatant water and seepage water (if applicable) for key
parameters, including cyanide (including free cyanide, weak acid dissociable cyanide, and total cyanide),
salinity, dissolved and total metals, nutrients, and AMD (via drainage sump and piezometers); and
Monthly groundwater quality monitoring of the installed bores downgradient of the TMF for water level and
key parameters including cyanide (including free cyanide, weak acid dissociable cyanide, and total cyanide),
salinity, dissolved and total metals, nutrients, and AMD.
Once operations commences, this monitoring programme should be re-evaluated based upon previous results and
existing operations and environmental conditions.
Further surface water management measures associated with the TMF are detailed below.
Tailings management
The establishment of the TMF will be staged, and designed to ANCOLD and ICOLD standards. The TMF has been
designed for geotechnical and geochemical stability and will be operated as a zero discharge facility. The TMF has
sufficient stormwater capacity for all design storm events and rainfall sequences for a 1 in 100 year storm event
(particularly during the wet season), with an additional 1 m contingency freeboard. The embankment, TMF surface
and piping facilities have been engineered to minimise the potential for groundwater contamination or seepage.
In summary, the TMF will incorporate the following water quality management measures:
A soil liner with permeability less than 1 x 10-8
m/s will minimise the potential for seepage over the extent of
the basin area;
An HDPE geomembrane liner will be installed in the lower reaches of the TMF basin and on the TMF
embankment upstream face. The liner will conform to Nevada’s Water Controls for Mining Facilities
Standards (Nevada Administrative Code: NAC 445A.438). This stipulates that synthetic liners must have a
resistance to the passage of process fluids equal to a permeability coefficient of 1 x 10-11
cm/sec;
Two drainage collection systems implemented for TMF drainage:
» A Leakage Collection and Recover System (LCRS) will be placed under the HDPE liner. The LCRS water
will be collected using a sump with an inclined outlet riser pipe on the upstream face of the
embankment; and
» Tailings Underdrainage Collection System placed over the HDPE liner. The underdrainage will be spaced
at 50 m spacing on the HDPE with the spacing being reduced to 25 m if HDPE liner is not used. Similar
to the LCRS, the underdrainage will be collected via a sump and inclined riser on the upstream face of
the embankment.
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Groundwater drains constructed in the existing stream channels below the low permeability soil liner, and
above liner drains at the TMF embankment. This will reduce the pressure on the liner and reduce any
potential seepage. This underdrainage system will comprise a network of finger and collector drains;
All drainage pipes directed to a lined seepage collection pond (event pond) located downstream of the TMF
embankment for subsequent pumping of event pond water back into the TMF if required;
Seepage and supernatant water will be collected and stored in the seepage collection system to decant
prior to be recirculated back to the Process Plant. The system will operate as a pump-out decant utilising a
slotted concrete tower with a pump and pipeline on an access causeway;
Recycling of up to 80% of the TMF decant / supernatant water in the Process Plant via a return water
pipeline to supplement water sourced from the WSD. All event pond water will be pumped back to the
Process Plant or TMF;
A stormwater interception and diversion system to be installed around the TMF perimeter (with a raised
access road) to capture and divert all surface water runoff. The diversion will intercept seasonal slope runoff
from the catchment area outside of the TMF and divert it around the TMF to spillways on the east and west
abutments. At each raising of the embankment, temporary connections to the spillway will be provided;
Stormwater and sediment control structures (e.g. culverts and small sediment control ponds) will be
installed within the facility perimeter to capture and divert all site runoff into the decant system (during and
after construction of the facility);
Tailing and return water pipelines to be constructed in a lined trench (about 1 m deep) and contained to
report to the TMF in the event of a spill or leakage;
Monitoring of groundwater bores and surface water sampling stations downstream of the TMF; and
Regular inspection and maintenance of the TMF and associated pipelines (tailing and return water) in
accordance with the TMF Operation and Monitoring Manual.
Specific measures to ensure stability of the TMF dam include:
An emergency spillway provided at all times in the event that rainfall exceeds the 1 in 100 year storm event
(i.e. greater than the dam design criteria). Discharge under these conditions is required in order to protect
the integrity of the embankments from overtopping;
Dam embankment constructed with at least a slope of 2.5H:1V, with rock armouring (i.e. rip rap) provided
on the outer banks and spillway to prevent potential scouring, erosion and embankment instability;
Security fencing around the site perimeter of the TMF to limit the public and livestock from accessing the
area;
Ongoing review of the site water balance and inventory to avoid potential water overcapacity or shortages
at the Project site;
A regular inspection and maintenance schedule of TMF and WSD dam infrastructure (i.e. spillway,
embankment, pipelines, flanges, seals and pumps;
Independent audits of the TMF and WSD conducted by a suitably qualified geotechnical engineer on an
annual basis to ensure structural and operational integrity of the dam facility is maintained; and
The TMF Operating and Monitoring Manual to be finalised prior to Operations.
Acid mine drainage management
The following measures will be implemented to avoid potential for acid and metal generation during the
operations and decommissioning / closure phase:
Grading of the ROM pad towards the Badalla Valley so that surface water flows are retained onsite for reuse
in Process Plant;
Processing of only basalt ore material when approaching closure to achieve a final NAF basalt layer of
tailings (0.5 to 1 m thickness) as the final upper layer of tailings for the TMF. Consideration will be given to
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Environmental and Social Management and Monitoring Plan
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blending this tailings material with low oxygen / water permeability substrates (e.g. clay) to minimise
atmospheric oxygen infiltration into the tailings material;
Depending on the solute loads generated, an engineered passive anaerobic wetland system may be
effective in further lowering sulfate salinity and arsenic loads released from the TMF supernatant pond and
TMF seepage post-closure, if required; and
Cover the TMF with a suitable low permeability capping layer to minimise infiltration and oxygen transfer.
The Company will determine preferred method following more detailed investigation during Project
operations.
Routine monitoring of geochemistry and water quality will be conducted to ensure potential risk of acid generation
is appropriately managed.
Noise management
The Company has designed the Process Plant for enclosure in a concrete building on three sides, with the fourth
side partially open for access. The Company will implement the following additional measures to minimise noise
emitted by the Process Plant operations, as required:
Selection of the quietest plant and equipment;
Use of barriers (e.g. near vibrating screen) and other noise abatement technologies (e.g. ventilation fan size
or use of windscreens near ventilation fan);
Full acoustic enclosure of high noise emitting areas such as the crushing and grinding areas;
Sound insulation of plant and machinery engines, if required; and
Provision of noise protection PPE for workers in areas where plant equipment emits noise in excess of
80 dB(A).
Visual amenity management
The visual impacts of the Process Plant and ROM will be minimised by implementing the following measures:
Vegetation clearance restricted to the minimum extent practicable for Project construction;
Cleared areas around facilities progressively rehabilitated and revegetated to the extent practicable as soon
as respective areas are no longer required for construction / operations;
Project structures painted in muted colours in keeping with the local area and vegetation;
Construction sites to be well maintained and kept tidy;
Physical barriers such as earth/rock banks or vegetation to be considered for concealing Project
components to the extent feasible;
Where relevant, visual amenity management and mitigation measures will be incorporated into the Construction
Environmental Management Plan (CEMP).The SOP11: Lighting and Visual Amenity Management (Appendix A)
provides additional measures, where relevant.
Biodiversity management
A combination of bird-scaring techniques or measures will be employed to prevent fauna poisoning from drinking
tailings water. The Company will incorporate management, mitigation, and monitoring as detailed in the
Biodiversity Action Plan (Volume C).
6.3.3 Decommissioning and closure phase
The Company will rehabilitate and revegetate the Process Plant, ROM Pad and TMF areas according to
methodologies detailed in the RMCP (Volume E). As with all facilities that will be revegetated, rehabilitation will
be conducted to ensure closure criteria are met for the facilities (development of self-sustaining Shrub savannah
for the TMF and grassland for the Process Plant area).
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Decommissioning of the Process Plant and TMF will require careful management, mitigation, and monitoring with
respect to the following:
Surface water from the TMF (which includes runoff from the WRD and the Mine Pit) will be reconnected to
Badalla Creek and discharge from the Project Area will resume. Therefore the Company will have to ensure
water quality meets applicable discharge and ambient water quality guidelines prior to discharge; and
Soil and groundwater at the Process Plant, associated facilities, and TMF may be subjected to pollutants
during operations, with remedial actions required to meet closure criteria.
Further details for each of the facilities are specified below.
Tailings Management Facility
Upon Project decommissioning / closure, the Company will implement the following management and monitoring
measures at the TMF site to ensure closure objectives are met:
Partially cap the facility with waste rock in order to prevent seepage and engineer the surface at the top to
prevent water pooling;
Grade to a stable 1 in 100 slope and engineer the slopes to encourage sheet flow of run-off water and
prevent excessive channelling and erosion;
Rehabilitate the TMF and develop armoured drainage channels to ensure that tailings material is securely
stored (i.e. erosion resistant);
At closure, the stormwater spillway on the eastern abutment of the TMF will be converted into a
permanent to discharge channel to allow surface water to freely discharge from the surface of the
rehabilitated facility;
Sample TMF supernatant water laboratory analysis, including the full suite of dissolved and total metals,
cyanide (total cyanide, free cyanide, and WAD cyanide), salinity, pH, nutrients, etc. to determine whether
treatment is required; and
If treatment is required, consider remedial measures, frequency of treatment, and requirements for
ongoing post-closure treatment, if necessary.
As surface water from the facility will discharge into Badalla Creek, a key environmental issue related to the
closure of the TMF will be water management and potential downstream water quality impacts. As such, surface
water from this spillway will be continually monitored for compliance with relevant water quality standards and
guidelines.
In addition, the Company will monitor the success of revegetation activities to ensure that tailings material are
securely stored (i.e. erosion resistant) for an indefinite period and present no hazard to public health and safety or
the environment. Closure criteria will be established for the Final Rehabilitation and Mine Closure Plan. Examples
of measureable completion criteria that will be met for the TMF include:
On-site and downstream water quality (i.e. with respect to baseline conditions and applicable discharge
guidelines);
Revegetation success (e.g. % coverage, species diversity, % weeds); and
Geotechnical and landform stability.
Process Plant and ROM Pad
A specific Decommissioning Plan will be developed for the Process Plant and ROM Pad. The following
management and monitoring measures will be taken in relation to the decommissioning and rehabilitation of
these facilities:
The Company will implement a strategy for the disposal of processing reagents, decontamination of
equipment, removal of water from pond surfaces, reduction of cyanide concentration to a level protective
of human health and wildlife, and installation of equipment necessary for long-term protection of ground
and surface water quality during the facility’s closure period;
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At the end of operations, the Process Plant and ROM pad will be cleared to ground level. The concrete will
be broken up and rehabilitated;
All exposed soil will be re-contoured and ripped and re-vegetated to a landform consistent with the
surrounds upon mine closure to minimise potential for erosion;
A strategy for the disposal of processing reagents, decontamination of equipment, removal of water from
pond surfaces, reduction of cyanide concentration will be developed to a level protective of human health
and wildlife, and installation of equipment necessary for long-term protection of ground and surface water
quality during the Process Plant’s closure period;
Soil and groundwater testing will be undertaken to determine whether contamination has occurred with
treatment/remediation implemented if required. The faces of the ROM pad, the immediate surrounds of
the Process Plant and any exposed areas of soil within the Process Plant site will be tested for contaminants
and re-vegetated as early as possible after deconstruction (unless remediation for waste is required first);
Any concrete foundations or soil contaminated by metals, hydrocarbons or other contaminants will be
decontaminated (volatilisation) and disposed of in a lined landfill;
Treatment strategies will be further refined before commissioning of operations; and
Drainage will be redirected as necessary to minimise erosion until vegetation is established. Water in the
sediment control structures will be treated to achieve compliance with appropriate discharge standards.
6.4 Monitoring Measures
The primary monitoring measures related to the mineral processing and tailings management associated with the
Process Plant and TMF are summarised in Table 6-2. These will be incorporated into the detailed monitoring
programmes prepared by the Company and its contractors for all phases of the Mako Gold Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 6-2 Register of Environmental Monitoring Measures - Minerals Processing and Tailings Management
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Water
quality
Routine water
quality
monitoring
Pre-
construction,
Construction
Refer to SOP02.9
and SOP2.10
Key parameters:
Turbidity, TSS, DO,
temperature, electrical
conductivity (EC), and
pH
Visual checks for
sedimentation, oils and
grease
Threshold limits
provided in Table 2-5 to
Table 2-7
Weekly
Discharge
points (refer to
monitoring
sites shown in
Figure A2,
Appendix C)
Water quality
monitoring of
tailings,
supernatant
water and
seepage water
collected in the
seepage
collection
system
Operations Refer to SOP02.13
Key parameters:
Cyanide (including free
cyanide, weak acid
dissociable, and total),
salinity, total and
dissolved metals (full
suite), nutrients, and
field parameters (e.g.
pH, EC, ORP, DO, etc.)
Threshold limits
Monthly
TMF
supernatant
water,
drainage
sump, and
piezometers
(refer to
monitoring
sites shown in
Figure A2,
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
provided in Table 2-5 to
Table 2-7
Appendix C)
Groundwater
quality
monitoring via
piezometers
and concrete
monitoring
weirs
Operations Refer to SOP02.14
and SOP02.15
Key parameters:
Groundwater level,
cyanide (free, weak
acid dissociable, and
total), related
breakdown products of
cyanide (e.g. ammonia,
nitrate, thiocyanate),
salinity, nutrients, and
field parameters (e.g.
pH, EC, ORP, DO,
temp. etc.); acidity /
alkalinity, sulfate, and
dissolved metals (to be
determined by waste
rock characterisation)
Threshold limits
provided in Table 2-5 to
Table 2-7
Monthly
Groundwater
monitoring
bores down
hydraulic
gradient of the
TMF, Mine Pit
and WRD
(refer to
monitoring
sites shown in
Figure A2,
Appendix C)
Regular
inspection for
potential
leakage or
seepage of
contaminated
water
Operations
Visual check for
visible leakage or
seepage (refer to
SOP02.19(
Project compliance Monthly
Process Plant,
TMF and
associated
pipelines
(tailing and
return water)
Water
Quality
(discharge
)
Discharge
monitoring of
surface and
groundwater
quality upon
mine closure
Upon mine
closure,
Decommissio
ning
Refer to SOP02.14
and SOP02.15
Key parameters:
Cyanide (free, weak
acid dissociable, and
total), related
breakdown products of
cyanide (e.g. ammonia,
nitrate, thiocyanate),
salinity, nutrients, and
field parameters (e.g.
pH, EC, ORP, DO,
temp. etc.); acidity /
alkalinity, sulfate, and
dissolved metals (to be
determined by waste
rock characterisation)
Threshold limits
provided in Table 2-5 to
Table 2-7
Once-off
TMF
Reservoir and
down-gradient
groundwater
monitoring
bores (refer to
monitoring
sites shown in
Figure A2,
Appendix C)
Acid mine
drainage
Static geo-
chemistry
testing to
Operations,
DecommissioRefer to SOP02.17
Static geochemistry of Monthly
Tailings
samples from
the thickener
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
monitor any
potential
change in the
geochemical
risk
classification
of the tailings
material
ning tailings samples for
total sulphur, acid
neutralizing capacity,
and net acid producing
potential
Threshold limits
provided in Table 2-5 to
Table 2-7
underflow of
the TMF
Air quality
and dust
Dust
monitoring
Construction,
Operations Refer to SOP04.16
Daily visual check for
fugitive dust
Monitoring of PM10, and
PM2.5, SO2, NOx, CO
and dust deposition
rates
Threshold limits
provided in Table 2-4
Monthly
Existing dust
monitoring
point near the
Process Plant
(refer to
monitoring
sites shown in
Figure A1,
Appendix C)
Noise
Noise
monitoring
Construction,
Operations Refer to SOP 05.12
Noise levels in dB(A)
LAeq (daytime and
night-time period
Threshold limits
provided in Table 2-8
Bi-annually
Process Plant
(refer to
monitoring
sites shown in
Figure A1,
Appendix C)
Hazardou
s
materials
leakage /
spillage
Regular
inspection for
potential
leakage or
seepage of
hazardous
materials and
wastes
All Project
phases
Visual check for
visible leakage or
seepage (refer to
SOP07.28)
Project compliance Weekly
Project-wide
(including
Process Plant
and
hazardous
storage areas)
Spills
inventory
All Project
phases
Review of relevant
registers and records
maintained by the
Company (refer to
SOP07.28)
Number, type (e.g.
cyanide, hydrocarbons,
chemical, etc.) and
scale of spills (i.e.
small, large, major)
occurring at the Project
Volume of accidental
releases to the
receiving environment
(including soils and
water), if any
Actions taken for
immediate remediation
Ongoing
Hazardou
s wastes
Hazardous
waste
inventory
All Project
phases
Review of relevant
registers and records
maintained by the
Company (refer to
SOP07.28)
Volume of hazardous
waste generated by the
Project
Volume of hazardous
waste disposed of
offsite but not recycled
(e.g. no longer in
Ongoing
Project-wide
(including
Process Plant
and TMF)
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
temporary storage)
Volume of hazardous
waste recycled offsite;
Volume of
contaminated spillage
treated onsite
Trends for hazardous
waste volumes
compared to previous
years
Volume of hazardous
waste transported
across international
boundaries
TMF dam
integrity
Monitoring of
the TMF
structural
integrity
Operations
Independent audit of
dam structural
integrity by a suitably
qualified specialist for
operational safety
(refer to SOP03.13).
Project compliance
Inspection records for
geotechnical and
landform stability
Annual
TMF
Operations
Regular inspection of
dam toe, emergency
spillway,
embankment, tailings
pipelines, and
monitor the
groundwater
downstream to
inform any remedial
works required (refer
to SOP03.13 and
SOP03.14).
Project compliance
Verification of security
practices
Verification of safety
controls and inspection
records
Periodic
(e.g.
weekly)
Monitoring of
the TMF water
levels
Operations
Routine visual
inspection of the
TMF for freeboard
management to
maintain sufficient
freeboard for
operational safety
(refer to SOP03.13).
Project compliance
Verification of security
practices
Verification of safety
controls and inspection
records
Daily
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7 WATER SUPPLY
7.1 Objectives
Key Company management objectives for the Mako Gold Project water supply include:
Providing adequate raw water storage capacity to satisfy Project needs for Process Plant water
requirements and dust suppression;
Minimising site water consumption by maximising reuse of water; and
Developing a sustainable water supply programme that avoids potential downstream impacts to the
Gambia River and its tributaries in conformance with applicable discharge water quality guidelines.
7.2 Context
The WSD embankment will be constructed across the Kobokou Creek (an ephemeral creek), a Gambia River
tributary in Wayako Valley, to impound water for the reservoir. The facility will store surface water from the 56 ha
upstream catchment area and water abstracted from the Gambia River during the rainy season. Abstraction will
require pumping raw water from the Gambia River to the WSD via a floating decant barge (to prevent a shortfall
for a 1 in 100 dry year at any stage of operation). A water supply pipeline will transfer raw water from the Gambia
River to the WSD, and to the Mine Site for reticulation.
Key sensitivities related to water supply for the Mako Gold Project primarily include the aquatic environment and
downstream water users of the Gambia River and its tributaries.
7.2.1 Pre-construction and Construction Phase
Impacts from the WSD will primarily be limited to the pre-construction and construction phase, with site
preparation activities including land clearance, earthworks and excavation to establish the dam embankment and
spillway infrastructure. Construction water will be sourced, using temporary portable diesel pumps, from the
Gambia River (Coffey, 2015). Temporary water ponds will be constructed to hold water during early construction
activities. Once the WSD is completed, water will be drawn directly from the dam.
Potential construction impacts associated with the creation of the WSD include:
Removal of approximately 14.84 ha of natural vegetation and habitat for terrestrial species (refer to Chapter
10 of the ESIA, Volume A);
Altered hydrology (refer to Chapter 9 of the ESIA, Volume A);
Erosion and sediment transport from disturbed surfaces (refer to Chapter 9 of the ESIA, Volume A);
Hydrocarbon spillage (refer to Chapter 9 of the ESIA, Volume A); and
Vehicle emissions and dust generation (refer to Chapter 9 of the ESIA, Volume A).
The primary impact will be impoundment of surface water from the ephemeral stream in the WSD for operations.
7.2.2 Operations Phase
Potential impacts during operations will be minor. Standing water stored in the WSD during operations may
provide breeding grounds for waterborne vectors such as mosquitoes, and a potential drinking water source for
local wildlife. Safety hazards typically associated with dams will not be significant given the small scale of the
WSD. The WSD is not likely to support aquatic life.
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Potential impacts from Gambia River abstraction have been evaluated in the ESIA (refer to Chapter 9), and are
considered minor as abstraction will occur during the rainy season.
7.2.3 Decommissioning and Closure Phase
The Company will fully decommission the WSD prior to mine closure, and reconstruct and rehabilitate the area to a
self-sustaining natural ecosystem. The potential impacts during this phase will be similar to those in the pre-
construction and construction phase, including the potential for soil erosion, sedimentation, and potential
accidental hydrocarbon spillage.
7.3 Management and Mitigation Measures
7.3.1 Pre-construction and Construction Phase
Construction environmental management
Historical rainfall, evaporation and runoff data have been used to inform the WSD design and construction (refer
to Knight Piesold, Mako Gold Project – TSF and WSD Design Summary (2015b)). Additional measures that have
been adopted by the Company in the design and implementation of the WSD to minimise potential environmental
impacts include:
Optimised water efficiency onsite by maximising reuse and recycling of mine and process water during all
phases of the Project;
Construction footprint has been minimised to limit vegetation clearing to the extent practicable;
Dam infrastructure (including engineered embankment and spillway) has been designed to accommodate a
1 in 100 year rainfall event plus contingency freeboard;
WSD will have a 21 m high engineered embankment formed of compacted low permeability earth , and
upstream and downstream structural fill zones, to create an impervious barrier to minimise loss of the
stored water by seepage. A cut off trench will be located beneath the WSD embankment, which will be
excavated to extend through to competent low permeability foundation material (depth to be confirmed).
The cut off trench will be constructed continuously along the embankment and backfilled with low
permeability fill;
An emergency spillway provided at all times in the event that rainfall exceeds the 1 in 100 year storm event
(i.e. greater than the dam design criteria). Discharge under these conditions is required in order to protect
the integrity of the embankments from overtopping;
WSD embankment constructed with a slope of 2.5H:1V, with rock armouring (i.e. rip rap) provided on the
outer banks and spillway to prevent potential scouring, erosion and embankment instability;
Ongoing review of the site water balance and inventory to avoid potential water overcapacity or shortages
at the Project site; and
Topsoil from the disturbed area to be progressively stripped and stockpiled for use during site
rehabilitation.
During construction, the Company will implement the following SOPs to address risks and potential impacts
associated with the creation of the WSD include (refer to Appendix A):
SOP09: Land Clearance and Soil Stockpiling;
SOP01: Erosion and Sediment Control;
SOP02: Water Quality and Pollution Management;
SOP03: Hydrology and Water Management;
SOP07: Hazardous Materials Management;
SOP04: Emission and Dust Control, and
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SOP05: Noise and Vibration Management.
The Biodiversity Action Plan (Volume C) will provide biodiversity mitigation and offset measures relevant for the
WSD on a Project level.
7.3.2 Operations Phase
The Company has adopted the following management measures to minimise potential environmental impacts
during the operations of the WSD:
Regular review of site water consumption for ongoing improvements in water efficiency, reuse and
recycling strategies within the Mine site (refer to SOP03: Hydrology and Water Management, for further
details on a site water balance and inventory);
Project abstraction from the Gambia River will not exceed 3% of the instantaneous volumetric flow.
Abstraction will be limited to periods when the Gambia River discharge exceeds 5 m3/sec;
Security fencing to be provided around the site perimeter of the WSD to limit the public and livestock from
accessing the area;
Automated water level gauge sensors will detect any excessive water loss from seepage/leakage;
Discharge from the WSD will occur in a controlled manner via an engineered spillway, excavated into the
eastern abutment of the WSD embankment;
A regular inspection and maintenance schedule of the dam infrastructure to ensure sufficient freeboard for
a 1 in 100 year rainfall event is maintained to prevent overtopping of the dam wall and dam failure during
periods of high or extended rainfall;
A regular inspection and maintenance schedule of the water supply pipeline, flanges, seals and pumps.
Channels will be kept free of vegetation and physical obstructions. Sediment and debris traps around the
perimeter of the reservoir will also be maintained in order to reduce the amount of dirt in the reservoir. The
Company will engage with the community, and in particular herders, to prevent deliberate tapping of the
pipe;
Vegetation buffers may be used where necessary to help stabilise the soil and reduce evaporation rates
caused be wind and thermal exposure;
Training and awareness provided to employees and contractors regarding:
» Prevention of vector-borne diseases, including malaria transmission from mosquitoes; and
» Water efficiency, recycling and reuse strategies in place at the Mine Site.
Independent audits of the WSD to be conducted by a suitably qualified geotechnical engineer on an annual
basis to ensure structural and operational integrity of the dam facility is maintained; and
The TMF and WSD Operating and Monitoring Manual will be finalised prior to Operations.
In addition, ongoing management and monitoring of the WSD will assist to ensure water shortages are avoided
onsite, particularly in the dry season.
7.3.3 Decommissioning and Closure Phase
The RCMCP (Volume E) details the rehabilitation plan for restoring the temporarily impounded Kobokou Creek.
The WSD embankment will be breached after mine closure and the channel re-established so that the watercourse
will resume its natural flow regime post-closure. The WSD footprint will be rehabilitated with local non-invasive
plant species.
Upon decommissioning, the Company will carry out appropriate water quality testing prior to discharging the
remaining water from the WSD into the Gambia River, to ensure it meets applicable water quality discharge
standards (particularly for salinity and turbidity). Where appropriate, the Company will ensure adequate water
treatment is carried out prior to discharging into the Gambia River.
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7.4 Monitoring Measures
Table 7-1 presents the monitoring regime related to water supply for the Mako Gold Project during construction,
operation and decommissioning/closure. The Company will ensure contractors incorporate the monitoring
programme into a Construction Environmental Management Plan, where appropriate.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 7-1 Register of Environmental Monitoring Measures – Water Supply
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Water
quality
Routine water
quality
monitoring
Construction Refer to SOP02.9
and SOP2.10
Key parameters:
Turbidity, TSS, DO,
temperature, electrical
conductivity (EC), and
pH
Visual checks for
sedimentation, oils
and grease
Threshold limits
provided in Table 2-5
to Table 2-7
Weekly
Discharge points
(refer to
monitoring sites
shown in
Figures A2 and
A3, Appendix C)
Discharge
water quality
monitoring of
reservoir
Decommission
ing Refer to SOP02.14
Key parameters;
Salinity, Turbidity, TSS,
temperature, EC,
ORP, pH
Threshold limits
provided in Table 2-5
to Table 2-7
Once-off
prior to
discharge
WSD discharge
point
Water
managem
ent
Site water
balance
monitoring
Operations
Refer to SOP04.17
and SOP03.10 to
avoid potential water
shortages onsite.
Monitor rainfall,
temperature,
evaporation rates and
other relevant site
water balance
parameters (refer to
SOP03.10)
Continuousl
y
Meteorological
monitoring at
site based
existing weather
stations near the
WSD (refer to
monitoring sites
shown in Figure
A1, Appendix C)
Dam
safety and
integrity
Monitoring of
the WSD
structural
integrity and
water levels
Operations
Independent audit of
dam structural
integrity by a
suitably qualified
specialist for
operational safety
(refer to SOP03.13)
Project compliance
Inspection records for
geotechnical and
landform stability Annual
WSD
Operations
Regular visual
inspections of the
WSD reservoir
levels for sufficient
freeboard
management (refer
to SOP03.13).
Project compliance
Verification of security
practices
Verification of safety
controls and
inspection records
Daily
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Operations
Regular inspection
of dam toe,
emergency spillway,
embankment, and
water supply
pipelines to inform
any remedial works
required (refer to
SOP03.13 and
SOP03.14)
Project compliance
Verification of security
practices
Verification of safety
controls and
inspection records
Periodic
(e.g. weekly)
Air quality Dust
monitoring Construction
Visual check for
excessive dust and
Project Grievance
mechanism (refer to
SOP04.16)
Project compliance,
logged dust
complaints
Threshold limits
provided in Table 2-4
Daily
Active
construction
areas (refer to
monitoring sites
shown in Figure
A1, Appendix C)
Hydrocarb
on
leakage /
spillage
Monitoring for
potential
leakage or
seepage of
hydrocarbon
(e.g. diesel)
Construction
Visual check for
signs of leakage or
spillage and
observation of
hydrocarbon
management
effectiveness
Project compliance
with relevant
procedures, presence
of spill clean-up
materials, etc.
Daily
Active
construction
areas
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8 POWER SUPPLY
8.1 Objectives
Key management objectives related to power supply for the Mako Gold Project will include:
Provision of sufficient power supply for the Project without compromising environmental and social values;
Implementation of a power supply that minimises energy consumption / maximises efficiency; and
Design of a Project power supply to minimise potential pollutant emissions.
8.2 Context
The Company has indicated that a diesel fuelled Power Station will be constructed to supply power to the Mako
Gold Project. The Power Station will be located within the Process Plant perimeter fence and will comprise nine
1.8 MW diesel generators. It will incorporate 4 x 20 kL 'day tanks' for fuel, which will be topped up as required from
the main fuel depot. Overhead power lines of 11 kV will distribute power across the site (Coffey, 2015).
Power Station operations, construction equipment, and fuel delivery (including transportation) have the potential
to produce significant hydrocarbon combustion emissions, including carbon monoxide (CO), ozone (O3), nitrogen
oxides (NOx) and sulfur dioxide (SO2), and particulate matter (measured as PM2.5 and PM10) during Project
construction and operations. These are unlikely to affect air quality significantly in key sensitive areas such as
surrounding villages and PNNK if appropriately managed.
The impact assessment for the ESIA utilised the CALPUFF air quality model to predict dispersion of target
pollutants. All emission sources included in the simulations were treated individually with continuous, un-
mitigated emissions for each source estimated from the Australian National Pollutant Inventory (NPI) Emissions
Estimation Technique Manual for Mining v3.1 (2012) during the operational phase of the Project. According to the
detailed modelling, the Process Plant and Power Station area predicts higher particulate concentrations due to the
number of individual emission sources located in close proximity. Refer to the ESIA (Volume A, Chapter 9) for
more details. However, concentrations will fall sharply with distance.
8.2.1 Pre-construction and Construction Phase
Air emissions during construction will primarily be from construction vehicular activity, material transportation and
use of diesel powered generators. Associated emissions will contribute to existing concentrations of particulate
matter (PM10, PM2.5), sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO) and volatile organic
compounds (VOCs).
8.2.2 Operations Phase
Air pollutant emissions
Combustion emissions sources during Project operations will primarily originate from the diesel Power Station,
fuel depot, and fuel delivery (including transportation). Combustion emissions from the Power Plant will include
CO, SO2, nitrogen dioxide (NO2), and particulates (PM10 and PM2.5).
8.2.3 Decommissioning and Closure Phase
The Power Station will be dismantled and the area rehabilitated to a self-sustaining natural ecosystems (refer to
Rehabilitation and Conceptual Mine Closure Plan, Volume E). Power generation requirements as well as
decommissioning and closure activities will be similar to that of construction (i.e. diesel powered generators,
vehicles, etc.)
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8.3 Management and Mitigation Measures
The management, mitigation and monitoring measures provided in the below subsections are applicable to each
of the power supply options and may require revision following identification of the final design for the Power
Station.
8.3.1 Pre-construction and Construction Phase
The design and layout of the Power Station footprint has been minimised to limit construction impacts to
surrounding land. The Company will follow international industry practices for minimising Project related
greenhouse gas emissions. Measures will include:
Selection of Power Station generators compliant with IFC Ambient Air Guidelines (2007);
Integrate energy efficiency principles in building or facility design;
Ensure contractors comply with relevant energy conservation measures outlined in the ESMMP;
Conduct awareness training on energy conservation and greenhouse gas reduction for Project employees
and workforce; and
Establish energy conservation targets for the Project for measuring improvement in greenhouse intensity of
mining operations in accordance with good international industry practices.
The Company will also apply relevant SOPs (refer to Appendix A) to manage construction impacts of the Power
Station, including:
Vegetation clearance (refer to SOP09: Land Clearance and Soil Stockpiling);
Land erosion, compaction and sedimentation (refer to SOP01: Erosion and Sediment Control);
Hazardous materials transport, handling and disposal (refer to SOP07: Hazardous Materials Management);
General wastes (refer to SOP06: Waste Management);
Dust, noise and vibration emissions (refer to SOP04: Emission and Dust Control, and SOP05: Noise and
Vibration Management, respectively); and
Cultural heritage (refer to SOP10: Cultural Heritage Management).
8.3.2 Operations Phase
Where appropriate, SOPs in Appendix A will continue to apply during Project operations, particularly for the
management of hazardous materials transport, handling and disposal.
Air quality management
Management of source emissions from power stations include using primary (dry) methods to meet IFC Thermal
Power Plant Guidelines (2008), and secondary flue gas treatments for low grade fuels or for stringent local and
national regulations. Where appropriate, the following primary and secondary methods will be applied to the
Power Station to reduce emissions:
Use of low-sulfur/low-emission diesel fuel where available and compatible with generators;
Primary Dry Methods – where a low NOx combustion process is used in liquid fuel engines, including:
» Late fuel injection start;
» High compression ratio;
» Optimised combustion chamber;
» Optimised fuel injection rate; and
» Suppressed peak temperatures for NOx reduction.
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Secondary Methods - the IFC provides guidelines for flue gas emissions reduction techniques and
efficiencies. Most of the technologies available on the market require specific provisions for transport,
waste handling and disposal, which may prove challenging in developing countries. These include:
» Wet scrubber – Wet Flue Gas De-sulfurisation (FGD) technology e.g. wet sodium hydroxide (NaOH) in
smaller plants and wet calcium carbonate (CaCO3) in larger plants. These require additional power and
considerable water resources to operate;
» Dry scrubber – Dry Flue Gas De-sulfurisation (FGD) technology e.g.; lime powder (CaO). There are
options available for the lime to be re-used by the cement industry;
» Electrostatic Precipitator (ESP) – repetitive electrostatic pulse drops out particulates from stack flue.
The composition of the collected fly ash depends on the fuel and lubrication oil used. A sulfur trioxide
(SO3) or ammonia (NH4) mist can also be sprayed;
» Cyclone – a flue gas fan that collects particulates. Requires additional power and may lead to
swirling/stratified gas flow in system that can concentrate gas emissions;
» Fabric Filter (Baghouse) – large fabric bags that collect particulates. These require cooling below 160° C,
pressure drop and additional flue gas fans. Particulate matter can clog filters and require regular bag
maintenance, replacement and adequate environmental disposal; and
» Electron-Ammonia – a new technology where an electron beam, similar to that of a cathode ray TV,
ionises an ammonia mist to react flue gas SO2 to form ammonium sulfate.
Selective catalytic reduction (SCR) process, which can be added to reduce NOx emissions by 80-90% using
an aqueous reagent of urea or ammonia (catalysts may not be compatible with high-sulfur-content diesel
fuel).
Transportation of hydrocarbons
Refer to Sections 9.3 for relevant management measures that will be applied for the bulk transportation of diesel
fuel for the Power Station during Project operations.
Safety management
Fire suppression water for the Power Station will be drawn from the raw water tank located at the nearby Process
Plant. Suctions for other water services fed from the raw water tank will be at an elevated level to ensure a fire
water reserve always remains in the raw water tank. The fire water pumping system will contain an electric jockey
pump to maintain pressure, an electric fire water delivery pump to supply fire water at the required pressure and
flowrate, and a diesel driven fire water pump will serve as a backup (automatically starting in the event that the
electric pump fails to maintain pressure in the fire water system). Additional measures include:
Security fencing and authorised personnel only around the site perimeter for the Power Station;
Fire hydrants and hose reels provided at strategic locations (e.g. Power Station, flammable material storage
areas, offices and camps) to ensure complete coverage in areas where flammable materials are present;
Plant operations and transport fuels will avoid using petrol and LPG where feasible, thereby limiting the risk
from explosive materials to only explosives and diesel fuel;
Bushfire prevention controls to be in place, including Project ban on open-burning of wastes, establishment
of fire breaks near sensitive buildings (e.g. at explosives magazine, fuel storage areas, Process Plant, Power
Station or accommodation camps), and no controlled burning activities for vegetation maintenance will be
allowed; and
Training provided to the Project personnel, as appropriate for their role and responsibilities, for fire-
fighting, emergency response, and hydrocarbon management.
Noise management
The Power Station has been designed to be fully enclosed, with noise abatement insulation and protection for the
equipment provided.
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8.3.3 Decommissioning and Closure Phase
Pre-construction and construction phase management measures will be applied for decommissioning and closure
activities associated with the Power Station, where relevant. The final end land use for the Power Station will be
determined through ongoing stakeholder consultation.
8.4 Monitoring Measures
Table 8-1 presents the key monitoring measures related to power supply for the Project. These will be
incorporated into the detailed monitoring programmes prepared by the Company and its contractors for all phases
of the Mako Gold Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 8-1 Register of Environmental Monitoring Measures – Power Station
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Power
Station
emissions
Ambient air
quality monitoring
All Project
phases
Air quality
monitoring
station (refer to
SOP04.16)
PM10, PM2.5,
SO2, NOx, CO
Threshold limits
provided in
Table 2-4
Bi-annually
Refer to monitoring
sites shown in
Figure A1
(Appendix C),
including:
Near Power
Station
At sensitive
receptors (e.g.
Tambanoumouya,
Linguekoto,
Niemenike, PNNK
Buffer Zone Site 1,
PNNK Buffer Zone
Site 2)
Road and
transport
Refer to Sections 9.4 for monitoring measures associated with road and transport for the Project, including for
vehicle exhaust emissions and transportation of hazardous materials (i.e. hydrocarbons).
Fire safety Fire safety
compliance
All Project
phases
Fire safety
compliance
monitoring
Fire safety
inspection
records
Checks of all fire
suppression
equipment to
ensure regular
maintenance
has been
undertaken
Training records
for fire-fighting
Weekly Power Station
Hydrocarb
on spills
and leaks
Routine
inspection for
potential leakage
or seepage of
hydrocarbons
All Project
phases
Visual check to
ensure there are
no visible
leakage or
seepage (refer
to SOP07.28)
Project
compliance
Regular (e.g.
weekly)
Power Station,
Fuel Depot and
other areas where
fuel is stored or
handled
Hydrocarbon All Project Review of Number , type Monthly and
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
spills inventory phases relevant
registers and
records
maintained by
the Company
(refer to
SOP07.28)
(e.g. diesel, etc.)
and scale of
spills (i.e. small,
large, major)
occurred
Volume of
accidental
releases to the
receiving
environment
(including soils
an water), if any
Actions taken for
immediate
remediation
Annual
Power Station,
Fuel Depot and
other areas where
fuel is stored or
handled
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9 ROADS AND TRANSPORT
9.1 Objectives
Key objectives related to managing roads and transport for the Mako Gold Project include:
Ensuring compliance with international guidelines for transport of hazardous materials (including cyanide
and additional process reagents);
Minimising the impact of Project mine traffic and road infrastructure on the local communities and the
environment;
Managing transport safety for the Project; and
Maximising community benefits of Project road infrastructure.
9.2 Context
The paved National Road 7 (RN7) and the Main Access Road will be used as the primary haulage route during all
Project phases for supplies and material delivery. The RN7 is in varying states of repair and is primarily used by
heavy vehicles (39% of traffic) and light vehicles (33%), with five Niemenike villages, Mako and Badian 2 (a hamlet
of Marougoukoto) located directly adjacent this road. Vehicular use of this road also includes frequent
transportation of various goods and supplies for mining projects in the region, including hazardous materials and
hydrocarbon.
From the RN7, the existing rural Mako-Tambanoumouya access road network is comprised of unsealed roads.
Vehicle access is difficult during the wet season, particularly to Tambanoumouya, Kerekonko, Bomboya and
Soukouta (Socio-Economic, Land and Water Use Study, Earth Systems, 2015).
Project implementation will comprise the following road development:
Main Access Road: The Main Access Road will be constructed from RN7 to the PDA. The first section of the
road running from the RN7 west of Niemenike to the Mako-Tambanoumouya road will be 7.1 km in length
and 9 m wide. The second section will run parallel to the Mako-Tambanoumouya road for a 1.3 km stretch
and will then head north-west for a further 4 km towards the PDA, in part following an existing exploration
track. Parts of the road (in steep sections) may be sealed. There will also be a short access road of
approximately 750 m leading from the Mako-Tambanoumouya road to the WSD.
Additional Construction Phase Road Infrastructure: The existing road running parallel to the Gambia
River between Mako and Tambanoumouya will be upgraded for use during the Pre-Construction Phase
(prior to completion of the Main Access Road). The environmental and social impacts that may result from
the construction, operation and decommissioning / closure of proposed road developments are listed in
Table 9-2. The Company will conform to best industry practices for road construction and maintenance in
addition to implementing measures outlined in Section 9.3 to ensure these impacts are minimised.
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Table 9-1 Summary of potential environmental and social impacts associated with Project road infrastructure
Aspect Primary Potential Impact Phase of Project Initiating Project activity Impact
Duration C O D
Biodiversity Loss of habitat and biodiversity. Road establishment.
Permanent
Increased pressure on forested areas.
Habitat fragmentation and disruption to
local fauna migration between the Project
Area and PNNK.
Soil erosion Erosion. Vegetation removal and
ground disturbance during
construction; ongoing
sediment runoff from
unsealed access roads.
Permanent
Air quality Dust emissions. Construction activities and
Project road use.
Temporary
Noise Noise emissions. Construction activities and
Project road use.
Temporary
Water quality Sedimentation.
Ground disturbance during
construction.
Permanent /
Temporary
Pollution of surface and groundwater. Hazardous materials
storage and handling.
Waste Disposal of road construction debris and
wastes.
Construction activities. Permanent /
Temporary
Settlements
and land use
Permanent land use change. Road establishment. Permanent
Loss of timber and NTFP resources. Road establishment and
construction activities.
Permanent
Encroachment into communal and private
properties (e.g. farming land).
Construction activities. Permanent
Health and
safety
Injury and sickness to workers to the
community (e.g. flyrock from blasts, traffic
accidents, etc.).
Construction activities (e.g.
blasting)
Permanent /
Temporary
Project road use.
Local village
activities
Disruption to local village activities (e.g.
farming).
Construction activities. Temporary
Assets and
infrastructure
Impact to existing private and communal
infrastructure.
Road establishment and
construction activities.
Permanent /
Temporary
Archaeology
and cultural
heritage
Direct or indirect impacts on archaeology
and/or cultural heritage sites.
Road establishment and
construction activities.
Permanent /
Temporary
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9.2.2 Pre-construction and Construction Phase
No major disruption to existing roads are envisaged, however pre-construction phase upgrade of the access road
between Mako and Linguekoto may slow movement on this road for a short duration.
The majority of direct impacts will be from land clearance, road construction / upgrade and conversion of existing
land use to access roads. Biodiversity impacts will include habitat loss and fragmentation as well as increased
access to forested areas from construction of a new road making these areas more readily accessible for forest
resource extraction (e.g. increased hunting, timber, NTFP collection) (refer to ESIA, Volume A, Chapter 10).
If unmanaged, water quality impacts may occur from sedimentation of downstream watercourses from erosion of
cleared areas and unsealed road surfaces, and surface or groundwater pollution from fuel leakage or spillage
during construction activities.
Significant dust emissions during this period (from the perspective of social receptors) are expected to result from
using the current road network, construction of the Main Access Road near its intersection with RN7, and upgrades
to the existing road network during construction, particularly during the extensive dry season and annual
Harmattan winds.
Villages along the Project access road infrastructure and RN7 may also be exposed to increased risk of traffic
accidents from Project vehicles and moderate nuisance noise. Health and safety risks to construction personnel
and the community may also occur from flyrock associated with blasting for road construction.
9.2.3 Operations Phase
Unmitigated Project traffic on the local road network may lead to a number of environmental and social impacts
during Project operations, including:
Traffic related health and safety impacts to roadside communities, including increased road accidents and
moderate dust and noise nuisance;
Water quality impacts, including from erosion and sediment transport from unsealed access roads;
Road hazards from bulk transportation of hazardous materials (e.g. hydrocarbons, cyanide) and dangerous
goods (e.g. explosives) required for the Project. The potential for road accidents involving Project vehicles
that could lead to environmentally hazardous discharges have been considered in Chapter 9 of the ESIA
(Volume A) and the Risk Assessment (Volume B);
Increased traffic volumes and cumulative degradation of the local road network; and
Potential economic / livelihood / health impacts to roadside communities.
9.2.4 Decommissioning and Closure Phase
Following Project closure, the most significant impact will likely occur from the greater accessibility of the Wayako
Valley, which was previously less isolated from vehicles. This may lead to increased hunting pressure, timber
harvest and NTFP collection.
It is anticipated that the Company will transfer the majority of Project road infrastructure to the local government
or communities, providing lasting benefits to the region. Accordingly, the primary potential impacts may include:
Greater accessibility to forested areas, which could lead to increased illegal exploitation of forest resources
(e.g. hunting, timber and NTFPs), as above;
Maintenance costs for government / communities; and
Ongoing erosion of the unsealed road network and associated sedimentation of surface waters.
9.3 Management and Mitigation Measures
The Company will implement management and mitigation measures provided in this sub-section (and will include
them in the CEMP), to address potential impacts from Project road construction / upgrade and use of roads.
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Principal contractors for the Project will also be required to develop specific Environmental Management Plans
(EMPs) which incorporate measures detailed in the following subsections and as relevant to their work activities.
The Company will continue to monitor and adapt relevant measures throughout the life of the Project to ensure
they remain effective.
9.3.1 Pre-construction and Construction Phase
Construction environmental management
The Company has integrated best road design practices, and require contractors implement construction
techniques that are consistent with good industry practice. The full suite of SOPs provided in Appendix A will be
considered in the CEMP to manage environmental impacts as required, including:
SOP01: Erosion and Sediment Control;
SOP02: Water Quality and Pollution Management;
SOP04: Emission and Dust Control;
SOP05: Noise and Vibration Management;
SOP06: Waste Management;
SOP07: Hazardous Materials Management;
SOP08: Blasting Management;
SOP09: Land Clearance and Soil Stockpiling;
SOP10: Cultural Heritage Management; and
SOP11: Lighting and Visual Amenity Management.
Additional management measures to be implemented during this phase are specified below.
Vegetation and biodiversity management
As stated in Section 9.2, Project roads have been aligned to minimise vegetation clearance and habitat
fragmentation, and avoid environmentally sensitive areas such as an important water source (i.e. a spring used by
wildlife for drinking during the dry season).
The Company will implement key biodiversity management measures during construction including:
Applying applicable elements of the Biodiversity Action Plan (Volume C);
Minimising road and clearing widths to allow for greater connectivity of habitat (so that some species may
cross a small clearance width), and clearly define their boundaries with marker posts or equivalent to
prevent vehicles from deviating outside these boundaries;
Avoid impacts to environmentally sensitive areas wherever practicable as identified through the land
disturbance permitting system in place (SOPO9: Land Clearance and Soil Stockpiling). Sensitive areas will
be marked as ‘No Go Zones’;
Maintaining a relatively continuous canopy above linear or narrow clearings (e.g. roads) to reduce edge
effects (e.g. microclimate, light) and allow arboreal fauna to move without coming to the ground;
Night-driving to be avoided where practical, and night-driving techniques employed to avoid wildlife
collision, e.g. reduced speed limits and use of vehicle high beam lights;
Avoiding impacts to waterways and riparian vegetation during road construction to the extent practicable;
Progressively rehabilitate temporarily disturbed areas as soon as possible;
Restricting access to Project roads within the PDA (where appropriate) to authorised people only;
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Mandatory reporting of observed illegal activities (e.g. poaching, logging) and reportable wildlife incidents
that includes road accidents (e.g. collision with wildlife or livestock) for all Project workers and contractors
(refer to Chapter 16 , Biodiversity Management); and
In accordance with the Injured Wildlife Protocol (refer to Chapter 16, Biodiversity Management), roadkill will
be moved to the sides of roads so that scavenging wildlife (e.g. vultures, leopards) are not hit by other
vehicles, where practical. Appropriate PPE (e.g. gloves) will be used to minimise possible transmission of
zoonotic diseases (that can pass between animals and humans).
Water quality management
The Company will implement the following measures (adapted from the Mine site Water Management Handbook
(MCA, 1997) to minimise erosion and sedimentation to receiving waters from Project road infrastructure:
Appropriate road specification standards will be selected to minimise excessive earthworks with
subsequent requirements for large amounts of fill material;
Design of roads to include drainage systems that channel water from the road surfaces to outlets with
erosion and sediment control facilities, including rip-rap at inlets and outlets of culverts and channels and
sediment control basins constructed for larger catchment areas;
The gradient of all roads and tracks restricted to no more than +/- 10% to reduce erosion caused by runoff;
Roads to be constructed during the dry season to the extent possible. Erosion and sediment controls for
unsealed roads will be completed before the onset of the wet season;
Roads to be constructed with cross-fall slopes of (maximum 3%) to promote rapid drainage from unsealed
road surfaces to avoid scouring. Where cross-fall is insufficient, waterbars will be constructed to direct
water to road discharge channels that will be outfitted with velocity dissipaters and sediment control (e.g.
rip-rap, sumps and/or silt fencing);
Drainage from upslope of road surfaces to be diverted via roadside drainage channels to culverts with
velocity dissipaters and sediment control at outlets;
Culverts installed at drainage crossings s;
Permanent structures designed using an average peak storm recurrence interval of 100 years, and
temporary structures designed using an average recurrence interval of 2 years (24 hour storm events);
Batter slope angles will be minimised to the extent feasible; and
Where feasible, vegetation will be left intact on road verges and roadside batters to reduce surface flow
velocity and erosive potential.
In addition, relevant measures from SOP07: Hazardous Materials Management will be employed to manage any
potential for hydrocarbon or chemical spills during road construction activities.
Community road safety management
The Company will regularly engage with affected communities throughout the pre-construction and construction
phase to ensure associated impacts are appropriately managed (refer to Chapter 13, Community Engagement). In
addition, the Company will implement the following measures for managing community health and safety in
relation to transport:
Road design and construction methods will consider community road safety issues, including ensuring the
junction of the Main Access Road does not pass close to village settlement areas, lane closures, and
providing safe turning lanes off the RN7;
Appropriate traffic safety controls implemented and enforced, including road signage in both pictures and
words written in French for all roads within the PDA, (e.g. for reduced speed zone limits, warning signs,
pedestrian crossings) and speed bumps or pedestrian crossings through high risk areas (e.g. schools,
livestock crossings, etc.);
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Vehicular speed limits as follows: Maximum of 50 km/h for Main Access Road and other Project roads, Haul
Roads, and other Project roads; National speed limit on the RN7; and 20 km/h through villages, residences
or sensitive areas (e.g. school, known wildlife (e.g. West African chimpanzee) and livestock road crossings,
and environmentally sensitive areas, etc.);
Prior to construction, the Company will educate local villagers about traffic safety in collaboration with
relevant government authorities. This may include conducting road safety education classes in local
primary and secondary schools at key roadside communities along the Project transport routes;
Monitor and enforce transport safety protocols for all employees and contractors to minimise road
accidents, including:
» A ‘driver code of conduct’ for Project drivers and contractors;
» The use of private vehicles restricted once past the Project entrance boundary;
» Project vehicles to follow designated Project transport routes within permitted driving hours, subject to
approval by the Company’s OHS&E Manager. Approved routes to avoid passing through villages and
settlement areas (e.g. Niemenike) wherever possible;
» Off-site vehicle movements (e.g. delivery of supplies) to the day time, where practicable;
» Regular Project driver and contractor checks for adherence to local traffic laws;
» Speed restrictions for Project vehicles (see above for further details on speed limits to be provided);
» No driving is permitted on the Main Access Road during night-time. Employees and contractors will
require prior approval if night-use of the road is required during exceptional circumstances;
» Training to be provided to vehicle drivers on safe driving (e.g. collision avoidance), fatigue
management, and first aid training;
» Project vehicles equipped with first aid equipment and appropriate personal protection equipment
(PPE) (e.g. high visibility vest);
» Vehicles transporting oversized loads to be preceded by an escort ‘warning’ vehicle;
» Transportation of dangerous goods and hazardous materials to comply with measures specified in
Section 9.3.2 (including available spill kits);
» Zero tolerance on driving under the influence of drug and alcohol and proper fatigue management for
Project drivers. The Company will conduct regular compliance monitoring such as random breathalyser
and remote monitoring of driver performance;
» Project vehicles to meet road weight limits on the designated routes, including for bridge crossings;
» Safety inspections of Project vehicles will be conducted on a regular basis; and
» Road safety precautionary controls, such as restricting material deliveries (particularly for hazardous
materials and dangerous goods transport) and workforce movements during periods when more
vulnerable road users are present on the route (e.g. during school opening and closing times).
Detailed procedures and training as part of the Project-specific Emergency Preparedness and Response
Plans to be developed (refer to Section 3.7) for managing road accidents and transporting hazardous
materials; and
A road incident log and reporting system that enables road users and Project drivers to report road
accidents as well as unsafe driving / speeding involving Project vehicles. The database will capture relevant
information, e.g. date, time, location, persons involved, and any response required or action taken by the
Company.
Traffic and transport management
The Company will implement the following measures during construction to minimise road construction and
Project traffic impacts to road users on the local road network:
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Schedule for road works to be coordinated with relevant agencies and stakeholders to minimise traffic
disruption for public and private road users;
Community use of all Project roads will be permitted. However, there will be a control post just north of
Tambanoumouya to control access to the mine facilities;
Prior notification of planned road construction activities likely to cause nuisance noise and dust (e.g. blasts)
to potentially affected villagers;
Appropriate signage and traffic safety measures (e.g. barriers) for road works will be undertaken in
consultation with local government and key stakeholders;
All Project roads within the PDA signposted in French to provide directions to traffic movements;
Vehicle road trips and transport distances for material deliveries and workforce movements will be
minimised to the extent practicable by prioritising local materials and labour;
Optimised transport logistics for workers and materials delivery to minimise the number of Project vehicles
on the road. The Company will provide daily bus transportation for staff to and from the camp and work
sites, and to and from nearby villages and Kedougou;
The use of private vehicles restricted once past the Project entrance boundary;
Journey management plans and in-vehicle monitoring system to track all Project vehicles. Disciplinary and
corrective actions to be applied for non-compliances recorded (e.g. speeding, fatigue management, etc.);
Establishment of a vehicle and machinery maintenance programme for the Project to comply with relevant
standards and guidelines for transport safety and vehicle manufacturers’ instructions; and
Project Grievance Management Procedure for road users and villagers to register issues and complaints in
relation to road degradation caused by Project vehicles.
Community and land use management
Where possible, a number of Project road alignments have been refined to avoid impacts to settlement areas and
land uses. The Company will implement the following key measures to minimise potential settlement and land use
impacts and in-migration caused by Project road construction / upgrades:
Prior consultation with potentially affected villagers and local government on planned road construction
activities to minimise or mitigate potential impacts, where possible;
Prior to construction commencing, adequate compensation to directly and indirectly affected villagers
adversely affected by land or asset loss, to ensure that households achieve at least their pre-Project
wellbeing and standard of living;
Maintaining existing access routes to local sites and land uses to the extent practicable, or alternative
temporary access may be considered for unavoidable restrictions over a long period following proper
consultation with affected parties; and
Project Grievance Management Procedure to ensure that unanticipated land and village complaints can be
identified and resolved in a timely manner.
The Company will continue ongoing community engagement for the Project with affected communities to confirm
the effectiveness of strategies and make any improvements where necessary.
Blast management
The Company will ensure an appropriate Blast Management Plan is prepared and implemented prior to any blast
activities required for road construction. This plan will incorporate key safety measures to avoid potential health
and safety impacts from flyrock, including ensuring that no unauthorised vehicles or pedestrians can access the
blast exclusion zone, and restricting access controls at entry and exit points along Project roads.
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Air quality and noise management
The Company will establish an appropriate community consultation programme (refer to Chapter 13, Community
Engagement) covering all mine related traffic as well as a Project Grievance Mechanism to record and respond to
air quality, noise and vibration related complaints appropriately.
During road construction, the Company will implement the following measures to minimise air quality and noise
impacts:
Prior notification of planned road construction activities likely to cause nuisance noise and dust (e.g. blasts)
to potentially affected villagers;
Scheduling of road construction works to avoid night time near roadside communities to limit potential
disruption;
Blasts to avoid being conducted during unfavourable weather (e.g. dry and windy conditions from
Harmattan winds) to avoid excessive dust generation and dispersion, where possible; and
Implementation of the Project Grievance Procedure to enable villagers and road users to report any noise or
dust related complaints in relation to Project vehicles.
The Company will employ additional measures for managing air quality and dust impacts associated with
transport for the Project, including:
Regular watering of unsealed road surfaces and trafficked areas during the dry season or when excessive
dust generation is evident near sensitive receptors (e.g. villages / settlements). Dust suppression water will
be sourced from treated wastewater or raw water from the WSD. Frequency of watering will be increased
during periods of high risk (e.g. dry and windy conditions);
Project vehicle speed limits through villages 20 km/h;
Low emission diesel engines and/or catalytic convertors for Project heavy vehicles, trucks, and excavators
will be used, where possible;
Dusty material loads will be covered where transport is required through settlements;
Unsealed roads heavily trafficked by Project vehicles over a long period will be considered for future
application of gravel or paving; and
Regular maintenance of unsealed Project roads.
Key mitigation measures for the Project to manage noise and vibration impacts associated with transport include:
Ensure Project vehicles avoid overloading or unnecessary revving and queuing, particularly near community
sensitive receptors;
Prohibit idling, use of air brakes and reduce noise level of loud warning devices in settlement areas. Vehicles
will be turned off if parked near residences, offices or eating areas;
Retain existing vegetation screening to the extent practicable along Project road infrastructure and
consider planting vegetation buffers or creating earth mounds for noise shielding in particularly sensitive
areas (e.g. residential areas);
Seal uneven or rough road surfaces, or maintain road surfaces regularly to minimise surface unevenness,
particularly where trucks pass through (particularly for the Main Access Road); and
Train Project drivers in good driving practices to minimise noise impacts.
Waste management
All waste generated by road construction / upgrades will be managed in accordance with SOP06: Waste
Management. Hazardous wastes will be addressed with measures specified in SOP07: Hazardous Materials
Management.
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Cultural heritage management
Detailed archaeology and cultural heritage studies will be conducted in advance of all land disturbance activities.
Infrastructure corridors will be the subject of an archaeology and cultural heritage study in advance of Project
construction.
The Company will implement the Chance Find Procedure for the protection of physical cultural resources in the
PDA, as per Appendix B and SOP10: Cultural Heritage Management (Appendix A). Staff will be trained in the
implementation of SOP10, as relevant to their roles and responsibilities. A register will be maintained of all areas
that have been the subject of detailed archaeology and cultural heritage studies. The register will include all sites
and artefacts identified in the Project area. The Company will liaise with specialists regarding the documentation
and display of archaeology and cultural heritage artefacts identified in the Project area.
9.3.2 Operations Phase
Where appropriate, the Company will apply relevant management measures identified for the pre-construction
and construction phase during operations. Additional measures for implementation during the operations phase
are listed below.
Transportation of hazardous materials and dangerous goods
The Company has developed preliminary emergency response procedures for managing risks associated with
transportation of dangerous goods and hazardous materials, which are detailed in SOP07: Hazardous Materials
Management (Appendix A). The procedures will be further refined in the Emergency Preparedness and Response
Plans to be developed for the Project (refer to Section 3.7).
As per SOP07, hazardous substances and dangerous goods will be transported in accordance with relevant
legislative requirements and applicable international and national standards and guidelines, including:
International Cyanide Management Code Principles and Standards of Practice for cyanide handling, storage
and transportation (ICMI, 2014);
IFC General Environmental, Health and Safety (EHS) Guidelines 2007 (particularly Chapter 1.5 Hazardous
Materials Management and Chapter 3.5 Transport of Hazardous Materials);
United Nations, Transport of Dangerous Goods - Model Regulations. 17th Revised Edition (Volume 1)
Geneva 2011;
AS 1940 – The Storage and Handling of Flammable and Combustible Liquids. (Current 2004 ed.); and
AS 2187 – Explosives – Storage, Transport and Use. (Current 1998 ed.).
Explosives and other hazardous materials will be transported by a suitably licensed and reputable carrier (e.g. ICMI
2014 Cyanide Code-compliant transporter). Management of risks and emergency response to spills or accidents
during the transport of hazardous materials and dangerous goods will be the responsibility of the licensed carrier.
Key measures to adopt by the contractor for the transportation of hazardous materials and dangerous goods
include:
A road safety and maintenance programme for transport vehicles that includes procedures for vehicle and
tire inspections, preventive maintenance, drivers fatigue management and permitted driving hours, tie-
down of loads, and actions to be taken if severe weather conditions are encountered;
Careful consideration of transport distances and routes;
Where appropriate, the Contractor will arrange for a specialised escort ‘warning’ vehicle where transport
routes present safety or security concerns for the transport of cyanide, explosives and other dangerous
goods or hazardous materials;
Audit of health and safety documentation of transporters for hazardous materials and dangerous goods to
be engaged, to ensure they are adequate and compliant with legislative requirements;
Cyanide transporters to be compliant with the Cyanide Code (ICMI, 2014). The code-compliant transporters
will be required to prepare a detailed procedure for cyanide transport to the Project site, and provide
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options where necessary to minimise risks in consultation with community and other stakeholders. The
escort contractor must be a signatory to the Cyanide Code (ICMI, 2014) for cyanide transport;
Project vehicles carrying dangerous goods and hazardous materials will travel in off-peak times when there
is less traffic on roads to the extent practicable. Procedures for regular communications between transport
vehicles and the transporter contractor will be in place;
Drivers of dangerous goods and hazardous materials adequately trained to handle local road conditions and
follow safety protocols;
The contractor will develop specific emergency response and clean-up procedures for road transport ;
Drivers transporting dangerous goods and hazardous materials will be adequately trained on appropriate
emergency response and clean-up procedures to follow in the case of a spill;
The contractor will provide appropriate PPE and clean-up skill kits (including for cyanide specific PPE and
neutralising agents, where appropriate) for drivers transporting hazardous materials and dangerous goods,
including gloves, plastic coveralls, safety glasses and self-contained respirators, etc.; and
Inventory controls and/or chain of custody documentation in place to identify the loss of any hazardous
material during transport (refer to SOP7, Appendix A).
Prior to Project construction, a specific Waste Management Plan will be developed for the Project incorporating
key measures and procedures to follow for the safe transportation, handling, and disposal of cyanide, hydrocarbon
and other hazardous materials and dangerous goods.
Vegetation and biodiversity management
The Company will implement relevant measures to minimise potential impacts on aquatic and terrestrial
biodiversity as detailed in Chapter 16, Biodiversity Management and the Biodiversity Action Plan (Volume C),
including:
Collaboration with the PNNK area managers to ensure impacts on the integrity of the PNNK and
surrounding forested areas are adequately mitigated;
Requirement for employees and contractors to report any observed illegal activities and wildlife encounters
(including injured wildlife) that may impact biodiversity values along access roads; and
Specific procedures that will be followed to prevent invasive weed spread, vehicle washdown, regrowth
maintenance, and injured wildlife management.
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9.3.3 Decommissioning and Closure Phase
It is anticipated that the Main Access Road, remaining Road Infrastructure, and workforce accommodation
facilities will be transferred to the local government or communities (pending stakeholder consultation). Road
infrastructure in the PDA will be rehabilitated. The RCMCP (Volume E) specifies management measures for the
decommissioning of access roads, including:
Road borders and embankments to be progressively re-vegetated where necessary for erosion control;
Rehabilitation of roads will be undertaken by:
» Road related structures will be removed where practicable, including road signage, culverts, oil or
grease traps and hydrocarbons (if applicable).
» Rehabilitate Project roads (unless they will be made available for community use) by ripping road
surfaces, re-shaping to pre-construction contours, and stabilising and revegetating with native plant
species of local provenance; and
» Road drainage will be re-directed as necessary to minimise erosion until vegetation is established.
An earth berm will be constructed across the Main Access Road to maintain community safety.
For Project infrastructure that will be transferred for future use by local government or community, the Company
will consult and negotiate with the relevant parties and stakeholders to ensure that:
Remaining mine facilities (e.g. TMF) that may pose a safety risk to the public are adequately secured; and
Maintenance requirements and associated costs are clearly defined.
9.4 Monitoring Measures
Table 9-2 lists the key monitoring measures related to Project roads and transport. These will be incorporated into
the detailed monitoring programmes prepared by the Company and its contractors for all phases of the Mako Gold
Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18.
Table 9-2 Register of Environmental Monitoring Measures – Roads and Transport
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Air quality
and dust
Dust
monitoring
Pre-
construction,
Construction,
Operations
Visual check for
excessive dust and
Project Grievance
mechanism (refer to
SOP04.16)
Project
compliance and
logged dust
complaints
Threshold limits
provided in Table
2-4
Daily
Key sensitive
receptors (e.g.
residence,
school) in
roadside
communities
along Project
road transport
routes (note
there are no
monitoring
sites proposed
for Project road
transport
routes at
present)
Pre-
construction,
Construction,
Operations
Monitoring using dust
gauges (refer to
SOP04.16).
Dust deposition
rate, PM10, and
PM2.5
Threshold limits
provided in Table
2-4
Bi-annual (no
sensitive receptors
currently directly
on Project access
roads - if new
receptors are
located directly
along routes, this
will be updated to
continuous
monitoring)
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Noise
and
vibration
Noise and
vibration
monitoring
Construction,
Operations Refer to SOP 05.12
Noise levels in
dB(A) LAeq
(daytime and
night-time period
Threshold limits
provided in Table
2-8
Bi-annual
Process Plant
(refer to
monitoring
sites shown in
Figure A1,
Appendix C)
All Project
phases
Refer to SOP 05.12
and Project
Grievance
mechanism
Project
compliance and
logged noise
complaints
Threshold limits
provided in Table
2-8 and Table
2-9
Ongoing
Key sensitive
receptors (e.g.
roadside
communities)
along the
Project road
transport
routes,
particularly for
the Main
Access Road
(refer to
monitoring
sites shown in
Figure A1,
Appendix C)
Water
quality -
ambient
Routine
ambient
water quality
monitoring
Construction
Visual checks for
sedimentation, oils
and grease (refer to
SOP2.10)
Project
compliance Weekly
Discharge
points (refer to
monitoring
sites shown in
Figure A2,
Appendix C)
All Project
phases Refer to SOP02.12
Field parameters
and laboratory
testing as listed
in SOP02.12
Threshold limits
provided in Table
2-5 to Table 2-7
Monthly
Upstream and
downstream of
Badalla creek
and Gambia
River (refer to
monitoring
sites shown in
Figure A2,
Appendix C)
Transport
ation of
hazardou
s
materials
and
dangerou
Monitor
compliance
with
international
and national
requirements
for the
All Project
phases
Audit and review of
licensed and certified
suppliers /
transporters (refer to
SOP07.09)
Project
compliance Annual
Project-wide
(including road
transport
routes)
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
s goods transportation
of hazardous
materials and
dangerous
goods
All Project
phases
Review of hazardous
materials and
dangerous goods
inventory, tracking
and chain of custody
documentation
maintained by the
Company (refer to
SOP07.28)
Volume of
hazardous
material and
dangerous
goods
transported
Volume of
hazardous
materials and
dangerous
goods
transported
across
international
boundaries
Project-wide
(including road
transport
routes)
Incident
register to
include spills
All Project
phases
Record any road
transport related spills
of hazardous
materials in the
Project spills
inventory (refer to
SOP07.28)
Number, type,
scale
Volume
Remediation
actions taken
Ongoing
Loss of
habitat,
vegetatio
n and
biodiversi
ty
impacts
Monitoring of
vegetation
clearing
Pre-
Construction,
Construction
Monitor vegetation
clearing to check it is
confined to clearly
demarcated areas of
disturbance (refer to
SOP09.2).
Extent of
vegetation
cleared for the
Project
During vegetation
clearing
Project-wide
(including for
Project road
infrastructure
and upgrades)
Incident
reporting
system for
Project staff
and
contractors
All Project
phases
Incident reporting
system maintained by
the Company
Reportable
observed illegal
activities (e.g.
poaching, illegal
logging, etc.)
and road
incidents (e.g.
collision with
wildlife or
livestock)
Ongoing
Road
safety
and
environm
ental
complian
ce
Safety
inspections of
Project
vehicles
All Project
phases
Audit of vehicle
checklist to complete
Schedule and
records of
completed
checklists
Daily prior to
driving a vehicle
Project-wide
(including for
Project road
infrastructure
and upgrades)
Road safety
and
environmenta
l compliance
of Project
vehicle and
equipment
fleet
All Project
phases
In-vehicle monitoring
system
Traffic incident
reporting system for
the community and
Project workers
Road safety and
driver compliance
monitoring
Records of traffic
incidents,
including date,
time, location,
persons
involved, and
any actions
taken or
required by the
contractor or the
Ongoing
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Company
Records of
driving training
and
qualifications
Random
breathalyser and
remote
monitoring of
driver
performance
All Project
phases
Project vehicle fleet
database and
maintenance
programme
General vehicle
condition and
safety
Check of vehicle
brakes and tyre
air pressure
Regular vehicle
exhaust and
noise emission
test for
compliance with
relevant
emissions
standards for
noise and air
pollution
Maintenance in
accordance with
the vehicle
manufacturer’s
instructions
Smoke belching
vehicles and
equipment will
be fixed or
replaced
Any leakage of
engine fluids will
be immediately
fixed
Periodic
Vehicle
Workshop and
other vehicle
maintenance
areas as
appropriate
Road
integrity
Routine
maintenance
of Project
roads
All Project
phases
Visual check of road
condition
Project Grievance
mechanism
Incident register
Reportable
traffic
observations,
complaints and
incidents
Ongoing
Project-wide
(including for
Project road
infrastructure
and upgrades)
Blast
impact
Mine blast
monitoring
Construction,
Operations
Routine monitoring of
noise, airblast,
ground vibration, and
flyrock impacts (refer
Blast analysis
and audits
Noise, airblast,
ground vibration,
Periodic (e.g.
when there is a
change of blast
location)
Within 500 m
of blast areas
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
to SOP08.12)
and flyrock
parameters
(refer to
SOP08.12)
Threshold limits
provided in Table
2-4 to Table 2-10
Blast
exclusion
zone
Construction,
Operations
Visual observation for
unauthorised people
within the PDA
Project
compliance
Zero incident
record for blasts
Prior to blasting
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10 ACCOMMODATION FACILITIES
10.1 Objectives
Key management objectives related to accommodation facilities for the Mako Gold Project will include mitigating
potential impacts of the construction and operation of Project accommodation and complying with associated
legislative requirements.
Furthermore, the Company is committed to ensuring Project accommodation maximises the economic benefits
for villages directly impacted by the Project, by implementing the measures specified in the Worker
Accommodation Guidance Note (rePlan, 2015a), which includes the development of a Worker Accommodation Plan
for the Project.
10.2 Context
The Company has developed worker accommodation strategies detailed in the Worker Accommodation Guidance
Note (rePlan, 2015a). Key outcomes of the worker accommodation strategies established is summarised as
follows:
The need for accommodation facilities has been minimised via sourcing local personnel (where workers can
potentially live at home) to the extent practicable. Accommodation support from the Company will be
largely for non-local workers. Kedougou has the highest capacity to absorb influx of the communities in the
Project area, and this area will be the focus of worker accommodation strategies;
The Company will provide eligible workers accommodation onsite while the remaining workforce will be
lodged off-site within daily commuting distance of the Project, i.e. within the Tomboronkoto Commune and
broader Kedougou Region;
Pre-construction workers will be housed in the existing Exploration Camp onsite, which was previously used
for exploration activities for the Project. Construction of a new Accommodation Camp located onsite near
the WSD will commence concurrently and it is intended that this facility will provide accommodation
during Project construction and operations;
Construction workers will be accommodated both in the existing Exploration Camp and new
Accommodation Camp onsite. As a shortage of approximately 50 to 80 camp beds is expected during the
peak construction period, temporary demountable accommodation facilities will be provided near the new
Accommodation Camp to meet the temporary shortage;
The new Accommodation Camp will fully provide for all Project on-site staff accommodation requirements
during the operations phase; and
Incentives will be used to help support and encourage workers to find safe, affordable and comfortable
living arrangements locally, as further described in the Worker Accommodation Guidance Note (rePlan,
2015a).
The primary potential impacts associated with workforce accommodation during each phase of the Project,
detailed in the ESIA (Volume A), are summarised below.
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10.2.1 Pre-construction and Construction Phase
The environmental and social impacts associated with construction of the on-site new Accommodation Camp are
expected to be typical of site preparation and establishment of building infrastructure and services.
If unmitigated, the primary impacts from this workforce accommodation during the pre-construction and
construction phase may include:
Surface and groundwater quality pollution (e.g. accommodation effluent and waste, sediment transport
from disturbed areas, hydrocarbons from vehicles/equipment, and inputs from general construction refuse);
and
Nuisance level air quality and noise for nearby sensitive receptors resulting from site preparation,
construction and vehicle movements.
In addition, the existing Exploration Camp and off-site workforce accommodation also poses transport safety
impacts risks to road users and roadside communities from staff and contractors daily movements to and from the
Project site on the local road network, and greater vehicular noise and dust impacts. Nearby sensitive receptors
(e.g. residences) may also experience minor noise disturbance from residing workers (e.g. audible chatter, TV and
radio noise, etc.), depending on their proximity.
Further impacts are discussed in the ESIA (Volume A). The Company will adopt appropriate environmental
management practices to ensure adverse impacts during this phase are adequately minimised.
10.2.2 Operations Phase
During Project operations, the following potential water quality impacts from workforce accommodation will
require careful management, mitigation and monitoring:
Surface water quality impacts associated with greywater and raw sewage generation (e.g. nutrients and
pathogens) from kitchen / ablution facilities if discharging into the receiving environment;
Pollution from general refuse (e.g. kitchen waste, packaging, metal and plastic); and
Contamination of water or soil from hydrocarbon leakage or spills in the diesel storage areas.
In-migration (including migrant workforce and expatriates) associated with the Mako Gold Project also has the
potential to affect local communities, primarily in the following ways:
Changes to the local demography (including gender imbalance and reduced availability of labour for non-
mining related activities such as farming and agriculture);
Increased pressure on existing community services and infrastructure such as the road network, health
facilities and law enforcement;
Ethnic and religious conflicts, increased incidents of illegal or immoral activities such as crime, alcohol and
drug abuse, and exploitation of vulnerable groups (e.g. prostitution of women and children) and Indigenous
people; and
Community health and safety impacts, including the spread of sexually transmittable infections (STIs) and
other communicable diseases (e.g. malaria, dengue fever, etc.).
10.2.3 Decommissioning and Closure Phase
Much of the accommodation infrastructure will be designed to facilitate ease of dismantling and reuse following
closure. It is anticipated that impacts will be negligible, and likely similar in nature to the pre-construction and
construction phase impacts.
Depending on the outcome of ongoing stakeholder consultation, the Company may transfer the ownership of
existing accommodation camps to the local government or village for future reuse following decommissioning.
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10.3 Management and Mitigation Measures
The new Accommodation Camp will be located onsite at a significant distance from surrounding communities (i.e.
no closer than 3 km). The rural siting of the camp sites will substantially help minimise potential impacts to
community and social receptors, e.g. avoidance of noise, visual amenity (e.g. lighting), and negative interactions
between Project staff and local people.
The following sub-sections details the management measures that the Company will adopt to manage adequately
environmental and social impacts associated with workforce accommodation facilities for the Mako Gold Project.
10.3.1 Pre-construction and Construction Phase
The Company will implement relevant SOPs provided in Appendix A to manage potential impacts generated
during construction, including:
SOP01: Erosion and Sediment Control;
SOP02: Water Quality and Pollution Management;
SOP04: Emission and Dust Control;
SOP05: Noise and Vibration Management;
SOP06: Waste Management;
SOP07: Hazardous Materials Management;
SOP09: Land Clearance and Soil Stockpiling; and
SOP11: Lighting and Visual Amenity Management.
The Company will undertake a final review of proposed locations for the new Accommodation Camp and
temporary demountable accommodation camp site to confirm no significant environmental, social or cultural
values will be affected prior to construction commencing.
10.3.2 Operations Phase
Applicable environmental management SOPs provided in Appendix A will be employed as necessary during
Project operations in combination with the below strategies and measures for worker accommodation.
In-migration
The Company will mitigate the adverse impacts arising from Project induced in-migration. The Company will
monitor the impacts of in-migration in consultation with local authorities and communities in Project affected
villages. Chapter 15 provides further details of the Company’s planned actions for managing in-migration, which
will primarily comprise of:
Provision of daily bus transportation for Project staff between the Project site and Kedougou town to
enable workers to live and commute from Kedougou without suffering from fatigue;
A social and environmental awareness programme to educate non-local Project workers about local cultural
and environmental sensitivities. Local staff will also receive cultural awareness training to promote
understanding of migrant and expatriate workers;
Provision of proper hygiene and sanitation practices and facilities (e.g. camp water treatment plant for
sewage and wastewater, waste management facilities), and preventive measures to avoid the transmission
of communicable diseases (including STIs) between Project staff and the local community, as further
detailed in Section 14 (Community Health and Safety);
Where practicable, integrating sustainable design options in camp facilities to minimise electricity and
water requirements, such as solar panels, solar hot water systems, and stormwater capture and reuse
systems (e.g. rainwater tanks); and
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Ongoing community engagement and consultation throughout the life of Project to ensure community
concerns or grievances with respect to workforce accommodation are appropriately addressed.
Sanitation and hygiene
The Company will ensure augmentation of potable water supplies as necessary. Enough potable water (compliant
with WHO 2011 drinking water standards) will be provided to staff accommodated in camp sites, and all
wastewater and raw sewage generated from kitchen, bathrooms, and toilets will be treated to meet relevant
discharge standards (refer to SOP02: Water Quality and Pollution Management, Appendix A). Raw water from the
Gambia River will be treated for potable use in the accommodation camps via a modular potable water treatment
plant (including filtration, ultra-violet sterilisation and chlorination) and distributed for drinking, site ablutions,
safety showers and other potable water outlets. The plant will have additional capacity for providing potable
water to allow for future workforce expansion.
During Project operations, a site based sewage treatment plant (STP) will treat raw sewage and wastewater from
various sources, including from the accommodation camps. Suitable treatment plant sludge from the STP
(estimated at < 50 kg/day) will most likely be disposed of by direct landfill burial in unlined pits (Coffey, 2015).
Treated effluent water from camp sites (estimated at 50 – 100 m3/day) will be disposed of via leach drains.
Medical and sanitary waste will be disposed of as per SOP07: Hazardous Waste Management, while relevant
worker disease prevention measures will be employed as detailed in Chapter 14, Community Health and Safety. In
addition, accommodation camps will be made ‘mosquito proof’ as far as practicable by ensuring doors and
windows are adequately sealed, suitable ventilation systems are installed, and mosquito nets provided as required.
Waste management
The Company will implement proper waste management procedures for the collection, separation, and disposal of
Project wastes (refer to above). Suitable waste management facilities will be constructed and operated in
accordance with SOP06: Waste Management (Appendix A). The Company will apply the preferred waste
management hierarchy, with opportunities for waste minimisation, reuse and recycling implemented where
practicable.
Putrescible waste such as food scraps and kitchen wastes from the site based accommodation camps will be
disposed of in a suitably designed and lined landfill within the PDA. Other non-recyclable and non-hazardous solid
waste will also be disposed of at the engineered landfill, while recyclables will be recycled with an approved
contractor, where available.
General safety and hydrocarbon storage and handling
Liquid hydrocarbon products (e.g. diesel) required for site power generation at accommodation facilities will be
stored in appropriately bunded tanks (to meet 110% of stored volume capacity) in accordance with SOP07:
Hazardous Materials Management (Appendix A). Regular machinery maintenance (e.g. of diesel generators) will
help minimise the risk of diesel spillage/leakage.
The Company will ensure that each accommodation facility is equipped with adequate fire-fighting equipment
(e.g. fire extinguishers), first aid kits, medical waste disposal facilities, alarm systems; and nominated staff are
provided suitable emergency training (e.g. fire warden). Emergency procedures will be developed to respond to
emergency situations such as fires as part of the Project Emergency Preparedness and Response Plans (to be
developed), with fire evacuation plans posted at strategic locations throughout each facility.
Access to the accommodation camps will be restricted to Project staff and people with an authorised visitor pass.
No staff will be allowed outside the camps between the hours of seven pm till morning.
Dust management
A dust suppression programme for the Project will be employed, involving regular water of unsealed roads, heavily
trafficked areas, and where excessive dust is evident.
Revegetation of disturbed areas around camp sites immediately following construction will also assist in
minimising localised dust generation and attenuate potential visual and noise impacts.
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Transport safety risks
The Company will provide mandatory induction for safe driving practices for all relevant Project staff (including
staff living offsite) to minimise potential transport safety risks. These are further specified in detail in Chapter 9
(Roads and Transport), but include relevant measures such as:
Mandatory driving licence and induction for Project drivers on local road rules and safety;
Road safety protocols including speed limits through settlement areas, zero tolerance for drugs and alcohol
use while driving, and fatigue management;
Establishment of a notification system (Grievance Mechanism) where road users and residents may report
dangerous driving by Project drivers to the Company; and
Established procedures for the proper transportation of flammable materials (e.g. diesel) and emergency
response for traffic accidents involving Project vehicles.
In addition, the Company will provide a shuttle bus service between accommodation camp sites and work sites as
well as to and from nearby villages and Kedougou, to minimise Project road safety impacts. Further details are
specified in Chapter 9 (Roads and Transport).
Noise management
The new Accommodation Camp has been sited to ensure mine related noise and vibration emissions do not cause
unacceptable disturbance for residing staff. For the off-site camp sites, quiet hours will be enforced whereby noisy
activities will be prohibited for a suitable timeframe.
10.3.3 Decommissioning and Closure phase
If transferring ownership for an accommodation facility is agreed to with the government or local communities
(pending the results of stakeholder consultation), the Company will conduct site soil and groundwater testing to
determine whether treatment is required for any unintentional contamination from a hydrocarbon spill or other
hazardous substances. Where hydrocarbons are found in soils, the material will be volatilised, with the residual
waste transferred to the TMF. Accommodation facilities will meet all closure criteria prior to asset transfer or
decommissioning and rehabilitation (refer to the RCMCP, Volume E).
10.4 Monitoring Measures
Table 10-1 summarises the key monitoring measures that will apply for accommodation facilities associated with
the Project. These will be incorporated into the detailed monitoring programmes prepared by the Company and
its contractors for all phases of the Mako Gold Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
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Table 10-1 Register of Environmental Monitoring Measures– Accommodation Facilities
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
In-migration
related
issues
Refer to Sections 14.4 and 15.4 for relevant monitoring measures associated with community health and safety,
and Project in-migration.
Water
quality -
discharge,
ambient
and
drinking
water
Routine water
quality monitoring
Pre-
construction,
Construction
Refer to
SOP02.9 and
SOP2.10
Key parameters:
Turbidity, TSS,
DO, temperature,
electrical
conductivity
(EC), and pH
Visual checks for
sedimentation,
oils and grease
Threshold limits
provided in Table
2-5 to Table 2-7
Weekly
Discharge
points (refer to
monitoring sites
shown in Figure
A2, Appendix C)
Discharge water
quality monitoring of
treated effluent and
wastewater from
water treatment
plants
Pre-
construction,
Construction,
Operations
Refer to
SOP2.14
Key parameters:
Total and faecal
coliform, Total
nitrogen, Total
Phosphorous,
COD, and BOD
Threshold limits
provided in Table
2-7
Periodic
(during
discharge)
At treated
effluent
discharge points
(refer to
monitoring sites
shown in Figure
A2, Appendix C)
General
waste
Detailed inventory
of waste streams
generated by
workforce
accommodation
All Project
phases
Refer to
SOP06.16
Composition and
waste type
according to
different waste
streams
Quantity and
storage location
Transport and
disposal
methods (e.g.
safe disposal
certificates)
Final destination,
including amount
of each waste
type that has
been recycled or
reused
Ongoing
At each
accommodation
facility
Hydrocarbo
n leakage /
spillage
Routine inspection
for potential leakage
or seepage of
hydrocarbons (e.g.
diesel)
All Project
phases
Visual check to
ensure there are
no visible
leakage or
seepage (refer to
SOP07.28)
Project
compliance
Regular
(e.g.
weekly)
Hydrocarbon
storage areas at
each
accommodation
facility Hydrocarbon spills
inventory
All Project
phases Review of
hydrocarbon
Number , type
(e.g. diesel, etc.)
Monthly and
Annual
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
spills inventory
maintained by
the Company
(refer to
SOP07.28)
and scale of
spills (i.e. small,
large, major)
occurred
Volume of
accidental
releases to the
receiving
environment
(including soils
an water), if any
Actions taken for
immediate
remediation
Air quality Dust monitoring All Project
phases
Visual check for
excessive dust
and Project
Grievance
mechanism
(refer to
SOP04.16)
Project
compliance,
logged dust
complaints
Threshold limits
provided in Table
2-4
Daily
At sensitive
receptor, e.g.
residence near
a camp site
(refer to
monitoring sites
shown in Figure
A1, Appendix C)
Transport
safety Refer to Sections 9.4 and 10.4 for relevant monitoring associated with Project traffic and workforce transport.
Noise
Investigative
monitoring of
nuisance noise
All Project
phases
Project
Grievance
mechanism
(refer to SOP
05.12).
Project
compliance,
logged noise
complaints
Threshold limits
provided in Table
2-8
As required
At sensitive
receptor, e.g.
residence near
a camp site
(refer to
monitoring sites
shown in Figure
A1, Appendix C)
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11 BORROW AREAS AND QUARRIES
11.1 Objectives
Key management objectives related to borrow area and quarries for the Mako Gold Project will include:
Complying with legal requirements and environmental and social standards and guidelines;
Minimising potential impacts of quarry and borrow area operations; and
Meet safety requirements of quarry and borrow area operations.
11.2 Context
The Project will require significant amounts of gravel, fill and sand as construction material for the Mine Pit, WRD,
and TMF as well as ancillary mine facilities (e.g. Process Plant, and access roads). Based on the current Project
designs, approximately 6,500 t of aggregate and rip-rap (crushed stone), 4,950 t of sand, and fill material
(engineering grade clay-rich material) will be required to support the mine development and associated
infrastructure.
Where possible, these will be obtained from suitable sources available onsite during the pre-construction and
construction phase, and ongoing mine development. However, a number of borrow areas and quarries will likely
be required to supplement the needs for Project construction material requirements, where the amount of suitable
material available onsite is insufficient.
A preliminary study of local sand availability indicates additional sand supplies will most likely be required from a
larger source outside the Mining Concession to fully satisfy Project demand for sand. An initial 2,000 t of sand will
be required in the months preceding civil works, followed by an average of three to four trucks per week during
construction to provide the remaining material progressively in small quantities stockpiled onsite (used as
required, with additional sand delivered to the site as needed).
The development of borrow pits and quarries will primarily occur during the pre-construction and construction
phase, with the majority of impacts expected to be limited to this phase. The Company envisages engaging a
contractor to produce the required aggregate at the quarry sites, operating a portable crushing plant over a two to
three month period (excluding time for mobilisation). Aggregate will be stockpiled at the quarry site and
progressively trucked to the Project site over the following seven months. It is expected the production of
aggregate will be a one-off activity meeting the full Project requirements.
The full impact assessment of borrow areas and quarries for the Project is provided in the ESIA (Volume A). The
Company will conduct further investigation of the stone and sand quality required to confirm suitability.
11.2.1 Pre-construction and Construction Phase
The Company has undertaken an initial site evaluation of existing borrow pits and quarry sites situated locally, and
has identified three existing quarry sites, including the quarry and gravel stockpile recently used for the RN7
upgrade. This site is equipped with a loading ramp and laydown area for stockpiling crushed aggregate and is
ready for immediate re-commissioning. Preliminary investigations of the basalt rock available at this site confirm
it as the preferred site as it can provide suitable materials.
The new Main Access Road entering the Project site is planned for establishment during pre-construction, before
trucking of bulk materials (including gravel, sand and fill) transportation commences.
Borrow pits and quarries no longer required at the end of this phase will be progressively decommissioned and
rehabilitated.
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11.2.2 Operations Phase
During Project operations, a small number of borrow areas and quarries will be retained to provide fill material and
gravel for ongoing development of the TMF and WSD embankment, and Project road maintenance, as needed.
These sites will be managed and operated as per during the construction phase.
11.2.3 Decommissioning and Closure Phase
Where required, borrow pits and quarries no longer required during Project operations will be progressively
decommissioned and rehabilitated at the end of this phase.
11.3 Management and Mitigation Measures
11.3.1 Pre-construction and Construction Phase
The use of existing quarries and borrow pits including the preferred one located on the RN7, will greatly assist in
avoiding significant construction impacts associated with site preparation for a new quarry site or borrow pit, e.g.
change to existing landform, land clearance, and vegetation removal. The Company will require contractors to
operate the portable crushing plant during daytime only, to avoid potential night-time disturbance.
The establishment of the Main Access Road initially during this phase will also assist in minimising potential
transport impacts on the local communities and the environment, by avoiding direct impacts on the existing local
road network.
Best management practices will be adopted by the Company and contractors for the development and operation
of borrow pits and quarries including:
Minimising the footprint disturbance area;
Limiting the number of rock and borrow pit cuts required;
Minimising site erosion and sedimentation through appropriate control measures (SOP01);
Restricting access to the public; and
Progressive rehabilitation of sites as they become no longer needed.
SOP09 (Appendix A) provides specific requirements for the construction and operations of borrow pits and quarry
sites in an environmentally responsible manner. The Company will further require contractors to incorporate these
in its CEMP, as well as applying other SOPs for managing significant impacts associated, such as (refer to Appendix
A):
SOP1, SOP2 and SOP3 for managing water quality impacts associated with disturbed surfaces and surface
water management;
SOP07 for the adequately storing, handling and disposing of hazardous materials onsite (e.g. hydrocarbons,
explosives, etc.);
SOP04 for managing dust and air quality impacts associated with handling of dusty materials;
SOP05 for managing noise and vibration impacts to nearby community receptors, if applicable; and
SOP10 for managing potential cultural heritage impacts, including use of the Chance Find Procedure
developed for the Project (Appendix B).
The management of vehicle emissions and road safety / transport (including for hazardous materials and
dangerous goods) associated with trucking sand, gravel and fill material to the Project site are provided in Section
9.3 and will be incorporated into the CEMP. Additional measures that will be applied to these sites for managing
biodiversity impacts are provided in Chapter 16 (Biodiversity Management), and the Biodiversity Action Plan
(Volume C).
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Monitoring for water quality, air quality and safety aspects of borrow pits and quarries used by the Project will be
conducted, where necessary. Ongoing consultation and the implementation of a Project grievance management
system will ensure that unanticipated community impacts will be adequately managed.
The selection of any new quarry or borrow pit will follow the protocol detailed in SOP09: Land Clearance and Soil
Stockpiling (Appendix A).
Decommissioning and rehabilitation
The progressive decommissioning and rehabilitation of borrow pits and quarries no longer required throughout
the life of the Project will be undertaken as per the strategies and measures detailed in the Rehabilitation and
Conceptual Mine Closure Plan (RCMCP) (Volume E). The main aspects that will be adopted by the Company and
contractors include:
Rehabilitation of the site as soon as possible to final natural landform taking into account pre-disturbance
state, public and wildlife safety, and community consultation outcomes;
Stabilisation of disturbed land surfaces to promote natural revegetation; and
Adequate site drainage to avoid water quality issues and erosion.
11.3.2 Operations Phase
The management measures and strategies specified for the pre-construction and construction phase management
will continue to be applied during Project operations, where relevant.
11.3.3 Decommissioning and Closure Phase
Refer to Section 11.3.1 for detailed measures on the decommissioning and rehabilitation of borrow areas and
quarries no longer used throughout the life of the Project.
11.4 Monitoring Measures
Table 11-1 summarises the key monitoring measures that will apply for borrow areas and quarries required for the
Mako Gold Project. These will be incorporated into the detailed monitoring programmes prepared by the
Company and its contractors for all phases of the Project.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 11-1 Register of Environmental Monitoring Measures– Borrow Areas and Quarries
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Water
quality
Routine water
quality
monitoring
Pre-
construction,
Construction
Refer to SOP02.9
and SOP2.10
Key parameters:
Turbidity, TSS, DO,
temperature,
electrical
conductivity (EC),
and pH
Visual checks for
sedimentation, oils
and grease
Threshold limits
provided in Table 2-5
to Table 2-7
Weekly
Discharge
points (refer
to monitoring
sites shown in
Figure A2,
Appendix C)
Routine ambient
water quality
All Project
phases Refer to SOP02.12
Field parameters
Monthly Upstream and
downstream
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
monitoring and laboratory
testing as per
SOP02.12
Threshold limits
provided in Table 2-5
to Table 2-7
of Badalla
creek and
Gambia River
(refer to
monitoring
sites shown in
Figure A2,
Appendix C)
Quarry
and
borrow pit
safety and
integrity
Routine safety
monitoring
Pre-
construction,
Construction
Operations
Regular visual
inspections of the
borrow pits and
quarries for safety
and structural
integrity
Project compliance
Inspection records
for geotechnical and
landform stability
Verification of
security practices
Verification of safety
controls and
inspection records
Weekly
Actively used
borrow areas
and quarry
sites
Air quality Dust monitoring All Project
phases
Visual check for
excessive dust
(refer to SOP04.16)
and Project
Grievance
mechanism
Project compliance
Logged dust
complaints
Threshold limits
provided in Table 2-4
Daily
At sensitive
receptor, e.g.
residence
near a quarry
site (refer to
monitoring
sites shown in
Figure A1,
Appendix C)
Hydrocarb
on
leakage /
spillage
Routine
inspection for
potential
leakage or
seepage of
hydrocarbons
(e.g. diesel)
All Project
phases
Visual check for
visible leakage or
seepage (refer to
SOP07.28)
Project compliance
Regular (e.g.
daily)
Active
construction
areas
Noise
Investigative
monitoring of
nuisance noise
All Project
phases
Refer to SOP 05.12
and Project
Grievance
mechanism
Project compliance
Logged noise
complaints
Threshold limits
provided in Table 2-8
As required
At sensitive
receptor, e.g.
residence
near a quarry
site (refer to
monitoring
sites shown in
Figure A1,
Appendix C)
Acid rock
drainage
and
suitability
Monitoring of
acid rock
drainage
potential and
construction
material
suitability
Construction
Operations
Routine testing of
acid rock drainage
potential and
engineering grade
suitability
Project compliance
Periodic (e.g.
quarterly)
Actively used
borrow areas
and quarry
sites
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12 LAND MANAGEMENT AND LIVELIHOOD RESTORATION
The Company has identified the following key management objectives related to land management and livelihood
restoration for the Mako Gold Project:
Identify principles to compensate those who are affected by inevitable impacts from the Project activities
such as land loss and associated impacts on livelihoods;
Implement mitigation measures to address community concerns or grievances, or if there are no feasible
measures, provide appropriate compensation to affected community members;
Meet or exceed Senegalese requirements, international standards and best practices, and corporate
policies; and
Actively seek and engage community input in consultation sessions with respect to mine activities,
environmental performance and community initiatives for improvement purposes.
12.1 Context
The Company intends to either lease or purchase the land within the PDAs and pay any appropriate compensation.
The Company will formally registering all privately owned and community assets that are likely to be impacted by
Project development. This registration process will be done in consultation with local communities and
government authorities.
Potential issues with land acquisition include loss of agricultural land and grazing land as well as the economic
displacement of miners from the artisanal mine sites within the proposed PDAs. Other livelihoods at risk of being
affected by the Project development are collection of timber and non-timber products.
12.2 Management and Mitigation Measures
12.2.1 Land clearance
Impacts to community land will be minimised to the extent feasible. Prior to any land clearance, the SOP09: Land
Clearance and Soil Stockpiling will be implemented (refer to Appendix A). Where appropriate, the procedure for
land clearance includes consultation with local villagers regarding current land uses, and social and cultural assets
in the area prior to disturbance. A register will be maintained of all land disturbed by the Project.
Management measures to be implemented during the Pre-Construction and Construction phases to minimise
adverse impacts on cultural heritage include:
A cultural heritage survey undertaken along the alignment of the Main Access Road in advance of
construction;
The Company and its contractors will follow the Chance Find Procedure developed and SOP10: Cultural
Heritage Management (Appendix A), and ensure that staff are adequately trained during road
construction/upgrade works involving ground disturbance;
Known cultural heritage sites from the Cultural Heritage Study to be clearly marked on construction maps
as ‘No Go Zones’;
Impacts to cultural heritage sites to be avoided where possible;
Ensure that inductions and training regarding the protection of cultural heritage values is conducted for all
staff and contractors on site, as relevant to their role and responsibilities;
Where practical, refine the alignment of the Main Access Road to avoid disturbance of a prayer tree;
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Engage a Senegalese cultural anthropologist or sociologist to carry out the consultation process regarding
the prayer trees to be impacted and supervise any compensation;
Prohibit Project staff from accessing culturally significant sites;
Implement noise, vibration and lighting mitigation measures to minimise disturbance to cultural practices
performed adjacent to the PDA; and
Implement the Grievance Procedure.
Management measures to be implemented during the Pre-Construction/ Construction and Operation phases to
minimise adverse impacts on archaeology include:
Further excavations and a detailed archaeological investigation to be undertaken if sites are likely to be
impacted by construction activities (i.e. Sites Arch 04, 05, 15, 18, 26, 27, 28, 105, 120, 121, 122, 124, 128);
Test pitting and material recovery for the archaeological sites that fall directly in the footprint of Project
components;
An archaeological and cultural heritage register to be maintained for the life of the Project. Confirmed sites
of cultural heritage or archaeological significance will be accurately mapped and added to the register to
prevent accidental disturbance and avoid direct disturbance to these sites to the extent feasible;
Project employees and contractors educated (through mandatory inductions and training) to raise
awareness of the protection measures undertaken by local archaeological contractors;
Implement the management measures as described in the Chance Find Procedure for the Project (refer to
ESMMP, Volume C);All staff and contractors involved in any ground disturbance works will be informed of
the measures described in the Chance Find Procedure ; and
Establish protection measures (fencing, signage) for sites at risk of impact due to proximity to Project
activities.
The Project Access Road alignment has been designed to avoid impacts to settlement areas and land uses. The
Company will implement the following key measures, in addition to relevant measures from the LRP (Volume D),
to minimise potential settlement and land use impacts caused by Project road construction / upgrades:
Prior consultation with potentially affected villagers and local government on refinement of road alignment
and planned road construction activities to minimise or mitigate potential impacts, where possible;
Existing access routes to be maintained to local sites and land uses to the extent practicable, or alternative
temporary access may be considered for unavoidable restrictions;
Project Grievance Management Procedure to ensure that unanticipated land and village complaints can be
identified and resolved in a timely manner.
12.2.2 Land acquisition and livelihood restoration
The Company’s approach to land acquisition, land management and livelihood restoration will follow all applicable
national legislation, IFC Performance Standards, and Company policies. Any economic displacement resulting
from the Project will be managed as outlined in the Livelihood Restoration Plan (Volume D). The following
principles are the basis of the LRP:
Minimise negative impact on livelihoods;
Identify livelihood impacts systematically;
Recognise advantage of location as an asset;
Plan and negotiate mitigation measures with affected people;
Livelihood restoration is individual;
Plan to over-compensate;
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Give preference to replacement of existing livelihood activities, rather than introduction of alternative
livelihoods;
Implement pilot activities where possible; and
Maintain intervention until success is demonstrated.
Provide compensation/restoration for lost land and associated livelihoods (refer to the Livelihood
Restoration Plan, Volume D). This includes:
» Grazing land restoration;
» Forest resource restoration;
» Agricultural land restoration;
» Mitigation for loss of artisanal mining sites; and
» Mitigation for restrictions on access to other lands.
The livelihood restoration programmes will have the following outcomes relevant to crop production:
» Facilitation of allocation of fallow agricultural land between Project-affected villages/people and
Commune authorities and compensation (in kind or in cash) to assist in improving replacement land;
and
» Where active land has been impacted, in-kind assistance to prepare replacement land.
The livelihood of all impacted households will be restored and, where possible, improved.
To minimise the effect of loss of grazing land and disturbance of livestock associated with Project facilities, the
following management and mitigation measures will be implemented during Construction and Operation Phases:
Restrict clearance of land to only the land required for construction of Project components. Clearance of
buffer zones around Project infrastructure will be minimised where possible;
Refine alignment of Main Access Road to minimise disturbance to pastoral land and livestock
management practices;
In consultation with Tambanoumouya and Linguekoto, identify and manage one or two preferred cattle
grazing areas to improve pastures and facilitate change to livestock management practices to minimise
interaction and/or conflict with Project facilities, particularly road corridors;
Establish vehicle speed limits and other traffic control measures; and
Undertake regular public consultation through existing structures such as the Groupe de Contact to
ensure the effectiveness of management and mitigation strategies.
To minimise impacts on land access, the following management and mitigation measures will be implemented
during Construction and Operation Phases:
Limit the extent and period of exclusion from land areas, for example through the implementation of the
blast exclusion zone at required times only; and
Allow community access to the Main Access Road.
The following key measures will be implemented during the Pre-Construction/Construction and Operation Phase
to minimise impacts on artisanal mining:
Minimise the extent of the safety exclusion zone in artisanal mining areas downstream of Project
components;
Continue consultation with artisanal miners through the Groupe Technique – Orpaillage already established
by the Company;
Support the Government of Senegal with the legalisation of artisanal miners where they operate in the
Company’s Mining Concession area; and
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Contribute to the development of a permanent alternative to artisanal mining for the affected households
of Tambanoumouya, Linguekoto, Niemenike and Mako. The Company will support affected households to
engage in profitable and sustainable irrigated agriculture on approximately 0.25 ha of land per household
(refer to Livelihood Restoration Plan, Volume D for more details).
To minimise impacts on ecosystem services associated with the use of forest resources during the Pre-
Construction/ Construction and Operation Phase, the following avoidance, management and mitigation measures
will be implemented:
Livelihood restoration measures in relation to hunting and the collection of forest resources implemented,
as per the Livelihood Restoration Plan (Volume D), including the planting of useful tree species in
consultation with the residents of Tambanoumouya and Linguekoto;
Maintenance and upgrade of existing public roads to facilitate access to forest resources;
Environmental and social inductions for all Company employees and contractors. The programme will
cover the importance of biodiversity values and prohibition of hunting, trading or buying wildlife products
or harvesting and collecting forestry products (including timber and NTFPs).;
Company employees and contractors to be prohibited from hunting, buying or trading wildlife products as a
condition of their Code of Conduct;
Monitor forest resources to identify the impact of any additional pressure resulting from in-migration and
pursuit of alternative livelihoods reliant on forest products such as construction, artisanal mining, hunting,
etc. Monitoring can be undertaken by regular consultation with local communities and authorities;
In consultation with local residents and the authorities, ensure that they have had the opportunity to
remove timber, firewood and other forest resources from Project areas to be cleared prior to any vegetation
clearance; and
Consider the potential impact on forest resources when planning livelihood restoration activities.
The following mitigation and management measures will help to minimise potential impacts on fishing, water and
aquatic resource use during Pre-construction/Construction:
Minimise disturbance of streams and riparian areas where possible, and prioritise re-vegetation activities in
riparian areas if disturbance is required;
Ensure appropriate management of general waste and hazardous materials to minimise potential impacts
on water quality;
Undertake earthworks associated with construction of access roads and clearance of land for Project
facilities in a manner that minimises erosion and impacts on watercourses;
Minimise impact on riparian habitats during the construction of the Gambia River pump station;
Undertake environmental education and awareness programmes to raise awareness among Project staff
regarding the importance of aquatic resource use for local residents and the need to minimise impacts on
waterways;
Prohibit Project staff and contractors from fishing, collection and hunting of other aquatic species, including
invertebrates, fish and herpetofauna;
Continue the water quality monitoring programme;
Periodic monitoring of habitat and key terrestrial and aquatic wildlife species will be conducted as part of
the Project-specific Biodiversity Action Plan (Volume C) to assess whether any further mitigation or
management measures are required, to include aquatic macroinvertebrate surveys, hippo surveys and fish
catch surveys;
Monitor potential impacts of the Project on food security, health and livelihoods through the biennial socio-
economic surveys of local villages.
The following mitigation and management measures are proposed to minimise the potential impacts on water
and aquatic resource use during Operations:
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The setting of a minimum environmental flow (5 m3/s) under which water supply abstraction will not take
place, resulting in less than 3% of the Gambia River’s flow being abstracted at any one time;
Abstraction from the Gambia River only during the months of higher flows (approximately July –
December); and
Recycling of Project-affected waters on-site during operations.
Land management and livelihood restoration will be managed in coordination with local authorities (village, rural
community, and other applicable levels of government). Land owners and users will be identified and
compensated prior to any disturbance to the land. The Project Negotiations Forum (PNF) (refer to Section 12.3)
established by the Company will be used during the planning and implementation of the land acquisition
programme.
Unanticipated impacts which lead to compensation claims relating to land and other assets will be managed
through the grievance process (refer to Section 13.3.3).
Detailed measures for compensation and livelihood restoration are provided in the LRP (Volume D). Following the
submission of the ESIA documents (including this ESMMP and the LRP) and obtainment of environmental permit,
the Company will conduct negotiations with Project affected persons and government authorities regarding
precise livelihood restoration measures.
In accordance with Senegalese legislation, international standards and Company policies, the key steps in the
livelihood restoration planning process are as follows:
Development of Mako Livelihoods Strategy, with consultation of affected people, based on preliminary
project design options (completed);
Development and refinement of the Livelihood Restoration and Resettlement Framework, based on
national and international standards (completed);
Optimization of project design and footprint to minimise impacts on livelihoods, with consultation of
affected people (completed);
Identification of residual impacts on livelihoods and affected groups (completed);
Development of the initial LRP as a component of the ESIA (completed);
Submission of ESIA with LRP to Government of Senegal, followed by public audiences (completed);
Approval of ESIA with LRP by Government of Senegal (not completed);
Financing of Project and decision to proceed (not completed);
Detailed negotiations with communities, finalisation of LRP and formal agreement (not completed);
Implementation of LRP and signing of formal individual agreements with affected people (not completed);
Formal granting of access to land (not completed); and
Continuation of livelihood restoration and livelihood improvement programmes (not completed).
12.2.3 Decommissioning and Closure Phase
To minimise impacts on land access during Decommissioning/Closure, the key mitigation measures are:
Handover the Main Access Road to local authorities for ongoing community use; and
Partial restoration of access within the PDA, with the exception of the Mine Pit.
To minimise impacts on artisanal mining, the following measures are required during the
Decommissioning/Closure:
Restore hydrological regime of the Badalla Creek and Kobokou Creek;
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Review the closure objectives for the PDA and the acceptability of allowing artisanal mining. This may be
facilitated through continuing consultation and coordination with the communities, local authorities and
miners.
During the Decommissioning/Closure Phase the rehabilitation and revegetation of some impacted areas will be
undertaken. Key measures for terrestrial resource use in this Phase include:
Planting and regeneration of useful species, in consultation with forest users; and
Species selection for all rehabilitation works should include species of economic or subsistence value to
local residents where possible.
Monitoring conducted in rehabilitated areas, in order to assess the success of restoration of forest areas for
wildlife and community use, as per the Rehabilitation and Conceptual Mine Closure Plan (Volume E).
12.2.4 Livelihood Improvement Programmes
Livelihood improvement refers to programmes or measures designed specifically to improve the assets, levels of
economic productivity, and/or standards of living of affected people to above pre-project levels. Subject to further
consultation with the Project affected communities, the Company has committed to supporting a range of
Livelihood Improvement Programmes covering agricultural, livestock and forest activities as detailed in the LRP
(Volume D). These Programmes will be primarily focused on people whose livelihoods are directly affected by the
Project. The Company will also target economically displaced people within the spirit and intent of IFC
Performance Standard 5.
12.2.5 Vulnerable Groups
Vulnerable groups are people who by virtue of gender, ethnicity, age, physical or mental disability, economic
disadvantage, or social status may be limited in their ability to claim or take advantage of development benefits.
A “vulnerable persons” assistance programme will be implemented as part of the LRP which will include specific
assistance measures for vulnerable households or groups that may be affected by Project land acquisition.
Specific aspects of the “vulnerable persons” programme will include:
Recruitment of part-time Vulnerable Persons Officer; and
Preparation and up-date of a formal register of vulnerable groups (“vulnerables watch list”) throughout the
life of the Project.
Other preventive measures and follow-up measures that will be considered include:
Ensuring that recruitment agencies meet national and relevant international standards, including the
following three principles in particular that are relevant to vulnerable groups (Toro Gold,2014a):
» The company is committed to the principles of equal opportunity and fair treatment and will not
discriminate in its employment decisions;
» The company will operate transparent and participatory approaches to employment; and
» The company will not employ forced labour, nor will it directly employ children.
Effective stakeholder engagement will continue via regular public consultation through existing structures
such as the Groupe de Contact to ensure the effectiveness of management and mitigation strategies; and
A Grievance Mechanism will be established to provide a means for responding to stakeholder concerns,
including vulnerable groups.
12.2.6 Gender
While the Project does not have a specific gender policy, gender considerations will be integrated into the general
management of the Project, and potential gender issues have been considered throughout the life of the Project.
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Measures to manage and mitigate Project impacts to women will be applicable throughout all Project Phases.
These measures will include:
Implement the Company’s ‘equal opportunity’ employment policy, which requires the Project to provide
equal opportunity to all applicants regardless of age, gender or ethnicity;
Ensure the mine site infrastructure and work environment are not a barrier to employment of women (e.g.
ensure that accommodation and ablutions facilities include separate facilities for men and women; ensure
that site uniforms meet safety standards, but are available and culturally appropriate for both men and
women) and adopt a zero tolerance policy to discrimination including threatening or sexist behaviour;
Implement gender sensitive livelihood restoration and livelihood improvement measures as part of the
Livelihood Restoration Plan (Volume D) including specific measures for vulnerable persons;
Implement a maternity leave policy as per Senegalese law. Ensure that female staff are aware of this policy;
Regularly monitor socio-economic conditions in Project-affected villages and particular changes to the
distribution of labour that adversely affect women ;
Provide continuous training and development of local employees;
Carry out community consultation sessions targeted at engaging women from the local communities;
Maintain female representation in the Project Community Relations Department and on the Groupe de
Contact/Consultation Committee and other relevant consultation groups; and
Code of Conduct for all Project staff and contractors, including curfew for Camp residents and restricted
access to villages.
12.3 Monitoring Measures
Table 12-1 presents the key monitoring measures related to land management and livelihood restoration for the
Mako Gold Project throughout all phases of development. These will be incorporated into the detailed monitoring
programmes prepared by the Company and its contractors.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 12-1 Register of Social Monitoring Measures – Land Management and Livelihood Restoration
Aspect / Impact Monitoring
Measure
Phase Method Parameters Frequency Location
Compensation
and livelihood
restoration
Establish a
programme to
monitor the
implementation
of the livelihood
restoration
programme
Prior to
Construction
Formal register of
Project affected
land, assets and
livelihood
Monitoring of key
indicators for
livelihood
restoration
Indicators shall
be developed in
consultation with
the community
and government
Ongoing
Project
affected
villages
Construction,
Operations
External
compliance
reviews and a
completion audit
will focus on the
assessment of
compliance with
the requirements
contained in the
Project audit and
compliance
Annually
Project
affected
villages
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Aspect / Impact Monitoring
Measure
Phase Method Parameters Frequency Location
LRP
Livelihood
Improvement
Programme
Establish a
programme to
monitor the
implementation
of the livelihood
improvement
programme
Prior to
Construction
Formal register of
Project affected
land, assets and
livelihood
Monitoring of key
indicators for
livelihood
improvement
Indicators shall
be developed in
consultation with
the community
and government Ongoing
Project
affected
villages
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13 COMMUNITY ENGAGEMENT
13.1 Objectives
The Company’s objectives for the Community Engagement programme for the Mako Gold Project will be to:
Ensure that Project affected communities and other stakeholders are well informed of the Project, its
potential environmental and social impacts and their mitigation measures;
Seek and document community input and actively engage in community consultation regarding project
activities, environmental performance and community initiatives; and
Implement mitigation measures to address community concerns; or if there are no feasible measures,
provide appropriate compensation to affected stakeholders.
13.2 Context
The Company is committed to continuing formal and informal consultation with stakeholders as the Mako Gold
Project progresses. The Company’s approach to stakeholder engagement has focused on the following core
values:
Proactive engagement to enable the early identification of potential issues and risks;
Generation of ideas and alternative solutions for early design considerations; and
Respect for local culture and established political, social and economic relations.
The OHS&E Manager will be directly responsible for ensuring the day-to-day implementation of the procedures
for interaction with community members and stakeholders. The OHS&E Manager will also ensure that the
Company has a presence at local community events to which the Company has been invited wherever appropriate.
Encouragement and support will be provided by the Company for a range of staff to attend these events. The
Community Relations Department will act as a conduit for local people to gain information about mining activities,
as well as to air any concerns or grievances.
As part of the induction programme, the Company employees and contractors will be provided with information
on cultural awareness and community sensitivity. Information may include (but is not limited to):
Local custom(s), beliefs, and traditions;
Any applicable laws unique to the area;
Languages and local dialects; and
Government structure and chains of command.
In accordance with international best industry practices, Company records communications and engagement.
13.3 Management and Mitigation Measures
13.3.1 Ongoing Public Disclosure and Consultation
The overall goal of stakeholder consultation for the Mako Gold Project is to improve decision-making and build
understanding to ensure the long-term viability of the Project and to enhance potential Project benefits. A
Stakeholder Engagement Plan (SEP, Volume C) has been prepared for the Project, detailing the methodology for
conducting stakeholder consultation and documenting the results of consultation activities. The Company’s
Community Relations Department will be responsible for updating and maintaining the SEP and providing regular
updates on progress of community projects.
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The Company has committed to continuing formal and informal consultation with stakeholders as the Project
progresses. A Grievance Mechanism will also be implemented (refer to Section 13.3.3 below). Community team
personnel will regularly (formally and informally) consult with and listen to individuals, community
representatives, government agencies, and non-profit organisations affected and/or interested in the Company’s
activities.
The Company will ensure that community consultations involve a cross-section of local residents (i.e. different
ethnicities, a range of ages, gender balance, etc.) to ensure that the opinions and concerns of all groups are
considered. The Company has also committed to undertaking regular household surveys in villages in the
immediate Project area to gain a greater understanding of the impacts and benefits occurring over time.
A number of groups have been established or are in the process of being established to facilitate consultation
during Project design and permitting, including existing structures such as with Municipal Councils and
Department Councils. These groups are detailed below.
Project Negotiation Forum to support the LRP
The Company will establish a Project Negotiations Forum (PNF), which will serve as a key, multi-stakeholder
decision-making forum for the planning and implementation of the land acquisition and livelihoods restoration
programme. The PNF includes representatives from the Company, Project affected communities, the Rural
Council and other Government representatives, as well as third party observers such as NGOs, community
organisations, spiritual leaders. Basic functions include (but are not limited to) providing strategic direction for the
land acquisition process, including preparing and implementing the LRP (Volume D). This team will be led by
professionals comprised of a mix of Company staff, licensed experts, as well as government technicians. Further
details on the PNF are outlined in the LRP (Volume D).
Local Consultation Committee (Groupe de Contacte)
The Company has established a Local Consultation Committee (Groupe de Contact Locale) comprising of local level
village and administrative representatives (i.e. Mayor of the Conseil Municipale de Tomboronkoto; Vice-Presidents;
Village Chiefs; and Women’s Group Representative and Youth Representatives from Project affected villages) to
assist with the dissemination of Project information, identification of potential issues and risks, to generate ideas
and alternative solutions on early design questions. Committee members are charged with the responsibility to
report back to the respective communities on the resolutions of the Committee.
Technical Groups
A number of ad hoc Technical Groups (Groupes Techniques) have been established to advise the Local Consultation
Committee on specific issues such as economy, artisanal mining, forest resources, etc. These comprise village
representatives from Project affected villages.
Group of Independent Experts
The Company has established a Group of Independent Experts to focus on the biodiversity in the Project
Development Area and surrounding areas as well as the Niokolo Koba National Park (PNNK). The group includes
specialists from the Université Cheikh Anta Diop, an IUCN representative and independent biodiversity specialists.
13.3.2 Community Awareness and Education Programme
Further awareness and education programmes for local communities will be conducted. The scope of these
programmes may include:
Public health, sanitation, and sexually transmitted diseases;
Safety exclusion zones;
Traffic awareness and safety (refer to Section 9.3);
Employment and skills development;
Livelihood, restoration and improvement; and
Economic participation (e.g. micro financing, financial management, etc.).
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Programmes will be adapted to meet ongoing needs and new risks, and will be prepared developed and
implemented with the participation of local authorities, NGOs, and community groups.
13.3.3 Grievance Management
During the implementation of Company activities, conflicts, complaints and grievances will undoubtedly arise and
will need to be resolved in a fair and transparent manner. The most important step in conflict resolution is conflict
avoidance, and a consultative and participatory nature in planning of activities affected the communities is used to
reduce the occurrence of disagreements and conflicting positions.
In instances where grievances do occur, it is important that they are resolved quickly before positions harden and
disagreements escalate. A grievance management system (Grievance Mechanism) receives and addresses
concerns raised by stakeholders in a transparent, constructive, timely, confidential (if desired), culturally
appropriate and accessible manner.
This grievance management system will comprise the four basic mechanisms.
First Order Mechanism - this will comprise an informal resolution process, in which a stakeholder brings
forward his/her concern for discussion with the Company, either directly or indirectly via their nominated
representatives (refer to Section 13.3.1). The Company expects that the vast majority of questions and
concerns will be heard and resolved within these informal interactions.
If this informal process does not resolve the issue satisfactorily, complainants will be encouraged to make
use of any of the other mechanisms presented below.
Second Order Mechanism - this will comprise the formal management of substantive, difficult and/or
written comments and concerns. The Company anticipates that most substantive grievances will be
successfully resolved by this mechanism. The procedure for this is summarised in Table 13-1 below. The
Company will inform local government authorities, village chiefs, and community representatives on the
use of the grievance procedure.
Table 13-1 Summary of the Company Grievance Procedure
Stages Activities Responsibilities Timeframe
Registration Complete the grievance registration
form.
Complainant, with the Company Community
Relations Department.
24 – 48 hours
Reporting Declare complaint / grievance to
Company management
Company Community Relations Department.
Validation Validate the complaint / grievance. OHS&E Manager.
Investigation Assess causes of grievance /
complaint and suggest solutions.
Company Community Relations Department
and the complainant if necessary.
14 days
Resolution Validation the action plan and
timeframe.
Implement the action plan.
Inform the complainant of the
progress and results of actions.
OHS&E Manager and Community Relations
Department.
If the OHS&E Manager cannot resolve the matter, or when more complex issues require higher-level
decision making, grievances will be forwarded on to the Third Order Mechanism.
Third Order Mechanism - this involves the presentation of grievances to a multi-stakeholder forum (i.e.
Local Consultation Committee) for discussion and resolution. The Company hopes that such forums will
serve as an important and trusted arbiter in complicated grievances. Deliberation and any decision taken
will be reflected in the minutes, and a written response provided to the complainant.
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Fourth Order Mechanism - this involves the formal judicial system. The Company recognizes that it is
unlikely to be able to satisfactorily address all grievances with the amicable mechanisms outlined above,
and that all parties have the right under Senegalese law to take their grievances into the judicial system at
any time. The Company will inform those who prefer litigation of their rights, entitlements and the
existence of any legal aid.
13.4 Monitoring Measures
Table 13-2 presents the key monitoring measures related to community engagement for the Mako Gold Project
throughout all phases of development. These will be incorporated into the detailed monitoring programmes
prepared by the Company and its contractors.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 13-2 Register of Social Monitoring Measures – Community Engagement
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Effectiveness
of the Project
Grievance
Mechanism
Review of
records
Informal
discussion
All
Project
phases
Review of
grievance register
and records
maintained by the
Company
Response times on claims Quarterly
Project
affected
villages
Number of claims elevated
to Third or Fourth Order
Mechanism
Quarterly
Satisfaction levels - gauged
via discussions with the
Local Consultation
Committee / Project
Negotiation Forum
As required
Information
disclosure
and
knowledge
Informal
discussion
All
Project
phases
Review of the
Company’s
stakeholder
engagement
activities to date
Community awareness and
understanding of Project
information, gauged after
consultations or through
discussions with the Local
Consultation Committee /
Project Negotiation Forum
Information disclosed as per
the Stakeholder
Engagement Plan
As required
and quarterly
Project
affected
villages
Implementati
on of
community
engagement
activities
Review of
records
All
Project
phases
Review of the
Company’s
stakeholder
engagement
activities to date
Key stakeholders consulted
as per the Stakeholder
Engagement Plan
Number of consultations
conducted
Records (i.e. attendance
sheets, photos, material
used, etc.) of local
community attendance
Quarterly and update each time information is produced or disseminated
Project
affected
villages
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14 COMMUNITY SAFETY AND HEALTH
14.1 Objectives
The Company’s objectives for community safety and health management for the Mako Gold Project are to:
Minimise potential health and safety risks for local communities due to the presence of the Project; and
Support the development of local health services as part of the Project's community development plan.
14.2 Context
The presence of the Project is likely to directly and indirectly result in improvement to local health facilities and
services in the area, such as improved water supplies and sanitation facilities, improved health care facilities and
easier access to such services (e.g. through road upgrade and maintenance). This is a significant potential benefit
of the Project.
The key health issues relevant to the Mako Gold Project are:
A potential increase in sexually transmitted infections (STIs) resulting from in-migration (and primarily in-
migration of young, single males for employment);
Local incidence of diseases, such as malaria, resulting from Project-induced in-migration and potentially
increased mosquito breeding areas due to Project development;
Potential indirect impacts on water quality due to Project-induced in-migration and informal settlements,
with subsequent impacts on health;
Increase in occurrence of ‘wealthy’ diseases, such as hypertension, high blood pressure and diabetes;
Potential psycho-social and health impacts from air quality and noise emissions;
Increased pressures on local food security due to Project-induced in-migration;
Community safety issues resulting from unauthorised access to Project facilities; and
Community safety and security issues resulting from in-migration.
14.2.1 Disease transmission and HIV/AIDS
The most common adult illnesses reported in surveyed villages was malaria, diarrhoea and the flu. Malaria was
also the most common illness affecting children and other reported illnesses included fever, dermatological
conditions, diarrhoea measles, stomach illness and dysentery. Malaria was also reported to be the primary cause
of death.
There will be a potential increase in sexually transmitted infections (STIs) resulting from both influx of Project
employees and in-migration (and primarily young, single males seeking employment). The risk of disease
introduction (e.g. STIs) will be greatest during Construction when short-term workers and in-migrants from other
regions of Senegal or other countries will arrive.
14.2.2 Water and Sanitation
As the surveyed villages rely on surface and groundwater resources for drinking, washing, cooking, recreation,
etc., the protection of water quality is understandably a key health issue for the Project. This is further discussed in
in Chapter 7 of the ESMMP.
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14.2.3 General Community Health and Safety
The key community safety impact would result from unauthorised access to Project facilities. There may also be
community safety and security issues related to Project-induced in-migration and influx of Project employees,
linked to potential lifestyle changes including increased drug and alcohol abuse, gambling, domestic violence and
anti-social behaviour. Transport safety issues are discussed in Section 9.
Other community safety concerns associated with the Project include fly rock, accidental spills, fires and
explosions, and accidents resulting from unauthorized access to Project areas. There are a number of safety risks
inherent at these sites, which could be particularly harmful to individuals unaware of these risks.
Air and noise may present a nuisance and reduced visibility on roads which may have a psycho-social impact (e.g.
leading to reduced quality of life and depression). Dust emissions may also increase the incidence of Acute
Respiratory Infections (ARIs), particularly asthmatic conditions. Social determinants of health which may be
affected by lifestyle changes resulting from the presence of the Project include drug and alcohol abuse, gambling,
domestic violence and anti-social behaviour associated with the rapid influx of labour (IFC Mining EHS Guidelines,
2007).
In-migration associated with the Project is also likely to place a burden on existing health facilities in proximity to
the Project.
Worker health and safety issues for the Operation are outside the scope of this document. However, the Company
has committed to developing and maintaining appropriate health and safety procedures for its staff and
contractors prior to pre-construction commencing, based on the Emergency Response Plan (to be prepared).
14.3 Management and Mitigation Measures
14.3.1 Pre-construction and Construction Phase
General management of community health and safety
Various measures will be implemented to minimise Project impacts on community health and safety during
Construction. These include:
The establishment of health and safety management systems for the community, covering aspects on
security, Project hazards, disease prevention (e.g. HIV and Malaria programmes), and safe sanitation and
hygienic practices;
A range of security controls will be developed in consultation with relevant actors in advance of Project
Construction. These controls will be routinely reviewed with regional authorities;
Provision of health care services for Company employees with an appropriately staffed on-site clinic and
medivac capabilities; The Company will implement a community education and awareness programme
regarding public safety in and around the PDA (particularly related to road safety);
Appropriate environmental emergency response procedures for potential spillage and accidents will be in
place;
A defined exclusion zone to restrict and control access within the PDA and ensure community safety for all
blasting activity to prevent fly rock injury. This zone will include the blast exclusion zone. The zone will be
monitored prior to blasting activity;
In partnership with local authorities, the Company will support community hygiene and sanitation
programmes in Project affected villages;
Mitigating the adverse impacts of the Project on access to community infrastructure and services (e.g.
water supply, hygiene and sanitation, health, security), particularly those related to Project induced in-
migration. The Company will monitor the impacts of in-migration in consultation with local authorities and
communities in Project-affected villages;
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Maintenance of a water quality monitoring programme including routine sampling of village drinking water
in Project-affected villages; and
Supporting community drinking water management programs in Project affected villages, in partnership
with local authorities.
Traffic Management and Road Accidents
The Company’s main objective for Project traffic management is to minimise the impact of mine traffic on local
villagers and the environment. The strategy for dealing with the road safety management associated with the
Project is discussed in Section 9.
Disease Transmission
The Company will facilitate and seek to provide assistance to local agencies to support training to local health
workers in implementing and providing education on sanitary practices for the community. An institutional
support programme to community hygiene committees in all Project affected villages will be established to
reinforce community sanitation and hygiene. This will be implemented by suitably qualified local partner under
supervision of the local health authority.
The potential for HIV / AIDS transmission will be minimised through strategies such as the development of
partnerships with Government HIV / AIDS programmes and NGOs / Aid agencies working in the area on HIV / AIDS
prevention and treatment.
The following specific measures will be implemented:
Implementation of a Code of Conduct for all Project staff and contractors, a camp curfew and restricted
access to villages to reduce the potential for transmission of STDs;
In partnership with local health authorities, support community HIV/AIDS awareness programmes in
Project affected villages;
In partnership with local health authorities, support community malaria prevention programmes in Project
affected villages.
Dust and Noise
General strategies to minimise community related impacts from dust and noise are provided in SOP04: Emission
and Dust Control and SOP05: Noise and Vibration (Appendix A).
During road construction, the Company will implement the following measures to minimise air quality and noise
impacts:
Prior notification of planned road construction and maintenance activities likely to cause nuisance noise and
dust (e.g. blasts) to potentially affected villagers;
Avoidance of road construction and maintenance works during night time hours where works are located
near roadside communities, to limit potential disruption;
Continue monitoring of noise and dust impacts within Project-affected villages to ensure that impacts are
at acceptable levels; and
Implementation of the Project Grievance Procedure to enable villagers to report any noise or dust related
complaints in relation to Project vehicles.
In-Migration
Strategies to minimise impacts of in-migration are discussed in Chapter 15.
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14.3.2 Operations Phase
Avoidance, mitigation and management measures for health during operations will be consistent with those
outlined for the pre-construction and construction phase, where applicable.
Community health and safety indicators will be developed in consultation with local authorities. These will be
monitored as part of the biennial socio-economic surveying for villages in the vicinity of the Project. Management
measures will be adapted accordingly.
14.3.3 Decommissioning and Closure Phase
The Company plans to construct an earth berm on Project roads within the PDA to prevent unauthorised access
and maintain community safety. For Project access roads that will be transferred to local governments or
communities, the Company will consult and negotiate with the relevant parties and stakeholders to ensure that:
Access to remaining mine facilities (e.g. TMF) that may pose a safety risk to the public are adequately
secured; and
Operation and maintenance requirements are clearly defined.
14.4 Monitoring Measures
Table 14-1 presents the key monitoring measures related to community health, food security and safety for the
Mako Gold Project throughout all phases of development. These will be incorporated into the detailed monitoring
programmes prepared by the Company and its contractors.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 14-1 Register of Social Monitoring Measures – Health and Safety
Aspect /
Impact
Monitoring
measure
Phase Method Parameters Frequency Location
Traffic
management
Refer to Chapter 9 (Roads and Transport).
Noise, dust
and vibration
nuisance
Dust and noise
inspection
investigation and
monitoring
All
Project
phases
Review of grievance
register maintained by
the Company
Community
complaints logged
via Grievance
mechanism
As required
Project
affected
villages
(refer to
monitoring
sites
shown in
Figure A1,
Appendix
C)
Monitoring of noise,
vibration and air quality
impacts
Noise limit and air
quality limit
exceedances at
nearby sensitive
receptors
Threshold limits
provided in Table 2-4
to Table 2-10
Introduction /
increased
transmission
of disease
(e.g. malaria,
STIs, etc.)
Survey
All
Project
phases
Monitoring of health in
the local community and
workforce
Health indicators (to
be developed in the
next phase)
Every two
years
Project
affected
villages
Increased
injuries and
fatalities
Monitoring
All
Project
phases
Grievance register
Training records (i.e.
attendance sheets,
Number of transport
related incidents /
grievance claims
Quarterly Project-
wide and
affected
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Aspect /
Impact
Monitoring
measure
Phase Method Parameters Frequency Location
photos, material used,
etc.)
Visual inspection and
audit records
Consultation record
sheet and database
Number of worker
training conducted
Number of
community safety
incidences or
livestock losses
associated with
restricted areas
Number of
community
consultations /
awareness sessions
conducted
villages
Food security
and nutrition Survey
All
Project
phases
Monitoring of nutrition in
the local community and
workforce
Nutritional indicators
in the local
community (e.g.
availability of food,
food supply options,
prevalence of
undernourishment,
agricultural / food
production etc.)
Every two
years
Project
affected
villages
Psychosocial
impacts
associated
with general
lifestyle and
quality of life
changes
Monitoring
All
Project
phases
Project Grievance
mechanism
Logged community
complaints Quarterly
Project
affected
villages
All
Project
phases
Socio-economic
monitoring/surveys
In-migration and
employment
statistics
Every two
years
All
Project
phases
Training and induction
records of Project staff /
contractors and the local
community
Number of
environmental and
social induction
programmes for the
workforce / cultural
awareness training
for the community
Records (i.e.
attendance sheets)
Quarterly
All
Project
phases
Socio-economic
monitoring/surveys
Socio-economic
conditions
Every two
years
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15 IN-MIGRATION
15.1 Objectives
The Mako Gold Project will generate employment and other economic opportunities that may lead to an increased
population in the socio-economic area surrounding the PDA, particularly during construction.
The Company is committed to local recruitment and the Company’s employment policy will assist in minimising
the influx of labour from outside the vicinity of the immediate Project region.
15.2 Context
Internal migration is common in Senegal. The primary reasons for migration within the country include economic
development, employment opportunities and family affairs, followed by moving due to a shortage of food,
shortage of land, or lack of water. In addition to permanent migration (i.e. moving to establish long-term
residency, establish crops, etc.), the area in the vicinity of the Project experiences some seasonal migration
primarily for artisanal mining. The dry season is peak time for seasonal migrations.
In-migration resulting from the employment and economic opportunities created by the Project is likely to be
greatest during Project construction. The extent of in-migration to each village will depend on the geographical
location and accessibility of each village. Villages such as Mako and the Niemenike cluster, which are located on
the RN7, are at the highest risk of potential impacts from Project-induced in-migration. If they experience a
population growth rate similar to the rate experienced by Sabodala village with the development of the nearby
Sabodala Mine, it is conceivable that the population could easily double within the life of the Project.
Migration rates in the vicinity of the PDA are currently moderate. Most of the Project-affected villages have
experienced some permanent migration, as well as a relatively large number of seasonal migrants. Most Project-
affected villages also reported a greater degree of in-migration compared to out-migration. Villages such as Mako
and the Niemenike cluster have had relatively high rates of recent migration and population growth (4% per
annum from 2004 to 2014) which is already putting some strain on local infrastructure and natural resources.
15.2.1 Pre-construction and Construction Phase
In the absence of management measures, in-migration into the Project area could potentially have the following
consequences (although note that there is already a certain level of seasonal migration, so many of the issues
below are likely to be already present to some degree):
Strain existing social services such as health, security and education facilities which are limited in the
Project-affected villages. This is a particular risk for Mako and the Niemenike cluster as they are already
experiencing some strain from existing migration;
Increased demand for (and reduced availability of) land, natural resources and agricultural produce by
migrant population. This is a particular risk for Mako and the Niemenike cluster as they are already
experiencing pressure on timber resources;
Increased demand for (and reduced availability of) water supply and pressure on water infrastructure. This is
a particular risk for Mako and the Niemenike cluster as they are already experiencing pressure on water
infrastructure;
Localised increase in cost of goods and services;
Reduced employment opportunities for original residents;
Increased risk of introduced diseases, especially those transmitted sexually. This is also likely to be a
particular risk for Mako as the largest village in close proximity to the Project;
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Increased solid waste generation in Project-affected villages;
Increased improper disposal of human waste and exacerbated unsanitary conditions and water quality
issues in Project-affected villages;
Impacts on priority species and habitats in the PNNK and potential for increased poaching;
Social disharmony and conflict between original residents and incoming migrants;
Changes to the social structures of local communities including an increase in sex workers; and
Gender imbalance, as the migrant population is likely to be predominantly male.
15.2.2 Operations Phase
Potential impacts of in-migration during the operations phase are likely to be similar to that of the pre-
construction and construction phase, however the magnitude of the impact may decrease with stabilisation of in-
migration levels.
15.2.3 Decommissioning and Closure Phase
During closure, a net out-migration may occur, as people leave to seek other employment opportunities.
15.3 Management and Mitigation Measures
Migration into the area will be controlled in a manner that does not compromise the development of the Project
by introducing new environmental and social issues.
The Company’s general approach to minimising and mitigating potential in-migration impacts will be to
incentivise in-migration to Kedougou, dis-incentivise in-migration to the local area, and increase the local capacity
to absorb in-migration in a manner that maximises the potential benefits to local communities.
A Local Economic Participation Plan (LEPP, Volume D), In-Migration Guidance Note (rePlan, 2015b) and Worker
Accommodation Guidance Note (rePlan, 2015a) have been prepared for the Project which together plan for
Project development to occur, where possible, in a way that allows Project benefits to accrue to local communities.
The LEPP includes measures that will assist in reducing the impacts of in-migration. Clear communication and
consistent application of these measures, and strict enforcement of hiring rules in particular, should serve to dis-
incentivise in-migration related to direct project employment.
In addition, the Company will establish a Local Enterprise Development Programme and a Local Procurement Policy
which will provide support for the growth of enterprises, including measures to maximise the opportunity for local
suppliers to participate in the supply chain for the Project. The preferred implementation approach is to work with
local partner organisations that have existing programmes and who have a mandate to support local enterprise
development. The priority for implementation will be to emphasise scaling up of existing activities rather than to
start new activities.
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15.3.1 Pre-construction and Construction Phase
The following policies and practices will be implemented by the Company to minimise the adverse impacts of
Project-induced in-migration in the vicinity of the PDA:
Work with local authorities to minimise the potential impacts on in-migration (e.g. security, education and
awareness campaigns against drug and alcohol abuse, supporting health services) to monitor demand and
resources;
Continual public disclosure and consultation with the local community during all stages of the Project;
Implement measures provided in the Local Economic Participation Plan (LEPP, Volume D), which prioritise
local employment, local procurement and local economic development. A “Local Economic Participation
Committee” with representatives from affected villages will be established in consultation with local
authorities and the community. Other measures include (but are not limited too):
» Implementation of a recruitment policy which prioritises local employment;
» Recruitment for unqualified positions to be restricted to residents in Tomboronkoto Commune only;
» Preferential access to skills upgrading courses for local and regional residents, based on Project skill
requirements;
» Provision of training as part of a Local Enterprise Development Programme to assist in developing local
skill levels and entrepreneurship that is not solely dependent upon the Project; and
» Local Procurement Plan: Prioritisation of local procurement and provision of assistance for businesses to
participate;
Increase the capacity of Tomboronkoto Commune, and Mako and Niemenike in particular, to plan for and
absorb in-migration in a manner that improves quality of life and maximises economic benefit. This may
include providing assistance to the Municipal Council to support the preparation of the Commune
Development Plan;
Work with local authorities and communities to restrict the development of new habitation areas within the
PDA and other areas of the mining concession where this could present risks to human safety and/or the
operational security of the Project;
Implement the measures in the In-Migration Guidance Note (rePlan, 2015b), which include:
» Use the pre-construction and construction phase as a training phase for local workers and businesses to
increase their ability to participate / bid for operations phase employment opportunities;
In partnership with local authorities, control illegal mining where this occurs within the proposed Mining
Concession;
Establish a social and environmental induction programme to educate outside contractors on the cultural,
social and environmental sensitivities of the Project location. Conversely, employees who are local
residents will receive cultural awareness training to encourage understanding of incoming workers;
Implement measures to incentivise land and natural resource use in areas that are not likely to impact on
the PNNK, threatened species or habitats; and
In partnership with relevant technical services and the Commune Council, improve village water
infrastructure and management systems to address the impact of Project-induced in-migration.
The following policies and practices will be implemented by the Company to minimise the adverse impacts of
influx of workers for the Project:
Implement the measures in the Worker Accommodation Guidance Note (rePlan, 2015c), which include:
» Incentivise the in-migration of Project staff to Kedougou where this has potential to result in adverse
impacts to Project-affected villages;
» Provide transportation from Kedougou and shorter shifts (e.g. 8 hours) to enable workers to live and
commute from Kedougou without suffering from fatigue;
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» Provision of short-term loans to workers recruited locally for the construction of new rooms or
separate buildings for rental to Project employees from outside Kedougou Region;
» Development of a homeownership programme to provide new, permanent housing for Project
employees from outside Kedougou Region; and
Working with national and regional government to encourage the distribution of Project-related government
revenues to local communities to improve physical infrastructure and services.
Community Development
The Company will also support other programmes that contribute to local economic development and mitigation
of in-migration, including providing support to the Tomboronkoto Council in rural and urban land use and
development planning, and implementing a Social Investment Programme. These include:
Continued community development investment focused on key areas (e.g. water resources, health and
education services);
Preparation of training programmes relevant to the Project’s closure to help people transition to alternative
employment as discussed in the LEP;
Support for the Tomboronkoto Council and work with the local community to develop formal land use and
urban development plans (e.g. the Commune Development Plan); and
Ensuring that revegetation and agricultural intensification activities increase the ability of local
communities to sustainably maintain access to natural resources and reduce stress on the nearby PNNK.
In-migration monitoring
The Company will undertake socio-economic surveying and review of census data for Project affected villages to
be conducted over the Project life to understand the extent of population growth and any related impacts,
including but not limited to the effect it has on water quality and availability.
15.3.2 Operations Phase
Operations mitigation measures for in-migration will be as per the pre-construction and construction phase as
outlined above, where applicable.
15.3.3 Decommissioning and Closure Phase
No additional management and mitigation measures are expected to be required during the decommissioning and
closure phase.
15.4 Monitoring Measures
The Company will develop Project-specific KPIs for employment of local and national workers and associated
training. Table 15-1 summarises the key monitoring measures that will apply for in-migration associated with the
Mako Gold Project during all phases of development. These will be incorporated into the detailed monitoring
programmes prepared by the Company and its contractors.
Relevant guidelines and standards applicable to the Project are specified in Section 2.4 and the Registers of
Environmental and Social Management and Monitoring Commitments in Chapter 18 of this Plan.
Table 15-1 Register of Social Monitoring Measures – In-Migration
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Socio-
economic
and
livelihood
changes in
the vicinity
of the
Project
Socio-economic
conditions (e.g.
demographics,
livelihoods,
health etc.)
All Project
phases Household surveys
Demographic
indicators
Population growth
and in-migration
Income and
expenditure
indicators, incidence
of poverty
Livelihoods and
employment
indicators
Housing and assets
Education
Health and nutrition
indicators
Every two
years
Villages in
the vicinity
of the PDA
Monitoring of
regional socio-
economic
conditions for
Kedougou
All Project
phases
Socio-economic
monitoring/surveys
Similar indicators to
the above obtained
through review of
publically available
reports or in
consultation with
local authorities
Annually Kedougou
Region
Economic
Developmen
t and
Employment
Monitoring of
effectiveness of
local recruitment
All Project
phases
Employment records
Training register/records
Local workforce
statistics (including
employment by
contractors)
Number of training
sessions
Quarterly Project-
wide
Monitoring of
effectiveness of
local
procurement
All Project
phases
Local supplier and
procurement
records/database
maintained by the
Company
Training register/records
Local goods and
services procured by
the Company
Local suppliers used
by the Company
Number of training
session for suppliers
Quarterly Project-
wide
Monitoring of
local economic
pilot
programmes
All Project
phases
Socio-economic
monitoring/surveys
Indicators will be
developed in
consultation with the
community and
government
Quarterly
Villages in
the vicinity
of the
Project
Community
Relations
Review of
records
All Project
phases
Grievance register
Consultation record
sheet and database
Logged grievances
and resolutions Quarterly
Project
affected
villages
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16 BIODIVERSITY MANAGEMENT
16.1 Objectives
The key objective related to biodiversity management for the Mako Gold Project will be to minimise Project
impacts on nearby protected areas (i.e. PNNK) and local terrestrial and aquatic flora and fauna (particularly local
and international conservation significant species). Where biodiversity impacts will be unavoidable, the Company
will implement an offset programme that meets with government, local community and other stakeholder
expectations, to ensure a net gain of biodiversity values is achieved upon closure.
16.2 Context
In summary, key biodiversity sensitivities within and near the Project Area that will be protected from potential
Project impacts include:
Niokolo-Koba National Park (Parc National du Niokolo-Koba, PNNK), a National Protected Area and World
Heritage site located approximately 1 km west of the PDA;
Communal Nature Reserve (Réserve Naturelle Communautaire, RNC) located near Niemenike (though not
considered to be part of the State network of protected areas in Senegal and it is a not a priority biodiversity
feature);
Local flora and fauna, particularly local populations of priority species (Critically Endangered or Endangered
species according to IUCN listing) recorded within and near the PDA, including:
» Priority fauna species, e.g. West African chimpanzee (Pan troglodytes spp verus, CR), African Wild Dog
(West Africa subpopulation), Western Giant Eland (subspecies), and Lion (West African subpopulation);
» Priority flora species - Lepidagathis capituliformis, Scleria chevalieri and Tephrosia berhautiana.
Habitats of high conservation value, including the Bowal and Gallery forests and other priority biodiversity
features (which include species which are not critical habitat qualifying features but where their
conservation is considered significant at the regional and National scales), e.g. African elephant (Loxodonta
africana – VU), Hooded vulture (Necrosyrtes monachus – EN), and White-backed vulture (Gyps africanus –
EN); and
Downstream aquatic habitat and biodiversity values of the Gambia River and tributaries, including the
restricted range fish species Barbus dialonensis (a priority species).
Significant biodiversity impacts have been summarised in the following subsections. The ESIA (Volume A) provides
a full list of the priority biodiversity species and features relevant to the Project, including a detailed discussion of
potential Project impacts and relevant management and mitigation measures for the Company to adopt.
16.2.1 Pre-construction and Construction Phase
The most significant impact on habitat and flora associated with the Project is expected to be during this phase
from land clearance and site preparation for Project components and establishment of Project road infrastructure
and upgrades, including:
Removal of vegetation and habitat for Project components (approximately 216.22 ha of natural vegetation
in total, mainly tree savannah and woody savannah bamboo mosaic);
Habitat fragmentation and degradation from vegetation removal;
Project related access to forested areas associated with construction of new access roads making these
areas more readily accessible for forest resource extraction (e.g. increased hunting, timber, NTFP collection)
(refer to ESIA, Volume A, Chapter 10);
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Displacement of local populations of priority species (e.g. West African chimpanzee) within the PDA; and
Introduced non-native and invasive species, including weeds and pests.
The Project will result in both temporary and permanent loss of vegetated areas. However, all natural vegetation
and habitat to be removed for the Project components have been previously disturbed by anthropogenic activities
(e.g. artisanal mining, burning, land cultivation, and over-exploration of forest resources), at varying levels.
No key priority habitat will be removed for Project components. There will be no direct impact on the vegetation
within the PNNK as none will be removed for the Project.
16.2.2 Operations Phase
Many impacts experienced during the previous phase will continue in varying degrees and intensities during
Project operations. Clearance activities will be scaled back, however noise, vibration, airblast and dust impacts will
likely intensify, particularly from blasting and excavation of the Mine Pit. Local fauna populations within the PNNK
adjacent to the Mine Pit may be displaced by noise, vibration and airblasts. It is anticipated that local fauna within
the PDA, including priority species, will disperse into surrounding areas (especially the PNNK) during construction,
and all priority species will avoid the PDA during blasting and other operational activities. As such, the potential
impact on behaviour and the stress response will most likely be minimal.
Another significant biodiversity impact will likely be the potential physical barrier posed by the Mine and ancillary
facilities (e.g. access roads) to local fauna movements, particularly for breeding exchange of female chimpanzees.
In addition, although the Project has been designed for ‘zero discharge operations’, there may be inadvertent
impacts on downstream water quality and aquatic biodiversity values. Project water contaminated with cyanide
or high levels of salinity can be particularly hazardous, and fatal to some species (at certain concentrations), e.g.
avifauna. The WSD and TMF may pose a physical and chemical hazard to fauna, such as drowning, or poisoning
from drinking saline water or cyanide contaminated tailings water from the TMF (particularly for avifauna).
Changed behaviour of local fauna may also occur from sustained night lighting within the PDA (e.g. the Process
Plant, which will operate 24 hours).
16.2.3 Decommissioning and Closure Phase
Most impacts experienced during the previous phases will cease during the decommissioning and closure phase.
The most likely impacts will be similar to site preparation impacts during the Pre-Construction and Construction
Phase, including:
Significant erosion of disturbed surfaces yet to be stabilised and surface runoff sediment transport, leading
to water quality issues in the local catchments;
Dust and exhaust emissions from earthworks to reinstate pre-existing landforms, revegetation of land, and
removal of paved areas and existing infrastructure; and
Noise emissions from combustion engines of diesel generators, trucks, dozers, and hydraulic excavators.
If unmitigated, the greatest potential source of impact would be to water quality. Potential contaminants in
discharges to the receiving environment, particularly from the TMF, include: cyanide, metals (particularly Cu and
Mn), AMD, nutrients, saline water and suspended sediment. In the event of a contaminated discharge, impacts on
flora and will be the same as those outlined in the case of an accidental release during the Operation Phase.
16.3 Management and Mitigation Measures
The Mako Gold Project will apply IFC Performance Standards 6 to its operations where they are more rigorous than
local regulation as an appropriate benchmark of international good practise for the Project. A Project-specific
Biodiversity Action Plan (BAP, Volume C) has been prepared that will outline detailed plans and procedures for the
protection and management of biodiversity (aquatic and terrestrial) issues for the Mako Gold Project. A CEMP will
be developed in line with this ESMMP prior to construction. Key biodiversity measures and strategies detailed in
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the BAP and Offset Strategy will be incorporated into relevant procedures, training, and instructions for the
workforce and contractors, as relevant to their roles and responsibilities.
During every stage of the Project, the Company will implement the mitigation hierarchy to avoid, mitigate,
manage, restore and offset impacts on biodiversity. The Company will adopt a net-gain approach, where impacts
to biodiversity and conservation values are compensated through environmental benefits (e.g. biodiversity
offsets).
16.3.1 Pre-construction and Construction Phase
The Company will implement relevant SOPs provided in Appendix A to manage potential impacts generated
during pre-construction and construction of the various Project components, including those specific for
biodiversity management.
Vegetation, flora and protected areas management
To minimise inadvertent impacts to the PNNK from mining activities, the Company will avoid land disturbance
within a 1 km buffer zone of the PNNK. The Company will adopt measures outlined in the BAP (Volume C) to avoid
or manage temporary and permanent impacts on flora, fauna and protected areas during pre-construction and
construction, including:
The footprint of the Project components have been minimised to limit vegetation clearance to the extent
practicable. The Company will adopt the relevant vegetation clearance measures specified in SOP09: Land
Clearance and Soil Stockpile (Appendix A), where appropriate;
Access to the PNNK and buffer zone by Project staff to be restricted and subject to approval from the DPN;
Ban Project staff, as a condition of employment, from hunting, buying or trading wildlife as well as
collecting timber and NTFPs to help conserve existing fauna and forest resources (e.g. food for wildlife);
Environmental education and awareness programmes for Project staff and contractors as relevant to their
roles and responsibilities (e.g. through staff inductions) to improve their understanding of conserving
threatened species and forest resources for the environment and local communities. This will also ensure
that the penalties and Project ban regarding hunting, wildlife trade and the collection of other forest
resources are widely known;
The requirements for land disturbance permits prior to any vegetation clearance, in accordance with SOP09
(Appendix A). Environmentally sensitive areas (e.g. critical habitat, PNNK boundary) will be clearly marked
as ‘No Go Areas’;
In areas to be cleared, identification and retention or relocation of restricted-range (Lepidagathis
capituliformis, Scleria chevalieri and Tephrosia berhautiana), threatened flora and important fauna resources
(e.g. baobab trees), where practicable. Seed collection and propagation of priority flora species identified in
the Project Area will be included in the inventory of plants used for Project revegetation activities;
Removal of identified Bowal (where this provides habitat to restricted-range flora species) and gallery forest
habitat (priority habitat for West African chimpanzee nesting sites) to be avoided where possible;
Invasive weed prevention protocol implemented as per SOP9 (particularly to prevent the spread of Mimosa
pigra), including washdown procedures and site access control (along designated ingress/egress routes) for
vehicles entering and exiting the PDA, limiting vehicle movements between areas where Mimosa pigra is
confirmed to occur and unaffected areas, and use of non-invasive local species for revegetation;
Progressive rehabilitation and revegetation undertaken as soon as possible throughout the life of the
Project to minimise the impact of land clearance as per the RCMCP (Volume E);
Bushfire controls implemented, including Project ban on open-burning of wastes, specific emergency
response procedures developed for managing bushfires, and establishment of fire breaks (where required);
Consult with local authorities to minimise the impact of in-migration on natural resource exploitation
(including hunting); and
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Periodic monitoring of habitat and key terrestrial and aquatic wildlife species to be conducted as part of the
BAP (Volume C) to assess whether any further mitigation or management measures are required.
In addition, Chapter 9 (Road and Transport) details specific measures for minimising potential impacts on wildlife
from Project related transportation, including emergency response systems for spills, and speed limits through
known sensitive areas (e.g. West African chimpanzee wildlife crossings).
Fauna management
The Company will adopt additional measures to mitigate fauna impacts, including:
Primary sources of water potentially contaminated with cyanide and other pollutants (e.g. waste
management facilities, Process Plant and TMF, hazardous chemicals and fuel storage areas) have been sited
within a single catchment away from major drainage lines with primary and secondary containment
facilities in place to prevent potential discharge into the receiving environment. These sites will have
fencing constructed to prevent access by fauna;
Security fencing provided around the site perimeter of the TMF to restrict livestock and local wildlife from
accessing this area;
Mandatory reporting system to record reportable incidents involving wildlife (and livestock), including
encounters of wildlife (i.e. injured and priority species) and observation of poaching, illegal wildlife trade or
logging. Relevant government authorities will be notified as necessary;
Adherence to the Injured Wildlife Protocol by staff and contractors if injured or dead wildlife is found or in
the event of an accident (e.g. fauna move away following vehicle collision), which includes the following
steps:
» Species identification;
» Procedures for the safe management of injured or dead wildlife including minimising human contact;
and
» Mandatory reporting of wildlife incidents that includes road accidents (e.g. collision with wildlife or
livestock) for all Project workers and contractors;
Operation of noisy machinery to be avoided at dusk, dawn and night;
Project staff to avoid initiating contact with fauna to minimise the risk of disease transfer and disturbance;
Project staff and contractors banned from hunting, buying or trading wildlife, fishing, collecting timber and
non-timber forest products and from entering the PNNK;
An ecologist will be on call during habitat clearance work to provide assistance / advice regarding any
biodiversity issues if required;
Priority species-specific monitoring and management (e.g. for West African chimpanzees) to be undertaken
as appropriate, as per the BAP (Volume C);
Implement relevant fauna management measures for night lighting detailed in SOP11: Lighting and Visual
Amenity Management, where necessary; and
Adherence to SOP02: Water Quality and Pollution Management for water quality and pollution
management throughout the lifespan of the Project to minimise the risk of adverse impacts to aquatic
fauna and habitats.
Project Induced In-migration
The Company will consult with local authorities to minimise the impacts of Project-induced in-migration on
chimpanzees and their habitats arising from hunting and the increased exploitation of timber and non-timber
products. The Company will also collaborate with PNNK area managers to ensure indirect impacts to the PNNK are
adequately mitigated.
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Biodiversity offset
To ensure ‘no net loss’ of regional and local biodiversity values, the Company has developed a Biodiversity Offset
Strategy to provide a compensatory mechanism to offset adverse impacts that cannot be avoided, mitigated
and/or managed. The Biodiversity Offset Strategy will be designed through a process of stakeholder engagement
and will focus on the conservation of priority species and habitats including the protection of the PNNK.
Refer to the BAP (Volume C) for further details of the strategy.
16.3.2 Operations Phase
The Company has designed for the Project to be a ‘zero discharge operations’ to avoid downstream water quality
impacts from environmental release of water potentially contaminated with pollutants such as cyanide, heavy
metals, nutrients and salinity. Additionally, concentrations of cyanide in tailings water will be regularly monitored
for consistency with relevant standards (i.e. ICMI Cyanide Code, 2014).
The management measures and strategies specified for the pre-construction and construction phase management
will continue to be applied during Project operations, where relevant. Additional biodiversity management
measures that will be applied during Project operations include:
Management of habitats and buffer zones adjacent to and within the PDA to minimise disturbance and
vegetation clearance (e.g. from poaching, exploitation of natural resources);
Establishment of a checkpoint at the entrance to the PDA to ensure no unauthorised entry;
Continual improvement of mine blast associated noise, vibration and airblast management measures to
minimise fauna impacts; and
Adaptive priority species-specific monitoring and management, as necessary.
16.3.3 Decommissioning and Closure Phase
Upon decommissioning and closure, the TMF will be rehabilitated and surface water from the facility (as well as
inputs from the WRD and Mine Pit overflow) will discharge from a constructed spillway into Badalla Creek
downstream of the facility, upstream from the PNNK.
In addition to the SOPs provided in Appendix A and the continued implementation of relevant measures listed
above, the Company will adopt the following vegetation mitigation measures as per the RCMCP (Volume E) in
accordance with the Forest Code and other legislative requirements:
Creation of natural filtering systems (e.g. mini-wetlands), where required;
Progressive revegetation and rehabilitation of all cleared/disturbed areas, unless required for community or
Government use;
Use of artificial filtering systems on discharge water;
Closure criteria for revegetation and vegetation offsets will be met; and
Monitoring conducted in rehabilitated areas, in order to assess the success of restoration of habitat.
16.4 Monitoring Measures
Table 16-1 summarises the preliminary monitoring measures that will apply for biodiversity management in
relation to the Mako Gold Project. The preliminary detailed biodiversity monitoring programme will further be
refined as more biodiversity management and offset information becomes available, and will be incorporated into
relevant documents for the Company and contractors to adhere to for the pre-construction, construction,
operation, and decommissioning and closure of the Project.
Refer to Biodiversity Action Plan (Volume C) for further details on the detailed biodiversity monitoring
programme, including specific monitoring sites for the Project. Relevant guidelines and standards applicable to
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the Project are specified in Section 2.4 and in the Registers of Environmental and Social Management and
Monitoring Commitments in Chapter 18 of this Plan.
Table 16-1 Register of Environmental Monitoring Measures– Biodiversity Management
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Terrestrial
habitat and
biodiversity
Terrestrial
habitat and
biodiversity
Camera
trapping
All
Project
phases
Review of data collected
from camera trapping
Changes in the location
of habitat use
Changes in frequency
of habitat use
Trigger for adaptive
management:
Decline in habitat use
Traps
checked
every two
months
Refer to
Biodiversit
y Action
Plan
(Volume C)
Targeted
chimpanzee
surveys
All
Project
phases
Review of data collected
from targeted
chimpanzee surveys
Changes in the number
of fresh, recent, old and
ancient nests
Changes in nesting
range
Changes in habitat
usage
Trigger for adaptive
management:
Significant decline in
the number of fresh /
recent nests
Significant declines in
maximum number of
nests per nesting site
Reduction in nesting
range
Census
undertaken
every two
years during
the wet and
dry seasons
Targeted
hippopotami
surveys
All
Project
phases Review of data collected
from targeted
hippopotami surveys
Changes in the total
number of hippopotami
Changes in the
maximum number of
hippopotami per group
Changes in seasonal
habitat use
Trigger for adaptive
management:
Significant reduction in
hippopotami numbers
Reduction in habitat
use between seasons
Census
undertaken
once a year
over a 3 days
period during
wet and dry
seasons
Vulture nest
surveys
All
Project
Review of data collected
from vulture nest surveys
Changes in the number
of active vulture nests
Changes in the number
of vulture nesting sites
Trigger for adaptive
Twice a year
during the
optimum
breading
season,
supplemente
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
Terrestrial
habitat and
biodiversity
phases management:
Significant decline in
the number of active
nests
Decline in sites
d by camera
trapping
Priority flora
survey
All
Project
phases
Assessment of presence
/ likely absence of key
flora species
Records of
presence/absence of
key flora species
Beginning of
the wet
season when
grasses and
herbs are in
flower
Priority flora
monitoring
All
Project
phases Assessment of priority
flora monitoring
Dust levels
High level of dust on
individuals and signs of
plant stress
Changes in species
abundance
Trigger for adaptive
management:
Elevated dust levels
High coverage of dust
on priority flora and
bowal habitat
Monthly
checks during
construction
Quarterly
checks during
operations
Ongoing for
dust
monitoring
Invasive
species
reporting and
checks
Pre-
constru
ction,
Constru
ction,
Closure
Assessment of invasive
weed monitoring
New record of invasive
species i.e. Mimosa
Pigra
Trigger for adaptive
management:
Increased number of
infested sites
Bimonthly
during pre-
construction,
construction,
and closure
Quarterly
during
operations
Reportable
incidents
involving
wildlife (and
livestock),
including
encounters of
wildlife (i.e.
carcass,
injured and
priority
species) and
observation of
poaching,
illegal wildlife
All
Project
phases Mandatory wildlife
incident reporting system
for Project employees
and contractors
Relevant government
authorities will be notified
as necessary
Reportable information
includes:
- Species details, any
distinguishing features
(e.g. carcass found
near the TMF or road
side);
- Location / GPS data;
- Time and date;
- Weather conditions;
- Photograph, if
possible; and
- Any measures or
actions undertaken, if
applicable.
Trigger for adaptive
Ongoing
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Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
trade or
logging.
management:
- Changes in the
number of deaths
- Confirmation of
disease outbreak
- Number of confirmed
poison cases
Monitoring of
vegetation
clearance
Pre-
Constru
ction,
Constru
ction
Routine checks to ensure
vegetation clearing is
confined to defined areas
of disturbance, vehicles
use designated access
routes, and any sensitive
environmental areas (i.e.
‘No Go Areas’) flora
specimens to be retained
are clearly marked (e.g.
flag/tape).
Land disturbance register
Extent of vegetation
cleared for the Project
During
vegetation
clearing
activities
Project-
wide
Aquatic
habitat and
biodiversity
Macro-
invertebrate
survey and
bio-indicator
water quality
assessment
All
Project
phases Aquatic fauna and habitat
monitoring as per
SOP02.18
Changes in water
quality identified by the
macro-invertebrate bio-
indicator assessment
Trigger for adaptive
management:
Significant decline in
macro-invertebrate
abundance and
diversity
Significant changes in
bio-indicator species
Reduction in the
biological health of the
Gambia River
Threshold limits
provided in Table 2-5 to
Table 2-7
Bi-yearly
during the dry
season over
a 5 day
period
Refer to
monitoring
sites
shown in
Figure A3
(Appendix
C) and
Biodiversit
y Action
Plan
(Volume C)
Drift net
survey
All
Project
phases
Aquatic fauna and habitat
monitoring as per
SOP02.18
Changes in the
diversity, abundance
and catch per unit effort
of fish
Changes in the
proportion captured
juvenile and adult fish
Trigger for adaptive
management:
Significant decline in
Bi-yearly
basis during
the dry and
wet seasons.
Each survey
conducted
over a 5-day
period
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 150
Aspect /
Impact
Monitoring
Measure
Phase Method Parameters Frequency Location
the diversity,
abundance, CPUE of
fish
Significant decline in
adult fish
Impingement
checks
All
Project
phases
Review of aquatic
monitoring data collected
High quantity of biotic
impingement matter
Weekly for
one month
following pipe
installation,
subsequent
quarterly
checks
Rehabilitatio
n
Routine
monitoring of
rehabilitation
areas to
assess the
success of
restoration
measures
All
Project
phases
Land rehabilitation
register
Monitoring records of:
- Area
revegetated/rehabilitate
d;
- Survival rate of
planted seedlings by
species type and
replanting
requirements;
- Native versus non-
native plant
establishment; and
- Photographs.
Ongoing
Project-
wide (refer
to the
RMCP,
Volume D)
Water
quality
(ambient)
Routine
ambient water
quality
monitoring
Pre-
constru
ction,
Constru
ction
Visual checks for
sedimentation, oils and
grease
Project compliance Weekly
Discharge
points
(refer to
monitoring
sites
shown in
Figure A2,
Appendix
C)
All
Project
phases
Refer to SOP02.12
Field parameters and
laboratory testing as
per SOP02.12
Trigger for adaptive
management:
Water quality exceeds
applicable compliance
limit
Threshold limits
provided in Table 2-5 to
Table 2-7
Monthly
Upstream
and
downstrea
m of
Badalla
Creek and
Gambia
River (refer
to
monitoring
sites
shown in
Figure A2,
Appendix
C)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 151
17 ESTIMATED COSTS
The Company is committed to providing sufficient resources to ensure the successful implementation of the
environmental and social management and monitoring of the Mako Gold Project as identified in the ESMMP. The
Company will also ensure that, where applicable, contractors also include sufficient resources for the
environmental management of their activities.
The Company currently invests significant expenditure on environmental and social management and monitoring
for their Mako exploration activities. The development of the Mako Gold Project will lead to a significant increase
in the overall the Company environmental and social management operating budget.
A preliminary analysis of environmental and social management costs associated with the construction and
management of the Mako Gold Project has been undertaken.
Table 17-1 displays a conceptual Environmental and Social Management and Monitoring Budget. The proposed budget
includes capital cost, annual operating costs, and a closure cost (over five years). The closure budget will need to
be refined based on the result of closure investigations.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 152
Table 17-1 Conceptual budget for social and environmental management and monitoring for the Mako Gold Project during pre-construction, construction, operations, and decommissioning /
closure phases (FCFA ±20%) (converted from USD: 1USD = 587.706 FCFA, 9/9/2015)
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
Staffing Costs
Human Resources (Environment and Social Dept.)
- 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 129,295,3
20 129,295,
320 129,295,
320 129,295
,320 129,295,320
3,555,621,300
Sub-total 0 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 323,238,3
00 129,295,3
20 129,295,
320 129,295,
320 129,295
,320 129,295,320
3,555,621,300
Capital Costs
Installation of groundwater monitoring bores
- 158,680,6
20 - - - - - - - - - - - - - 158,680,620
Establishment of environmental monitoring and laboratory equipment
- 88,155,90
0 - - - - - - - - - - - - - 88,155,900
Maintenance of environmental monitoring and laboratory equipment (10% capital)
- - 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,59
0 8,815,59
0 8,815,5
90 8,815,590
114,602,670
Sediment control infrastructure / materials
Not costed - to be included in mine design 0
TMF control measures for fauna (e.g. fencing)
Not costed - to be included in mine design 0
Sub-total 0 246,836,5
20 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590 8,815,590
8,815,590
8,815,590
8,815,590
8,815,590
361,439,190
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 153
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
Environmental and Social Management Systems
Environmental and social monitoring protocols
23,508,240
11,754,120
11,754,120
- 2,938,530 - 2,938,530 - 2,938,530 - - - - - - 55,832,070
Preparation / Update of Monitoring Manual, CEMPs and Operations ESMMP
14,692,650
14,692,650
- - - - - - - - - - - - - 29,385,300
Regular updates of environmental and social management plans
- - 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0
Refer Closure Costs
141,049,440
Internal audits / performance review
5,877,060
5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 58,770,600
External audits 23,508,2
40 23,508,24
0 23,508,24
0 23,508,24
0
23,508,240
23,508,24
0 141,049,440
Annual Sustainability Report
- 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 5,877,060 - - - - - 52,893,540
Capacity building for local authorities, including Regional Environmental Monitoring Committee
- 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,18
0 17,631,1
80 17,631,1
80 17,631,
180 17,631,180
246,836,520
Sub-total 67,586,1
90 79,340,31
0 82,278,84
0 70,524,72
0 49,955,01
0 47,016,48
0 73,463,25
0 47,016,48
0 49,955,01
0 70,524,72
0 17,631,18
0 17,631,1
80 17,631,1
80 17,631,
180 17,631,180
725,816,910
Environmental Management and Mitigation
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 154
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
Hazardous Facility Registration (ICPE) and Emergency Response Plan (POI)
11,754,120
11,754,120
11,754,120
- - - - - - - - - - - - 35,262,360
Environmental monitoring, laboratory analysis and consumables
- 117,541,2
00 117,541,2
00 117,541,2
00 117,541,2
00 117,541,2
00 117,541,2
00 117,541,2
00 88,155,90
0 88,155,90
0 58,770,60
0 58,770,6
00 44,077,9
50 29,385,
300 29,385,300
1,219,489,950
Finalisation of Biodiversity Action Plan (BAP)
14,692,650
29,385,300
14,692,650
- - - - - - - - - - - - 58,770,600
Supplementary pre-construction baseline surveys
20,569,710
11,754,120
- - - - - - - - - - - - - 32,323,830
General Biodiversity Monitoring including targeted fauna surveys
8,815,590
8,815,590 17,631,18
0 8,815,590
17,631,180
8,815,590 17,631,18
0 8,815,590
17,631,180
8,815,590 17,631,18
0 8,815,59
0 17,631,1
80 8,815,5
90 17,631,180
193,942,980
Preparation and implementation of Cultural Heritage/Archaeology Management Plan
- 8,815,590 17,631,18
0 - 8,815,590 - 5,877,060 - 5,877,060 - - - - - - 47,016,480
Major Update of Rehabilitation and Closure
- - - - - - - - - 17,631,18
0 - - - - - 17,631,180
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 155
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
Plan Prior to Decommissioning
Preparation of Blasting Management Plan by blasting contractor
Not costed - to be included in mine design 0
Implementation of other aspects of ESMMP and BAP
Covered by staffing costs 0
Sub-total 55,832,0
70 188,065,9
20 179,250,3
30 126,356,7
90 143,987,9
70 126,356,7
90 141,049,4
40 126,356,7
90 111,664,1
40 114,602,6
70 76,401,78
0 67,586,1
90 61,709,1
30 38,200,
890 47,016,480
1,604,437,380
Biodiversity Offset Programme
Preparation of Biodiversity Offset Plan
29,385,300
29,385,300
29,385,300
- - - - - - - - - - - - 88,155,900
Biodiversity Offset Programme implementation
- 14,692,65
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 - - - - - 719,939,850
Biodiversity Offset Fund
- - 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 88,155,90
0 - - - - - 705,247,200
Biodiversity Offsets Monitoring (including detailed monitoring protocol development, satellite imagery analysis and ground-
17,631,180
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
11,754,120
182,188,860
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 156
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
truthing)
Supporting Biodiversity Conservation Actions
- - 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 - - - - - 235,082,400
Sub-total 47,016,4
80 55,832,07
0 246,836,5
20 217,451,2
20 217,451,2
20 217,451,2
20 217,451,2
20 217,451,2
20 217,451,2
20 217,451,2
20 11,754,12
0 11,754,1
20 11,754,1
20 11,754,
120 11,754,120
1,930,614,210
Social Management / Stakeholder Consultation Costs
Stakeholder and Government consultation / Community relations
- 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 Refer Closure Costs 264,467,700
Design and planning for Livelihood Restoration Program
29,385,300
44,077,950
29,385,300
- 14,692,65
0 - 5,877,060 - - - - - - - - 123,418,260
Livelihood Restoration Program Implementation (rePlan, 2015)
23,508,240
185,127,390
108,725,610
99,910,020
23,508,240
17,631,180
- - - - - - - - - 458,410,680
Livelihood Improvement Programs (rePlan, 2015)
- - - 105,787,0
80 82,278,84
0 82,278,84
0 70,524,72
0 70,524,72
0 - - - - - - - 411,394,200
Vulnerable Peoples Programs (rePlan, 2015)
- 14,692,65
0 14,692,65
0 - - - - - - - - - - - - 29,385,300
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 157
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
Community Infrastructure Mitigation Program (water, health and sanitation facilities)
29,385,300
58,770,600
58,770,600
29,385,300
29,385,300
29,385,300
14,692,650
14,692,650
14,692,650
14,692,650
Refer Closure Costs 293,853,000
Local Economic Participation Plan (including local content initiatives and capacity building)
29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 29,385,30
0 - - - - - 264,467,700
Preparation of Community Safety Plan
11,754,120
11,754,120
- - - - - - - - - - - - - 23,508,240
Social Monitoring
11,754,120
- 29,385,30
0 -
29,385,300
- 29,385,30
0 -
29,385,300
- Refer Closure Costs 129,295,320
Sub-total 105,787,
080 373,193,3
10 299,730,0
60 293,853,0
00 238,020,9
30 188,065,9
20 179,250,3
30 143,987,9
70 102,848,5
50 73,463,25
0 0 0 0 0 0
1,998,200,400
Environmental and Social Investment Fund
Environmental and Social Investment Fund
- 117,541,2
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 - - - - -
2,233,282,800
Sub-total - 117,541,2
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 264,467,7
00 - - - - -
2,233,282,800
Rehabilitation and Closure Costs
Physical Closure Costs
- - 39854608
4 39854608
4 39854608
4 39854608
4 39854608
4 39854608
4 39854608
4 39854608
4 75158427
7 1337257
27 1131731
58 103097
674 103097674
4,393,047,179
Closure Investigations and Methodology
- - 58035968 58035968 58035968 58035968 58035968 58035968 58035968 58035968 0 0 0 0 0 464,287,740
Socio- - - 45914531 45914531 45914531 45914531 45914531 45914531 45914531 45914531 0 0 0 0 0 367,316,250
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 158
Item Pre-
construction
Construction
Operations Decommissioning and Closure
Total
Year 0 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9 Year 10 Year 11 Year 12 Year 13
economic Closure
Stakeholder Consultation
- - 11754120 - 11754120 - 11754120 - 11754120 - 11754120 0 1175412
0 0
11754120
82,278,840
Purchase/Hire Specialised Equipment
- - 29385300 29385300 29385300 29385300 29385300 29385300 29385300 29385300 0 0 5877060
0 0 0 293,853,000
Planning, Auditing and Reporting
- - 22038975 22038975 22038975 22038975 22038975 22038975 22038975 22038975 49073451 0 0 0 19688151
245,073,402
Staff and Contractor Demobilisation
- - - - - - - - - - 98734608 0 0 0 42314832
141,049,440
Post-Closure Monitoring
- - - - - - - - - - 11871661
2 1187166
12 1187166
12 118716
612 118716612
593,583,060
Administration and Personnel Costs
- - 47016480 47016480 47016480 47016480 47016480 47016480 47016480 47016480 17631180
0 4701648
0 4701648
0 470164
80 47016480
740,509,560
Sub-total 0 0 612,691,4
57 600,937,3
37 612,691,4
57 600,937,3
37 612,691,4
57 600,937,3
37 612,691,4
57 600,937,3
37 1,206,174
,868 299,458,
819 349,430,
970 268,830
,766 342,587,869
7,320,998,471
Grand Total 276,221,
820 1,384,047
,630 2,017,308
,797 1,905,644
,657 1,858,628
,177 1,776,349
,337 1,820,427
,287 1,732,271
,387 1,691,131
,967 1,673,500
,787 1,450,072
,858 534,541,
219 578,636,
310 474,527
,866 557,100,559
19,730,410,661
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 159
18 REGISTERS OF ENVIRONMENTAL AND SOCIAL MANAGEMENT AND MONITORING MEASURES
18.1 Summary of Environmental Management and Monitoring Measures
Table 18-1 Register of Environmental Management Systems Improvement Measures
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Project Staff
Responsibilities
The Company will appoint suitably qualified and
experienced staff to implement the Project
ESMMP, including personnel responsible for
security, health and safety, environment and
community, emergency response, human
resources, and logistics.
Verification of implementation Project Director /
Operations Manager /
DEEC and CRSE
Not applicable.
Project Capacity
Building
The provisions for Project capacity building of
relevant external (i.e. regulatory government
authorities) and internal (i.e. for Project staff)
parties will be continually adapted to meet ongoing
needs, including for training, workshop,
competency upskilling, and induction provisions.
This will include capacity building and support for
the Regional Environmental Monitoring
Committee.
Verification of implementation OHS&E Manager / DEEC
and CRSE
Not applicable.
Project Capacity
Budget
The Company will continually review, update, and
fund the Project Environmental and Social
Management and Monitoring Budget.
Verification of implementation Project Director /
Operations Manager /
DEEC and CRSE
Not applicable.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 160
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Environmental
awareness,
training and
induction
A community awareness program will be
undertaken regarding community safety issues
associated with blasting, road safety, hygiene and
sanitation, and disease prevention. The program
will be continually adapted to meet ongoing needs
and risks to potentially affected peoples.
Records (i.e. attendance sheets,
photos, material used, etc.) of
local community attendance
OHS&E Manager / DEEC
and CRSE
Not applicable.
An environmental induction will be conducted for
Project staff and contractors as appropriate for
their role and responsibilities. In addition to
increasing understanding of environmental issues
on site, this will also ensure that applicable
penalties and Project bans (e.g. drink driving,
trading wildlife products, etc.) are widely known.
Records (i.e. attendance sheets)
of Project staff and contractors
OHS&E Manager / DEEC
and CRSE
Not applicable.
Environmental training on specific work
procedures as specified in this ESMMP will be
provided for employees (including Contractors), as
appropriate for their role and responsibilities.
Records (e.g. attendance
sheets, formal training register)
of specific training course
attendance
OHS&E Manager / DEEC
and CRSE
Not applicable.
Emergency
Preparedness
And Response
Project specific Emergency Preparedness and
Response Plans will be developed prior to the
start of operations to include a POI in line with
Senegalese guidelines and a Cyanide Spill
Contingency Plan, and appropriate spill prevention
and response procedures in line with industry best
practice, IFC General EHS Guidelines, and the
ICMI Cyanide Code.
Verification of implementation Project Director /
Operations Manager /
DEEC and CRSE
Company Plans and Procedures
Project Risk Assessment (Etude de
Danger)
Emergency Preparedness and Response
Plans
Relevant Guidelines and Standards
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 161
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
The Company will undertake a Project risk
assessment on an annual basis to review potential
emergency situations that may arise from the
Project in line with the methodology developed in
the Risk Assessment (Etude de Danger).
Records of risk workshops
Up-to-date Project risk register
Risk audits, job safety analysis,
etc.
OHS&E Manager / DEEC
and CRSE
Risk Assessment Guide (DEEC, 2007)
General EHS Guidelines (IFC, 2007)
Mining EHS Guidelines (IFC, 2007)
Cyanide Code (ICMI, 2014)
Monitoring Plans
and Programs
The Project Environmental and Social Monitoring
Manual will be updated in line with the various
monitoring programs set out in the ESMMP for the
different phases of the Project.
Verification of implementation OHS&E Manager / DEEC
and CRSE
Company Plans and Procedures
Environmental and Social Monitoring
Manual
A comprehensive environmental monitoring
program will be implemented in line with this
ESMMP to ensure any Project discharges to the
receiving environment will comply with applicable
guidelines and standards (e.g. for water quality, air
quality, and noise).
Monitoring databases,
inventories, results, records of
inspections/observations, etc.
(refer to Section 3.5.1 for further
details)
OHS&E Manager / DEEC
and CRSE
Relevant Guidelines and Standards
Refer to Table 2-3 of the ESMMP for
relevant environmental standards and
guidelines for the Project.
A comprehensive social monitoring program will
be implemented in line with this ESMMP.
Monitoring databases,
inventories, results, records of
inspections/observations, etc.
(refer to Section 3.5.1 for further
details)
OHS&E Manager / DEEC
and CRSE
Relevant Guidelines and Standards
Refer to Table 2-3 of the ESMMP for
relevant environmental standards and
guidelines for the Project.
Develop a detailed protocol for biodiversity
monitoring in accordance with this ESMMP and
the BAP.
Verification of implementation OHS&E Manager / DEEC
and CRSE
Company Plans and Procedures
BAP
Project reporting
Quarterly and annual reporting will be undertaken
for relevant regulatory authorities, as well as
reportable incidents and community grievances
reporting. Databases will be established and
maintained to support the Project reporting
Quarterly Reports and Annual
Sustainability Reports
Logged grievances
Reported incidents and near-
OHS&E Manager / DEEC
and CRSE
Global Reporting Initiative Sustainability
Reporting Guidelines
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 162
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
commitments in place.
misses
Audit reports
Construction
Environmental
Management
Plan (CEMP)
A CEMP will be developed in line with this ESMMP
prior to construction.
Verification of implementation OHS&E Manager,
Contractors / DEEC and
CRSE
Company Plans and Procedures
CEMP, ESMMP
Contractor
Environmental
Management
Plans (EMPs)
Principal contractors for the Project will be
required to develop specific EMPs , which
incorporate measures detailed in this ESMMP and
as relevant to their work activities.
Verification of implementation OHS&E Manager,
Transport contractor,
Construction contractor,
Mining contractor,
Blasting contractor, Fuel
farm contractor, Power
station contractor / DEEC
and CRSE
Company Plans and Procedures
CEMP, ESMMP, SOPs
Blasting and
Flyrock
Management
Planning
A detailed Blast Management Plan will be
prepared that will specify blasting procedures,
training, auditing, PPE and other requirements.
OHS&E Manager, Blast
Contractor / DEEC and
CRSE
Company Plans and Procedures:
Blast Management Plan (to be
developed)
SOP08: Blast Management
SOP04: Emission and Dust Control
SOP05: Noise and Vibration
Management
International Standards and Guidelines:
Leading Practice Sustainable
Development Program for the Mining
Industry: Airborne Contaminants, Noise &
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 163
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Vibration (Australian Government, 2009)
Mining EHS Guidelines (IFC, 2007)
Waste
Management
Planning
The Company will prepare and implement a
detailed Waste Management Plan (inclusive of
hazardous wastes), and Waste Rock Management
Plan for the Project. The TMF Operating and
Monitoring Manual will be finalised prior to
Operations.
Verification of implementation OHS&E Manager / DEEC
and CRSE
Company Plans and Procedures
Waste Management Plan (to be
developed)
Waste Rock Management Plan (to be
developed)
TMF Operating and Monitoring Manual
(to be finalised)
National Standards:
Draft Standard on Management of Solid
Waste / Projet de Norme relative à la
Gestion des Déchets Solides (2005)
International Standards and Guidelines:
Mining EHS Guidelines (IFC, 2007)
General EHS Guidelines– Waste
Management (IFC, 2007)
Community
Safety Planning
A Community Safety Plan will be prepared and
implemented Verification of
implementation
Logged grievances
Noise limit and air quality
limit exceedances at
nearby sensitive
receptors
Health and nutritional
OHS&E Manager,
Contractors / DEEC and
CRSE
Company Plans and Procedures
Emergency Preparedness and Response
Plans (to be developed)
Blast Management Plan (to be
developed)
International Standards and Guidelines:
General EHS Guidelines (IFC, 2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 164
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
indicators in the local
community (e.g.
availability of food, food
supply options,
prevalence of
undernourishment,
agricultural / food
production etc.) and
workforce
Incident register
Mining EHS Guidelines (IFC, 2007)
IFC PS4 Community Health, Safety and
Security (2012)
IFC PS5 Land Acquisition and Involuntary
Resettlement (2012)
ICMI, International Cyanide Management
Code (2014)
Update of Plans
and Manuals
Review and update ESMMP prior to the
commencement of Construction, prior to the
commencement of Operations and every two
years during Project Operations to reflect changes
to Project activities, commitments, environmental
and social conditions, regulatory requirements,
and potential optimisation of best management
practices
Verification of implementation OHS&E Manager / DEEC
and CRSE
Company Plans and Procedures
ESMMP
Review and update the key
plans/manuals/programs prior to Operations and
then at least every 2 years thereafter, or when
there is a major change in the design or operation
of the Project. These will include:
Biodiversity Action Plan;
Stakeholder Engagement Plan;
Livelihood Restoration Plan;
Local Economic Participation Plan (LEPP);
Verification of implementation OHS&E Manager / DEEC
and CRSE
Not applicable.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 165
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Community Safety Plan;
Waste Management Plan (inclusive of
hazardous wastes);
Waste Rock Management Plan;
TMF and WSD Operating and Monitoring
Manual;
Blast Management Plan;
Environmental and Social Monitoring
Manual; and
Emergency Preparedness and Response
Plans.
Rehabilitation
and Closure
Planning
Review and update Rehabilitation and Conceptual
Mine Closure Plan (RCMCP) at least every 3
years during Operations, or when there is a major
change in the design or operation of the Project.
Verification of implementation Operations Manager /
DEEC and CRSE
Company Plans and Procedures
RCMCP
Prepare a Final Rehabilitation and Mine Closure
Plan prior to Decommissioning.
Verification of implementation Operations Manager /
DEEC and CRSE
Company Plans and Procedures
RCMCP
Audits /
Inspections
Independent external audits of the ESMMP and its
implementation will be conducted once during the
construction phase and on an annual basis for the
first two years of operation. The frequency of
subsequent operational audits will be based on the
recommendations from the initial audits, and will
be at least every 3 years during operations.
As part of the audit of the ESMMP, an independent
external audit of the RCMCP will also be
Verification of
implementation
Audit reports
Project Director /
Operations Manager /
DEEC and CRSE
Company Plans and Procedures
ESMMP
RCMCP
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 166
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
conducted as key operational and closure
milestones are reached.
The Environment Department will undertake a site
inspection of all Project facilities on a monthly
basis using a visual inspection form to record
observations onsite. KPIs will be developed to
enable environmental performance to be assessed
objectively and quantitatively across the operation.
Verification of
implementation
Site inspection reports
OHS&E Manager / DEEC
and CRSE
Company Plans and Procedures
Environmental Monitoring Manual
Social Monitoring Manual
TMF and WSD Operating and Monitoring
Manual
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 167
18.2 Summary of Physical Management and Monitoring Measures
Table 18-2 Register of Physical Environment Management and Monitoring Measures
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Project Traffic
and Transport
Safety
The Company will implement measures during the
construction, maintenance and operation of Project roads to
minimise the impact to other road users. These may include
the following:
Schedule for road works coordinated with relevant
agencies and stakeholders to minimise traffic
disruption for public and private road users;
Prior notification of planned road construction
activities likely to cause nuisance noise and dust
(e.g. blasts) to potentially affected villagers; and
Appropriate signage and traffic safety measures
(e.g. barriers) for road works will be undertaken in
consultation with local government and key
stakeholders.
The Company will implement measures to ensure traffic
safety, including:
All Project roads within the PDA will be signposted in
French to provide directions to traffic movements;
The use of private vehicles to be restricted once
past the Project entrance boundary;
Implementation of a ‘driver code of conduct’ for
Verification of implementation
Journey management plans
and in-vehicle monitoring
system for all Project vehicles
Records of driving training and
qualifications
Vehicle inspection checklists
Road safety and driver
compliance monitoring, e.g.
random breathalyser and
remote monitoring of driver
performance
Project vehicle fleet database
and maintenance program
Traffic incident reporting
system for the community and
Project workers: recording
date, time, location, persons
involved, and any actions
taken or required by the
OHS&E Manager,
Contractors /
DEEC and CRSE
1. Company Plans and
Procedures
2. CEMP
3. (Transport)
Environmental
Management Plan
4. Relevant Standards
and Guidelines:
5. Local and national
road standards
6. PS4 Community
Health, Safety and
Security (IFC, 2012)
7. General EHS
Guidelines – Traffic
Safety and Transport
of Hazardous
Materials (IFC, 2007)
8. International Cyanide
Management Code
(ICMI, 2012)
9. International Cyanide
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 168
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Project drivers and contractors;
Project vehicles to follow designated Project
transport routes within permitted driving hours;
Off-site vehicle movements (e.g. delivery of
supplies) to be limited to the day time, where
practicable;
Regular Project driver and contractor checks
performed for adherence to local traffic laws;
Vehicular speed limits as follows: Maximum of 50
km/h for Main Access Road, Haul roads and other
Project roads; National speed limit on the RN7; and
20 km/h through villages, residences or sensitive
areas (e.g. school);
Provision of training to vehicle drivers on safe
driving (e.g. collision avoidance), fatigue
management, and first aid training;
Project vehicles equipped with first aid equipment
and appropriate personal protection equipment
(PPE) (e.g. high visibility vest);
Vehicles transporting oversized loads to be
preceded by an escort ‘warning’ vehicle;
Transportation of dangerous goods and hazardous
materials will comply with measures specified in
SOP07: Hazardous Materials Management;
Zero tolerance on driving under the influence of drug
and alcohol for Project drivers. The Company will
contractor or the Company.
Management Code
Principles and
Standards of Practice
for cyanide handling,
storage and
transportation (ICMI,
2014)
10. United Nations,
Transport of
Dangerous Goods -
Model Regulations.
17th Revised Edition
(Volume 1) Geneva
2011
11. AS 1940 – The
Storage and Handling
of Flammable and
Combustible Liquids.
(Current 2004 ed.)
12. AS 2187 – Explosives
– Storage, Transport
and Use. (Current
1998 ed.).
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 169
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
conduct regular compliance monitoring such as
random breathalyser and remote monitoring of
driver performance;
Project vehicles to meet road weight limits on the
designated routes, including for bridge crossings;
and
Safety inspections of Project vehicles will be
conducted on a regular basis (i.e. vehicle checklist
to complete).
A dust suppression program will be implemented involving
regular watering of unsealed road surfaces and trafficked
areas during the dry season or when excessive dust
generation is evident near sensitive receptors (e.g. villages /
settlements). Frequency of watering will be increased
during periods of high risk (e.g. dry and windy conditions).
Verification of implementation
Ambient dust monitoring for
dust deposition rates, PM10,
and PM2.5
Visual check for excessive
fugitive dust on unsealed
roads
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
CEMP
SOP04: Emissions and Dust
Control
National Standards:
Atmospheric Pollution Standard,
NS 05-062 / La Norme de rejets
NS 05-062 – pollution
atmosphérique (2004)
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines – Air
Emissions and Air Quality (IFC,
2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 170
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
WHO Air Quality Guidelines –
Global Update (2005).
Routine maintenance of Project roads. Visual checks of road
condition
Project grievance mechanism
Incident register
OHS&E Manager /
DEEC and CRSE
Not applicable.
A vehicle and machinery maintenance program will be
established for the Project fleet to comply with relevant
standards and guidelines for transport safety, and vehicle
manufacturer’s instructions.
Project vehicle fleet database
and maintenance program
Vehicle inspection schedule
and checklists
OHS&E Manager /
DEEC and CRSE
National Standards:
Atmospheric Pollution Standard,
NS 05-062 / La Norme de rejets
NS 05-062 – pollution
atmosphérique (2004)
Environment Code (noise) (Code
de l’Environnement) (2001)
International Standards and
Guidelines;
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines (IFC,
2007)
WHO Air Quality Guidelines –
Global Update (2005)
UK Standards (vibration) BS
6472:2008, 4866:2010 and
7385-2:1993
International Cyanide
Management Code Principles
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 171
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
and Standards of Practice for
cyanide handling, storage and
transportation (ICMI, 2014)
United Nations, Transport of
Dangerous Goods - Model
Regulations. 17th Revised
Edition (Volume 1) Geneva 2011
AS 1940 – The Storage and
Handling of Flammable and
Combustible Liquids. (Current
2004 ed.)
AS 2187 – Explosives – Storage,
Transport and Use. (Current
1998 ed.).
Waste Rock
Management
The WRD will be constructed with an overall slope
angle of 20 degrees for geotechnical stability and
operational safety, and incorporate features to
minimise the effect of leaching of contaminants;
The WRD will be progressively rehabilitated from
the bottom up using contoured batter slopes on the
outer face, native species planting for groundcover,
and erosion control blankets (e.g. Jute netting) and
fibre rolls to minimise water quality issues at the
base;
Seepage from the waste rock dump will be routinely
monitored and evaluated for water quality.
Verification of implementation
Seepage water quality data
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP01: Erosion and Sediment
Control
SOP09: Land Clearance and
Soil Stockpiling
Waste Rock Management Plan
RCMCP
International Standards and
Guidelines
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 172
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Ore Stockpiling
Management
Seepage from the ore stockpile will be routinely monitored
and evaluated for water quality. Verification of implementation
Seepage water quality data
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP01: Erosion and Sediment
Control
SOP09: Land Clearance and
Soil StockpilingRCMCP
International Standards and
Guidelines
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
General Mine
Safety
The following management and monitoring measures will be
implemented to ensure mine safety for workers and the
community:
Enforcement of a mine blast exclusion zone during
blasting;
Provision of 24 hour security guards and restricted
access safeguards (e.g. perimeter security fencing
and authorised personnel only) to provide a high
level of security for the explosives magazine and
Process Plant;
A safety berm and signage at key locations around
the Pit rim perimeter will be installed to prevent falls
into the Pit;
Zero incident record for blasts
Routine monitoring of flyrock
impacts (refer to SOP08.12)
Verification of security
practices
Verification of safety controls
and inspection records
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
SOP08: Blasting Management
International Standards and
Guidelines
General EHS Guidelines (IFC,
2007
Mining EHS Guidelines (IFC,
2007
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 173
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
The explosives magazine will comprise two separate
containments for the secure storage of (i) high
explosives and (ii) accessories (i.e. initiators). Each
containment will be surrounded by an earth
barricade. ;
Appropriate handling and storage of explosives
(refer to SOP07: Hazardous Materials Management)
and established procedures for initiating blasts (refer
to SOP08: Blasting Management, Appendix A) will
be followed by appropriately trained staff.
Fire Safety
Management
Fire prevention and response controls will be provided
onsite, including:
Fire water, hydrants and hose reels at strategic
locations (e.g. Power Station, flammable material
storage areas, offices, and camp) to ensure
complete coverage in areas where flammable
materials are present;
Bushfire prevention controls, including Project ban
on open-burning of wastes, establishment of fire
breaks near sensitive buildings (e.g. at explosive
magazine, fuel storage areas, Process Plant, Power
Station, accommodation camps);
Site-specific emergency procedures to respond to
fires, including fire evacuation plans posted at
strategic locations throughout each Project facility;
and
Training for Project personnel, as appropriate for
Fire safety inspection records
Checks of all fire suppression
equipment to ensure regular
maintenance has been
undertaken
Training records for fire-
fighting
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
International Standards and
Guidelines
General EHS Guidelines (IFC,
2007
Mining EHS Guidelines (IFC,
2007
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 174
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
their role and responsibilities, for fire-fighting,
emergency response, and hydrocarbon
management.
Process Plant
Safety
Additional management and monitoring measures for
implementation at the Process Plant to ensure worker safety
include:
Provision of backup critical plant and equipment
(e.g. process water pumps, emergency diesel-
powered fire water pump) with proper safety controls
in place to ensure there is sufficient redundancy in
the plant system if there is a process failure or
maintenance work is required;
Built-in emergency warning system and plant
shutdown mechanisms (e.g. statutory interlocks
such as emergency stops and thermal protection to
be hardwired) to avoid the discharge of hazardous
materials to the environment;
Fire protection and control system for the Process
Plant and Power Station that will supply fire water at
the required pressure and flowrate in the event of an
emergency;
Adequate lightning and surge protection provided for
the Process Plant building structures and sensitive
equipment; and
Maintenance of the mechanical integrity and
operability of plant process systems (e.g. relief and
vent valves, shutdown systems, pumps,
Regular inspection for
potential leakage or seepage
of hazardous materials and
wastes
Inspection records
Zero incidents record for Plant
operation
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines –
Hazardous Materials
Management and Transport of
Hazardous Materials (IFC, 2007)
United Nations, Transport of
Dangerous Goods - Model
Regulations. 17th Revised
Edition (Volume 1) Geneva 2011
AS 1940 – The Storage and
Handling of Flammable and
Combustible Liquids. (Current
2004 ed.)
International Cyanide
Management Code Principles
and Standards of Practice for
cyanide handling, storage and
transportation (ICMI, 2014)
AS 2187 – Explosives – Storage,
Transport and Use. (Current
1998 ed.).
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 175
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
containment infrastructure, pressure tanks, etc.).
Dam Safety and
Integrity
The structural integrity of the TMF and WSD will be ensured
by implementing the following measures:
Dam infrastructure (including engineered
embankment and spillway) designed to
accommodate a 1 in 100 year rainfall event plus
contingency freeboard;
Provision of an impervious barrier and other design
measures to minimise loss of stored water by
seepage (e.g. installation of a cut off trench, low
permeability foundation sub-base material, etc.);
An emergency spillway will be provided at all times
in the event that rainfall exceeds the 1 in 100 year
storm event (i.e. greater than the dam design
criteria). Discharge under these conditions is
required in order to protect the integrity of the
embankments from overtopping;
Dam embankment constructed with at least a slope
of 2.5H:1V, with rock armouring (i.e. rip rap)
provided on the outer banks and spillway to prevent
potential scouring, erosion and embankment
instability;
Security fencing around the site perimeter of the
TMF to limit the public and livestock from accessing
the area;
Ongoing review of the site water balance and
inventory to avoid potential water overcapacity or
Independent audit reports of
the TMF dam structural
integrity
Regular inspections of dam
toe, emergency spillway,
embankment, tailings pipelines
(refer to SOP03.13 and
SOP03.14)
Monitoring of dam water levels
(i.e. TMF, WSD) for sufficient
freeboard and the groundwater
downstream
Monitoring of rainfall,
temperature, evaporation rates
(refer to SOP04.17) and site
water balance parameters
(refer to SOP03.10)
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
TMF and WSD Operating and
Monitoring Manual
International Standards and
Guidelines:
ANCOLD and ICOLD standards
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 176
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
shortages at the Project site;
A regular inspection and maintenance schedule of
TMF and WSD dam infrastructure (i.e. spillway,
embankment, pipelines, flanges, seals and pumps)
as detailed in the TMF and WSD Operational and
Monitoring Manual; and
Independent audits of the TMF and WSD conducted
by a suitably qualified geotechnical engineer on an
annual basis to ensure structural and operational
integrity of the dam facility is maintained.
The TMF and WSD Operating and Monitoring Manual will
be finalised prior to Operations.
Workforce
Sanitation and
Hygiene
Potable water will be treated to comply with WHO 2011
Drinking Water Standards and distributed for drinking, site
ablutions, safety showers and other potable water outlets.
All wastewater and raw sewage generated from kitchen,
bathrooms, and toilets will be treated to meet relevant
discharge standards via a site based modular sewage
treatment plant (STP).
Surplus activated sludge from the STP will most likely be
solar dried in a lined pond, and then buried in a lined landfill,
or co-disposed with process tailings. Treated effluent water
from camp sites (estimated at 50 – 100 m3/day) will be
disposed of via leach drains.
Verification of implementation
Potable water quality
monitoring
Discharge water quality
monitoring of wastewater for
parameters: Total and faecal
coliform, Total nitrogen, Total
Phosphorous, COD, and BOD
(refer to SOP2.14)
Waste inventory of major
waste streams generated
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and
Procedures:
SOP02: Water Quality Pollution
and Management
SOP06: Waste Management
SOP07: Hazardous Waste
Management
National Standards:
Draft Standard on Management
of Solid Waste / Projet de Norme
relative à la Gestion des
Déchets Solides
International Standards and
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 177
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Guidelines:
General EHS Guidelines (IFC,
2007)
Mining EHS Guidelines (IFC,
2007)
EU Ambient Water Quality
Guidelines
EU Council directive 9883/EC of
November 1998 on the quality of
water intended for human
consumption (EU, 1998).
WHO Guidelines for Drinking
Water Quality, fourth edition
(2011).
The Company will implement proper waste management
procedures for the collection, separation, and disposal of
Project waste. A preferred waste management hierarchy
will also be applied, with opportunities for waste
minimisation, reuse and recycling implemented where
practicable. Medical and sanitary waste will be disposed of
as per SOP07: Hazardous Waste Management.
Waste Inventory of major
waste streams generated by
workforce accommodation
Hazardous Waste Inventory
Inspection records
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
National Standards:
Draft Standard on Management
of Solid Waste / Projet de Norme
relative à la Gestion des
Déchets Solides
International Standards and
Guidelines:
General EHS Guidelines -Waste
Management (IFC, 2007)
Mining EHS Guidelines (IFC,
2007)
Water Quality
and Pollution Adopt relevant water quality and pollution management and
monitoring measures specified in SOP02: Water Quality and
Verification of implementation OHS&E Manager / Company Plans and
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 178
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Management Pollution Management.
DEEC and CRSE Procedures:
SOP02: Water Quality and
Pollution Management
Specific water quality management measures for
implementation at the Project site include:
Reuse and recycle process water to reduce the
requirement for raw water abstraction from the
Gambia River;
Use of erosion and sediment control measures as
detailed in SOP01: Erosion and Sediment Control;
Surface runoff diverted around the Project site;
All wastewater and sewage generated from
kitchens, bathrooms and toilets to be treated to meet
relevant discharge standards via a site-based
modular sewage treatment plant;
Adherence to proper handling and storage of
hazardous materials onsite in fully bunded,
weatherproof areas, including appropriate
emergency response and spill clean-up procedures
(refer to relevant measures specified in SOP07:
Hazardous Materials Management);
Maintenance of primary and secondary
containments for all hazardous material storage and
handling areas; and
Regular inspection for potential leakage or seepage
of contaminated water.
Verification of implementation
Visual check to ensure there
are no visible leakage or
seepage (refer to SOP02.19)
Inspection records
Incident records
Water quality monitoring
results
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and
Procedures:
SOP02: Water Quality and
Pollution Management
SOP01: Erosion and Sediment
Control
SOP07: Hazardous Materials
Management
International Standards and
Guidelines:
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines –
Wastewater and Ambient Water
Quality (IFC, 2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 179
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
The following measures will be implemented to minimise
erosion and sedimentation to receiving waters from Project
road infrastructure:
Appropriate road specification standards selected to
minimise excessive earthworks with subsequent
requirements for large amounts of fill material;
Roads designed to include drainage systems that
channel water from the road surfaces to outlets with
erosion and sediment control facilities, including rip-
rap at inlets and outlets of culverts and channels
and sediment control basins constructed for larger
catchment areas;
Roads to be constructed during the dry season to
the extent possible. Erosion and sediment controls
for unsealed roads will be completed before the
onset of the wet season;
Drainage from upslope of road surfaces to be
diverted via roadside drainage channels to culverts
with velocity dissipaters and sediment control at
outlets;
Culverts installed at drainage crossings.
Permanent structures designed using an average
peak storm recurrence interval of 100 years, and
temporary structures designed using an average
recurrence interval of 2 years (24 hour storm
events);
Batter slope angles minimised to the extent feasible;
Verification of implementation
Routine erosion and sediment
transport monitoring (refer to SOP01:
Erosion and Sediment Control)
Water quality monitoring results
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
CEMP, ESMMP
SOP01: Erosion and Sediment
Control
Relevant Guidelines
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 180
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implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
and
Where feasible, vegetation will be left intact on road
verges and roadside batters to reduce surface flow
velocity and erosive potential. Road borders and
embankments will be progressively re-vegetated
where necessary for erosion control.
The TMF and tailings piping facilities will incorporate the
following water quality management measures:
A soil liner with permeability less than 1 x 10-8 m/s
will minimise the potential for seepage over the
extent of the basin area;
An HDPE geomembrane liner installed in the lower
reaches of the TMF basin and on the TMF
embankment upstream face. The liner will conform
to Nevada’s Water Controls for Mining Facilities
Standards (Nevada Administrative Code NAC
445A.438);
Monitoring of groundwater bores and surface water
sampling stations downstream of the TMF; and
Regular inspection and maintenance of the TMF and
associated pipelines (tailing and return water) in
accordance with the TMF Operation and Monitoring
Manual.
Verification of implementation
Inspection records
Incident records
Water quality monitoring
results
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and
Procedures:
SOP02: Water Quality and
Pollution Management
SOP03: Hydrology and Water
Management
TMF Operation and Monitoring
Manual
International Standards and
Guidelines
ANCOLD and ICOLD Standards
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
Nevada’s Water Controls for
Mining Facilities Standards
(Nevada Administrative Code:
NAC 445A.438)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 181
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
During Project Construction, routine water quality monitoring
will be conducted at discharge points to assess impacts.
Key parameters: Turbidity, TSS, DO,
temperature, electrical conductivity
(EC), and pH (refer to SOP02.9)
Visual checks for sedimentation, oils
and grease (refer to SOP2.10)
OHS&E Manager /
DEEC and CRSE
National Standards:
Inter-ministerial Decree No.
1555 Discharge Water
Guidelines / L’arrêté
interministériel No. 1555 de 15
mars 2002 portant application de
la norme NS 05-061 sur les
rejets des eaux usées (2002)
Waste Water Discharge
Standard, NS 05-061 / La norme
sur les rejets des eaux (NS 05-
061) (2001)
International Standards and
Guidelines:
General EHS Guidelines –
Wastewater and Ambient Water
Quality (IFC, 2007)
EU Ambient Water Quality
Guidelines
EU Council directive 9883/EC of
November 1998 on the quality of
water intended for human
consumption (EU, 1998)
WHO Guidelines for Drinking
Water Quality, fourth edition
(2011).
During Project operations, a routine water quality monitoring
program will be conducted of surface, ground and discharge
water This will include multi-element testing of samples
using ICP-MS to fully characterise water quality.
Surface water parameters (i.e. from
Pit sumps and Mine water):
Key parameters: Cyanide
(including free cyanide, weak
acid dissociable, and total),
salinity, total and dissolved
metals (full suite), and
nutrients, and AMD.
Field parameters (e.g. pH, EC,
ORP, DO, Temp., etc.) (refer to
SOP02.13 and SOP02.16)
Discharge parameters;
Salinity, Turbidity, TSS,
temperature, EC, ORP, pH
(refer to SOP02.14)
Visual checks for
sedimentation, oils and grease
(refer to SOP2.10)
Groundwater parameters :
Groundwater level
Key parameters: cyanide (free,
OHS&E Manager /
DEEC and CRSE
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 182
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
weak acid dissociable, and
total), related breakdown
products of cyanide (e.g.
ammonia, nitrate, thiocyanate),
salinity, nutrients, and field
parameters (e.g. pH, EC, ORP,
DO, temp. etc.)
Acidity/alkalinity, sulfate, and
dissolved metals (to be
determined by waste rock
characterisation)
Hydrology and
Water
Management
Relevant hydrology and water management and monitoring
measures specified in SOP03: Hydrology and Water
Management will be adopted, where appropriate.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP03: Hydrology and Water
Management
Key measures of the Mine site water management system
for implementation include:
The mine will function as a ‘zero-discharge’
operation. Surface water from the Mine Pit, WRD,
Ore Stockpile and TMF will be contained by the TMF
embankment; and
Project abstraction from the Gambia River will not
exceed 3% of the instantaneous volumetric flow.
Abstraction will be limited to periods when the
Gambia River discharge exceeds 5 m3/sec.
Verification of implementation
Regular inspections of surface
water management features to
ensure their efficacy
Incident records
Hydrology records for the
Gambia River
Record of abstraction from
Gambia River
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans nd Procedures:
SOP02: Water Quality and
Pollution Management
SOP03: Hydrology and Water
Management
International Standards and
Guidelines
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 183
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Erosion and
Sediment
Transport
Management
Relevant erosion and sediment control management and
monitoring measures specified in SOP01: Erosion and
Sediment Control will be adopted, where appropriate.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP01: Erosion and Sediment
Control
The following specific erosion and sediment management
measures will be implemented for mine facilities during the
pre-construction and construction phase of the Project:
The CEMP will include provision for erosion and
sediment control, including the measures specified
in SOP01;
Dam embankments to be constructed with a slope of
at least 2.5H:1V, with rock armouring (i.e. rip rap)
provided on the outer banks and spillway to prevent
potential scouring, erosion and embankment
instability; and
Soil stockpiles formed with as little compaction as
possible in mounds generally no more than 2 m high
(for topsoil) and 5 m high (for subsoil) to minimise
losses to erosion.
Verification of implementation
Routine erosion and sediment
transport monitoring (refer to
SOP01: Erosion and Sediment
Control)
Water quality monitoring
results
Project Director /
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
CEMP, ESMMP
SOP01: Erosion and Sediment
Control
RMCP
International Standards and
Guidelines
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
During the decommissioning and closure phase, specific
erosion and sedimentation management and mitigation
measures as specified in the RMCP include:
All exposed soil to be re-contoured and ripped
(during the dry season) and re-vegetated (at the
onset of the rainy season) to a landform consistent
with the surrounds upon mine closure to minimise
Verification of implementation
Routine erosion and sediment
transport monitoring (refer to
SOP01: Erosion and Sediment
Control)
Inspection records
Designers, OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
SOP01: Erosion and Sediment
Control
RCMCP
International Standards and
Guidelines
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 184
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
potential for erosion;
The TMF will be graded to a stable 1 in 100 slope
and the slopes engineered to encourage sheet flow
of run-off water and prevent excessive channelling
and erosion; and
Drainage will be redirected as necessary to
minimise erosion until vegetation is established.
Water in the sediment control structures will be
treated to achieve compliance with appropriate
discharge standards.
Water quality monitoring
results
Mine site Water Management
Handbook (MCA, 1997)
Mining EHS Guidelines (IFC,
2007)
Air Emissions
and Dust
Management
The Company will implement the following management
and mitigation measures to minimise impacts to air quality
from Mine Pit and WRD development:
Prepare an Occupational Health and Safety Plan
prior to Project Operations
Limitation of land clearing to the minimum required
area to reduce the potential for dust generation;
Topsoil stripping preferably conducted at times when
soil moisture can be expected to be optimal to
minimise dust formation; and
Progressive revegetation of disturbed areas.
Verification of implementation
Visual check for fugitive dust
Ambient monitoring of
particulates and dust
deposition
Land clearance and
revegetation records
OHS&E Manager /
DEEC and CRSE
Not applicable.
The Company will implement the following management
and mitigation measures to minimise impacts to air quality
from the Process Plant:
The lime silo will be fitted with a dust collector;
Water sprays and dust collection systems to be
Verification of implementation
Visual check for fugitive dust
Ambient monitoring of PM10,
and PM2.5, SO2, NOx, CO
and dust deposition rates via
Designers /
OHS&E Manager
/Operations
Manager / DEEC
and CRSE
National Standards:
Atmospheric Pollution Standard,
NS 05-062 / La Norme de rejets
NS 05-062 – pollution
atmosphérique (2004)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 185
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
installed for dust suppression in the crushing and
screening circuit and lime addition point, where
feasible;
As required, the Company will further consider
containing fugitive emissions within the Process
Plant to the extent practicable by either:
» Enclosing or covering all fugitive source
emissions such as the conveyors, hoppers, bins;
» Watering roads or gravel sheeting in ore-
handling areas to minimise windblown and traffic
generated dust; and
» Controlling a fugitive emission source from feed
ore handling by employing air extraction and
treatment through a baghouse or cyclone.
Routine monitoring of fugitive dust emissions at the
Process Plant.
dust gauge
Stack emission monitoring of
PM10, PM2.5, NOx, SO2, CO,
O3
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines – Air
Emissions and Air Quality (IFC,
2007)
WHO Air Quality Guidelines –
Global Update (2005)
Specific measures for managing air quality and dust impacts
associated with transport for the Project will include:
A dust suppression program for the Project involving
regular watering of unsealed road surfaces, heavily
trafficked areas, and where excessive dust is
evident;
Project vehicle speed limits through villages of 20
km/h;
Low emission diesel engines and/or catalytic
Verification of implementation
Visual check for fugitive dust
Ambient monitoring of
particulates and dust
deposition
Grievance register
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
As above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 186
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
convertors for Project heavy vehicles, trucks, and
excavators will be used, where possible;
Dusty material loads covered where transport is
required through settlements;
Unsealed roads heavily trafficked by Project
vehicles over a long period will be considered for
future application of gravel or paving; and
Regular maintenance of unsealed Project roads.
Adopt relevant air emissions and dust management and
monitoring measures specified in SOP04: Emission and
Dust Control, where appropriate.
Verification of implementation
OHS&E Manager,
Contractors /
DEEC and CRSE
Company Plans and Procedures
SOP04: Emission and Dust
Control
A detailed air quality monitoring regime will be implemented
and adapted for Project construction and operations which
will include ambient air quality monitoring and dust
deposition rates.
The Company will consult with local villages and will
address potential complaints regarding dust via the Project
Grievance Mechanism.
Visual check for fugitive dust
Ambient air quality station
monitoring for PM10, and
PM2.5, SO2, NOx, CO and
dust deposition rates via dust
gauge (refer to SOP04.16)
Grievance register
OHS&E Manager /
DEEC and CRSE
Same as above.
Noise and
Vibration
Management
The Company will implement specific noise and vibration
measures for Project facilities, including:
Integration of physical barriers (such as vegetation,
soil banks/berms and commercially-available
acoustic shields) with site components (e.g.
stockpiles and constructed buildings) to strategically
act as noise barriers for potential sensitive
Verification of implementation
Noise levels in dB(A) LAeq
(daytime and night-time period
(refer to SOP 05.12)
Grievance register
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
SOP05: Noise and Vibration
Management
National Standards:
Environment Code (noise) /
Code de l’Environnement (2001)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 187
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
receptors;
Commercial acoustic shielding (typically insulator
material panels) around noise sources where
necessary and the adoption of high frequency
technology for fans, ducting and electrical systems;
Vibration-proofing and noise-reduction measures for
various noise sources within the Mine site, including
treatment measures for mine equipment such as
hydraulic excavators, crawler bull-dozers, loaders,
and jaw crushers;
Additional measures to minimise noise emitted by
the Process Plant operations may include:
» Use of barriers (e.g. near vibrating screen) and
other noise abatement technologies (e.g.
ventilation fan size or use of windscreens near
ventilation fan);
» Sound insulation of plant and machinery
engines, if required;
» Enclosure of high noise emitting areas such as
the crushing and grinding areas; and
» Provision of noise protection PPE for workers in
areas where plant equipment emits noise in
excess of 80 dB(A).
International Standards and
Guidelines
Leading Practice Sustainable
Development Program for the
Mining Industry: Airborne
Contaminants, Noise & Vibration
(Australian Government, 2009)
UK Standards (vibration) BS
6472:2008, 4866:2010 and
7385-2:1993
General EHS Guidelines – Noise
(IFC, 2007)
Mining EHS Guidelines (IFC,
2007)
The following air blast and vibration management measures
will be implemented for mine blasts:
Use of electronic detonation to significantly reduce
Verification of implementation
Routine monitoring of noise,
airblast, ground vibration, and
OHS&E Manager,
Blast Contractor /
DEEC and CRSE
Company Plans and Procedures
SOP08: Blast Management
SOP05: Noise and Vibration
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 188
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
vibrations caused by the blast;
No explosive charge per blast hole to exceed the
estimated maximum charge weight per delay (i.e.
285 kg);
Only one charge detonated per delay and every
charge will be able to break and displace its burden
with reasonable ease;
Inter-row delays that long enough to give good
progressive relief of burden; and
Detonating cord trunklines to only be used to fire
pre-split blasts. Trunklines will have a core load of
only 5 g/m and will be covered by at least 250 mm of
sand or fine screenings; and
Inspection and review of any reported structure
damage after each blast, with immediate
investigation and follow-up control measures
implemented (as required).
flyrock impacts (refer to
SOP08.12)
Grievance register
Management
Relevant Guidelines
Leading Practice Sustainable
Development Program for the
Mining Industry: Airborne
Contaminants, Noise & Vibration
(Australian Government, 2009)
Mining EHS Guidelines (IFC,
2007)
Noise and vibration monitoring will be undertaken as
necessary for the Project during construction and
operations, including near noise sensitive receptors.
Noise levels in dB(A) LAeq
(daytime and night-time period
(refer to SOP 05.12)
Ground vibration levels
Grievance register
OHS&E Manager /
DEEC and CRSE
Same as above.
Relevant noise and vibration management and monitoring
measures specified in SOP05: Noise and Vibration
Management will be adopted, where appropriate.
Verification of implementation
OHS&E Manager,
Contractors /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 189
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Blasting and
Flyrock
Management
A detailed Blast Management Plan will be prepared that will
further specify blasting procedures, training, auditing, PPE
and other requirements.
Detailed drill and blast procedures will be designed by
blasting specialists to ensure the safety of the mine
workforce and surrounding local population, the control of
flyrock, noise and vibration, in accordance with the following
measures:
A 500 m blast exclusion zone (minimum) enforced
for all blasting activities for the Project;
To ensure people are outside the blast exclusion
zone, the Company will deploy methods including:
sirens, amplified verbal warnings, the posting of
sentries, the closure of access roads, and pre-blast
surveys;
Blasting to be conducted at specified times during
the day (during daylight hours), with at least 24 hour
notice given to local villages;
Blast times and locations posted on boards in local
villages;
Visual monitoring of flyrock to confirm that the
exclusion zone is sufficient to protect sensitive
receptors (biological and social);
The Company will engage a blast contractor with
relevant expertise and experience; and
Training of Project staff on fly rock safety and
conduct a public education program regarding
Zero incident record for blasts
Communication notification
records
Grievance register
Project workforce induction
and training records
Routine monitoring of noise,
airblast, and ground vibration
impacts (refer to SOP08: Blast
Management)
Air quality discharge
monitoring (refer to SOP04:
Emission and Dust Control)
Noise emission monitoring
(refer to SOP05: Noise and
Vibration Management)
OHS&E Manager,
Blast Contractor /
DEEC and CRSE
Company Plans and
Procedures:
SOP08: Blast Management
SOP04: Emission and Dust
Control
SOP05: Noise and Vibration
Management
Blast Management Plan (to be
developed)
International Standards and
Guidelines:
Leading Practice Sustainable
Development Program for the
Mining Industry: Airborne
Contaminants, Noise & Vibration
(Australian Government, 2009)
Mining EHS Guidelines (IFC,
2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 190
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
community safety issues associated with blasting.
Borrow Areas
and Quarries
Best management practices will be adopted by the
Company and contractors for the development and
operation of borrow pits and quarries including:
Minimising the footprint disturbance area;
Limiting the number of rock and borrow pit cuts
required;
Minimising site erosion and sedimentation through
appropriate control measures (SOP01);
Restricting access to the public; and
Progressive rehabilitation of sites as they become
no longer needed.
Verification of implementation
Regular visual inspections of
the borrow pits and quarries
for safety, structural integrity
and authorised personnel
access
Grievance register
Routine monitoring of noise,
airblast, ground vibration, and
flyrock impacts
Visual checks for
sedimentation, oils and grease
Routine ambient and
discharge water quality
monitoring for field
parameters, laboratory testing,
and Turbidity, TSS, DO,
temperature, electrical
conductivity (EC), and pH
OHS&E Manager,
Contractors /
DEEC and CRSE
Company Plans and
Procedures:
CEMP
SOP09: Land Clearance and
Soil Stockpiling
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
Waste
Management
Putrescible waste such as food scraps and kitchen wastes
from site based accommodation camps will be disposed of
in a suitably designed and lined landfill within the PDA.
Other non-recyclable and non-hazardous solid waste will
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 191
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
also be disposed of at the engineered landfill, while
recyclables will be recycled with an approved contractor,
where available.
Inert construction waste (i.e. concrete) will be co-disposed
with waste rock.
A detailed inventory of waste streams generated by the
Project will be maintained.
Verification of implementation
Inventory of Project waste streams
recording the following information:
Waste type;
Source;
Quantity; and
Management method.
OHS&E Manager /
DEEC and CRSE
Same as above.
Relevant waste management and monitoring measures
specified in SOP06: Waste Management will be adopted,
where appropriate.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP06: Waste Management
Hazardous
Materials and
Wastes
Management
The explosives magazine will comprise two separate
containments for the secure storage of (i) high explosives
and (ii) accessories (i.e. initiators). Each containment will be
surrounded by an earth barricade.
The magazine will be located a minimum of 800 m buffer
distance from human settlement, land use areas, and/or
built structures. (Distance subject to review during detailed
design when the quantities of explosive has been
confirmed).
Verification of implementation Designers / DEEC
and CRSE
International Standards and
Guidelines:
AS 2187 – Explosives – Storage,
Transport and Use. (Current
1998 ed.).
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 192
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Ammonium-nitrate fuel oil (ANFO) will be used as a low cost
and high stability blasting agent. ANFO will be mixed,
transported and loaded into blast holes using a specialised
truck.
The Company will implement the following specific
measures for hazardous materials stored and handled at
the Process Plant:
Hazardous wastes in the process circuit to be
reused to the extent practicable, including process
water, used carbon (which will be recovered and
reactivated) and spent electrolyte required for the
electrowinning process;
Primary containment (bunding) will be integrated for
all hazardous materials storage, handling and
transfer areas in the Process Plant (refer to below)
to ensure rainwater or spillage does not discharge
into the receiving environment. Secondary
containment has been designed for potential
discharges outside of primary bunding;
All pipe work and pumps within bunds or routed
above ground to allow the early identification of any
leaks;
Steel framed reagent storage shed constructed with
concrete floor, sumps and appropriate layout and
facilities to isolate, separate and handle hazardous
goods;
Plant areas subject to possible contamination from
chemical or slurry spills will have concrete slabs and
Verification of implementation
Spills and contaminated soil
inventory
Regular inspections for
hazardous materials leakage /
spillage
Incident register
Water quality monitoring
results
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and
Procedures:
SOP06: Waste Management
SOP07: Hazardous Materials
Management
Emergency Preparedness and
Response Plans (to be
developed)
National Standards:
Draft Standard on Management
of Solid Waste / Projet de Norme
relative à la Gestion des
Déchets Solides (2005)
Law No. 2001-01 of 15 January
2001 on the Environment Code
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines –
Hazardous Materials
Management and Transport of
Hazardous Materials (IFC, 2007)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 193
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
bunds (with 110% holding capacity) installed;
Liquid hydrocarbon products (e.g. diesel) required
for site power generation at accommodation facilities
will be stored in appropriately bunded tanks (to meet
110% of stored volume capacity);
Bunded areas to be equipped with sump pumps to
recover any spilled material or rain falling on the
slabs, for reclaim to the process;
Site run-off and spillage exceeding the capacity of
the bunds that are potentially contaminated with
cyanide and reagents will report to a lined event
pond with a submersible pump for reclaim to the
process circuit (contaminated spillage will ultimately
report to the TMF), or discharge to the TMF. ;
The distance for the tailings / return pipelines to the
TMF has been minimised and the pipeline will follow
an alignment that runs down a continuous downhill
slope to the TMF with no ‘dead legs’ in the line
requiring drain valves and scour pits to minimise
potential for leakage;
Safety showers provided for workers accidentally
exposed to hazardous chemicals; and
Routine monitoring of water quality discharge from
the Process Plant will be conducted.
United Nations, Transport of
Dangerous Goods - Model
Regulations. 17th Revised
Edition (Volume 1) Geneva 2011
AS 1940 – The Storage and
Handling of Flammable and
Combustible Liquids. (Current
2004 ed.)
International Cyanide
Management Code Principles
and Standards of Practice for
cyanide handling, storage and
transportation (ICMI, 2014)
The Company will implement the following measures for
cyanide management at the Process Plant to be consistent
with the International Cyanide Management Code and
Verification of implementation
Incident register
Project Director /
Operations
Manager / OHS&E
Company Plans and Procedures
Emergency Preparedness and
Response Plans (to be
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 194
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Guidelines (Cyanide Code) (ICMI 2014):
Materials handling, containment and bunding in all
plant areas will be consistent with the Cyanide Code
(ICMI 2014) as well as well as Senegalese
legislative requirements, in particular Law No. 2001-
01 of 15 January 2001 on the Environment Code;
Cyanide storage, handling, destruction, and disposal
consistent with the Cyanide Code (ICMI 2014) and
be conducted in a manner that avoids potential
releases to receiving waters;
Cyanide will be purchased from a member of the
International Council of Chemical Associations
Responsible Care Program consistent with the
Cyanide Code (ICMI, 2014);
As a minimum, two people with rigorous cyanide
and emergency specific training will always be
present for cyanide unloading, storage and
automated mixing (to minimise human handling,
exposure and error);
Cyanide destruction methodology will ensure
residual cyanide from the CIL circuit in the Process
Plant will be less than 50 parts per million (ppm);
Preparation of a specific Cyanide Spill Contingency
Plan as part of the Project Emergency
Preparedness and Response Plans (to be
developed); and
Monthly water quality monitoring of tailings and
Regular inspections for
hazardous materials leakage /
spillage
Water quality monitoring of
tailings and supernatant water
for key parameters (refer to
SOP02.13)
Manager / DEEC
and CRSE
developed)
SOP07: Hazardous Materials
Management
National Standards:
Law No. 2001-01 of 15 January
2001 on the Environment Code
Inter-ministerial Decree No.
1555 Discharge Water
Guidelines / L’arrêté
interministériel No. 1555 de 15
mars 2002 portant application de
la norme NS 05-061 sur les
rejets des eaux usées (2002)
Waste Water Discharge
Standard, NS 05-061 / La norme
sur les rejets des eaux (NS 05-
061) (2001)
International Standards and
Guidelines:
International Cyanide
Management Code and
Guidelines (Cyanide Code)
(ICMI 2014)
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines –
Wastewater and Ambient Water
Quality (IFC, 2007)
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implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
supernatant water for cyanide concentrations
(including breakdown products of cyanide).
EU Ambient Water Quality
Guidelines
A detailed inventory of hazardous wastes generated by the
Project will be maintained to include:
Waste type;
Source;
Quantity; and
Management method.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
Waste Management Plan (to be
developed)
National Standards:
Draft Standard on Management
of Solid Waste / Projet de Norme
relative à la Gestion des
Déchets Solides (2005)
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines– Waste
Management (IFC, 2007)
The following measures will be implemented to mitigate and
prevent potential land or water contamination from
accidental releases of hazardous chemicals into the
receiving environment:
Regular preventive inspections in areas where there
is potential for potential leakage or seepage of
hazardous materials and wastes (e.g. Process
Plant, storage areas, etc.);
The implementation of an incident register to include
spills and relevant spill management procedures to
effectively prevent and manage hazardous spills and
Visual check to ensure there
are no visible leakage or
seepage (refer to SOP07.28)
Incident register
Actions taken for immediate
remediation
Inspection records
Hazardous Waste Inventory
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
leaks as necessary; and
Maintenance of a detailed Hazardous Waste
Inventory that accurately records and tracks the
location, destination and amounts of hazardous
wastes associated with the Project to ensure proper
management and disposal in accordance with best
practices.
Relevant hazardous materials and waste management and
monitoring measures specified in SOP07: Hazardous
Materials Management will be adopted, where appropriate.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP07: Hazardous Materials
Management
Transportation of
hazardous
wastes and
dangerous goods
Hazardous substances and dangerous goods will be
transported in accordance with relevant legislative
requirements and applicable standards and guidelines.
Explosives and other hazardous materials will be
transported by a suitably licensed and reputable carrier.
Prior to contract engagement, an audit of health and safety
documentation of transporters for hazardous materials and
dangerous goods to ensure they are adequate and
compliant with legislative requirements.
Cyanide transporters will be compliant with the Cyanide
Code (ICMI, 2014). The code-compliant transporters will be
required to prepare a detailed procedure for cyanide
transport to the Project site, and provide options where
necessary to minimise risks in consultation with community
and other stakeholders. The escort contractor must be a
signatory to the Cyanide Code (ICMI, 2014) for cyanide
transport.
Management of risks and emergency response to spills or
Verification of implementation
Compliance audit and review
of licensed and certified
suppliers / transporters’
documentation (refer to
SOP07.09)
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
CEMP
SOP07: Hazardous Materials
Management
International Standards and
Guidelines:
Mining EHS Guidelines (IFC,
2007)
General EHS Guidelines –
Hazardous Materials
Management and Transport of
Hazardous Materials (IFC, 2007)
United Nations, Transport of
Dangerous Goods - Model
Regulations. 17th Revised
Edition (Volume 1) Geneva 2011
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
accidents during the transport of hazardous materials and
dangerous goods will be the responsibility of the licensed
carrier.
AS 1940 – The Storage and
Handling of Flammable and
Combustible Liquids. (Current
2004 ed.)
International Cyanide
Management Code Principles
and Standards of Practice for
cyanide handling, storage and
transportation (ICMI, 2014)
AS 2187 – Explosives – Storage,
Transport and Use. (Current
1998 ed.)
IFC PS4 Community Health,
Safety and Security (2012)
Key measures to adopt by the contractor for the
transportation of hazardous materials and dangerous goods
include:
A road safety and maintenance program for
transport vehicles that includes procedures for
vehicle and tire inspections, preventive
maintenance, drivers fatigue management and
permitted driving hours, tie-down of loads, and
actions to be taken if severe weather conditions are
encountered;
Careful consideration of transport distances and
routes;
Where appropriate, the Contractor will arrange for a
specialised escort ‘warning’ vehicle where transport
Verification of implementation
Compliance audit and review
of licensed and certified
suppliers / transporters’
documentation (refer to
SOP07.09)
Contractor training records
Hazardous materials and
dangerous goods inventory,
tracking and chain of custody
documentation
Incident register
OHS&E Manager,
Contractors /
DEEC and CRSE
Same as above.
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
routes present safety or security concerns for the
transport of cyanide, explosives and other
dangerous goods or hazardous materials;
Project vehicles carrying dangerous goods and
hazardous materials will travel in off-peak times
when there is less traffic on roads to the extent
practicable. Procedures for regular communications
between transport vehicles and the transporter
contractor will be in place;
Drivers of dangerous goods and hazardous
materials will be adequately trained to handle local
road conditions and follow safety protocols;
The contractor will develop specific emergency
response and clean-up procedures for road
transport;
Drivers transporting dangerous goods and
hazardous materials will be adequately trained on
appropriate emergency response and clean-up
procedures to follow in the case of a spill;
of the contractor will provide appropriate PPE and
clean-up skill kits (including for cyanide specific PPE
and neutralising agents, where appropriate) for
drivers transporting hazardous materials and
dangerous goods, including gloves, plastic coveralls,
safety glasses and self-contained respirators, etc.;
and
Inventory controls and/or chain of custody
Inspection records
Mako Gold Project
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
documentation in place to identify the loss of any
hazardous material during transport.
Land and
Vegetation
Clearance
Management
The footprint of the Project has been minimised to limit
vegetation clearing to the extent practicable. The Company
will adopt relevant vegetation clearance measures specified
in SOP09: Land Clearance and Soil Stockpiling, where
appropriate.
Where appropriate, the procedure for land clearance will
include consultation with local villagers regarding current
land uses, and social and cultural assets in the area prior to
disturbance.
A register will be maintained of all land disturbed by Project
activities.
The extent of vegetation clearing will be continually
monitored to ensure unnecessary vegetation removal does
not occur (refer to SOP09.2).
Verification of implementation
Register of land clearance and
soil stockpiling
Ongoing monitoring of the
extent of vegetation clearing
for the Project
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP09: Land Clearance and
Soil Stockpiling
International Standards and
Guidelines:
IFC PS6 Biodiversity
Conservation and Sustainable
Management of Living Natural
Resources (2012)
UNESCO Operational
Guidelines for the
Implementation of the World
Heritage Convention (2013)
Land and Soil
Resources
Management
Relevant land and soil resource measures specified in
SOP09: Land Clearance and Soil Stockpiling will be
adopted, where appropriate.
Verification of implementation
Soil stockpile inventory,
including location of temporary
and long-term stockpiles and
approximate volume of
material
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP09: Land Clearance and
Soil Stockpiling
Archaeology and
Cultural Heritage
Management
The Company will implement the Chance Find
Procedure for the protection of physical cultural
resources in the PDA, as per SOP10: Cultural
Heritage Management.
Verification of implementation
Regular review of compliance
and implementation of
archaeological and cultural
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
Chance Find Procedure
SOP10: Cultural Heritage
Mako Gold Project
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Project staff will be trained in the implementation of
SOP10, as relevant to their roles and
responsibilities.
A register will be maintained of all areas that have
been the subject of detailed archaeology and
cultural heritage studies. The register will include all
sites and artefacts identified in the Project area.
heritage management
measures
Periodic inspection of known
sites of cultural heritage or
archaeological significance
within or adjacent to a
construction worksite to
confirm no accidental
disturbance has occurred
Cultural heritage register
Grievance register
Training records
Management
Detailed archaeology and cultural heritage studies will be
conducted in advance of all land disturbance activities.
Infrastructure corridors will be the subject of an archaeology
and cultural heritage study in advance of Project
construction.
The Company will liaise with specialists regarding the
documentation and display of archaeology and cultural
heritage artefacts identified in the Project area.
Verification of implementation OHS&E Manager /
DEEC and CRSE
Same as above.
Lighting and
Visual Amenity
Management
The visual impacts of the Process Plant and ROM will be
minimised by implementing the following measures:
Strategic use of revegetation as visual screening
and noise buffer, where required;
Night lighting from the Process Plant and ROM to be
minimised to the extent possible for a safe working
environment, and site lighting will be directed to
Verification of implementation
Inspection records
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Company Plans and Procedures
SOP11: Lighting and Visual
Amenity Management
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 201
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
minimise spillage to external areas; and
Buildings, roofs and fencing will be painted in a
neutral non-reflective colour that blends with the
natural landscape and surrounds (e.g. dark green or
brown).
Relevant lighting and visual amenity measures specified in
SOP11: Lighting and Visual Amenity Management will be
adopted, where appropriate.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
SOP11: Lighting and Visual
Amenity Management
Rehabilitation
and Mine
Closure
General environmental management measures that will be
implemented during the decommissioning and closure
phase of the Mako Gold Project will include:
Removal of access to facilities that present safety
risk (e.g. Mine Pit);
Removal of all equipment and vehicles from the site;
Removal and appropriate disposal of all chemicals,
fuels and oils from the PDA;
Buildings and structures demolished and the rubble
transported to an appropriate disposal area;
Buildings / facilities with significant residual value to
the Company may be sold for dismantling, relocation
and/or recycling;
Buried pipelines to be cleaned, sealed and left in-
situ;
Power lines and above ground pipelines removed to
an approved disposal area;
On-site and downstream water
quality (i.e. with respect to
baseline conditions and
applicable discharge
guidelines);
Land rehabilitation register:
revegetation success (e.g. %
coverage, species diversity, %
weeds)
Geotechnical and landform
stability
GPS locations of recorded
contaminated land sites
Inspection records
OHS&E Manager, /
Operations
Manager / DEEC
and CRSE
Company Plans and
Procedures:
RCMCP
BAP
Final RMCP (to be developed
prior to decommissioning)
SOP02: Water Quality and
Pollution Management
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 202
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Footings / foundations will be removed;
Stormwater management systems (i.e. drainage
channel and sediment pond below the TMF) will be
retained until they are no longer needed;
A contaminated land survey conducted to identify
any such areas and appropriate clean up measures
will be designed and implemented;
Compacted areas, including roads and building
footprints will be ripped and graded to blend into
surrounding contours and to ensure drainage
patterns are similar to pre-mining conditions;
Establishment of engineered erosion control
measures where needed;
All seeding and planting sourced from native stock
of local provenance; and
Fencing removed, unless retained for public and
livestock safety reasons.
The Company will implement the following specific
decommissioning and closure strategies and measures for
Project facilities:
Rehabilitation and revegetation of Pit margins and
temporary equipment access roads. A safety berm
will be constructed around the Pit void for public
safety. Targeted species may be planted on pit
benches, pending the suitability of the material to
support plant life;
Full suite of dissolved and total
metals, cyanide (total cyanide,
free cyanide, and WAD
cyanide), salinity, pH,
nutrients, etc. of the TMF
supernatant water
On-site and downstream water
quality (i.e. with respect to
baseline conditions and
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 203
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
The WRD to be graded to contours that align with
adjacent topography and ripped to minimise batter
scour. Where possible, the WRD will be
progressively revegetated to establish a Wooded
Savannah vegetative community comprised of
native species of local provenance. Rock-lined
drains will be constructed, where required, to ensure
excess run-off is controlled and directed down to
sediment traps or to the TMF;
The TMF to be partially capped with waste rock in
order to prevent seepage; the top surface
engineered to prevent water pooling; slopes graded
to a stable 1 in 100 slope and engineered to
encourage sheet flow of run-off water and prevent
excessive channelling and erosion; and rehabilitated
with armoured drainage channels to ensure that
tailings material is securely stored (i.e. erosion
resistant);
At closure, the stormwater spillway on the eastern
abutment of the TMF will be converted into a
permanent discharge channel to allow surface water
to freely discharge from the surface of the
rehabilitated facility;
At the end of operations, the Processing Plant and
ROM pad will be cleared to ground level and
rehabilitated.All exposed soil will be re-contoured
and ripped and re-vegetated to a landform
consistent with the surrounds upon mine closure
applicable discharge
guidelines);
Land rehabilitation register:
revegetation success (e.g. %
coverage, species diversity, %
weeds)
Inspection records for
geotechnical and landform
stability
GPS locations of recorded
contaminated land sites
Mako Gold Project
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
(i.e. Bowal) to minimise potential for erosion;
A strategy for the disposal of processing reagents,
decontamination of equipment, removal of water
from pond surfaces, will be developed to a level
protective of human health and wildlife, and
installation of equipment necessary for long-term
protection of ground and surface water quality
during the Process Plant’s closure period.
Soil and groundwater testing will be undertaken to
determine whether contamination has occurred with
treatment/remediation implemented if required. The faces
of the ROM pad, the immediate surrounds of the Process
Plant and any exposed areas of soil within the Process
Plant site will be tested for contaminants and re-
vegetated as early as possible after deconstruction
(unless remediation for waste is required first). Any
concrete foundations or soil contaminated by metals,
hydrocarbons or other contaminants will be
decontaminated (volatilisation) and disposed of in a lined
landfill.
Treatment strategies to be further refined before
commissioning of operations;
The WSD embankment breached after mine closure
and the channel re-established so that the
watercourse will resume its natural flow regime post-
closure. The WSD footprint will be rehabilitated with
local non-invasive plant species;
Monitoring of aurface water quality at the
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
downstream compliance points (Badalla Creek and
Gambia River) to ensure applicable discharge and
ambient water quality guidelines are met;
Analysis of the TMF supernatant water to determine
whether treatment is required before establishment
of a permanent discharge channel. Suitable
remedial measures, frequency of treatment, and
ongoing requirements will be determined, if post-
closure treatment is required;
Monitoring of planted / seeded vegetation for
successful establishment. These will be maintained
where necessary;
Monitoring of rehabilitated landforms for
maintenance requirements, particularly with respect
to erosion; and
Monitoring of biodiversity as per the Project BAP to
assess the effectiveness of mitigation measures for
rehabilitation. Monitoring will be undertaken in both
dry and wet seasons to allow comparisons to be
made between seasons over time and in key areas
such as chimpanzee nesting habitat.
For the decommissioning of Project road infrastructure, the
following management and mitigation measures will be
implemented to mitigate water quality and other
environmental impacts:
Road borders and embankments progressively re-
vegetated where necessary for erosion control;
Verification of implementation
On-site and downstream water
quality
Land rehabilitation register:
revegetation success (e.g. %
coverage, species diversity, %
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation &
monitoring /
Enforcement
Relevant Documentation
C* O* D*
Road related structures removed where practicable,
including road signage, culverts, oil or grease traps
and hydrocarbons (if applicable);
Rehabilitate Project roads (unless they will be made
available for community use) by ripping road
surfaces, re-shaping to pre-construction contours,
and stabilising and revegetating with native plant
species of local provenance;
Road drainage redirected as necessary to minimise
erosion until vegetation is established; and
An earth berm constructed across the Main Access
Road to maintain community safety.
weeds)
Geotechnical and landform
stability
Inspection records
For Project infrastructure that will be transferred for future
use by local government or community, the Company will
consult and negotiate with the relevant parties and
stakeholders to ensure that:
Remaining mine facilities (e.g. TMF) that may pose
a safety risk to the public are adequately secured;
and
Maintenance requirements and associated costs are
clearly defined.
Verification of implementation OHS&E Manager /
DEEC and CRSE
Same as above.
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18.3 Summary of Biological Environment Management and Monitoring Measures
Table 18-3 Register of Biological Environment Management and Monitoring Measures
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Terrestrial and
Aquatic
Biodiversity
Management
The Company will implement the mitigation hierarchy to
avoid, minimise, restore and offset impacts on biodiversity.
The Company will adopt a no net loss approach, where
residual impacts to habitats and species will be offset.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
BAP
SOP09: Land Clearance and Soil
Stockpiling
The Biodiversity Action Plan developed for the Project will
be implemented, providing detailed plans and procedures
for the protection and management of biodiversity (aquatic
and terrestrial) issues. Project personnel and contractors
will adhere to this Plan.
A Biodiversity Offset Strategy will also be implemented to
provide a compensatory mechanism to offset residual
impacts that cannot be avoided, mitigated and/or managed.
The Biodiversity Offset Strategy will be designed through a
process of stakeholder engagement and will focus on the
conservation of priority species and habitats including the
protection of the PNNK.
Key biodiversity measures and strategies detailed in the
BAP and Offset Strategy will be incorporated into relevant
procedures, training, and instructions for the workforce and
contractors, as relevant to their roles and responsibilities
Verification of implementation
Training records
OHS&E Manager,
Contractors /
DEEC and CRSE
Company Plans and Procedures
BAP (including Biodiversity Offset
Strategy)
SOP01: Erosion and Sediment Control
SOP09: Land Clearance and Soil
Stockpiling
International Standards and
Guidelines:
IFC PS 6: Biodiversity Conservation
and Sustainable Natural Resource
Management (2012)
IUCN Red list of Threatened Animals
and Plants (2013)
Good Practice Guidance for Mining
and Biodiversity (ICMM, 2006)
Standards on Biodiversity offsets
(BBOP, 2012)
Resolution VIII.9: 'Guidelines for
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incorporating biodiversity-related
issues into environmental impact
assessment legislation and/or
processes and in strategic
environmental assessment' adopted by
the Convention on Biological Diversity
(CBD), and the Ramsar Convention
The following biodiversity management measures will be
adopted to minimise potential impacts on flora, fauna and
protected areas:
To minimise inadvertent impacts to the PNNK from
mining activities, the Company will avoid land
disturbance within the 1 km buffer zone of the
PNNK;
Collaboration with the PNNK area managers to
ensure impacts on the integrity of the PNNK and
surrounding forested areas are adequately
mitigated;
The footprint for the various Project components
have been minimised to the extent practicable, and
a specific vegetation clearance procedure will be
implemented to avoid further disturbance to
surrounding areas. Land disturbance permits will be
required prior to any vegetation clearance, in
accordance with SOP09: Land Clearance and Soil
Stockpiling. Environmentally sensitive areas (e.g.
critical habitat, PNNK boundary) will be clearly
marked as ‘No Go Areas’;
Access to the PNNK and buffer zone by Project staff
to be restricted and subject to approval from the
DPN;
As a condition of employment, ban Project staff from
Verification of
implementation
Incident register
Detailed biodiversity
monitoring program
(refer to further details
below)
Training records
Consultation records
Land rehabilitation
register
OHS&E Manager /
DEEC and CRSE
Same as above plus:
SOP07: Hazardous Materials
Management
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Environmental and Social Management and Monitoring Plan
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hunting, buying or trading wildlife as well as
collecting timber and Non-timber Forest Products
(NTFPs) to help conserve existing fauna and forest
resources (e.g. food for wildlife);
In areas to be cleared, identification and retention or
relocation of restricted-range flora (Lepidagathis
capituliformis, Scleria chevalieri and Tephrosia
berhautiana), threatened flora and important fauna
resources (e.g. baobab trees), where practicable.
Seed collection and propagation of priority flora
species will be included in the inventory of plants
used for Project revegetation activities;
Removal of identified bowal habitat (where this
provides habitat to restricted-range flora species)
and gallery forest habitat (priority nesting habitat for
West African chimpanzee) will be avoided where
possible;
Use of water to minimise dust levels in areas of
biodiversity sensitivity. Control measures will be
employed to minimise erosion and the risk of
suspended sediments release drainage systems as
per SOP01: Erosion and Sediment Control;
Avoid impacts to habitats, priority flora and protected
area through spills of spills of hydrocarbon and
hazardous materials (e.g. paint, solvents etc.)
through adherence to SOP07: Hazardous Materials
Management;
Implementation of the invasive weed prevention
protocol to prevent the introduction and transfer of
invasive species (i.e. Mimosa pigra). This will
include the avoidance of affected areas by staff and
vehicles where possible; wash-down procedures of
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Project vehicles moving from the Gambia River and
other known affected areas; and use of non-
invasive local species for revegetation;
Progressive rehabilitation and revegetation
undertaken as soon as possible throughout the life
of the Project to minimise the impact of land
clearance as per the RCMCP (Volume E);
Implementation of bushfire controls, including
Project ban on open-burning of wastes, specific
emergency response procedures developed for
managing bushfires, and establishment of fire
breaks (where required);
Consultation with local authorities and communities
to minimise the impact of in-migration on natural
resource exploitation (including hunting);
Periodic monitoring of habitat and key terrestrial and
aquatic species will be conducted as part of the BAP
(Volume C) to assess the efficacy of the mitigation
measures and to inform any requirements for
adaptive management; and
Environmental education and awareness programs
will be conducted for Project staff and contractors as
relevant to their roles and responsibilities.
Supplementary flora studies of Bowal habitat in the vicinity
of the Project will be conducted
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Same as above.
The Company will adopt additional measures to mitigate
fauna impacts, including:
Testing a variety of bird scaring techniques to
assess their effectiveness in deterring birds from
ingesting the surface water at the TMF. If the trials
are successful, bird scarers will be utilised on a
Verification of
implementation
Incident register
Detailed biodiversity
monitoring program
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Same as above, plus:
SOP11: Lighting and Visual Amenity
Management
SOP02: Water Quality and Pollution
Management
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regular basis to prevent fauna poisoning from
drinking tailings water;
Security fencing around the site perimeter of the
TMF to restrict livestock and some species of local
wildlife from accessing these areas;
Injured Wildlife Protocol to be followed by staff and
contractors if injured or dead wildlife is found or in
the event of an incident (e.g. fauna move away
following vehicle collision), which includes the
following steps:
» Species identification;
» Procedures for the safe management of injured
and dead wildlife including the minimisation of
human contact;
» Mandatory reporting of wildlife incidents that
includes road accidents (e.g. collision with
wildlife or livestock) for all Project workers and
contractors.
Operation of noisy machinery will be avoided at
dusk, dawn and night wherever practicable, to avoid
disturbance to fauna;
Project staff to avoid initiating contact with fauna to
minimise the risk of disease transfer and
disturbance;
Vegetation clearance undertaken in a progressive
and sensitive manner to enable priority fauna to
move away from the area of works and to avoid
fauna from being isolated in fragmented pates of
habitat;
An ecologist will be on call during habitat clearance
(refer to further details
below)
SOP05: Noise and Vibration
Management
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work to provide assistance / advice regarding any
biodiversity issues if required;;
Priority species-specific monitoring and
management (e.g. for West African chimpanzees)
undertaken as appropriate, as per the BAP
monitoring requirements;
Implement relevant fauna management measures
for night lighting detailed in SOP11: Lighting and
Visual Amenity Management, where necessary; and
Adherence to SOP02: Water Quality and Pollution
Management for water quality and pollution
management throughout the lifespan of the Project
to minimise the risk of adverse impacts to aquatic
fauna and habitats.
Project roads have been aligned to minimise vegetation
clearance and habitat fragmentation, and avoid
environmentally sensitive areas. The Company will
implement key biodiversity management measures during
construction of Project roads, including:
Applying applicable elements of the BAP where
appropriate;
Avoid impacts to environmentally sensitive areas
wherever practicable as identified through the land
disturbance permitting system in place (refer to
SOP09: Land Clearance and Soil Stockpiling).
Sensitive areas will be marked as ‘No Go Zones’;
To minimise the risk of vehicle collision with fauna,
speed limits within the PDA will be reduced and
driving at night outside of the PDA will not be
permitted unless permission has been sought or in
the event of an emergency;
Verification of
implementation
Incident register
Detailed biodiversity
monitoring program
(refer to further details
below)
Land disturbance
register
Land rehabilitation
register
Project Director /
Operations
Manager / OHS&E
Manager / DEEC
and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 213
Avoiding impacts to waterways and riparian
vegetation during road construction to the extent
practicable;
Progressively rehabilitate temporarily disturbed
areas as soon as possible;
Restricting access to Project roads within the PDA
(where appropriate) to authorised people only; and
Adherence to the Injured Wildlife Protocol.
Specific biodiversity management measures that will be
applied during Project operations include:
Management of habitats adjacent to and within the
PDA to minimise disturbance to fauna, habitat loss
and degradation (e.g. from poaching, exploitation of
natural resources);
Establishment of a checkpoint at the entrance to the
PDA to ensure no unauthorised entry;
Continual improvement of mine blast associated
noise, vibration and airblast management measures
to minimise fauna impacts; and
Monitoring and adaptive management, as
necessary.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Same as above, plus:
SOP08: Blasting Management
The following mitigation measures will be adopted during
the decommissioning and closure phase:
All cleared/disturbed areas to beprogressively
revegetated and rehabilitated, unless required for
community or Government use;
Assess the feasibility of artificial filtering systems
(e.g. mini wetlands) for the treatment of discharge
Verification of
implementation
Rehabilitation and
closure success criteria
monitoring (as per
RCMCP)
Revegetation success
OHS&E Manager /
DEEC and CRSE
Company Plans and Procedures
RMCP
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 214
water, and implement as appropriate;
Closure criteria for rehabilitation will be met; and
Monitoring in rehabilitated areas, in order to assess
the success of restoration of habitat.
Inspection records
A comprehensive biodiversity monitoring program for the
Project will be further refined and implemented, including
confirmation of specific monitoring sites, including:
See further details below.
OHS&E Manager /
DEEC and CRSE
Same as above.
Camera trapping and sightings
Changes in species
recorded;
Changes in frequency of
habitat use; and
Trigger for adaptive
management: decline in
habitat use.
Targeted chimpanzee surveys
Changes in the number
of fresh, recent, old and
ancient nests;
Changes in nesting
range;
Changes in habitat
usage;
Trigger for adaptive
management: significant
decline in the number of
fresh / recent nests,
significant declines in
maximum number of
nests per nesting site;
and reduction in nesting
range.
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 215
Targeted hippopotami surveys
Changes in the total
number of hippopotami;
Changes in the
maximum number of
hippopotami per group;
Changes in seasonal
habitat use; and
Trigger for adaptive
management: significant
reduction in hippopotami
numbers, and reduction
in habitat use between
seasons.
OHS&E Manager /
DEEC and CRSE
Same as above.
Vulture nest surveys
Changes in the number
of active vulture nests;
Changes in the number
of vulture nesting sites;
and
Trigger for adaptive
management: significant
decline in the number of
active nests, and decline
in sites.
OHS&E Manager /
DEEC and CRSE
Same as above.
Priority flora survey and monitoring. Presence / likely
absence of priority flora
species based on field
investigations;
Dust levels;
High level of dust on
individuals and signs of
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 216
plant stress e.g.
chlorosis;
Changes in species
abundances ;
Trigger for adaptive
management: elevated
dust levels, and high
coverage of dust on
priority flora and bowal
habitat.
Invasive species reporting and checks. New record of invasive
species i.e. Mimosa
Pigra;
Trigger for adaptive
management: increased
number of infested sites.
OHS&E Manager /
DEEC and CRSE
Same as above.
Report incidents involving wildlife (and livestock), including
encounters of wildlife (i.e. carcass, injured and priority
species) and observation of poaching, illegal wildlife trade or
logging.
Mandatory wildlife incident
reporting system for Project
employees and contractors.
Relevant government authorities
will be notified as necessary.
Trigger for adaptive
management: changes in
the number of deaths;
confirmation of disease
outbreak; number of
confirmed poison cases.
OHS&E Manager /
DEEC and CRSE
Same as above.
Monitoring of vegetation clearance. Routine checks to ensure
vegetation clearing is confined to
defined areas of disturbance,
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 217
vehicles use designated access
routes, and any sensitive
environmental areas (i.e. ‘No Go
Areas’) to be retained are clearly
marked (e.g. flag/tape).
Land disturbance register
Macro-invertebrate survey and bio-indicator water quality
assessment. Changes in water quality
identified by the macro-
invertebrate bio-indicator
assessment.
Trigger for adaptive
management: significant
decline in macro-
invertebrate abundance
and diversity; significant
changes in bio-indicator
species; and reduction in
the biological health of
the Gambia River.
Aquatic fauna and habitat
monitoring as per SOP02.18.
OHS&E Manager /
DEEC and CRSE
Same as above.
Drift net survey; Changes in the diversity,
abundance and catch
per unit effort of fish;
Changes in the
proportion captured
juvenile and adult fish;
Trigger for adapted
management: significant
decline in the diversity,
abundance, CPUE of
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 218
fish; significant decline in
adult fish.
Routine monitoring of rehabilitation areas to assess the
success of restoration measures. Monitoring records will include
the following:
Area
revegetated/rehabilitated
;
Survival rate of planted
seedlings by species
type and replanting
requirements;
Native versus non-native
plant establishment; and
Photographs.
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 219
18.4 Summary of Social Management and Monitoring Measures
Table 18-4 Register of Social Management and Monitoring Measures
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Land
Management
and Livelihood
Restoration
The Company will avoid and/or minimise the economic
displacement due to Project land take. Mitigation measures will
be implemented such that no person will suffer a livelihood loss
due to the Project. The principles and approach that will be
adhered to are outlined in the Draft Livelihood Restoration Plan
(LRP).
Subject to consultation with Project affected people (PAP),
livelihood mitigation will be planned according to the following
hierarchy of preference:
Category 1 – Restoration of existing livelihood;
Category 2 – Intensification of existing livelihoods;
Category 3 – Introduction of alternative livelihoods.
Verification of implementation
Monitoring of the
implementation of livelihood
restoration program (indicators
will be developed in
consultation with the community
and government)
External compliance reviews
and a completion audit
focussing on the assessment of
compliance with the
requirements contained in the
LRP
OHS&E Manager /
DEEC and CRSE
Company Plans and
Procedures:
LRP
National Standards:
Senegal - Decree for
application 64-573 (GRS,
1964)
International Standards
and Guidelines:
IFC PS5 Land Acquisition
and Involuntary
Resettlement (2012)
IFC A Guide to Getting
Started in Local
Procurement (2011)
IFC Strategic Community
Investment (2010)
The Company will formally register privately owned and
community assets that are likely to be impacted by Project
development. This registration process will be done in
consultation with local communities and government authorities.
Formal register of Project affected land,
assets and livelihood
OHS&E Manager /
DEEC and CRSE
Same as above.
The Company will undertake detailed negotiations with Project Stakeholder engagement OHS&E Manager / Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
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Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
affected people on the mitigation measures resulting from Project
land take. The outcome of these negotiations will include a
finalised LRP and collective and/or individual-level agreements.
database and consultation
meeting records
Collective and/or individual
agreements with Project
affected people
Final LRP
DEEC and CRSE
The Company will implement Livelihood Restoration and
Livelihood Improvement Programs as agreed with PAPs, aimed to
restore and improve the assets, levels of economic productivity,
and/or standards of living to pre-Project levels.
Livelihood mitigation measures will be maintained by the
Company for as long as necessary to fully restore the livelihood of
PAPs.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Same as above.
Vulnerable
Groups
A “vulnerable persons” assistance program will be implemented
as part of the LRP, which will include specific assistance
measures to vulnerable households or groups.
Specific aspects of the vulnerable persons’ assistance program
will include:
Recruitment of part-time Vulnerable Persons Officer; and
Preparation and up-date of a formal register of vulnerable
groups (“vulnerables watch list”) throughout the life of the
Project.
Verification of implementation
Formal register of vulnerable
groups (“vulnerables watch list”)
OHS&E Manager /
DEEC and CRSE
Same as above.
Employment
Opportunities
The Company will implement an overall Equal Opportunity
Employment Policy, which requires the Project to provide equal
opportunity to all applicants regardless of age, gender or ethnicity.
Workforce statistics (including
employment by contractors)
OHS&E Manager /
DEEC and CRSE
Company Plans and
Procedures:
LEPP and LRP
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 221
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
The Company will implement a Local Recruitment Policy that is
based on a preference for the most local candidate. The Local
Economic Participation Plan (LEPP) will be implemented to
support this recruitment approach.
International Standards
and Guidelines:
IFC PS5 Land Acquisition
and Involuntary
Resettlement (2012)
IFC: A Guide to Getting
Started in Local
Procurement (2011)
IFC Strategic Community
Investment (2010)
International Council on
Mining and Metals (ICMM)
Sustainable Development
Framework
Local
Procurement
The Company will implement a Local Procurement Policy to
maximise the opportunity for local suppliers to participate in the
supply chain for the Project.
Local goods and services
procured by the Project - refer
to procurement records
Maintenance of a Local Supplier
Database
Company Plans and
Procedures:
LEPP
International Standards
and Guidelines:
IFC: A Guide to Getting
Started in Local
Procurement (2011)
IFC Strategic Community
Investment (2010)
International Council on
Mining and Metals (ICMM)
Sustainable Development
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 222
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Framework
Community /
Stakeholder
Engagement
Stakeholder consultation will be conducted for affected peoples,
and villagers.
The established Stakeholder Engagement Plan (SEP) for the
Project will be implemented and further refined.
Community consultation will involve a cross-section of local
residents (i.e. different ethnicities, a range of ages, gender
balance, etc.) to ensure that the opinions and concerns of all
groups are considered.
Disseminate understandable information in advance of
consultation and decision-making
Community awareness and
understanding of Project
information
Information disclosed as per the
SEP
Key stakeholders consulted as
per the SEP
Number of consultations
conducted
Grievance register
OHS&E Manager /
DEEC and CRSE
Company Plans and
Procedures:
SEP
International Standards
and Guidelines:
Stakeholder Engagement:
A Good Practice
Handbook for Companies
doing Business in
Emerging Markets. IFC
(2007)
Doing Better Business
through Effective Public
Consultation and
Disclosure. A Good
Practice Manual. IFC
(1998)
Handling and Resolving
Local Level Concerns and
Grievances. ICMM (2009)
Community Development
Toolkit. ICMM (2005).
Develop and maintain structured engagement mechanisms for
the dissemination of Project information responding to people’s
concerns, suggestions and grievances. This is expected to
include:
Verification of implementation
Consultation database
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 223
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Project Negotiations Forum (PNF) to support the LRP;
Local Consultation Committee (Groupe de Contact); and
Other thematic working groups and focus group
discussions (as needed).
The Company will use a range of other engagement tools and
activities including:
Public Information Centre (PIC) to serve as a space for
trainings, meetings, workshops and to post notices;
Notice boarding, advertisements and press releases;
Community meetings in Project affected villages;
Meetings with existing structures such as the Municipal
Council.
Workshops to discuss technical issues with relevant
stakeholders;
Direct engagement with stakeholders where necessary.
Project
Grievances
The Project grievance management system will be implemented
to record and resolve community complaints in a transparent,
constructive and timely manner.
Reported grievances and
resolutions
Response times on claims via
the grievance register
Number of claims elevated to
Third or Fourth Order
Mechanism
Satisfaction levels - gauged
through discussions with the
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 224
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Local Consultation Committee /
Project Negotiation Forum
Community
Health, Safety
and Security
The following general management measures will be
implemented to minimise Project impacts on community health
and safety:
Establishment of health and safety management systems
for the community, covering aspects on security, Project
hazards, disease prevention (e.g. HIV and Malaria
programs), and safe sanitation and hygienic practices;
A range of security controls will be developed in
consultation with relevant actors in advance of Project
Construction. These controls will be routinely reviewed
with regional authorities;
Implementation of a community education and awareness
program regarding public safety in and around the PDA
(particularly related to road safety);
An exclusion zone defined to restrict and control access
within the PDA and ensure community safety. This zone
will include the blast exclusion zone. The zone will be
monitored prior to blasting activity;
In partnership with local health authorities, support
community malaria prevention programs in Project
affected villages;
In partnership with local authorities, support community
hygiene and sanitation programs in Project affected
villages;
In partnership with local health authorities, support
Verification of implementation
Logged community complaints
and grievances through the
Project grievance management
process
Noise limit and air quality limit
exceedances at nearby
sensitive receptors
Health and nutritional indicators
in the local community (e.g.
availability of food, food supply
options, prevalence of
undernourishment, agricultural /
food production etc.) and
workforce
Increased injuries and fatalities,
including:
Number of transport related
incidents / grievance claims –
refer to grievance log
Number of community safety
incidences or livestock losses
associated with restricted
areas– refer to visual inspection
OHS&E Manager /
DEEC and CRSE
Company Plans and
Procedures
Emergency Preparedness
and Response Plans (to
be developed)
International Standards
and Guidelines:
General EHS Guidelines
(IFC, 2007)
Mining EHS Guidelines
(IFC, 2007)
IFC PS4 Community
Health, Safety and
Security (2012)
IFC PS5 Land Acquisition
and Involuntary
Resettlement (2012)
ICMI, International
Cyanide Management
Code (2014)
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 225
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
community HIV/AIDS awareness programs in Project
affected villages;
Mitigate the adverse impacts of the Project on access to
community infrastructure and services (e.g. water supply,
hygiene and sanitation, health, security), particularly those
related to Project induced in-migration. The Company will
monitor the impacts of in-migration in consultation with
local authorities and communities in Project affected
villages;
Maintain a surface and groundwater quality monitoring
program, including routine sampling of village drinking
water in Project affected villages;
In partnership with local authorities, support community
drinking water management programs in Project affected
villages.
and audit records
Number of community
consultations / awareness
sessions conducted – refer to
consultation record sheet and
database
Worker health
and safety
Establishment of health and safety management systems
for Project workers, covering aspects on security, Project
hazards, disease prevention (e.g. HIV and Malaria
programs), and safe sanitation and hygienic practices;
Provision of health care services for its employees with an
appropriately staffed on-site clinic and medivac
capabilities;
Health and nutritional indicators
in the workforce
Number of worker training
sessions conducted (refer to
training records)
OHS&E Manager /
DEEC and CRSE
In-Migration
Prior to construction and in consultation with local authorities, the
Company will re-assess the need for the development of an In-
Migration Management Strategy.
Verification of implementation
OHS&E Manager /
DEEC and CRSE
Not applicable.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 226
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
The Company will mitigate the adverse impacts arising from
Project induced in-migration. The Company will monitor the
impacts of in-migration in consultation with local authorities and
communities in Project affected villages. Management measures
will include:
Working with local authorities to minimise the potential
impacts on in-migration (e.g. security, education and
awareness campaigns against drug and alcohol abuse,
supporting health services) and to monitor demand and
resources;
Provision of daily bus transportation for Project staff
between the Project site and Kedougou town to enable
workers to live and commute from Kedougou without
suffering from fatigue;
Implementation of a recruitment policy which prioritises
local employment;
Recruitment for unqualified positions to be restricted to
residents in Tomboronkoto Commune only;
Local and regional residents will have preferential access
to skills upgrading courses, based on Project skill
requirements;
Provision of training to assist in developing local skill
levels and entrepreneurship that is not solely dependent
upon the Project;
Access to the accommodation camps restricted to Project
staff and people with an authorised visitor pass. No staff
Verification of implementation
Household surveys recording the
following socio-economic indicators:
Demographic indicators;
Population growth and in-
migration;
Income and expenditure
indicators, incidence of poverty;
Livelihoods and employment
indicators;
Housing and assets;
Education; and
Health and nutrition indicators.
Monitoring of effectiveness of local
recruitment and procurement, including;
Local workforce statistics
(including employment by
contractors) - refer to
employment records;
Number of training sessions;
Local goods and services
procured by the Company (refer
to procurement records);
OHS&E Manager /
DEEC and CRSE
Company Plans and
Procedures:
In-Migration Guidance
Note
Worker Accommodation
Guidance Note
LEPP and SEP
Project recruitment policy
International Standards
and Guidelines:
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 227
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
will be allowed outside the camps between the hours of
seven pm till morning;
Socio-economic surveying and review of census data for
Project affected villages will be conducted over the Project
life to understand the extent of population growth and any
related impacts; and
Incentivise the in-migration of Project staff to Kedougou
where this has potential to result in adverse impacts to
Project affected villages;
Increase the capacity of Tomboronkoto Commune, and
Mako and Niemenike in particular, to plan for and absorb
in-migration in a manner that improves quality of life and
maximises economic benefit. This may include providing
assistance to the Municipal Council to support the
preparation of the Commune Development Plan ;
Work with local authorities and communities to restrict the
development of new habitation areas within the PDA and
other areas of the mining concession where this could
present risks to human safety and/or the operational
security of the Project.
Maintain a Local Supplier
Database;
Training session for suppliers
Monitoring of livelihoods, health and in-
migration indicators (indicators will be
developed in consultation with the
community and government)
Monitoring of local economic pilot
programs (indicators will be developed
in consultation with the community and
government)
Reported Project grievances and
resolutions
Community
Development
The Company will establish a social and environmental
investment fund to ensure that the Commune of Tomboronkoto,
and more broadly the State of Senegal, shares the benefits of the
Project. Investment will be aligned with government policy and
local development plans i.e. Commune and Departmental
development plans and PNNK management plan.
Verification of implementation
Achievement of development goals as
agreed with local authorities
OHS&E Manager /
DEEC and CRSE
Same as above.
Mako Gold Project
Environmental and Social Management and Monitoring Plan
FINAL 228
Aspect / Impact Phase Management Measure / Commitment Monitoring Indicators Responsible for
implementation
& monitoring /
Enforcement
Relevant Documentation
C
*
O* D*
Community
Awareness and
Education
Program
A community awareness and education program for local
communities will be conducted. The scope of these programs
may include:
Public health, sanitation, and sexually transmitted
diseases;
Safety exclusion zones;
Traffic awareness and safety;
Employment and skills development;
Livelihood restoration and improvement; and
Economic participation (e.g. micro financing, financial
management, etc.).
Programs will be adapted to meet ongoing needs and new risks,
and will be developed and implemented with the participation of
local authorities, NGOs, and community groups.
Number of social education and cultural
awareness training programs for the
community
OHS&E Manager /
DEEC and CRSE
Not applicable.
Project Staff and
Worker
Awareness
Social and cultural awareness programs for Project staff and
contractors (e.g. through staff inductions) will be implemented to
improve their understanding of various cultural and social
sensitivities.
Number of environmental and social
induction programs for the workforce
and contractors
OHS&E Manager,
Contractors /
DEEC and CRSE
Not applicable.
Mako Gold Project
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FINAL 229
19 REFERENCES
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Coffey (2015). Toro Project Definitive Feasibility Study (June 2015).
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SRK (2014b). Mako Prefeasibility Study Chapter 10: Tailings Management Facility.
SRK (2014c). Mako Prefeasibility Study Chapter 7: Mining Engineering, Design and Production Scheduling.
SRK (2014d). Mako Prefeasibility Study Chapter 12: Water Management.
SRK (2015). Geochemical Characterisation and Management Report (unpublished).
Toro Gold (2013). ‘Toro Gold’. Source: http://www.torogold.com (Accessed 8 August 2013).
Toro Gold (2014). Environmental and Social Performance Framework.
Toro Gold (2015). Mako Gold Project Feasibility Study Monthly Report, January and May 2015.
UNESCO (2014a). World Heritage List. Source: http://whc.unesco.org/en/list/, accessed on 03/09/2014.
USEPA (2009). National Recommended water quality criteria; republication. United States Environmental Protection Agency, Federal Register Vol. 64, No. 277, 2009.
World Health Organization (WHO) (2011). Guidelines for drinking-water quality, 4th ed. Geneva, World Health Organization.
WHO (2005). Air Quality Guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide – Global Upate 2005, World Health Organization
Mako Gold Project
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APPENDIX A
Standard Operating Procedures (SOPs)
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SOP01: Erosion and Sediment Control
I.D. No. Measures for erosion and sedimentation control and management Applicable
for
C* O* D
*
SITE EROSION AND SEDIMENT CONTROLS
SOP01.1 The Construction Environmental Management Plan (CEMP) will include provision for erosion and sediment control. Where appropriate, the plan will detail upstream and
downstream locations for structures, devices, and monitoring sites.
SOP01.2 Minimise erosion and sedimentation by employing the following measures, where appropriate:
Minimise vegetation clearance to the extent practicable;
Avoid ground disturbance works within 50 m of a river, stream or wetland unless necessary for in-stream works (e.g. water abstraction tower in Gambia River);
Schedule major earthworks and grading operations for early in the dry season. Avoid the wet / rainy season or periods of high intensity rainfall wherever possible;
Divert upstream surface runoff of a worksite away from exposed areas; and
Restrict vehicles to designated access tracks / roads and exclude vehicles from operating in areas not in use for construction or operation.
SOP01.3 Implement best practice erosion and sediment controls prior to any earthworks commencing, and maintain these in place until no longer required. Key measures include:
Identifying drainage lines and installing erosion and sediment control measures suitably designed for site conditions to accommodate for expected peak water flows
(e.g. designed for a one-in-two-year storm event for temporary structures, and 1 in 100 year 24 hour average return interval storm event for permanent structures),
where appropriate;
Containing surface runoff between worksites and adequately treating sediment-laden runoff prior to discharge to the receiving environment;
Install sediment control dams, drainage structures and additional sediment control facilities prior to the commencement of the wet season;
Employing intermediate controls to capture silt and coarser particles downstream of turbid water source, including check dams, sediment/silt traps, baffles, and
stormwater and sediment retention ponds;
Ripping the surface and re-contouring slopes and batters to maximise rainfall infiltration and decrease the velocity of water across the slope during rainfall events.
Where possible, drainage channels will typically have a uniform slope between 0.5% to 1%;
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I.D. No. Measures for erosion and sedimentation control and management Applicable
for
C* O* D
*
Installing dissipation structures or rock / concrete flow barriers at regular intervals for drainage channel slopes greater than 1%, to reduce water velocity (if
appropriate);
Employing scouring controls including vegetation, rip rap or other erosion resistant material to protect drainage lines, spillways and inlets/outlets from scouring;
Keeping to a minimum time exposed surfaces, and revegetating and/or stabilising exposed areas as soon as possible after works are completed;
Using cleared vegetation for erosion control and stabilisation of disturbed areas, where possible;
Disturbed land areas will be progressively rehabilitated when feasible, with priority rehabilitation and revegetation undertaken in high risk areas, such as steep slopes
and sites close to rivers and creeks; and
Embankments will be constructed with suitable materials to minimise the risk of failure due to erosion or excessive seepage rates and ensure geotechnical stability.
SOP01.4 For any in-stream construction work (e.g. for water abstraction from the Gambia River), ensure works are conducted during no or low water flow events (e.g. during dry
season), stream bank stabilisation is provided, and appropriate erosion and sediment control measures are implemented to protect streambeds from damage and minimise
sediment transport from construction.
SOP01.5 Incorporate additional water quality and stormwater management measures specified in SOP02: Water Quality and Pollution Management, and SOP03: Hydrology and
Water Management, where appropriate.
EROSION AND SEDIMENT MONITORING
SOP01.6 Implement routine maintenance and inspection schedule for erosion and sediment control devices to ensure they work properly and are effective. Key aspects will include:
Continually assess the suitability and effectiveness of erosion and sediment control measures and improve control measures if they are no longer effective, e.g.
clearing channels of sediment and replacement of bed scour protection; and
Routinely monitor for visual evidence of erosion and sedimentation (e.g. in areas where major earthworks is being conducted), particularly following intense rainfall
events.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP02: Water Quality and Pollution Management
Surface and groundwater within the natural receiving environment may be contaminated from Mako Gold Project activities such as site preparation, open-cut mining and ore
processing, handling and disposal of hazardous materials, and workforce accommodation. Primary sources of contaminated water may include process and mine water, oily water
from vehicle workshops and washdown areas, raw sewage and wastewater from Accommodation Camps, and spillage/leakage of fuel or hazardous materials in storage and
handling areas.
As the Project will be a ‘zero-discharge’ operation, no releases to the receiving environment will occur. To ensure adequate management of contaminated water onsite and
compliance with applicable water quality discharge standards and guidelines, the Company will implement the management measures and procedures outlined in the table below
and ensure they are incorporated into a CEMP as appropriate.
I.D. No. Measures for water quality and pollution management Applicable
for
C* O
*
D
*
WATER QUALITY POLLUTION MANAGEMENT
SOP02.1 Where possible, clean water diversion structures will be provided outside the Mine Site perimeter and around active construction areas to intercept and divert upstream
clean water into sedimentation / retention ponds for release into the natural environment. Prior to release, ensure silt and coarser sediments have sufficient time to settle
to acceptable levels compliant with relevant discharge standards. Properly operate and maintain sedimentation / retention ponds to ensure they remain efficient.
SOP02.2 As the Project will be a ‘zero-discharge’ operation, all mine water from within the Mine Site boundary and from dewatering the Pit will be collected and diverted to
sedimentation / retention ponds, WSD or the TMF depending on the location and suitability of water, to allow for settling and reuse as process water or for dust
suppression (if water quality is suitable).
SOP02.3 Clearly communicate to all employees and contractors that any dumping or discharging of potentially contaminated water (e.g. oily water, raw sewage, untreated waste
water, mine water, etc.) into the receiving environment is strictly prohibited: through employee training, mandatory induction, specific contract requirements, and
procedures in place. Severe penalties will apply for any breaches and compliance monitoring and audits will be undertaken to ensure conformance with the ‘zero
discharge’ policy onsite.
SOP02.4 For any in-stream works carried out (e.g. for water abstraction from the Gambia River), the worksite will be operated as a closed system to the extent possible to avoid
pollution of surrounding surface water, and appropriate erosion and sediment control measures will be employed as per SOP04.4 to limit sedimentation impacts.
SOP02.5 Where possible, primary sources of hazardous material contaminated water will be identified (e.g. vehicle workshops, hazardous materials and fuel storage areas) and
equipped with appropriate facilities for the containment / controlled release of spills and stormwater, including bunding, sump collection, provision of grease and sediment
traps. Contaminated water from these areas will be transferred to the TMF via pipeline / channel. Refer to SOP07: Hazardous Materials Management for further details
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I.D. No. Measures for water quality and pollution management Applicable
for
C* O
*
D
*
on management procedures.
SOP02.6 The paving of surfaces for roads and other constructed areas will be scheduled to avoid wet weather, where possible, with appropriate sediment control devices provided
downstream of area to be paved.
SOP02.7 Refer to SOP06: Waste Management for implementing management procedures for solid and liquid waste, including for adequate treatment of raw sewage and
wastewater.
WATER QUALITY MONITORING
SOP02.8 Establish and maintain the detailed water quality monitoring programme for all phases of the Project based on the following applicable guidelines to ensure compliance:
Water Discharge and Monitoring
National Standards
Inter-ministerial Decree No. 1555 Discharge Water Guidelines / L’arrêté interministériel No. 1555 de 15 mars 2002 portant application de la norme NS 05-061
sur les rejets des eaux usées (2002)
Waste Water Discharge Standard, NS 05-061 / La norme sur les rejets des eaux (NS 05-061) (2001)
Draft Standard on Management of Solid Waste / Projet de Norme relative à la Gestion des Déchets Solides
International Standards:
IFC Mining EHS Guidelines (2007)
IFC General EHS Guidelines – Wastewater and Ambient Water Quality (2007)
EU Ambient Water Quality Guidelines
ICMI International Cyanide Management Code (2014).
Aquatic fauna / freshwaters
International Standards:
US National recommended water quality criteria (United States Environmental Protection Agency (USEPA), 2009)
EU Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on environmental quality standards in the field of water policy,
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I.D. No. Measures for water quality and pollution management Applicable
for
C* O
*
D
*
amending and subsequently repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC
of the European Parliament and of the Council (EU, 2008)
EU Directive 2006/44/EC of the European Parliament and of the Council of 6 September 2006 on the quality of fresh waters needing protection or improvement
in order to support fish life (EU, 2006)
Drinking water
International Standards:
WHO Guidelines for Drinking Water Quality, fourth edition (2011)
EU Council directive 9883/EC of November 1998 on the quality of water intended for human consumption (EU, 1998).
SOP02.9 Weekly field water sampling at major construction area discharge points, active construction / mining areas, and soil stockpile areas for Turbidity, TSS, DO, temperature,
electrical conductivity (EC), and pH.
SOP02.10 Weekly visual checks for sedimentation, oils and grease at construction area discharge points.
SOP02.11 Routine monthly monitoring of treated effluent and wastewater from water treatment plants for total and faecal coliform, total nitrogen, total phosphorous, COD, and BOD
at the water treatment plants and/or discharge points.
SOP02.12 Monthly ambient water monitoring of field water parameters (pH, Redox potential (ORP), Dissolved Oxygen (DO), Electrical conductivity (EC), Total Dissolved Solids
(TDS), Turbidity and temperature) and laboratory testing for pH, EC, Total Dissolved Solids (TDS) and Total Suspended Solids (TSS), Cyanide (Weak Acid Dissociable
(WAD) CN and Free CN), Total alkalinity (or acidity), bicarbonate alkalinity, carbonate alkalinity and total hardness as CaCO3, Nutrients (ammonia as N, nitrate as N, total
Kjeldahl nitrogen and total phosphorous), Cations and anions (Cl, SO4, Ca, Mg, Na, K), total cations and total anions; and Total and dissolved metals (Ag, Al, As, Au, Ba,
Be, Cd, Co, Cr, Cu, Fe, Hg, Li, Mo, Mn, Ni, Pb, Sb, Se, Sn and Zn).
Monitoring locations are situated upstream and downstream of Badalla Creek and Gambia River, as described in the Surface Water and Groundwater Resources
Baseline Report (Volume C, Appendix 3).
SOP02.13 Monthly water quality monitoring of tailings, supernatant water, and seepage water at the TMF as well as of the mine water within the Pit (e.g. pit sumps) will be
undertaken. Sampling for laboratory testing of the following parameters will be undertaken to ensure cyanide concentrations are consistent with ICMI International
Cyanide Management Code (2014): cyanide (including free CN, WAD and total), salinity, total and dissolved metals (full suite), and nutrients. Field parameters (e.g. pH,
EC, ORP, DO, Temp. etc.) will also be sampled for using field probes.
The TMF will be monitored through the installation of geotechnical instruments including monitoring bores/ piezometers.
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I.D. No. Measures for water quality and pollution management Applicable
for
C* O
*
D
*
SOP02.14 The quantity and the concentrations of contaminants being discharged from the Project to the environment at Closure will be monitored for compliance. It is only when
the water quality is of adequate quality (in accordance with the relevant discharge and ambient (downstream) water quality criteria) that the water may be discharged
from site. Compliance sites (e.g. point of discharge at the Badalla Creek and Gambia River) and frequency will be confirmed in the next phase of the Project, as
described in the Surface Water and Groundwater Resources Baseline Report (Volume C, Appendix 3).
Parameters to be monitored will include pH, EC, ORP, acidity/alkalinity, sulfate, dissolved metals (to be determined by waste rock characterisation) and cyanide (i.e. free,
WAD, and total), related breakdown products of cyanide (e.g. ammonia, nitrate, thiocyanate), salinity, nutrients, pathogens and field parameters (e.g. pH, EC, ORP, DO,
temp. etc.). Multi-element testing using ICP-MS will be undertaken from time to time to fully characterise the discharge (refer to the Surface and Groundwater
Resources Baseline Report (Volume C, Appendix 3).
SOP02.15 Groundwater quality monitoring for the Project will include ongoing monitoring at the existing Company monitoring programme locations as described in the Surface and
Groundwater Resources Baseline Report (Volume C, Appendix 3).
During construction, a number of groundwater monitoring bores will be installed both up-gradient and down-gradient of the TMF, Mine Pit and WRD. Bores up-gradient
of the TMF and Mine Pit will be monitored monthly for water level, EC and pH, and quarterly for metals, major ions and ligands. Bores down-gradient will be monitored
according to the procedure described above for ‘Discharge Monitoring’ (refer to SOP02.14).
Once operations commence, this monitoring programme should be re-evaluated based upon previous results, existing operations, and environmental conditions.
SOP02.16 Prior to mine closure, surface and groundwater sampling of TMF water and down-gradient bores will be undertaken to ensure water quality is acceptable and meets
discharge standards. Sampling for laboratory testing of the following parameters will be undertaken to ensure cyanide concentrations are consistent with ICMI
International Cyanide Management Code (2014): cyanide (including free, WAD and total CN), salinity, total and dissolved metals (full suite) and nutrients. Field
parameters (e.g. pH, EC, ORP, DO, Temp. etc.) will also be measured using field probes.
SOP02.17 If a change in the geochemical risk classification of the tailings is observed, an AMD management plan will be prepared.
SOP02.18 The existing baseline aquatic fauna and habitat monitoring programme will be continued for areas upstream, within and downstream of the Project Development Area
using standard monitoring techniques (e.g. surveys and bio-indicator analysis, drift net surveys for fish), particularly for the restricted range fish species Barbus
dialonensis (a priority species).
The programme will use sample sites established in the baseline studies, as appropriate.
SOP02.19 All field sampling, handling, storage, and transport of samples will strictly be conducted in accordance with approved methodologies and procedures. All sample
laboratory testing will be conducted at an adequately licensed and accredited laboratory. Frequent re-calibration checks of field probes and instruments will be
undertaken to ensure they remain accurate.
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I.D. No. Measures for water quality and pollution management Applicable
for
C* O
*
D
*
SOP02.20 Regular visual checks and site inspections for potential leakage or seepage of contaminated water at primary source locations (e.g. Process Plant, TMF and associated
pipelines, fuel storage areas, etc.) for hazardous chemicals and hydrocarbons.
SOP02.21 Where appropriate, investigative water quality monitoring at key locations in response to applicable complaints received through the Project grievance management
system. Provide or adapt with additional mitigation if required.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP03: Hydrology and Water Management
Water entering the Project site has the potential to become contaminated by hydrocarbons, chemicals (including hazardous chemicals), toxic pollutants (e.g. cyanide) and
sediments. To minimise the amount of water entering the Project Development Area and potentially becoming contaminated, the Company will implement a water management
strategy that is aligned with its ‘zero-discharge’ policy, and effectively manages site water according to international mining industry standards. The management measures and
procedures provided in the table below will be adopted and incorporated into the CEMP and other Project documents as appropriate.
I.D. No. Measures for hydrology and water management Applicable
for
C* O
*
D
*
WATER MANAGEMENT
SOP03.1 The amount of surface water runoff entering the Mine Site and active construction areas will be minimised by installing stormwater drainage systems with appropriate
erosion and sediment controls outside the boundary of the active Mine Site, to intercept and divert ‘clean water’ upstream for release into the natural environment, as
per SOP02.1.
SOP03.2 All water (including surface runoff) within the Mine Site will be captured in sedimentation / retention ponds and eventually discharged into the TMF or WSD facilities for
reuse as process water or dust suppression water (if water quality permits), where appropriate (as per SOP2.2).
SOP03.3 Surface water management infrastructure will be designed and installed as appropriate within and outside the Project Development Area to manage surface runoff and
mine water in a controlled and efficient manner (refer to SOP01: Erosion and Sediment Control and SOP02: Hydrology and Water Management, for details).
SOP03.4 Stormwater infrastructure/devices including cut-off / diversion drains, velocity dissipation devices and culverts will be used, where appropriate, to control water flow
velocities and avoid flows over bare slopes and disturbed surfaces. Devices will need to accommodate peak flows (e.g. at least 1:100 year average return interval storm
events)
SOP03.5 Water from dewatering the Pit and other potentially contaminated sites will be transferred via sumps to the TMF for reuse as process water.
SOP03.6 The use of passive water treatment methods will be maximised within the Project Development Area (e.g. sedimentation pond), where possible.
SOP03.7 Construction materials, equipment and chemicals will be stored away from flood prone waterways/drainage lines and inundation areas during the rainy season to avoid
accidental release to the natural environment.
SOP03.8 Upon completion of construction activities, disturbed surfaces will be graded where practicable to provide proper drainage.
SOP03.9 Provide employee training and awareness programmes on water management that focuses on water pollution prevention and water efficiency, recycling and reuse
strategies in place within the Project Development Area. Contractors will also be required to ensure water efficiency, recycling and reuse opportunities are maximised to
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I.D. No. Measures for hydrology and water management Applicable
for
C* O
*
D
*
the extent possible, and that they conform to water pollution prevention procedures.
SURFACE WATER MONITORING
SOP03.10 A site water balance and inventory will be prepared and continually maintained that monitors site water consumption (according to volume and water quality), as well as
water stored and managed onsite (including at the WSD and TMF), to avoid potential water shortages and/or overcapacity. Trigger levels will be established specifying
water volumes and parameter concentrations that, if exceeded, will require an appropriate management response. Historical climatic data collected onsite and
regionally will be considered for identifying new trends and continuous improvement.
SOP03.11 The Company has established a number of hydrology monitoring stations around the Mako Project area which are monitored on an ongoing basis. Installation of a
series of additional stream gauges on waterways upstream and downstream of the Project may be required depending on the preferred Project layout. Stream gauges
will be used to measure surface flow and stream height. Data will be collected routinely (e.g. daily or monthly) depending on the location. Implementation and
management will be the responsibility of the Company’s Environment Department.
SOP03.12 Surface water management structures and devices within and outside of the Project Development Area will be periodically checked to ensure their efficacy (and
improved or upgraded, if required).
SOP03.13 A regular inspection and maintenance schedule of dam infrastructure (e.g. TMF, WSD) to ensure adequate structural integrity and water levels for dam safety:
Daily visual inspections will be conducted of reservoir water levels for freeboard management to ensure sufficient freeboard for a 1 in 100 year rainfall event is
maintained to prevent overtopping of the dam wall and dam failure during periods of high or extended rainfall;
Periodic (e.g. daily or weekly) visual inspections will be undertaken of dam toe, emergency spillway and embankment, to inform any remedial works required.
The emergency spillway of the WSD will be inspected weekly during the dry season and on a daily basis during the wet season to ensure it is free of debris or
vegetation. The emergency spillway for the TMF will be inspected annually; and
Independent annual audits of the TMF and WSD will be conducted by a suitably qualified specialist to ensure structural integrity (e.g. for embankment
movement) is maintained.
Sediment and debris traps around the perimeter of the reservoir will also be maintained in order to reduce the amount of dirt in the reservoir.
SOP03.14 A regular inspection and maintenance schedule of water pipelines (e.g. raw water, process water, tailings), flanges, seals and pumps to ensure physical integrity and
condition. Pipeline channels will be kept free of vegetation and physical obstructions. The Company will engage with the community, and in particular herders, to
prevent pipe tapping of the pipe.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP04: Emission and Dust Control
Project activities are expected to result in significant greenhouse gas (GHG) emissions as well as increased air pollutants of potential concern including fugitive dust or particulate
matter (PM10 and PM2.5), carbon monoxide (CO), carbon dioxide (CO2), oxides of nitrogen (NOx), sulphur dioxide (SO2), ozone (O3) and volatile organic compounds (VOCs). While
greenhouse gas emissions are known to be the primary contributor to global warming and climate change, the latter can create nuisance to local communities (particularly along
unsealed roads in the dry season) or impact public health, vegetation growth and agriculture.
The following SOP provides the minimum management measures to address dust, air quality and greenhouse gas impacts based on the IFC General EHS Guidelines 2007. These
will be incorporated into site procedures for the Project to be prepared prior to construction.
I.D. No. Measures for dust, air quality and greenhouse gas management Applicable
for
C* O
*
D
*
PREVENTION OF FUGITIVE DUST AND AIR POLLUTION
SOP04.1 Use dust controls (e.g. watering, gravel application) on unsealed access tracks and exposed surfaces heavily trafficked by machinery and vehicles (e.g. site entry/exit
points, loading and unloading areas, etc.) during the dry season or when excessive dust generation is evident. Increase frequency during periods of high risk (e.g. dry
and windy conditions). Dust suppression water will be taken from suitable recycled water sources (e.g. treated truck wash water and other mine wastewater), wherever
possible.
SOP04.2 Revegetate or cover any unused or exposed soils with mulching, woodchips, stone/gravel layering or grass matting (to quickly stabilise exposed soils).
SOP04.3 Implement the following dust management measures for soil stockpiling:
Rib and roughen smooth surfaces to reduce wind velocity;
Locate stockpiles in areas naturally sheltered from wind, if feasible;
Install temporary wind fences, if required;
Plant / revegetate long-term topsoil stockpiles (more than three months); and
Spray water on stockpiles if excessive dust generation is evident.
SOP04.4 Avoid undertaking primary dust generating activities during dry and windy conditions (e.g. loading, hauling and dumping of topsoil, blasts).
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I.D. No. Measures for dust, air quality and greenhouse gas management Applicable
for
C* O
*
D
*
SOP04.5 Ban open-burning of general wastes and vegetation. Unavoidable waste incineration (e.g. for cyanide and hydrocarbon wastes) will be undertaken in accordance with
the IFC General EHS Guidelines - Waste Management Facilities (2007).
SOP04.6 For temporary and permanent crushing and batching plant activities (e.g. concrete batching plant, Process Plant), employ suitable dust suppression control measures
(e.g. sprayers, dust collectors, unloading tubes) to ensure that dust emissions are not excessive.
SOP04.7 Employ additional measures provided in Chapter 9 (Roads and Transport) of the ESMMP for managing road and transport air quality emissions and SOP09: Land
Clearance and Soil Stockpiling to assist in managing dust emissions from land clearing and soil stockpiling.
BLASTING AND DRILLING MANAGEMENT
SOP04.8 Implement the following general dust and air quality management measures for blasting and drilling activities:
Lower dust aprons during drilling;
Equip drills with dust extraction cyclones or water injection systems;
Use water injection or dust suppression sprays prior to undertaking drilling or blasting when high levels of dust are being generated; and
Consider prevailing wind conditions (e.g. Harmattan winds) prior to blasting.
GREENHOUSE GAS MANAGEMENT
SOP04.9 Follow good international industry practices for minimising and offsetting Project related greenhouse gas emissions, particularly for major emission sources (e.g. Power
Station, Process Plant), including:
Adherence to energy, water and resource conservation and efficiency principles (e.g. fuel, reagents, grinding media, etc.) as per the IFC General EHS
Guidelines;
Use of best available technology to minimise emissions and energy consumption;
Selection of construction materials to minimise carbon footprint impact, where practicable (e.g. recycled steel, concrete with recycled fly ash and aggregate,
etc.);
Additional greenhouse gas emissions control procedures as described in Chapter 9 of the ESIA Study (Volume A), where practical; and
Minimisation of vegetation clearance and maximising abatement opportunities through vegetation offsets and carbon sequestration in the form of revegetation of
land during and after mining (as per the Rehabilitation and Conceptual Mine Closure Plan, Volume E).
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I.D. No. Measures for dust, air quality and greenhouse gas management Applicable
for
C* O
*
D
*
SOP04.10 Applying appropriate greenhouse gas management measures to all Project-related transport activities, including:
Minimising haul distance for material delivery and workforce transport to reduce fuel consumption;
Selecting fuel efficient vehicles and equipment; and
Avoid unnecessary idling, queueing, and overloading when operating vehicles or equipment.
SOP04.11 Integrate energy efficiency principles in building or facility design, including:
Optimised lighting system, e.g. skylight installations, solar powered or fluorescent lamps, timers on lights, etc;
Design to minimise air conditioning requirements and for building internal temperature to be maintained at optimum;
Energy efficient equipment in accordance with industry standards, including adoption of best industry practice technology for the processes involved, and most
efficient mining, blasting and crushing/grinding practices;
Alternative energy sources considered, e.g. co-generation plant, reciprocating engines, waste heat recovery, renewable energy sources such as biomass
gasification, solar power or the use of biofuels; and
Additional energy source and control procedures as described in Chapter 9 of the ESIA Study (Volume A), where practical.
SOP04.12 Ensure contractors comply with relevant measures for greenhouse gas management and energy conservation set out for the Mako Gold Project.
SOP04.13 Conduct awareness training on energy conservation and GHG reduction for Project employees and workforce.
SOP04.14 Establish greenhouse gas reduction and energy conservation targets for the Mako Gold Project for measuring improvement in the GHG intensity of mining operations in
accordance with good international industry practice.
AIR QUALITY AND GREENHOUSE GAS MONITORING
SOP04.15 Establish and maintain the detailed air quality programme for all phases of the Project based on the following applicable guidelines to ensure compliance:
National Standards:
Atmospheric Pollution Standard, NS 05-062 / La Norme de rejets NS 05-062 – pollution atmosphérique (2004)
International Standards:
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I.D. No. Measures for dust, air quality and greenhouse gas management Applicable
for
C* O
*
D
*
IFC Mining EHS Guidelines (2007)
IFC General EHS Guidelines – Air Emissions and Air Quality (2007)
WHO Air Quality Guidelines – Global Update (2005)
SOP04.16 Four dust monitoring points have been established by the Company in the vicinity of the PDA (refer Air Quality, Noise and Vibration Assessment, Volume A).
Maintain and update the air quality monitoring programme for the Project based on the IFC General EHS Guidelines for Air Quality to ensure compliance with relevant
national and international guidelines. Key air quality monitoring requirements include:
Daily visual checks for visible fugitive dust on all active Project roads, stockpiles, and material transfer points (e.g. at Process Plant);
Continued monitoring (on a biannual basis) of PM2.5 and PM10, SO2, NOx, CO and dust deposition rates at the four existing dust monitoring stations to evaluate
the performance and adequacy of management and mitigation measures (refer Air Quality, Noise and Vibration Assessment, Volume C). Dust monitoring of
both PM10 and PM2.5 will continue to be undertaken at these sites, with ten (10) days continuous monitoring undertaken at each site on a rotational basis.
Additional monthly monitoring of TSP at each site will also be required to allow comparison to IFC standards;
Where appropriate, investigative dust and air quality monitoring at key locations in response to applicable complaints received through the Project grievance
management system. Provide additional mitigation if required.
Additional dust monitoring sites may be required in villages located near the Main Access Road, at the new Accommodation Camp, and at a control site (refer to Air
Quality, Noise and Vibration Assessment, Volume A).
SOP04.17 Continued meteorological monitoring from the two Automatic Weather Stations (AWS) established in 2012 by the Company for the Mako Gold Project (refer
Meteorological Baseline Study, Volume C). The AWS automatically logs measurements of rainfall, wind speed and direction, temperature, and relative humidity. Data
will be downloaded on a monthly basis. Evaporation readings from an evaporation pan will also be recorded manually on a daily basis.
SOP04.18 As per IFC requirements, periodically update the Project GHG inventory developed for construction and operational GHG emissions during the calendar year period,
and assess performance against set GHG reduction and energy conservation targets. Incorporate additional GHG mitigation and abatement measures if required.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP05: Noise and Vibration Management
The Mako Gold Project will involve heavy construction and earth moving plant and machinery, truck haulage, processing plant operations, and blasting practices. These Project
activities will generate increased noise and vibration (ground and airborne) impacts. General management measures are presented below to ensure that noise and vibration
impacts produced by the Project do not result in disturbance or nuisance to adjacent sensitive receptors (e.g. settlements, noise sensitive fauna), damage to nearby structures, or
exceed applicable noise and vibration criteria guidelines. They are based on the IFC General EHS Guidelines – Noise Management (2007), with the adoption of the following control
hierarchy for noise and vibration mitigation and management:
Elimination of the source;
Substitution with quieter equipment/process;
Engineering controls at the source;
Treatment of the propagation path; and
Installation of mitigation controls at the receiver.
More detailed site procedures specific to the Mako Gold Project will be developed prior to construction incorporating the below general management measures.
I.D. No. Measures for noise and vibration management Applicable for
C* O* D
*
ACTIVITY AND INFRASTRUCTURE SITING
SOP05.1 Locate major noise stationary sources (such as plant equipment and infrastructure including compressors, generators, concrete batching plant) away from potentially
sensitive receptors (biological and community) and take advantage of natural terrain and existing features (e.g. vegetation) to buffer the noise generated.
SOP05.2 Obtain approval by the Company’s OHS&E Manager for locating major noise/vibration sources (activities and infrastructure) near potentially sensitive receptors.
SOP05.3 Enforce exclusion zone of 500 m (to prohibit establishment of new settlements) near major Project components (e.g. Mine Pit, Process Plant, Power Station, etc.) to
limit noise and vibration impacts on potentially sensitive receptors.
NOISE AND VIBRATION MANAGEMENT
SOP05.4 Ensure all Mako Gold Project noise emissions comply with relevant noise and vibration guidelines for nearby residential dwellings, particularly the IFC General EHS
Guidelines – Noise Management (2007) (refer to SOP05.11 for further details):
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I.D. No. Measures for noise and vibration management Applicable for
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*
75 dB(A) LAeq (daytime period) and 50 dB(A) LAeq (night-time period) during Project construction and closure; and
55 dB(A) LAeq (daytime 1 hour) and 45 dB(A) LAeq (night-time 1 hour) during Project operations.
SOP05.5 Adopt methods and technologies informed by detailed noise modelling to reduce noise impacts in the Project design, where possible.
SOP05.6 Implement the following noise and vibration management measures to all Project activities, where appropriate:
Maximise use of existing topography and features (e.g. vegetation) to shield noise sensitive receptors from major stationary sources;
Select quietest plant and equipment that can economically undertake the work;
Regularly maintain heavy machinery equipment and vehicle fleet in good working order and ensure they are within industry standards for noise and vibration
emissions;
Avoid conducting earthmoving, ground impacting, and demolition activities simultaneously near a sensitive receptor or structure to minimise the amount of
noise and vibration generated at any given time (if applicable);
If night-time work in residential areas is required, employ noise attenuation measures such as temporary noise enclosures or barriers to minimise noise
disturbance. Ensure affected residents are appropriately notified in advance of night-time works;
Use piling/drilling methods with the lowest noise and vibration impact, such as lowering drop heights or impact levels for piling hammers, and using piling
shrouds or temporary barriers or hoardings; and
Provide hearing protection to Project personnel working in noisy construction areas (i.e. where noise levels are expected to be greater than 80 dB(A)).
SOP05.7 Where required, incorporate noise reduction, sound insulation and absorption to different equipment and operations, including:
Impedance mufflers/silencers and vibration insulating on air compressors, blowers and fans;
Sound insulation covers, where applicable;
Sound insulation treatment for high noise equipment and primary noise-emitting buildings to improve acoustic performance (e.g. crushing area of the Process
Plant);
Suitable mufflers on engine exhausts and compressor components; and
Acoustic enclosures for equipment casing radiating noise.
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I.D. No. Measures for noise and vibration management Applicable for
C* O* D
*
SOP05.8 Employ additional measures provided in Chapter 9 (Roads and Transport) of the ESMMP for vehicular noise and vibration management, where applicable.
COMMUNITY COMMUNICATION PROTOCOL
SOP05.9 Ensure potentially affected nearby residents have been appropriately notified and consulted on scheduled Project activities prior to works commencing, following an
established communication protocol. Details will be communicated for:
Type of proposed activities (e.g. road construction, blasting, etc.)
Commencement and completion dates
Hours and likely timing of activities (including number of blasts, if applicable)
Any mitigation measures to be employed.
SOP05.10 Noisy construction activities near community sensitive receptors will be restricted to daytime hours only when ambient noise and levels are higher and less disruptive.
If a change is required to the approved hours or schedule, approval will be sought by the Contractor from the Company’s OHS&E Manager and affected local
residents notified in advance.
NOISE AND VIBRATION MONITORING
SOP05.11 Establish and maintain the detailed noise and vibration monitoring programme for all phases of the Project based on the following applicable guidelines to ensure
compliance:
National Standards:
Environment Code (noise) / Code de l’Environnement (2001)
International Standards:
British Standards (vibration) BS 6472:2008, 4866:2010 and 7385-2:1993 (1993, 2008, 2010)
IFC General EHS Guidelines – Noise (2007)
Mining EHS Guidelines (2007)
SOP05.12 Four noise monitoring points in the Mako Project area have been established by the Company (refer Air Quality, Noise and Vibration Assessment, Volume C).
Maintain and update the noise and vibration monitoring programme for the Project based on the IFC General EHS Guidelines (2007) for Noise to ensure compliance
with relevant national and international guidelines. Key noise and vibration monitoring requirements include:
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I.D. No. Measures for noise and vibration management Applicable for
C* O* D
*
Periodic (e.g. when there is a change of blast location) monitoring of noise, airblast, and ground vibration impacts within 500m of blast areas (during Project
pre-construction, construction and operations);
Bi-annual monitoring of noise levels in dB(A) LAeq (daytime and night-time period) at the Process Plant during Project Construction and Operations;
Noise logger monitoring (10 days continuous) will continue to be undertaken at the existing sites on a rotational basis for all phases of the Project to allow
comparison to IFC standards; and
Where appropriate, investigative noise and vibration monitoring in response to applicable complaints received through the Project grievance management
system. Provide additional mitigation if required (e.g. additional shielding, change timing of scheduled Project activities, substitute with quieter equipment,
etc.).
Additional noise monitoring sites may be required in villages located along the Main Access Road, at the new Accommodation Camp, and at a control site (refer to Air
Quality, Noise and Vibration Study, Volume A, Appendix 4).
SOP05.13 Maintain ongoing consultation and prior notification of potentially noisy works with affected settlements/villages to ensure noise and vibration associated impacts are
adequately addressed.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP06: Waste Management
Proposed activities and personnel required for the Mako Gold Project will generate a number of general (non-mining) waste materials, including biodegradable (e.g. food scraps,
wood) waste, recyclable waste (e.g. plastics, scrap metal and timber, packaging) and residual landfill waste (e.g. construction concrete) as well as raw sewage and greywater.
General waste that is improperly stored or disposed of could have adverse effects on human health, habitat and biodiversity.
A preliminary summary of the general wastes to be generated by the Project and their method of disposal is presented below. This inventory will be updated in the next phase of
the Project as necessary.
General waste stream Nature of the general waste Estimated quantity Method of disposal in order of preference
LIQUID WASTE
Mine services area waste water Truck wash water <50 m3/day Used for dust suppression on haul roads
Sewage Treatment Plant (STP) treated water for
the accommodation camps
Treated water from camp STP 50-100 m3/d
Leach drains
Recycle/reuse
STP treated water plant for the mine services area Treated water from plant site STP 50-100 m3/d
Disposal to the plant tails hopper or TMF and recovered
for use as process water
SOLID WASTE
Putrescible waste Kitchen waste and food scraps 250 kg/day Burial in lined landfill
Office waste Paper , toner, etc. 250 kg/week Burial in lined landfill
Other domestic waste Bottles, cans, plastics <2 m3/day
Recycle
Balance to landfill
Construction waste Various categories 10 t/day
Sorted in accordance with types below and disposed of
in a similar manner
Scrap timber Packaging, scrap pallets, off cuts, etc. <2 m3/week
Recycle
Landfill
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General waste stream Nature of the general waste Estimated quantity Method of disposal in order of preference
Scrap metals Scrap equipment and parts, steel off cuts, etc. <2 m3/week
Recycle
Landfill
Non-toxic solid reagent packaging Polypropylene or similar bags <100 kg/week Landfill
Grinding media packaging 200 L steel drums 50/week Recycled
Vehicle workshop waste Used tyres Not available Reuse in mine site recapping if possible, or reuse in
retaining mine wall construction, or transfer to landfill as
a last resort.
General waste management for the Project will be undertaken in accordance with IFC General EHS Guidelines - Waste Management (2007) (refer to Chapter 1.6 Waste Management
of Guideline) and the following waste management hierarchy (in decreasing order of preference):
1. Minimise the production of waste
2. Maximise waste recycling and reuse
3. Treatment of waste
4. Ensure safe waste disposal.
A detailed inventory of hazardous wastes generated by the Project will be maintained to include:
Waste type;
Source;
Quantity; and
Management method.
Mine related wastes such as waste rock and tailings will be separately addressed in the Waste Rock Management Plan and Tailings Operating and Monitoring Manual respectively,
which will be developed in the next phase of the Project by the Company. Refer to SOP07: Hazardous Materials Management for relevant measures to specifically manage and
dispose of hazardous wastes.
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I.D. No. Measures for general waste management Applicable for
C* O
*
D
*
GENERAL WASTE MANAGEMENT AND PREVENTION OF LITTERING
SOP06.1 Employ site waste minimisation strategies, including
Optimising efficiency and resource use of all site production processes; and
Procuring supplies and consumables that have been produced from recycled materials or produce less waste in packaging and production
Educating staff and contractors on waste minimisation during inductions.
SOP06.2 Prohibit Project workforce from littering onsite.
SOP06.3 Install colour-coded bins with weatherproof lids and appropriate signage at designated locations around the Project site (e.g. workforce accommodation camp, Project
construction sites, and active operations sites) for collection and segregation of waste. Waste collection to occur frequently to avoid overflowing of bins.
SOP06.4 Train staff and contractors on waste management and specific procedures to follow.
SOP06.5 Educate staff, contractors and local community to actively clean-up litter and minimise the generation of litter.
SOLID WASTE MANAGEMENT, RECYCLING, AND REUSE
SOP06.6 Establish a waste management system and comprehensive waste inventory that identifies, tracks and quantifies major waste streams generated at the Project site.
The following information will be recorded:
Composition and waste type according to different waste streams
Quantity and storage location
Transport and disposal methods (e.g. safe disposal certificates)
Final destination, including amount of each waste type that has been recycled or reused.
SOP06.7 Collect and segregate solid waste into the following categories:
Biodegradable materials, e.g. cleared vegetation and food scraps;
Recyclable materials, e.g. scrap timber and metal, hard plastic, glass, paper and cardboard, batteries, and tyres; and
Non-hazardous residue waste, e.g. excess concrete, non-recyclable plastics, bricks, etc.
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I.D. No. Measures for general waste management Applicable for
C* O
*
D
*
SOP06.8 Manage general Project waste in accordance with IFC General EHS Guidelines – Waste Management (2007), including as follows:
Suitable waste management facilities for the Project include:
» Recycling facilities for the storage and collection of recyclable materials in separate weather-proof storage areas that can easily be cleaned, including
for glass, scrap metal, and scrap timber;
» Landfill facilities for disposal of non-recyclable and non-hazardous residue wastes. The landfill facility will be suitably designed and constructed with
lined cells developed progressively as required, and covered with soil on a weekly basis to prevent scavenging and windblown rubbish.
» Composting pits for the disposal of biodegradable waste, will be covered with soil on a weekly basis to avoid scavenging and windblown rubbish;
» Sewage treatment plants for the treatment of raw sewage and greywater (see below for further details).
Location of waste management facilities will be at least 50 m from any drainage lines, streams or rivers and within the TMF catchment, if possible;
Primary containment bunds will be provided containing at least 110% of the volume of non-hazardous wastes in storage areas; and
Perimeter security fencing will be provided, where appropriate, to deter wildlife and pest species, and ensure public safety (e.g. for land fill facilities and
sewage treatment plants).
SOP06.9 Identify opportunities for recycling and reusing Project wastes generated onsite to the extent practicable. Where possible, consider the following beneficial reuse
options:
Composted biodegradable materials for revegetation activities;
Treated effluent and wastewater for dust suppression; and
Inert construction waste (e.g. excavated subsoil, building rubble, concrete waste) for construction backfilling.
SOP06.10 Mark on maps of the Project site all waste management facilities (active and decommissioned), including GPS coordinates, area, volume, and type of waste stored in
each facility.
SOP06.11 Prohibit open-burning of general waste and vegetation for disposal.
SOP06.12 Identify reputable, licensed service providers for the recycling of recyclable wastes. Prior to engaging, review and audit contractor’s transport and disposal practices
and certification to ensure they are suitably qualified.
SEWAGE AND GREY WATER MANAGEMENT AND TREATMENT
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I.D. No. Measures for general waste management Applicable for
C* O
*
D
*
SOP06.13 Install ablution facilities and pit latrines (at isolated construction areas) for the Project workforce, and instruct workers to use the toilets provided.
SOP06.14 All raw sewage and wastewater will be treated by appropriate water treatment plants to meet relevant national and international water quality guidelines (refer to
SOP2.10). Dumping of untreated raw sewage and domestic wastewater into the receiving environment will be strictly prohibited. Installed storage facilities (e.g.
septic tanks) and water treatment plants will be sufficient to accommodate for the Project workforce, and conform to the industry standards for domestic water
treatment.
SOP06.15 Reuse treated water onsite (e.g. for dust spraying, process water, fire water tank, etc.), where possible.
GENERAL WASTE MONITORING
SOP06.16 Develop and maintain the detailed waste monitoring programme for the Project up-to-date based on the IFC General EHS Guidelines for Waste (2007) to ensure
compliance with relevant national and international guidelines. Key waste monitoring requirements include:
Conduct of annual waste audits to monitor emerging trends in waste generation over time. Relevant site waste management plans and procedures will be
updated for new waste streams and improved waste minimisation methods and recycling techniques, where applicable;
The Company to undertake regular inspections to monitor the success and compliance of waste management strategies onsite according to key performance
indicators (e.g. use of appropriate containers for waste, beneficial reuse or recycling, and waste reduction); and
Investigative monitoring for waste related complaints through the Project Grievance management system and implementation of remedial actions accordingly.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP07: Hazardous Materials Management
Hazardous materials and dangerous goods may pose a hazard to human health or the environment if improperly handled due to its quantity, concentration, acute or chronic toxic
effects, carcinogenicity, flammability, explosiveness, radioactivity, or physical, chemical or infectious characteristics.
Hazardous materials that will be stored and handled onsite for the Mako Gold Project include cyanide and other process plant reagents; oils, solvents, and other hydrocarbons (e.g.
diesel); and herbicides. In addition, dangerous goods involving explosives will be stored and handled onsite for blasting during the construction and operational phases.
A number of hazardous wastes will be generated, including reagent bags (that are likely to contain some reagent residue), medical waste (e.g. sharps and bandages), waste oil and
lubricants, paints and solvents, hydrocarbon contaminated soil, and raw sewage sludge. A preliminary summary of the hazardous wastes expected to be generated by the Project
and their method of disposal is presented below. This inventory will be updated in the next phase of the Project as necessary.
Hazardous waste stream Nature of the hazardous waste Estimated quantity Method of disposal in order of preference
LIQUID WASTE
Truck wash sludge Hydrocarbon contaminated sludge from truck wash
sump <10 m3/week
Volatilise contaminants and burial in lined landfill
All water to be directed to Tailings Management Facility
(TMF)
Plant tailings Process plant tailings 225 t/h solids, 225 t/h process
water
Solids deposited in the TMF
50% of process water entrained in saturated tailings in TMF
Balance of process water recovered and returned to
process plant for re-use
Sewage treatment plant (STP) sludge Treatment plant sludge from all sewage treatment plants <50 kg/d Direct landfill burial in unlined pits
Waste oil Used as lubricating oil for vehicles and machinery 1,000 L/week Recycle
SOLID WASTE
Liquid reagent packaging 200 L plastic drums 20/week
Recycle
Landfill
Cyanide reagent packaging Wood and plywood bulk-boxes, bags <1,000 kg/week Burn and dispose of ashes in lined landfill
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Hazardous waste stream Nature of the hazardous waste Estimated quantity Method of disposal in order of preference
Oil-based waste Oil filters, waste oily rags
Not available
Removal of recyclable parts where possible, then
incineration.
Ash disposed in lined landfill
Contaminated soil Contaminated with chemicals and / or oil spills <1 m3/week average Volatilise contaminants and burial in lined landfill
Medical waste Clinic and first aid waste Not available Burn and dispose in landfill
The Company and its contractors will develop specific hazardous materials management procedures and sub-plans (i.e. Cyanide Spill Contingency Plan) as part of the Project Waste
Management Plan and Emergency Preparedness and Response Plans to be developed prior to construction commencing, which incorporate the below measures to ensure proper
compliance with the transportation, management, and disposal of hazardous chemicals and dangerous goods.
I.D. No. Measures for hazardous materials management Applicable for
C* O D*
HAZADOUS MATERIALS STORAGE AND CONTAINMENT (INCLUDING FOR HYDROCARBONS AND CYANIDE)
SOP07.1 Construct appropriately designed and marked hazardous material delivery, transfer and storage areas as follows:
Compliant with applicable building, fire safety and hazardous materials/dangerous goods code requirements;
Within the catchment of the TMF, where possible; or at least 100 m away from natural streams, wetlands, flood prone areas and sensitive areas;
Clear labelling of the type of hazardous materials handled or stored with relevant Material Safety Data Sheets (MSDS) displayed;
A primary containment system comprised of concrete slabs, bund (that can contain at least 110% of the volume of hazardous material stored onsite) and
sump to recover spilled material and rain from slabs (if applicable);
A secondary containment system where any spillage exceeding the capacity of bunds will report to a lined event pond;
All pipe work and pumps will be within bunds or routed above ground to allow the early identification of any leaks; and
Weatherproof shelters to prevent collection of rainfall within the bunded area.
SOP07.2 Install primary and secondary containment systems as per SOP07.1 in all areas where hazardous materials are stored, handled, transferred, or where there is
potential for contamination (e.g. Process Plant, Mine Services Area, Power Station).
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HAZARDOUS MATERIALS MANAGEMENT AND DISPOSAL (INCLUDING FOR HYDROCARBONS AND CYANIDE)
SOP07.3 Be consistent with the following international standards and codes for hazardous materials and dangerous goods, where applicable:
International Cyanide Management Code Principles and Standards of Practice for cyanide handling, storage and transportation (ICMI, 2014);
IFC General EHS Guidelines 2007 (Chapter 1.5 Hazardous Materials Management and Chapter 3.5 Transport of Hazardous Materials);
United Nations, Transport of Dangerous Goods - Model Regulations. 17th Revised Edition (Volume 1) Geneva 2011;
AS 1940 – The Storage and Handling of Flammable and Combustible Liquids. (Current 2004 ed.); and
AS 2187 – Explosives – Storage, Transport and Use. (Current 1998 ed.).
SOP07.4 Establish a rigorous process that continually reviews risks, management priorities, and residual risks presented by hazardous materials onsite to reduce potential
risks to as low as reasonably practicable. Maintain a detailed inventory of hazardous materials used onsite, with the following details documented in a database:
Type and source of hazardous materials including wastes;
Quantity, location and physical state of stored materials;
Complete set of up-to-date MSDS from the supplier and manufacturer of products;
Method and date of storage, treatment or disposal; and
Waste tracking documentation including quantity, type, date dispatched / transported / received, and record of the originator, transporter and receiver.
SOP7.5 Provide and enforce use of appropriate personal protective clothing and equipment (i.e. gloves, plastic coveralls, safety glasses and self-contained respirators),
emergency information posters, and clean-up spill kits (including specialised kits for hydrocarbons, cyanide and other chemical spills) at strategic locations where
hazardous chemicals are handled.
SOP7.6 Develop work safety procedures, instructions and emergency response procedures (i.e. as part of the Project Emergency Preparedness and Response Plans to be
developed) on how to safely handle, store and dispose of hazardous materials (including for cyanide spills) as well as for adequate emergency communication
capability with potentially impacted communities, governments and nominated emergency response teams within a timely manner. Relevant safety procedures and
supporting material will be provided in the local language used onsite.
SOP7.7 Train workers responsible for hazardous materials handling, storage and use of hazardous materials as well as comprehensive emergency response training for
process operators. Employees with emergency spill clean-up training will be present during unloading and handling of hazardous materials. Key aspects covered in
training will include:
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I.D. No. Measures for hazardous materials management Applicable for
C* O D*
Identification and potential dangers and risks from hazardous materials and wastes;
Proper hazardous waste storage, handling and disposal procedures;
Safety and emergency response procedures; and
Use of warning signs, MSDS, PPE and clean up materials for spills.
SOP7.8 Secure and clearly label all designated hazardous materials and explosive storage areas and containers (including for collection and disposal) with the following
information displayed (in local language):
Words ‘Hazardous’ and name of material and its physical state (liquid or solid);
Hazard characteristics (e.g. ignitable, corrosive, toxic, reactive) and health danger (e.g. poison, burn, inhalation or eye/skin irritant);
MSDS; and
Date of storage and source.
SOP7.9 Identify suitably qualified and licensed transporters for dangerous goods and hazardous materials (e.g. ICMI 2014 Cyanide Code-compliant transporter).
Review/audit their internal health and safety documentation to ensure they are adequate prior to contract engagement.
SOP7.10 Use recommended herbicides (for weed control) and pesticides (for vector control) as pre-authorised by the Company Environment Department. Strictly follow usage
instructions and do not apply herbicides / pesticides during or just before rain events.
GENERAL HAZARDOUS WASTE MANAGEMENT (INCLUDING FOR HYDROCARBONS AND CYANIDE)
SOP7.11 Manage hazardous wastes using the following procedure, where appropriate:
Comply with applicable codes specified in SOP07.3 and SOP7.15 for the collection, handling and disposal of hazardous materials and wastes;
Collect hazardous wastes and store in appropriate waste management facilities constructed in accordance with SOP07.1;
Separate hazardous and non-hazardous waste streams, while considering the use of less hazardous substitutes for hazardous materials wherever possible.
Keep hazardous wastes separate to prevent potential for chemical reactions. Consider recycling useful hazardous wastes such as oil or water-based paint;
Prohibit disposal of hazardous wastes (e.g. solvents, used oils, paints, reagents, cracked batteries, acids) in general waste bins;
Hazardous chemicals in drums or bags stored on pallets;
Store cracked batteries in a non-leaking container even if the acid appears to have been drained out; and
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Schedule periodic waste collection to prevent overflow of containers / facilities.
SOP7.12 Hazardous wastes such as reagent packaging that cannot be reused or recycled will be buried in a designated waste landfill lined with synthetic or compacted clay
basal liner to prevent contamination of surrounds. Hazardous waste requiring prior incineration (e.g. contaminated soil from chemical or oil spills, reagent packaging,
contaminated truck wash sludge) will be volatised in an appropriately designed burn-pit or incinerator.
SOP7.13 Ensure pests and native fauna cannot access hazardous waste items.
SOP7.14 Dispose of suitable sewage treatment plant sludge by direct landfill burial in unlined pits.
CYANIDE MANAGEMENT
SOP7.15 Be consistent with the ICMI Cyanide Management Code (Cyanide Code) Principles and Standards of Practice for cyanide handling, storage and transportation,
including independent third-party auditing of procedure conformance. ICMI Principles include (ICMI, 2014):
Production: Encourage responsible cyanide manufacturing by purchasing from manufacturers who operate in a safe and environmentally protective manner;
Transportation: Protect communities and the environment during cyanide transport;
Handling and Storage: Protect workers and the environment during cyanide handling and storage;
Operations: Manage cyanide process solutions and waste streams to protect health and the environment;
Decommissioning: Protect communities and the environment from cyanide through development and implementation of decommissioning plans for cyanide
facilities;
Worker Safety: Protect workers’ health and safety from exposure to cyanide;
Emergency Response: Protect communities and the environment through the development of emergency response strategies and capabilities;
Training: Train workers and emergency response personnel to manage cyanide in a sage and environmentally protective manner;
Dialogue: Engage in public consultation and disclosure.
SOP7.16 Specific training will be provided to plant operators and employees handling and transporting cyanide. In accordance with the ICMI 2014 Cyanide Code, the training
programme will include:
Improving the understanding of cyanide related hazards and health risks (including learning how to recognise and treat cyanide poisoning);
Use of operating manual, standard operating procedures, equipment, checklists, training documents, and tracking records in place to prevent or control
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C* O D*
worker exposures and environmental releases during cyanide unloading, storage and mixing;
Emergency response procedures to respond to worker exposure or environmental release of cyanide, including decontamination and first aid procedures;
Refresher courses on a periodic basis and emergency drills to ensure effectiveness of procedures and training in place; and
Relevant staff and contractors will need to be trained and instructed to adhere to the specific Cyanide Spill Contingency Plan to be developed for the Project.
SOP7.17 Dispose of cyanide waste (e.g. packaging and containers) by incinerating in an appropriately engineered burn-pit/incinerator and disposing of potentially
contaminated ashes at an adequately designed landfill (refer to SOP7.12 for details on burying hazardous wastes).
HYDROCARBON MANAGEMENT
SOP7.18 Develop a specific hydrocarbon contaminated soils procedure detailing different methods for treatment and disposal based on scale and type of situation (e.g. small
spill, general spill, large spill).
SOP7.19 Implement the following procedure for areas used for hydrocarbon storage, refuelling, equipment laydown, and vehicle maintenance and washdown (e.g. Vehicle
Workshop, Fuel Depot, truck washdown area, grease and oil waste storage facility):
Perimeter bunding and interception drains to contain oily runoff. Containment facilities to include sediment and grease traps as a minimum;
Appropriate spill clean-up materials (e.g. Sorbex) for small hydrocarbon spills, and drop cloths and drain pains during vehicle maintenance to catch leaks or
spills;
All drainage in areas where fuel is stored or used will be routed through an oil interceptor before discharge to the TMF. Oily contaminated runoff water will be
collected at source and transferred to the TMF (via pipeline or channel). Discharge of oily contaminated water into the receiving environment without prior
treatment will be banned;
Grease and oily wastes (e.g. waste oils, lubricants, oil filters and oily rags) will be collected at source and immediately transferred to the grease and oil waste
storage facility. Waste oil, lubricants and oil filters will be recycled, where possible;
Truck washdown area will be paved with surface water diverted to a collection sump. Hydrocarbon contaminated sludge from the sump (<10 m3 per week)
will be volatilised and then buried in a lined landfill facility (as per SOP7.12). Treated wastewater (e.g. from oil / water separator at the sump) will be used for
dust suppression on haul roads;
Project vehicles/equipment will be checked regularly for any leaks (to be addressed immediately);
Project vehicles and equipment will be parked on sealed surfaces during non-operation, where possible;
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Safety, fire and accidental spill procedures and ‘No Smoking’ signs will be posted clearly in strategic locations wherever fuel is handled or stored; and
Containment facilities will be checked on a regular basis to ensure their effectiveness.
SOP7.20 Ensure personnel are adequately trained in hydrocarbon storage, handling, spill prevention, and spill treatment measures with appropriate personal protective
equipment (PPE) provided. Stock adequate volume of hydrocarbons spill kits (e.g. Sorbex) in readily accessible locations where hydrocarbons are stored or handled.
EXPLOSIVES HANDLING AND STORAGE
SOP7.21 Store explosives in appropriately designed facility within an ‘explosives magazine storage area’. The facility must ensure the following measures are met:
Sufficiently located away from populated structures, frequently used areas and other utilities;
Designed, constructed and operated in accordance with AS 2187 – Explosives – Storage, Transport and Use. (Current 1998 ed.). As a minimum, the
magazine will be fully bunded/mounded and weatherproof, with appropriate earthing and lightning protection safety considerations provided;
Facility is fully secured with fencing, lock and 24 hour security, and access is restricted to authorised staff only;
Explosives inventory will be maintained and use of high explosives will be minimised (use of ANFO will be preferred);
Incompatible materials (e.g. detonators and dynamite) will be stored in separate facilities;
Adequate fire safety equipment, emergency management plan and procedures and employee training will be in place;
Regular stock takes and inspections will be conducted;
Fire break in place to prevent bushfires; and
Boxes containing explosives clearly labelled with an ‘explosive’ sign and appropriate posters (e.g. ‘No Smoking’) and MSDS will be provided.
SOP7.22 Maintain a log book at the facility to register movements of the explosives stored onsite (recording quantity, name of visitor/user and date).
CONCRETE WASTE MANAGEMENT
SOP7.23 Manage concrete waste in line with good industry practices to avoid potential discharge into the receiving environment by:
Providing appropriate concrete waste management facilities and training for employees and contractors;
Properly storing concrete and cement materials in adequate storage containers undercover;
Collecting and properly disposing of aggregate concrete wastes; and
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Washing concrete-coated vehicles or equipment in designated washbay areas away from nearby waterways and wetlands, with primary and secondary
containment facilities installed to ensure contaminated wash water is captured and appropriately managed, e.g. transfer to a temporary pit or level bermed
area where the concrete can set and water can evaporate or be treated.
HAZARDOUS SPILL AND CONTAMINATED SOIL MANAGEMENT
SOP7.24 Personnel will be trained in the emergency preparedness and response protocols, and contractors to develop Emergency Preparedness and Response Plans that will
detail proper training requirements, storage and handling procedures, emergency spill clean-up requirements, etc.
SOP7.25 Ensure contracted dangerous goods and hazardous materials transporters are adequately prepared for emergency response and have detailed hazardous materials
transport plans (e.g. cyanide transport plan) and detailed risk assessment in place.
SOP7.26 In the event of a spill or leak of hazardous materials, the following procedure will be followed, as a minimum:
First person to notice the spill/leak will immediately notify nominated persons (i.e. the Company’s Environment Department) and authorities (depending on the
size, nature and scale of the spill/leak). Surrounding people will also be warned immediately (e.g. verbal notification, alarm, siren), particularly if there is a
health danger;
The spill/leak will immediately be contained, secured for restricted site access, and cleaned up by appropriately trained staff with PPE and spill clean-up kits;
Depending on the size of the spill, a sand berm or dike may be constructed to absorb the discharge if secondary containment should fail;
Avoid or minimise amount of water used to clean up spills on paved surfaces, and ensure contaminated water is captured and disposed of appropriately (refer
to above);
Properly dispose of materials used to clean-up spill/leak (e.g. contaminated soil from chemical or oil spills) in accordance with current national and
international regulations and SOP7.12 (which provides details on disposing of hazardous wastes); and
The Company’s Environment Department will be notified as soon as possible if the amount of discharge is sufficient to be reportable or if the discharge is
accidentally released into the receiving environment, for further spill response and management.
SOP7.27 Maintain a contaminated site register that tracks contaminated sites at the Project site, including accurate GPS coordinates of the location, type of contamination,
estimated volume, and any action taken to remediate. Prior to ground disturbance, check if any planned works will affect a contaminated site by reviewing relevant
historical records and databases.
HAZARDOUS MATERIALS AND DANGEROUS GOODS MONITORING
SOP7.28 Develop and maintain the detailed hazardous materials and dangerous goods monitoring programme for the Project up-to-date to ensure compliance with relevant
national and international guidelines. Key monitoring procedures include:
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Regular (e.g. weekly) inspections of hazardous materials storage areas/containers/pipelines/flange seals to check their condition (for potential leakage or
seepage) and visually observe workforce compliance with established procedures to ensure preventive measures are effective and adequately employed;
The Company to undertake regular inspections to monitor the success and compliance of waste management strategies onsite according to key performance
indicators (e.g. use of appropriate containers for waste, beneficial reuse or recycling, and waste reduction);
Annual audits of hazardous materials and dangerous goods stored, handled and transported for the Project. Relevant site management plans and
procedures will be updated, where required;
Review of annual reportable incidents of accidental hazardous material spills and contaminated sites register to determine if additional preventive measures
for hazardous materials management are required;
Continuously measure usage rates per unit operation of cyanide, elution and detoxification reagents and diesel to reconcile with the records of amounts
delivered and stored onsite through delivery receipts and stock takes. Minimise the amounts of hazardous materials are stored, where possible; and
Investigative monitoring for related complaints through the Project grievance management system and implementation of remedial actions accordingly.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP08: Blasting Management
Blasting of ore and rock for construction and mining activities will generate fly rock as well as significant noise and vibration (ground and airborne) emissions through the areas
surrounding the blast area. The blast contractor will prepare a Blast Management Plan prior to construction that is specific to the Project conditions and incorporates the below
management measures, where relevant. All blasting activities for the Mako Gold Project will be undertaken in accordance with the Blast Management Plan.
I.D. No. Measures for blast management Applicable for
C* O
*
D
*
BLAST MANAGEMENT
SOP08.1 Consider the following good industry practice measures in the blast design and procedure:
Only staff and contractors appropriately trained in handling and using explosives will be permitted to conduct blasts following rigorous training and review of
competency;
Ensure no explosive charge per blast hole exceeds the estimated maximum charge weight per delay;
Check that the charge is able to break and displace its burden with reasonable ease;
Verify that burden distances are not too small;
Ensure premature ejection of stemming columns does not occur;
Place inter-row delays long enough to give good progressive relief of burden. Consider using delayed/micro delayed electronic detonators, where practicable;
Detonate cord trunklines to fire pre-split blasts and ensure these trunklines have a core load of only 5 g/m ad are covered by at least 250 mm of sand or fine
screenings;
Ensure blast pattern designs and powder factors are sufficient to provide the required fragmentation while minimising the potential to cause damage to pit walls
and infrastructure.
SOP08.2 Blasts will be conducted no more than one blast during the daytime between 9 am and 5 pm, preferably in the afternoon at regular intervals to reduce startle factor.
Detonate only one charge per delay.
SOP08.3 Blasts will be conducted during favourable weather conditions, where practical (e.g. avoid periods of dry and windy conditions, Harmattan winds).
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SOP08.4 Implement additional management measures relevant to blasting from the various SOPs and management plans developed for the Mako Gold Project, including dust,
noise and vibration control measures specified in SOP04: Emission and Dust Control and SOP05: Noise and Vibration Management.
BLAST HEALTH AND SAFETY
SOP08.5 Incorporate the following health and safety measures prior to any blasts conducted for the Project:
Blasting will be no closer than 500 m from an existing dwelling / structure without prior consultation and approval by a directly affected landowner;
Enforce a 500 m radius exclusion zone;
Secure site perimeter with security personnel (e.g. block access roads, exit/entry points, fencing and signage);
Use sirens or amplified verbal warnings to notify nearby people of the imminent blast; and
Survey the blast exclusion zone to ensure it has been cleared of unauthorised people or potential hazards (e.g. vehicles, hydrocarbon containers, etc.).
SOP08.6 Monitor flyrock visually to confirm that the exclusion zone is sufficient to protect sensitive receptors (i.e. biological and social). A record of any flyrock that travels more
than 200 m will be kept, with an investigation on how this occurred. Review any reported structural damage from blasting activities.
SOP08.7 Train Project staff on fly rock safety and conduct a public education programme regarding community safety issues associated with blasting.
SOP08.8 Drill and blast procedures will be designed by blasting specialists to ensure the safety of the mine workforce and surrounding local population, the control of flyrock,
noise and vibration. Procedures will be periodically re-assessed to confirm the effectiveness of blast management strategies.
COMMUNICATION FOR BLASTING
SOP08.9 Establish a blast schedule plan and communication protocol whereby nearby villagers and Project personnel receive sufficient prior notification. Notification will be
conducted via the following methods:
Ongoing village consultation and posters in villages with blasting dates / times or notification of blasting schedule at least 24 hours in advance of scheduled blast;
Appropriate signage in French located near the blast area; and
Use of a sounding horn to warn people in the area of impending blast (e.g. sounded 15 minutes and 5 minutes in advance of blast).
BLAST CONTRACTOR MANAGEMENT
SOP08.10 Select a blast contractor using the following criteria:
A licensed and competent blast contactor that has sound reputation and track record with respect to blast practices;
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Proposed blasting practices are consistent with good industry standards;
Contractor’s staff are trained and competent; and
All relevant safety systems and procedures strictly followed.
SOP08.11 Employ blasting experts on a regular basis to audit and provide specialist advice on blasting issues.
BLAST MONITORING
SOP08.12 Maintain and update the blast monitoring programme for the Project to ensure compliance with relevant national and international guidelines. Key blast monitoring
requirements include:
Monitor blast results continually to make improvements and inform future blast designs (including extent of flyrock generated, and levels of airblast and vibration
caused) to achieve a ‘Zero incident record’ for blasts;
Visually inspect and monitor for flyrock to confirm that the exclusion zone adequately protects community and worker safety;
Routine monitoring of noise, airblast, ground vibration, and flyrock impacts within 500 m of the blast area on a periodic basis (e.g. when there is a change of blast
location) to determine extent of impact;
Visual observation checks for unauthorised people within the blast area prior to blasting; and
Regular audit of Quality Assurance and compliance processes based on blasting results and practices (by a blasting expert).
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP09: Land Clearance and Soil Stockpiling
Detailed site procedures and a CEMP will be developed by the Construction Contractor and the Company for the Mako Gold Project prior to pre-construction commencing, which
will detail the appropriate management and mitigation of Project impacts associated with land: including social aspects for Project compensation/restoration of temporary and
permanent land, assets and livelihood losses; and consultation with directly affected people and other relevant stakeholders. These procedures will incorporate the environmental
management and mitigation measures and strategies listed below for land clearance, soil resources and progressive rehabilitation management.
I.D. No. Measures for land clearance and stockpiling management Applicable
for
C
*
O
*
D
*
MINIMISATION OF SOIL AND VEGETATION DISTURBANCE
SOP09.1 Plan topsoil stripping, stockpiling and management prior to ground disturbance works commencing (preferably in dry periods) and avoid long periods of disturbed land
remaining unstable. Avoid conducting significant land clearance during the rainy season, where possible.
SOP09.2 Implement the following land clearance procedure for the Project (where appropriate):
Further consultation will be conducted through established consultation groups in advance with local villages/settlements regarding current land uses, and social
and cultural assets in the area to identify cultural, land and livelihood sensitivities; ;
The compensation process for any Project affected person will be in accordance with the Project Livelihood Restoration Plan (LRP) (Volume D);
Vegetation clearance will be conducted during the dry season and confined to the minimum area required for safe operations to reduce the potential for dust,
erosion and sediment transport. Where practicable, vegetation will be retained in steep areas and riparian corridors, or at least preserved in situ as long as
possible up until clearing is unavoidably required;
Temporary land disturbance (e.g. for construction laydown areas, site access, stockpiles) will be carried out in previously disturbed areas, where possible;
Prior to clearance, commercial forestry timber inventories will be determined by the Department of Water and Forests (Département des Eaux et Forêts) to
calculate the total loss of commercial timber and any applicable forestry taxes (note the Company will be exempt from paying forestry taxes under a current
Exploitation Permit);
Any commercially valuable timber will either be salvaged or compensated (where salvaging is not possible). This will be coordinated with the Department of Water
and Forests (Département des Eaux et Forêts) using local licensed logging contractors. Project affected communities will also be allowed to collect traditional
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forest resources (e.g. firewood, non-timber forest products), wherever possible;
Areas scheduled for land clearance will be clearly demarcated in advance and personnel informed that any activities outside the designated areas will be strictly
forbidden except for entry and exit along designated access routes;
Vegetation and topsoil removal will be minimised to the extent practicable by retaining trees and vegetation or clipping tree branches rather than complete removal
of trees (particularly along Project roads). If possible, retain roots in the ground to reduce erosion and to facilitate rapid revegetation;
An ecologist will be on call during habitat clearance work to provide assistance / advice regarding any biodiversity issues if required;
Progressive clearing of vegetation in a controlled manner (to allow mobile fauna to move away from clearance areas) giving priority to manual clearing near
sensitive vegetation, steep terrain, and along local waterways. Machinery and chemical clearance will be strictly supervised to ensure safe working conditions;
Progressively rehabilitate landforms from temporarily impacted areas that will not be required at a later stage, including buffer areas required for construction
equipment (e.g. road embankments, access for construction equipment, etc.);
Salvage stripped topsoil (topsoil removal to a depth of 10 cm) and subsoil, where feasible, in stockpiles for future reuse, and windrow cleared vegetation
stockpiles for later reuse in mulching / chipping or as an erosion control. Ensure stockpiles are managed to prevent spread of fire or collapse in accordance with
SOP09.7 and 9.8 below;
Soil seed bank in the topsoil will be preserved for future rehabilitation, to maintain local genetic diversity;
Stabilise any cleared areas in areas prone to erosion (e.g. steep terrain, near waterways or wetlands) as a priority by covering with wood chippings or grass
matting;
A land disturbance permit system will be established and any necessary land disturbance permits to be obtained in advance from the Company Environment
Department. The permit system will include the following key aspects:
» Proposed location and area of vegetation to be cleared;
» A site map indicating the boundaries of the area to be cleared, designated site access entry/exit routes, and clearly marked ‘No Go Areas’ for sensitive
residential, cultural and environmentally areas to avoid where feasible;
» Timing and duration of land clearance activities;
» Consideration of potential impacts associated with biodiversity, visual amenity, noise and dust nuisance, water quality, and future rehabilitation of the cleared
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areas;
» Consideration of potential impacts associated with cultural heritage, current land use, community and livelihood use of the cleared areas;
» Proposed means for planned mitigation (if applicable) and compensation requirements;
» Written approval or permit for forestry clearance issued by the relevant government authority;
» Proposed means for handling and reusing cleared vegetation and topsoil; and
» Authorised signatures of the Company’s nominated person of authority.
SOP09.3 Ensure acid sulphate soils (ASS) surveys are carried and an ASS management plan implemented in advance, where required.
SOP09.4 Provide employee training and awareness programmes for all Project staff and contractors (e.g. through staff inductions) focusing on improving their understanding of the
importance of threatened fauna and flora as well as forest resources for local communities. Communicate the Project ban (and associated penalties) that applies
regarding harvesting and collecting forest resources (including timber and non-timber forest products) and hunting, trading and buying of wildlife.
SOP09.5 Invasive weed spread will be minimised by implementing the following preventative controls:
Use of local non-invasive plant species for revegetation purposes; and
Compliance with the washdown procedures for vehicles and equipment entering worksites and site access control (refer to SOP07.18-20 and SOP09.9).
SOP09.6 Where appropriate, implement additional measures specified in SOP01: Erosion and Sediment Control, and the Project Biodiversity Action Plan (Volume C).
SOIL STOCKPILE MANAGEMENT
SOP09.7
Soil stockpiles will be constructed and managed following the below procedure, as appropriate:
Soil overburden will be stockpiled for use in later rehabilitation of mined-out areas;
Stockpiles will be located within designated soil stockpile areas where movement of vehicles and equipment are excluded and up-slope (at least 20 m away) from
local waterways and flood inundation areas;
Soil overburden will be stripped from all pit and waste rock dump areas during the dry season immediately prior to major earthworks, where feasible. Wherever
possible, overburden will be stripped and immediately placed on rehabilitation areas in the same area of the operation;
Where this proves impractical, topsoil and subsoil will be stockpiled separately;
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Soil overburden dumps will be formed with as little compaction as possible in mounds generally no more than 2 m high (for topsoil) and 5 m high (for subsoil) to
minimise losses to erosion. These stockpiles will be formed on flat ground, surrounded by low bunds and/or additional erosion and sediment control facilities that
will be constructed prior to the onset of the rainy season;
Slope ratios will be no more than 2:1 (horizontal/vertical);
Stockpiles will be stabilised with revegetation, grass matting or other appropriate controls if they are to remain bare for more than 3 months, particularly in the
rainy season;
Compaction of stockpiles will be avoided as this will hinder establishment of stabilising vegetation;
Location of soil stockpiles and batters will be geo-referenced and mapped in a GIS database with details on type of material and duration of stockpiling recorded;
Stockpiles to avoid visually unobtrusive locations, where possible; and
Diversion structures will be installed up-slope of stockpiles and sediment controls (e.g. silt fence) located downslope, to limit the generation of turbid water (refer to
SOP01: Erosion and Sediment Control for further details).
SOP09.8 Implement additional measures specified in SOP01: Erosion and Sediment Control, SOP2: Water Quality and Pollution Management, SOP04: Emission and Dust Control,
to minimise associated stockpile impacts, where appropriate.
SITE ACCESS CONTROL AND INVASIVE SPECIES PREVENTION
SOP09.9 A washdown procedure will be employed to prevent invasive weed spread (particularly for Mimosa pigra), and potential contamination of the receiving environment from
concrete coating and sediment tracking. The procedures will ensure that earthmoving equipment and vehicles will: 1) follow designated ingress/egress routes to control
site access; and 2) be thoroughly checked and cleaned in designated washdown bay areas before entering/leaving main worksites onto public roads and between areas
where Mimosa pigra is confirmed to occur and unaffected areas. Refer to SOP07; Hazardous Materials Management, for design and implementation details of the wash
bay areas.
SOP09.10 Clearly demarcate site access tracks/roads with flagging tape or signage where required, to minimise risk of rutting and erosion and unnecessary damage to road verge.
BORROW PITS AND QUARRIES
SOP09.11 Prioritise reuse of suitable construction waste (e.g. excavated subsoil, waste rock or inert construction rubble) available onsite as fill/gravel material, where possible. An
inventory of suitable materials (and testing undertaken) available onsite will be prepared and maintained.
SOP09.12 Where suitable sand, fill and gravel available onsite is not sufficient to meet Project demands, the Company and its contractors will source additional sand, gravel and fill
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material consistent with the following procedure:
Sand will be sourced from identified borrow areas situated within 5 km of the Project. If required, additional sand to supplement local sand available will be
sourced from a larger source located outside the Mining Concession;
Gravel (including aggregate and rip-rap material) will be sourced from the pre-existing quarry and gravel stockpile identified off the National Road 7, which was
used for the RN7 highway upgrade (preferred site);
Clay-rich material (engineering grade) required (e.g. for WSD and TMF embankment / dam construction / and maintenance and for the TMF HDPE liner) will be
sourced from local borrow areas within 2 km of construction activity;
Use of disturbed areas will be maximised for temporary laydown areas and key extraction areas;
The number of rock and borrow pit cuts will be minimised, where practicable;
Borrow pits and quarries will be slightly raised to promote site drainage, where possible;
Further testing of acid rock drainage (ARD) potential and construction material suitability will be conducted, as necessary;
Only mobile excavators will be permitted to extract fill and other soft materials;
Extraction will not exceed 6 m in depth or penetrate the underlying water table, whichever is the shallower;
Portable crushing plant operation and blasting will be conducted during daytime only, to avoid potential night-time disturbance;
Adequate drainage, erosion and sediment control devices will be installed to reduce sediment-laden runoff into the receiving environment (refer to SOP01, SOP02
and SOP03); and
Relevant environmental management measures detailed in SOP04 to SOP08, SOP10 and SOP11 will be implemented, as necessary.
SOP09.13 If required, identify new locations for borrow pits and quarries in accordance with the following site selection criteria:
As close to the Project and accessible to existing transport infrastructure as possible;
Avoidance of environmentally sensitive areas, known cultural heritage or archaeology sites, residential areas and productive agricultural land (cultivated or fallow),
where possible;
No closer than 500 m from an existing dwelling / structure unless a shorter distance is agreed through community consultation; and
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No closer than 50 m from a watercourse or wetland.
SOP09.14 For any blasting required, adhere to the Blast Management Plan that will be developed for the Project, in accordance with SOP08: Blasting Management.
SOP09.15 For discontinued use of borrow pits and quarries, progressively rehabilitate as soon as possible to final natural landform that takes into account pre-disturbance state,
public and wildlife safety, and community consultation outcomes (see below for further details).
POST-CLEARING MANAGEMENT AND MONITORING
SOP09.16 Disturbed areas will be progressively rehabilitated when feasible as soon as practicable after completion of works, with priority rehabilitation and revegetation undertaken
in high risk areas such as steep slopes and areas close to drainage lines and watercourses. Post-clearing management and monitoring from land clearance will be
undertaken as per the Rehabilitation and Conceptual Mine Closure Plan (Volume E), including:
Landscape disturbed area to reflect natural contours and restore suitable drainage paths;
Ensure re-planting uses indigenous and locally native species that are non-invasive;
Align with the rehabilitation requirements and strategies outlined in the Rehabilitation and Conceptual Mine Closure Plan (Volume E), Biodiversity Action Plan
(Volume C) and Livelihood Restoration Plan (Volume D) for the Project;
Monitor and maintain rehabilitated / revegetated areas to ensure effectiveness of planting and landscaping; and
Employ remedial measures (e.g. replanting dead or damaged trees or other vegetation types), as required.
SOP09.17 Regrowth vegetation will be regularly maintained (e.g. for fire breaks, operational safety purposes) using appropriate methods relative to the site’s environmental
sensitivity. Use of specific herbicides (for weed control) will need to be pre-authorised by the OHS&E Manager, and usage instructions strictly followed. Application of
herbicides will not be permitted during or just before rain events. Mechanical clearing or thinning will generally be preferred to the use of herbicides for vegetation
maintenance in sensitive locations because it is less likely to damage regenerating forest-edge vegetation and soil seed banks. No controlled burning will be allowed
activities for vegetation maintenance.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure
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SOP10: Cultural Heritage Management
Several cultural heritage surveys conducted for the Mako Gold Project (i.e. in Tambanoumouya) indicated there are no archaeological and culturally significant sites of local and
regional importance identified within the PDA. However, as there is still potential for Project activities to disturb cultural heritage values within the PDA during activities involving
ground disturbance or earthworks, the Company and its contractors will adhere to the below procedures and the CEMP accordingly. The cultural heritage management measures
provided below will be incorporated into relevant documents to ensure direct impacts on sites of international, national or regional cultural heritage significance are appropriately
managed.
I.D. No. Measures for cultural heritage management Applicable for
C* O
*
D
*
CULTURAL HERITAGEMENT MANAGEMENT
SOP10.1 Implement and maintain archaeological and cultural heritage register, management procedures, training, and instructions for employees and contractors in consultation
with a local cultural heritage expert and relevant government authorities.
SOP10.2 Educate and raise awareness of Project employees and contractors on the protection of local archaeological and cultural heritage values to employees and contractors
through mandatory inductions and training.
SOP10.3 Accurately map confirmed sites of cultural heritage or archaeological significance to prevent accidental disturbance and avoid to the extent possible direct disturbance to
these sites for site development and construction. Clearly mark known cultural heritage sites within and adjacent to disturbance areas as ‘No Go Areas’ to restrict
access by employees and contractors.
SOP10.4 Appropriately train all staff and contractors involved in any ground disturbance works on the latest version of the Chance Find Procedure for the Project provided in
Appendix B.
In the event of a find or suspected find of an artefact, human remains or site of cultural / archaeological significance, the Site Supervisor will strictly undertake the
following steps:
1. Immediately halt the ground disturbance works until further instructions from the Company’s Environment Department;
2. Implement the Chance Find Procedure as appropriate;
3. Notify relevant authorities of the find within 48 hours of the find and follow all instructions given by the authority, e.g. Ministry of Culture (Ministère de la Culture)
for human remains;
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4. Conduct an investigation of the site in situ in collaboration with archaeologists and/or local specialists and prepare a Chance Find Report, if required;
5. Based on the outcome of the investigation, agree on the best course of action (e.g. if item should be removed or left in situ). Further investigation and
involvement of other government agencies (e.g. Directorate of Cultural Patrimony (Direction du Patrimoine Culturel) may be required, where necessary; and
6. Only allow ground disturbance works to recommence after the Company has been granted written approval by the relevant authority.
SOP10.5 For any unavoidable disturbance to an item or site of cultural / archaeological significance, consult in advance with relevant stakeholders (e.g. relatives of a burial site),
authorities (e.g. local government or Ministry of Culture and experts (e.g. archaeologists and/or local cultural heritage specialists) to inform, discuss and obtain approval
for any proposed management and/or mitigation measures.
The Company will provide appropriate relocation of the artefact or physical cultural resource to an agreed and safe location, or where an item cannot be relocated,
adequate compensation to affected parties in accordance with the Chance Find Procedure (Appendix C) and the Project’s compensation framework.
SOP10.6 Minimise risks of theft and vandalism to cultural sites and illegal trade of artefacts and other historic objects providing evidence of prehistoric human occupation in the
region, by providing adequate fencing and signage to restrict public access.
CULTURAL HERITAGE MONITORING
SOP10.7 Develop and maintain the detailed cultural heritage monitoring programme for the Project to ensure compliance with relevant national and international regulatory
requirements. Key cultural heritage monitoring procedures include:
Regularly monitor the implementation of archaeological and cultural heritage management measures for compliance, and adapt measures as necessary;
Periodically inspect known sites of cultural heritage or archaeological significance within or adjacent to a construction worksite to confirm no accidental
disturbance has occurred;
Continue to document all new archaeological or culturally significant sites and intangible heritage values within the Project Area in a GIS database; and
Investigate with monitoring and management measures as appropriate in response to cultural heritage related complaints through the Project grievance
management system.
* C = Construction; O = Operations; D = Decommissioning/Closure
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SOP11: Lighting and Visual Amenity Management
Potential visual amenity impacts from the Mako Gold Project may result from vegetation clearance, land disturbance, establishment of mine and ancillary infrastructure (e.g. access
roads), and night lighting from the 24-hour mine operations. Night lighting may affect local light-sensitive fauna and nearby communities, while landscape change has the
potential to impact surrounding tourism values (e.g. Niokolo Koba National Park). The level of visual and lighting impacts impact is expected to decrease considerably the further
away from villages and tourist sites.
The following table provides measures based on principles outlined in the IFC Mining EHS Guidelines (2007) to address visual amenity and lighting impacts, and will be incorporated
into detailed site procedures (e.g. CEMP) to be developed for the Project prior to pre-construction commencing.
I.D. No. Measures for lighting and visual amenity management Applicable for
C* O
*
D
*
VISUAL IMPACTS MANAGEMENT
SOP11.1 Take into account existing culturally or economically important viewpoints and visually sensitive locations (e.g. tourism areas, mosques, settlements) when planning the
locations of infrastructure and structures, where practicable.
SOP11.2 Commensurate to the landscape sensitivity, the following management procedures will be adopted to ensure infrastructure, access roads, storage areas and other
Project components are designed to minimise visual impact as much as practicable:
Minimise vegetation clearing to the extent practicable;
Use naturally occurring terrain features to conceal Project features, where possible;
Retain existing road and hillside vegetation as a screening buffer for the Project, where possible;
Clip or prune tree branches rather than removing trees (particularly along Project roads) and avoid clearing mature trees from areas that will only be disturbed
temporarily (e.g. laydown areas);
Consider placing Project components such as stockpiles, earth banks and access cuttings as visual barriers to sensitive receptors;
Ensure that construction sites are well maintained and kept tidy;
Progressively rehabilitate cleared areas and revegetate around major Project structures (e.g. Process Plant) to help it blend into the surroundings;
Actively pursue opportunities to reuse excavated material to minimise the length of time spoil is stored in the Project Area;
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Utilise low-impact fencing such as wire mesh, rather than palisade or solid fence structures;
Use non-reflective surfaces for roofs, fences and building, and paint Project structures in muted colours in keeping with the local area and vegetation; and
Where relevant, incorporate visual amenity management and mitigation measures in tender documents and contracts with the Construction Contractor(s).
SOP11.3 Prior to construction, consider providing vegetation screening (e.g. significant tree or bamboo planting) around residential areas that are directly impacted by Project site
visibility, as identified through the community consultation process.
SOP11.4 Implement progressive rehabilitation as soon as practicable following disturbance and construction works. Revegetation will be consistent with surrounding landscape
character.
NIGHT LIGHT SPILLING MANAGEMENT
SOP11.5 Take into account locations of light-sensitive sensitive receptors (community and biodiversity) when designing measures to mitigate light spill, particularly for large
permanent facilities and buildings. Position night works lighting to minimise light spillage, e.g. directional lighting and/or shields to minimise spill into external areas.
SOP11.6 Keep site night lighting to the minimum necessary for safety and security. To minimise night-time light pollution and skyglow, consider using shielded lighting, lamps with
timers, or movement sensors to ensure lights are only lit when required.
SOP11.7 Avoid the need for night works in the vicinity of sensitive receptors (community and biodiversity) which are likely to be impacted, where possible.
SOP11.8 Limit light impacts from Project traffic by ensuring headlights are dipped after dark or using hoods, shields, or shorter lighting columns.
VISUAL AMENITY MANAGEMENT POST MINE CLOSURE
SOP11.9 To the extent feasible, land rehabilitation will be undertaken consistent with the surrounding landscape and aligned with the rehabilitation requirements and strategies
outlined in the Rehabilitation and Conceptual Mine Closure Plan (Volume E) developed for the Project.
VISUAL AMENITY MONITORING
SOP11.10 Investigate with monitoring and management measures as appropriate to respond to visual amenity related complaints through the Project grievance management
system.
* C = Pre-Construction/Construction; O = Operations; D = Decommissioning/Closure.
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APPENDIX B
Chance Find Procedure
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APPENDIX C
Monitoring Maps
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Figure A1 Air Quality and Noise Monitoring Sites Utilised for ESIA
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Figure A2 Water Quality Monitoring Sites Utilised for ESIA
Mako Gold Project Environmental and Social Management and Monitoring
Plan
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Figure A3 Aquatic Biodiversity Monitoring Sites Utilised for ESIA
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