Ulubelu 3&4 Revised ESIA Report - Volume IV · he K3LL existence, as an integrated part of the operations, is to support the implementation of the Oil, Gas and Geothermal objectives

Ulubelu 3&4 RevisedESIA Report - Volume IVEnvironmental and Social Management Plan

March 2011Pertamina Geothermal Energy

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E2558 v7

T +44(0) 1273 365 000 F +44(0) 1273 365 100, www.mottmac.com

Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom

265718 RGE GEV 13 A

F:\PROJECTS\265718 PGE Geothermal ESIAs\(2) Ulubelu\Reports\Submitted Draft\Addressing Comments\Ulubelu 3&4

01 December 2010

Ulubelu 3&4 Revised ESIA Report - Volume IV

Environmental and Social Management Plan

March 2011

Pertamina Geothermal Energy

Menara Cakrawala 15th floor, Jalan MH. Thamrin No. 09 - Jakarta 10340, Indonesia


Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom T +44(0) 1273 365 000 F +44(0) 1273 365 100, www.mottmac.com

Revision Date Originator Checker Approver Description

A 01/12/10 B. Cornet M. O’Brien D. Boyland First Draft

B 24/12/10 M. O’Brien D. Boyland D. Boyland Second Draft addressing PGE Review

C 09/02/11

M. O’Brien I. Bray H. White D. Mackay

D. Boyland I. Scott Revised Draft ESIA

D 25/02/11 M. O’Brien H. White

D. Boyland D. Boyland Revised ESIA

E 28/03/11 M. O’Brien D. Boyland D. Boyland Revised ESIA (addressing comments)

Issue and revision record

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.


Content

Chapter Title Page

1. Introduction 1

2. Key Roles and Responsibilities 2

2.1 Overview __________________________________________________________________________ 2

2.2 PGE EHS Management _______________________________________________________________ 2

2.3 Capacity Building ____________________________________________________________________ 6

2.4 Contractors’ EHS Management _________________________________________________________ 7

3. Plans, Policies and Procedures 9

3.1 Overview __________________________________________________________________________ 9

3.2 Identification of Indonesian Geothermal Environment Forum __________________________________ 9

4. Construction ESMP 15 4.1 Overview _________________________________________________________________________ 15

4.2 Social Management (Construction) _____________________________________________________ 16

4.3 Hydrology Management (Construction) __________________________________________________ 22

4.4 Groundwater Management (Construction)________________________________________________ 26

4.5 Noise Management (Construction) _____________________________________________________ 28

4.6 Ecology Management (Construction)____________________________________________________ 30

4.7 Air Quality Management (Construction)__________________________________________________ 33

4.8 Climate Change Management (Construction) _____________________________________________ 34

4.9 Waste Management (Construction) _____________________________________________________ 35

4.10 Geology and Erosion Management (Construction) _________________________________________ 36

4.11 Land Contamination Management (Construction) __________________________________________ 38

4.12 Transport Management (Construction) __________________________________________________ 40

4.13 Archaeology and Cultural Heritage Management (Construction) ______________________________ 41

5. Operation ESMP 43 5.1 Overview _________________________________________________________________________ 43

5.2 Social Management (Operation) _______________________________________________________ 44

5.3 Hydrology Management (Operation) ____________________________________________________ 46

5.4 Groundwater Management (Operation)__________________________________________________ 49

5.5 Noise Management (Operation)________________________________________________________ 50

5.6 Ecology Management (Operation) ______________________________________________________ 51

5.7 Air Quality Management (Operation) ____________________________________________________ 51

5.8 Waste Management (Operation) _______________________________________________________ 54

5.9 Geology and Erosion Management (Operation) ___________________________________________ 55

5.10 Land Contamination Management (Operation) ____________________________________________ 55

6. Air Quality / H2S Monitoring Programme 58 6.1 Overview _________________________________________________________________________ 58

6.2 Purpose __________________________________________________________________________ 58

6.3 Schedule _________________________________________________________________________ 58

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6.4 Data Collection Methods _____________________________________________________________ 59

6.5 Locations _________________________________________________________________________ 60

6.6 Quality Assurance/Quality Control ______________________________________________________ 62

6.7 Analysis, Reporting and Actions _______________________________________________________ 62

6.8 Costs ____________________________________________________________________________ 63

6.9 Responsibilities ____________________________________________________________________ 63

7. Health Data Collection Programme 64 7.1 Overview _________________________________________________________________________ 64

7.2 Purpose __________________________________________________________________________ 64

7.3 Schedule _________________________________________________________________________ 64

7.4 Data Collection Methods _____________________________________________________________ 64

7.5 Analysis, Reporting and Actions _______________________________________________________ 66

7.6 Responsibilities ____________________________________________________________________ 67

8. H2S Emergency Response Plan 68 8.1 Overview _________________________________________________________________________ 68

8.2 Response to Elevated H2S Concentrations and / or Observed Health Effects ____________________ 68

9. Other Management Plans / Method Statement Framework 71 9.1 Overview _________________________________________________________________________ 71

9.2 Recruitment Plan ___________________________________________________________________ 71

9.3 Retrenchment Plan _________________________________________________________________ 72

9.4 Labour Grievance Mechanism Framework _______________________________________________ 72

9.5 Waste Management Plan_____________________________________________________________ 73

9.6 Traffic Management Plan_____________________________________________________________ 74

9.7 Temporary Worker Accommodation Management Plan _____________________________________ 75

9.8 Chance Finds Procedure _____________________________________________________________ 76

Tables

Table 3.1: Plans, Policies and Procedures ________________________________________________________ 11 Table 4.1: Construction ESMP Structure _________________________________________________________ 15 Table 5.1: Operation ESMP Structure ___________________________________________________________ 43

Figures

Figure 2.1: PT PGE Construction Organogram ______________________________________________________ 4

Figure 2.2: PT PGE Operation Organogram ________________________________________________________ 5

Figure 4.1: Proposed Monitoring Locations – Construction ____________________________________________ 42

Figure 5.1: Proposed Monitoring Locations – Operation ______________________________________________ 57

Figure 6.1: H2S Passive Diffusion Tube and Mounting Method_________________________________________ 60

Figure 6.2: Proposed H2S Monitoring Locations ____________________________________________________ 61

Figure 8.1: H2S Emergency Response Plan Flowchart _______________________________________________ 70

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1. Introduction

The primary objective of an Environmental and Social Management Plan (ESMP) is to safeguard the environment, site staff and the local population from site activity which may cause harm or nuisance. The management plan, which also covers monitoring, will form the basis of the environmental and social protection measures implemented by PGE and its contractors (EPC contractors for the power plant and Steamfield Above Ground System and drilling contractors). The implementation of the ESMP ensures EHS performance is in accordance with international standards (including the relevant World Bank operational policies and World Bank Group EHS guidelines) and best practice.

Where relevant this volume consolidates the mitigation requirements identified in the various AMDAL processes and those identified as part of the international ESIA process (presented in Volume II of the ESIA).

The environmental management requirements presented in this document have been based on the findings of the following:

Site visit and data collected by MML’s team to the Project site in March and June 2010; This international ESIA documentation prepared by MML (draft in 2010, revised 2011); and ANDAL and RPL/RKL reports for the Project.

The mitigation measures identified within this document will be implemented within a formal EMS aligned to ISO 14001:2004, the international standard for EMS, or equivalent. Guidance on requirements for EMS for power plants is also discussed and addresses:

Organisation and responsibilities; Training and awareness; Emergency procedures and response; Record keeping; and Performance monitoring, reporting and auditing.

Responsibilities for implementation are outlined in the ESMP and fall to either PGE or the various contractors including the power plant EPC Contractor, the Steamfield Above Ground System (SAGS) EPC Contractor and the drilling contractors. Where responsibilities fall to the EPC Contractor these should be implemented via the contractor’s own EMS (preferably accredited to ISO 14001:2004 or equivalent).

In addition to this ESMP, this volume provides a more detailed programme for monitoring H2S concentrations and for monitoring potential health impacts in the Project area in view of the possible air quality impacts identified.

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2. Key Roles and Responsibilities

2.1 Overview

The key parties and their primary roles in implementing the ESMP as elaborated with this Volume IV of the ESIA for the Project are summarised as follows: PGE – responsible for overseeing compliance with environmental policy and monitoring compliance of

the Project, and ensure compliance with the obligations set out in the ESMP on a day to day basis during the construction phase and operation phase; and

EPC Contractors (power plant and SAGS) - responsible for implementing the site specific construction ESMP via their own environmental management system to be approved by PGE; and

Drilling Contractors – responsible for following and complying with construction ESMP requirements set out by PGE.

2.2 PGE EHS Management

2.2.1 Environmental Health and Safety Policy and Commitment

Pertamina’s Corporate Centre for Environmental Protection, Occupational Health and Safety (known as HSE Corporate or Kesehatan Keselamatan Kerja dan Lindung Lingkungan (from here on referred to as K3LL) has the task to carry out corporate studies and development efforts in the field of Environmental Protection and Occupational Health and Safety across the Pertamina businesses (including PGE). Progress in various aspects of this task has been achieved by K3LL since its establishment, in particular in obtaining Pertamina’s Board of Director’s commitment on a company wide Environmental Protection and Occupational Health and Safety Policy.

The K3LL existence, as an integrated part of the operations, is to support the implementation of the Oil, Gas and Geothermal objectives for its operations to be safe, reliable and environmentally oriented. K3LL’s function is to: Study matters on Environmental Protection and Occupational Health and Safety in the company’s

periphery. Present views, suggestions and opinions on matters related to Environmental Protection and

Occupational Health and Safety. Develop systems, procedures and rules on how Environmental Protection and Occupational Health and

Safety should be brought about and maintained. Monitor the results of the efforts in the field of Environmental Protection and Occupational Health and

Safety. Cooperate with the Government institutions and institutes concerned with Environmental Protection and

Occupational Health and Safety.

The Environmental Protection and Occupational Health and Safety Management System (EHSMS) is applied in a flexible way so as to enable the Company’s operational units to quickly adjust to and meet the prevailing environmental regulations and standards. The EHSMS is a live document that is periodically monitored and reviewed to enable continual improvement.

An EHSMS has been applied with the aim of achieving the Corporate aims and objectives for its operations to be safe, reliable and environmentally oriented. This EHSMS is the base for all operations and is an integral part of the Oil, Gas and Geothermal business.

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Pertamina’s philosophy for all its operations is to ensure safe, dependable and environmentally oriented execution. The EHSMS is one of the ways of applying this philosophy in operational practices and has been set up to achieve continual improvement through: Identifying and setting up the required basic policies, performance standards and the required

operations to support the company in carrying out safe, reliable and environmentally oriented operations.

Studying the results of the applied policies, procedures, practices, controls and standards through self assessment programmes.

Identifying potential hazards and assessing risks for effective cost control. Systematically determining the aim, objectives and targets of the required level of environmental

protection. Developing application plans to meet the organization’s aim and objectives. Evaluating and analysing performances. Assessing the environmental management performance and the future requirements concerned.

PGE has developed its own sector specific EHS guidelines and procedures as part of its own management plan which addresses the specific needs and requirements of geothermal projects from exploration through to operation. PGE’s Environmental, Health and Safety Management System (known as Sistim Manajemen Keselamatan, Kesehatan Kerja dan Lindungan Lingkungan or SMK3LL) includes policies and procedures that are relevant to the company’s operations and also addresses aspects such as legislative compliance, EHS training, auditing, managing contractors’, monitoring and reporting and communication. The SMK3LL is a company wide system in line with the requirements of ISO 9001:2008 Quality Management System and ISO 14001:2004. As part of an ongoing programme, future commitments include developing an Integrated Management System across the company.

PGE’s existing SMK3LL will form the basis of the EHS management for the development and operation of the Ulubelu Unit 3&4 Geothermal Power Plant. During the construction phase of the Project the EPC contractor will be required to develop a health, safety and environmental (HSE) plan which will be co-ordinated with the requirements of PGE’s SMK3LL. The Contractor EHS management system (EHSMS) will include an EHS Policy for the Project and procedures outlining how it is intended to implement EHS management requirements through the design, construction and commissioning stages of the Project to ensure that works are executed in a responsible manner, and are in compliance with the national AMDAL process and international World Bank standards. These procedures will cover, as a minimum, environmental management, environmental monitoring, environmental training, communications, emergency procedures, record keeping and performance monitoring, reporting and auditing. Once approved, all employees/contractors should be provided training in the EHSMS and associated procedures and it should be implemented at all operating units/facilities.

2.2.2 Current Organisational Structure and Responsibilities

PGE’s personnel key roles and responsibilities are set in procedures separate from the SMK3LL, including organisational and individual working procedures.

There are currently two HSE personnel stationed at Ulubelu Unit 3&4 site office. These include an environmental engineer and a safety engineer. Meanwhile, the Environmental Specialist, Quality Management Specialist and OHS Specialist and Head of Quality, Environment, Health and Safety are stationed at the PGE head office. In addition to the HSE personnel at site, there is one public relations officer employed on-site. The site public relations officer is supported by one public relations and one government relations members of staff based at the PGE head office responsible for all PGE operations and projects with input on consultations from the single environmental specialist.

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Construction and Operation organograms which sets out the key roles and responsibilities of PGE for Ulubelu 3&4 are presented in Figure 2.1 and Figure 2.2 below.

Figure 2.1: PT PGE Construction Organogram

Source: PGE

PGE will appoint a dedicated person from the project team to oversee environmental management and implementation (Environmental Engineer under HSE/K3LL department in Figure 2.1 above), and to act as the main point of contact with the EPC contractor and Steamfield contractors. In addition, for the Lahendong Units 5&6 Project, the Environmental Engineer will also act as the Occupational, Health and Safety Engineer. The PRO for construction will operate under Legal & Human Relation department in Figure 2.1 above.

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A typical PGE project operation organogram setting out the key roles and responsibilities is presented in Figure 2.2 below. During operations, the Environmental Engineer will work under the Health, Safety and Environment (HSE) Manager as identified in Figure 2.2 below. The PRO will work under the General Service Manager as identified in Figure 2.2 below.

Figure 2.2: PT PGE Operation Organogram

Source: PGE

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2.3 Capacity Building

2.3.1 Environmental Staff

There is an opportunity for capacity building within PGE to improve the provision of training for the on-site environmental engineer in order to effectively identify and manage environmental issues associated with the construction of Ulubelu Units 3&4. In part, this is due to lack of environmental specialists within the Jakarta head office team available to provide the necessary guidance. PGE has taken steps to introduce new quarterly co-ordination meetings for all of its on-site environmental engineers starting in January 2011 during which training briefings can be facilitated. These quarterly meetings will include all site environmental engineers from PGE’s operational sites and projects (there are currently nine projects in total) with PGE head office environmental specialists briefing the site environmental engineers on the following (but not limited to): Updates in any relevant Indonesian environmental regulation; Updates in any relevant PGE environmental management systems / procedures; Environmental issues arising at other sites for wider dissemination on lessons learnt in order to prevent

repeat occurrences across PGE projects; Guest lectures from external agencies when possible (e.g. KLH).

The success of this quarterly co-ordination programme for on-site environmental engineers and also ongoing monitoring of projects is subject to sufficient environmental specialists being available in the head office. Currently, the head office includes one environmental specialist who is responsible for the implementation of environmental management across all operational sites (three sites as PGE and five sites as joint operation contract or venture) and all projects under development (nine projects in total as of January 2011). For all projects, this one environmental specialist is responsible for ensuring all requirements of RKL/RPL or UKL/UPL are met as well as managing the letting of contracts for the AMDAL and UKL/UPL process associated with new projects. This also involves co-ordination with various government agencies to secure AMDAL or UKL/UPL approval (further taking into account that for any one project, a number of AMDALs or UKL/UPLs may be required to accommodate the overall geothermal project development as is the case for Ulubelu Units 3&4).

In addition, this individual environmental specialist is responsible for the implementation of the PGE environmental management system and oversight of all on-site environmental engineers. With the increase training burden for on-site environmental engineers as identified above, this workload is considered to be far in excess of what the current individual environmental specialist can be expected to perform and it is therefore identified that additional environmental specialists are required in the head office. All projects / on-site environmental engineers would further benefit from a greater frequency of project environmental audits from head office environmental specialists.

PGE currently recognises the shortage in environmental staff in the head office and currently has an environmental manager position identified. In addition to this environmental manager position, PGE also has another vacancy for an environmental specialist to supplement the existing environmental specialist. With these new resources in place, PGE will have sufficient head office resource in order to effectively provide guidance and oversight for the on-site environmental engineer in the implementation of this ESMP.

PGE has further committed to ongoing training of the head office environmental specialists with a mixture of internal and external training courses. External training courses include those run within Indonesia by external agencies such as KLH or EBTKE and also courses specifically in geothermal environmental

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issues run internationally by higher education establishments in countries such as New Zealand and Iceland.

The environmental manager, head office environmental specialist and site environmental engineer posts will be responsible for the range of environmental aspects set out in Sections 4 and 5 of this ESMP.

2.3.2 Social Staff

Similar to environmental staff, there is an opportunity for capacity building within PGE to improve the provision of training for the on-site Public Relations Officer (PRO) in order to effectively identify and manage social issues associated with the construction of Ulubelu Units 3&4. For the Ulubelu Units 3&4 project, there is one PRO employed on-site. In addition, contractors are required to have a Community Liaison Officer (CLO) identified to work in conjunction with the PGE PRO. One PRO per site is sufficient and no further capacity is needed. However, there is a requirement for further training for the on-site PRO as this individual will be responsible in part for the adherence to the Land Acquisition and Resettlement Policy Framework in the event of any future land acquisition required to support the project. In addition, the PRO will be required to assist with the implementation of various commitments included within this ESMP. For example, implementation of the Community Grievance Mechanism, HIV / AIDS awareness programme, malaria awareness programme and the traffic safety sessions for children.

As for environmental staff, there is insufficient capacity in head office for overall co-ordination / support to site based PRO. Much of this requirement falls upon the two public relations and government relations members of staff responsible for all PGE operations and projects with input on consultations from the single environmental specialist. Currently, PGE has one further position identified for recruitment thereby expanding the number of head office public relations and government relations staff from two to three (including one manager). This additional recruitment will alleviate staff shortages in the Head Office and will enable more frequent visits to the Ulubelu Units 3&4 project thereby enabling training of the PRO on-site to be facilitated.

The head office public relations and government relations and the site PRO posts will be involved in the mitigation and enhancement activities set out in Sections 4.2 and 5.2 of this ESMP.

2.4 Contractors’ EHS Management

Although not a requirement, preference will be given to selection of contractors who are ISO 14001:2004 and OHSAS 18001:2007 accredited or have equivalent accreditation. This standard places strong emphasis on the need for continuous improvement of the environment and health and safety management systems and resultant environmental and health and safety management performance. In particular, for the power plant and SAGS, as part of the tender process for the construction phase there will be a requirement that both the EPC contractors, drilling contractors and their respective local partners provide copies of their EHS policy, procedures, an overview of their management system and an example construction EHS management plan for review. In addition the EPC contractors and drilling contractors will be required to include within their proposal for a dedicated EHS professional to be part of the project team based on site full time.

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PGE’s appointed EPC contractors and drilling contractors will be required to agree to the following actions: Implement the requirements of the construction ESMP as defined in this Volume IV below; Provide a construction site layout plan that identifies key activity area including laydown,

accommodation and welfare blocks, parking, etc. prior to commencement of works; Produce detailed method statements relating to key activities that include specific reference to

requirements of the plans contained herein during the project progression; Provide all training necessary to oversee and implement ESMP requirements; Be responsible for producing a comprehensive suite of EHS management and coordination procedures;

and Identify a full time person on site with dedicated EHS responsibilities to oversee works on site.

The EPC contractors and drilling contractors project management organisation will be required to be responsible for sub-contractors’ performance, including ensuring that sub-contractors adhere to the requirements of the construction ESMP.

The PCDP identifies the need for the EPC contractors and drilling contractors to identify someone within their full time team to act as Community / Stakeholder liaison officer (CLO). This person will be the first point of contact between PGE and the EPC contractors / drilling contractors for coordinating the implementation of the PCDP including advance notification of works with the potential to impact on wider stakeholders and the community, and for processing and closing out community grievances.

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3. Plans, Policies and Procedures

3.1 Overview

In parallel to the general ESMP, a number of topic specific documents are required. Prior to each new phase in the development (such as any new wellpad development / additional wells drilling during construction or operation), and prior to commissioning of the plant, PGE will develop a number of plans, policies and procedures to ensure adequate management and monitoring of social and environmental aspects. Table 3.1 below summarises key policies required. Given the current start of activities at Clusters G and H, timescales for policies relevant to drilling and construction activities have been set as immediate. PGE’s current management system already covers a number of the policies identified below.

Table 3.1 also makes reference to the requirements to implement or produce a number of management plans. It is intended that these framework plans will be elaborated by PGE to complement its existing Environmental, Health and Safety Management System specifically for the Project. Where relevant and under respective contracts, drilling contractors and the EPC contractor (power plant and SAGS) should be required to implement corresponding arrangements (as directed within the ESMP). As a minimum, the following is likely to be required: H2S monitoring programme; Health data collection programme; H2S emergency response plan; Recruitment plan; Retrenchment plan; Waste management plan; Traffic management plan; Temporary worker accommodation management plan; and Chance finds procedure.

Frameworks for these plans are provided within this Volume.

3.2 Identification of Indonesian Geothermal Environment Forum

During the course of elaborating this international quality ESIA, PGE has identified a number of requirements for internal capacity building (see Section 2.3 above) as well as the need for various monitoring government agencies to be more familiar with key issues to be addressed by the geothermal industry as a whole. Although the requirement for government agency capacity building has been identified, it is beyond PGE’s remit as a private company to be responsible for training government agencies that have an institutional responsibility for monitoring PGE’s project development activities. Furthermore, the identification of need for institutional agency capacity building should be done in agreement with the overall Indonesia geothermal industry, not PGE operating in isolation as part of a project specific ESMP. Such a collective endeavour will ensure that any agency capacity building is aimed at serving the requirements of the Indonesian geothermal industry as a whole to be benefit of all industry stakeholders.

In order to further a collective endeavour, PGE is committed to the formation of an industry-wide geothermal environment forum with invitations extended to all existing operators within Indonesia. Interest has also been registered by other geothermal operators. A regular Indonesian geothermal environment forum meeting represents an opportunity for environmental issues facing the geothermal industry as a whole to be discussed, agreed and presented as a collective for discussion with government stakeholders (notably the Ministry of Environment). Such an approach will enable the geothermal industry as a whole to

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identify potential barriers to geothermal development as well as raising awareness of important responsibilities for the geothermal industry to be cognisant of (such as robust assessment of potentially harmful emissions to local communities and more regular identification of precautionary abatement to address such emissions). A geothermal environment forum can propose and agree with the government a potentially more streamlined environmental management process for operations where a potential re-designed RKL/RPL process can be configured bespoke to the geothermal industry allowing more focus on issues that are considered of greatest / most importance.

In order to provide impetus for the geothermal forum formation, for its effective operation, and for securing necessary support from all member geothermal operators, Mott MacDonald recommends that PGE represents to the Indonesian government the need for an initial grant mechanism request to be made to, for example, an international donor agency. This could be administered via the Ministry of Environment and / or technical department New Energy, Renewable and Energy Conservation - EBTKE (under the Ministry of Energy and Mineral Resources). An initial estimate of meaningful start-up budget for the forum is $300,000 with an annual budget thereafter of $100,000. As a suggestion, the start-up budget would be aimed at external support engagement to independently elaborate objectives for the geothermal environment forum (collating objective aims from all respective operators), an external chair for an inauguration workshop event drawing on a range of national and international contributors. The event organiser would be responsible for collating the findings of the forum together with identification of priority issues to be taken forward in future forum workshops with an eventual aim of presenting an industry consensus to relevant government agencies.

It is hoped that through the formation of an Indonesian geothermal forum, the industry as a whole can build capacity which can thereafter be communicated through to relevant government agencies.


Table 3.1: Plans, Policies and Procedures

Aspect Plan / Policy Objective / Content Timescale PGE Department Responsibility

Institutional Monitoring Responsibility

Recruitment Recruitment policy

(See Section 9.2)

Retrenchment plan

(See Section 9.3)

Equity in local employment benefits / minimise social conflict. Prohibit the use of child and forced labour / promote non-discrimination and equal opportunities. Refer to:

IFC PS2 – Labour and Working Conditions and ILO Fundamental Human Rights Conventions: Elimination of Forced and Compulsory Labour (Conventions 29/105) – ratified 1950/1999;

Elimination of Discrimination in Respect of Employment and Occupation (Conventions 100/111) – ratified 1958/1999;

Abolition of Child Labour (Conventions 138/182) – ratified 1999/2000; ILO Core Labour Standard

Law No. 13 year 2003 regarding Manpower

Immediately. Policy to be disclosed.

Overall responsibility of recruitment policy / retrenchment policy with Head Office Human Resources.

Project Manager (construction) / General Manager (operation) responsible for implementation at project / operation level.

Labour Agency at Regency Government Level

Community Complaints

Community Grievance mechanism

(See Volume II, Section 6.9)

Formalised process by which grievances can be raised by the local community during construction and operation and to allow structured investigation by PGE to review the validity, responsibility and response / action.


Overall responsibility of community grievance mechanism with Corporate Secretary

Project Manager (construction) / General Manager (operation) / PRO responsible for implementation at project / operation level.

Communication Agency at Regency Government Level

Labour Complaints

Labour Grievance mechanism

(See Section 9.4)

Formalised process by which grievances can be raised by the workforce during construction and operation and to allow structured investigation by PGE to review the validity, responsibility and response / action.


Overall responsibility of labour grievance mechanism with Head Office Human Resources.


Labour Agency at Regency Government Level

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Aspect Plan / Policy Objective / Content Timescale PGE Department Institutional Monitoring Responsibility

Responsibility

Occupational Health and Safety

OHS management plan

(Existing PGE SMK3LL)

Safe working environment, procedures and culture. Further policies / procedures to be developed on top of SMK3LL if need identified through site audits

IFC PS2 – Labour and Working Conditions

World Bank Group General EHS Guidelines / Geothermal Power Generation EHS Guidelines on Occupational Health and Safety (OHS)

Ministry of Manpower Letter No. SE-01/MEN/1997 regarding Ambient Threshold Limit of Chemical Factor in Working Environment

As needed Overall responsibility of OHS management plan with Head Office QHSE.


Directorate General of New Renewable Energy and Energy Conservation (EBTKE) (under Ministry of Energy and Mineral Resources)

H2S Emergency

H2S Emergency response plan

(see Section 8)

See Section 8.

IFC PS4 – Community Health, Safety and Security

World Bank Group General EHS Guidelines / Geothermal Power Generation EHS Guidelines on Community Health and Safety (CHS)

Immediately for the construction phase plans. Prior to commissioning for the operation phase plans.

Overall responsibility of H2S Emergency Response plan with Head Office QHSE.


BLH at Regency Government level

Chemicals and fuels. Spent oils and lubricants.

Management procedures.

Spill response plan

(Existing PGE SMK3LL / requirements of RKL / RPL)

Appropriate storage, transfer and use of chemicals and fuel on site.

Identify responsibilities and equipment required to deal with a spill.

Immediately. Procedures to be communicated to contractors.

Prior to commissioning for operations related procedures

Overall responsibility of spill response plan with Head Office QHSE.


Implementation and effectiveness to be reported to BLH through the RKL/RPL process

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Aspect Plan / Policy Objective / Content Timescale PGE Department Institutional Monitoring Responsibility

Responsibility

Groundwater quality

Investigation and remediation strategy

Action plan to assess any reduction in groundwater quality in the villages and measures to be implemented, including stopping the source if identified and providing alternative water sources.

Immediately – formalising current practices

Before commissioning for operation phase procedures.

Overall responsibility of groundwater investigation and remediation with Head Office QHSE.


BLH at Regency Government level; Ministry of Environment

Waste Waste Management Plan

(see Section 9.5)

See Section 9.5.

Identify measures for minimisation of waste and safe disposal of construction wastes

Immediately. WMP to be developed by / communicated to contractors.

Overall responsibility of waste management plan with Head Office QHSE.



Drilling muds and cuttings

Management procedures.

Spill response plan

(Existing PGE SMK3LL / requirements of RKL / RPL)

Appropriate storage, handling, testing, transport and reuse of drilling mud or cuttings on site or disposal.

Identify responsibilities and equipment required to deal with a spill

Immediately. Procedures to be communicated to contractors

Overall responsibility of spill response plan with Head Office QHSE.



Transport Traffic Management Plan

(see Section 9.6)

See Section 9.6 Prior to main mobilisation / demobilisation periods. Plan to be developed with / by contractors.


Regency Government and local police

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Aspect Plan / Policy Objective / Content Timescale PGE Department Responsibility

Institutional Monitoring Responsibility

Archaeology Chance finds procedure (see Section 9.8)

See Section 9.8. In particular, the procedure should include:

Definition of cultural resources / archaeological features

Ownership of the artefact

Recognition

Procedure upon discovery:

Conditions and requirements for work stoppage

Fencing and protection of the find

Internal reporting

Expert analysis

Instructions for moveable finds

Immediately. Procedures to be communicated to contractors / requirement within contractors contracts.

Overall responsibility of chance finds procedure with Head Office QHSE.

Project Manager (construction) responsible for implementation at project level.

Notification to the Preservation of Archaeological Heritage Office (Balai Pelestarian Peninggalan Purbakala) and Archaeology Office (Balai Arkeologi).


Brine / condensate

Brine management plan

Minimise and control brine discharges during well production tests or in case of a reinjection failure during operation. Plan to involve secondary containment and procedure to reroute the brine / condensate, brine treatment (heat, pH etc.) prior to discharge if required, community warning

Available before commissioning and during operational life of project

Overall responsibility of brine management plan with Vice President of Management Operations and Utilities.


Directorate General of New Renewable Energy and Energy Conservation (EBTKE) (under Ministry of Energy and Mineral Resources);



4. Construction ESMP

4.1 Overview

The construction ESMP is summarised in the following tables. These include measures to be transposed into each contractor’s ESMP (EPC contractors for power plant and SAGS and drilling contractors) or work procedures. Reference is also made to the above plans and procedures for PGE to work with its contractors to ensure adequate implementation. PGE will review and approve the EPC Contractors and drilling contractors respective HSE Plans to ensure continuity with PGE HSE requirements (including commitment to this ESMP).

All mitigation measures and monitoring requirements applicable to wells drilling during Project development should also be applied for make up wells drilling during operation and maintenance. The ESMP shall be updated (in particular roles and responsibilities) and relevant requirements should be included as part of each new drilling contract.

The following sub-sections address individual project construction activities identifying specific mitigation and monitoring measures associated with environmental and social aspects where relevant and as required.

Table 4.1 sets out the structure of the construction ESMP as presented over the following sub-sections.

Table 4.1: Construction ESMP Structure

Sub-Section Discipline / Media

4.2 Social Management

4.3 Hydrology Management

4.4 Groundwater Management

4.5 Noise Management

4.6 Ecology Management

4.7 Air Quality Management

4.8 Climate Change

4.9 Waste Management

4.10 Geology and Erosion Management

4.11 Land Contamination Management

4.12 Transport Management

4.13 Archaeology and Cultural Heritage Management

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4.2 Social Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Equity in local employment benefits / minimise social conflict

Employment generation

PGE Recruitment Policy (see Section 9.2) to specifically include requirement to prioritise local employment taking into account available skills. Requirement to also be reflected in contractor’s employment policy.

(refer to Section 9.2) (refer to Section 9.2)

Ongoing implementation

Disclosed Recruitment Policy in Site Office and Kepala Desa offices of local villages.

Village committee meeting minutes.

Included in normal human resources and site management budget.

Local skills development


Local employment to be prioritised, contractor to provide additional specialised training to local workforce in skills required by contractor (i.e. administrator, driving etc).

World Bank Operational Policy 4.01 Environmental Assessment

PGE Project Manager

EPC contractor


Addition of local skills development requirement of EPC Contractor contract.

Records of specialised training for local staff provided by EPC Contractor to PGE. PGE to monitor EPC Contractors and ensure that they are providing local skills development.

Certificates from EPC Contractor issued to employees (copied to PGE) detailing training received / new skills acquired while employed.

PGE monitoring to be included in site management budget.

Contractor local skills development to be included in costs of EPC contracts.

Labour Grievance Mechanism

Labour management

Development, formalisation and disclosure of staff grievance polices and mechanisms for complaints about unfair treatment or unsafe living or working conditions without reprisal. (see Section 9.4)


(see Section 9.4)

PGE Human Resources

EPC contractors and drilling contractors

(see Section 9.4)


Documented grievance mechanism established.

Maintenance of complaints log and resolution process.

Included in normal human resources and site management budget.

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Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Protecting the workforce

Labour management

Include clauses for contractors in line with PGE’s labour management procedures and welfare safeguard measures (as embodied within the existing PGE SMK3LL).

Law No. 1 of 1970 regarding Work Safety;

Law No. 23 of 1992 regarding Health;

IFC PS2 – Labour and Working Conditions, terms of employment to be in line with ILO standards.

Ministry of Manpower Letter No. SE-01/MEN/1997 regarding Ambient Threshold Limit of Chemical Factor in Working Environment.

PGE Project Manager / Human Resources


Apply to all new EPC / drilling contracts.

PGE to review and approve Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP).

Included in normal human resources and Site management budget.

Identify and Remove Occupational Health and Safety hazards

Labour management

Occupational Health and Safety (OHS) assessment / schedule of audits.



IFC PS2 – Labour and Working Conditions;

World Bank Group EHS General Guidelines on Occupational Health and Safety (OHS) / Geothermal sector specific guidelines.

Ministry of Manpower Letter No. SE-01/MEN/1997 regarding Ambient Threshold Limit of Chemical Factor in Working Environment.

PGE Project Manager / OHS Engineer

Daily inspections (observations of non-compliance will be reported only), annual OHS audit or at least two audits during contract scope.

As part of CSMS (Contractor Safety Management System) Audit Program

OHS audit reports, corrective measures and action plan, photographs demonstrating corrective measures implemented.

Accident statistics reported as part of OHS performance records.

Included in routine PGE site management expenses.

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Maintain the well-being of workers living in camps

Labour management

PGE audit of contractors workers camps to determine need for upgrade / improvement.


Workers’ accommodation: processes and standards - A guidance note by IFC and the EBRD

PGE Project Manager


Once every two months or upon receipt of worker complaints via the Labour Grievance Mechanism.

Worker camp audit reports, corrective measures and action plan, photographs demonstrating corrective measures implemented.


Any upgrade or improvement required would be at Contractors cost.

Inform workers of HIV/AIDs risks and protection to minimise risk of infection to workers and communities

Labour management

Provision of HIV / AIDS awareness and prevention briefings.


HIV/AIDS in the Workplace, IFC Good Practice Note, December 2002, Number 2

WHO Guidelines

PGE OHS Engineer


Brochure raising HIV/AIDS awareness to be issued to all new members of staff as part of employment induction.

Members of staff to receive brochure which raises HIV/AIDS awareness.

Staff to sign acknowledging receipt of brochure.

PGE production of HIV awareness brochures estimated at $1,500.

Distribution of HIV awareness brochures to be included within Contractors scope.

Inform workers of malaria risks and implement protection measures to prevent infection

Labour management

Awareness and prevention briefings (e.g. through brochure).

Provision of mosquito nets, regular fumigation of campsite, anti malarial where necessary.

Maintain campsite free of stagnant pools (use of larvicides if necessary / appropriate).


PGE OHS Engineer


Brochure raising malaria awareness to be issued to all new members of staff as part of employment induction.

Ongoing for mosquito management measures.

Members of staff to receive brochure which raises malaria awareness and preventative measures.


Contractor requirement to implement measures to prevent spread of malaria.

PGE production of malarial prevention brochures estimated at $1,500.

Distribution of Malarial prevention brochures to be included within Contractors scope.

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Community Grievance Mechanism

Safeguarding community health, safety and security

Develop formally documented grievance mechanism and resolution process. See Section 6.9 of ESIA Volume II.


PGE PRO

Contractors CLO

Refer to Section 6.9 of ESIA Volume II

Ongoing Documented grievance mechanism established.


Included in normal human resources management budget.

Restrict access to sites, especially hazardous areas


Appropriate fencing / signage around site perimeter and where necessary, certain key site installations during periods when construction activity is low such as completed wellhead Christmas trees / drilling mud ponds.

Appoint site security personnel (appropriately vetted and trained as per the requirements of the EPC / steamfield contractors Terms of Reference)


World Bank Group EHS General Guidelines on Community Health and Safety (CHS)

PGE Project Manager to request from contractor

PGE Procurement



Provision / review of the following documentation:

Description / photographs of fencing / signage around site perimeter.

EPC / drilling contractors to provide PGE with CV and training certification of security personnel proposed as per contract requirements.

Site registry identification system.

Fencing of existing clusters not yet fenced: PGE estimated cost of $90,000 per cluster (includes perimeter fencing, pond fencing in wood and wellhead fencing).

New clusters – cost of fencing to be included in infrastructure contractor scope.

Security measures to be included within Contractors scope.

Preparation in the event of an H2S emergency


Require contractors to apply / integrate PGE’s H2S Emergency Response Plan. See Section 8.


Refer to Section 8.

H2S Emergency Response Plan applicable throughout construction.

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP).

Annual H2S Emergency Response Plan Drill to be undertaken with subsequent feedback documentation.


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Minimise traffic hazards within community


Road safety plans / maximum speed limits for site and access routes. Implement Traffic Management Plan (refer to Section 9.6).

Contractor programme to monitor and enforce safety plans, accident reporting and statistics, establish penalties for violations.



PGE Project Manager, PGE OHS Engineer



Road Safety Plan documentation including identification of maximum speed limits for site and access routes. To be defined under PGE HSE requirements. PGE to review and approve Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP and implementation of Traffic Management Plan - refer to Section 9.6).

Requirement for contractor programme of monitoring

Reporting of accidents and statistics as part of OHS performance records.


Contractor to develop and implement safety plans as part of their scope.

Maintain roads to reduce congestion / erosion


Maintenance of site and access roads under PGE responsibility to reduce erosion / degradation of drainage channels.



PGE Project Manager

Duty to be included in EPC contractors’ scope.

When brought to attention by stakeholders.

Record of maintenance measures


Improve road safety


Traffic safety sessions for children including distribution of safety awareness brochures.



PGE Project Manager / PRO

Annual traffic safety session for children in all schools along road to site from Karang Rejo village.

Document traffic safety sessions and maintain session schedule.

Maintain attendance register.

Time included in routine PGE site management expenses.

PGE production of supporting brochures estimated at $800 per year.

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Reducing malaria incidence


Maintain good construction site drainage, minimize standing water, and manage ponds to control mosquitoes through use of larvicides if appropriate.


WHO Guidelines

PGE Project Manager / OHS Engineer


Ongoing General site housekeeping audits

Record of general site housekeeping / maintenance activities.


Malarial prevention measures to be included within Contractors scope.

Safeguard the well-being and improve the living standards of those whose land is acquired, avoid involuntary resettlement (last resort)

Land acquisition for non-forest area

Continue using current willing buyer / willing seller practices. Only pursue expropriation as a last resort and follow Land Acquisition and Resettlement Policy Framework included in ESIA Volume III.

Refer to Land Acquisition and Resettlement Policy Framework (ESIA Volume III) which includes identification of Indonesian Land Law (including expropiation)

PGE Project Manager / PRO / land acquisition team

Ongoing throughout construction

Following documentation:

-Initial site description and land acquisition plan;

-Schedule of survey, socialisation activities and inventory;

-Land acquisition report - submitted for corporate agreement;

-Minutes of negotiation;

-Summary compensation data (land and other assets);

-Payment date;

-Date of transfer of revised certificates to owners; and

In cases where expropriation is followed as a last resort, preparation of a Land Acquisition Plan acceptable to the Bank, as specified in the Policy Framework before proceeding.

Included in normal project management budget.

PGE socialization to describe land acquisition procedures and grievance mechanisms for all people involved in land acquisition negotiations – included in normal project management budget.

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4.3 Hydrology Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Protection of surface water supply quantity for local users and the environment

River abstraction for drilling activities

Prior to any new river abstractions, identify any local users downstream as far as Karang Rejo.

Choose abstraction flow rate and timing to minimise impacts on water course and to ensure minimal stream flow maintained.

Where this cannot be achieved, before drilling construction, PGE to construct new water supply pipeline from alternative source to ensure community water supply unaffected.

World Bank Group EHS General Guidelines on Community Health and Safety / Geothermal sector specific guidelines.

PGE PRO / Project Manager / Environmental Engineer


Monitoring throughout Construction

Contractor to record quantity of water abstracted and timing of abstractions.

PGE to review Contractors abstraction records.

PGE to undertake river flow measurements before, during and after abstraction periods.

No complaints from downstream users (as recorded under Community Perception in RKL / RPL).

PGE review included in normal project management budget.

Contractor monitoring measures to be included within Contractors scope.

PGE to purchase a water current meter for use in flow measurements. Estimated cost - $250 one-off. Training for PGE environmental engineer on how to take river flow measurements estimated cost - $1,000 one-off.

Potential additional costs in event of alternative water supply – approximately $5,000 per water supply.

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Protection of surface water quality for local users and the environment

Vegetation clearance, earth moving

Use good construction practices to prevent erosion and sediment reaching water courses, including:

Bunding off the working area to avoid any sediment from the workings entering local water courses;

Minimising vegetation clearance; and

If any temporary or permanent diversion of water courses or natural flow paths ensure that diversion works are of adequate capacity.

Government Regulation No. 82 of 2001 regarding the Management of Water Quality and Water Pollution Control.

PGE Project Manager, Environmental Engineer


Mitigation throughout Construction.

Monitoring on quarterly basis (as per RKL / RPL).

Collection of surface water samples and analysis by accredited laboratory (as per monitoring locations in Figure 4.1 which are in addition to current RKL / RPL monitoring).

No deterioration in pre-project river water quality.

Mitigation included in routine PGE site management expenses.

Estimated cost for water quality monitoring $1,500 per quarter over and above current RKL / RPL budget for monitoring implementation.

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Pollution of surface water from drilling muds or water from testing wells

Use of water based drilling muds as opposed to oil-based drilling muds.

Recycling of drilling muds.

Design adequate capacity of treatment ponds / water filters to safely manage quantities of waste water arising.

Storage ponds to have impermeable lining such as HDPE or similar geomembrane of appropriate thickness bonded together to ensure water-tightness. Regularly checked for rips and tears.

Ponds monitored and cleared of silt periodically to maintain integrity of treatment and drainage system.


World Bank Group EHS General Guidelines on Wastewater and Ambient Water Quality / Geothermal sector specific guidelines.


Drilling contractors

Mitigation throughout construction. Monitoring on quarterly basis (as per RKL / RPL requirements)

Requirement for contractors to implement mitigation as part of drilling contracts.

Collection of surface water samples and analysis by accredited laboratory (as per monitoring locations in Figure 4.1 which are in addition to current RKL / RPL monitoring).

No incidents of discharge of incompletely treated effluent.

Regular review by on-site environmental engineer. Quarterly on-site audit by head office staff.

Mitigation installation included within current infrastructure construction contract scope.

Maintenance of ponds and site drainage system by PGE estimated at $15,000 per year per cluster.

Estimated cost for water quality monitoring $1,500 per quarter over and above current RKL / RPL budget for monitoring implementation.

Regular review included in routine PGE site management expenses.

Increased audit frequency from head office (quarterly) estimated $4,000 expenses per year.

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Well blow out / overflow of settling ponds

Drains from wells to route effluent fluids to settling ponds. In case of an overflow, PGE to determine whether downstream users affected and if required construct new water supply pipeline from alternative source to ensure community water supply unaffected.


World Bank Group EHS General Guidelines on Wastewater and Ambient Water Quality / Geothermal sector specific guidelines.

PGE site manager / PRO / OHS Engineer / Environmental Engineer


Mitigation throughout construction.

Monitoring following well blow out / overflow events.

Collection of surface water samples and analysis by accredited laboratory (in the event of overflow). Monitoring locations dependent upon area of overflow using professional judgement with typical sampling points including representative upstream location, immediate downstream location from overflow, prior to nearest downstream community and after confluence with other tributaries.

Mitigation included in routine PGE site management expenses.

Estimated cost for water quality monitoring $1,500 per overflow event.


To protect water courses from contamination from fuel or chemical spills

Storage, transportation and use of chemical and fuel on development site

Development of relevant procedures to avoid and minimise risk of spills, including but not limited to the following.

All chemicals and fuels are to be stored in designated sites with impermeable surface and adequate bunding to prevent accidental contamination.

Storage areas to be located away from surface waters.

Suitable spill kits to be provided within storage areas and near any fuelling / loading areas.

Goverment Regulation No 74 of 2001 regarding Hazardous and Toxic Material Management


World Bank Group EHS General Guidelines on Wastewater and Ambient Water Quality; Hazardous Materials Management / Geothermal sector specific guidelines.

PGE Project Manager / Environmental Engineer



Daily inspections by PGE of Contractor (observations of non-compliance will be reported only); At least two formal audits of Contractor by PGE during contract scope.

As part of CSMS (Contractor Safety Management System) Audit Program.

Requirement for contractors to implement mitigation as part of EPC / drilling contracts.

No spills affecting surface water quality.

PGE to audit Contractor storage areas against mitigation requirements, for example, check availability of spill kits, adequate bunded storage for chemicals and fuels.

Mitigation (excluding spill kits) included within current construction contract scope. Future EPC / drilling contract scope to include spill kits as well (estimated cost of $5,000 for two wheeled locker spill kits per cluster location).

Monitoring included in routine PGE site management expenses.

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4.4 Groundwater Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

To protect groundwater from contamination from fuel or chemical spills


Development of relevant procedures to avoid and minimise risk of spills, including but not limited to the following:

All chemicals and fuels are to be stored in designated sites with impermeable surface and adequate bunding to prevent accidental contamination.

Suitable spill kits to be provided within storage areas and near any fuelling / loading areas.

Goverment Regulation No 74 of 2001 regarding Hazardous and Toxic Material Management.





Daily inspections by PGE of Contractor (observations of non-compliance will be reported only); At least two formal audits of Contractor by PGE during contract scope.



PGE to audit Contractor storage areas against mitigation requirements, for example, check availability of spill kits, adequate bunded storage for chemicals and fuels.

Mitigation (excluding spill kits) included within current drilling contract scope. Future EPC / drilling contract scope to include spill kits as well (estimated cost of $5,000 for two wheeled locker spill kits per cluster location).

Monitoring included in routine PGE site management expenses

To protect groundwater resource during land clearance and excavation

Vegetation clearance and land levelling

Provide baseline of current springs to ensure any potential new springs created by excavation can be identified as such.

Provide baseline of current community water supply wells. If community groundwater wells affected either deepen affected wells or if required construct new water supply pipeline from alternative source to ensure community water supply unaffected.

Decree of. Minister of Health Regulation No. 416 of 1990 regarding Requirements for Monitoring of Water Quality




Survey / monitoring for springs to be undertaken ahead of site activities.

Survey / monitoring for community wells to be undertaken on quarterly basis (as per RKL / RPL requirements).

Site walkover, identification of spring locations and flow rate (using a simple weir or bucket measurement). Site walkover, identification of representative community well locations and water depth (using a dip meter or plumb line). To be undertaken in area surrounding construction site (up to 1km radius depending on location of known springs / community wells). Collection of community water well sample from representative well and analysis by accredited laboratory (as per RKL / RPL requirements).

$1,500 per year for site walkover and measurements of springs and representative community wells over and above current RKL / RPL budget for monitoring implementation.


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To project groundwater from cross contamination

Drilling of new wells

Well designs to employ deep set surface casing to prevent blow outs (the uncontrolled discharge of deep aquifer water/steam into the upper aquifer or to the surface).

World Bank Group EHS Geothermal sector specific guidelines.

PGE project manager / drilling manager / drilling engineer



Daily inspections by PGE of Contractor (observations of non-compliance will be reported only).

Requirement for contractors to implement mitigation as part of drilling contracts.

PGE undertake daily inspection of Contractor drilling activities against well design.

Drilling contractors to include deep set surface casing as part of their scope.


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4.5 Noise Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Avoid noise nuisance generated by on-site plant and activities

Site preparation excavation and foundations, construction and drilling

Position noise generating plant as far from the edge of the site as possible.

Construction machinery and vehicles that may be in intermittent use to be shut down between work periods.

Material stockpiles and other structures effectively utilised, where practicable, to screen sensitive receptors from noise from on-site construction activities.

Construction machinery with directional noise features positioned to minimise the potential for noise disturbance.

Hours of general construction activity (excluding specific drilling activities) restricted to avoid sensitive periods of the day (e.g. religious event) and also to avoid night working typically following World Bank night-time noise guidelines (22:00 to 07:00).

If construction activities cause breaches of Indonesian and World Bank standards as identified through monitoring, noise barriers of no less than 10kg/m2 surface density should be put in place at properties (ensuring that the noise source is entirely hidden from the receptor).

Minister of the Environment Decree No. 48 of 1996 regarding Noise Standard.

World Bank Group EHS General Guidelines on Noise Management



Mitigation to be included as requirement of all new EPC / drilling contracts.

Monitoring frequency: weekly or upon receipt of noise complaints via community grievance mechanism.


PGE to monitor noise levels using sound level meter at the nearest residential properties to construction activities for comparison against standards.

Record and investigate complaints using sound level meter via the community grievance mechanism.

Contractor to include noise mitigation measures as part of their scope.

Contractor to include option within their scope for suitable quality sound attenuation barriers as directed by PGE Invitation To Tender.

PGE purchase of sound level meter – one off cost of approximately $5000.

Ongoing sound level meter calibration approximately $350 per year.

One off external training course for Environmental Engineer for sound level meter approximately $1000.

If additional noise barrier is required following noise monitoring, estimated PGE cost at $400 per square metre (excluding contractors’ scope).

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Avoid noise nuisance generated by on-site plant and activities

Well production tests.

Local community to be notified in advance of noisy activities e.g. horizontal well production tests.

Avoid well column clearing / vertical well testing.

Use of rock muffler to mitigate noise emissions during horizontal well production testing.

Minister of the Environment Decree No. 48 of 1996 regarding Noise Standard. Decree of Mining and Energy No 02.P/20/M/PE/1990 regarding exploration and exploitation of safety work on geothermal resources


PGE Project Manager / PRO / operational department

Notification ahead of noisy activities.


Notification of local community following procedures in PCDP.


PGE undertake daily internal inspection of well production tests.

Monitoring and horizontal well testing included in routine PGE site management expenses.

Avoid noise nuisance generated by construction traffic

Construction vehicles and traffic

Schedule regular road traffic movements to avoid noise sensitive periods (e.g. avoid night-time traffic movements for normal loads).

Use of modern (less than 5 years old) vehicle / construction fleet equipped with exhaust silencers.





All new EPC / drilling contracts


Contractor to include noise mitigation measures as part of their scope.

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4.6 Ecology Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost

Minimise incidental ecological mortality

Vegetation clearance, earthworks, and spoil disposal during construction.

In the event of additional cluster / site development, pre-clearance surveys for endangered species and breeding birds, burrowing mammals, reptiles and amphibians.

Law No. 5 of 1990 regarding Conservation of Natural Resources and Ecosystems

Law No. 41 of 1999 regarding Forestry.

PGE Environmental Engineer.

Local Environmental (AMDAL) Consultant

Surveys undertaken on six monthly basis throughout construction

Ecological survey requirements as per RKL/RPL except extended to include potential additional clusters.

Monitoring estimated at $1,500 per year for each additional cluster.

Control of non-native plant species

Vegetation clearance, earthworks, and spoil disposal during construction.

Use of native species as part of any re-vegetation programme during construction.

Identification of non-native plant species and their extent within development boundary: Treatment of materials contaminated by invasive plant material e.g. seeds, roots etc.

Where necessary based on above findings, development of non-native species management plan.



PGE Environmental Engineer

Local Environmental (AMDAL) Consultant

Surveys undertaken on six monthly basis throughout construction

Ecological survey requirements as per RKL/RPL.

Implementation of non-native species plan where necessary.


Development and implementation of non-native species management plan estimated at $1,500 per year if required.

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Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost

Minimise risk of illegal hunting in forestry areas

Introduction of Construction staff to area

Prohibit hunting, cultivation and deforestation by PGE and contractor staff members.

Contractor to instruct all personnel with regards to the prohibition and clearly advise of disciplinary action associated with non compliance.





Brochure to be issued to all new members of staff as part of employment induction.

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan including disciplinary action measures to ensure continuity with PGE HSE requirements (including commitment to this ESMP).

Members of staff to receive brochure which identifies prohibition of hunting and deforestation.


Contractor requirement to implement measures to prevent hunting.


Hunting prevention measures to be included within Contractors scope through acceptance of PGE HSE requirements.

PGE production of hunting and deforestation prohibition brochures estimated at $1,500 one-off cost.

Protection of watershed protection forest

Drilling and plant construction activities

Strict prohibition of contractors to undertake any construction activities within 500m of the watershed protection forest boundary or outside defined Project boundaries.

The prescribed construction boundary limit shall be clearly demarcated.

PGE to implement disciplinary action for non compliance.



PGE project manager / Environmental Engineer


Throughout Construction.

Disciplinary action for violation to be specified in all new EPC / drilling contracts.

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan including disciplinary action measures to ensure continuity with PGE HSE requirements (including commitment to this ESMP).

PGE Environmental Engineer to inspect construction areas on monthly basis.

Maintenance of record of violations where observed and disciplinary action imposed on contractor.

Mitigation to be included within EPC and drilling contractors scope.


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Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost

Minimise impacts on aquatic flora and fauna

Construction and operation of weirs for abstraction.

Weirs built to facilitate water abstraction at the WPS should be opened regularly where possible to minimise impacts on aquatic ecology.

Government Regulation No. 35 of 1991 regarding Rivers.

Presidential Decree No. 32 of 1990 regarding Management of Protected Areas.

Regulation of Minister of Public Work No. 63 of 1993 regarding Line Border Rivers, Regional Benefits River, River Region and Former River courses.

PGE Environmental Engineer


Throughout Construction and upon completion of construction activities.

Contractor to record quantity of water abstracted and timing of abstractions.

PGE to review Contractors abstraction records.


PGE review included in normal project management budget.

Contractor monitoring measures to be included within Contractors scope.

PGE to purchase a water current meter for use in flow measurements. Estimated cost - $250 one-off. Training for PGE environmental engineer on how to take river flow measurements estimated cost - $1,000.

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4.7 Air Quality Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Drilling, land clearing and construction

Locate activities and rock / earth stockpiles away from receptors (in particular at Clusters B and F).

Cover vehicles loads and stockpiles.

Minimise amounts of material and avoid double handling.

Hard-standing in high activity areas and water spraying

Minimise dust nuisance

Traffic and vehicle movements

Contractor to implement and develop framework Transport Management Plan provided in Section 9.6.

Water spraying if required.

Government Regulation No. 41 of 1999 regarding Air Pollution Control

World Bank Group EHS General Guidelines on Air Emissions and Ambient Air Quality



Layout to be agreed 4 weeks before start of works

Mitigation ongoing Throughout Construction.

PGE bi-weekly visual inspections (violations to be reported only).

Quarterly monitoring of TSPs.

PGE Environmental Engineer to undertake bi-weekly visual checks of construction areas.

Maintenance of record of violations where observed and disciplinary action imposed on contractor.

Quarterly monitoring of TSP as per RKL / RPL requirements.

Mitigation to be included within Contractors scope.


Minimise construction machinery / vehicle emissions

Construction traffic and machinery

Use of modern (less than 5 years old) vehicle / construction fleet to minimise emissions. Regular servicing of machinery.

Locate generators away from receptors (workers’ camps and residents)

Government Regulation No. 41 of 1999 regarding Air Pollution Control

World Bank Group EHS General Guidelines on Air Emissions and Ambient Air Quality


EPC Contractor and drilling contractors

Layout to be agreed 4 weeks before start of works


PGE Environmental Engineer to undertake bi-weekly visual checks of construction vehicles. (violation to be report only)

Contractor to maintain servicing records for all machinery.

PGE to review Contractors servicing records at beginning of contract and thereafter on 6 months basis for longer term contracts lasting more than 6 months.

Mitigation to be included within Contractors scope.


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Ensure safety of workers and community

Drilling Employ H2S safety contractor. Review and implement their H2S safety procedures.

Employ H2S emergency response plan when necessary (see Section 8).

Minister of Manpower Letter No. SE-01/MEN/1997 Ambient Threshold Limit of Chemical Factor in Working Environment

World Bank Group EHS General Guidelines on Air Emissions and Ambient Air Quality / Geothermal Power Generation.

PGE Project Manager / Safety Enginer

H2S safety and monitoring contractor


Monitoring for worker exposure – ongoing throughout construction.

Monitoring for community exposure – refer to Section 6.

Monitor site concentrations of H2S for worker health and safety as per safety monitoring requirements under drilling contracts.

Monitor ambient concentrations of H2S for community exposure (refer to Section 6).

Refer to Section 6.

Minimise nuisance and pollution from well tests

Well production tests

Avoid vertical well column cleaning / vertical well testing.

Use of rock muffler to elevate emission source.

Decree of Mining and Energy No 02.P/20/M/PE/1990 regarding exploration and exploitation of safety work on geothermal resources

World Bank Group EHS Guidelines for Geothermal Power Generation.

PGE Project Manager / Operation and Production Engineer / Environmental Engineer

Throughout well production tests.

PGE to conduct horizontal well tests only.

PGE to employ mitigation during well production tests.

PGE undertake daily internal inspection of well production tests.

Monitoring and horizontal well testing included in routine PGE site management expenses.

4.8 Climate Change Management (Construction)

No mitigation / monitoring specific to climate change management required as part of construction.

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4.9 Waste Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Minimisation and safe disposal of waste.

Minimisation and safe disposal of waste.

Waste generated as a result of day to day drilling and construction activities

Implement Waste Management Plan (WMP) which identifies measures for minimisation of waste and safe disposal of construction wastes (refer to Section 9.5).

Appropriate facilities/containers for segregation and temporary storage of general wastes on site and establishment of regular disposal to licensed third party landfill or recycling where possible.

Use of water based drill muds and recycling of drill muds. Storage of muds in lined ponds and of cuttings in dedicated houses. Regular removal of muds from the settling ponds for re-injection into total loss wells where available or storage and subsequent treatment of the muds as relevant waste category as determined by Indonesia regulation;

Disposal of hazardous waste by third party licensed by MOE. Segregation of waste streams for reusing and recycling. Identify reuse and recycle options of non hazardous waste with local community; Identification of appropriate site(s) for excavation material disposal, away from sensitive surface / ground water features.

Government Regulation No. 18 of 1999 as amended by No 85 of 1999 regarding Management of Toxic and Hazardous Wastes.

MOE Regulation No. 18 of 2009 on Licensing Procedures for Management of Hazardous and Toxic Waste.

BAPEDAL Decree No. KEP-01 – 05 / 1995 on Technical Procedures and Requirements on Storages and Collections of Hazardous and Toxic Wastes; Wastes Manifests; Wastes Management.

World Bank Group EHS General Guidelines on Waste Management / Geothermal Power Generation.

PGE Project Manager / Environmental Engineer / PRO


Mitigation throughout construction phase.

PGE daily inspections (observations of non-compliance will be reported only), annual waste audit or at least two audits during contract scope.

Toxicity testing of drilling muds prior to removal from ponds when not re-injecting.

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP with inclusion of a Waste Management Plan as identified in Section 9.5).

PGE review / audit of contractors HSE plan including waste management procedures as part of audit programme (CSMS).

PGE audit reports, including photographs (where relevant) and documentation of suitable storage measures, documentation of approved waste disposal facility, transfer notes, and/or contractor employed to collect wastes.

Toxicity testing of hazardous wastes such as drilling muds.

Contractor to include mitigation within their scope/costs.


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4.10 Geology and Erosion Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

Prevent soil erosion and transportation

Soil excavation, levelling and construction.

Cover of vulnerable soil with erosion resistant material and re-vegetation.

Special focus should be on this during the rainy season.

N/A

International best practice.




PGE daily inspections (observations of non-compliance will be reported only).

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP and mitigation measures as identified).

PGE review / audit of contractors HSE plan as part of audit programme (CSMS).

Contractor to include mitigation as part of their scope under EPC / drilling contracts.


Stabilise slopes to prevent landslides


All cuts of slopes should be stabilised with appropriate walls or other structures to ensure slope stability and prevent mudflows or landslides.

N/A










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Maintain and monitor water channels to prevent erosion


Concrete water drainages system to direct water and prevent bank erosion.

N/A










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4.11 Land Contamination Management (Construction) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

To protect land and soil from contamination from drilling mud ,and cuttings and other potential hazardous wastes

Collection, storage, transport of drilling muds and cuttings.

Use of water based drill muds and recycling of drill muds.

Storage of muds in lined ponds and of cuttings in dedicated houses;

Regular removal of muds from the settling ponds for re-injection into total loss wells where available or storage and subsequent treatment of the muds as relevant waste category as determined by Indonesia regulation;




World Bank Group EHS General Guidelines on Contaminated Land / Geothermal Power Generation.

Dutch Soil Quality Standards

PGE Project Manager / Environmental engineer




Toxicity testing of drilling muds prior to removal from ponds when not re-injecting.



Toxicity testing of hazardous wastes such as drilling muds.

Contractor to include use of water based drilling muds within their scope/costs.

PGE to include storage provision / removal of muds and auditing / toxicity testing in routine PGE site management expenses.

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To protect land and soil from contamination from fuel or chemical storage facilities or spent oils, lubricants storage

Storage, transport and use of chemical and fuel on development site

Appropriate facilities / containers for segregation and temporary storage of chemicals / fuel on site including impermeable surfaces and adequate bunding.

Training of Contractor employees by Contractor.

Government Regulation No 74 of 2001 regarding Management of Hazardous and Toxic Material Management.








Contractor to include mitigation with possible exception of fuel storage where omitted under contract within their scope/costs.

PGE to include fuel storage provision if not in construction contract and auditing in routine PGE site management expenses.

To protect land and soil from contamination from well test brine

Collection and storage of brine during horizontal well testing

Storage of brine in lined ponds until potential future reinjection.

Develop brine management plan to minimise risk of brine discharges.

Decree of Mining and Energy No 02.P/20/M/PE/1990 regarding exploration and exploitation of safety work on geothermal resources


PGE Vice President of Management Operations and Utilities / Project Manager (construction) responsible for implementation at project level.

Mitigation throughout construction phase (well test).

PGE to implement Brine Management Plan.

Regular review of brine management plan implementation by on-site environmental engineer during periods of well production tests. Audit of brine management plan under quarterly HSE and Operations head office visit if and when visit coincides with period of well testing.

Mitigation installation included within current infrastructure drilling contract scope.

Maintenance of ponds and site drainage system by PGE estimated at $15,000 per year per cluster.

Auditing in routine PGE site management expenses.

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4.12 Transport Management (Construction) Objective Activity Action Standards Responsibility Timescales Monitoring / KPI Cost estimate

Minimise road hazards, congestion and damage to road infrastructure

Traffic Management

Contractor to implement and develop framework Transport Management Plan provided in Section 9.6.

National laws and permitting requirements

PGE Project Manager



To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP and implementation of Traffic Management Plan - refer to Section 9.6).

PGE review / audit of contractors HSE plan including traffic management plan as part of audit programme (CSMS).

Reporting of accidents and statistics by Contractor to PGE.

PGE / Contractor to develop and implement Traffic Management Plan depending on requirements of individual construction contracts.

Review and auditing included in routine PGE site management expenses.

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4.13 Archaeology and Cultural Heritage Management (Construction) Objective Activity Action Standards Responsibility Timescales Monitoring / KPI Cost estimate

Record and protect any archaeological finds

Excavation works during construction phase

Contractors to establish a chance finds procedure (refer to sub-section 9.8)

WB’s Physical Cultural Resources Policy Guidebook

World Bank Operational Policy 4.11

PGE Project Manager


Apply to all new construction contracts.

To be defined under PGE HSE requirements. PGE to review Contractors HSE Plan to ensure continuity with PGE HSE requirements (including commitment to this ESMP and development of a chance finds procedure as identified in Section 9.8).

Reporting / notification of finds to the Preservation of Archaeological Heritage Office (Balai Pelestarian Peninggalan Purbakala) and Archaeology Office (Balai Arkeologi).

Implementation of chance finds procedure included in routine PGE site management expenses.

Training for PGE environmental engineer on how to recognise physical cultural resources estimated cost - $5,000.

Contractor to implement chance find procedure as part of their scope.

Cost apportionment in the event of a chance find of physical cultural resource resulting in suspension of works to be covered under terms of EPC / drilling contracts.

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Figure 4.1: Proposed Monitoring Locations – Construction

Note: Air quality monitoring locations defined in Section 6.


5. Operation ESMP

5.1 Overview

The operation ESMP is summarised in the following tables. These include measures to be transposed in PGE’s detailed ESMP or work procedures.

As mentioned previously, all mitigation measures and monitoring requirements applicable to wells drilling during Project development should also be applied for make up wells drilling during operation. The ESMP shall be updated (in particular roles and responsibilities) and relevant requirements should be included as part of each new drilling contract.

The following sub-sections address individual project operation activities identifying specific mitigation and monitoring measures associated with environmental and social aspects where relevant and as required.

Table 5.1 sets out the structure of the operation ESMP as presented over the following sub-sections.

Table 5.1: Operation ESMP Structure

Sub-Section Discipline / Media

5.2 Social Management

5.3 Hydrology Management

5.4 Groundwater Management

5.5 Noise Management

5.6 Ecology Management

5.7 Air Quality Management

5.8 Waste Management

5.9 Geology and Erosion Management

5.10 Land Contamination Management

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5.2 Social Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Safeguard the livelihoods of any workers laid off

Labour management

Development and adoption of PGE retrenchment plan for permanent PGE staff (see Section 9.3).

Law No. 13 of 2003 regarding Manpower


PGE General Manager / Human Resources

Within 1st year of power plant beginning operations

Disclosed retrenchment policy / plan documentation to all permanent PGE staff.

Included in normal operation and human resources management budget.

Increase knowledge of safety risks related to tampering with steam pipes to avoid damage and safety incidents


Health and safety awareness brochures for local communities living / working near pipes to discourage tampering.



PGE General Manager / HSE Manager / PRO

Brochure raising health and safety awareness to be issued to community prior to pipes becoming operational.

Community to receive brochure which raises health and safety awareness.

Community to sign acknowledging receipt of brochure.

PGE production of health and safety awareness brochures estimated at $6,000 as one-off.

Distribution of health and safety awareness brochures to be included in routine PGE site management expenses.

Equity in local employment benefits / minimise social conflict


PGE Recruitment Policy (see Section 9.2) to specifically include requirement to prioritise local employment taking into account available skills.

(refer to Section 9.2) (refer to Section 9.2)


Disclosed Recruitment Policy in Site Office and Kepala Desa offices of local villages.

Village committee meeting minutes.


Local skills development


Local employment to be prioritised; where possible PGE to provide vocational training schemes to local workforce employed for a minimum of one year via supply companies in skills required by power plant operation (i.e. administrator, driving etc).

World Bank Operational Policy 4.01 Environmental Assessment



Records of specialised training for local staff maintained by PGE.

Certificates issued by PGE to employees detailing training received / new skills acquired while employed.

PGE identified budget of up to $150 per person per day to be invested in local skills development. Not possible to determine total cost budget until staffing numbers known and quantity of training required.

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Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Labour Grievance Mechanism

Labour management

Development, formalisation and disclosure of staff grievance polices and mechanisms for complaints about unfair treatment or unsafe living or working conditions without reprisal. (see Section 9.4)


(see Section 9.4)


(see Section 9.4)


Documented grievance mechanism established.



Protecting the workforce

Labour management

Implement PGE’s labour management procedures and welfare safeguard measures (as embodied within the existing PGE SMK3LL).



IFC PS2 – Labour and Working Conditions, terms of employment to be in line with ILO standards.

PGE General Manager / Human Resources / HSE Manager

Implement throughout operation.

Daily inspections (observations of non-compliance will be reported only), annual HSE audit.

HSE audit reports, corrective measures and action plan, photographs where relevant demonstrating corrective measures implemented.

Accident statistics.


Community Grievance Mechanism


Develop formally documented grievance mechanism and resolution process. See Section 6.9 of ESIA Volume II.


PGE General Manager / PRO.

Refer to Section 6.9 of ESIA Volume II.

Ongoing Documented grievance mechanism established.


Included in normal Corporate Secretary / operation management budget.

Restrict access to sites, especially hazardous areas


Appropriate fencing / signage around site perimeters.

Appoint site security personnel (appropriately vetted with security training certification)



PGE General Manager / General Services

Ongoing Provision / review of the following documentation:

Description / photographs of fencing / signage around site perimeter.

Contracts of security personnel appointed and description of due-diligence performed and training certification.

Site registry identification system.

Erection of fencing as part of construction scope.

Security provision included in normal operation management budget.

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Preparation in the event of an H2S emergency


PGE to implement H2S Emergency Response Plan. See Section 8.


Refer to Section 8.

H2S Emergency Response Plan applicable throughout operation.

Annual drill with community for first three years of operation. Revert to drill once every 3 years if monitored H2S concentrations stable below guidelines

Documentation in place and operator aware of responsibilities.

H2S Emergency Response Plan Drill to be undertaken with subsequent feedback documentation.

Included in normal operation management budget.

5.3 Hydrology Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Protection of surface water supply quantity for local users and the environment

Abstraction for first filling of cooling tower basin

Choose abstraction rate and timing to minimise impacts on water course and to ensure minimal stream flow maintained.

Record quantity of water abstracted and timing of abstractions


PGE General Manager / HSE Manager / Power Plant Manager

During first filling and any abstraction thereafter.

PGE to record quantity of water abstracted and timing of abstractions.


No complaints from downstream users (as recorded under Community Perception in RKL / RPL).


Ongoing flow meter calibration approximately $100 per year.

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Protect surface water and end users

Reinjection Minimise risk of brine / condensate discharge through implementation of reinjection system and provision of adequate sized lined storage ponds / system shut down in case of reinjection failure.

Develop brine management plan to minimise risk of brine discharges.

In the event of emergency discharge of brine / condensate to surface waters, treatment will be undertaken prior to discharge of effluent to comply with Indonesian discharge geothermal effluent standard.

MOE Regulation No.04 of 2007 regarding wastewater quality from oil and gas and geothermal exploration and production


Government Regulation No. 35 of 1991 regarding Rivers.

Presidential Decree No. 32 of 1990 regarding Management of Protected Areas.

Regulation of Minister of Public Work No. 63 of 1993 regarding Line Border Rivers, Regional Benefits River, River Region and Former River courses.


PGE Vice President to Management Operations and Utilities / General Manager / Operations Manager / Maintenance Manager / HSE Manager

Mitigation throughout Operation.

Monitoring on quarterly basis (as per RKL/RPL).


Regular review of brine management plan implementation by on-site environmental engineer during operation. Audit of brine management plan under annual HSE and Operations visit.

Collection of surface water samples and analysis by accredited laboratory (as per monitoring locations in Figure 5.1 which are in addition to current RKL/RPL monitoring).

No deterioration in pre-project river water quality as result of PGE effluent discharges.

Mitigation included in normal operation management budget.

Estimated cost for water quality monitoring $1,500 per quarter over and above current RKL/RPL budget for monitoring implementation.

Review and audit process included in normal operation management budget.

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To protect water courses from contamination from fuel or chemical spills


Development of relevant procedures to avoid and minimise risk of spills, including but not limited to the following:

All chemicals and fuels are to be stored in designated sites with impermeable surfaces and adequate bunding to prevent accidental contamination.

Storage areas to be located away from surface waters.

Suitable spill kits to be provided within storage areas and near any fuelling/ loading areas.

Regulation No 74 of 2001 regarding Management of Hazardous and Toxic Material Management.



PGE General Manager / HSE Manager

Mitigation throughout Operation.

Daily internal inspections by PGE HSE staff (observations of non-compliance will be reported only); Annual HSE audit during Operation.

PGE to implement mitigation as part of operational procedures.


PGE HSE staff to inspect storage areas against mitigation requirements, for example, check availability of spill kits, adequate bunded storage for chemicals and fuels.


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5.4 Groundwater Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Protection of groundwater supply quantity for local users

Potential groundwater abstraction for power plant operation

In the event of groundwater abstraction for power plant operation, PGE to provide baseline of current community water supply wells. If community groundwater wells affected either deepen affected wells or if required construct new water supply pipeline from alternative source to ensure community water supply unaffected.

Record quantity of groundwater abstracted and timing of abstractions.

Decree of. Minister of Health Regulation No. 416 of 1990 regarding requirements for monitoring of water quality


PGE General Manager / HSE Manager / PRO

Annual survey of community well locations.

Sampling of representative community wells to be undertaken on quarterly basis (as per RKL/RPL requirements).

Site walkover, identification of representative community well locations and water depth (using a dip meter or plumb line). To be undertaken in area surrounding operational abstraction points (up to 1km radius depending on location of known community wells). Collection of community water well sample from representative well and analysis by accredited laboratory (as per RKL/RPL requirements).


No complaints from downstream users (as recorded under Community Perception in RKL/RPL through questionnaire response).

$1,500 per year for site walkover and measurements of representative community wells over and above current RKL/RPL budget for monitoring implementation.


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5.5 Noise Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Avoid noise nuisance from site operation

Plant operation

Ancillary plant to be of low noise design and employ sound attenuation. Building design to include acoustic absorption material. Use of acoustic enclosures for steam turbines and associated equipment, inlet and exhaust silencers, duct mounted attenuators, acoustic louvers and vibration isolation systems. Use of insulation, enclosures, three sided pens, and low noise trims for generators and transformers.

Maintain equipment / acoustic enclosures to ensure noise levels do not increase over time.

Hours of general maintenance activity restricted to avoid sensitive periods of the day (e.g. religious event) and also to avoid night working typically following World Bank night-time noise guidelines (22:00 to 07:00).

If operational activities cause breaches of Indonesian and World Bank standards as identified through monitoring, noise barriers of no less than 10kg/m2 surface density should be put in place at affected properties (ensuring that the noise source is entirely hidden from the receptor).



PGE General Manager, HSE Manager, PRO

Mitigation ongoing throughout operation.

Monitoring frequency: quarterly or upon receipt of noise complaints via community grievance mechanism.

PGE to monitor noise levels using sound level meter at the nearest residential properties to operational activities for comparison against standards. To be undertaken on a quarterly basis as per RKL/RPL requirements.


Mitigation measures to be included in the design scope for the EPC Contractor.

Ongoing sound level meter calibration approximately $350.

If additional noise barrier is required following noise monitoring, estimated PGE cost at $400 per square meter.

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5.6 Ecology Management (Operation)

As ecological impacts during operation are mostly indirect, refer to water, air, noise and waste sections.

5.7 Air Quality Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

To ensure the health and safety of workers and the community

Operational emissions from the Power Plant Site

H2S monitoring of the steam line serving the Power Plant and cooling tower emissions (as required by national legislation).

Air Quality / H2S Monitoring Programme (see Section 6), including meteorological monitoring.

Health Data Collection Programme (see Section 7).

H2S Emergency Response Plan (see Section 8).

MOE Regulation No. 21 of 2008, on Air Emissions from Thermal Power Plants.

WHO ambient air quality guideline for H2S.

PGE General Manager / Operations Manager / HSE Manager

Monitor steam line for H2S content in NCGs on monthly basis.

Monitor H2S content of emissions from the cooling towers on a bi-annual basis.

Air Quality / H2S Monitoring Programme (including meteorological monitoring) and Health Data Collection Programme to begin no later than December 2011.

H2S Emergency Response Plan to be implemented upon operation.

Monitored H2S emission concentrations to meet the emission limit standard.

Monitored ambient H2S concentrations to meet the WHO ambient air quality guideline and not result in health effects on the local community.

Monitoring of emissions included in normal operation management budget.

Initial cost for the continuous monitoring equipment (and meteorological station) estimated at around $40,000 excluding shipping and installing costs which are estimated to be $50,000 on top of initial costs. Ongoing maintenance and calibration could cost up to $17,000 - $27,000 per year. Passive monitoring costs estimated as up to $10,000 per year.

Production of health data collection program up to $25,000

Production of a H2S emergency response plan costs is estimated

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at $20,000 excluding any ancillary requirements that may be required following production of the plan (e.g. equipment)

To ensure the health and safety of workers and the community

Steam / H2S accidental release from steam pipeline rupture

Installation of pressure relief valve and rupture disks in steam pipeline to minimise risk of pipeline rupture / control point of rupture. If pressure in pipeline drops pipeline failure, steam will be automatically diverted to the rock muffler.

Manual valves included to isolate steam supply. Detection of pipeline rupture through steam pressure monitoring. In event of steam pipeline rupture, manually close emergency valves to isolate steam supply.

Manually inspect that steam release stopped from rupture following isolation of steam supply.

In the unlikely event that emergency valves cannot be closed, the wells will be shut down as a last resort.

World Bank Group EHS Guidelines on Geothermal Power Generation.

PGE General Manager / Operations Manager / HSE Manager

Throughout operation

No adverse health effects for workers / local community.

Physical mitigation included as part of Project design.

Response included in normal operation management budget.

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To ensure the health and safety of workers


Provide personal protective equipment, such as dust masks where dust levels are likely to be excessive.

Provision of facility emergency response teams, and workers in locations with high risk of exposure with personal H2S monitors, self-contained breathing apparatus and emergency oxygen supplies, and training in their safe and effective use.

Provision of adequate ventilation of occupied buildings to avoid accumulation of H2S.

Provide workers with a fact sheet or other readily available information about the chemical composition of H2S with an explanation of potential implications for human health and safety.

Confined space procedures (as per World Bank Group guidance)

Ministry of Manpower Letter No. SE-01/MEN/1997 regarding Ambient Threshold Limit of Chemical Factor in Working Environment




Monitored H2S concentrations to meet the occupational limit.

No adverse health effects for workers.


PGE production of H2S safe working brochures estimated at $1,500 one-off cost.


To ensure the health and safety of the community


60% abatement of emissions from cooling towers using integrated removal technology

MOE Regulation No. 21 of 2008, on Air Emissions from Thermal Power Plants.

WHO ambient air quality guideline for H2S.



Monitored H2S emission concentrations to meet the emission limit standard and estimated removal efficiency of abatement systems

Monitored ambient H2S concentrations to meet the WHO ambient air quality guideline and not result in health effects on the local community.

Part of construction and operation costs, to be included in EPC contractor’s scope

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5.8 Waste Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

Minimise waste generation, avoid contamination.

Plant and steam field operation and maintenance

Implement waste management plan framework, refer to Section 9.5.




World Bank Group EHS General Guidelines on Waste Management / Geothermal Power Generation.


Mitigation throughout operation phase.

PGE daily inspections (observations of non-compliance will be reported only), annual HSE audit.

PGE to develop and implement Waste Management Plan (refer to Section 9.5) as part of standard operational procedures.

PGE internal audit reports, including photographs where relevant and documentation of suitable storage measures, documentation of approved waste disposal facility, transfer notes, and/or contractor employed to collect wastes.

Record quantities of all wastes generated from different waste streams as part of overall site waste inventory.

Maintain records of hazardous wastes disposed off-site.


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5.9 Geology and Erosion Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost estimate

To ensure natural geothermal activity remains as close to original activity as possible.

Steam field operation.

Direct observation and mapping of surface activity and comparison with baseline environment (pre-Project).


PGE General Manager / PSD

Monitoring throughout operation phase.

Annual monitoring / sampling of surface activity.

Daily monitoring of production wells.

Monitoring of surface activity (hot springs, mud pools, steam vents). Sampling of flow rates and water chemistry.

Sample production wells for fluid chemistry, steam fraction and well pressure.

Surface activity monitoring - $7,000 per year over and above current RKL/RPL budget.

Production well sampling included in normal operation management budget.

5.10 Land Contamination Management (Operation) Objective Activity Mitigation / Enhancement Standards Responsibility Timescales Monitoring / KPI Cost Estimate

To protect land and soil from contamination from fuel or chemical storage facilities or spent oils, lubricants storage

Storage, transport and use of chemical and fuel on operational sites

Appropriate facilities / containers for segregation and permanent storage of chemicals / fuel on site including impermeable surfaces and adequate bunding. Temporary storage facilities available for maintenance periods.

Internal training of PGE operational shift staff / maintenance staff.

Government Regulation No. 74 of 2001 regarding Management of Hazardous and Toxic Material Management.


PGE General Manager, HSE Manager

Mitigation throughout operation phase.

HSE monthly housekeeping walkover (observations of non-compliance will be reported only),

Internal annual HSE audit.

Requirement for PGE to implement mitigation as part of operational procedures.

Monthly HSE manager site walkover to observe site housekeeping.

PGE internal audit reports, including photographs where relevant and documentation of suitable storage measures, inventory of chemical storage maintained, documentation of spills / clean up / corrective actions.


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To protect land and soil from contamination from brine / condensate

Steam field operation.

Minimise risk of brine / condensate discharge through implementation of reinjection system and provision of adequate sized lined storage ponds / system shut down in case of reinjection failure.

Develop Brine Management Plan to minimise risk of brine discharges.

In the event of emergency discharge of brine / condensate to land, treatment will be undertaken prior to discharge of effluent to comply with Indonesian discharge geothermal effluent standard.

MOE Regulation No. 04 of 2007 regarding wastewater quality from oil and gas and geothermal exploration and production



PGE Vice President for Management Operations and Utilities / General Manager / Operations Manager / Maintenance Manager / HSE Manager

Annual survey of community well locations.

Sampling of representative community wells to be undertaken on quarterly basis (as per RKL/RPL requirements).


Regular review of brine management plan implementation by on-site environmental engineer during operation. Audit of brine management plan under annual HSE / Operations head office visit.

Site walkover, identification of community well locations and water depth (using a dip meter or plumb line). To be undertaken in area surrounding operational abstraction points (up to 1km radius depending on location of known community wells). Collection of community water well sample from representative community well and analysis by accredited laboratory (as per RKL/RPL requirements).


No complaints from downstream users (as recorded under Community Perception in RKL/RPL through questionnaire response).

Mitigation included in normal operation management budget.

$1,500 per year for site walkover and measurements of representative community wells over and above current RKL/RPL budget for monitoring implementation.

Review and audit process included in normal operation management budget.


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Figure 5.1: Proposed Monitoring Locations – Operation

Note: Air quality monitoring locations defined in Section 6.


6. Air Quality / H2S Monitoring Programme

6.1 Overview

This section presents an ambient H2S Monitoring Programme which will be implemented within the study area, in light of the air quality assessment results described within the ESIA volume II and III. The introduction of a Monitoring Programme is in accordance with the IFC General EHS Guidelines for Geothermal Power Generation which notes that:

“Where the potential for community exposure is significant, examples of mitigation measures include:… Installation of a hydrogen sulfide gas monitoring network with the number and location of monitoring

stations determined through air dispersion modeling, taking into account the location of emissions sources and areas of community use and habitation;

Continuous operation of the hydrogen sulfide gas monitoring systems to facilitate early detection and warning;”

As described within the ESIA volume II and III, H2S concentrations are predicted to be well below the occupational exposure limits. Nevertheless, installation of an on-site H2S monitoring system is to be included within the EPC contract scope of works to assess worker exposure to H2S concentrations, as described in the Project Feasibility Study 2010. Beyond these measures, no further consideration is therefore given to occupational H2S monitoring within this H2S Monitoring Programme. Similarly, H2S emissions monitoring will be carried out by PGE and therefore the focus of this Monitoring Programme is ambient H2S concentrations beyond the site boundary relating to community exposure only.

In the event that additional wells are drilled during the life of the project, the monitoring measures set out below would be applied to any new well drilling, with additional monitoring locations established in accordance with the philosophy described.

This ambient air quality Monitoring Programme should be read in conjunction with the Health Data Collection Programme presented in Section 7.

6.2 Purpose

The overall purpose of the Monitoring Programme is to determine the change in ambient concentrations of H2S, in areas of public exposure, as a result of the project in the context of the WHO ambient air quality guideline for the protection of human health1. This is achieved through two steps: Collecting data on ambient H2S concentrations in public areas near to project site before the

construction of Units 3&4 begins; and Collecting data on ambient H2S concentrations in public areas near to the project site during the

construction and operation of Units 3&4.

6.3 Schedule

In order to provide sufficient data on existing ambient H2S concentrations, the Monitoring Programme will commence as soon as is practicable, and no later than December 2011. This will allow ambient concentrations to be established as they currently are, as well as following the construction and operation

_________________________ 1 The WHO guideline is 150 µg/m3 averaged over 24 hours

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of PLN Units 1&2. Although determining the change in H2S concentrations as a result of PGE Units 3&4 is the overall purpose of the programme, the air quality assessment presented in the ESIA has identified that emissions from PLN Units 1&2 contribute to the larger proportion of total ambient concentrations at some locations.

The Monitoring Programme will cease upon the decommissioning of Units 3&4.

6.4 Data Collection Methods

There are a number of methods available for the monitoring of H2S in ambient air. For this programme, a combination of two methods has been selected; ‘continuous’ and ‘passive’. This combination allows high temporal resolution data to be collected at the location of maximum predicted impacts as well as lower temporal resolution data to be collected across the wider study area at a reasonable cost. In addition, the continuous analyser allows the availability of near real-time data on H2S concentrations to facilitate early detection and warning which is important for short term H2S episodes.

In order to provide reasonable flexibility during the implementation of the programme, the specification of the equipment to be used is described below rather than identifying specific manufacturers.

6.4.1 Continuous Monitor

Continuous monitoring of H2S shall be carried out using an Ultra Violet (UV)-fluorescence sulphur dioxide (SO2) analyser coupled to an H2S converter unit containing a scrubber to remove oxides of sulphur (SOx) and a catalyst to convert H2S passing through the scrubber into SO2. The unit shall have a lower detection limit of no more than 1.5ppb (approximately 2.3 µg/m3), an upper range of no less than 2ppm (approximately 3000 µg/m3) and a fast response time of approximately 180 seconds. The monitor will incorporate an internal data logger, capable of recording average H2S concentrations over 1 hour and 24 hour periods as a minimum, based on readings taken at least every minute, and record data for periods of up to a year. The use of UV continuous monitoring methods is internationally recognised.

The continuous monitor will require a weatherproof, air conditioned enclosure and a continuous electrical power supply in accordance with the chosen manufacturer’s specifications.

6.4.2 Passive Monitors

Passive monitoring will be undertaken using diffusion tubes. The analysis method of the diffusion tubes (to determine H2S concentrations) shall be colorimetric using UV Spectroscopy, or equivalent. The diffusion tubes contain fibre coated filters coated with an absorbent i.e. zinc acetate / glycol solution. They are exposed to air for a period of two to four weeks during which any H2S present reacts to form zinc sulphide. The exposed filter is then removed from the tube in the Laboratory for analysis. Zinc Sulphide (ZnS) is reacted with ferric chloride (FeCl2) and N, N- dimethyl-p-phenylene diamine to form methylene blue the absorbance of which is measured spectrophotmetrically. The concentration of hydrogen sulphide in the atmosphere is then calculated from a pre-calibrated response factor. The tubes used will have a lower detection limit of no less than 0.5 µg/m3.

A typical H2S passive diffusion tube and appropriate mounting method is presented in Figure 6.1. One diffusion tube will be installed at each position with the exception of the ‘co-located’ tubes described below where three tubes will be present.

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Figure 6.1: H2S Passive Diffusion Tube and Mounting Method

6.4.3 Meteorological Monitor

In addition to the air quality monitors, a metrological station of suitable specification to allow data to inform future dispersion modelling will also be established at an appropriate location to record the following parameters; Wind speed; Wind direction; and Temperature.

6.5 Locations

The proposed locations of the monitors are presented in Figure 6.2. The proposed location of the continuous monitor is at the closest known village to the area of maximum H2S concentrations (as a result of the operation of PGE Units 3&4) predicted by the dispersion modelling. The diffusion tubes are located to the east, south and west of the project site at the nearest villages.

Notwithstanding these proposals, the monitoring equipment will be installed in accordance with the manufacturer’s instructions and be consistent with siting principles describe below: The continuous monitor inlet height and diffusion tube heights shall be between 1 metre and 3 metres

from the ground; Monitoring sites shall be open to the sky, with no overhanging vegetation or buildings; Monitoring sites shall not be within 10 metres of flues serving combustion sources.

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Figure 6.2: Proposed H2S Monitoring Locations

Legend:

Source: Mott MacDonald

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6.6 Quality Assurance/Quality Control

6.6.1 Continuous Monitor

Calibration of the continuous monitor shall be carried out in accordance with the manufacturer’s instructions and no less than every six months using calibration gases.

6.6.2 Passive Monitors

Three diffusion tubes shall be exposed at the inlet of the continuous monitor and changed every two to four weeks with the other tubes. Data from the three tubes will then be compared against data from the continuous analyser in order to determine the accuracy of the passive monitoring results for that period. The differences between the measured concentrations of the three tubes will also be compared to determine the precision of the diffusion tube method. During each changeover of the diffusion tubes a ‘travel blank’ will be used and results adjusted according to the concentrations monitored by it.

In addition, the laboratory used for the analysis of the tubes shall carry out periodic calibration; periodically samples of tubes prepared for exposure are spiked with known concentrations of zinc sulphide solution and measured.

6.7 Analysis, Reporting and Actions

6.7.1 Normal Reporting

Every quarter a report will be produced based on the preceding calendar months’ data, detailing the following information: Validated hourly H2S data from the continuous analyser and data capture rate; Raw results from the laboratory for the passive diffusion tubes and data capture rate; Summary data for comparison with the WHO air quality guideline:

Mean 24 hour concentrations for the period (from the continuous analyser) Maximum 24 hour concentrations for the period (from the continuous analyser) The number of occasions when the 24 hour mean concentration exceeded 150 µg/m3 (from the

continuous analyser) Period mean concentrations for each of the passive diffusion tube sites.

Summary meteorological data for the preceding month; Discussion of any salient quality assurance issues and reporting of the collocation data; Copy of the calibration report (if applicable); Details of any investigation or remedial action taken as a result of an exceedence; and Salient health data collected by local health clinics (see Section 7).

In all cases the target data capture rate for an averaging period should be over 75%. In the event that data capture rates are below this level, this should be noted in the monthly report and steps taken to remedy any recurring causes.

The report will be reviewed by the H2S Steering Group (see Section 8.2.2 for further details) and a copy stored at the project site.

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6.7.2 Action in the Event of an Exceedence

Data from the continuous analyser will be checked on a daily basis by a representative of PGE. Where concentrations for the preceding day are found to be above the WHO air quality guideline, but below 1,500 µg/m3 (the WHO acknowledges that most probably, at concentrations below 1.5 mg/m3 (1 ppm), even with exposure for longer periods, there are very few detectable health hazards in the toxicological sense), this shall be reported immediately to PGE’s Occupational Health and Safety Manager. The cause of the breach shall be investigated and remedial action taken. As a minimum, this investigation shall include: Review of recent data collected by the health clinics (see Section 7), including that collected in the week

preceding the exceedence; Review of H2S emissions monitoring data for the plant during, and prior to the exceedence(s); and Convening the H2S Steering Group (see Section 8.2.2 for further details) to discuss findings and further

action which could include investigations for additional mitigation to be employed in order for H2S concentrations in the airshed to meet WHO guideline values.

Nominated community representatives within the H2S Steering Group shall ensure that the potentially affected community is informed of any elevated H2S concentrations and / or observed health effects and report how they are being responded to. The ‘potentially affected’ community will be identified by the H2S Steering Group based on the data available. As a minimum this shall include those who are likely to experience H2S concentrations above the above the WHO air quality guideline of 150 µg/m3.

Where concentrations for the preceding day are found to be above 1,500 µg/m3 (the WHO acknowledges that most probably, at concentrations below 1.5 mg/m3 (1 ppm), even with exposure for longer periods, there are very few detectable health hazards in the toxicological sense), this shall be immediately reported to PGE’s Occupational Health and Safety Manager. In response, the Occupational Health and Safety Manager will implement the Emergency Response Plan.

6.8 Costs

The estimated initial purchase cost of the continuous analyser and meteorological station is $40,000. Additional costs will be associated with its delivery, installation, and power supply, amongst others which could be substantial given the remote location. It is estimated that these additional costs could add up to $50,000 on to the initial costs. Maintenance (including calibration) is likely to cost up to $17,000 per year. If a generator is required this would increase the running costs of the monitoring station by up to $10,000 per year.

The estimated cost of the passive diffusion tubes, including analysis, (assuming changeover once per month) is $10,000 per annum.

6.9 Responsibilities

The installation (including power supply provision), operation, maintenance and reporting procedures set out above for the Monitoring Programme will be the responsibility of PGE.

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7. Health Data Collection Programme

7.1 Overview

As described within Section 9 of the ESIA volume II, elevated concentrations of H2S in ambient air can have detrimental effects on human health. The air dispersion modelling has indicated that maximum ground level concentrations of H2S are elevated in respect of the WHO ambient air quality guideline at some residential receptors. Because of these predictions, further data are needed on the health of the local community and potential links with elevated ambient H2S concentrations.

7.2 Purpose

The overall purpose of collecting data on health effects is to detect any health effects in the potentially affected population that might be correlated with ambient H2S concentrations. Data collection is to begin in 2011 in order to have a baseline that is established before any units are operating. This will provide an initial base upon which to make future decisions on managing H2S emissions from PGE Units 3&4. This is achieved through two steps; Collecting relevant health data from communities near to project site before the construction of PGE

Units 3&4 begins; and Collecting relevant health data from communities near to the project site during the construction and

operation of PGE Units 3&4.

7.3 Schedule

In order to collect sufficient data on existing community health, the data collection will commence as soon as is practicable, and no later than June 2011. This will ensure that a focussed health baseline is collected prior to the commissioning of PLN Units 1&2 (2012) and thereafter PGE Units 3&4 (2014). Any change in health statistics following commissioning of either plant can be identified through the establishment of this baseline.

The collection programme will cease upon the decommissioning of Units 3&4.

7.4 Data Collection Methods

Data will be collected by health clinics that are located within the area2 identified in Figure 7.1. This area covers the spatial scope of predicted changes in H2S concentrations and also includes communities that are not predicted to experience changes in H2S concentrations. H2S monitoring is proposed at various sites within this area, and collection of public health data across a similar geographic scale will enable health incidents to be analysed alongside monitored concentrations.

_________________________ 2 The health clinics within the defined area serve communities that are identified on the map and other communities that are not on

the map. It is the location of the health clinic, not the location of the community, which determines whether data will be collected.

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Figure 7.1: Health Monitoring Area and Proposed H2S Monitoring Locations

Legend:

Source: Mott MacDonald

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Baseline data on the health of the population will be collected to provide a snapshot of the existing public health issues in the local community. As well as general indicators of health such as mortality, morbidity and life expectancy, this will include statistics on patient complaints that have evidential links to H2S. Acute inhalation exposure to high concentrations may result in effects on the respiratory, neurological, ocular and cardiovascular systems. Exposure to low concentrations may result in irritation to the mucous membranes of the eyes and respiratory tract. Sources of information include clinic and hospital records.

Upon the commencement of the Programme, health professionals within these clinics shall be made aware of the potential for adverse effects due to H2S to ensure they are familiar with the symptoms of chronic and acute exposure to elevated H2S concentrations.

Acute inhalation exposure to high concentrations may result in effects on the respiratory, neurological, ocular and cardiovascular systems. Exposure to low concentrations may result in irritation to the mucous membranes of the eyes and respiratory tract. Following acute ocular exposure, eye irritation, with keratoconjunctivitis (inflammation of the cornea and conjunctiva, the mucous membrane that covers the white part of the eye), punctate corneal erosion (damage of the cornea in a pinpoint pattern), blepharospasm (neurological movement disorder involving involuntary and sustained contractions of the muscles around the eyes), lacrimation and photophobia may occur. It is expected that health professionals will make their own determination as to whether a patient may be experiencing the effects of H2S exposure based on their professional opinion. Detailed information on the health effects of H2S are available from, amongst others, the U.S. Department of Health and Human Services’ Agency for Toxic Substances and Disease Registry3.

In the event that a patient is identified as presenting symptoms of exposure to H2S, the health clinic shall log this on a separate register held at the clinic for that purpose. Additional information shall be recorded at the health professional’s discretion to aid in the identification of the location of the exposure and source of the H2S.

7.5 Analysis, Reporting and Actions

7.5.1 Normal Reporting

Each quarter, data from the registers at the health clinics shall be collected and reviewed by PGE’s Occupational Health and Safety Manager, in conjunction with the H2S Steering Group (see Section 8.2.2 for further details) to determine whether further investigation or remedial action is required. Further investigation could include a detailed Health Impact Assessment.

7.5.2 Action in the Event of a Health Incident or Increased Prevalence

In the event that a patient presents extreme symptoms of H2S exposure, or significant numbers of patients report symptoms of H2S exposure over a short period, the health clinic in question should contact PGE’s Occupational Health and Safety Manager immediately. The emergency contact details (including out-of-hours contact) for PGE’s occupational Health and Safety Manager should be provided to all health clinics for this purpose. In response, the Occupational Health and Safety Manager will implement the Emergency Response Plan.

_________________________ 3 http://www.atsdr.cdc.gov

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7.6 Responsibilities

The implementation and running of the Health Data Collection Programme set out above will be the responsibility of PGE.

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8. H2S Emergency Response Plan

8.1 Overview

A comprehensive plan is currently being prepared by PGE that will address each potential incident and be issued to all relevant managers. It is recommended that these Emergency Response Plans should follow a standard format comprising of the following: Title; Details of Crisis Management Team; List of contacts with external organisations (names, address, telephone numbers) and individual

responsibilities for making these contacts; List of individual responsibilities under the headings; Preparation in the event of an accident; Actions during the emergency; Actions after the emergency; and Sources of necessary information and locations of the pollution control facilities.

These plans should be integrated with the fire-fighting and safety response plans. Further specific recommendations in response to elevated H2S concentrations are provided in the following subsections.

The focus of this H2S Emergency Response Plan is to avoid impacts on the health of the community only. As described in Section 4.7 and 5.7 above and Section 9.6 of Volume II, an H2S safety contractor will be employed to introduce plans and procedures to control occupational exposure to H2S emissions.

8.2 Response to Elevated H2S Concentrations and / or Observed Health Effects

8.2.1 Overview

The H2S Monitoring Programme and Health Data Collection Programme describe programmes for the monitoring of H2S concentrations in ambient air and the collection of data on health and H2S effects.

The H2S Monitoring Programme directs that where concentrations are found to be above 1,500 µg/m3 as a 24 hour mean this shall be immediately reported to PGE’s Occupational Health and Safety Manager (the WHO acknowledges that most probably, at concentrations below 1.5 mg/m3 (1 ppm), even with exposure for longer periods, there are very few detectable health hazards in the toxicological sense). In response, the Occupational Health and Safety Manager will implement the Emergency Response Plan.

For concentrations between 150 and 1500µg/m3, although the ERP would not be immediately triggered, the Steering Group (see below) would be notified and actions followed as presented in Section 6.7.2.

The Health Data Collection Programme directs that in the event that a patient presents extreme symptoms of H2S exposure, or significant numbers of patients report symptoms of H2S exposure over a short period, the health clinic in question should contact PGE’s Occupational Health and Safety Manager immediately. The emergency contact details (including out-of-hours contact) for PGE’s occupational Health and Safety Manager should be provided to all health clinics for this purpose. In response, the Occupational Health and Safety Manager will implement the Emergency Response Plan.

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The following sub-sections identify specific measures that should be included in the overall Emergency Response Plan for the Project in relation to responding specifically to community exposure to elevated H2S concentrations.

8.2.2 H2S Steering Group

Both the H2S Monitoring Programme and the Health Data Collection Programme set out how the data collected should be reported and under what circumstances further action should be taken if results indicate elevated ambient concentrations and/or negative health effects. It is recommended that an H2S Steering Group be formed to ensure that results are properly interpreted and that the appropriate remedial action is carried out. Given that the Ulubelu airshed will include two primary H2S emitters (PLN Units 1&2 and PGE Units 3&4), it is appropriate that this Steering Group includes representatives from both power plant developments in order to ensure that the quality of the airshed is managed in a holistic manner.

The H2S Steering Group should comprise, as a minimum; A member of the PGE Unit 3&4 plant management; A member of the PLN Unit 1&2 plant management; PGE Occupational Health and Safety Manager; PLN Occupational Health and Safety Manager; A Health Professional (with specific knowledge of H2S effects); Community relations officer; Community representative(s).

Part of the role of the community representatives and community relations officer will be to ensure that the potentially affected community is informed of any elevated H2S concentrations and / or observed health effects and report how they are being responded to. The 'potentially affected' community will be identified by the Steering Group (or, the Occupational Health and Safety Manager if the Emergency Response Plan has been initiated) based on the data available. As a minimum, this shall include those who are likely to experience H2S concentrations above the WHO air quality guideline of 150 µg/m3.

The following Sections describe how the H2S Steering Group will respond to potential events of community exposure to elevated H2S concentrations.

8.2.3 Response to Monitored Elevated Concentrations

Where concentrations are found to be above 1,500 µg/m3 as a 24 hour mean (the WHO’s Lowest-observed-adverse-effect level), this shall be immediately reported to PGE’s Occupational Health and Safety Manager. In response, the Occupational Health and Safety Manager will follow the flow chart presented in Figure 8.1. In addition to following the flowchart, a representative of the Government’s environmental regulator will be notified.

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Figure 8.1: H2S Emergency Response Plan Flowchart

Source:Mott MacDonald

The 'potentially affected' community will be identified by the Occupational Health and Safety Manager based on the data available

8.2.4 Response to Steam Pipeline Rupture

Although unlikely, there exists the potential for steam pipelines serving the units to rupture, thereby releasing extremely high temperature steam into the nearby environment. The plant will include an in-built control system which can detect such ruptures (usually through resulting acute pressure drop) and, in response, automatically close emergency valves which isolate the steam supply.

In the event that a steam pipeline rupture does occur, procedures shall be in place to manually check that the control valve system has responded as designed, and that the release of high temperature steam has been prevented. In the even that the control valve system has malfunctioned, a safety exclusion zone around the rupture shall be established, until other measures can be implemented to prevent the release.

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9. Other Management Plans / Method Statement Framework

9.1 Overview

The following sections provide a framework for each of the management plans proposed below: Recruitment plan (for implementation by PGE and requirement for contractors to comply); Retrenchment plan (for implementation by PGE); Labour Grievance Mechanism Framework (for implementation by PGE); Waste management plan (for elaboration and implementation by EPC Contractors and drilling

contractors during construction and thereafter by PGE during operation); Traffic management plan (for elaboration and implementation by EPC Contractors and drilling

contractors during construction and thereafter by PGE during operation); Temporary worker accommodation management plan (for elaboration and implementation by EPC

Contractors and drilling contractors during construction); and Chance Finds Procedure.

It is intended that these framework plans will be elaborated by PGE and / or its contractors to compliment PGE’s existing Environmental, Health and Safety Management System specifically for the Project. Where relevant, under respective contracts, drilling contractors and the EPC contractors (power plant and SAGS) will be required to implement corresponding arrangements (as directed within the ESMP).

9.2 Recruitment Plan

The Local Recruitment Plan will include but not be limited to the following: Policy statement of PGE’s commitment to meeting Indonesian Laws and international best practice with

regards to recruitment and labour management including non-discrimination and equal opportunities; Description of the types of employment opportunities to be provided to local people from the

construction and operational phases of the project including skills levels, indicative timeframes of recruitment and likely duration of contracts;

Description of the local recruitment processes including timely (at least once month prior to recruitment) disclosure of information about vacancies through community meetings with Village Employment Committees as well as the job application procedures for candidates; and

Information about how job opportunities are advertised equitably between the different villages in the assessment area to ensure equal opportunities for all local people subject to appropriate skills availability.

PGE will disclose this policy document to the Kepala Desa offices of each village in the assessment area to promote transparency in the recruitment process and address community misconceptions of favouritism being shown to some villages over others.

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9.3 Retrenchment Plan

PGE will adopt the Pertamina Group’s existing retrenchment policy and where necessary update it to meet international best practice standards. The Retrenchment Plan will include but not be limited to the following: Policy statement of intent that if PGE anticipates the elimination of a significant number of jobs or a

layoff of a significant number of employees (i.e. in cases where this cannot be avoided), PGE will develop a plan to mitigate the adverse impacts of retrenchment on employees;

The plan will be in accordance with Indonesian Law and based on the principle of non-discrimination; The plan will reflect the PGE’s consultation with employees, their organizations and, where appropriate,

the government; The retrenchment plan will be disclosed to employees at the outset of the process will in advance of any

lay offs; and A grievance mechanism will be developed to deal with claims that any provisions in the retrenchment

plan were not followed.

The plan will be formalised within PGE’s Human Resources Management System.

9.4 Labour Grievance Mechanism Framework

The labour grievance mechanisms will include but not be limited to the following: A PGE policy statement that grievances can be raised by any member of staff without fear of reprisals; Response times for grievances categorised according to the severity of the grievance or the issue in

question; A process for logging grievances and when and how they are closed out; A process for monitoring grievances to identify repeat or unresolved grievances and reporting these

issues to senior management in order to expedite remedial action; and Contact details for staff to whom grievances should be raised.

The grievance mechanisms will be explained to all contractor and PGE staff on appointment and a notice summarising the approach and providing contact details for staff to whom grievances should be raised will be posted in the site accommodation areas and offices.

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9.5 Waste Management Plan

This subsection presents a framework of the Waste Management Plan to be elaborated and implemented by the EPC contractors and drilling contractors during construction and thereafter by PGE during operation. The following key steps will be considered within the WMP elaborated for respective phases of the Project: Identify who is responsible for each key stage and inform individuals of their responsibilities. They will

be required to hold sufficient authority to ensure compliance with the WMP by other site operatives; Identify the types and quantities of waste - all waste streams that will be produced during construction,

operation and decommissioning require to be identified; Identify waste management options - Where hazardous wastes are being generated, particular attention

to the arrangements for identifying and managing such waste will need to be addressed and procedures put in place;

Identify suitable waste management sites - the location of waste management sites will need to be identified (through co-ordination with local government), ideally the most local sites should be used to minimise transportation costs. Use licensed waste disposal contractors that comply with the environmental legislative requirements of the local and national area;

Training - all staff must be trained to ensure they understand the requirements of the WMP; Plan - using the steps above, establish indicative percentages of the waste quantities to be produced

over the life span of the Project; Measure - the quantities of wastes produced should be recorded on a monthly basis, and where

possible measures taken to re-use, reduce or recycle waste as appropriate; and Monitor - throughout the Project life cycle, waste management on site should be monitored, to ensure

compliance with the WMP; Hazardous Classes – hazardous wastes should be classified and treated according to national

requirements ; Identify waste management options - as described in the construction and operational ESMPs provided

in Volume II, a waste hierarchy of reduce, reuse, and recycle and needs to be considered and prepared. Where hazardous wastes are being generated, particular attention to the arrangements for identifying and managing such waste will need to be addressed and procedures put in place.

PGE will review and approve the EPC contractors and drilling contractors elaborated WMPs for the construction phase of the Project.

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9.6 Traffic Management Plan

9.6.1 Introduction

This subsection presents a framework of the Traffic Management Plan to be elaborated and implemented by the EPC contractors and drilling contractors during construction and thereafter by PGE during operation. PGE will review and approve the EPC contractors and drilling contractors elaborated Traffic Management Plans for the construction phase of the Project. Pre-defined access routes will be used by long, wide and/or heavy load vehicles transporting power plant components, e.g. turbines, condensers, cooling towers, electrical equipment. These routes will be agreed with the relevant authorities in advance and the police will be notified.

A number of abnormal loads will be generated through construction activity associated with: Drilling rigs; Construction plant; Steam turbine – engine/generator; Condenser – prefabricated elements; and Cooling tower – prefabricated elements.

9.6.2 Delivery Plan

Power plant components shall be delivered to site in accordance with the following: Plant to be delivered in sufficient time to meet the agreed erection programme; Plant to be delivered in accordance with the requirements of the local municipality, police and road

authority; Loads to be delivered to site by road and stored on site. It will be the contractor’s responsibility to

identify a suitable storage location and approved by PGE and obtain any necessary authorisations; A pilot escort vehicle should be used to provide an escort for all abnormal load vehicles travelling to the

site. The general preference in these situations is to employ a convoy system, with a vehicle at the front and rear to warn oncoming vehicles of the approaching load. The escort would also help to minimise disruption of flow for other road users by pulling the convoy over at pre-identified locations to allow build up of following traffic to pass. Drivers responsible for operating the convoy should be fully briefed on the route, where and when to make the pre-defined stops, and be aware of all contingency measures in place in the event of an incident occurring. All vehicles and lead traffic management staff shall be in contact with the use of two-way radios;

Employ additional traffic management staff (to be agreed with police if required prior to transportation) for any locations where pedestrians are most likely to be present;

Ensure clear roadways to allow transporters passage through geometrically constrained sections of the route. At strategic locations parking will need to be restricted at times of delivery; and

Develop contingency plan, in consultation with the police, to cover an event where an abnormal load becomes immovable on the public road, for any reason (for example, breakdown, un-anticipated route restriction, accident).

A driver’s induction for abnormal load vehicles will include: Safety briefing including detail of all contingency measures; The need for appropriate care and speed control; Identification of specific sensitive areas; and Clarification of identified route, the requirement not to deviate from this route, the requirement to adhere

to convoy system and pull over at pre-defined points to allow build up of traffic to pass.

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9.6.3 Site Traffic

The following points will apply to general site traffic: General site traffic and general construction traffic will not require the presence of an escort when

travelling to and from site; Drivers shall be aware of route and contingency measures as pre-defined at induction stage; Drivers of HGV are to be briefed in good road practice and will be instructed to pull over on narrow

sections of road to allow build up of traffic to pass; All general site traffic and construction vehicles, including concrete related deliveries, will run to

coincide with site working hours; Normal load construction vehicles will use a defined route, which will need to be agreed for each

construction phase; Signage will be kept to a minimum, however temporary direction signs indicating local routes to site and

site entrances will be required at strategic locations on local roads; The detailed signing arrangement will be agreed between the appointed contractor in close liaison with

the local municipality and the police service; Wherever possible, arrangements will be made for site workers to be transported to site via shared

transport to minimise unnecessary traffic movements locally; and The contractor will be required to implement induction procedures and regular up-dates for all drivers to

establish and promote an overall culture of safety and awareness of other road users.

9.7 Temporary Worker Accommodation Management Plan

This subsection presents a framework of the Temporary Workers Accommodation Management Plan to be elaborated and implemented by the EPC contractors and drilling contractors during construction. PGE will review and approve the EPC contractors and drilling contractors elaborated Temporary Worker Accommodation Management Plans for the construction phase of the Project. Temporary Worker Accommodation Management Plans will be developed for all new construction accommodation camps prior to them being inhabited as per either EPC or drilling contract requirements. These plans will be developed in accordance with international best practice guidance, as exemplified by “Workers’ accommodation: Processes and standards, a guidance note by IFC and the EBRD” (2009) and follow a standard format addressing the following: Assessment of the need for workers’ accommodation (availability of workforce, availability of existing

housing; and assessment of impacts of workers’ accommodation on communities including: Specific impacts during the construction phase; Community infrastructure; Community services and facilities; Local businesses and local employment; Community health and safety; Community cohesion; Land acquisition and resettlement; and Dismantling and reinstatement.

Demonstrating how national and international best practice standards for workers’ accommodation will be met in relation to: General living facilities; Room/dormitory facilities; Sanitary and toilet facilities; Canteen, cooking and laundry facilities; Standards for nutrition and food safety; Medical facilities; and

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Leisure, social and telecommunication facilities; Description of the management and monitoring approach, structure, roles and responsibilities of the

accommodation area in relation to: Management and staff structure; Charging fees for accommodation and services; Health and safety on site; Security of workers’ accommodation; Workers’ rights, rules and regulations; Consultation and grievance mechanisms; and Management of community relations.

These plans will be integrated with fire-fighting and safety response plans as elaborated under PGE’s SMK3LL framework for the Project.

9.8 Chance Finds Procedure

9.8.1 Overview

Effective protection of cultural heritage is based on an understanding of the key issues, appropriate assessment and the correct action to minimise damage or loss. As unknown features / objects could be encountered during works, in particular earthworks, a ‘chance finds procedure’ will be in place to stop works and require investigation by an archaeologist in case of such findings.

This section of the ESMP contains a ‘chance finds procedure’ for use by the EPC contractors and drilling contractors. PGE will consult with the relevant authorities (the Preservation of Archaeological Heritage Office (Balai Pelestarian Peninggalan Purbakala) and Archaeology Office (Balai Arkeologi)) to ensure that it is acceptable to them and that it complies with local and national regulations. Updates or amendments will be made by the EPC contractors and drilling contractors where appropriate.

9.8.2 Framework Chance Finds Procedure

9.8.2.1 Definitions

‘Chance finds’ are defined for the purposes of this procedure as physical cultural resources encountered unexpectedly during project implementation.

‘Physical Cultural Resources’ (PCR) are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, palaeontological, historical, architectural, religious, aesthetic, or other cultural significance. Their cultural interest may be at the local, provincial, national or international level.

9.8.2.2 Ownership

The ownership of any chance finds discovered on the Project will be determined by the Preservation of Archaeological Heritage Office (Balai Pelestarian Peninggalan Purbakala) and Archaeology Office (Balai Arkeologi) at provincial level. These agencies fall under the Archaeology Research and Development Centre and Directorate of Archaeology, which are at national level.

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9.8.2.3 Recognition

So that the contractor and employees such as equipment operators and supervisors on the Project can identify physical cultural resources, training will need to be given. Prior to commencement of works the EPC contractors and drilling contractors (in collaboration with PGE) will consult with the authorities mentioned above in order to arrange training for its employees. PGE will monitor this process to ensure that effective training is given to the correct members of the workforce.

9.8.2.4 Procedure Upon Discovery

Suspension of work: Upon discovery of physical cultural resources, the responsible contractor shall stop work (responsible

contractor will vary depending upon which Project component the find is associated with – e.g. EPC contractor for Power Plant area or SAGS EPC contractor for pipeline corridor area).

In some cases, all work will need to be suspended, in others just the work in the immediate vicinity of the find will need to stop, in others still, all work within a certain radius of the find must cease. This issue will depend on the type of find and will be informed by a qualified archaeologist.

After stopping work, the contractor must immediately report the discovery to PGE’s Project Manager. The contractor may not be entitled to claim compensation for work suspension during this period.

PGE’s Project Manager may be entitled to suspend work and to request from the contractor some excavations at the contractor’s expense if he thinks that a discovery was made and not reported.

Conditions and requirements for work stoppage: With the approval of PGE’s Project Manager (PM), the contractor is then required to temporarily

demarcate and limit access to the site, or, the PM may decide that the item can be removed and work may continue, for example where the item is a single coin of archaeological value.

Chance Find Report: The contractor will submit a Chance Find Report within one day of the find. This will record the

following information: Date and time of the discovery; Location of the discovery; Description of the PCR; Estimated weight and dimensions of the find; and Temporary protection that has been implemented.

The Chance Find Report will be submitted to PGE’s Project Manager, and other concerned parties as agreed with the provincial cultural authorities, and in accordance with national legislation (to be agreed upon submission of this Chance Finds Procedure to the provincial authorities for their comment/approval).

PGE’s Project Manager is required to inform the cultural authority immediately following the submission of the Chance Find Report.

9.8.2.5 Arrival and Actions of Cultural Authority

The cultural authority (Preservation of Archaeological Heritage Office) undertakes to send a representative to the discovery site, who will arrive within a stipulated time frame, such as 24 hours if all work has been suspended (details will be agreed between the authority, PGE and the contractor). The representative will determine the action to be taken which may include, but will not be limited to: Removal of the PCR(s) deemed to be of significance;

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Execution of further excavation within a specified distance of the discovery point; Extension or reduction of the area demarcated by the contractor.

These actions should be taken within seven calendar days of the representative arriving on site in the case of the suspension of works.

The contractor may or may not be entitled to claim compensation for work suspension during this period (to be elaborated by PGE within the tender documents).

If the cultural authority fails to arrive within the stipulated period (for example, 24 hours), PGE’s Project Manager will have the authority to extend the period by a further stipulated time.

If the cultural authority fails to arrive after the extension period, PGE’s Project Manager may have the authority to instruct the contractor to remove the PCR or undertake other mitigating measures and resume work. Such additional works can be charged to the contract. However, the contractor may not be entitled to claim compensation for work suspension during this period.

9.8.2.6 Further Suspension of Work

During this seven calendar day period (see above section on arrival and actions of cultural authority) the cultural authority may be entitled to request the temporary suspension of the work at or in the vicinity of the discovery site for an additional period of up to 30 calendar days or longer if deemed necessary.

The contractor may, or may not be, entitled to claim compensation for work suspension during this period (to be elaborated by PGE within the tender documents). However, the contractor will be entitled to establish an agreement with the cultural authority for additional services or resources during this further period under a separate contract with the cultural authority.

9.8.2.7 Resumption of Work

Following approval from the cultural authority (Preservation of Archaeological Heritage Office), PGE’s Project Manager will issue the contractor with the instruction to recommence works.

9.8.2.8 Review

PGE’s Project Manager will review the process and amend it as necessary to ensure efficiency and effectiveness of the chance finds procedure in the future.

Documents

Ulubelu 3&4 Revised ESIA Report - Volume IV · he K3LL existence, as an integrated part of the operations, is to support the implementation of the Oil, Gas and Geothermal objectives