Environmental Management Plan
Background
Environmental Impact Assessment has made commitments to:
– Meet defined standards– Implement defined mitigation measures– Limit defined impacts– Monitor compliance and environment
Approval will include these as conditions to be attached to consents.
Environmental Management Plan: Implementation Plan for meeting Commitments and Conditions of Consents
1. Regulators think in terms of environmental compartments – consent organised in terms of Air, Water, Waste.
2. Operators think in terms of Activity – Management Plan organised in terms of operation and management structure.
Objective
• A stand alone tool for the management of potential adverse impacts and to enhance project benefits
• Activity based mitigation of impacts identified in the ESIA
Responsible Parties
• Each Phase of the project will be implemented by different groups– Construction: Contractors– Operations: Company/outsourcing
• HSE will not be the main focus of each groups activity• Expertise in HSE may be lacking
Barriers to Implementation
1. Clear definition of Responsible Parties
2. Clear communication of requirements
3. Clear definition of KPIs, monitoring & reporting
4. Clear definition of consequences of non-compliance
5. Irregular or inappropriate internal checks (audits)
6. Not included in tender documents – contracts
Content of Environmental Management Plan1. Targets and Standards2. Procedures
– Activities– Aspects– Mitigation– KPIs– Reporting
3. Organization and Responsibilities4. Monitoring and Reporting5. Auditing6. Management Review7. Specific Plans
Targets and Standards– Taken from consents & company requirements
– Emissions and effluent standards
– Environmental Quality standards
– Frequency of monitoring
– Reporting requirements
Procedures
Day to day operations– Organized by Activity
– Lists impacts
– Defines mitigation measures
– Defines KPIs
– Define what is to be reported and when
Basis of audit protocols
Activity Target Landform
Backfilling And Restoration Topsoil Desert
Impact
If topsoil is not replanted, there is potential for loss through erosion.If original or indigenous species are not used for replanting, there is potential for the introduction of opportunistic or invasive species.Advanced survey work will need to identify the exact nature of the desert soil structure. If a hardpan is present it will need to be re-created to prevent serious erosion.
Mitigation
Minimum Requirements Reference TS/02/DE/01
Spread topsoil evenly during backfilling and restoration. Topsoil must be spread evenly over the disturbed ground by backhoe, bulldozer and/or grader and compacted.Wet the topsoil may to minimise wind dispersion, and to assist compaction. Stabilise the replaced topsoil to prevent erosion using mulch, straw matting, chipped vegetation or other.Revegetate using native plants or crops. (The intention is that in areas of agricultural land this will be undertaken by the farmers who previously cropped the land).
Decision Tree
Not applicable
Example Protocol
Performance Indicators
Action Level: 1 – stop Work-report; 2 – Fix & Report Immediately; 3 – Fix & Report Same Day; 4 – Monthly Report
Parameter Compliance
1 2 3 4 Report ing
1 Desert soil replacement replanting within one month of backfilling
Yes/No Monthly
2 Stabilisation in place Yes/No Monthly
3 Appropriate revegetation in place Yes/No Monthly
Reporting
Content By To Frequency
Monthly site visits HSE inspectors
PJV Monthly
Organisation and Responsibilities
– Who is accountable?
– Who is responsible for each activity?
– Tendering and Contracting
– Reporting Lines
Monitoring and Reporting
As per Management Plan Requirement
Refer to Environmental Monitoring Plan
Auditing
Compliance:– To assess performance of operations against targets
– QA/QC of monitoring programme
– Check on documentation and recording
– Check on equipment
Scope reflected in protocols
Management Review
Review teamFrequencyScope:
Review of results of KPIs and internal auditsResponse to exception reporting (including non-compliance)Response to and investigation of incidentsResponse to complaintsUpdating EMP for changes in regulationsTraining reviews
Specific Management Plans
References to Stand Alone Plans, e.g.
Solid Waste Management Plan
Hazardous Waste Management Plan
Occupational Health and Safety Plan
Emergency Response
Human Resources and Training Plan