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