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Environmental Management Plan
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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.
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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.
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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
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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
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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
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Content of Environmental Management Plan 1.Targets and Standards 2.Procedures –Activities –Aspects –Mitigation –KPIs –Reporting 3.Organization and Responsibilities 4.Monitoring and Reporting 5.Auditing 6.Management Review 7.Specific Plans
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Targets and Standards –Taken from consents & company requirements –Emissions and effluent standards –Environmental Quality standards –Frequency of monitoring –Reporting requirements
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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
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Activity TargetLandform Backfilling And Restoration TopsoilDesert 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 ReferenceTS/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
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Performance Indicators Action Level: 1 – stop Work-report; 2 – Fix & Report Immediately; 3 – Fix & Report Same Day; 4 – Monthly Report ParameterComplianc e 1234Report ing 1Desert soil replacement replanting within one month of backfillingYes/NoMonthly 2Stabilisation in placeYes/NoMonthly 3Appropriate revegetation in placeYes/NoMonthly Reporting ContentByToFreq uen cy Monthly site visitsHS E insp ecto rs PJVMo nthl y
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Organisation and Responsibilities –Who is accountable? –Who is responsible for each activity? –Tendering and Contracting –Reporting Lines
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Monitoring and Reporting As per Management Plan Requirement Refer to Environmental Monitoring Plan
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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
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Management Review Review team Frequency Scope: Review of results of KPIs and internal audits Response to exception reporting (including non-compliance) Response to and investigation of incidents Response to complaints Updating EMP for changes in regulations Training reviews
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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
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