ENVIRONMENTAL MANAGEMENT PLAN (EMP)

by | Mar 30, 2020 | Uncategorized

Environmental Management Plan (EMP) translates the pollution prevention and mitigation measures (P2M2s) proposed in the EIA Report and the approval conditions (COAs) into action.

The EMP document states in explicit terms what actions will be taken, what measures will be instituted, what structures will be built, what will be installed, when the actions will be executed; etc. to integrate the P2M2s into the project activities and to ensure that the project activities comply with the COAs.

By nature, the EMP is a living document that needs to be revised and updated when there are certain circumstances that require changes. These factors may include changes in the details of the project and surrounding areas and inadequacy of control measures to meet regulatory standards.

STEPS FOR EMP PREPARATION
First, the project proponent and the consultant responsible for preparing the EMP shall study and understand the pollution prevention and mitigation measures (P2M2s) recommended in the EIA Report and the EIA conditions of approval (COAs). Second, the Consultant shall specify for each P2M2 and COA, whether of an administrative or physical nature, the Consultant shall identify actions required to be executed in order to implement the P2M2s or comply with the COAs.

Third, for each of the executable actions, the Consultant shall calculate an estimated cost to incur. Fourthly, the Consultant must advise the Project Proponent (PP) on the executable actions to be taken and the consequences of the costs. Later, the PP shall make a declaration or pledge that all the actions stipulated in the EMP will be implemented.

The logical steps to be followed in the EMP preparations as outlined above are depicted in Table 1.

EMP PHASE
The Environmental Management Plan (EMP) is vital to give the Project Proponent a framework in order to mitigate effectively against any impacts which is significant and subsequently, rendering them to minimal, acceptable level which is stipulated by the State DOE (Department of Environment). The management plan covers construction and operation phases of the Project.
The EMP comprises of these following topics

1. Construction Phase

The purpose of a construction environmental management plan is to outline how a construction project will avoid, minimize or mitigate effects on the environment and surrounding area. Construction environmental management plans often detail the implementation of measures in accordance with environmental commitments outlined in; an Environmental Statement, an environmental policy or environmental plan, requirements of planning conditions or other legislative requirements. They are ‘live’ documents that are reviewed and updated at regular intervals throughout the project life cycle.

The purpose of a construction environmental management plan is typically to:

  • Highlight stakeholder requirements.
  •  Ensure that the development is compliant with current environmental legislation.
  •  Outline Environmental Management System requirements (in accordance with ISO 14001).
  • Detail the mitigation committed to within the Environmental Statement and how it will be
    implemented on site.
  • Ensure that any adverse effects are minimized during construction.
  • Describe any site-specific method statements required.

2. Operation Phase

Basically, the operation phase is a series of arrangements to secure an effective implementation of mitigation measures. These arrangements shall be communicated to the different levels of the EMP hierarchy i.e. from the consultants to the developer and finally to the operation project team (which comprise of the appointed contractors, technical staff and workers themselves). In particular, it is the systematic arrangement of pollution control measures during the operations phase to curtail potential pollution, which is the key focus

i. Commissioning Phase

The on-site management plan during pre-operations phase generally includes:

  • Traffic management scheme which specifies the approved haulage routes and includes inventory of daily trips in terms of frequency and nature of transport;
  • Maintenance programme to be established for pollution control structures (i.e. leachate treatment system), heavy vehicles and machinery and all erosion and sedimentation control elements are to be made regularly;
  • Training programme to be devised for on-site workers to include awareness of the requirements pertaining to good environmental practices i.e. minimize waste generation,proper disposal of waste material, observing on-site speed limits, practice standard safety procedures whilst working;
  • Health and safety management plan, which specifies and records health screening provisions and the respective medical results of on-site workers. This plan shall be integrated with the safety guidelines for the pre-operations workers.
  • Formulation and implementation of other plans as required by the Department of Environment before execution of works on-site. During the project implementation stage, developer shall:
  • Allocate administrative responsibilities for planning and managing the environmental requirements as outlined in the EIA Approval Condition.
  • Ensure the implementation of pollution prevention and mitigation measures (P2M2).
  • Implement a monitoring programme (i.e., Impact Monitoring, Compliance Monitoring and Performance Monitoring) to check the effectiveness of the mitigation measures provided.
  • Ensure that mitigation measures are incorporated in all relevant contract and design.

 

ii. Operational Phase

  • Implementation of the programmes, plans and schedules drafted during the preoperations stage.
  • Inventories of the input waste must be documented extensively with details of the waste supplier, the logistic route used, the transport provider and personnel involved all documented in manner that allows for immediate retrieval of data and for quick reference.
  • Regular maintenance and inspection of the equipment on-site to ensure that they are always in optimal operating condition. Records of maintenance and inspection must be available for reference at the office.
  • An Environmental Management Plan (EMP) must be drawn up and available at the plant/landfill site office. All employees must undergo initial induction training on safe environment management procedures and best practices prior to commencing work at the landfill expansion site.

 

PREPARATION OF LAND DISTURBING POLLUTION PREVENTION AND MITIGATIONMEASURES (LD-P2M2) TO BE INTERGRATED IN EMP REPORT

The LD-P2M2 document is a legal pledge made by the Project Proponent to take efforts, measures, actions, or due diligence in accomplishing the goal of protecting the environment and in mitigating the environmental impact in the process of implementation of the proposed development project. The LD-P2M2 provides guidance to Project Proponent’s personnel, in particular the Environmental Officer (EO), in overseeing the implementation of the LD-P2M2 which involves the installation, inspection and maintenance (2I’s1 M) of Best Management Practices (BMPs), and in preparing the required documentation and reports on (2I’s1 M). The LD-P2M2 focuses on prevention, mitigation and control of the discharge from the project site comprising the major pollutant (suspended solids) resulting from land disturbance activities.

The Guidance Document for the preparation of the document on Land Disturbing Pollution Prevention and Mitigation Measures (LD-P2M2) replaces the Guidance Document for the Preparation of Erosion and Sediment Control Plan (ESCP) issued earlier by the DOE. As part of the EMP application process, the Land Disturbing Pollution Prevention and Mitigation Measures (LD-P2M2) document must be attached to or incorporated into the EMP. In general, the following shall be prepared and provided in the EMP document.

FORMAT OF EMP
At a minimum, the EMP shall include the following chapters: Chapter 1 to Chapter 5. However, the scope and information addressed in Chapter 5 shall be tailored to suit the individual project, the pollution prevention and mitigation measures (P2M2s) recommended in the EIA Report, and EIA approval condition (COA). The EMP for prescribed activities falling under both Schedules (First Schedule and Second Schedule) of the EIA Order shall follow the general specifications and format and shall contain chapters 1 to 5 as explained below.

1. Chapter 1: Introduction

Provide information on:

  1. Project layout as approved in the Development Order by Local Authority.
  2. Project implementation schedule.
  3. Name of the EMP preparer and his consulting firm.

 

2. Chapter 2: Policy

  1. Company’s corporate policy statement on environmental management and protection.
  2. Commitment by the top management on the mainstreaming of environmental agenda and instilling of self regulation in the development project and on ensuring continuous compliance with the environmental regulatory requirements.

 

3. Chapter 3: Organizational Structure

  1. Organization chart of the company’s top management with responsibilities on environmental management and protection (provide names, positions, mobile phone contact numbers and e-mail addresses).
  2. Name, mobile phone contact number and e-mail address of environmental manager, environmental officer (EO), engineering consultant, contractor, site supervisor and competent person (wherever relevant and available).
  3. Name of environmental consultant and accredited laboratory conducting environmental monitoring, analysis of environmental samples and submitting reports to the DOE.

 

4. Chapter 4: Training Requirement

Plan for staff training in order to develop competency to discharge responsibilities on environmental requirements and compliance. The training areas shall include maintenance and performance monitoring of all P2M2 (LD-P2M2, IETS, APCS, STS, management of scheduled waste), wherever relevant.

 

 

5. Chapter 5: Environmental Requirements

    1. EIA Approval Conditions (COAs)
    2. LD-P2M2 document
    3. Pollution prevention and mitigation measures (P2M2) to be implemented.
    4. Water Pollution Control
      1. Water pollution control monitoring

        Water pollution control monitoring consists of performance monitoring (PM) of effluent treatment system (for treating sewage or industrial effluent), effluent discharge monitoring (Compliance monitoring-CM) and ambient water quality monitoring (Impact monitoring-IM). IETS or STS performance monitoring (PM) is compulsory, while ambient water quality monitoring covering areas beyond the boundary of project site may be required only on a case to case basis (IM). Proposed PM and CM program shall be prepared with details on parameters, the
        recommended ranges, monitoring frequency, field log sheets, data analysis and interpretation, and record keeping. For IM program, details on monitoring location, longitude and latitude, frequency, parameters, equipment, monitoring schedule, and personnel required shall be provided.

      2. Effluent treatment

        The following information shall be provided: proposed treatment technology; schedule for submission of Notification for new source of effluent discharge, design of IETS; recruitment of competent person and purchase of relevant equipment. The IETS shall be that which can be described as state of the art technologies or industry best practices.

      3. Temporary sullage and sewage treatment

        The following information shall be provided: proposal for the management and treatment of sullage and provision of temporary sewage facilities for workers shall be provided.

      4. Permanent sullage and sewage treatment

        The following information shall be provided: proposed treatment technology; schedule for submission of Notification for new source of sewage discharge, design of sewage treatment system (STS); recruitment of competent person and purchase of relevant equipment.

      5. Control of oil and grease, concrete wash, etc.

        The following information shall be provided: proposed methods of managing discharge of other pollutants, particularly oil and grease, and concrete wash effluent during the construction phase.

      6. Control of Air Pollution and Noise
        1. Air pollution control monitoring

          Air pollution control monitoring consists of performance monitoring (PM) of air pollution control system (APCS), air emission discharge monitoring (Compliance monitoring-CM), and ambient air quality monitoring (Impact monitoring-IM). APCS performance monitoring (PM) is compulsory, while ambient air quality monitoring covering areas beyond the boundary of project site (IM) may be required only on a case to case basis. Proposed PM and CM program shall be prepared with details on parameters, the recommended ranges, monitoring frequency, field log sheets, data analysis, and record keeping. For IM program, details on monitoring location, longitude and latitude, frequency, parameters, equipment, monitoring schedule, and personnel required shall be provided.

        2. Air pollution control

          The following information shall be provided: proposed control technology; schedule for submission of Notification for new sources of air pollution; design of air pollution control system (APCS); recruitment of competent person and purchase of relevant equipment. The APCS shall be that which can be described as “state of the art technologies” or industry best practices.

      7. Materials And Waste Management
        1. Raw materials and stockpiles.

          The following information shall be provided: proposal for the management of raw materials, including chemicals, fuels, etc., and stockpiles.

        2. Solid waste.

          The following information shall be provided: proposal for the management of solid waste during land disturbance and construction phase.

        3. Biomass.

          The following information shall be provided: proposal for the management of biomass during land clearing and construction phase.

        4. Spoils/dredge materials/construction waste.

          The following information shall be provided: proposal for the management of spoils/dredge materials/construction waste during land disturbance/earthwork and construction phase.

        5. Open burning.

          The following information shall be provided: Measures to prevent occurrence of open burning.

        6. Housekeeping.

          The following information shall be provided: proposal for implementing best practices in general housekeeping, including housekeeping of the vehicles and machinery maintenance area.

        7. Scheduled Waste Management

          The following information shall be provided: proposal for the management of scheduled waste to comply with Environmental Quality (Scheduled Waste) Regulations 2005 generated during construction and post construction stages.

        8. Emergency Response Plan (ERP)

          The following information shall be provided: name and contact details (mobile phone number, e-mail address) of the professional who has been tasked to prepare the ERP and the schedule for its preparation and submission to DOE.

        9. Abandonment And Closure Plan

          In a particular case where the project proponent intends to abandon a project whether it is in the construction stage or after it has started operation, an abandonment and closure plan shall be prepared. Decommissioning and closure plan is especially relevant to extractive industries such as minerals mining and oil and gas exploration and extraction.

        10. Declaration And Checklist

          The Project Proponent is required to make a declaration that all the actions/measures/plans outlined in the EMP. The form is required to be filled out and submitted to the DOE together with the EMP document.

References:
Department of Environment Putrajaya (2016, July 19). Guidance Document For Preparation And Submission of
Environmental Management Plan (EMP). Retrieved from http://eia.doe.gov.my/escv8/dokumen_esc/eiaemp_guidance_doc.pdf