environmental management plans

Diploma of Environmental Monitoring & Technology

Study module 6 Environmental Management Plans

Environmental

management systems

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EMS Study module 6 Environmental Management Plan

Chemical, Forensic, Food & Environmental Technology [cffet.net] Page | 1

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INTRODUCTION 2

ENVIRONMENTAL MANAGEMENT PLANS 2

What is an Environmental Management Plan? 2

The purpose of an EMP 2

Consultation 3

Contributors 4

Review of EMP’s 4

Types of EMPs 5

EMP STRUCTURE 5

Background 5

Environmental management 6

Implementation and operation 6

Monitoring and reviewing 6

IMPLEMENTING AN ENVIRONMENTAL MANAGEMENT PLAN 6

Where is the EMP? 7

Project management 7

Project staff 8

Environmental field technicians 8

PDCA – The Last Step 8

ASSESSMENT 12

Required knowledge questions 12

Assessment & submission rules 15

References & Resources 16

http://www.cffet.net/



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Introduction

Thus far into our journey of Environmental Management Systems we have discussed a

variety of topics including;

◗ defining environmental management in general

◗ why our society needs it

◗ the role of environmental planning

◗ the role of environmental protection, and,

◗ environmental management systems themselves

We are now at the ‘business end’ of the journey, which, in relation to the job role of an

environmental technician, all relates to the implementation of an Environmental

Management Plan (EMP).

Environmental Management Plans

What is an Environmental Management Plan?

An Environmental Management Plan (EMP) is a site or project specific plan developed to

ensure that appropriate environmental management practices are followed during a

project’s construction and/or operation.

It results from a once common criticism of the overall Environmental Impact Assessment

(EIA) process which claimed that once approval for a project had been given, proponents

turned a ‘blind eye’ to the environmental management of the project. The EMP became part

of the EMS and also, in NSW, part of the planning system, which has since given rise to

better environmental management of projects both during the assessment period and the

overall operating period of the project.

The purpose of an EMP

Project proponents, including government agencies, are often required to prepare a project

specific EMP as a condition of approval or consent. There is a reliance on the EMP to ensure

that a project’s actual environmental impacts are consistent with those evaluated in the

environmental impact assessment (EIA) process. The EMP is therefore fundamental to the

EIA process and should ensure that commitments given at a project’s planning and

assessment stage are carried out in the construction and/or operation stage.

An effective EMP should ensure:

◗ application of best practice environmental management to a project

◗ the implementation of a project’s EIA including its conditions of approval or consent

◗ compliance with environmental legislation, and




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◗ that environmental risks associated with a project are properly managed

EMPs are valuable tools to:

◗ define details of who, what, where and when environmental management and

mitigation measures are to be implemented

◗ provide government agencies and their contractors, developers and other

stakeholders better on-site environmental management control over the life of a

project

◗ allow proponents to ensure their contractors fulfil environmental obligations on

their behalf, and

◗ demonstrate due diligence

In addition, EMPs are often required as part of tendering for projects and are essential for

some types of government projects. In NSW, Parts 4 and 5 of the EP&A Act 1979 are all

relevant to the implementation of an EMP

A construction EMP is generally developed about the same time as the detailed design and

related activities are undertaken. Each process should influence the other. An operation

EMP should be developed before commencing operation of an activity or development.

The broad steps for the preparation of an EMP in relation to the post-approval process are

illustrated in the flowchart contained in Appendix A. The flowchart summarises the

implementation of environmental requirements for a project from approval or consent

through to construction, operation and decommissioning.

It is important to note that an EMP is a “living” document that should be focused on

continual improvement and should be updated as necessary.

Consultation

Specific impacts and associated environmental control measures may not be fully described

at the EIA stage of a project. For this reason, government agencies that have environmental

protection responsibilities may need to be consulted as part of an EMP’s preparation.

Any agency consultation undertaken at this stage should be limited to that required by

specific conditions, or clarify specific issues, or obtain other approvals, licences or permits.

Authorities that typically need to be consulted include:

◗ The Department of Environment and Heritage

◗ The Department of Primary Industries

◗ Department of Trade and Investment

◗ NSW Heritage Office, and




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◗ Local Councils

As well as any of the specific agencies related to the mentioned departments such as;

◗ NSW EPA

◗ NSW Office of Water

◗ Office of Resources and Energy

During the preparation of an EMP, all relevant parties should be consulted as early as

possible to facilitate a reasoned response. Community involvement in the EMP may also be

appropriate, depending on the type of project. Community liaison groups are often

established for larger projects.

These groups may comment on the specific environmental management measures to be

considered in an EMP. In all cases, the specific requirements arising from environmental

assessment and consultation should be established and defined as early as possible for

inclusion in the EMP.

Contributors

A project’s proponent (whether government agency, developer or industry) retains primary

responsibility for the environmental performance of its projects or activities. As such, the

proponent is responsible for ensuring the preparation, certification, approval and

implementation of an acceptable EMP whether for construction or operation.

During a project’s construction and/or operation the preparation and implementation of an

EMP is often passed onto a contractor by a contract specification. While an EMP might be

prepared and implemented by a contractor the responsibility for implementing the

conditions of approval or consent lies with the proponent.

Conditions of approval or consent generally require that an EMP be approved before

commencing construction and operation. The time required to obtain an approval often

depends on the quality of the documentation provided.

The certification and approval requirements for an EMP should be recognised before the

document is prepared to ensure that sufficient time is allowed.

Review of EMP’s

An EMP is not static. It is a working document that requires review and amendment during

the life of a project. Making changes to an EMP is an important aspect of improving a

project’s environmental management. The EMP review process is also a valuable means of

continually improving the effectiveness of current and future EMPs.

Review timings depend on the nature and scale of the project but would typically be




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undertaken:

◗ when there is a change in the scope of the project

◗ following significant environmental incidents

◗ when there is a need to improve performance in an area of environmental impact

◗ at the completion of environmental audits, and

◗ at the end of a project (to allow for improvements in subsequent projects).

The review process should include looking at the environmental controls and procedures in

use to make sure they remain effective. Reasons for making changes to the EMP should be

documented. A copy of the original EMP document and subsequent versions should be kept

for the project records.

The EMP should state under what circumstances an updated EMP should be resubmitted to

an approval or consent body, for review and approval. A requirement to submit updated

EMPs to the relevant authority may also be stipulated in conditions of approval or consent.

Types of EMPs

EMPs can be prepared at different times in a project’s life. Usually these are prepared as:

◗ Construction EMPs (CEMPs)

◗ Operation EMPs (OEMPs)

CEMPs are developed to ensure that appropriate environmental management practices are

followed during a project’s construction. OEMPs are developed to ensure that appropriate

environmental management practices are followed during a project’s operation and

decommissioning.

EMP Structure

The exact structure of an EMP will be determined by the project’s potential size and impacts

on the environment. The basic structure of an EMP would be to include all temporal aspects

from the background or planning phase right through to continuous operation of shutdown

and rehabilitation (if the project has a known deadline). DIPNR (2004) suggest that the four

elements of the EMP structure would include (but not restricted to) background,

environmental management elements, implementation and operational elements, and

finally monitoring and reviewing programs.

Background

The background information collected would provide introductory information about the

project and possibly about the EMS as well in general, a detailed description of the project,

the scope and context of the EMP, a clearly stated set of EMP objectives and include an

environmental policy which explains the projects or proponents charter for the




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environment.

Environmental management

This section would detail the management structure, roles and responsibilities of the key

personnel, a detailed statement of environmental compliance and licensing arrangements,

all significant internal and external reporting requirements including incidents, aspects of

environmental training for staff and contractors training or skill requirements, as well as an

environmental emergency management plan including key contacts and response

procedures.

Implementation and operation

During the implementation and operation of the project a focus on environmental hazard

identification, risk assessment & control (HIRAC) is required, procedural management

activities and controls, environmental monitoring plans, maps and procedures are required

as well as any scheduling information contained therein. This is paid particular attention in

the next section.

Monitoring and reviewing

All of the above aspects require procedural and activity based reviews and audits to identify

problems and provide mechanisms for corrective action to be taken.

Implementing an Environmental Management Plan

So what is the relationship between an EMP and the work that an environmental technician

does for a living? The answer is simple, the EMP outlines how a an organisation will manage

and mitigate environmental harm, which needs to be monitored, which requires data, which

the environmental technicians collect through sampling and testing of environmental

samples.

The specific role of the technician depends on the company. Some will focus on air, water

and soil, whilst others can focus on ecology, biodiversity and heritage issues. Our focus is on

the air, water and soil side as this course is based on environmental technology.

Environmental technicians don’t simply go to work, grab an EMP and then go sampling. As a

matter of fact, most technicians would not have even seen an EMP, and that’s the problem

– how to relate the EMP with the work performed, so now we need to position the EMP in

context to the technician.

How an EMP is implemented depends on the organisation it belongs to, and as such is a

difficult thing to explain. What follows is a brief explanation of the implementation process,

you will actually learn how it is done by an assignment.




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Where is the EMP?

That is best introduced by the use of an image. Figure 6.1 below shows how the work that a

technician does can relate to different aspects of a job.

An explanation of the above flowchart is required. The flowchart is an attempt to relate the

work done by field technicians to the various phases of development and is structured as

follows;

◗ The top row is the phase of development

◗ The second row is the key legislative triggers

◗ The third row is the key reporting or management documents used

◗ The fourth row shows key licences that commonly apply to a project

◗ The last two rows show data analysis and the sampling and testing

Most assessors would be very impressed if the technician could draw an accurate flowchart

showing the precise documents that were involved from the sampling to the phase of the

project simply because everything in the first three rows is usually ‘invisible’ to the

technician. The purpose of this study module is to make these visible.

As can be seen, the precise location of the EMP depends on the phase of development being

considered at the time, but the implementation of an EMP is essentially the same

regardless.

Also remember that by the time an EMP is being implemented, all of the background work

has been done, so the knowledge of the environment surrounding the project is extensively

understood. All that is required is for the work outlined by the EMP to be started.

Project management

The Project Manager is the person or team of people who run the project from the top.

They make strategic decisions based on overall project requirements.

These people deal with their counterparts in government and industry, and as such can be

involved with several high ranking people. The strategic decisions they make can have

massive impacts on the ground, such as whether a project continues or not.

Management work is that work undertaken by the project managers and includes;

◗ Requesting or submitting tenders for work

◗ Determining project staff requirements

◗ Communicating with stakeholders at higher levels

◗ Drawing up timelines for actions




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◗ Ensuring quality

Generally speaking, following the PDCA cycle as outlined in the Australian Standards for

Environmental Management Systems (EMS). We won’t speak any more of the project

manager’s job role here.

Project staff

The role of the project staff is to act as middle men for the project implementation. These

people (which usually range in experience and qualification from senior technicians to

project specialists such as managers, scientists and engineers) are the coordinators of action

and perform functions that include;

◗ Determining the internal project requirements (i.e. equipment, vehicles etc)

◗ Drawing up management documents such as Sampling & Analysis Plans

◗ Communicating directly with stakeholders such as laboratories and landholders

◗ Organising GIS and mapping information

◗ Keeping all information up-to-date for audits

And the list goes on.

Environmental field technicians

The fieldwork is obviously different, and effectively forms the basis of this entire course. The

implementation role of the field technician is quite simply to perform all outlined fieldwork

in accordance with the organisational or enterprise requirements to an acceptable level of

quality and do so safely. To do this effectively, this requires;

◗ Initial site visits to identify sites and field conditions

◗ Ensuring transportation capabilities

◗ Organising (client side) or participating in (consultant side) inductions

◗ Collecting sample bottles and ensuring laboratory requirements are met

◗ Undertaking fieldwork on a routine basis

◗ Collecting sample, site and field test data

◗ Performing data techniques related to DQO

Any other specialist activities related to specific work.

PDCA – The Last Step

And now that the cycle has been completed, we step back and look at the role of the EMP in

EMS and see that the PDCA cycle has almost gone full turn. What happens now is a review

of all aspects of the management and implementation of the EMP, from the general

management, through to compliance, and finally ending on procedures and documentation




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which all ensure that the data collected complies with the requirements of the

project.When the review is complete, recommendations are implemented and the whole

process starts again, or at least continues on its new and improved path.




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Figure 6.1 – An example of environmental management in NSW, relating the implementation of various EMPs to the ‘bigger picture.

DEVELOPMENT PHASE PLANNING CONSTRUCTION OPERATION SHUTDOWN REMEDIATION

Legislative triggers >>

LEP's, SEPP's, EP&A Act, EPBC

Act, POEO Act, Specific

industry Acts

EP&A Act, POEO Act NEPMs, POEO ActEP&A Act, POEO Act amongst

others

EPBC Act, SEPP 55, NEPMs,

EP&A Act, CLM Act, amongst

others

Licenses & Conditions >> Planning consent conditions EPL & consent conditions EPL, TWA, amongst othersEPL, planning consent

conditions

Consent conditions (hihgly

variable)

Management Plans >> SEE, REF, EIS, SIS & other

environmental assessments(C)EMP, PIRMP (O)EMP, PIRMP (C)EMP, PIRMP

RPA, MREMP, Rehabilitaiton

Plans

Implementation >>

Fieldwork >>

Laboratory Analysis >>

Data Treatment >>

Impact Assessment >>

Checklists and matices(scaled

and weighted), modelling and

GIS

Measured against planned

targets and objectives

MANAGEMENT PHASEENVIRONMENTAL IMPACT

ASSESSMENT

ENVIRONMENTAL

REHABILITATIONENVIRONMENTAL PROTECTION COMPLIANCE

AIR (Dust gauges, TSP, PM10, PM2.5, Odour), STATIONARY SOURCES (particulates and gases), WATER (grab, depth and composite for surface, groundwater

sampling & testing), SOILS (Contaminated site and natural resources sampling of pits, cores), BIODIVERSITY (Fauna and flora surveys and assessments), NOISE

(Environmental and occupational noise and vibration assessment),

Cations (Na, K, Ca, Mg), Anions (NO3-, SO42-, PO4

3-, Cl-, CN-) Heavy metals and metalloids (Pb, Hg, Cd, Sn, Cr, As), NOM, BOD, COD, TSS, TDS, TPH, BTEX, PAH,

PCBVOC, Pesticides and herbicides, other regulated organics

Data Quality Objectives (DQO), Workplace Health & Safety (WHS) requirements, Sampling plans, laboratory requirements and Chain of Custody (CoC) etc,

Stakeholder consultation, Staffing requirements, Time management.

Data cleaning (to match DQO), Descriptive statistics, graphical techniques, ANOVA, ARIMA, ecological and biodiversity statistics and indices, incorporation into

GIS systems and displays

Compartitive techniques against impact baselines and licence condition criteria. EPA will be

Load and Risk based as of June 2015

An overview of Environmental Management in NSW




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Figure 6.2 – Post approval EMP flowchart from the DIPNR EMP Guidelines (available from the cffet website)




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Assessment

Required knowledge questions

This section provides formative assessment of the theory. Answer all questions by typing

the answer in the boxes provided. Speak to your teacher if you are having technical

problems with this document.

◗ Type brief answers to each of the questions posed below.

◗ All answers should come from the theory found in this document only unless the

question specifies other.

◗ Marks shown next to the question should act as a guide as to the relative length or

complexity of your answer.

1. Very briefly, in your own words, remind your assessor of the inevitable consequence of

human society not being sustainable. [1mk]

Click here to enter text.

Assessor feedback

2. Generally speaking, and in your own words, what is the difference between the concepts

of ‘sustainability’ and ‘environmental management? [2mk]


Assessor feedback

3. List the three types of decisions that data collected by environmental technicians can be

used in making. [1mk]


Assessor feedback




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4. What are the two main reasons for monitoring of the environment? [1mk]


Assessor feedback

5. Generally speaking, environmental law falls into two categories of reasons. List these

reasons. [1mk]


Assessor feedback

6. Under which agreement was governmental environmental responsibility determined?

[1mk]


Assessor feedback

7. List the three major drivers that determine Commonwealth environmental

responsibility. [1mk]


Assessor feedback

8. Identify two State level environmental responsibilities under the IGAE. [1mk]





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Assessor feedback

9. Although the Local tier of government is not constitutional, how was local Government’s

environmental responsibility defined under the IGAE? [2mk]


Assessor feedback

10. Generally speaking, what is the difference between an ‘Act’ and a ‘Regulation’? [2mk]


Assessor feedback

11. What is the Court’s role in environmental management? [2mk]


Assessor feedback

12. Identify the key planning and protection legislationat both the Federal and State (NSW)

tiers of Government (four acts all up) [1mk]


Assessor feedback




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Assessment & submission rules

Answers

◗ Attempt all questions and tasks

◗ Write answers in the text-fields provided

Submission

◗ Use the documents ‘Save As…’ function to save the document to your computer

using the file name format of;

Yourname-EMS-SM1

◗ email the document back to your teacher

Penalties

◗ If this assessment task is received greater than seven (7) days after the due date, it

may not be considered for marking without justification.

Results

◗ Your submitted work will be returned to you within 3 weeks of submission by email

fully graded with feedback.

◗ You have the right to appeal your results within 3 weeks of receipt of the marked

work.

Problems?

If you are having study related or technical problems with this document, make sure you

contact your assessor at the earliest convenience to get the problem resolved. The contact

details can be found at;

◗ www.cffet.net/env/contacts




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References & Resources

References

You are not required to read these references unless the question you are answering

requires it. Note that some of these resources might be available from the links provided in

the resources (below), your teacher or the library.

Bates, G. (2010). Environmental Law in Australia. Australia: LexisNexis-Butterworths. EDO, NSW. (2005). Environmental law Toolkit - NSW. 5th Ed. Sydney, Australia: The

Federation Press. Farrier, D. (. (2011). The Environmental Law Handbook. Sydney: Thomson Reuters. Fisher, D. (2010). Australian Environmental law: norms, Principles and Rules. Australia:

Lawbook Company. Lipman, Z. E. (2009). Environmental and Planning Law in New South Wales. Sydney,

Australia: The Federation press. StandardsAustralia. (2004). AS/NZS ISO 14001:2004 Environmental Management Systems:

Requirements with guidance for use. Australia: Standards Australia.

Resources

◗ Information on environmental law can be found at the EDO here.

◗ Current Commonwealth legislation can be found here.

◗ Current State legislation can be found here.

◗ NSW environmental planning materials can be found here.

◗ NSW environmental protection information (EPA) can be found here.

◗ Commonwealth EPBC Act website is here.

◗ Local Government information can be found here.


http://www.edonsw.org.au/

http://www.comlaw.gov.au/

http://www.legislation.nsw.gov.au/

http://www.planning.nsw.gov.au/

http://www.epa.nsw.gov.au/

http://www.environment.gov.au/topics/about-us/legislation/environment-protection-and-biodiversity-conservation-act-1999

http://www.lgnsw.org.au/

environmental management plans

Documents

environmental legislation

environmental technician

project management

role of environmental

food environmental technology

project specific emp

emp project proponents

project specific plan