Approach in Developing Environmental Management Plan (EMP) : Abstract
Approach in Developing Environmental Management Plan (EMP) : Abstract
Approach in Developing Environmental Management Plan (EMP) : Abstract
Baby, S.
GEO Environmental Consultation, Hawally, P. O. Box: 677, Al-Surra 4507, Kuwait.
Contact Email: sajimathewvk@hotmail.com
Abstract. The paper documents the Environmental Management Plan (EMP) developed during the
Environmental Impact Assessment (EIA) studies conducted for road construction and upgrading in the ‘State
of Kuwait’. The Environmental Management Plan (EMP) plan was developed based on the baseline studies,
impact assessment, impact evaluation and complying with KEPA (Kuwait Environmental Public Authority)
guidelines and standards. The paper gives a framework for developing EMP and the components that should
be included in the plan. The main components of EMP are: (i) Mitigation Program (ii) Monitoring Program
(iii) Recommendations and (iv) EMP Implementation Program. The EMP should consist of cost estimates for
monitoring program, equipment procurement, manpower, transportation, office cost, studies, reporting,
stationeries, etc. EMP Implementation Program consists of ‘Environmental Supervision Plan’ which is an
important instrument to ensure effective implementation of ‘Environmental Management Plan’. In this paper
the recommendations that are suggested are specific to the project and geographical conditions in the State of
Kuwait. The vital active part of EMP is EMP implementation and execution program.
Keywords: Environmental Impact Assessment, Emergency Response Plan, Health and Safety
1. Introduction
Environmental Impact Assessment has become an increasingly well-known environmental management
tool as a result of demands that is mounted on companies and industries to advance upon their environmental
performance. It is now a common tool in the developed nations and is increasingly being functional in
developing countries by overseas and local investors. It is applied to a variety of industrial and business
activities; from small through medium to large scale concerns. However, it is noticed in many of the
countries and in the State of Kuwait that most of the environmental impact assessment (EIA) practice
appears to be directed at the scoping and assessment stages of EIA’s. The mitigation, monitoring and
management components of EIA’s receive less attention at formulating and implementation level. Recently,
attention is being focused on the need to demonstrate that impacts can be monitored and managed. The
Environmental Management Plan (EMP) is the plan constructed during the process of EIA that provides a
description of the methods and procedures for mitigating and monitoring impacts. EMP promotes the
awareness and use of best practice environmental management by site operatives during construction and
operative phase (Rizzolo, 2006).
The EMP document can be used throughout the project life cycle – commissioning, mobilization &
construction, operation & maintenance and decommissioning. It is regularly updated to be aligned with the
project progress from commissioning to mobilization to construction to operation to decommissioning.
EMP’s outline the environmental impacts, the mitigation measures, roles and responsibilities, timescales and
cost of mitigation. EMP is a practical and achievable plan of management to ensure that any environmental
impact during all the phases is minimized and lead in the direction of sustainable development.
An important objective of environmental assessment is to develop procedures and plans to ensure that
the mitigation measures and monitoring requirements approved during the environmental compliance review
will actually be carried out in subsequent stages of the project. Mitigation measures may then be of a more
generic nature without compromising its importance to be implemented. The EMP is a dynamic and flexible
document subject to review and updating. During the implementation of a project there is always the
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possibility that unforeseen issues could arise, this EMP should therefore be revised where necessary to
mitigate unanticipated impacts.
The study shows an EMP is developed to outline measures that are to be implemented in order to
minimize adverse environmental degradation associated with the construction and upgrading of road in the
State of Kuwait. It serves as a guide for the contractor and the workforce on their roles and responsibilities
concerning environmental management on site (Saiccor, 2008), and it provides a framework for
environmental monitoring throughout the development period. The EMP was developed based on the KEPA
(Kuwait Environmental Public Authority) guidelines and standards.
Purpose of the EMP:
• Encourage good management practices through planning and commitment to environmental issues
concerning any project;
• It tells how the management of the environment is reported and performance evaluated periodically;
• To provide rational and practical environmental guidelines that will assist in minimizing the potential
environmental impact of activities;
• Helps in minimizing disturbance to the environment (physical, biological and ecological, socio-
economic, cultural, and archeological,) ;
• Combat all forms of pollution through monitoring air, noise, land, water, waste, and energy and
natural resources;
• Protection of sensitive and endangered flora and fauna;
• Prevent land degradation;
• Comply and adhere to all applicable laws, regulations, standards and guidelines for the protection of
the environment;
• Adopt best practicable waste management for all types of waste (liquid and solid) with objective on
prevention, minimization, recycling, treatment or disposal of wastes;
• Describe all monitoring procedures required to identify impacts on the environment;
• Train and bring awareness to employees and contractors with regard to environmental obligations and
compliance.
• Reduce environmental risk and provide better Health, Safety and Environment (HS&E)
• Increase efficiency through minimum consumption and conservation of energy deplete-able resources
• An EMP also provides with a plan answering - what, where, when, how and who?
• Establishing the reporting system to be undertaken during the construction.
• The EMP also serves to highlight specific requirements that will be monitored during the
development and should the environmental impacts not have been satisfactorily prevented or
mitigated, corrective action will have to be taken.
2. Environmental Management Plan
Definition of an “Environmental Management Plan”: A plan or program that seeks to achieve a
required end state and describes how activities, which have or could, have an adverse impact on the
environment, will be mitigated, controlled, and monitored during the commissioning, mobilization,
construction, operation, maintenance and decommissioning of a project; and that the positive benefits of the
projects are enhanced.
EPA, 2005 states that EMP is the action an organization is taking to determine how it affects the
environment, complies with regulations, keeps track of environmental management activities, and meets
environmental goals and targets. It also documents key elements of environmental management including the
environmental policy, responsibilities, applicable standard operating procedures and Best Management
Practices (BMP), record keeping, reports, communication, training, monitoring, and corrective action.
The EMP features the "Plan, Do, Check, Act" model (EPA, 2005) for ongoing improvement:
• Plan - Planning, including identifying environmental impacts and establishing environmental goals.
• Do - Implementing, including employee training and establishing operational controls.
• Check - Checking, including auditing, monitoring and taking corrective action.
• Act - Reviewing, including progress reviews and taking action to make needed changes.
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Fig. 1: EMP Cycle (Source: EPA, 2005)
Environmental management is easier if you have an EMP, because it will help you better track your
environmental management activities and implement them in a more organized and streamlined manner.
An EMP gives you a framework (EPA, 2005) in which to:
• Comply - Assist you in assessing compliance with environmental regulations
• Improve - Allow you to identify opportunities for improvement and cost savings
• Know - Decrease costly confusion for your employees by spelling out exactly what is expected of
them.
3. Approach
The EMP is most effectively developed when impacts are evaluated followed by detailed EIA completed
with supporting baseline studies for the project and site. Impact evaluation signifies the importance for the
mitigation measures suggested during the impact analysis or assessment (IA). The residual impact estimated
with execution of proposed mitigation measures is vital towards developing EMP. This EMP details the
mitigation measures to prevent, reduce and where possible offset any significant adverse effects on the
environment throughout the different phases of the project (Magnox North Ltd., 2009). EMPs are therefore
important tools for ensuring that the management actions arising from Environmental Impact Assessment
(EIA) processes are clearly defined and implemented through all phases of the project life-cycle (Lochner,
2005).
Figure 1 shows the steps in the EIA and when EMP is prepared. The main components of EMP are:
1. Mitigation Program
2. Monitoring Program
3. Recommendations
4. EMP Implementation Program
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EMP adopted for roadways project was precautionary approach, or in the case of management
recommendations, a philosophy of ‘best practice’. The EMP considers the institutional arrangements for
implementation. Responsibilities for mitigation and monitoring were defined along with arrangements for
information flow, and for coordination between agencies responsible for mitigation. The developed EMP
specifies the organizations and individuals that will be responsible for undertaking the mitigation and
monitoring measures, e.g., for enforcement of remedial actions, monitoring, training, and financing.
4. Developed Environmental Management Plan (EMP)
The EMP plan was developed based on the KEPA (Kuwait Environmental Public Authority) guidelines
and standards. EMP is developed to mitigate the negative impacts and enhance the positive impacts which
was investigated during the studies of baseline conditions, impact assessment and evaluation for the project.
The below EMP is developed for road construction and upgrading. Similar EMP plans were developed by
the author for various other EIA projects (WES 2007, 2009a, 2009b, 2009c, 2010a, 2010b, 2010c and GEO
2011a, 2011b). The below EMP is one among them and is specific to roadways construction project.
4.1. Potential Impacts and Mitigation Programs
Table 5.1 and 5.2 depicts mitigation measures and monitoring programs for different phases of the
project considering the potential impacts.
Table 1: Pollution Impacts and Mitigation Programs
Type of
Location of Pollution Major Pollutant
Pollution Pollution Sources Treatment Measures Applicable Standards
Sources or Parameter
Source
Construction sites; access construction sites and exposed earth surfaces; KEPA and Municipality
Blasting; construction
roads and surrounding TSP, NO2, SO2 use of vehicles covers; vehicle and equipment standards and
machinery and vehicles
Phase
construction equipment and workers camp petroleum water bodies; wastewater from equipment and
Wastewater
regulations
vehicles, Workers camp vehicle washing treated with settling ponds
Phase
workers camps; staff refuse and walls greening; refuse collected and transported standards and
workers and staff daily
quarters construction waste to local landfill sites. regulations
living
Phase
International standards
Phase
Operation
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BOD = Biochemical Oxygen Demand, COD Chemical Oxygen Demand, dB = Decibel, m = Meter,
NOx = Nitrogen Oxides, NO2 = Nitrogen Dioxide, SO2 = Sulfur Dioxide, TSP = Total Suspended
Particles, TSS = Total Suspended Solids.
Environmental Monitoring plan is reported in the table below for construction and operation that is prone
to bring adverse impact on to the environment and its activities.
4.2. Environmental Monitoring Programs
Table 2: Details of Environmental Monitoring Program
Frequency (When)
Cost
Monitoring Parameter Location Responsibility
How Why Estimates
Scope (What) (Where) (Who)
Construction Operation
Air TSP, NOx, SO2, Along the road Field Measurement Monthly for 3 Biannual Contractor &
CO route, especially Portable Gas Must not exceed K- consecutive Management
concentrating Analyzer, Air EPA guidelines days
on populated Mobile Lab
and sensitive
area
Wastewater TSS, COD, Effluent outlets, Laboratory Must not exceed K- Monthly for 3 Monthly Contractor &
and surface BOD, DO, pH, local drinking Analysis EPA guidelines consecutive Management
water, Oil, Phenol water supply days
domestic, sources;
irrigation, important water
drinking water bodies
Noise dB Construction In situ Must not exceed K- Monthly for 3 Quarterly Contractor &
area and Measurements. EPA guidelines. consecutive Management
Sensitive spots Portable According to WB days
noise/sound meters guidelines Noise
Day and night level must not exceed
measurement 70 dB.
Solid Waste Demolition Disposal sites In-situ observation Avoid Quarterly Biannual for Contractor,
waste, earth Contamination. first two years, Management &
materials; Slag, Proper collection, then annual Municipality
domestic refuse, disposal and thereafter
metallic scraps, treatment
sludge
Spoils Material Entire road Visual inspection Resource Biweekly Twice a year at Contractor,
resources alignment conservation start and end of Management &
season Municipality
Energy Electricity, fuel, Site, vehicles, Inspection, Save resources and Every day or Every day or Contractor,
gas, etc. labor camp, Energy efficient avoid wastage Periodically Periodically Management
offices system monitoring the monitoring the and Energy
Maintenance, consumption of consumption of Auditors
electricity energy may be energy may be
consumption monthly basis. monthly basis.
awareness, limiting
unwanted use of
electricity and fuel
Soil erosion Land degradation Entire road Technical Avoid loss of soil by Biweekly Biannual Contractor,
alignment inspection erosion, lead to high Management,
risk level, Municipality &
undesirable accretion Relevant
Ministry
Public safety Signs, culverts, Entire road Hazard and HSE Safety of people and Monthly Quarterly for Contractors and
public safety alignment inspection, and workers the first ear, Management
records implementation of then annual
safety measure, thereafter
PPE (personal
protective
equipments)
Natural Scenic Animal Species, Desert Visual Aesthetic Merits and concerns Monthly Biannual Contractors,
Beauty vegetation and Landscape Inspection of Psychological Management &
natural impact Kuwait
Landscape Agriculture, and
Landscape
Planner
Land Compensation, Relocated Government, Adhere to Before the Depends upon Relevant
acquisition and income, housing, families and concerned government land project concerned Ministry, land
population employment, receiving organization and acquisition laws, acts commences authority and revenue,
resettlement social adaption communities Administrative and notices Municipality,
Procedures Public Works
Health, Safety Human, property Site, Safety measures, For Protection of All the time All the time Contractors
& and environment Surroundings Personal Protective Life (at first) and during the during the during
Environment and workers Equipments, second Environment mobilization, operation and construction and
(HS&E) camp Mentioned in HSE and Third property. construction, of maintenance of maintenance.
Plan Adhering to Safety the road the road Government
rules for construction during the
works, rules for operation
handling hazardous
material, operating
risk based
equipments, safety
for roads, driving and
signals etc.
BOD = Biochemical Oxygen Demand, CO = Carbon Monoxide, COD Chemical Oxygen Demand, dB = Decibel, DO =
Dissolved Oxygen, EPB = Environmental Protection Bureau, EPMO = Environmental Protection and Management Office,
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LAR = Land Acquisition and Resettlement, NOx = Nitrogen Oxides, pH = Measure of Acidity/Alkalinity, SO2 = Sulfur
Dioxide, TSP = Total Suspended Particles, TSS = Total Suspended Solids.
4.3. Recommendations
Following recommendations are provided based on the baseline studies done for the road project in
Kuwait (arid environment) with in EIA studies:
4.3.1 Sensitivity of Sabkha / Low-lying wetland
Proper consideration should be given while constructing on sabkha/ low-lying wetland. Generally
sulphur, carbonate and salt contents are high in the sabkha in Kuwait. The piles and construction materials
constructed should be resistant to this chemicals and reaction.
4.3.2 Animal Corridor
The construction should take care of the camel, cattle and desert wildlife movement especially along the
corridors through passage underground through road and fencing the rest of the road.
4.3.3 Sand Drift and Accumulation
Sand drift and accumulation is a strong phenomenon in Kuwait. Kuwait spends millions to combat the
accumulating sands along the public places, roads and around utilities. Sand barrier, concrete wall, berm,
trench, sand trap and technically designed greenbelt along the direction of predominant wind direction would
be a solution to keep the sand away from reaching the road and causing disturbance to mobility.
4.3.4 Tackling H2S Contaminated Groundwater
The possibility of this occurrence of H2S associated with water is very less in the proposed study route
because of greater depth of water table as compared to the excavation depth required for road works.
Geotechnical reports do not show any evidence of H2S. Here recommendations are provided for the worst
case situation.
There are various methods that should be chosen based on the level of H2S, the amount of water being
treated, the levels of iron and manganese, and bacterial contamination. H2S can be reduced or removed by
activated carbon filtration, shock chlorination, oxidizing chemical injection, oxidizing filtration, and water
heater modification.
• Activated carbon filters are good when H2S is present in low levels. The H2S is absorbed onto the
surface of the carbon particles.
• Shock chlorination may reduce, but not eliminate, the H2S producing bacteria. It involves mixing a
sufficient amount of a chlorine-based chemical with the water to create a solution containing 200 ppm
of chlorine throughout the water system. It is left in the system for several hours. The system must be
flushed with fresh water when the process is complete.
• Oxidation removes H2S concentrations exceeding 6 ppm. It can be done by aeration, chlorination,
ozone, and potassium permanganate. There should be at least 20 minutes of contact between the
chemical and the water.
• Oxidizing filters will work for concentrations up to 6 ppm. The filter contains sand with a manganese
dioxide coating that changes H2S gas to tiny particles of sulfur that are trapped inside the filter.
• Water heater modification is necessary when H2S is causing an odor within the water heating system.
Replacing the magnesium corrosion control rod with one made of aluminum or other metals usually
improves the situation.
4.3.5 Dewatering During Construction Works
Prior to installing equipment, a comprehensive assessment of the potential environmental impacts of
dewatering should be undertaken during project feasibility phase, to highlight environmental risks and
develop management strategies to overcome any significant environmental issues.
The assessment should include:
• Description of the dewatering technique (e.g. spears, bore field, or pit and sludge pump),
commencement date, duration, anticipated volume and frequency of dewater discharge.
• Details of the local environment (before dewatering), including the seasonal variability of standing
water levels, groundwater flow regime and quality, and the water values at risk down-gradient from
the dewatered site and planned discharge point should be undertaken.
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• The radius of influence and profile of any water table draw-down could be calculated via empirical
methods or scientific modeling (including threat to any vegetation or existing structures from land
settling) under the supervision of an experienced hydrogeologist.
• Advice on any measures proposed to limit the extent of offsite influence of the dewatering e.g.
scheduling for end of dry season, sheet piling, hydraulic barriers, grout curtains or ground freezing.
• Definition of the quality of water to be discharged by either bore sampling or access to recorded data,
including probable contaminant concentrations based on natural groundwater contaminants and the
local land use history.
• The need and viability of the dewatering treatment before release into the environment e.g. aeration,
chemical flocculation, filtration, odor control, pH adjustment or settling of solids.
4.4. EMP Implementation and Execution Programs
4.4.1 Environmental Audit
This section provides a checklist of the mitigation measures that must be taken to ensure that they are
adequately carried out to meet various conditions stipulated by the authorities.
A. Planning and Design
1. Has the design followed appropriate standards set by the relevant agencies and/or authorities
in Kuwait?
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(6) Environmental supervision of the wildlife: Prevent the impact of water and soil loss. Control the
construction as per the regulations of vegetation protection, especially the implementation of the
measures of protection and relocation of the ancient trees, as well as separation of the rare animals.
(7) Environmental supervision of people’s health: Ensure safety and reliability of the domestic drinking
water, prevent infectious disease, and provide necessary welfare and sanitation.
(8) Supervision of construction and installation of the environmental protection facilities: supervise
construction of the facilities of sewage treatment, acoustic protective screen and green work.
3. Supervision after Completion of Inspection
1. Assist the Owner in the organization of final acceptance of construction.
2. Prepare the final report for the environmental supervision of the project.
5. Conclusion
The developed EMP addresses the environmental impacts during the design, construction and
operational phases of the project. EMP outlines the key environmental management and safeguards that will
be initiated by the project proponent to manage the project’s key environmental concerns. Environmental
Management Plan (EMP) is the mechanism to ensure that environmental considerations are integrated into
the project survey and design, contract documents and project supervision and monitoring. These are tools
for mitigating or offsetting the potential adverse environmental impacts resulting from various activities of
the project.
The EMP prepared consists mainly of mitigation measure, monitoring plan and recommendations. The
recommendations that are suggested are specific to the project and geographical conditions in the State of
Kuwait. The vital section of EMP is the EMP implementation and execution program. The EMP should
consist of cost estimates for monitoring program, equipment procurement, manpower, transportation, office
cost, studies, reporting, stationeries, etc.
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