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General
Environmental, Health, Safety (EHS)
and Social Management Plan
for the Implementation of the N.V.EBS Investment Plan
Component 2
(SU-L1039)
Report Prepared by:
Dept. Health, Safety, Environment & Quality (HSEQ)
April 2015
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Table of Contents
1 General introduction .................................................................................................... 3
2 Roles and Responsibilities .......................................................................................... 5
2.1 Design Phase ................................................................................................................... 5
2.2 Construction Phase ........................................................................................................... 5
2.3 Operation Phase ............................................................................................................... 6
2.4 Decommissioning Phase ................................................................................................... 7
3. Environmental, Health, Safety and Social Procedures ...................................................... 7
3.1 Method Statements ........................................................................................................... 7
3.2 Corrective Action ............................................................................................................... 8
3.3 Community Liaison ........................................................................................................... 9
4 Implementation of the management plans ............................................................... 10
4.1 Monitoring .............................................................................................................................. 10
4.2 Reporting ............................................................................................................................... 10
4.3 Audit and Review ............................................................................................................ 10
5 Environmental, Health, Safety And Social Mitigation ............................................. 12
5.1 Approach to the management plans and specifications................................................... 12
5.2 Results of the Environmental, Health, Safety and Social Assessment ............................. 13
5.3 Design Phase Mitigation and Monitoring Matrix............................................................... 17
5.4 Construction Phase Management Mitigation and Monitoring Matrix ................................ 18
5.5 Operations Phase Management Mitigation and Monitoring Matrix ................................... 23
5.6 Decommissioning Phase Management Matrix ................................................................ 26
6. Conclusion ............................................................................................................................ 31
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Approval and Revision
Approval
Organization/dept. Name Date
Composed EBS / HSEQ C. Resomardono April 2015
Approved EBS / CEO E. Duiker April 2015
Revision
Revision no. Date Description of revision
1 April Improvement of version 0, February 2015
Distribution
Organization/dept. Name Position No. of copy’s
EBS E. Duiker CEO 1
EBS M. Eyndhoven CTO 1
EBS/ HSEQ J.Wanner Manager HSEQ 1
EBS / HSEQ C. Resomardono Dep.Head
HSEQ
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1 General introduction
The environmental, health and safety management and monitoring plan (EHSMP) and the social
management plan (SMP) is described in the following chapters. The EHSMP and SMP is developed
according to the contract: SUPPORT FOR THE IMPLEMENTATION OF THE EBS INVESTMENT PLAN
(SU-L1039), ENVIRONMENTAL AND SOCIAL MANAGEMENT REPORT (ESMR).
Both management plans will set out the roles and responsibilities for environmental, health and
safety management and social management according to the component I and II that will be
executed considering the loan:
Component I. Improvement of EBS’s Operations.
Component I will support EBS’s institutional and operational strengthening by:
(i) implementing a Distribution/Outage Management System (DMS/OMS) and training
activities;
(ii) financing the implementation of an Enterprise Resource Planning (ERP) platform and
training activities;
(iii) assisting EBS during the transition to the new unbundled corporate model; and (iv)
implementing a program to promote RE and EE.
Component II. Component II will contribute to the upgrade and retrofitting of the National Power
System’s critical infrastructure, with aim of improving the reliability of the EPAR sub-system.
Activities to be financed include:
(i) upgrade of two existing S/S in the EPAR network (J and F); and
(ii) construction of a new S/S in the EPAR network (Boma).
S/S J is one of the main providers of energy to the central zone of Paramaribo. With the current
expansion in generation and transmission, its design ratings will be exceeded.
The upgrade will consist of:
1. the renovation of the existing building;
2. the replacement of switchgears to facilitate the dispatch of EBS’s generation from
DPP2;
3. the replacement of protections and accessories; and
4. the incorporation into the SCADA system.
S/S F is an open air substation located in Para district. The substation needs to be upgraded to
improve the reliability and to facilitate the connection of future customers. The retrofit will mainly
include:
1. construction of the substation building;
2. installation of a 25-MVA transformer;
3. installation of switchgears; and
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4. integration into the SCADA system.
The new S/S Boma and substation E will improve the quality and reliability of the electricity supply
in the Santo Boma area, and allow for the connection of new customers.
The activities include:
1. construction of S/S Boma and provision of equipment;
2. construction of a new 33-kV line to connect the new S/S to the existing S/S HL;
3. construction of a new 33-kV line to connect the new S/S to the existing S/S E; and
4. the upgrade of the existing S/S E.
The mitigation measures will be applied to the following three phases of the development process:
The Design Phase: These measures relate to the detailed layout, planning and design, and will largely be implemented by the planning and development team, prior to the commencement of any physical on site activities.
The Construction Phase: These mitigation measures are applicable during site preparation and construction and must be implemented by the relevant contractors.
The Operations Phase: These mitigation measures are applicable during the long-term operation.
The Decommissioning Phase: These recommendations are applicable to the decommissioning and rehabilitation of the area at the end of the operational lifespan.
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2 Roles and Responsibilities
2.1 Design Phase
The key role players during the design phase are:
Project Engineering
HSEQ Department
Their roles and responsibilities during the detailed design phase with respect to the
implementation of the EHSMP are outlined below.
The Chief Executive Officer (CEO) of EBS has overall accountability for all the activities including
HSEQ matters.
Project Engineering
Confirm that all HSE and social management measures have been incorporated into the project
design on completion of the design phase.
Ensure contractors are aware of and take into consideration all measures of the EHSMP and
SMP
HSEQ
Confirms that all HSE & Social management plans are implemented and in compliance are with
the relevant regulations and standards
Ensure the review of the management plans.
2.2 Construction Phase
NV EBS will strive to HSE and Social performance during the construction phase through the
following activities:
Implementation and management of a programme of inspection, monitoring and
reporting;
Ensuring that all staff undergo awareness training, focusing on the key issues
concerning the activities of the projects; and
Implementation of a programme for follow-up and analysis of all near misses, incidents
or accidents or pollutions.
The Chief Executive Officer (CEO) has overall accountability for all the activities including HSEQ
matters.
The EBS HSEQ Department has overall responsibility for HSE management. They will:
Review monthly reports on the performance of the HSE and Social management and
monitoring of the projects;
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Review weekly compliance checklists submitted by relevant department managers; and
Provide direction on strategic matters to the CEO.
Issue Corrective Action Requests to contractors
Verify that contractors activities are conducted in accordance with the requirements of
the EHSMP and SMP
Undertake frequent site inspections to determine compliance with the EHSMP and
SMP
Review the following:
- Weekly environmental compliance checklists / performance reports
- Corrective Action Plans submitted by contractors
- Incident, accidents, near misses and pollution reports
Compile monthly monitoring and performance reports for the CEO
2.3 Operation Phase
EBS will enhance EHS and Social performance during the operations phase through the following
activities:
Implementation and management of a programme of inspection, monitoring and
reporting; and
Implementation of a programme for follow-up and analysis of all near misses, incidents
or accidents or pollutions.
It should be noted that only roles and responsibilities that directly relate to EHS and Social
management are described here. The general roles and responsibilities of various parties will
outline in more specific projects.
During the operations phase, EBS will have overall accountability and responsibility for EHS and
Social management and monitoring of the Project, to ensure that compliance is achieved. This
includes responsibility for the performance and management of EBS employees and activities, as
well as oversight of any contractors on site.
The Chief Executive Officer (CEO) of EBS has overall accountability for all the operation, including
HSEQ matters.
The EBS HSEQ Department will manage all HSEQ matters the project activities. They will:
Be responsible for the integration of EHS and Social management controls into day-to-
day activities in collaboration with the relevant manager of the project;
Ensure that operations comply with the provisions of the management plans;
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Allocate and manage resources to ensure adequate supervision of EHS and Social
matters;
Ensure that activities are conducted in accordance with the requirements of the
management plans and that high standards of EHS and Social management are
pursued;
Oversee development of awareness and training materials by the training department,
and their implementation during training and induction sessions for new workers and
at regular periods as appropriate;
Oversee and review EHS and Social monitoring and data management and verify that
EHS and Social monitoring results are within specified limits;
Submit quarterly EHS and Social monitoring and performance reports to the Chief
Executive Officer.
- Incident, accidents, near misses and pollutions reports.
2.4 Decommissioning Phase
The objective of this section is to provide recommendations for the decommissioning and the
rehabilitation of the area at the end of the operational lifespan, to achieve sustainable land use
conditions and avoid or minimize costs and long term liabilities to EBS.
Very limited information is currently available regarding the anticipated lifespan and the exact
method of decommissioning. The measures listed in Matrix 4 are based on the assumption and
associated infrastructure will be removed at the end of operations.
Details regarding the roles and responsibilities during the decommissioning phase and the desired
post-decommissioning land use will be developed closer to the time of decommissioning.
3. Environmental, Health, Safety and Social Procedures
3.1 Method Statements
Each Method Statement will address environmental, health, safety and social aspects relevant to
the activity and will typically provide detailed descriptions of items including, but not necessarily
limited to:
Nature, timing and location of activities;
Procedural requirements and steps;
Management responsibilities;
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Material and equipment requirements;
Transportation of equipment to and from site;
Method for moving equipment/material while on site;
How and where material will be stored;
Emergency response approaches, particularly related to spill containment and clean-
up;
Response to compliance/non-conformance with the requirements of the management
plans; and
Any other information deemed necessary by the HSEQ Department.
Since many of the main physical construction impacts will occur during site preparation (much of
which has been already completed), only a relatively limited number of Method Statements is
required. Method Statements are required for, but not limited to:
Stormwater control, including construction and maintenance of sediment traps.
Handling and storage of hazardous materials, including hazardous wastes.
Delivery of abnormal loads by road.
3.2 Corrective Action
Corrective action is a critical component of the implementation–review–corrective action–
implementation cycle and it is through corrective action that continuous improvement can be
achieved. Where repeated non-compliance is recorded, procedures may need to be altered
accordingly to avoid the need for repeated corrective action.
Corrective action will be required during the construction and operations phases and the
recommended channels to manage such action are described below.
If, during the construction phase, EHS and Social monitoring data or other information
demonstrates or indicates non-conformance with set standards and targets, the EBS HSEQ
Manager will formally notify the contractors in a Corrective Action Request. This procedure will be
used in respect of all sub-standard HSE conditions or actions. The Corrective Action Request will
document:
The nature of the sub-standard conditions or actions;
The actions requested to correct the situation; and
The date by which each corrective or preventative action must be completed.
It should be noted that the corrective actions requested by EBS may include requests for further
monitoring information or investigations to establish the nature or cause of the non-compliant
data.
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Upon receipt of the Corrective Action Request contractors will be required to produce a Corrective
Action Plan (or similar plan), which will detail how the required actions will be implemented. The
Corrective Action Plan must be submitted to the EBS HSEQ and Project Engineering Department
for approval prior to implementation. Once it has been approved, the corrective action must be
carried out within the time limits stipulated in the Corrective Action Request. Additional
monitoring by contractors will then be required to confirm the success or failure of the corrective
action.
If, during the operations phase, data demonstrate non-conformance with set standards and
targets, the EBS HSEQ Department will inform the relevant departments or his appropriate
delegate. The manager responsible for the activity or location in question will prepare a
Corrective Action Plan in the same way as for the construction phase and submit it and for
approval by the EBS HSEQ Department. On approval, the responsible manager will immediately
proceed with implementation of corrective actions. Additional monitoring by EBS staff to confirm
the success or failure of the corrective action will then be required.
3.3 Community Liaison
The HSEQ Department, with assistance from the EBS Public Relations (PR) Department will oversee
interactions with stakeholders and communities. Therefore a communication plan for external
stakeholders regarding complaints is already developed.
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4 Implementation of the management plans
The management plans will be implemented and used to guide activities during the construction
and operations phases.
During both the construction and operations phases the following principal items will be
monitored:
The management plans shared with all relevant managers and contractors
Correct and full implementation of management plan procedures;
Compliance with contract commitments and approved Method Statements; and
Compliance with project standards/guidelines.
4.1 Monitoring
The objective of implementing an inspection and monitoring programme is to ensure complete
compliance with mitigation measures, approved plans and permit conditions. The monitoring
programme also provides transparent assurance to EBS (and external parties) that specified
standards are being set so as to reduce (negative) impacts to tolerable levels, and that target
performance levels are being met.
Contractors and EBS are responsible for the collection and monitoring of EHS and Social data
during both the construction and the operations phases respectively.
Monitoring will begin at the commencement of construction activities. Monitoring will continue
throughout the construction and operations phases, and the duration and frequency of
monitoring may be modified to best characterise any affected EHS and Social aspect.
4.2 Reporting
The frequency and nature of reporting of EHS and Social management performance will depend
upon the nature of the activity and aspect that is being managed. Reporting may take several
forms:
Reports on critical issues, as required;
Formal reports and contributions to weekly and monthly project management
meetings;
Monthly reports on performance and compliance;
Quarterly performance reports on key indicators.
4.3 Audit and Review
The management plans will be subject to a self-assessment audit, against corporate Management
Standards.
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Performance will be reviewed on an ongoing basis by the EBS HSEQ Department or his delegate.
This will include review of:
EHS and Social performance data;
Management plans function and implementation; and
Management structures and team.
Contractors are subject to annual audit, while EBS HSEQ and Social Management Systems are
subject to an internal annual audit, in accordance with corporate requirements.
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5 Environmental, Health, Safety And Social Mitigation
5.1 Approach to the management plans and specifications
The general principles contained within this section apply to all activities for the duration of the
design, construction and operations phases.
A series of Management Mitigation and Monitoring Matrices has been developed and grouped to
cover activities that give rise to potential impacts during the construction and operations phases.
These matrices were developed by SRK Consultancy. Each Management Mitigation and
Monitoring Matrix provides detail on the following:
The management aspect describing an action and/or activity which interacts with and
impacts the environment;
Description of mitigation measures;
Identification of the person(s) responsible for implementation of the mitigation
measure(s);
Monitoring and performance evaluation, including performance indicators; and
Compliance reporting requirements.
These Management Mitigation and Monitoring Matrices are presented in the remainder of this
section of the management plans. To facilitate readability, avoid repetition and make the
document more “user friendly”, similar activities have at times been combined or “rolled up” and
mitigation measures have been ascribed to the combined activity.
The summary table below lists the Management Mitigation and Monitoring Matrices for the
design, construction, operation and decommissioning phases respectively.
Table 1: Summary Table of Management Mitigation and Monitoring Matrices.
Matrix Activity Phase
1 General considerations during design phase DESIGN
2 General management of construction activities CONSTRUCTION
3 General management during operations. OPERATIONS
4 General management during decommissioning. DECOMMISSIONING
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5.2 Results of the Environmental, Health, Safety and Social Assessment
An assessment had been done by the IADB consultant regarding the SU-L1039 PROJECT.
The outcomes of the assessment mentioned in the report and to be considered for the mitigation
measures are:
1. ESA did not identify the presence of any sensitive biodiversity areas or cultural sites within
the areas of the projects. However, it is important to note that the land had not been
acquired for the specific location for the new substation of Santo Boma at the time the
environmental and social due diligence was conducted. Given these circumstances, the
Bank considers it necessary to establish a set of required criteria to be applied during the
selection of remaining sites to ensure compliance with IDB Policy requirements and
consistency with the project’s environmental categorization.
2. The proposed activities under the Program shall not:
Cause significant negative impacts on protected areas;
Cause significant conversion or partial degradation of natural habitats, so to result in
extensive changes in the socio-environmental context;
Cause immitigable adverse impacts on culturally sensitive sites or objects, including
archaeological, historical or paleontological sites;
Cause immitigable adverse impacts of resettlement, by means of a Resettlement Plan;
Be located in areas for which land titling or land use agreements have not been
properly obtained by the Executing Agency;
Be located in areas of inconsistent zoning or land use planning patterns; and
Cause strong opposition from the community, where it can become a high risk factor
against the implementation of the activities or the reputation of the Bank.
3. Supervision and Monitoring. The Program’s ESMP will include guidelines for developing
the monitoring program and monitoring reports that form part of the semiannual reports
to be submitted to the Bank. Within the monitoring reports issues such as the
responsibilities and associated costs will be included in the monitoring of each project as
well as the progress in the implementation of plans for environmental, social management,
and occupational health and safety.
4. Hazardous Materials B.10. To ensure compliance with this Directive, the ESMP will include
a comprehensive waste management plan that includes transportation, handling, disposal,
and treatment of the most significant hazardous waste and hazardous materials to be
used, to address potential impacts from the disposal of hazardous waste. The ESMP will
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also include guidelines on the use of hazardous materials referenced in the IDB’s Exclusion
List of activities to be financed. The ESMP must be presented to the Bank and obtain the
non-objection before initiating the tendering process for the proposed works.
5. Disaster Risk. The disaster risk category of the project was evaluated and found to be low.
The Bank has developed site selection criteria to avoid, among others, areas prone to
natural disaster risks. According to the Directive A.2 of Disaster Risk Policy OP-704
operations with low risk level of natural disasters generally do not require specific disaster
risk management measures.
6. According to the information gathered during the ESA of the Program, in Suriname power
sector regulations, standards, guidelines and design criteria mainly follow the United States
guidelines, ANSI (American National Standards Institute1) and the National Electrical Code
(NEC), which includes NFPA 70, a United States standard for the safe installation of
electrical wiring and equipment. It is part of the National Fire Codes series published by the
National Fire Protection Association (NFPA). The use of NEC is commonly mandated by
state or local law in the U.S, as well as in many jurisdictions outside of the United States.
NEC codifies the requirements for safe electrical installations into a single, standardized
source. In Suriname, EBS will be responsible for ensuring compliance with these minimum
standards2.
EBS applies the NEC codes and IFC regulations concerning removal and disposal of toxic
wastes, but no laws currently exist to enforce these standards.
Suriname has ratified the Basel Convention3, on the Control of Transboundary Movements
of Hazardous Wastes and Their Disposal, and the Stockholm Convention4 Stockholm
Convention, on Persistent Organic Pollutants (POPs). Both conventions are intended to
minimize the amount and toxicity of wastes generated, to ensure their environmentally
sound management as closely as possible to the source of generation, and to assist less
developed countries in environmentally sound management of the hazardous and other
wastes they generate.
In addition to compliance with obligations under the Stockholm and Basel Conventions
pertaining to management & disposal of PCBs, and extending to licensing of contractors
who do disposal of heavy metals, the Program will take into account the IFC’s General
Guidelines on Environment, Health and Safety.
1 http://www.ansi.org
2 http://www.esfi.org/index.cfm/page/National-Electrical-Code-(NEC)/pid/10860#sthash.nAIKuAZK.dpuf
3 The Basel Convention was opened for signature on 22 March 1989, and entered into force on 5 May 1992.
4 Stockholm was signed in 2001 and effective from May 2004.
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7. The Bank has categorized the project as a “B”. As a result, effects are expected to be
localized and short-term that usually results from the construction of the proposed
activities
8. Construction. At this stage it is expected that infrastructure projects generate both
negative and positive environmental impacts. The negative impacts are considered
moderate and relatively short duration. Primarily, it is expected that nuisances to the
surrounding communities will increase during the construction phase. These impacts are
not considered significant and can be mitigated by following the recommendations
specified in the ESMP.
9. Operational Phase. During this stage the most significant environmental risks and impacts
are related to the disposal and maintenance of equipment. In particular, the removal and
disposal of hazardous waste, such as polychlorinated biphenyls (PCBs) traditionally found
in electric transformers dating back to the 1970’s and typically used as fire retardants.
10. Social Impacts and Risks. It is anticipated that investments under the Program will produce
a net positive social impact on the quality of life and welfare of beneficiaries through the
overall improvement on the reliability of the service through upgrades to critical
infrastructure in the National Power System.
Table 1 and 2 presents the results of the impact analyses done by IADBs consultant. The impacts
will be considered in the matrices developed by EBS for the mitigation.
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Table 1 IMPACTS DURING CONSTRUCTION PHASE
NEGATIVE POSITIVE
o Increased particulate matter, dust and noise in the surrounding environment
o Risk fuel spill and oils of machinery during construction work.
o Altered surface runoff due to soil movements
o Erosion natural terrain and elimination of native flora
o Increase of transit movement of trucks for the work
o Nuisances to neighbors because of increased noise and dust
o Increase of the demand for labor for
construction work (short term effect).
Table 2 IMPACTS DURING OPERATIONAL PHASE
NEGATIVE POSITIVE
o Risk of contamination to environmental receptors due to inadequate handling and disposal of hazardous materials and hazardous waste and during equipment maintenance activities.
o Occupational-accidents related to the operation of distribution / transmission equipment.
o Development of adequate environmental and social management plans
o Improvement to the quality of life of the beneficiary population
o Implementation of environmental controls o More reliable electricity service to the
population
5.3 Design Phase Mitigation and Monitoring Matrix
Matrix 1: Project-specific management and mitigation measures that must be implemented during the design phase.
Design phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe
Monitoring methods Performance indicators
Plant design 1. If a significant impact is expected, depending on land use and ownership:
Implement higher specification procedures to reduce any noise increase according to the national regulations for noise and World Bank Noise Standards
Contractor in consultation with EBS Project Manager
Before construction Review plans
Design layout
2. Incorporate noise control in the design
3. Design visible permanent structures to be as unobtrusive as possible.
4. Design substation to allow for containment of contaminated stormwater runoff and all wastewater generated for treatment.
5. Route stormwater around the plant as much as possible to minimise the potential for contaminating runoff.
6. Design substation to allow for containment and contaminated oil spills and all wastewater with oil generated for treatment.
7. Analyses of transformer oil regarding PCBs.
5.4 Construction Phase Management Mitigation and Monitoring Matrix
Matrix 2: Project-specific management and mitigation measures that must be implemented during the construction phase.
Construction phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe Monitoring methods Performance indicators
Construction preparation
1. Inform adjacent residents and business owners about completed and planned construction activities, including anticipated construction traffic.
Contractor, in consultation with EBS Project Manager
Immediately Visual inspections
Review reports
Record of meetings, notifications and/or interactions
2. Undertake awareness training to ensure that all staff are aware of environmental, health and safety management of construction activities and the stipulations of the management plans, particularly:
- Spill protocols (fuel) and emergency procedures;
- Run-off management; and
- Waste management.
Consider implementing a penalty system if required, e.g. contractors are liable for the remediation of sites they pollute and, in the case of repeat offences, consider issuing a stop work order.
All contractors Regularly, throughout construction
At regular toolbox talks
When new personnel comes on site
Keep a record of attendance at all training sessions
Training records
Awareness of staff
Construction site
3. Ensure that access to the construction site is restricted and sign-posted.
Control access to all working areas such that only approved vehicles and persons have access.
All contractors operating sites
Throughout construction Security and entry logs Number of breaches of access restrictions
4. Ensure that the site office, toilets and storage areas for building materials are located in such an area that contamination of nearby water resources are not taken place.
Review site layout Suitable distance
5. Ensure that storage and laydown areas are appropriately bunded to prevent runoff from these areas towards canals or water resources
Weekly visual inspection of areas surrounding construction site
Bund in place
No runoff observed from site or in adjacent areas / water bodies
6. Keep a copy of the management plans at the construction site. Check availability of management plans
7. Keep construction sites tidy and all activities, material and machinery contained within an area that is as small as possible. Clear and clean site weekly.
Weekly visual inspection of site
Neat, uncontaminated site
8. Keep sufficient fire fighting equipment on site at all times, especially where activities such as welding are performed.
Check availability of fire fighting equipment
Hazardous materials
9. Design and construct hazardous material storage facilities, especially fuel storage, with suitable impermeable materials and a minimum bund containment capacity equal to 110% of the largest container.
All contractors Throughout construction Weekly visual inspection of hazardous materials handling and storage
Number of incidents of non-compliance with safety procedures
Construction phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe Monitoring methods Performance indicators
10. Locate hazardous material storage facilities, especially fuel storage, as far as practically possible from canals or water resources
areas concerning hazardous materials, including waste materials
Number of spills of hazardous materials, including waste materials
Cost of cleaning up spills
Evidence of contamination and leaks
11. Ensure that contaminants (including cement) are not placed directly on the ground (e.g. mix cement on plastic or metal sheeting).
12. Develop (or adapt and implement) procedures for the safe transport, handling and storage of potential pollutants.
13. Avoid unnecessary use and transport of hazardous substances.
14. Keep Material Safety Data Sheets for all hazardous materials on site and ensure that they are available for reference by staff responsible for handling and storage of materials.
Transportation and refuelling
15. Undertake regular maintenance of vehicles and machinery to identify and repair minor leaks and prevent equipment failures.
All contractors Throughout construction Weekly visual inspection of vehicles, barges, machinery and refuelling/maintenance areas
Number of incidents of non-compliance
Number of leaks and spills
Cost of cleaning up spills
16. Undertake any on-site refuelling and maintenance of vehicles/machinery in designated areas. Line these areas with an impermeable surface and install oil traps.
17. Use appropriately sized drip trays for all refuelling and/or repairs done on machinery – ensure these are strategically placed to capture any spillage of fuel, oil, etc.
18. Ensure that boats and barges do not release pollutants into the water and have adequate mooring or anchoring facilities.
19. Ensure compliance with international safety standards in barge and tanker operations.
20. Clean up any spills immediately, through containment and removal of free product and appropriate disposal of contaminated soils
21. Keep spill containment and clean-up equipment at all work sites and for all polluting materials used at the site.
Construction near the canals and water resources
22. Stabilise exposed surfaces if required to avoid soil erosion. All contractors Throughout construction Weekly visual inspection of construction site and surrounding / downstream land and river areas
Visible erosion
23. Avoid dumping of material in canals or near water resources Indication of dumping in water bodies
24. Contain contaminated stormwater runoff, contaminated water and all wastewater generated from construction areas and treat prior to discharge as far as practicable.
Indication of pollution of / discharge into water bodies
Presence of stormwater containment
Construction phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe Monitoring methods Performance indicators
25. Avoid washing of vehicles and machinery near the canals or water resources.
Dedicated wash place
Indication of runoff into water bodies
Noise and air emissions
26. Limit the use of heavy machinery and construction activities associated with high noise levels to 08h00 to 17h00 from Mondays to Fridays.
Notify any nearby residents if construction work is planned outside of those times.
All contractors operating machinery
Throughout construction Daily visual assessment of dust plumes
Random machinery checks
Number of registered complaints
Number of days that dust plumes are visible
Visibility of dust coming off construction site
Dust mitigation measures in place
27. Reduce airborne dust at construction sites through e.g.:
- Damping dust-generating areas with freshwater;
- Use of cloth or brush-barrier fences; and
- Covering dumps or stockpiles of lose material with plastic sheeting or netting, especially during windy conditions.
28. Maintain all generators, vehicles, vessels and other equipment in good working order to minimise exhaust fumes and excess noise.
29. If complaints regarding noise are received from residents, consider installing partial screening around the noisiest activities and/or mufflers on noisy equipment.
Waste management
30. Develop a waste management plan or implement the waste management plan .
EBS Immediately Availability of plan
31. Aim to minimise waste through reducing and re-using (packaging) material.
All contractors Throughout construction Weekly visual inspection of waste collection and disposal areas
Weekly visual inspection of construction areas (litter)
Presence of litter
Availability of rubbish bins and skips
Degree to which rubbish bins and skips are filled
Degree to which different waste is separated
Frequency of waste collection
Area of land used for waste
32. Collect all waste in bins and/or skips at the construction site.
Prevent littering by construction staff at work sites by providing bins or waste bags in sufficient locations.
33. Provide separate bins for hazardous / polluting materials and mark these clearly.
Store hazardous / polluting materials on impermeable ground until it is disposed of / collected.
34. Dispose of waste appropriately to prevent pollution of soil and groundwater.
35. Collect recyclables separately if facilities exist to process these.
Delivery recyclables to suitable facilities or arrange for collection.
36. Do not allow any burning or burying of waste on site.
Construction phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe Monitoring methods Performance indicators
Road traffic management
37. Manage construction sites and activities so as to minimise impacts on road traffic as far as possible, e.g.:
- Attempt to arrange delivery of materials when it will least disrupt traffic;
- Keep construction materials and machinery at the construction site throughout the construction period, where possible.
All contractors operating vehicles or barges
Throughout construction Keep record of incidents and complaints
Number of incidences and complaints
38. Ensure that all safety measures are observed and that drivers comply with the rules of the road.
39. Ensure that trucks transporting abnormal loads or large volumes of hazardous material are clearly marked and escorted by safety vehicles, if necessary.
40. Attempt to maximise the occupancy rate of vehicles to minimise the number of required vehicles.
Encourage personnel to carpool when driving to and from the site.
Keep record of vehicles Number of vehicles travelling to site each day
Number of trips
41. Ensure compliance with international and national safety standards and procedures for barge and tanker operations.
Inspection of required papers
Weekly visual inspection of vessels
Availability of all required papers and certificates
Condition of vessels
42. Inform all potentially affected parties of any restrictions to road use.
Clearly mark areas to which restrictions apply.
Contractor, in consultation with EBS Project Manager
2 weeks before restrictions become effective
Keep record of communications
Frequency and type of restrictions
Number of incidents and complaints
Employment 43. Consider maximising the employment of local workers. EBS Project Manager
Throughout construction Keep record of employed staff split by origin
Number of Suriname nationals employed
44. Work closely with the local community to identify and communicate required skills and resources that the local community could provide.
Contractor, in consultation with EBS Project Manager
45. Consider implementing labour-intensive rather than capital-intensive work methods wherever possible.
46. Consider purchasing resources from Surinamese sources wherever possible.
47. Consider giving preference to qualified Surinamese nationals when filling vacancies.
Community interaction
48. Develop a communication policy and (grievance) mechanism that allows local communities to raise issues and concerns to EBS.
EBS Project Manager
Throughout construction Keep record of inductions and complaints.
Availability of communications policy
Construction phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation timeframe Monitoring methods Performance indicators
49. Maintain a complaints register. The register must record:
- Complainant name and contact details;
- Date complaint was lodged;
- Person who recorded the complaint;
- Nature of the complaint;
- Actions taken to investigate the complaint and outcome of the investigation;
- Action taken to remedy the situation; and
- Date on which feedback was provided to complainant.
Awareness of policy
Number of non-compliances with policy
Availability of complaints register on site
Number of complaints or compliments received
Construction site rehabilitation
50. Remove all building materials and obsolete structures from the site after construction.
All contractors operating sites
At end of construction activities in any one section
Visual inspection of site by EBS Project Manager before site hand-over to EBS
If required, sampling of portions of the site to determine contamination
Keep records of clean-up activities / disposal of contaminated material
Material and structures remaining on site and in adjacent areas
Contamination of soil (e.g. discoloration, test results)
Indications of erosion
51. Ensure soil stability by e.g. re-profiling or re-vegetating the site or using stabilisation measures such as geotextiles if required and possible and use of native flora
52. Check the site for contaminated soil.
Treat any contaminated soil with remediation products.
5.5 Operations Phase Management Mitigation and Monitoring Matrix
Matrix 3: Project-specific management and mitigation measures that must be implemented during operations.
Operations phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe
Monitoring Methods Performance Indicators
Plant maintenance
1. Implement a plant maintenance programme in line with international standards and guidelines.
EBS Operations Manager
Throughout operations Regularly audit programmes
Compliance with relevant programmes
Regular audits 2. Perform regular internal and external audits of the plant maintenance
programme to ensure it is implemented effectively, at least once every two years.
3. Regularly inspect all machinery and holding tanks for leaks or damages.
Visually inspect areas inside and outside the plant for pollution
Number of contaminations noted on site
4. Repair any defects as soon as possible. In the case of leaks, ensure that the leaking water or effluent is captured and not released into the environment.
5. Keep the area outside clean, especially during the rainy season when pollutants can wash into the canals with the storm water.
6. Maintain buildings and equipment so that facilities do not become unsightly and contribute to urban blight.
Waste management
7. Implement the waste management plan. EBS Operations Manager
Throughout operations Weekly visual inspection of waste collection and disposal areas
Presence of litter
Availability of rubbish bins and skips
Degree to which rubbish bins and skips are filled
Degree to which different waste is separated
Frequency of waste collection
Area of land used for waste
8. Aim to minimise waste through reducing and re-using (packaging) material.
9. Collect all waste in bins and/or skips at the plant site.
Prevent littering by staff by providing bins or waste bags in sufficient locations.
10. Provide separate bins for hazardous / polluting materials and mark these clearly.
Store hazardous / polluting materials on impermeable ground until it is disposed of / collected.
11. Implement a programme to regularly collect and dispose of redundant equipment, waste and litter.
12. Dispose of waste appropriately to prevent pollution of soil and groundwater.
13. Collect recyclables separately if facilities exist to process these.
Delivery recyclables to suitable facilities or arrange for collection.
Operations phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe
Monitoring Methods Performance Indicators
14. Do not allow any burning or burying of waste on site.
Hazardous materials
15. Ensure that contaminants are not placed directly on the ground. EBS Operations Manager
Throughout operations Weekly visual inspection of hazardous materials handling and storage areas
Number of incidents of non-compliance with safety procedures concerning hazardous materials, including waste materials
Number of spills of hazardous materials, including waste materials
Cost of cleaning up spills
Evidence of contamination and leaks
16. Implement procedures for the safe transport, handling and storage of potential pollutants.
17. Store hazardous materials in storage facilities with suitable impermeable floors and a minimum 110% containment capacity.
18. Avoid unnecessary use and transport of hazardous substances.
19. Keep Material Safety Data Sheets for all hazardous materials on site and ensure that they are available for reference by staff responsible for handling and storage of materials.
20. Clean up any spills immediately, through containment and removal of free product and appropriate disposal of contaminated soils.
Transportation and refuelling
21. Undertake regular maintenance of vehicles and machinery to identify and repair minor leaks and prevent equipment failures.
EBS Operations Manager
Throughout operations Weekly visual inspection of vehicles, machinery and refuelling/maintenance areas
Number of incidents of non-compliance
Number of leaks and spills
Cost of cleaning up spills
22. Ensure that no pollutants are released into the environment and have adequate oil spill clean-up facilities.
23. Ensure compliance with international safety standards
24. Clean up any spills immediately, through containment and removal of free product and appropriate disposal of contaminated soils.
25. Keep spill containment and clean-up equipment at all work sites and for all polluting materials used at the site.
Employment 26. Consider maximising the employment of local workers. EBS Operations Manager
Throughout operations Keep record of employed staff
Number of Suriname nationals employed
27. Work closely with the local community to identify and communicate required skills and resources that the local community could provide.
28. Consider purchasing resources from Surinamese sources wherever feasible.
29. Ensure all staff receive training in environmental management relevant to their tasks, including:
- Waste management; and
- Spill prevention and remedial measures.
Keep record of training Attendance at training
Compliance with measures
Community interaction
30. Develop a communication policy for interaction with local communities in the vicinity of EBS operations.
EBS Operations Manager
Immediately Regularly review policy and its effectiveness
Availability of communications policy
Operations phase mitigation measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe
Monitoring Methods Performance Indicators
31. Develop a grievance mechanism that allows local communities to raise issues and concerns to EBS.
Awareness of policy
Availability of complaints register on site
Number of complaints or compliments received
32. Maintain a complaints register. The register must record:
- Complainant name and contact details;
- Date complaint was lodged;
- Person who recorded the complaint;
- Nature of the complaint;
- Actions taken to investigate the complaint and outcome of the investigation;
- Corrective action taken to remedy the situation; and
- Date on which feedback was provided to complainant.
Throughout operations Keep record of complaints and responses / actions.
Effluent 33. Contain contaminated stormwater runoff and all wastewater generated from construction areas and treat prior to discharge as far as practical.
EBS Operations Manager
Throughout operations Implement monitoring programme (see below)
System delivers effluent of sufficient quality
34. Ensure that the oil sludge and oily water treatment system operates efficiently at all times.
35. Maintain the oil-water separator on a regular basis.
36. Regularly clean and maintain containment facilities to maximise settlement capacity.
37. Comply with World Bank discharge standards for effluent quality.
Response to environmental pollution
38. In the event of environmental pollution, e.g. through spillages, immediately stop the activity causing the problem.
EBS Operations Manager
Throughout operations Maintain register of pollution events and response
Following resumption of activities, frequently inspect repaired equipment to ensure proper functioning
Number of incidents
Time activities stopped
Number of recurring incidents
Availability and completeness of register
39. Only resume activity once the problem has been stopped or (in the case of spillages) the pollutant can be captured without reaching the environment.
40. Repair faulty equipment as soon as possible.
41. Install additional bunding / containment structures around the equipment that was the source of the leak / spillage to prevent pollution from reaching the environment in future.
42. Treat hydrocarbon spills, e.g. during refuelling, with adequate absorbent material, which then needs to be disposed of at a suitable landfill.
5.6 Decommissioning Phase Management Matrix
Matrix 4: Project-specific management measures that must be implemented during decommissioning.
Decommissioning phase measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe Monitoring Methods Performance Indicators
Determine decommissioning requirements
1. Initiate consultation with key stakeholders before any planned decommissioning to discuss potential decommissioning options, methods and requirements.
EBS project manager
Approximately 1 year before planned decommissioning
Monthly review of progress by EBS Management
Completion of relevant milestones
2. Determine other potential commercial uses for the plant equipment and infrastructure to be decommissioned.
3. Identify and assess any potential environmental, health, safety and societal risks associated with the preferred method of decommissioning.
4. Address potentially significant environmental, health, safety and societal risks by amending the proposed method of decommissioning to prevent any significant adverse impacts.
Approximately 6 months before planned decommissioning
5. Review operational history to identify potential problem areas (e.g. those subject to previous pollution incidences).
6. Prepare a detailed Decommissioning Plan, laying out the:
- Decommissioning objectives;
- Decommissioning procedures;
- Environmental, health, safety and social implications of decommissioning;
- Implementation strategy, including stakeholder engagement;
- Waste management, including opportunities to reuse or recycle material.
Facility cleaning 7. Notify relevant authorities and stakeholders before decommissioning activities commence.
Site manager or as determined in detailed Decommissio-ning Plan
Before decommissioning activities start
Review notifications sent Number of stakeholders notified
8. Clean all equipment before disconnecting or removing it. Throughout decommissioning activities
Monitor and log activities
Review compliance with specifications
No pollution incidents
9. Ensure that substances, for example the sludge remaining in the tanks, are properly disposed of.
10. Ensure that water (or any other substance used to clean the plant) is treated and tested for contamination before being discharged or disposed of.
Decommissioning phase measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe Monitoring Methods Performance Indicators
Waste management
11. Develop a waste management plan, laying out:
- Expected type and amount of waste;
- Measures to reduce waste;
- Type and expected volume of recyclable waste;
- Recycling facilities that will collect / receive waste;
- Type of storage for different waste types;
- Waste contractors that will collect waste; and
- Monitoring procedures to ensure the waste management plan is implemented.
EBS Project Manager
Before start of decommissioning
Availability of plan
12. Ensure that no litter and debris reaches the canals or water resources during the removal of equipment, cleaning of infrastructure and general decommissioning activities.
EBS Project Manager
Throughout decommissioning
Visual inspection of waste collection and disposal areas
Visual inspection of area (litter)
Check waste disposal slips
Presence of litter
Availability of rubbish bins and skips
Degree to which rubbish bins and skips are filled
Total volume of general and hazardous waste storage capacity
Total volume of general and hazardous waste stored on site
Degree to which different waste is separated
Frequency of waste collection
13. Train all staff in the effects of littering on the environment.
14. Do not place old equipment that is removed / refurbished in areas where it is exposed to stormwater.
15. Aim to minimise waste through reducing and re-using (packaging) material.
16. Aim to reuse or recycle decommissioned items.
17. Collect recyclables separately and deliver these to suitable facilities or arrange for collection, if a facility exists.
18. Collect all waste in bins and/or skips at the site.
Prevent littering by staff at work sites by providing bins or waste bags in sufficient locations.
19. Provide separate bins for hazardous / polluting materials and mark these clearly.
Store hazardous / polluting materials on impermeable ground until it is disposed of / collected.
20. Dispose of waste appropriately to prevent pollution of soil and groundwater.
21. Do not allow any burning or burying of waste on site.
Hazardous materials
22. Use hazardous material storage facilities, especially fuel storage, with suitable impermeable materials and a minimum bund containment capacity equal to 110% of the largest container.
All contractors Throughout decommissioning
Visual inspection of hazardous materials handling and storage areas
Number of incidents of non-compliance with safety procedures concerning hazardous materials, including waste materials
23. Locate hazardous material storage facilities, especially fuel storage, as far as practically possible from the water’s edge.
Decommissioning phase measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe Monitoring Methods Performance Indicators
24. Ensure that contaminants (including cement) are not placed directly on the ground (e.g. mix cement on plastic sheeting) to prevent runoff reaching the environment.
Number of spills of hazardous materials, including waste materials
Cost of cleaning up spills
Evidence of contamination and leaks
25. Develop (or adapt and implement) procedures for the safe transport, handling and storage of potential pollutants.
26. Avoid unnecessary use and transport of hazardous substances.
27. Keep Material Safety Data Sheets for all hazardous materials on site and ensure that they are available for reference by staff responsible for handling and storage of materials.
Transportation and refuelling
28. Undertake regular maintenance of vehicles and machinery to identify and repair minor leaks and prevent equipment failures.
All contractors Throughout decommissioning
Visual inspection of vehicles, machinery and refuelling/maintenance areas
Number of incidents of non-compliance
Number of leaks and spills
Cost of cleaning up spills
29. Undertake any on-site refuelling and maintenance of vehicles/machinery in designated areas. Line these areas with an impermeable surface and install oil traps.
30. Use appropriately sized drip trays for all refuelling and/or repairs done on machinery – ensure these are strategically placed to capture any spillage of fuel, oil, etc.
31. Ensure that no pollutants are released into the water and that oil spill clean-up material is available.
32. Ensure compliance with national safety standards
33. Clean up any spills immediately, through containment and removal of free product and appropriate disposal of contaminated soils
34. Keep spill containment and clean-up equipment at all work sites and for all polluting materials used at the site.
Noise and air emissions
35. Limit noisy activities to 08h00 to 17h00 from Mondays to Fridays.
All contractors operating machinery
Throughout decommissioning
Random noise measurements
Results of random noise measurements
Number of registered complaints
36. Notify adjacent residents or business premises before particularly noisy activities will take place.
37. If complaints regarding noise are received, investigate potential noise reduction measures such as mufflers on equipment.
38. Perform as much work as possible within the facilities to reduce noise in surrounding areas.
39. Maintain all generators, vehicles, vessels and other equipment in good working order to minimise exhaust fumes and excess noise.
Decommissioning phase measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe Monitoring Methods Performance Indicators
40. Reduce airborne dust at site through e.g.:
- Damping dust-generating areas with freshwater;
- Use of cloth or brush-barrier fences; and
- Covering dumps or stockpiles of lose material with plastic sheeting or netting, especially during windy conditions.
Contractors Visual assessment of dust plumes
Visibility of dust coming off site
Dust mitigation measures in place
Number of days that dust plumes are visible
Traffic Management
41. Manage decommissioning activities so as to minimise impacts on road traffic as far as possible, e.g.:
- Attempt to arrange delivery of materials when it will least disrupt traffic;
- Stagger deliveries if possible rather than concentrating them during rush hours; and
- Keep materials and machinery at the site throughout the decommissioning period, where possible.
All contractors operating vehicles or vessels
Throughout decommissioning
Keep record of vehicles entering the site and time they enter
Keep record of incidences and complaints
Visually inspect vehicles for any obvious faults or overloading
Number of incidences and complaints
Number of vehicles travelling to site each day
Condition of vehicles
42. Ensure that all safety measures are observed and that drivers comply with the rules of the road.
43. Ensure that vehicle axle loads do not exceed the technical design capacity of roads utilised by the project.
44. Investigate and respond to complaints about traffic.
Housekeeping 45. Regularly inspect all machinery and holding tanks for leaks or damages.
Throughout decommissioning
Visually inspect areas inside and outside the plant for pollution
Number of contaminations noted on site
46. Repair any defects as soon as possible. In the case of leaks, ensure that the leaking water or effluent is captured and not released into the environment.
47. Keep the area outside of the plant clean, especially during the rainy season when pollutants can wash into the sea with the stormwater.
48. Maintain a complaints register for all complaints. The register must list:
- Complainant name and contact details;
- Date complaint was lodged;
- Person who recorded the complaint;
- Nature of the complaint;
- Actions taken to investigate the complaint and outcome of the investigation;
- Action taken to remedy the situation;
- Date on which feedback was provided to complainant.
Inspect complaints register
Availability of register on site
Designated person to maintain register
Complaints logged
Complaints followed up and closed out
Decommissioning phase measures
Aspect ID Mitigation measure / Procedure Responsible Implementation Timeframe Monitoring Methods Performance Indicators
Response to environmental pollution
49. In the event of environmental pollution, e.g. through spillages, immediately stop the activity causing the problem.
EBS / Contractors
Throughout decommissioning
Maintain register of pollution events and response
Following resumption of activities, frequently inspect repaired equipment to ensure proper functioning
Number of incidents
Time activities stopped
Number of recurring incidents
Availability and completeness of register
50. Only resume activity once the problem has been stopped or (in the case of spillages) the pollutant can be captured without reaching the environment.
51. Repair faulty equipment as soon as possible.
52. Install additional bunding / containment structures around the equipment that was the source of the leak / spillage to prevent pollution from reaching the environment in future.
53. Treat hydrocarbon spills, e.g. during refuelling, with adequate absorbent material, which then needs to be disposed of at a suitable landfill.
General 54. Provide adjacent landowners with contact details to register any observations and complaints following decommissioning.
EBS or as determined in detailed plan
Before the end of decommissioning
55. Clarify issues of residual liability before relinquishment.
Rehabilitation 56. Rehabilitate areas as required by authorities and in terms of the intended future land use and the decommissioning plan.
EBS or as determined in detailed plan
After decommissioning Visual inspection of rehabilitation areas, if any
Success of rehabilitation
57. Notify relevant authorities and key stakeholders when decommissioning and rehabilitation are completed.
Review notifications sent
The Matrices have been developed and already implemented by SRK Consultancy during the Environmental and Social Assessment of the NV EBS DPP2 Power Plant.
All data used as source material plus the text, tables, figures, and attachments of this document have been reviewed and prepared in accordance with generally
accepted professional engineering and environmental practices.
6. Conclusion
Through the implementation of this management plan the NV EBS works towards the compliance
of the national regulations, NV EBS policies and IADB’s policies on environment, occupational
health and safety and social aspects.