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2.6.3 Environmental protection plan

Contents
2.6.3.1 Environmental protection compliance
2.6.3.2 Operation and control of environmental protection

2.6.3.1 Environmental protection compliance

Participants in a site remediation program will be expected to comply, as a minimum, with the environmental legislation, regulations at all places of work and other guidelines specified in any scope of work. Owners and operators of nuclear-licensed sites and defense sites are large organisations, and can be expected to hold, or have management systems designed to meet, the requirements of ISO 14001 52.
Such organisations will also be committed to continuous improvement programmes, and it may be expected that these organisations will require their consultants and subcontractors to meet specified requirements of environmental management competency. The adherence of suppliers to these requirements should also ensure:

  • Compliance with corporate environmental policies;
  • Minimisation of liabilities (i.e., not to exacerbate risk from any existing contamination or create new contamination or impacts);
  • Maintenance of integrated compliance with health, safety, security and environmental aspects;
  • Management of stakeholder involvement.

2.6.3.2 Operation and control of environmental protection

When producing specifications or evaluating tenders for site remediation works, site owners and occupiers (who are typically also the client) should ensure that the works comply with the requirements of the site’s environmental policy and environmental management system. In demonstrating that this is the case, consultants and subcontractors should ensure that their own assessments are site specific and activity specific. Effective communication and flow of information between the client/liability holder and consultant/contractor is necessary to demonstrate that the environmental protection systems of the two parties are compatible.

Guidance on compliance with an environmental management system is given in the ISO:14000 series 52. The key principles are listed below:

  • Minimise the direct and indirect adverse environmental effects of a site remediation programme. This should be demonstrated by provision of a safety, health and environment plan for performance of the work (not to be confused with a health and safety plan that may be required by the construction – design and management – regulations).
  • Every individual should be suitably qualified, trained and experienced to carry out their work and to understand their responsibility for the environmental effects of their activities.
  • Managers at all levels should understand their responsibilities for the environmental effects of the activities of the employees, contractors and visitors under their control.
  • All staff should know the environmental objectives and targets relevant to their work, and assume personal responsibility for the environmental effects of their actions.
  • Equipment and facilities used for site characterisation work should be appropriate for the job, adequately maintained and operated to a suitable system of work. This will minimise, as far as reasonably practicable, direct environmental effects.
  • All staff should know the procedures for reporting accidents and emergencies that have environmental implications, and the actions to be taken to minimize the effects of an accident.
  • Participation in audits, monitoring and review activities to check compliance with environmental legislation and management systems may be expected.
    Identification and evaluation of potentially significant environmental effects will be undertaken in a risk assessment specific to a site remediation activity. Such an assessment is likely to include consideration of the environmental aspects summarised in Table 2.7. An example of an environmental protection checklist is given in Appendix H.
Aspect description Example of activity or process Mitigation

Waste management Spoil generation and disposal Minimisation by choice of technique
Control of contaminated drilling returns

Water use Water flush drilling Avoid use

Materials storage and handling, including hazardous materials Fuel storage Store drums on appropriately sized bunded trays

Air quality Emission from generators Fit exhaust filters

Noise and vibration Use of heavy plant Refer to code of practice BS5228 – Noise control on construction and other open sites

Effluent including sewerage Purged borehole water Collection and disposal via authorised route

Contaminated land Interconnection of aquifers due to poor borehole design Borehole design to be approved by regulator

Ecology Disturbed flora Careful re-instatement of exaction locations

Odours Equipment emissions Site equipment so as to minimise impact, out of hours working

Transport Vehicle movements and their emissions Where appropriate ride a bicycle or electrical powered around site

Table 2.7 Some aspects of environmental protection appropriate to remediation activities