EMS in regeneration
The East Midlands Development Agency is tackling the environmental impacts associated with the regeneration of a former coking works via the application of an environmental management system (EMS) - The Avenue Project.
Risks of remediation
These significant environmental impacts are being tackled under the management of the current site owner, the East Midlands Development Agency (EMDA). The use of an environmental management system (EMS) specific to the regeneration scheme was proposed by EMDA's consultants, the Babtie Group. Babtie has been engaged as the lead consultant in a consortium also comprising the Turner and Townsend Group and TEP - The Environment Partnership. Over the next six years EMDA is to manage the regeneration of the site to improve environmental performance using best practice techniques in close liaison with the Environment Agency such that the site can benefit the local community. The work is being carried out largely from funding from the now Department of the Environment, Food and Rural Arrairs (DEFRA).
EMDA recognises that, whilst the site is currently having a significant impact on the environment, there are also numerous potential impacts associated with the project when the contaminants present are disturbed and treated and with the regeneration of the site. EMDA is committed to the implementation of an EMS across the site in order to ensure that the liabilities left from previous activities on site - as well as those associated with the project itself - are controlled, monitored and reviewed effectively.
As Phil Reeve, EMDA's project co-ordinator, stresses: "EMDA recognises the challenge of delivering a remediation project of the Avenue's size. The EMS is seen as the best means of identifying, assessing, and managing the complex interactions between activities. It will ensure delivery in accordance with full legal compliance, assist in developing and demonstrating best practice to our community partners, and address the stigma associated with the eventual disposal of reclaimed brownfield land."
Although the River Rother is of poor quality, wildlife has done well at the site since it closed and the river corridor now provides an important corridor for wildlife where species including grass snakes, great crested newts, water voles, kingfishers and other nesting birds can be found. In the long run EMDA hopes to encourage many other species to re-colonise the site once it is restored. Before this can be achieved, the EMS is being employed as a tool to manage the major engineering works to ensure that wildlife is fully protected at all times.
Work to date has focused primarily on preliminary assessments and an extensive site investigation to determine the extent and nature of the contaminants present. More recently, the process of draining down residues within the chemical plant has started, and the structures are being demolished. With over 300 tanks, 200 sumps and thousands of pipe runs, this will continue well into 2002. Trials are also underway to determine the most suitable remediation technologies for each of the materials present on site; these will enable a full-scale remediation programme to commence in 2002. Technologies currently under trial include soil bioremediation, washing and enhanced thermal conduction, and may later be expanded to include soil stabilisation. These technologies will help to deliver the objective of minimising the off-site disposal of wastes. The site's final masterplan is yet to be finalised but it is likely to involve a variety of land-uses, including recreational areas and an extension of the existing habitats on site to increase biodiversity.
The project's lead consultants, Babtie Group, are providing both the engineering solutions for the site and an EMS within which to deliver them. During the initial development of the EMS, Babtie undertook a detailed review of the environmental aspects of the project. Those that were found significant were ranked into six priority bands based on their potential to cause environmental harm; aspects with legal compliance issues were given the highest priority. This has allowed a review of monitoring and prioritisation of the many investigations required, ensuring that resources can be allocated to deal with the most significant issues first and that monitoring is proportional to the actual or potential harm.
Rules of engagement
As many aspects relate to activities to be carried out by a variety of contractors, it was necessary to produce Site Environmental Rules (SERs) that all parties must adhere to. These cover:
- Good site practice and housekeeping;
- Water and wastewater management and disposal;
- Waste management and disposal;
- Storage, use and handling of hazardous substances;
- Emissions to air and statutory nuisance; and
- Conservation and ecology.
The SERs are included within all new tender documents along with a health, safety and environmental questionnaire that forms the basis of the assessment of environmental performance and management prior to appointment of contractors. The SERs are developed further in task-specific method statements that are reviewed for technical, health, safety and environmental considerations before work is undertaken. Babtie's site-based condition manager carries out weekly inspections to ensure that the rules are implemented in practice. Issues identified are discussed with the relevant parties and verbal agreements are made as to the actions to be taken and their timescale. Whilst the majority of issues are resolved in this way, the more significant issues and ongoing issues are dealt with using health, safety and environmental concern forms. These forms are also available to everybody on site such that any concerns can be raised as they are identified throughout the project.
One of the key elements of the system is the provision of training for everybody on site in the form of an induction that covers all the SERs and areas of note on the site, for example the known locations of the water voles, great crested newts and nesting birds. Contractors also provide more detailed toolbox talks specific to each task and for activities such as refuelling and spill control.
Manage to measure
The effectiveness of the EMS is reviewed in monthly audits and through monthly health, safety and environmental review meetings in which the site's environmental performance is discussed. These allow current issues to be raised with the site's management and allow some of the more difficult issues associated with the site, such as the pollution of the Rother, to be discussed. The overall structure of the EMS will be reviewed every six months during management reviews.
The EMS is still in its early days, but already the awareness of site staff
at all levels has been seen to increase.