Management Plan

EIA Study of proposed 220kV Transmission Line Project, Kajiado County, Kenya
Table of Contents
11 Environment Management Plan (EMP) ...................... 11-2
11.1 Objectives of the EMP .................................................... 11-2
11.2 EMP roles and responsibilities ...................................... 11-2
11.2.1 Project Manager .................................................................... 11-3
11.2.2 Project HSE Officer ............................................................... 11-3
11.2.3 EPC Contractor ..................................................................... 11-4
11.2.4 Contractor HSE Officer ......................................................... 11-4
11.2.5 Independent HSE Auditor ..................................................... 11-4
11.2.6 Environmental management responsibilities ......................... 11-5
11.3 Environmental monitoring ............................................. 11-5
11.3.1 Compliance with the EMP and associated documentation .... 11-6
11.3.2 Training and Awareness ....................................................... 11-6
11.4 EMP requirements for pre-construction phase ............ 11-7
Chapter: Environment Management Plan (EMP)

11.5 EMP requirements for construction phase ..................11-10
11.5.1 Site preparation ................................................................... 11-10
11.5.2 Establishment of Construction Camps and Materials yards 11-10
List of Tables
Table 11-1: Environment Management Plan-Pre-construction Phase ..................................11-8
Table 11-2: Environment Management Plan-Construction Phase ......................................11-11
Table 11-3: Environment Management Plan-Operations Phase .........................................11-27
Table 11-4: Social Management Plan .................................................................................11-29
© Kurrent Technologies Ltd. Revision 00: August 2013 11-1

11 Environment Management Plan (EMP)
This EMP seeks to manage and keep to a minimum the negative impacts of the
proposed 220kV transmission line project and at the same time, enhance the
positive and beneficial impacts.
11.1 Objectives of the EMP
The objectives of the EMP are to:

 Identify a range of mitigation measures which could reduce and mitigate the
potential impacts to minimal or insignificant levels;
 To identify measures that could optimize beneficial impacts;
 To create management structures that address the concerns and complaints of
stakeholders with regards to the development;
 To establish a method of monitoring and auditing environmental management
practices during all phases of development;
 Ensure that the construction and operational phases of the project continues
within the principles of Integrated Environmental Management;
 Detail specific actions deemed necessary to assist in mitigating the
environmental impact of the project;
 Ensure that the safety recommendations are complied with;
 Propose mechanisms for monitoring compliance with the EMP and reporting
thereon; and
 Specify time periods within which the measures contemplated in the final
environmental management plan must be implemented, where appropriate.

11.2 EMP roles and responsibilities
Several professionals will form part of the construction team. The most important
from an environmental perspective are the Project Manager (Galetech Energy
Developments of Ireland), the Project HSE Officer, the EPC Contractor, and the
developer (Kipeto Energy Limited).
The Project Manager is responsible for ensuring that the EMP is implemented
during the pre-construction and construction phases of the project.
The Project HSE Officer is responsible for monitoring the implementation of the
EMP during the design, pre-construction and construction phases of the project.
The EPC contractor is responsible for abiding by the mitigation measures of the
EMP which are implemented by the Project Manager during the construction
phase.

The Project Manager is responsible for ensuring that the EPC contractor complies
with the mitigation measures and EMP requirements during the design, pre-
construction and construction phases of the project.
An Operations and Maintenance (O&M) company will be responsible for
implementation of the EMP during the operational and decommissioning phases
of the project. Decommissioning will however entail the appointment of a new
professional team and responsibilities will be similar to those during the design,
pre-construction and construction phases. It is unlikely that the transmission line
will be decommissioned for several years.
11.2.1 Project Manager
The Project Manager is responsible for overall management of the project and
EMP implementation. The following tasks will fall within his/her responsibilities:
 Be aware of the findings and conclusions of the Environmental Impact
Assessment and the conditions stated within the EIA License issued by
NEMA;
 Be familiar with the recommendations and mitigation measures of this EMP,
and implement these measures;
 Monitor site activities on a daily basis for compliance;
 Conduct internal audits of the construction site against the EMP;
 Confine the construction site to the demarcated area; and
 Rectify transgressions through the implementation of corrective action.
11.2.2 Project HSE Officer
The Project HSE Officer is responsible for the implementation of the EMP during
the construction phase as well as liaison and reporting to the Developer,

Contractor, Landowners and Authorities. The following tasks will fall within
his/her responsibilities:
 Be aware of the findings and conclusions of the Environmental Impact
Assessment and the conditions stated within the EIA License;
 Be familiar with the recommendations and mitigation measures of this EMP;
 Conduct weekly/monthly audits of the construction site according to the EMP
and EIA License conditions;
 Educate the construction team about the management measures of the EMP
and EIA License conditions;
 Regularly liaise with the construction team and the project leader;
 Recommend corrective action for any environmental non-compliance
incidents on the construction site; and
 Compile a regular report highlighting any non-compliance issues as well as
good compliance with the EMP.

11.2.3 EPC Contractor
The EPC contractor is responsible for the implementation and compliance with
recommendations and conditions of the EMP.
 Ensure compliance with the EMP at all times during construction
 Maintain an environmental register which keeps a record of all incidents
which occur on the site during construction. These incidents include:
o Public involvement / complaints
o Health and safety incidents
o Incidents involving Hazardous materials stored on site
o Noncompliance incidents
Most Landowners will see the construction period as interference with their daily
activities. There could potentially be a negative attitude towards the whole
construction process.
Landowners are always apprehensive toward changes they do not control and
strangers on their properties. If and where the transmission line is close to any
inhabited area, the necessary precautions shall be taken by the Contractor to
safeguard the lives and property of the inhabitants. The Contractor shall under no
circumstances interfere with the property of Landowners or nearby Communities.
11.2.4 Contractor HSE Officer
The Contractor HSE Officer will be appointed by the EPC contractor to monitor
activities on site on a daily basis. The Contractor HSE Officer will be the HSE
Officer’s representative on the site and will report back on all audit trips. The
Contractor HSE Officer must report any major incidents immediately to the
Project HSE Officer.

11.2.5 Independent HSE Auditor
The independent HSE auditor will conduct an environmental audit during the
construction phase of the project on a six-monthly basis according to the
provisions of the Environmental Management Plan. The independent auditor will:
 Conduct independent environmental audits;
 Submit audit reports to the Project HSE Officer and if required, relevant
authority;
 Engage specialist sub-consultants when required.

11.2.6 Environmental management responsibilities
The following are the environmental management responsibilities of the various

parties during construction and operational phases. Unless otherwise stated the
EMP will be adhered to as follows:
 The Contractor’s HSE Officer will be the responsible party for compliance
with this EMP during the construction phase;
 The monitoring party will be the Project HSE Officer;
 Method of record keeping will be weekly to two weekly inspections
depending on the stage of the project;
 The inspection technique will include a review of records that will be kept on
site by the Contractor HSE Officer and/or site inspections;
 The Client will bear ultimate responsibility for environmental management.
11.3 Environmental monitoring
A monitoring program will be implemented for the duration of the construction

phase of the project. This program will include:
 Monthly environmental inspections to confirm compliance with the EMP and
EIA License conditions. These inspections can be conducted randomly and do
not require prior arrangement with the project manager;
 Compilation of an inspection report complete with corrective actions for
implementation;
 Monthly HSE committee meetings to be held to ensure compliance with the
OSHA and its subsidiary legislation.
The HSE Officer shall keep a photographic record of any damage to areas outside
the demarcated site area. The date, time of damage, type of damage and reason for

the damage shall be recorded in full to ensure the responsible party is held liable.
All claims for compensation emanating from damage should be directed to the
Project HSE Officer for appraisal. The Contractor shall be held liable for all
unnecessary damage to the environment. A register shall be kept of all complaints
from the Landowner or community. All complaints/claims shall be handled in a
timely manner to ensure timeous rectification/payment by the responsible party.
It should be noted that it is difficult to outline a formal monitoring protocol for
specific environmental parameters and key impacts until detailed transmission line
design have been completed. A formal monitoring protocol will be included
within the revised EMP once the detailed transmission line design has been
completed, and once recommendations and conditions from the reviewing
authority have been received. It should further be noted that for the same reasons
mentioned above, it is difficult to delineate the cost of the EMP for specific
mitigation measures and therefore this has been excluded from the EMP tables.

The EPC contractor shall be responsible for acquiring all necessary permits during
the construction phase of the project. Such licenses include any abstraction of
water permits, local authority approvals for camp site locations and operations,
extraction of aggregates from borrow pits and their rehabilitation, etc.
11.3.1 Compliance with the EMP and associated documentation
A copy of the EMP must be kept on site during the construction period at all
times. The EMP will be made binding on all contractors operating on the site and
must be included within the Contractual Clauses. It should be noted that in terms
of the principles of environmental management espoused through the EMCA,
those responsible for environmental damage must pay the repair costs both to the
environment and human health measures to reduce or prevent further pollution
and/or environmental damage (the polluter pays principle).
The Contractor is deemed not to have complied with the EMP if:
 Within the boundaries of the site, site extensions and haul/access roads there is
evidence of contravention of clauses; or
 If environmental damage arises due to negligence; or
 The contractor fails to comply with corrective or other instructions issued by
the Project HSE Officer or Authorities within a specified time; or
 The Contractor fails to respond adequately to complaints from the public.
The Proponent is deemed to be out of compliance with the EMP if:
 Within the boundaries of the site there is evidence of contravention of clauses;
 If environmental damage arises due to negligence;
 The Proponent fails to respond adequately to complaints from the public.
11.3.2 Training and Awareness

11.3.2.1 Training of Construction Workers
The Construction Workers must receive basic training in environmental
awareness, including the storage and handling of hazardous substances,
minimization of disturbance to sensitive areas, management of waste, and
prevention of water pollution. They must also be appraised of the EMP’s
requirements.
11.3.2.2 Contractor Performance
The Contractor must ensure that the conditions of the EMP are adhered to. Should
the Contractor require clarity on any aspect of the EMP, the Contractor must
contact the Project HSE Officer for advice.

11.4 EMP requirements for pre-construction phase
The requirements that need to be fulfilled during the pre-construction phase of the
project are as follows:
 There should be continuous liaison between the Proponent, the EPC contractor
and Landowners along the wayleave to ensure all parties are appropriately
informed of construction phase activities at all times;
 The Landowners should be informed of the starting date of construction as
well as the phases in which the construction will take place;
 The EPC contractor must adhere to all conditions of contract including the
Environmental Management Plan;
 The EPC contractor should plan the construction program taking cognizance
of climatic conditions along the wayleave especially wet seasons and
disruptions that can be caused by heavy rains;
 Where existing private roads are in a bad state of repair, such roads’ condition
shall be documented before they are used for construction purposes. This will
allow for easy assessment of any damage to the roads which may result from
the construction process. If necessary some repairs should be done to prevent
damage to equipment;
 The construction site office must keep a proper record of all complaints
received and actions taken to resolve the complaints;
 A Project HSE Officer should be appointed by the Proponent and Contractor
HSE officer should be appointed by the EPC contractor to implement this
EMP as well as deal with Landowner related matters;
 Internal and external environmental inspections and audits should be
undertaken during and upon completion of construction. The frequency of
these audits should be quarterly;
 The Project HSE Officer should conduct regular inspections along the

wayleave in order to maintain good control over the construction process
during the construction phase;
 A formal communications protocol should be set up during this phase. The
aim of the protocol should be to ensure that effective communication on key
issues that may arise during construction be maintained between key parties
such as the Project HSE Officer, project manager and EPC contractor. The
protocol should ensure that concerns/issues raised by stakeholders are
formally recorded and considered and where necessary acted upon. If
necessary, a forum for communicating with key stakeholders on a regular
basis may need to be set up. This could be done through the EPC contractor’s
site office that would meet on a regular basis. The communications protocol
should be maintained throughout the construction phase.

Table 11-1: Environment Management Plan-Pre-construction Phase
Impact Environmental Mitigation Measure/Monitoring Plan Responsibility Frequency/

Monitoring
requirement
Pre-construction 1) The Proponent should appoint a project HSE Officer while the EPC Contractor KEL, Project Bi-monthly
phase impacts should appoint his/her HSE officer; HSE Officer
2) Demarcate clearly (e.g. using fencing) all areas to be developed before construction
commences;
3) The EPC contractor to comply with the conditions of the EIA License for the
project;
4) Maintain records of environmental incidents and avail a copy of these records to
relevant lead agencies on request throughout the construction phase;
5) Identify and confirm suitable sites for the construction camps and storage areas for
materials;

6) Store construction equipment in construction camps. Ensure oil changes take place
on an impermeable surface such as reinforced concrete slab;
7) Provide as much as possible opportunities for employment to persons from the local
areas along the wayleave;
8) Train site staff on the following areas of environmental management;
a) Environmental awareness training for construction staff, concerning the
prevention of accidental spillage of hazardous chemicals and oil; pollution of
water resources (both surface and groundwater), air pollution and litter control
and identification of archaeological artifacts;
b) Project Manager shall ensure that the training and capabilities of the
Contractor’s site staff are adequate to carry out the designated tasks;


Monitoring
requirement
c) Operators of construction equipment (such as excavators, loaders, etc.) shall be
adequately trained and sensitized to any potential hazards associated with their
tasks;
d) No operator shall be permitted to operate critical items of mechanical equipment
without having been trained by the EPC Contractor and certified competent by
the Project Manager;
e) Staff should be educated as to the need to refrain from indiscriminate waste
disposal and/or pollution of local soil and water resources and receive the
necessary safety training.

11.5 EMP requirements for construction phase
11.5.1 Site preparation
Site clearing along the wayleave will be limited to the width of the proposed
wayleave which is about 60m. Site clearing must take place in a phased manner,
as and when required. Areas which are not to be constructed on within say one
month of time must not be cleared to reduce erosion risks. The area to be cleared
must be clearly demarcated and this footprint strictly maintained. Topsoil from the
must be neatly stockpiled at the edge of the wayleave ready for backfill when
required.
11.5.2 Establishment of Construction Camps and Materials yards
The proposed 100MW wind farm and 220kV transmission line project will utilize
approximately two construction camps and laydown areas. The construction camp
locations have been identified based on the ease of access to the wind farm area as
well as the transmission line.
Site establishment shall take place in an orderly manner and all required amenities
shall be installed at Camp sites before the main workforce move onto site. The
Construction camp shall have the necessary ablution facilities with chemical
toilets at commencement of construction. The EPC Contractor shall inform all site
staff to make use of supplied ablution facilities and under no circumstances shall
indiscriminate sanitary activities be allowed other than in supplied facilities.
The Contractor shall supply waste collection bins where such is not available and
all solid waste collected shall be disposed of using NEMA approved waste
handlers. A Waste Tracking Sheet required by Legal Notice 121: Waste
Management Regulations, 2006 will be obtained by the EPC contractor and kept
on file. The disposal of waste shall be in accordance with the Waste Management
Regulations, 2006. Under no circumstances may any form of waste be burnt on

site.

Table 11-2: Environment Management Plan-Construction Phase

Monitoring
requirement
Poor traffic and Construction traffic EPC contractor, Bi-weekly
access Project HSE
1. Clearly define construction routes and required access roads;
management Officer
during 2. Use the minimum number of trips for delivering construction plant and equipment
construction along the wayleave;
3. Strictly control the access of all construction and material delivery vehicles
especially during wet weather to avoid compaction and damage to the topsoil
structure;
4. Schedule the delivery hours to avoid peak hour traffic, weekends and evenings;
5. Implement wheel washing and damping down of un-surfaced roads to reduce dust
and nuisance;

6. Service vehicles and equipment regularly to avoid the contamination of soil from
oil and hydraulic fluid leaks, etc. Servicing of vehicles and equipment must be
done off-site and on an impermeable surface such as concrete;
7. Soils compacted by construction equipment along the wayleave should be ripped
and regarded.
Access
8. Rehabilitate temporary access roads prior to the EPC contractor leaving the site;
9. Position entry and exit points strategically to ensure minimal effects on traffic;
10. Clearly signpost primary routes to the site and issue to all suppliers and Sub-
Contractors.


Monitoring
requirement
11. Plan access routes to the site for construction purposes in conjunction with the EPC
contractor and affected Landowners. All agreements reached should be documented
and no verbal agreements should be made. The EPC contractor shall clearly mark
all access roads.
12. Where new access roads are constructed, this must be done according to design and
contract specifications. Drainage channels shall be suitably designed to ensure
erosion does not occur, especially at the outflow points. The new access road shall
be designed to allow for the natural flow of water where required. Crossing of
eroded areas on access routes to new sites shall be thoroughly planned and installed
according to design and contract specifications. All areas susceptible to erosion
shall be protected with suitable erosion control measures from the onset of the
project. Prevention is the ultimate aim, as restoration is normally difficult and
costly.

Road maintenance
13. All damaged roads shall be rehabilitated using suitable measures. In the event of
rehabilitation work being required on private roads, such work will be done to the
original specifications of the private road;
14. Access roads should be maintained in good condition by attending to potholes,
corrugations and stormwater damage as soon as these develop.
General
15. Safety requirements shall be complied with at all times during the construction
phase. All equipment transported shall be clearly labeled as to their potential
hazards according to specifications. All the required safety labeling on the
containers and trucks used shall be in place;


Monitoring
requirement
16. The Contractor shall ensure that all the necessary precautions against damage to the
environment and injury to persons are taken.
Improper setup Site of construction camp EPC contractor, Bi-weekly
and operation of 1. The EPC contractor to seek approval from the relevant local authority for the Project HSE
Construction Officer,
location of the construction camp. Factors to consider during siting of construction
camps Contractor HSE
camps include location of local residents and/or ecologically sensitive areas,
Officer
including flood zones and slip/unstable zones. If the EPC contractor chooses to
locate the camp site on private land, he must get prior permission from both the
Project Manager and respective landowner;
2. Minimize the size of the construction camp (especially where natural vegetation or
grassland has had to be cleared for its construction);
3. Provide adequate parking for site staff and visitors. This should not inconvenience

or serve as a nuisance for neighbors;
4. Provide adequate drainage around the camp site to avoid standing water and/or
sheet erosion.
Storage of materials (including hazardous materials)
5. Choose storage area location by considering prevailing winds, distances to water
bodies, general onsite topography and water erosion potential of the soil.
Impervious surfaces must be provided where necessary;
6. Designate, demarcate, fence off and secure all storage areas to minimize the risk of
crime; storage areas should be safe from access by unauthorized persons;
7. Provide fire prevention facilities at all storage facilities;


Monitoring
requirement
8. Store all hazardous materials such as oils, paints, thinners, fuels, chemicals, etc. in
properly constructed and impermeable bunded areas. Hazardous materials must not
be allowed to contaminate the subsurface or enter into drainage systems. Siting of
hazardous material storage areas must be approved by the Project Manager.
9. The EPC contractor to acquire MSDSs for all chemicals and hazardous substances
used on site. Training on environmental impacts of chemicals and hazardous
substances and PPE required to worn must be provided to the users.
10. Hazardous material storage areas must be signposted clearly
11. Use a NEMA licensed waste handler for disposal of all used oils from the camp
sites. A waste tracking sheet must be completed as required by L.N. 121: Waste
Management Regulations 2006 whenever used oils are being disposed.

12. Dispose off any excess concrete mixes in consultation with the Project Manager.
13. Immediately contain, recover and cleanup any spillages that may occur during the
construction phase. All spillages must be reported to the HSE Officer and Project
Manager.
Drainage of construction camp
14. Ensure that all potentially contaminated run-offs from the construction camp meets
the discharge limits set under Legal Notice 120: Water Quality Regulations. Run-
off from the camp site must NOT discharge into neighbors’ properties or into
adjacent wetlands, rivers or streams.


Monitoring
requirement
End of construction
15. Rehabilitate all storage areas after construction has been completed on site and all
excess material has been removed. Such areas shall be rehabilitated to their natural
state. Any spilled concrete shall be removed and soil compacted during
construction shall be ripped, leveled and re-vegetated;
16. Store construction materials, soil stockpiles, machinery and other equipment in
designated areas;
17. The construction camp must be kept clear of litter at all times. Spillages within the
construction camp need to be cleaned up immediately and disposed of in the
hazardous skip bin for correct disposal. No open fires are allowed within the
construction camp and no wood from surrounding vegetation may be used to create
a fire.

Lack of HSE Environmental training EPC contractor, Monthly
training for 1. Ensure that all site personnel have a basic level of environmental awareness Project HSE
construction Officer
training. The EPC contractor must submit a proposal for this training to the Project
staff HSE Officer for approval.
Topics covered should include;
 What is meant by “Environment”;
 Why the environment needs to be protected and conserved;
 How construction activities can impact on the environment;
 What can be done to mitigate against such impacts;
 Awareness of emergency and spills response provisions; and
 Social responsibility during construction e.g. being considerate to local


Monitoring
requirement
residents.
2. It is the Contractor’s responsibility to provide the site foreman with no less that 1
hour’s environmental training and to ensure that the foreman has sufficient
understanding to pass this information onto the construction staff;
3. Training should be provided to the staff members on the use of the appropriate fire-
fighting equipment. Translators are to be used where necessary;
4. Use should be made of environmental awareness posters on site;
5. The need for a “clean site” policy also needs to be explained to the workers;
6. Staff operating equipment (such as excavators, loaders, etc.) shall be adequately
trained and sensitized to any potential hazards associated with their tasks.
Monitoring of environmental training

7. The Contractor must monitor the performance of construction workers to ensure
that the points relayed during their induction have been properly understood and are
being followed. If necessary, the Contractor HSE Officer and/or a translator should
be called to the site to further explain aspects of environmental or social behavior
that are unclear. Toolbox talks are recommended.
Improper use Location of borrow pits EPC contractor, Monthly
and Project HSE
1. Borrow pit localities must be negotiated with the relevant local authority to ensure
management of Officer,
consensus of their location;
borrow pits Contractor HSE
Management of borrow pits Officer
2. The EPC contractor must also compile an information document which states the
methods which will be utilized when creating borrow pits. This document must
include, but not be limited to the following:


Monitoring
requirement
 Plans which detail the expected quantity of excavation that will be required;
 Temporary and permanent stormwater control;
 The final contouring of the borrow pit and the proposed method of
rehabilitation;
 The current status and land use of the borrow pit;
 Topsoil management strategy (preservation of topsoil for reinstatement);
 Proposed management of dangerous conditions (e.g. steep slopes, loose and
unstable material, holes).
Impacts relating General construction EPC contractor, Bi-weekly
to construction 1. Limit construction time to daylight hours in sensitive areas such as residential areas. Project Manager

of the
Where construction is required after hours in order to avoid traffic interruptions,
transmission notification is to be sent out to all potentially affected land owners.
line
2. Send out prior notifications to relevant lead agencies, parastatals, etc. when essential
services such as water or electricity are to be affected by the construction process.
Clearing and grading
3. Refer to paragraph 11.5.1 above.
Construction of lattice towers
4. The design of the towers should be done in accordance with applicable international
standards.
5. The tower foundations will be constructed out of reinforced concrete in accordance
with appropriate design standards
6. Contractors experienced in the erection of towers will be engaged


Monitoring
requirement
7. The contractor will clean up the tower foundation area after erection of each tower
and all wastes handled in accordance with L.N. 121: Waste Management
Regulations, 2006.
Stringing cables on insulators
8. The correct insulators as provided in the Project Manager’s specifications will be
used.
9. Carefully inspect the transmission cables for defects as they are strung from the
drums.
10. Use the correct cable sizes according to appropriate transmission line standards and
codes of practice for a 220kV transmission line.
Foundations for towers

11. Clear as little as possible the four holes required for the steel tower foundation legs.
12. Place the top soil on one side of the excavated hole for use during reinstatement
13. Excavate and cart away to an approved land fill site the soil removed below the top
soil level to the final depth of each hole
Reinstatement
14. Rip the compacted areas along the wayleave to loosen the soil and then rehabilitate
it.
Impacts related Soil erosion EPC contractor, Monthly
to soils and 1. Provide wind screening and stormwater control to prevent soil loss from the site; Project HSE
geology Officer
2. Use silt fences and/or sand bags in areas that are susceptible to erosion;
3. Sensitive areas need to be identified prior to construction so that the necessary


Monitoring
requirement
precautions can be implemented.
4. Regularly maintain all erosion control mechanisms;
5. Retain vegetation where possible to avoid soil erosion. Vegetation clearance
should be phased to ensure that the least area of soil is exposed to potential erosion
at any one time;
6. Re-vegetate disturbed surfaces immediately after construction activities are
completed;
Soil compaction
7. Construction vehicles must only be allowed to utilize existing tracks or pre-planned
access routes.
8. Soils compacted during construction should be deeply ripped to loosen compacted

layers and re-graded to even running levels. Topsoil should be re-spread over
landscaped areas.
Soil contamination
9. The EPC contractor will arrange to remove all construction related contaminated
topsoil to the full depth of pollution and replace it at his own expense with
approved topsoil;
10. The EPC contractor will be responsible for remediating any polluted topsoil.
Impacts related Sanitation EPC contractor, Weekly
to surface water 1. Provide adequate sanitary facilities for male and female construction workers in Project HSE
and Officer
accordance with the Public Health Act requirements;
groundwater
2. Ensure that sanitary facilities are regularly serviced and emptied to reduce the risk
of surface or groundwater pollution.


Monitoring
requirement
Hazardous materials
3. Place all hazardous materials in bunded containment areas with sealed surfaces;
4. All hazardous substances must be stored at least 50m from any water body on site;
5. Contaminated wastewater must be managed by the Contractor to ensure existing
water resources on the site are not contaminated. All wastewater from general
activities in the camp shall be collected, treated and removed from the site for
appropriate disposal.
Public areas
6. Food preparation areas should be provided with adequate washing facilities and
food refuse should be stored in sealed refuse bins which should be removed from
site on a regular basis;

7. The EPC contractor should take steps to ensure that littering by construction
workers does not occur and persons should be employed on site to collect litter
from the site and immediate surroundings, including litter accumulating at fence
lines;
8. No washing or servicing of vehicles will be allowed on permeable surfaces.
Water resources
9. Site staff shall not be permitted to use any other open water body or natural water
source adjacent to or within the designated site for the purposes of bathing or
washing of clothing;
10. Treated water (or another source approved by the Project HSE Officer) should
instead be used for all activities such as washing of equipment or disposal of any
type of waste, dust suppression, compacting, etc.
11. An Effluent Discharge License shall be acquired from NEMA for the camp site to


Monitoring
requirement
ensure effluent discharge compliance in accordance with the discharge limits stated
in L.N. 120: Water Quality Regulations, 2006.
Impacts of air Dust control EPC contractor, Daily
quality Contractor HSE
1. The EPC contractor will dampen un-surfaced and un-vegetated areas with a water
Officer
bowser or sprinklers when necessary to reduce dust;
2. Excavations and other clearing activities must only be done during agreed working
times and permitting weather conditions to avoid drifting of dust into neighboring
areas;
3. The Contractor shall be responsible for dust control on site to ensure no nuisance is
caused to a Landowner or neighboring communities;
4. A speed limit of 40km/h must not be exceeded;

5. Any complaints emanating from the lack of dust control shall be attended to
immediately by the EPC contractor.
Rehabilitation
6. The EPC contractor will commence rehabilitation of exposed soil surfaces as soon
as practical after completion of earthworks.
Fire prevention
7. No open fires shall be allowed on site under any circumstance. All cooking shall be
done in demarcated areas that are safe and cannot cause runaway fires;
8. The Contractor shall have operational fire-fighting equipment available on site at
all times. The level of fire fighting equipment must be assessed and evaluated
thorough a fire risk assessment process.


Monitoring
requirement
Impacts of noise 1. The EPC contractor should comply with applicable sections of Legal Notice 61: EPC contractor, Daily
on surrounding Noise and Vibration Pollution Control Regulations, 2009 for environmental noise Contractor HSE
areas and Legal Notice 25: Noise Prevention and Control Regulations, 2005 for Officer
occupational noise; where necessary hearing protection should be worn;
2. Construction site yards, workshops and other noisy fixed facilities should be
located well away from noise sensitive areas. Truck traffic should be routed away
from noise sensitive areas, where possible;
3. Construction activities are to be contained to reasonable hours during the day and
early evening. Night-time activities near noise sensitive areas should not be
allowed;
4. With regard to unavoidable very noisy construction activities in the vicinity of
noise sensitive areas, the contractor and his HSE Officer should liaise with local

residents on how best to minimize impact, and the local population should be kept
informed of the nature and duration of intended activities;
5. Noise from laborers must be controlled;
6. Noise suppression measures must be applied to all construction equipment.
Construction equipment must be kept in good working order and where appropriate
fitted with silencers which are kept in good working order. Should the vehicles or
equipment not be in good working order, the contractor may be instructed to
remove the offending vehicle or machinery from site;
7. The contractor must take measures to discourage laborers from loitering in the area
and causing noise disturbance. Where possible labor shall be transported to and
from the site by the contractor or his Sub-Contractors.


Monitoring
requirement
Impacts on Existing vegetation Project HSE Weekly
ecology along 1. Existing indigenous vegetation must be retained where possible. A follow up Officer,
the wayleave Contractor HSE
vegetation survey should be conducted before site clearing to demarcate vegetation
Officer
that should remain and remove and relocate any plants of botanical or ecological
significance. Vegetation will be removed as it becomes necessary;
2. Materials should not be delivered to the site prematurely which could result in
additional areas being cleared or affected;
3. No vegetation to be used for firewood.
Rehabilitation
4. All damaged areas shall be rehabilitated upon completion of the contract to as near
pre-construction conditions;

5. All natural areas impacted during construction must be rehabilitated with locally
indigenous grasses typical of the representative botanical unit;
6. Rehabilitation must take place as soon as construction is complete to avoid the edge
effect, the infiltration of alien species and soil erosion within the wayleave;
Permits
7. Permits for removal of any protected species must be obtained from KWS or KFS or
other relevant lead agency should such species be affected.
8. All plants not interfering with the operation of the transmission line construction
shall be left undisturbed, clearly marked and indicated on the site plan;
9. The construction workspace must be well demarcated and no construction activities
must be allowed outside of this demarcated footprint;
10. Only vegetation within the trench area to be excavated must be removed.


Monitoring
requirement
Vegetation removal must be phased in order to reduce impact of construction;
11. Construction site office and laydown areas must be clearly demarcated and no
encroachment must occur beyond demarcated areas.
12. Construction areas must be well demarcated and these areas strictly adhered to.
13. Soils must be kept free of petrochemical solutions that may be kept on site during
construction. Spillage can result in a loss of soil functionality thus limiting the re-
establishment of flora.
Utilization of resources
14. Gathering of firewood or any other natural material onsite or in areas adjacent to the
site is prohibited unless with prior approval of the Project HSE Officer.
Impacts arising Construction rubble EPC contractor, Weekly

from Project HSE
1. All rubble from demolition activities must either be used on site as part of the
inconsistent Officer,
existing development, or must be taken away from the project site and disposed off
waste Contractor HSE
appropriately;
management Officer
2. Rubble must not be dumped on site but must be placed within a receptacle for
regular removal;
3. Construction rubble shall be disposed of in pre–agreed, demarcated spoil dumps
that have been approved by the Kajiado County Council.
Litter management
4. Refuse bins must be placed at strategic positions to ensure that litter does not
accumulate within the construction site;
5. A housekeeping team should be appointed to regularly maintain the litter and
rubble situation on the construction site;


Monitoring
requirement
6. Waste disposal will need to take place in accordance with Legal Notice 121: Waste
Management Regulations, 2006;
7. Littering by the employees of the Contractor shall not be allowed under any
circumstances. The Contractor HSE Officer shall monitor the neatness of the work
sites as well as the Contractor campsite;
8. Receptacle containers should be maintained on site. These should be kept covered
and arrangements made for them to be disposed regularly form the site;
9. Waste Tracking Sheets providing disposal shall be provided for the Project HSE
Officer’s inspection.
Hazardous waste
10. All hazardous materials must be carefully stored as advised by the Project HSE

Officer, and then disposed offsite using NEMA approved waste handlers;
11. Contaminants will be stored safely to avoid spillage;
12. Machinery must be properly maintained to keep oil leaks in check.
Sanitation
13. The Contractor shall install mobile chemical toilets on the site;
14. Staff shall be sensitized to the fact that they should use these facilities at all times.
No indiscriminate sanitary activities on site shall be allowed;
15. There should be enough toilets available to accommodate the workforce in
accordance with the Public Health Act requirements. Male and females must be
accommodated separately where possible;
16. Toilets shall be serviced regularly and the contractor HSE Officer shall inspect
toilets;


Monitoring
requirement
17. Under no circumstances may open areas, neighbors fences or the surrounding bush
be used as a toilet facility;
18. Potable water must be provided for all construction staff.
Remedial actions
19. Depending on the nature and extent of the spill, contaminated soil must be either
excavated or treated on-site;
20. Excavation of contaminated soil will involve careful removal of soil using
appropriate tools/machinery to storage containers until disposed of using NEMA
approved waste handlers;
21. If a spill occurs on an impermeable surface such as cement or concrete, the surface
spill must be contained using oil absorbent materials;

22. If necessary, oil absorbent sheets or pads must be attached to leaky machinery or
infrastructure.
23. Materials used for the remediation of petrochemical spills must be used according
to product specifications and guidance for use.
24. Contaminated remediation materials must be carefully removed from the area of the
spill so as to prevent further release of petrochemicals to the environment, and
stored in adequate containers until appropriately disposed off.

Table 11-3: Environment Management Plan-Operations Phase

Monitoring
requirement
Impacts Removal of equipment EPC Contractor, Weekly
associated with 1. Remove all structures comprising the construction camp. Check for any previous Proponent,
construction site Project Manager,
construction related chemical soil contamination and cleanup. Return the ground
decommissioning Project HSE
conditions within the camp sites to their near original state by undertaking the
Officer,
necessary landscaping.
Contractor HSE
Associated infrastructure Officer
2. All rubble is to be removed from the site to an approved disposal site as approved
by the Project Manager. Burying of rubble on site is prohibited.
3. The site is to be cleared of all litter.
4. The Contractor is to check that all watercourses are free from building rubble, spoil

materials and waste materials.
5. Fences, barriers and demarcations associated with the construction phase are to be
removed from the site unless stipulated otherwise by the Engineer.
6. All residual stockpiles must be removed or spread on site as directed by the
Engineer.
Impacts Maintenance Proponent Monthly
associated with 1. All applicable standards, legislation, policies and procedures must be adhered to
transmission line
during operation;
operations and
maintenance 2. Periodic inspection of the wayleave must take place to monitor the status of the
transmission line;


Monitoring
requirement
Public awareness
3. The Proponent should conduct an HSE awareness campaign to
landowners/residents affected by the transmission line;
4. The emergency preparedness plan must be ready for implementation at all times
should an emergency situation arise.
Impacts on 1. Indigenous vegetation must be maintained along the wayleave and all exotic Proponent Monthly
biodiversity species removed as they appear and disposed off appropriately.
2. Vegetative re-establishment shall, as far as possible, make use of indigenous or
locally occurring plant varieties
3. No faunal species must be harmed by maintenance staff during any routine
maintenance at the transmission line.

Impacts on Emergency response plan Proponent Monthly
health and safety 1. Upon completion of the construction phase, an emergency response risk assessment
should be undertaken and specific contingency plans incorporated in the
transmission line crisis management plan to ensure the safety of the staff and
surrounding land owners and users in case of an emergency.

Table 11-4: Social Management Plan
Impact Social Mitigation Measure/Monitoring Plan Responsibility Frequency/

Monitoring
requirement
Impacts due to 1. The use of labor intensive construction measures should be used where appropriate; EPC contactor, Weekly
increased Project HSE
2. Training of labor to benefit individuals beyond completion of the project
employment in Officer,
the project area 3. Labor to be sourced from the local community where possible Contractor HSE
4. Local suppliers to be used where possible Officer
5. The Project Manager must ensure that all staff working on the proposed project
must be in possession of a Kenyan Identity Document or a relevant work permit.
Impacts related Worker safety Proponent, EPC Daily
to health and Contractor,
1. Implement safety measures, work procedures and first aid on site. Workers have the
safety on Project HSE
right to refuse work in unsafe conditions;
workers and the Officer,

public exposed 2. Develop and implement a construction health and safety plan which must be Contractor HSE
to construction approved by the Project Manager. Officer
hazards 3. Comply with the relevant requirements of OSHA during the construction phase and
especially Legal Notice 40: Building Operations and Works of Engineering
Construction Rules, 1984 (BOWEC);
4. Train workers thoroughly in the safe use of potentially dangerous equipment;
5. Contractors must ensure that all equipment is maintained in a safe operating
condition;
6. Record all incidents in a “General Register” as required by OSHA and maintain an
updated copy of the Register in the site office for inspection. Any health and safety
incident must be reported to the project manager immediately and a DOSH1 form
filled out and forwarded to the nearest County DOSHS Officer;
7. Provide first aid facilities on site at all times as required by Legal Notice 160: First


Monitoring
requirement
Aid Rules, 1977;
8. The Contractor shall take all the necessary precautions against the spreading of
disease such as measles, foot and mouth, etc. especially under livestock;
9. The contractor must ensure that all construction workers are made aware about
HIV/AIDS and the risks surrounding this disease. The location of the local clinic
where more information and counseling is offered must be indicated to workers;
10. Material stockpiles or stacks, such as, cable drums, tower components, etc. must be
stable and well secured to avoid collapse and possible injury to site workers/local
residents.
Welfare facilities
11. Eating areas should be regularly serviced and cleaned to ensure the highest possible

standards of hygiene and cleanliness;
12. Fires are not to be allowed for cooking or heating purposes anywhere along or near
the construction areas.
Protective gear
13. Construction staff and visitors without exception must always wear appropriate
Personal Protective Equipment (PPE) while working. Access to any part of the
construction site will be forbidden to anyone not donning the correct PPE;
14. The EPC contractor will adhere to the “Protection of Eyes” Schedule within the
OSHA.


Monitoring
requirement
Site safety
15. The construction camp must remain fenced for the entire construction period;
16. Potentially hazardous areas such as trenches are to be demarcated and clearly
marked;
17. The EPC contractor will place adequate warning signs in all hazardous working
areas;
18. Uncovered manholes and excavations must be clearly demarcated;
19. Emergency numbers for local police and rescue services etc. must be placed in a
prominent area;
20. Firefighting equipment must be placed in prominent positions across the site where
it is easily accessible. This includes fire extinguishers, a fire blanket as well as a

water tank;
21. Suitable conspicuous warning signs in English and all other applicable languages
must be placed at all entrances to the site;
22. All speed limits must be adhered to.
Construction equipment safety
23. All construction plant and equipment must be properly guarded to prevent injuries
to workers;
24. All equipment used for construction must be in good working order with up to date
maintenance records.
Hazardous Material Storage
25. Staff that will handle hazardous materials must be trained on the health and safety
aspects of storage, handling and distribution;


Monitoring
requirement
26. Any hazardous materials (apart from fuel) must be stored within a lockable store
with a sealed floor;
27. All storage tanks containing hazardous materials must be placed in bunded
containment areas with sealed surfaces. The bund walls must be high enough to
contain 110% of the total volume of the stored hazardous material;
28. Material Safety Data Sheets (MSDS) which contain the necessary information
pertaining to a specific hazardous substance must be present for all hazardous
materials stored on the site;
29. The provisions of Legal Notice 60: Hazardous Substances Regulations, 2007
promulgated in terms of the OSHA must be adhered to. This applies to solvents and
other chemicals possibly used in the construction phase.
Procedure in the event of a petrochemical spill

30. The individual responsible for or who discovers the petrochemical spill must report
the incident to the Project Manager, contractor HSE officer or EPC Contractor. The
problem must be assessed and the necessary actions required will be undertaken;
31. The immediate response must be to contain the spill;
32. The source of the spill must be identified, controlled, treated or removed.
Fire management
33. Firefighting equipment should be present on site at all times as per Legal Notice 59:
Fire Risk Reduction Rules, 2007;
34. All construction staff must be trained in fire hazard control and firefighting
techniques;


Monitoring
requirement
35. All flammable substances must be stored in dry areas which do not pose an ignition
risk to the said substances;
36. No open fires will be allowed on site;
37. Smoking may only be conducted in demarcated areas.
Safety of surrounding residents
38. All residents affected by the construction of the transmission line should be notified
in advance of any known potential risks associated with the construction site and
the activities on it. Examples of these are:
 Earthworks/earthmoving machinery on steep slopes above houses/
infrastructure;
 Risk to residence along haulage roads/access routes.

General social 1. EPC contractor to ensure that communications with affected persons along the EPC Contractor Bi-monthly
impacts along wayleave is always courteous; Project HSE
the wayleave 2. Officer,
No interruptions other than those negotiated shall be allowed to any essential
and its vicinity Contractor HSE
services. Damage to infrastructure shall not be tolerated and any damage shall be
Officer,
rectified immediately by the Contractor. A record of all damage and remedial
Proponent
actions shall be kept on site;
3. All existing private access roads used for construction purposes, shall be
maintained at all times to ensure that the local people have free access to and from
their properties. Speed limits shall be enforced in such areas and all drivers shall be
sensitized to this effect;
4. Any possible disruptions to essential services must be kept to a minimum and
should be well advertised and communicated to the Landowners and surrounding
Communities. The position of all underground utilities in the vicinity of a site must


Monitoring
requirement
be obtained from the Landowners or local Community and clearly marked. Where
required such lines shall be deviated.
Impacts on 1. The EPC contractor will not fence off the construction area thus preventing EPC Contractor Monthly
grazing land livestock from grazing; Project HSE
Officer,
2. Rehabilitate all disturbed grazing areas within the wayleave and construction
Contractor HSE
workspace to near original condition to enable livestock continue to graze;
Officer,
3. Fence off exposed areas for maintenance to prevent livestock from moving through Proponent
the area;
4. Compensation to landowners will be provided if livestock gets hurt as a direct
result of negligence on the maintenance team’s part;
5. The area should be rehabilitated upon completion of the maintenance activities to

ensure that the land is returned in the same condition as prior to the maintenance
activities.
Impacts 1. For workers not indigenous to the wayleave area, awareness will be created among EPC Contractor Bi-monthly
associated with construction workers about local traditions and practices; Project HSE
influx of 2. Officer,
Communities living in close proximity to the wayleave should be given an
construction Contractor HSE
opportunity through the local area chief’s office to communicate their expectations
workers Officer,
of construction workers’ behavior;
Proponent
3. Implement methods (posters, talks, etc.) to create HIV and STI awareness amongst
construction workers;
4. Payment to Kenyan construction workers should comply with applicable Kenyan
Labor Laws in terms of minimum wages;
5. Where local laborers are employed on a more permanent basis, the EPC contractor
shall mandatorily register such workers with statutory bodies such as the KRA,


Monitoring
requirement
NHIF and NSSF and make the necessary deductions from the worker’s wages for
onward transmission to the statutory bodies.
Impacts 1. The EPC contractor will notify the local District Officer of the employment EPC Contractor Bi-monthly
associated with procedures of the company; Project HSE
job seekers Officer,
2. No loitering will be allowed in the vicinity of the camp sites. The EPC contractor
Contractor HSE
to work with relevant security agencies to evict any loiterers.
Officer,
3. Construction workers should be clearly identifiable by wearing proper construction Proponent
uniforms displaying the logo of the construction company. Construction workers
could also be issued with identification tags.
Impacts 1. Engage the local community early on and throughout the construction phase about EPC Contractor Bi-monthly
associated with the construction activities to get their buy-in. Project HSE
attitude Officer,

2. Employment opportunities should first be offered to the local community if the
formation Contractor HSE
skills are available within the community.
against the Officer,
project 3. The undertakings in the EMP should also be implemented effectively and with due Proponent
diligence.
Impacts of 1. Water is a scarce resource along the wayleave and subsequently construction EPC Contractor Bi-monthly
additional workers should be made aware of the limited availability and conservation Project HSE
demand on measures; Officer,
existing utilities 2. Contractor HSE
Construction camps should be located away from areas of concern to avoid
Officer,
pollution of water bodies.
Proponent
Impacts on 1. Construction workers should receive medical advice regarding correct sanitation EPC Contractor Bi-monthly
sanitation and receive correct medical attention where required; Project HSE
Officer,
2. Adequate water facilities should be provided;
Contractor HSE


Monitoring
requirement
3. Sufficient portable chemical toilets on site and at the construction camps should Officer,
be provided; Proponent
4. Adequate sanitation services (e.g. showers) at the construction camp should be
provided with effective drainage facilities to ensure that used water is carried
away from the site.
Impacts on 1. An aggressive STI and HIV/AIDS awareness campaign should be launched, which EPC Contractor Bi-monthly
integration with is not only directed at construction workers but also at the community as a whole; Project HSE
local Officer,
2. Contraceptives (such as condoms) should be distributed by placing them at
communities Contractor HSE
centrally located points and by ensuring that construction workers and community
Officer,
members are aware of the availability and location of contraceptives. The
Proponent
distribution of contraceptives should be approached with the necessary cultural
sensitivity;

3. Access at the construction site should be controlled to prevent commercial sex
workers from either visiting and/or loitering at the construction village;
4. Local women should be empowered. This could be achieved by employing them to
work on the project, which in turn would decrease their (financial) vulnerability.
Impacts 1. Develop and implement appropriate measures for artifacts of archeological and EPC Contractor Bi-monthly
associated with cultural significance unearthed during the construction phase; Project HSE
archeology and 2. Officer,
The workforce should be made aware of reporting any possible historical or
cultural heritage Contractor HSE
archaeological finds to the HSE Officer so that appropriate action can be taken;
Officer, KEL
3. Any discovered artifacts shall not be removed under any circumstances;
4. Report any archaeological sites and/or graves uncovered during construction to the
Project Manager;
5. Implement measures to ensure that behavior and practices of construction workers


Monitoring
requirement
do not cause offence to local communities and land owners.


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EIA Study of proposed 220kV Transmission Line Project, Kajiado County, Kenya

11 Environment Management Plan (EMP) ...................... 11-2

11.1 Objectives of the EMP .................................................... 11-2

11.2 EMP roles and responsibilities ...................................... 11-2

11.2.1 Project Manager .................................................................... 11-3

11.2.2 Project HSE Officer ............................................................... 11-3

11.2.3 EPC Contractor ..................................................................... 11-4

11.2.4 Contractor HSE Officer ......................................................... 11-4

11.2.5 Independent HSE Auditor ..................................................... 11-4

11.2.6 Environmental management responsibilities ......................... 11-5

11.3 Environmental monitoring ............................................. 11-5

11.3.2 Training and Awareness ....................................................... 11-6

11.4 EMP requirements for pre-construction phase ............ 11-7

Chapter: Environment Management Plan (EMP)

11.5.1 Site preparation ................................................................... 11-10

11.5.2 Establishment of Construction Camps and Materials yards 11-10

© Kurrent Technologies Ltd. Revision 00: August 2013 11-1

11 Environment Management Plan (EMP)

11.1 Objectives of the EMP

The objectives of the EMP are to:

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-2

11.2.1 Project Manager

11.2.2 Project HSE Officer

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-3

11.2.3 EPC Contractor

11.2.4 Contractor HSE Officer

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-4

11.2.6 Environmental management responsibilities

The following are the environmental management responsibilities of the various

11.3 Environmental monitoring

A monitoring program will be implemented for the duration of the construction

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-5

11.3.1 Compliance with the EMP and associated documentation

11.3.2 Training and Awareness

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-6

11.4 EMP requirements for pre-construction phase

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-7

Table 11-1: Environment Management Plan-Pre-construction Phase

Impact Environmental Mitigation Measure/Monitoring Plan Responsibility Frequency/

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-8

Impact Environmental Mitigation Measure/Monitoring Plan Responsibility Frequency/

Chapter: Environment Management Plan (EMP)

11.5 EMP requirements for construction phase

11.5.1 Site preparation

11.5.2 Establishment of Construction Camps and Materials yards

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-10

Table 11-2: Environment Management Plan-Construction Phase

Impact Environmental Mitigation Measure/Monitoring Plan Responsibility Frequency/

Chapter: Environment Management Plan (EMP)

© Kurrent Technologies Ltd. Revision 00: August 2013 11-11

Impact Environmental Mitigation Measure/Monitoring Plan Responsibility Frequency/