ایجاد ارتباط بین ارزیابی تاثیر سیستم مدیریت زیست محیطی : مطالعه موردی : ارتقاء نیروگاه نفت پایین دست در ونزوئلا

A proponent of a downstream upgrading petroleum plant in Venezuela requested to carry out the mandatory complete EIA report with an Environmental Management System in mind. In Venezuela, a complete EIA report is a document that includes: the Environmental Impact Assessment, the Supervision Plan, the Surveillance Plan, and the Guidelines for a Contingency Plan. For this task, a methodology was proposed to review the role of a complete EIA report within the framework of the requirements of a future Environmental Management System. The outcome was a Proposed Working Model that was applied to the case study. The results showed that the linkage sustains the ongoing use of the complete EIA report in the process of environmental evaluation throughout the life cycle of an industrial plant. In addition, outcomes from the linkage substantially improved the Environmental Supervision Plan in particular.

The Division of Technology, Industry, and Economics of the United Nations Environmental Program held a meeting in 1998 to review and assess the situation concerning Environmental Impact Assessment (EIA) for Industry (UNEP TIE, 1999). Several authors prepared thematic notes on key issues among which Turner (UNEP TIE, 1999), regarding “EIA and the Project Cycle,” stated that: • An EIA is mostly used as a checklist at the planning/development permission stage only; and • For an EIA to be effective, it must be operative throughout the whole project cycle. In most cases, there is no formal mechanism to ensure that measures agreed at the planning stage are subsequently carried out, with the result that they are often ignored. In what follows, Turner's statements are examined within the Venezuelan context by analyzing issues coming from impact assessments and audits carried out for industrial plants associated with the petroleum and gas sector. Before introducing these issues, a brief background on the Venezuelan legal framework for impact assessment is presented. For projects related to industrial plants, such as downstream upgrading petroleum plant, Decree 1.257 (República de Venezuela, 1996) requires a complete EIA report that includes the following four documents: 1. The Environmental Impact Assessment. 2. The Environmental Supervision Plan. 3. The Surveillance Plan. 4. The Guidelines for a Contingency Plan. In what follows, the term “complete EIA report” will refer to the set of the four documents required by Decree 1.257. In addition to the complete EIA report, a Register of Activities Susceptible to Downgrade the Environment (Registro de Actividades Susceptibles de Degradar el Ambiente, RASDA) must be completed in Venezuela before a new facility starts full operation. The RASDA allows the Ministry of Environment and Natural Resources (MARNR) to learn the operational status of a new industrial facility in relation to air emissions, waste water discharges, and industrial waste management República De Venezuela, 1995a, República De Venezuela, 1995b and República De Venezuela, 1998. If there are already environmental problems with the new facility, then a compliance plan with its schedule must be established. The procedure established with the EIA, Environmental Supervision Plan, Surveillance Plan, and RASDA might be visualized as a series of cycles of impact assessment. With these Venezuelan cycles of impact assessment, one might think that Turner's (1999) statements are not appropriate. However, even for industrial facilities with an EIA approval, there could be issues that cause delay in the processes of environmental management and compliance with regulation. In what follows, examples of these issues are presented under illustrative subheadings. 1.1. Documentation ⋅ Lack of documentation about detailed engineering plot plans, conditions approved by MARNR since the facility first started, site environmental setting and land occupation sequence, environmental control points, compliance status, risk events associated with the facility itself and its neighbors. ⋅ Lack of document control: Although there is an information center, a single employee usually manages the environmental information. In addition, the EIA document may be missing. ⋅ Incomplete information: A register of environmental compliance is inadequate, reports on the health status of workers have not been done regularly and the information about the environmental performance status of process and auxiliary units is available only for those with minor impact. 1.2. Environmental monitoring and measurements ⋅ Lack of technical support for environmental control points and measurements. ⋅ Poor performance of new environmental treatment facilities. ⋅ Inconsistency among verbal, documentary, and field evidences. For example, “We have a waste management plan but, these drums are not in the inventory yet,” or “We know all the substances those drums contain, except for these few.” 1.3. Internal and external communication ⋅ Lack of communication between departments of the industrial facility directly or indirectly related to environmental issues. ⋅ Poor communication with neighbors: A contingency plan exists, but citizens and community authorities are neither aware of nor prepared for it. 1.4. Management commitment ⋅ Lack of empowerment of top-ranking managers with environmental awareness: Responses like, “I was told we did that,” or “I was told we already solved that problem,” are frequent. ⋅ Lack of funds for environmental solutions. ⋅ Lack of understanding by top-ranking engineering managers of the need for an environmental assessment to have information about normal and abnormal conditions of operation and about “miscellaneous byproducts” associated with the operation, some of which are listed by law as toxic or dangerous waste. 1.5. Management attitude ⋅ Panic about questions on environmental compliance. Responses include, “We're trying to do our best but our department didn't have enough funds,” “We're trying to improve that,” “We're a little behind the planned schedule,” “We aren't in such bad shape, are we?” ⋅ Fear that the consultant will inform third parties about the existing situation. Managers tend to issue statements like “The information you are getting is confidential. Before the information is available to third parties, we have to verify that it is correct. The community could be alarmed for no reason.” The situation just presented reveals that the potential benefits of the complete EIA report are not fully understood. It is our experience that, for the project owners, the complete EIA report is the required step to start the site preparation for the construction and has no anticipated future use. This situation is not unique for Venezuela; for example, Brown (1998) states that the perception of an EIA's report being an end in itself rather than a means to an end is strongly ingrained in the culture of environmental assessment. The issues presented show that the environmental variable has not been realistically integrated as part of the organization. This situation takes place even in businesses with an environmental assessment culture and a proactive environmental discourse. One might think that this fact is related to the Venezuelan critical economic situation. Nevertheless, Piasecki et al. (1999) cited this text from the Rocky Mountain News (1993): In the middle of 1990s, the National Law Journal surveyed 223 corporate attorneys of firms having annual revenues in the $50 million to $10 billion range. Sixty-seven percent said their companies had violated environmental laws in the previous year. Moreover, 67 percent also said that they believe that full compliance is impossible. Due to the issues presented above, an organization responsible for an industrial facility may reach what is known as a Green Wall Condition that is characterized by efforts on environmental issues with no substantial results and lack of real progress among the portfolio of environmental programs. This term was first used by Robert Shelton from the A.D. Little firm (Piasecki et al., 1999). In addition to the issues already mentioned, by reviewing RASDA documents one may find out that the compliance plan schedule for a new facility in operation might have multiple extensions. This suggests that MARNR has adopted a conciliatory and not an enforcing attitude once a facility is in operation. The possibility of a noncompliance situation of a new facility and extensions for compliance once in operation could lead to a Green Wall Condition. Thus, there is in the facility's environmental program a repeating pattern of the phenomenon mentioned by Piasecki et al. (1999): one step forward, one step backward. Carr and Thomas (1997) stated that the balance between providing incentive for improving compliance and preventing the manipulative use of “audits of convenience” as cover for violations has been and will continue to be difficult to define and implement. In this context, an interdisciplinary team of professionals in charge of an environmental assessment might start the study either with a feeling of anticipated frustration, supported by fast findings, or with a challenging attitude to show the importance of a complete EIA report for the organization needs. The challenging attitude is what motivates this paper. In our opinion, one way to enhance the importance of a complete EIA report within an organization might be to prove that its findings feed the future Environmental Management System designed under ISO 14001. Other authors support the perspective of this article. For example, Cadwell (1998) stated that the full benefit of an environmental assessment depends upon the internalization of the process and its findings within the existing structure. Unless EIA contributes to the organization's learning and reviewing priorities, its effective implementation is unlikely. Ridgway (1999) stated that the role of an EIA must be reviewed within the framework of other environmental tools, particularly the environmental management system standard ISO 14001. The purpose of this paper is to present an exploratory case study to review the potential role of a complete EIA report within the framework of the requirements of future Environmental Management Systems, keeping in mind that the objectives of these managing tools are different. In what follows, background on the case study is first presented, then there is a reference of the methodology proposed to establish the linkage between a complete EIA report and an Environmental Management System. Finally, the results and the lessons learned from the experience are singled out.