Environmental Incident Response Procedure. Newcastle Gas Storage Facility Document Number: NGSF-PSV-NAS-EN-PLN-0024

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1 Environmental Incident Response Procedure Newcastle Gas Storage Facility Document Number: NGSF-PSV-NAS-EN-PLN-0024

2 Environmental Incident Response Procedure Document Number: NGSF-PSV-NAS-EN-PLN-0024 Version: 2.0 Date: 11 November 2013 Newcastle Gas Storage Facility Main Power Supply Report prepared for AGL Energy Limited Prepared by: Simon Kinvig SQE Advisor Document Revision History PLAN REVISION STATUS Rev Date Detail Prepared Reviewed Approved 1.0 Oct2013 For submission to DOP Simon Kinvig Kari Torpstrom Greg Robertson 2.0 Nov 2013 Issued for construction Simon Kinvig Kari Torpstrom Greg Robertson PLAN DISTRIBUTION LIST COPY NO. LOCATION HOLDER DATE 1. Thornton Head Office 2. Site Copies 3. Client Copy (Electronic) 4. Gongues PowerServe Pty Ltd (9 Kestrel Avenue, Thornton, NSW, 2322) T: F: W: i

3 Table of Contents 1.0 Purpose Scope Responsibilities Matrix Procedure Spill Response Flora and Fauna Cultural Heritage Illegal Dumping Complaints Relationship to Other Documents Definitions/Terms Notifying Incidents to Regulatory Authorities Contact List...16 List of Figures Figure 2-3: Main Power Supply project work site Figure 2: Flow Chart Figure C-1: Contingency Plan Flow Chart Appendices Appendix CA: CBI Constructors Pty. Ltd. Pollution Incident Response Management Plan ii

4 1.0 Purpose This document details site specific organisational responsibilities, actions, reporting requirements and the resources available to ensure an effective, consistent and timely management of environmental incidents that may occur on the Newcastle Gas Storage Facility Main Power Supply project. This includes details of the protocols used to deal with environmental incidents affecting or on the project site. Variations to this plan may occur subject to Emergency Aid Agency requirements or the knowledge of supervisory personnel dealing with occurrences as they unfold. 2.0 Scope This procedure has been written specifically for the Newcastle Gas Storage Facility Main Power Supply project and is consistent with Power Serve operational policies and procedures. The work site is shown in Figure 2-3 as the transition line works area. Figure 2-3: Main Power Supply project work site 1

5 3.0 Responsibilities Matrix Project personnel and their respective responsibilities as they relate to this procedure are summarised in the table below. Availability of the Procedure Management and Mitigation Measure Responsibility Inspection/ Timing Ensure that a copy of this Procedure is maintained at the construction site, in the site office, so that it is readily available to those responsible for its implementation. Project Manager At all times Implementation of Management and Mitigation Measure Responsibility Inspection/ Timing If an environmental incident occurs in the course of an activity at the construction ensure that the person carrying out the activity immediately implements the mitigation measures in this procedure. Construction Manager Project Manager At time of incident Incident Response Management and Mitigation Measure Attend to the incident immediately, no matter how small If it is safe to do so, stop the cause of the incident at its source Contact the NSW Fire Brigade immediately on 000 if the incident involves a hazardous substance (such as a flammable or toxic substance) or if you suspect that the spill will escape to the environment Implement corresponding mitigation measures for the type of incident Ensure that emergency vehicles can access the site at all times. Persons Responsible First responder First responder Construction Manager Project Manager Site personnel Construction Manager Project Engineer Inspection/ Timing Immediately Immediately As required As required During construction 2

6 Incident Reporting Determine if incident is considered to be material harm according to the POEO Act Section 147 Record all incidents and ensure that they are reported to management Classify Incidents using Environmental Incident Classification Guideline (Appendix A10) of the CEMP Report using the Incident Notification & Investigation Matrix incidents in accordance with reporting protocols (Appendix A10) of the CEMP Record all incidents and ensure that they are reported to management Classify Incidents using Environmental Incident Classification Guideline (Appendix A10) of the CEMP and report using the Incident Notification & Investigation Matrix Investigation Investigate the cause of each incident and ensure that precautionary action is implemented to reduce the risk of a similar incident occurring. SQE Manager Site personnel Project Manager SQE Advisor Construction Manager Project Manager SQE Manager Site personnel Project Manager SQE Advisor Construction Manager Project Manager SQE Manager Immediately Within 24 hours High -Immediate Moderate Within 4 hours Low Within- 24 hours Within 24 hours High -Immediate Moderate Within 4 hours Low Within- 24 hours Within 24 hours Testing of the Procedure Management and Mitigation Measure Responsibility Inspection/ Timing Response and Training The objective of the incident response training will be to educate relevant workers on how to categorise and deal with various types of environmental incidents. Verbal communication of incident response will form part of tool box talks. Ensure that this Procedure is tested within one month of any incident occurring. Environmental Manager Environmental Advisor Project Manager SQE Manager 12 monthly plan test Spill response at induction 1 month after initial incident 3

7 4.0 Procedure The procedural flow is outlined in Figure 2. Sections provide process information for specific types of environmental incidents. 4

8 AGL NGSF MPS Environmental Incident Occurs Is the incident an Emergency? Yes Apply Emergency Response Management Plan No Continue Apply PowerServe incident response process No Is the incident a pollution incident on CBI Licensed Premise? Yes Apply CBI Pollution Incident Response Management Plan Is the incident a spill? No Does the incident involve Flora or Fauna? Yes Yes Section 4.1 Spill Response Apply spill response protocol Section 4.2 Flora and Fauna Apply Controls as per Appendix B1, Table B6 Definitions and Terms: Illegal Dumping: Means the unlawful deposit of waste larger than litter onto land or into water. It includes waste materials that have been dumped, tipped or otherwise deposited onto land where no licence or approval exists to accept such waste. Illegal dumping varies from small bags of rubbish in an urban environment to larger scale dumping of waste materials in isolated areas, such as bushland. Illegal dumping includes illegal landfilling, which is waste used as fill material with the consent of the owner or occupier of the land but without the necessary council or Environment Protection Authority (EPA) approvals. No Does the incident involve cultural heritage? No Is the incident illegal dumping? No Yes Yes Section 4.3 Cultural Heritage Apply controls as per Appendix B2, B Protocol for unexpected heritage finds Section 4.4 Illegal Dumping Apply controls as per Appendix B4 Table B-3 and Appendix B11 Table 3-13 Pollution Incident Notification A pollution incident is required to be notified if there is a risk of "material harm" to the environment, which is defined in Section 147 of the POEO Act as: 147 Meaning of material harm to the environment (1) For the purposes of this Part: (a) harm to the environment is material if: (i) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, or (ii) it results in actual or potential loss or property damage of an amount, or amounts in aggregate, exceeding $10,000 (or such other amount as is prescribed by the regulations), and (b) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment. (2) For the purposes of this Part, it does not matter that harm to the environment is caused only in the premises where the pollution incident occurs. Pollution Incident Means a leak, spill or other circumstances as a result of which water pollution, air pollution or land pollution has occurred, is occurring or is likely to occur includes but is not limited to: "spill or leak of fuels, gas, chemicals, hazardous substances, dangerous goods (DGs) "dirty runoff, visible dust, smoke, fumes. Excluding circumstances involving only the emission of any noise. Does the incident involve a complaint? Yes Section 4.5 Advise the Community Relations Team of the enquiry or complaint as soon as possible And complete Record of Contact form (Appendix A4) Report Incident to PowerServe SQE Manager and SQE Advisor No Is the incident a pollution incident that has caused or threatens material harm to the environment? Yes Report Incident to AGL Classify the incident using Environmental Incident Classification Guideline (Appendix A10) and record incident particulars on - Environmental Incident Report Form (Appendix A11) Contact SQE Manager immediately who will in consultation with the AGL representative report incident immediately to EPA WorkCover Local Council Local Health Authority Fire and Rescue NSW Classify the incident using Environmental Incident Classification Guideline (Appendix A10) and record incident particulars on - Environmental Incident Report Form (Appendix A11) Figure 2: Flow Chart 5

9 4.1 Spill Response Spills are to be managed in accordance with Construction Environmental Management Plan - Appendix B4, surface water management plan Appendix C, spill response procedure, following the flow chart as depicted in Figure C-1. In the event of a significant spill on-site, this Spill Response Plan would be adopted immediately. For the anticipated chemicals to be used during construction, a significant spill volume would be one that exceeds a threshold of 20 L. This spill response strategy has been developed and is illustrated as a contingency plan flow chart in Figure C-1. If a significant chemical spill or leakage occurs, including potential impacts from illegal dumping, a response plan will be implemented that includes the following measures: Confirm the source and location of the contamination; Advise AGL, EPA, NOW, and HWC of the spill or leakage; Clean up the contamination source; Assess the groundwater quality with respect to relevant background concentrations and guidelines; Investigate the most appropriate remedial response (most likely to be hydraulic containment for significant spills and leaks), Implement remedial response (where hydraulic containment is the most appropriate remedial response, it will be implemented by installing down gradient (new) pumping bores). Install monitoring bores down gradient of the spill and increase monitoring frequency. Pump the reclaimed water to a treatment facility for treatment/disposal and re-inject to groundwater if the water meets relevant site criteria. A treatment facility would be established on the site to remove the contaminants from the groundwater pumped from the hydraulic containment system to meet appropriate standards and be returned to the groundwater system provided testing confirms that water quality is acceptable for discharge to this groundwater source. Treated groundwater would be returned up gradient and/or across gradient from the spill area and away from direct flow to the HWC pumping bores (if possible). Once the groundwater cleanup goals are achieved, stakeholders would be advised and hydraulic containment operation would cease. 6

10 If the treated groundwater is unsuitable for direct discharge, then the groundwater may require off-site disposal to an appropriate facility. Figure C-1 Contingency Plan Flow Chart (Source: Surface Water Management Plan, Appendix C) 7

11 4.2Flora and Fauna Incidents that involve flora or fauna are to be managed in accordance with Construction Environmental Management Plan - Appendix B1 - Flora and Fauna Management Sub Plan, Table B-6 by the ecologist in the first instance. Table B-6 General Fauna Displacement Protocol GENERAL FAUNA DISPLACEMENT PROTOCOL ID Management and Mitigation Measure Responsibility Inspection/ Timing Source 1 Captured fauna and/or displaced fauna will be relocated to adjacent habitat and on-site retained habitats by an Ecologist. 2 All fauna are to be handled in such a way as to prevent injury to the animal or the handler. 3 Once the animal is safely captured it should be relocated or caged in a hessian bag or box and released at an appropriate time of day. Ecologist At all times Ecobiological Ecologist At all times Ecobiological Ecologist At all times Ecobiological 4 If any animal is injured during the construction process, a veterinarian should be contacted immediately for professional advice on the best course of action. The Native Animal Trust Fund should also be contacted. Ecologist/ Environmental Manager At all times Ecobiological NATF number (0418-NATIVE) and Raymond Terrace Veterinary Clinic Contact telephone numbers will be posted on the site office wall at all times during construction 5 If any animal is injured during other construction processes while the project ecologist is not present, they must be contacted immediately. Environmental Manager/ Site Supervisor At all times Ecobiological 8

12 4.3Cultural Heritage Incidents that involve Cultural Heritage are to be managed in accordance with Construction Environmental Management Plan - Appendix B2 - Cultural Heritage Management Sub Plan, Appendix B: Cultural Heritage Education Training, Section 5.0 UNEXPECTED HERITAGE FINDS, Table 1 and following Flow Chart B. Table 1 Protocol for the Discovery of New Aboriginal Sites Aspect Action Responsibility Construction All phases of project work will be conducted in accordance with protocols for the discovery of new heritage sites and are to be followed as necessary (Flow Chart B). Brief personnel/ contractors prior to excavation during the site specific induction on heritage issues and on the appropriate course of action if any Aboriginal cultural heritage items are discovered. If any Aboriginal cultural heritage items, as defined by the National Parks and Wildlife Act 1974 are identified in the course of activities, then works in the vicinity of the finds are to cease immediately, the NSW OEH is to be contacted, and an appropriate course of action implemented. Enter site on the cultural site register Site Manager 9

13 Flow Chart B Protocol for Discovery of Potential Aboriginal Sites and Skeletal Remains 10

14 4.4Illegal Dumping Illegal Dumping is to be managed in accordance with Construction Environmental Management Plan - Appendix B4, surface water management plan, Table B3 and Miscellaneous Environmental Aspects Sub Plan, Table Table B-3 Illegal Dumping ILLEGAL DUMPING ID Management and Mitigation Measure Responsibility Inspection/ Timing Source 1 Reasonable measures will be taken to maintain security of the construction site to prevent third parties gaining unlawful access to the site. Site supervisor During construction CoA B41 2 If any evidence of illegal dumping of wastes on the project area is observed the dumped material will be removed immediately and this will be treated as an environmental incident. Site Manager During construction CoA B41 3 If any liquid sludge or chemical waste is observed then appropriate sampling and monitoring will be implemented to determine whether any impact to groundwater has occurred or is likely. Site Manager During construction CoA B41 4 Follow incident reporting procedure and update records. Site Manager During construction Section 5.4 of the CEMP Table 3-13 Illegal Dumping ILLEGAL DUMPING ID Management and Mitigation Measure Responsibility Inspection/ Timing Source 1 If material is illegally dumped on site by others (i.e. general public), it will be assessed, and recycled or disposed as per other materials on site. If the material appears to contain asbestos or other potentially hazardous materials, it will be covered and access to the material restricted. Site supervisor During construction As required CoA B41 SoC 342 The construction site will be fenced and locked to prevent access by others. 11

15 4.5Complaints Complaints are to be managed in accordance with Construction Environmental Management Plan Section- Section Consultation with Stakeholders, Complaints Handling as outlined below. Complaints Handling AGL s community relations team will be responsible for managing all enquiries and complaints relating to the Project. Project personnel who become aware of an enquiry or complaint will advise the Community Relations Team of the enquiry or complaint as soon as possible. Contact may be via: Telephone contact with the community relations office based in North Sydney (by use of the AGL toll free telephone number ); (via website or direct) gsf@agl.com.au; By post (Locked Bag 1837 St Leonards NSW 2065); In person to a contractor on site/in the community. In responding to enquiries or complaints PowerServe will: Record details of every complaint (Using record of contact form Appendix A4) received and how it was managed and closed out and enter the information into the Consultation Manager database (refer Section 4.5). Investigate the complaint researching any previous issues, checking whether any requirement has been breached, what corrective action, if appropriate, will be undertaken, a time frame for this action and the appropriate feedback / response to the complainant. Provide at least a verbal response to the complainant regarding what action is proposed as soon as possible and within a maximum of 4 hours from the time of the complaint where the complaint has been received via the AGL toll-free telephone number (unless the complainant requests otherwise). Where written correspondence is received, the submission will be acknowledged within 48 hours if a contact phone number is given and a written response will be provided within 5 working days. Where correspondence is received by or fax, the submission will be acknowledged with 24 hours. Forward details of any complaint, the action taken and any outstanding issues or remediation requirements to AGL s community relations manager and appropriate functional and construction managers. 12

16 AGL s community relations manager will immediately advise PowerServe of any complaints that have the potential to be escalated to government representatives and/or the media. For further information on complaints handling refer to the CEP. 5.0 Relationship to Other Documents This document is Appendix C of the Construction Environmental Management Plan for the Newcastle Gas Storage Facility Main Power Supply. The Construction Environmental Management Plan has a number of sub plans as indicated below. Mitigation measures are drawn from the sub plans as well as the adjacent occupiers Pollution Incident Response Plan. In the event of an emergency incident the PowerServe Newcastle Gas Storage Facility Main Power Supply emergency response plan is to be enacted. In the event that the incident is a pollution incident that occurs on CBI Constructors Pty. Ltd. licensed premise the CBI Constructors Pty. Ltd. Pollution Incident Response Plan is to be followed (Refer to Appendix CA - CBI Constructors Pty. Ltd. Pollution Incident Response Management Plan, EN- PL-00016). 6.0 Definitions/Terms Illegal Dumping Means the unlawful deposit of waste larger than litter onto land or into water. It includes waste materials that have been dumped, tipped or otherwise deposited onto land where no licence or approval exists to accept such waste. Illegal dumping varies from small bags of rubbish in an urban environment to larger scale dumping of waste materials in isolated areas, such as bushland. Illegal dumping includes illegal landfilling, which is waste used as fill material with the consent of the owner or occupier of the land but without the necessary council or Environment Protection Authority (EPA) approvals. Pollution Incident Notification A pollution incident is required to be notified if there is a risk of material harm to the environment, which is defined in Section 147 of the POEO Act as: 13

17 147 Meaning of material harm to the environment (1) For the purposes of this Part: (a) harm to the environment is material if: (i) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, or (ii) it results in actual or potential loss or property damage of an amount, or amounts in aggregate, exceeding $10,000 (or such other amount as is prescribed by the regulations), and (b) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment. (2) For the purposes of this Part, it does not matter that harm to the environment is caused only in the premises where the pollution incident occurs. Pollution Incident Pollution incident means an incident or set of circumstances during or as a consequence of which there is or is likely to be a leak, spill or other escape or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise. 14

18 7.0 Notifying Incidents to Regulatory Authorities Relevant information to be given when notifying incidents to an authority The relevant information to be given according to section 150 of the POEO Act (1997) when notifying the incident to the regulatory authorities is as follows: a) Time, date, nature, duration and location of the incident b) Location of the place where pollution is occurring or is likely to occur c) The nature, the estimated quantity or volume and the concentration of any pollutants involved, if known d) The circumstances in which the incident occurred (including the cause of the incident if known) e) Action taken or proposed to be taken to deal with the incident any resulting pollution or threatened pollution, if known f) When the information relating to items c), d) or e) is not known at the time of verbal notification, this information must be provided once it becomes available Relevant Information to record after notification to authorities The relevant information to be recorded after notification includes a) Date of notification for each authority b) Time of notification for each authority c) Incident number from EPA d) Attempts to contact authorities that may have failed e) A record of any instructions given by the relevant authorities f) And complete the Environmental Incident Report Form (Appendix A11 of the CEMP) 15

19 8.0 Contact List PowerServe Details Contact Number Service Centre Newcastle (Thornton) Project Manager Greg Robertson Site Manager Kari Torpstrom Site Supervisor Glenn Waters SQE Manager Suzie McLean (Thornton) SQE Advisor Simon Kinvig PowerServe After hours Contacts Site Manager Kari Torpstrom Site Supervisor Glenn Waters AGL Details Contact number Site Supervisor TBA TBA AGL Community Relations Office AGL Site Manager TBA TBA AGL Environment Manager - TBA TBA CBI Details Contact number CBI Project Manager TBA TBA CBI Site Manager TBA TBA Relevant Authority EPA Port Stephens Council NSW Ministry of Health the Ministry of Health via the local Public Health Unit Contact Details Emergency Newcastle Raymond Terrace after hours Council Officer HNE Newcastle PHU (Hunter/New England AHS) Phone: (02) Fax: (02)

20 Work Cover NSW Newcastle Reporting Line Fire and Rescue NSW Emergency 000 Fire and Rescue NSW Pollution Incident Other Contacts NSW Office of Water Contact Details Newcastle Hunter Water

21 Appendix : CA - CBI Constructors Pty. Ltd. Pollution Incident Response Management Plan, Document Number: EN-PL Newcastle Gas Storage Facility 18