Environmental Management Sub-Plan. Management Plan. Appendix I Pollution Incident Response. Bringelly Road Upgrade Stage 1

Transcription

1 Environmental Management Sub-Plan Appendix I Pollution Incident Response Management Plan Bringelly Road Upgrade Stage 1

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3 Pollution Incident Response Management Plan Bringelly Road Upgrade Stage 1 Table of Contents 1 Emergency Contacts Incident Anticipation, Planning and Response Background Preparedness; Risk Assessment and Pre-Emptive Actions to Prevent Pollution Incident Risks Summary of Pollution Types Risk Assessment Notification Incident Investigation Project Maps Incident Response Procedure Internal Communications - key names and contacts Emergency Response Planning Medical Emergency Spillage of Hazardous Liquids/Petroleum/Chemicals Excavation and Disposal of Contaminated Material Excavation Removal of sewage system Transport Personnel Refuelling or maintenance and clean of plant and equipment Sediment control resulting from large rainfall events Excessive Dust Bush Fire Injured animals Early Warnings and Communications to Neighbours Website information Availability and Location of This Plan Privacy Protection Training Summary and Reference to Project Procedure Updating of Plan Testing and Implementation Testing of the PIRMP Rev. C (1/07/2015) Page 3 of 51

4 8.2 Implementation of the Plan Appendix 1 Project Map Appendix 2 Risk Assessments Appendix 3 St John s Ambulance First Responder Chart Appendix 4 Emergency Spill Response Procedure Table 1 PIRMP Requirements and Reference in this document... 8 Table 2 List of Typical Main Pollutants in Road Construction Table 3 POEO (General) Regulation 2009 Requirements Table 4 External Emergency Contacts - not an immediate threat Table 5 External Emergency Contacts - immediate threat Table 6 List of Typical Main Pollutants and Potential Neighbour Impacts and Early Warnings Rev. C (1/07/2015) Page 4 of 51

5 1 Emergency Contacts SITE LOCATION: Bringelly Road: King Street to Camden Valley Way MAIN COMPOUND LOCATION: 111 Cowpasture Road South; Leppington EMERGENCY NUMBERS FIRE BRIGADE 000 AMBULANCE 000 POLICE 000 LOCAL EMERGENCY SERVICES Fire Station Fire Brigade NSW 162 Greenway Drive Horningsea Park NSW Police Station Police Station 33 Moore St Liverpool NSW Medical Centre AllCare Carnes Hill Medical Centre Cnr Kurrajong & Cowpasture Rds Horningsea Park NSW Hospital Liverpool Hospital Elizabeth Street Liverpool NSW Rev. C (1/07/2015) Page 5 of 51

6 AGENCY/STAKEHOLDER CONTACT NUMBERS For Immediate Contact following a Pollution Incident (see section 2.5) EPA Pollution Hotline Dial Before You Dig 1100 NSW Fire and Rescue (000) Horningsea Park Fire Station, 162 Greenway Dr, Horningsea Pk (02) Poisons Information WorkCover (Parramatta) NSW Ministry of Health (Liverpool Public Health Branch) ( ) Liverpool Council Camden Council Other Useful contacts in an Emergency Dial Before You Dig 1100 Poisons Information Telstra Endeavour Energy Jemena Gas APA POSITION NAME NUMBER Project Manager (PM) Jacques Lotter Environmental Site Representative (ESR) Sen Keomongkhoun Safety Manager Johnny Auditore Superintendant Mitch Coustley General Foreman Dave Liddicoat Steve Waller Project Engineers Martin Chan Adeesha Dodanwala First Aid Officers Ian Sherridan Brad Clare Rev. C (1/07/2015) Page 6 of 51

7 1.1 Roles and responsibilities BMD Constructions Project Team organisational structure and overall roles and responsibilities are outlined in the CEMP. Specific responsibilities for the implementation of this PIRMP are detailed below Project Manager and Environment Site Representative / Safety Manager General Requirements Be fully conversant with the requirements of this Plan Ensure the PIRMP is fully implemented, monitored and adjusted to suit the requirements of the operations system and the client s requirements Ensure the requirements of the Management System are fully complied with when administering the PIRMP Ensure all employees are conversant with their responsibilities and duties under the PIRMP Responsible to notify relevant stakeholders and government authorities Communication Ensure the spill response flowchart, emergency contact numbers and details and any other bulletin or information pertaining to emergency plans and management is placed on noticeboards Training Educate supervisory personnel in accordance with plan requirements, statutory obligations, and relevant procedures Ensure staff and s have been inducted into BMD safety and environmental management systems and procedures Superintendent / Foreman The Superintendent / Foreman are responsible for the day to day operations of the project, ensuring project operations comply with all relevant obligations for the period of this contract. The Superintendent / Foreman will be inducted into BMD Integrated Management Systems and Procedures, they will also receive a higher level of Project specific Emergency Preparedness and Incident Management training while onsite General Requirements Being familiar with the requirements of this PIRMP. Ensuring incidents are managed and strictly supervised in accordance with the PIRMP, company policies and procedures Being familiar with legislation and codes of practice relevant to this role, and ensuring the requirements of the same are bought to the attention of interested parties and implemented as is practicable across the Project site Understanding process and location of spill kits Communication Ensuring the requirements of the PIRMP are communicated to all personnel, subs and where appropriate, visitors to site through on site daily Pre Start meetings, Site Inductions, weekly Toolbox Meetings and Work Method Statement (WMS) review on commencement of new works with the potential to impact personnel and the environment Any external contact will be communicated to the client via the Project Manager or their delegate Employees, Contractors & Visitors On identification of an occurrence requiring emergency response each employee has the responsibility to immediately notify the site supervisor or delegate. In the event of a serious situation the employee shall utilise this Plan to make direct contact with the closest emergency service required (e.g. spill clean-up service) Rev. C (1/07/2015) Page 7 of 51

8 2 Incident Anticipation, Planning and Response 2.1 Background This Plan has been prepared in order to guide and direct the response by the Bringelly Road Upgrade Stage 1 Project Team to an incident or emergency, be it environmental or safety in nature. The Plan has been modified following a review by independent consultants to assess compliance with the POEO Act 1997 Part 5.7A; Duty to Prepare and implement Pollution Incident Response Management Plans, and POEO (General) Regulation 2009 Part 3A, carried out on the 5 th November Plan preparation is a requirement for holders of Environment Protection Licences (EPLs). BMD holds EPL for road construction on this Project. Key areas which this Plan covers are described in Table 1 below; PIRMP Requirements. Table 1 PIRMP Requirements and Reference in this document Section Description Reference POEO Act Part 5.7 Section 153A Duty of Licence holder to prepare PIRMP Whole document 153C Information to be included and procedures or actions to take after an incident and coordinating with authorities 2,3,4, 5 Appendix 3 153D Keeping of plan E Testing of plan F Implementation of plan 8.2 POEO (Gen) Reg C(a) Hazard Assessment 2.2, Appendix 2 98C(b) Likelihood assessment 2.2, Appendix 2 98C(c) Pre-emptive Action 2.2, Appendix 2 98C(d) An inventory of potential pollutants on the premises or used in carrying out the relevant activity 2.2, Appendix 2 98C(e) Pollutant Inventory Quantities 2.2, Appendix 2 98C(f) Safety equipment such storage containers, spill kits, and PPE will be located near the source of chemical/fuel for easy access. 2.2, Appendix 2 98C(g) Staff Contacts explanation 1 98C(h) Authority Contact 1, Rev. C (1/07/2015) Page 8 of 51

9 98C(i) Early Warnings to Neighbours 2.2, Appendix 1 98C(j) Minimising the risk of harm to any persons will be risk assessed daily as per activity within an area by the site Foreman. Items for consideration may include evacuation point, appropriate PPE requirements, site accessibility, etc. 2.2, Appendix 2 98C(k) Map locations of pollutants 3, Appendix 1 98C(l) Early Warnings General C(m) Training of Staff 6 98C(n) Timing of Testing C(o) Updating of Plan 7 98C(p) Plan Testing D(1) Availability of Plan D(2) Publishing Plan Parts D(3) Procedures under the Act 2.1, All Appendices 98D(4) Privacy Protection E(1) Testing of the Plan E(2) Minimum Testing Requirements 8.1 EPA Bunding and Spill Management Guidelines 4 Minimising the risk of spills to the environment 2.2 RMS Code of Practice for Water Management 2 Best Practice Principle Whole document 2.2 Preparedness; Risk Assessment and Pre-Emptive Actions to Prevent Pollution Incident Risks This chapter deals with the POEO (General) Regulation 2009 s sections 98(a) to 98(f) and partially covers s98(j). These sections deal with the hazard, likelihood and pre-emptive actions which are similar processes to undertaking a risk assessment and providing appropriate control measures to prevent or minimise these risks. The key to effective prevention of incidents is risk assessment, procedure development, monitoring and training. During construction activities, BMD s inspections and preventive actions will include: Risk Register updated on a 3-monthly basis; Rev. C (1/07/2015) Page 9 of 51

10 activity specific and daily risk assessments, inclusive of associated environmental risk, safety of workers, and emergency evacuation; development of work procedures, construction method statements and environmental work method statements in consultation with relevant BMD staff such as work teams, environment team members and senior management; daily inspections of active work sites; completion of routine environmental checklists; issue and quick close-out of non-compliance notices; ongoing environmental training; environmental audits of work sites, subs and compliance issues. Environmental and safety information on hazardous substances (e.g. SDS) will be available at the main site office and where such substances are stored. Personnel involved in emergency response activities will be provided with specific training. An up-to-date list of emergency response personnel and organisations will be maintained at the main office and compounds. Additionally, a more detailed assessment of the above issues and more are included in s2.4 and Appendix Summary of Pollution Types Road construction has by its nature a limited list of typical pollution types which require consideration (see Table 2 below). The Project CEMP addresses these in more detail. Table 2 List of Typical Main Pollutants in Road Construction Description Comments Air Based Emissions Dust Fire Noise Odour From use of plant and equipment, moving across dry surfaces. Covered under G36 and CEMP Sub Plan. Small bush fires and other fires are covered under G36 and CEMP. Fire is not considered an environmental incident, but the smoke from the fire can be and can affect neighbours. Emitted by plant and equipment. Covered under G36 and the CEMP Sub Plan. Noise is not considered a pollution incident and not covered further under this Plan. Odour is generally associated with laying of asphalt and is managed under the CEMP under complaints. Water Based Emissions Fuel (diesel and petrol), lubricants and hydraulic oils Paints and surface coatings Pesticides Concrete wash out For plant and equipment operations. Covered under G36 s6.12 and the CEMP Potential for lead based paint on existing bridge over the Upper Canal. Surface coatings in many cases must be applied on site. Covered under G36 and the CEMP Control of weeds and pests: Covered under G36 and the CEMP Wash out of concrete vessels: Covered under G36 and the CEMP, EWMS Rev. C (1/07/2015) Page 10 of 51

11 Bitumen materials Effluent Soils and erosion Potential Asbestos Containing Material Application of spray seal and laying of asphalt. Removal and relocation of sewage septic systems from existing properties. Effluent to be disposed as being Liquid Waste in accordance with the EPA Waste Classification Guidelines Part 1: Classification of waste. The demolition sub to be licence to manage the removal of the sewage septic system structure and dispose the material at a licence waste facility. General site issue for exposed soils: Covered under G36, G38 and G40, CEMP and Soil and Water Management Sub Plan. Project is guided by General road construction handbook, BLUE BOOK Managing Urban Stormwater: Soils and Construction. Demolition of existing buildings/structures and unexpected finds: Covered under G36, G38, G40, CEMP and Contaminated Land Management Sub-Plan. Works to be undertaken in accordance with The Code of Practice: How to Safely Remove Asbestos prepared by Safe Work Australia and WorkCover s guidelines to managing asbestos. 2.4 Risk Assessment To improve the effectiveness of the Plan, Table 3 below set out the requirements under the POEO (General) Regulation 2009: Table 3 POEO (General) Regulation 2009 Requirements Section Item heading Covered by 98C(a) 98C(b) 98C(c) 98C(d) Hazard assessment: Likelihood assessment: Pre-Emptive Action: Pollutant Inventory Types: Hazard and Likelihood Risk assessment and Corrective Control Measures tables Hazard and Likelihood Risk assessment and Corrective Control Measures tables Hazard and Likelihood Risk assessment and Corrective Control Measures Control measures and corrective action List Of Polluting Substance Storages/Uses At Site Initial Assessment Name/description, Covered under Hazardous Chemicals? 98C(e) 98C(f) 98C(i) Pollutant Inventory Quantities: Safety Equipment: Early Warnings Neighbours: List Of Polluting Substance Storages/Uses At Site Initial Assessment Amount Stored (maximum or estimated Maximums stored) List Of Polluting Substance Storages/Uses At Site Initial Assessment- Ref to Safety Coverage List Of Polluting Substance Storages/Uses At Site Initial Assessment Need for early warnings to neighbours Rev. C (1/07/2015) Page 11 of 51

12 98C(j) 98C(k) Staff Safety: Maps location of pollutants: List Of Polluting Substance Storages/Uses At Site Initial Assessment Ref to Safety Coverage List Of Polluting Substance Storages/Uses At Site Initial Assessment Location of Storage, Map reference (supports section 3 Maps and maps in Appendix 1) The controls are covered in Appendix 3 Risk Assessments. They are broken down into the following: Main Activities of Environmental Hazard: o Clearing and grubbing o Bridge demolition and construction o Building demolition o Road construction o Utility works o Erosion and sedimentation o Chemical storage and use Each activity in the above list is assessed on the types, quantities, usage and storages of potential pollutions listed by its: o Chemical type o Is it a Dangerous Good? o Max Quantity on site o Location description o Map Reference o Potential impact on neighbours o Pre-emptive measures o Use of safety equipment A risk assessment is undertaken based on the RMS risk matrix which considers: o Hazard identification o Risk assessment o More detailed control measures for specific hazard/incident If the risk assessment process was found to be unacceptable or review of an incident resulted in changes to the risks, alternative and improved pre-emptive measures will be considered. 2.5 Notification The ESR or Superintendent/Foreman will make a decision based on RMS Environmental Incident Classification and Reporting Procedure what level of notification and callout is initially required for the incident. Larger incidents may require higher levels of notification and the need for external resources to manage the incident and protect soil, water and biodiversity. The ESR or PM will immediately notify the authorities listed in the below table of pollution incidents on or adjacent to the site where material harm* to the environment is caused or threatened. *That is, environmental harm or potential harm to the health or safety of human beings (from environmental hazards) or to ecosystems that is not trivial; or that result in actual or potential loss or property damage of an amount over $10,000. If there is not an immediate threat to human health or the environment Table 4 External Emergency Contacts - not an immediate threat Emergency Contact / Organisation Contact Details EPA Pollution Hotline Rev. C (1/07/2015) Page 12 of 51

13 Liverpool / Camden Council / NSW Ministry of Health (Liverpool Public Health Branch) WorkCover Authority NSW Fire and Rescue If there is an immediate threat to human health or the environment Table 5 External Emergency Contacts - immediate threat Emergency Contact / Organisation Contact Details NSW Fire and Rescue 000 EPA Pollution Hotline NSW Ministry of Health (Liverpool Public Health Branch) WorkCover Authority Liverpool / Camden Council / The Principal will be verbally notified immediately (by phone) and, in any case in writing within 24 hours, of any incidents which have been reported to the EPA under Part 5.7 of the POEO Act. The Principal will be verbally notified of any Category 1 environmental incidents within 1 hour of the incident occurring. Category 1 incidents are potentially the most serious and generally reflect breaches of environmental legislation (refer RMS Environmental Incident Classification and Reporting Procedure Section 1 for more detailed information) 2.6 Incident Investigation All incidents will be documented, investigated and action plans established to prevent a reoccurrence. RMS incident classification categorisation is to be included within the BMD report form details. Where lessons are learnt from the investigation or current procedures are identified as being ineffective, the CEMP or associated documents will be revised by the ESR to include the improved procedures or requirement. An environmental investigation includes the following basic elements: identifying the cause, extent and responsibility of the incident identifying and implementing the necessary corrective action identifying the personnel responsible for carrying out the corrective action implementing or modifying controls necessary to avoid a repeat occurrence of the incident recording any changes in written procedures required advising the environmental authority (i.e. EPA) if any substantial pollution has occurred. All personnel are required to report all incidents or near hits (misses), as it is regarded as a valuable method of addressing shortcomings in procedures, training or equipment, and is an opportunity for improvement. Rev. C (1/07/2015) Page 13 of 51

14 3 Project Maps This section covers the POEO (General) Regulation s98e(k) requirements which are: A detailed map (or set of maps) showing the location of the premises to which the licence relates, the surrounding area that is likely to be affected by a pollution incident, the location of potential pollutants on the premises and the location of any stormwater drains on the premises. As the Project is staged the maps include: An overall map of the entire project area covered by the EPL Project Specification G36 requires that the prepare the necessary documentation including the detailed maps required under the POEO (General) Regulation Other maps for the project relevant to this PIRMP are listed in the Emergency Spill Response Plan for this project. Appendix 1 shows the entire project alignment and include the EPL boundary, outside premises likely to be affected by a pollution incident, location of potential pollutants outside project boundary, and site facilities. Rev. C (1/07/2015) Page 14 of 51

15 4 Incident Response Procedure 4.1 Internal Communications - key names and contacts Incident Occurs Is there a potential risk to environment, health and/or safety? No If possible, prevent/control/remove the risk and/or provide appropriate first aid/support. Yes Evacuate or isolate the area and prevent access if area unsafe. For environmental incidents involving spills follow Emergency Spill Response Plan. Call 000 in the event of a medical emergency and designate appropriate person to direct ambulance from the public road to the incident location. Immediately notify BMD supervisor via phone or radio. Foreman and ESR/Safety Co-ordinator to inspect the area/accident. Foreman and Project Manager to determine if further action is required. Project Manager and ESR/Safety Co-ordinator to determine if immediate reporting to EPA/WorkCover and other regulatory bodies is required. Note: to be immediately notified in the event of actual or potential harm to the environment or health of site personnel (see section 2.4) Complete the BMD and RMS Incident report No Yes Foreman to manage any works to prevent further damage/harm. Toolbox work crew and/or site personnel if required Immediately notify RMS of incident via phone. An incident report is to be provided within 48 hours. Complete the BMD and RMS incident report, undertake investigation and determine management and/or remediation measures to be implemented on site Rev. C (1/07/2015) Page 15 of 51

16 5 Emergency Response Planning 5.1 Medical Emergency (SEE ST. JOHN S AMBULANCE FIRST AID RESPONDER CHART INCLUDED AT APPENDIX 3) 1 Check for any threatening situation and control it if safe to do so 2 Remain with casualty (unless there is no other option) and provide appropriate support 3 Do not move any casualties unless in a life threatening situation 4 Notify the Foreman and the first aider 5 Notify the ambulance if not already done and designate people to direct them from the public road to the incident location. 6 If necessary arrange clear path for emergency vehicles to the incident location, e.g. grader/dozer may clear path 7 Provide support to first aider and/or emergency services if required 5.2 Spillage of Hazardous Liquids/Petroleum/Chemicals (AS THE RISK OF SPILLAGE IS DEEMED ONE OF THE MORE LIKELY EMERGENCY EVENTS ON THIS PROJECT, A DEDICATED EMERGENCY SPILL RESPONSE PLAN IS INCLUDED AT APPENDIX 4 BELOW). 1. Identify the source and if possible minimise/stop further spillage. IN ALL CASES, ASCERTAIN FIRST WHETHER IT IS SAFE TO TACKLE THE SITUATION. IF UNCERTAIN, CONTACT EMERGENCY PERSONNEL AND EVACUATE AND SECURE THE AREA. 2. Stop work in the area and notify Foreman/Supervisor. 3. Under instruction of Foreman/Supervisor and if safe to do so, isolate the contaminated area to ensure that hazardous material does not spread to other areas. In the case of oil or other contaminant spill unable to be contained by adjacent spill kit, the immediate area shall be bunded to prevent spread of spill. 4. In the event of a spill from plant, the plant shall be shut down immediately, and shall not be moved until the spill can be contained and leaking part plugged / fixed. 5. If spillage occurs in the vicinity of creeks or stormwater drains, all measures must be taken to ensure that the creeks or inlets are protected (e.g. a temporary dam is acceptable) to restrict hazardous substance entering downstream. 6. Contaminant shall be soaked up with appropriate spill kit material and disposal of contaminated material shall occur at an approved disposal site. If hazardous materials cannot be completely restricted and removed from the site by equipment available then the local fire department is to be contacted. 7. Call: 000 or if using a digital mobile phone: Contaminated absorbent material shall be stored in a suitable bunded off and covered area or regulated waste bin within the site compound until disposal to an approved regulated waste disposal centre. 9. All spills shall be notified to the Site Superintendent and ESR as soon as practicable and incident report actioned. 5.3 Excavation and Disposal of Contaminated Material If the excavation and disposal of contaminated material is required, a toolbox meeting should be held to highlight the correct procedure. Refer to Unexpected Discovery of Contaminated Material Procedure within Soil and Water Management Plan Excavation Clean fill material to be separated from contaminated material. Do not stockpile contaminated material on pavements Rev. C (1/07/2015) Page 16 of 51

17 Attempt to prevent spillage of contaminated material onto pavements. Keep pavements clean where trucks are being loaded to prevent material being transported off site by wheels of truck Removal of sewage system All liquid and solid waste to controlled pumped Transport Clean vehicles of dirt, if required, to prevent transport of material off site. Any spillages to be cleaned as quickly as practicable. Cover all loads securely. Chemical drums for disposal to be transported in accordance with the Dangerous Good Act Disposal receipts must be collected from landfill and returned to Foreman for each load Personnel No unauthorised personnel (i.e. not directly involved with the work) should enter excavation. Avoid direct contact with any contaminated soil or water that has come into contact with contaminated soil. Eating, drinking, smoking or any other hand to mouth practice should be avoided. Wash hands with cleaning agent prior to eating or drinking. Boots to be cleaned before leaving site. Symptoms of chemical exposure including headache, dizziness, nausea and irritation of the respiratory tract, eyes or skin should be reported to the Foreman or the first aider. 5.4 Refuelling or maintenance and clean of plant and equipment Fuel cart/truck operator and mechanic to contact BMD foreman on arrival before entering site to determine whether site access is permitted and the locations of plant and equipment for refuelling. Fuel cart/truck and mechanic to park parallel to the plant or equipment, away from any other obstructions. Refuelling and maintenance of all plant and equipment must be conduct on level impermeable surface, where possible. Plant or equipment must be switch-off before and during refuelling operation and maintenance. No refuelling or maintenance of plant and equipment near drainage inlets or the like, including swale drains and sediment basins. Spill kit, Safety Data Sheet and fire extinguisher must be accessible on the fuel cart/truck and mechanical truck. Drip tray or absorbent pads to be placed underneath where the nozzle refuels the machine/plant to contain leaks, including extracting oil and changing filters during maintenance. Dispose all waste material in accordance with legislative requirements. If a spill or leak occurs, contact BMD foreman who will inform BMD ESR for an initial investigation to determine the severity of the incident. RMS will be notified of the incident immediately, and written notification will be forwarded to the RMS within 24 hours. Designated concrete washout facility will be provided onsite or concrete agitators will be instructed to return back to their concrete batch yard for washout. Bitumen spray bars and asphalt pavers to cleaned of loose material at a location away from waterways before leaving site. Check and clean tyres before leaving site to minimise tracking of material on to public road. 5.5 Sediment control resulting from large rainfall events In the case of an environmental emergency event the Foreman shall be notified immediately and the following procedures shall be followed. Personal safety shall be given priority under all circumstances. Check all erosion and sediment control devices for conformance Rev. C (1/07/2015) Page 17 of 51

18 Diversion drains shall be cut into exposed batter slopes to direct sheet flows and divert concentrated runoff to stabilised channels. Emergency silt fence, straw bales, diversion drains or water runoff velocity check dams shall be placed to minimise impact. 5.6 Excessive Dust In the case of excessive dust, water shall be applied to the areas causing dust problems. Operations shall not cease until such time as dust generation is controllable. Consider wind direction, strength and location of sensitive receptors. Utilise appropriate dust minimisation measures such as scraping haul roads / cuts to underlying wetter layers, proactive shut down of areas not being worked for extended periods of time, or using dust suppressing additives in water carts. 5.7 Bush Fire Should a bush or grass fire occur the local fire authorities shall be contacted. Water trucks may also be used, when safe, to assist in the case of such an event. 5.8 Injured animals Any fauna injured as a result of work operations should be notified to the ESR who will contact WIRES or the local vet (as per Flora and Fauna management Plan). A list of names and phone numbers of emergency services is prominently displayed in the Site Office, and crib hut for quick reference in the event of an emergency. The importance of this emergency response plan shall be reiterated during toolbox talks. Rev. C (1/07/2015) Page 18 of 51

19 5.9 Early Warnings and Communications to Neighbours Key stakeholders and residents were sent a community update in January 2015 detailing the commencement and breakdown of project stages of the Bringelly Road Upgrade Stage 1. RMS have and will continue to provide key stakeholders and residents of project updates via the monthly Community Update newsletter. The will prepare an environment Action Table as part of the CEMP that details the cases where contact with community may be needed and how this contact will be managed. The project map in the Emergency Spill Response Plan shows the location of neighbouring properties. An assessment of the typical pollution incident types has been undertaken to consider the potential impacts on neighbours. This resulted in the early warning actions located in Table 7 below. Table 6 List of Typical Main Pollutants and Potential Neighbour Impacts and Early Warnings Air Based Emissions Description Potential Risks Early Warning actions Dust Air quality issues Loss of amenity Community complaints In extreme cases contact neighbours via doorknock process and ask them to close windows and doors and stay Fire Noise Odour Air quality issues Threat to safety Loss of amenity Community complaints Air quality issues Loss of amenity Community Complaints Spill type emissions Fuel including Water quality issues if spill enters waterway diesel and petrol Community complaints based fuels Lubricants and hydraulic oils Pesticides Paints and surface coatings Concrete alkali washings Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints inside until further notice In extreme cases contact neighbours via doorknock process and ask them to close windows and doors and stay inside until further notice. For larger fires, coordinate with combat agencies. Not required under PIRMP. Communicate with neighbours on as needs basis as per CEMP In extreme cases contact neighbours via doorknock process and ask them to close windows and doors and stay inside until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice. For larger spills coordinate with combat agency. In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice. For larger spills coordinate with combat agency. In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them Rev. C (1/07/2015) Page 19 of 51

20 Bitumen and cutting products Other chemicals Soils and erosion Contaminated materials uncovered Wastes Tannins Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints Water quality issues if spill enters waterway Community complaints to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice Ongoing community relations under the CEMP will ensure the community is kept up to date on pollution incidents and other matters. Such actions will also advise on the website information and how to respond to such incidents if required Website information This Pollution Incident Response Management Plan (PIRMP or Plan) will be uploaded on to the project BMD website as a requirements under the Protection of the Environment Operations Act 1997 (POEO Act) and the Protection of the Environment Operations (General) Regulation 2009 s98d: (2) A plan is also to be made publicly available in the following manner within 14 days after it is prepared: (a) in a prominent position on a publicly accessible website of the person who is required to prepare the plan, (b) if the person does not have such a website--by providing a copy of the plan, without charge, to any person who makes a written request for a copy. 3) Subclause (2) applies only in relation to that part of a plan that includes the information required under: (a) section 153C(a) of the Act, and (b) clause 98C (1) (h) and (i) or (2) (b) and (c) (as the case requires). The internet link below is where the PIRMP can be download and viewed by the public. Rev. C (1/07/2015) Page 20 of 51

21 5.10 Availability and Location of This Plan 5.10 The POEO (General) Regulation 2009 s98d(1) states: (1) A plan is to be made readily available: 5.10 (a) to an authorised officer on request, and (b) at the premises to which the relevant licence relates, or where the relevant activity takes place, to any 5.10 person who is responsible for implementing the plan. This 5.10 Plan is located at: The BMD Site office 5.10 On the BMD project webpage ( In any event the availability of this Plan will be made available by locating printed copies in the same locations 5.10 as the Environment Protection Licence (EPL) is located Privacy Protection Unlike the EPL this Plan is to only be available to those who are to implement the Plan. This is made clear by 5.10 The POEO (General) Regulation 2009 s98d(3) which States ) Any personal information within the meaning of the Privacy and Personal Information Protection Act 1998 is not required to be included in a plan that is made available to any person other than a person referred to in subclause (1) Where components of the Plan are considered to contain sensitive private information then only those cleared should be permitted access to the full Plan. Alternative Plans with such sensitive information removed (e.g contact phone numbers and names) can be more widely distributed. Full plans will be made available to the relevant government agencies, on request or during an incident response activity Training Summary and Reference to Project Procedure 5.10 As part of RMS G36 Environmental Protection (Management Systems) the Contractor s Environment Management 5.10 Plan the following induction and training must include where applicable the following: Purpose and objections of the CEMP 5.10 Requirement of due diligence and duty of care Condition of environmental licenses, permits and approvals Environmental emergency plans 5.10 Management and reporting processes for environmental incidents Lessons leant from environmental incidents 5.10 Environmental controls that are identified in the CEMP and its supplementary plan Site specific issues including, but not limited to erosion and sediment control, boundaries for vegetation clearing, locations of refuse bins, washing, refueling and maintenance of vehicles, plant and equipment. Environmentally sensitive areas Use of spill kits to contain any chemical, fuel or oil spills To also satisfy the requirements under this PIRMP the training is to also include: Awareness of the PIRMP Where this Plan can be accessed Pollution incident classification and reporting under this plan Spill response actions under this plan Other incident response actions under this plan Rev. C (1/07/2015) Page 21 of 51

22 Early warnings internally and to neighbours where appropriate Specific procedures in dealing with potential pollution incidents e.g. pump out of sedimentation basins Section 13 of the CEMP outlines the requirement for all project personnel, subs, consultants and visitors to be familiar with the environmental management obligations and requirements of the project, especially the requirements of this plan. The information will be communicated at the site specific induction, on occasion a specific environmental training (as per Table 14 of the CEMP) will be carried out, discussed at the daily site briefing, and monthly mentioned at toolbox talks. All records of induction, training, site briefing and toolbox talks will be held on file for at least four years after the date of Final Completion and will be available to the RMS and to the EPA officers on request. 7 Updating of Plan Effective date: April 2015 Review date This Plan will be updated according to the following: One month after the Contractor Environment Management Plan has been accepted by RMS; or 12 months from the last update; or Within one month of a Category 1 Incident; or As identified after testing of the Plan (see section 8). 8 Testing and Implementation 8.1 Testing of the PIRMP The POEO (General) Regulation E states for testing of the Plan: 1) The testing of a plan is to be carried out in such a manner as to ensure that the information included in the plan is accurate and up to date and the plan is capable of being implemented in a workable and effective manner. 2) Any such test is to be carried out: (a) routinely at least once every 12 months, and (b) within 1 month of any pollution incident occurring in the course of an activity to which the licence relates so as to assess, in the light of that incident, whether the information included in the plan is accurate and up to date and the plan is still capable of being implemented in a workable and effective manner Testing of the Plan will be integrated into other emergency and incident testing and training programs. Testing of the Plan cannot be properly undertaken or designed until the CEMP has been prepared for that Stage of development of the project. Initial testing of the plan will be undertaken within 6 months of the acceptance of the CEMP. Design of the testing will be undertaken 1 month before the testing is conducted. Records of the testing will be required by the RMS on the. Testing dates This Plan will be updated according to the following: Initially 6 months month after the Contractor Environment Management Plan has been accepted by RMS, or 12 months from the last update, or Design of the testing method will be 1 month before the initial test date Or before one month after a Category 1 Incident. Rev. C (1/07/2015) Page 22 of 51

23 Further details will be available under the Incident and Emergency Response Management Plan for the Project. Recording of Testing A detailed record of the testing of the Plan will be prepared after each testing of the plan is undertaken. If the test identifies any shortcomings in the Plan, especially the implementation of the spill response procedures, the Plan will be corrected or appropriate non-conformance actions will be undertaken. This plan was last tested in December Implementation of the Plan The POEO Act 1997 s 153F requires the Plan be implemented if a pollution incident occurs. A pollution incident is defined under clause 147 of part 5.7 of the POEO Act 1997 as: 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. $2 million maximum fines apply for failing to implement the Plan. Hence if a pollution incident occurs: It must be responded to according to this Plan and its reference documents. An incident response report/audit must be completed Rev. C (1/07/2015) Page 23 of 51

24 Appendix 1 Project Map Rev. C (1/07/2015) Page 24 of 51

25 Bonds Creek Northern Site Facility Fuel Storage Facility SCA Upper Canal Kemps Creek Main Site Compound Scalabrini Creek EPL Boundary Rev. C (1/07/2015) Page 25 of 51

26 Appendix 2 Risk Assessments This Plan uses a risk assessment process to demonstrate the existing risk control methods are effective in preventing and minimising environmental harm from pollution incidents. If unacceptable risks are identified new control measures will be introduced. The modular format permits the use of common activities associated with road construction to be used in future PIRMP documents. The modules used for this Plan for the Project include: Clearing and grubbing Road construction Soil and water management Chemical storage and use Each module uses a standard risk matrix used by RMS in its REF. Each module lists the type of use or storage for the pollutant/s being considered. Each of the above is considered for a range of hazards and their control method considered. Also considered in the above process is: Risk Matrix Impact on neighbours Safety Location If the pollutant is a hazardous chemical Environmental risks associated with RMS and its s activities use the following table. RMS Environmental Risk Matrix Severity (level of impact) Insignificant Minor Moderate Major Catastrophic Probability (Likelihood) 5 Almost Certain H H E E E 4 Likely M H H E E 3 Moderate L M H E E 2 Unlikely L L M H E 1 Rare L L M H H Risk Factors: E =Extreme, H = High, M = Moderate, L = Low The hazards, likelihood and pre-emptive measures assessments which follow the above table in assessing the environmental risks associated with the hazards identified. Rev. C (1/07/2015) Page 26 of 51

27 Clearing and Grubbing Purpose This risk module forms part of the PIRMP for the Bringelly Road Upgrade Stage 1 project. The activities associated with this module are related only to clearing and grubbing. Activities Clearing and Grubbing involves: Clearing of vegetation Clearing of minor built structures Clearing of rubbish and other Grubbing of trees and stumps Mulching Stockpiling of mulch Removal of Mulch This risk module describes the main hazards to human health or the environment associated with clearing and grubbing. The first table in the risk module lists the potential pollutants. The second table describes the potential pollution incidents with pre-emptive actions to be taken to minimise or prevent any risk of harm to human health or the environment. In the case of actual or threatened material harm to the environment or human health procedures must be followed for contacting authorities as in RMS Environmental Incident Classification and Reporting Procedure. For incidents where pollution has the potential to impact on the community, early warning systems as described in section 6 of this document are to be initiated. Further details on the risk assessment and appropriate control methods can be found in the following documents: CEMP Review of Environmental Factors (REF) 2011 and addendum REF 2013 Environmental Work Method statements The module has been written to cover general environmental hazards and their controls. As the construction process is fluid, new documentation may better reflect the risks and controls. Primarily this will be captured in the CEMP. Rev. C (1/07/2015) Page 27 of 51

28 LIST OF POLLUTING SUBSTANCE STORAGES/USES AT SITE INITIAL ASSESSMENT CLEARING AND GRUBBING Project Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineers, Foreman, ESR Date March 2015 Name / description Hazardous Chemicals Amount stored Location of storage Map reference CHEMICALS (raw materials and products which can cause pollution) Need for early warning 1 Pre-emptive action ref Ref to safety coverage Noxious Weeds No variable variable variable no See CEMP, G36 N/A See item 1 Oils and fuel from vehicles Ref to Hazard and likelihood assessment Yes < 1000 L variable variable no See CEMP, G36 See SMP See road construction and chemical module MATERIALS (eg stockpiles, silos, bulk solids etc.) Mulch no variable variable variable Only in extreme wind where dust threatens to impact on community Soil Erosion no variable variable variable Only in extreme cases where erosion materials threaten to impact on health of waterway rubbish and other Only for asbestos waste variable variable variable If asbestos is found and fibres enter waterway or become airborne and threaten to impact on community See CEMP, G36, G38 See CEMP, G36, G38 N/A See item 2 and 3 N/A See item 4 See CEMP, G36 N/A See item 5 1 Early warnings relate to informing neighbors who may be affected by the emission of this substance. If this substance is of a type and quantity which may reach neighbors then early warning assessment of actions is required to be undertaken. Rev. C (1/07/2015) Page 28 of 51

29 HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES CLEARING AND GRUBBING Project Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineers, Foreman, ESR Date March 2015 Name / ref of pollutant/ chemicals 1.Noxious weeds Description of Hazard / Incident leading to hazard Improper disposal of noxious weeds causing contamination of land Level of impact Likely hood Priority Impact on neighbours 2.Mulching Generation of dust 2 3 M Unlikely but possible Control Measures Corrective Action 2 2 L Negligible. Contractor to remove and dispose in accordance with Camden council regulations Staff training CEMP G to write clearing and grubbing plan Contractor waste management plan Ecologist report prepared on location of weeds and marked in drawings as per G40 CEMP clearing and grubbing plan Staff training Responsible Person Generation of tannins contaminating waterway with high BOD 3 3 H Unlikely but possible Reduce volume of mulch to be managed at any one time -RMS Enviro Direction Management of Tannins from Vegetation Mulch CEMP Staff Training 3.Mulch Stockpiling Dust 2 3 M Unlikely but possible CEMP clearing and grubbing plan RMS Stockpile site management guideline EMS-TG-10 Staff training Rev. C (1/07/2015) Page 29 of 51

30 Name / ref of pollutant/ chemicals 3.Mulch Stockpiling Description of Hazard / Incident leading to hazard Generation of tannins contaminating waterway with high BOD Level of impact Likely hood Priority Impact on neighbours 3 3 H Unlikely but possible Control Measures Corrective Action Reduce volume of mulch to be managed at any one time -RMS Enviro direction Management of Tannins from Vegetation Mulch Stockpile management plan and layout to be developed prior to stockpiling to ensure location of piles. Responsible Person CEMP Staff Training Fire 3 2 M Unlikely but possible RMS Stockpile site management guideline EMS-TG-10 CEMP Staff Training in turning stockpiles 4.Soil Erosion Erosion from cleared land entering waterway 3 2 M Unlikely but possible clearing not to be done within 15m water courses until immediately before construction in that area CEMP soil and water plan G38 Erosion and sediment control 5.Rubbish and other Improper disposal of waste causing contamination of land or water 2 2 L Unlikely but possible Contractor to remove and dispose in accordance with council regulations Staff training CEMP G40 to write clearing and grubbing plan Contractor waste management plan Rev. C (1/07/2015) Page 30 of 51

31 Name / ref of pollutant/ chemicals 6.Plant and equipment leaks and spills Description of Hazard / Incident leading to hazard Spills into waterways from plant and equipment (e.g. hydraulic hose leaks, concrete loading, leaks from vehicles and road plant.) Level of impact Likely hood Priority Impact on neighbours 3 3 H May impact on surface water quality if it goes off site Control Measures Corrective Action Project Team to ensure that chemical, fuel and lubricant storage areas must be suitably located inside a HazChem container in a secure protected area with an impermeable floor to minimise the impact of any spillage or contamination on the Site and adjoining areas. The HazChem container must be able to contain 120% of the total volume of the stored materials. Do not locate storage areas within 40 metres of natural or built drainage lines, flood prone areas, or on slopes steeper than 1:10. The Hazchem container is be located within the boundary of the main site compound and at nominated satellite site facilities. A fully equip spill kit shall be available and accessible and all the material safety data information for any chemical or fuel to be used or stored adjacent to the HazChem container. Sedimentation basins act as capture / additional containment Spill response measures implemented as per CEMP or Appendix 3 of this Plan Auditing of implementation of G36 by Responsible Person Contractor Rev. C (1/07/2015) Page 31 of 51