R8000 NEW AIR COMBAT CAPABILITY (NACC) FACILITIES PROJECT, RAAF BASE WILLIAMTOWN
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1 LEND LEASE BUILDING PTY LIMITED ABN R8000 NEW AIR COMBAT CAPABILITY (NACC) FACILITIES PROJECT, RAAF BASE WILLIAMTOWN HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN 3/12/2015 Revision No: 7
2 Plan Revision Status Date Revision (in numbers) 19/09/ Initial Draft Purpose and Summary of Amendments Reviewed by Approved by 15/10/ For Construction 14/11/ Updated to include SEM s and additional internal QA comments 16/03/ Updated chemical storage and labelling requirements 22/06/ Quarterly review. Included responsibilities coloum. 22/09/ Quarterly review and update 3/12/ Quarterly review and update *Note that all printed paper/hard copies of this document and related procedures are uncontrolled. The controlled copy of this document is found either in Project Web, within the Project Management Plan section, or other project specific database/server approved by the Regional EHS Manager. HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 2 of 11
3 HAZARDOUS SUBSTANCES/DANGEROUS GOODS MANAGEMENT PLAN Scope: This Hazardous Substances / Dangerous Goods Management Plan details management measures for Hazardous Substances / Dangerous Goods during construction at the NACC Facilities Project Williamtown. It defines mitigation measures to be implemented, storage and handling protocols that enables control of the impacts of construction activities on potentially affected areas, and contingency measures that may be implemented if unforseen release or exposures are experienced. Objective: To receive, store, utilise, handle and dispose of chemical and hazardous materials in an environmentally appropriate manner. To prevent any contamination of site work areas and adjoining properties including all aquatic ecosystems by chemicals and fuels etc. utilised on the construction site. To ensure proper treatment / disposed of substances as needed. Typically Hazardous Substances / Dangerous Goods exist in three (3) forms on a construction sites, being a solid, liquid or a gas. These substances are usually recognisable as bulk fuels; products containing asbestos, lead based paints as well as chemicals (both used and stored) such as PCBs. On a typical project site there are five (5) classes of Hazardous Substances and Dangerous Goods (HS&DG), which are most commonly utilised. 1. Dangerous Goods Class 2.1(Flammable gases): propane, LPG, acetylene 2. Dangerous Goods Class 2.2(Non-flammable non-toxic gases): argon 3. Dangerous Goods Class 3 (Flammable liquids): diesel fuels, petrol, lubricating oil etc. 4. Dangerous Goods Class 5.1 (Oxidizing substances): oxygen, hydrogen peroxide. 5. Dangerous Goods Class 8 (Corrosive substances): cleaning acids, chloride Risks: Hazardous Materials may also be encountered during demolition of existing structures and buildings, management of this risk is addressed in the Asbestos & Hazardous Building Materials Management Plan There is potential to encounter contaminated soil or groundwater during excavation work, this risk will be addressed in the Contaminated Soil & Water Management Plan. Sensitive receptors include: construction teams, RAAF Base personnel, Newcastle Airport staff and visitors, Fighter World Tomago Sand beds Aquifer. Neighbouring Properties An escape of hazardous substances may have a potentially significant environmental and human health consequence. Appropriate management measures must be established to prevent any environmental incidents from occurring. The implementation of the Hazardous Substances & Dangerous Goods Management Plan is intended as mitigation measures to prevent the following risks from occurring. HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 3 of 11
4 Leaks or spill from site storage, or use of dangerous / hazardous goods such as fuels. Exposure of site workers or base personnel or the public to dangerous goods or hazardous substances Inappropriate disposal of dangerous goods or hazardous substances Commonwealth: Environment Protection and Biodiversity Conservation Act 1999 State: While state legislation does not apply to Defence activities, Defence aims to be good environmental stewards and comply with State government legislation and policies to the extent that these do not conflict with Commonwealth legislative obligations or compromise operational objectives or capability. NOTE: State Legislation does apply to activities carried out outside of Defence land. Key Legislation / Standards / Guidance Protection of the Environment Operations Act (POEO) 1997; Protection of the Environment Operations (General) Regulation 1998; Contaminated Land Management Amendment Act 2008; Explosives Act 2003 and Regulation 2005; Occupational Health and Safety Act (OHS) 2000 and Regulation 2001; OHS Amendment Act (Dangerous Goods) 2003; Road and Rail Transport Act (Dangerous Goods) 1997; Pesticides Act 1999; Environmentally Hazardous Chemicals Act Guidelines and Standards: Waste Classification Guidelines 2014 (NSW EPA Publication); NSW Rural Fire Service publication Equipment and Machinery Use in Bush Fire Prone Areas ; and Acid Sulphate Soil Manual (ASSMAC 1998) Australian Standard AS 1940: 2004 Storage and Handling of Flammable and Combustible Liquids Australian Standard AS 4452B1997: The Storage and Handling of Toxic Substances National Code of Practice for the Labelling of Workplace Substances. National Code of Practice for the Preparation of Material Safety Data Sheets (Check Safe Work Australia) Work Health and Safety Act & Regulation 2011 Construction teams will aim to minimise the need bulk for storage on site of HS&DG. Site Controls: Hazardous substances/ dangerous goods (HS&DG) storage and handling impacts shall be minimised by incorporation of appropriate control measures in the specification and contract HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 4 of 11
5 arrangements, and quality assurance inspection and monitoring during construction. The installation and maintenance of HS&DG controls during the construction phase shall be accordance with the following table. All controls are to comply will the Lendlease GMRs Storage of HS&DG Site Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure A HS&DG stores location will be planned and recorded for the site. These plans will be updated as the site changes or work progresses Prior to works commencing Detail the designated storage locations for all dangerous goods on the site will be included in the Erosion and Sediment Control Plans (ESCP). CM/SM Review of ESCP prior works commencing. Diagram to be reviewed as required. ESCP prepared & containing all relevant details. HS&DG Stores located away from sensitive receptors. Dangerous goods storage locations must be positioned away from high traffic areas, pedestrian zones and environmentally sensitive areas such as waterways or natural habitats. CM Review prior to designation as a HS&DG Store. Review at quarterly EHS Audit Not within vicinity of sensitive receptor. Appropriate HS&DG stores constructed on site in designated areas. All chemicals to be stored in secure covered bundled areas with capacity to hold 110% of the volume of the largest container. SM Weekly inspection. Appropriate structures i.e. sealed floors & bund, cover/roof, signage, designated drainage & sump collection, security. Sump will be provided for pumping out the bund No uncontrolled spills/ leakages. Chemicals will be appropriately segregated and spill kits and firefighting appliances will be available at all chemical stores. Design and construct HS&DG stores prior to commencing works. Maintain bunds to preserve clean storage capacity Bunds to be maintained empty of accumulated chemicals or rainwater. SM Weekly inspection. All bunds maintained clean and with full capacity. All dewatering of chemical bunds tested and disposed of to an appropriately licenced liquid waste disposal facility (see Waste Management Plan) Ensure Storage and handling procedures are reviewed and made available. Chemicals, fuels and oil containers must be clearly labelled. Reference to these procedures should be included in the site induction. Prior to works commencing Covered in the site induction training. All storage containers are labelled in compliance with National Code of Practice for the Labelling of Workplace Substances SM Review effectiveness at 3 monthly EHS audit. Inspections No employee without site induction. No unlabled chemicals, fuels and oil containers are on site. Safety Data Sheet (SDS) register and Prior to Contractors to supply SDS and for inclusion in SM SDS supplied required prior to use SDS centrally located (first aid). HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 5 of 11
6 Site Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure HS&DG Register to be maintained on site. SDS should not be more than 5 years old from the issue date. substance being used on site. the Hazardous Substances/Dangerous Goods Register. Hazardous Substances/Dangerous Goods Register No substance being used without SDS. No substance being stored on-site without inclusion in HS&DG Register. Security measures in place for all HS&DG Stores. Install security prior to works commencing. Induct and train all staff and site personnel. SM Weekly inspection. No theft, vandalism or misuse. No HS&DG Stores left open or unlocked without supervision. Provide appropriate spill kits at any permanent fuel / chemical storage bunds and areas. Appropriate spill kits adjacent to all HS/DG Storage areas. Hydrocarbon Spill Kits to be provided where fuel and oils are being stored. Sub-Contractor/ SM Weekly inspection. Risk assessments Fully stocked and appropriate spill kit available at storage areas. General Spill Kits to be provided where water based products are being stored. Where risk assessments indicate, specialist chemical spill kits may be required for products such as acids or corrosive chemicals Emergency procedures regarding spillage containment, control and clean up shall be displayed in a prominent position within the site Implement the spill ranagement procedures described below in the event of a land-based or water based fuel, oil or chemical spill. SM Monitoring of activities and condition of spill kits including re-stock.. Drills to be undertaken every 6 months No spill or handling incidents with the potential to cause environmental degradation or human health impact. Use of HS&DG Refuelling of plant will take place in designated areas, 20m away from any water course or drain, on hard stand and with spill kits on hand to contain and clean up any spills. Light vehicles will be refuelled and maintained off site. Maintenance and cleaning of plant done in appropriately designed and controlled areas Refuelling to follow the Refuelling Procedure (Appendix A) SWMS to be provided Spill kit available at fuelling point. Containment controls must be in place prior to operations commencing. Major maintenance should be completed off site where possible. As a minimum maintenance activities should be carried out 20m away from any water course or drain, on hard stand and with spill kits on hand to contain and clean up any spills. Where emergency maintenance necessitates Sub-Contractor/SM Sub-Contractor./SM HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 6 of 11 Refuelling activities supervised at all times. Auditt of Work Method Statement Random inspection Work Method Statement No refuelling by other means No maintenance outside designated areas. Designated areas shown on ESCP.
7 Site Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure Plant and equipment checklists to be completed.. Provide appropriate spill kits in areas where fuels or chemicals are being used. Personnel to be trained in the use of the provided spill kits to control, contain and clean up spills exception to this requirement, all practical measures such as portable bunds, ground sheets and good housekeeping must be employed to prevent chemical, fuel or oil spills. As necessary Using developed checklists Plant operators/ SM Daily (documented) inspections by operators/subcontractors Prior to commencing work involving use of fuels or chemicals Appropriate spill kits to be readily available where fuel and chemicals are being used. Hydrocarbon Spill Kits to be provided where fuel and oils are being used. General Spill Kits to be provided where water based products are being used Where risk assessments indicate, specialist chemical spill kits may be required for products such as acids or corrosive chemicals Spill response procedure to be covered in Site Induction and trained in specific training / toolbox sessions as required Drills to be undertaken every 6 months All spills to be recorded and reported All spills to be reported to the Managing Contractor. Respond to spills to minimise environmental harm In the event of a spill The Managing Contractor will report to the Client as required, in accordance with the documented environmental incident reporting detailed within the Site Management Plan. Ensure all personnel are away from danger. Notify the site supervisor. Stop the leak or source of spill if possible Contain and absorb spill and all potential runoff from affected area On hardstand surfaces - Form a barrier around spill using booms. For large spills a temporary bund may be required to be installed. Sub-Contractor/SM Sub-Contractor/SM HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 7 of 11 Random checks EHS Weekly Checklist. ESCP Weekly inspection. Quarterly GMR Audit Periodic spill kit inspections /audits Induction and training records Spill Drill records Spill reports / investigations Daily log books filled out. No preventable spills. Fully stocked and appropriate spill kit available where chemicals and fuels are used. Appropriate level of understanding of spill response as demonstrated in response to spill incidents and during spill drills. SM Spill reports All spills reported in accordance with the EHS Management Plan and Site Management Plan SM / Sub-contractor /EM Spill reports All spill s manged appropriately to minimise environmental harm.
8 Site Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure Adequate Fire Fighting Equipment to be kept in designated areas. Concrete waste and wash water to be contained and managed Management of HS&DG Waste Waste substances (oil/ diesel/solvents) to be collected and stored in designated liquid waste containers within bundled area until Use absorbent material and pads to absorb the spill. Work from the perimeter of the spill towards the center. On soil and sand as soon as possible stop the source of the spill and/or prevent further spill onto the ground and excavate spill contaminated material to minimize potentntial for the spill soaking down into the aquifer. Place contaminated material on a bunded impervious surface. For spills on water ensure that absorbent materials from marine spill kit are used. Collect and dispose of absorbent materials appropriately. Waste absorbent materials are to be disposed of at a suitably licensed disposal facility and transported by a licensed contractor. Report spill and restock used spill response materials As per the site risk assessment. Contractor/SM Random / through weekly EHS walk. Sufficient firefighting equipment and suitable types based on Hazardous Substances/Dangerous Goods Register. As required Concrete washout will be to lined and bundled concrete wash out bays only. Site inductions and signage on site will direct concrete Agi s and pumps to the washout bays. Blow out lines and waste concrete will be to designated washouts or onto plastic sheeting or similar for collection and disposal. Sufficient capacity allowed in design of HS/DG storage facilities. See also Waste Management Plan HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 8 of 11 Contractor/SM Weekly inspection No pollution of soil or waterways/drains due to concrete waste or wash water Contractor/SM Inspection weekly Waste Register Waste receipts/dockets All liquid waste placed in appropriate containers. No uncontrolled spills or leakages.
9 Site Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure disposal can be arranged. Waste substances (oil/ diesel/solvents) to be removed/disposed to an appropriately licenced waste facility. As required As per approved contractors list. In accordance with contractor SWMS. Waste to be transported by a licenced contractor and/or tracked where required by NSW Waste legislation / guidelines. See also Waste Management Plan Contractor/SM Waste Register Waste receipts/dockets Waste tracking documentation (where required) Reports from waste contractor Liquid Waste collection/disposal dockets provided for every load. Waste disposal documentation available in site files, and provided to Managing Contractor as required. Verification through EHS Audits. Waste substances (oil/diesel/solvents) to be recycled, where possible. As required Designated area for storage of recyclable substances. Contractor/SM Verification through EHS Audits. Site inspections Waste dockets from recycling contractors. Toilet waste to be disposed to an appropriately licenced waste facility As required Via the HWC sewerage system, or collected by an appropriately licenced contractor. In accordance with the NSW EPA Waste Guidelines. SM As required Waste disposal receipts No uncontrolled discharges and/or spills HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 9 of 11
10 Appendix A Onsite Refuelling Protocol 1. Introduction This on site refueling protocol has been developed to manage all refueling of vehicles / plant during construction for NACC Facilities Project at RAAF Williamtown. The protocol is to be implemented by all sub-contractors and Lendlease personel responsible for refueling of plant, vehicles or machinery. The includes: i. a decision-making flowchart to determine whether on-site or off-site refueling is appropriate in a given situation; ii. iii. procedures for refueling to address the potential for spills, collisions with refueling vehicles or other hazardous incidents; and procedures to be followed in the event of a diesel spill, including containment and clean-up measures. 2. Refuelling Decision Flowchart The following decision making process diagram will be used to determine appropriate refueling locations. Are the vehicles / machinery to be refuelled able to reasonably travel to dedicated Project or external refueling locations? YES NO Refuelling must be undertaken in dedicated facilities either: 1. in external refueling locations or 2. in hardstand / compound / workshop locations to minimise construction-site refueling. See Section 3a Ensure all management measures and checks are completed as detailed in Section 3b of this Protocol. Refuelling may then commence Are vehicles / machinery positioned on level ground and at least 20m from a waterway? YES NO Are vehicles / machinery able to be reasonably repositioned to meet above criteria? (If Yes, do so) YES NO Ensure Environmental Officer is notified of works, Section 3b is complied with and any additional spill response material directed by the Environmental Coordinator is available. Refuelling may then commence HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 10 of 11
11 3a. Refuelling in Dedicated Areas Refuelling externally from the Project site or within dedicated hardstand / compound / workshop areas on the site is preferred. When refuelling in workshop or compound areas, the following standard safeguards must be followed: 1. refuelling areas must be on hardstand areas and able to capture and contain any spills in oil / water separators; 2. where practical, refuelling areas should be undercover to prevent interaction with rainwater; and 3. regular maintenance of refuelling areas and associated containment / treatment devices should be undertaken. 3b. On-Site Refuelling Requirements Where refuelling cannot be undertaken externally or in dedicated compound / workshop locations, the following control measures must be implemented: 1. refuelling must be undertaken on relatively level ground at least 20m from waterways, drainage lines and sensitive areas. Where this is not possible, notify the Environmental Officer and implement additional spill controls measures; 2. never refuel in vegetated areas; 3. never leave the refueling activity unattended; 4. know where your spill kit is kept and ensure you know how to use it. Keep a spill kit on the refueling truck; 5. ensure the machine operator shutdowns the machine and make safe according to the manufacturers specifications before refuelling; 6. where possible drip trays to be placed under standing machinery i.e. generators, compressors etc.; 7. handling, storage and disposal of fuel, oil, and other chemicals will be undertaken in accordance with the Waste Guidelines (DECCW 2008) and AS , the Storage and Handling of Flammable and Combustible Liquids; 8. control measures in this Protocol will be followed and all relevant personnel trained in the requirements; 9. emergency response procedures outlined in the HS&DGMP shall be implemented in the event of a spill or other environmental incident; and 10. spill incidents will be reported to the site supervisor, who will report this to the environment team for action. 3c. Fuel Transportation Requirements The following fuel transport controls will be implemented: 1. on site transportation of fuel will only be carried out on established access haul roads; 2. vehicles/trucks used to transport fuels and chemicals must be maintained to prevent spillage of loads; 3. fuel trucks entering site will be fitted with standard site safety gear including UHF radios, reversing beepers and flashing lights to ensure visibility on site and reduces the risk of vehicular collisions; and 4. any container used to transport fuel must be secured on the vehicle carrying the container. HAZARDOUS SUBSTANCES DANGEROUS GOODS MANAGEMENT PLAN Page 11 of 11
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