Rivalea(Australia) Pty Ltd Pollution Incident Response Management Plan

Transcription

1 Introduction The Protection of the Environment Legislation Amendment Act (POELA) 2011 requires the Environmental Protection Licence holder to prepare and implement a Pollution Incident Response Management Plan. Application This plan has been prepared by Rivalea (Australia) Pty Ltd to comply with its obligations under the POELA Act for Licence number 11393, RIVALEA AUSTRALIA- BUNGOWANNAH PIGGERY. Implementation Implementation of this plan addresses both systematic and incident procedures to be followed in order to prevent or minimize pollution incidents from occurring, limit their impact and respond appropriately when such incidents occur. Administration Administration for the implementing, maintenance, training of personnel and regular review is the responsibility of the General Manager Safety, Environment and Quality. Communication All enquiries should be directed to the General Manager Safety, Environment and Quality on (02) Rivalea Site: Bungowannah Piggery Address: Bungowannah Piggery Riverina Highway Bungowannah NSW 2640 Common Address: Bungowannah Piggery Riverina Highway Bungowannah NSW 2640 Locations Coordinates: 36 1'54.14"S '40.15"E EPA Licence Number: 11393

2 Site Plan

3 Flow chart of incident management Spill or discharge of polluting substance to the air, a waterway or land either within the site or onto neighbouring land SITE MANAGER GENERAL MANAGER ENVIRONMENT OFFICER MANAGING DIRECTOR Is the pollution incident likely to cause a threat to human health or safety? YES NO Activate Emergency Response Plan Evacuate affected area or site Advise at least one of the following people: GENERAL MANAGER ENVIRONMENTAL OFFICER MANAGING DIRECTOR Activate response team to mitigate further spills and clean up if safe to do so NO Will the pollution incident cause material harm to the environment? $10,000 damage including clean up costs? Log incident in The Vault Log incident in The Vault YES Advise EPA Immediately on Advise other relevant authorities as listed General Manager - Farming Kenton Shaw Manager Rivernian Contracting David Harrison Managing Director Paul Pattison General Manager Safety Environment, Quality Mark Hogan Environmental Officer (Technical) Ian Longfield Environmental Officer Hugh Erwin Site Manager Alan Spooner Environment Protection Authority (EPA) 24 Hour hotline to report pollution incidents

4 IMMEDIATELY INCIDENT TRIGGER ACTION TO TAKE WHO EMERGENCY INCIDENT Immediately call emergency services on 000 SITE MANAGER FIRE MEDICAL Nature of incident BUILDING PLANT Actual or potential injuries POLLUTION BOMB THREAT Actual or potential damage ASAP EVACUATION Evacuate affected area necessary Activate evacuation procedure Activate evacuation alarms / procedures Evacuate Site if necessary Account for staff and visitors to site at marshalling points ADVISE Site Managers General Manager Safety Manager or Officer Environment Manager or Officer POLLUTION INCIDENT If the incident involves actual or potential pollution ON OR OFFSITE, including SMOKE DUST CLOUD WATER EFFLUENT RAW PRODUCT CHEMICALS OR FUEL ANY OTHER POLLUTANT A General Manager with advice from the Environment Officer will decide if the incident is to be notified to EPA Notify the EPA hotline on If in doubt or unable to contact management or SEQ call the EPA hotline and discuss the incident with them. It is better to over report than not to report. The fine for not reporting a pollution incident immediately is $2 million REDUCE THE IMPACT Only If safe to do so: take action to limit further pollution. activate clean up If in doubt about safety, discuss with SEQ or combat authority REMAIN AVAILABLE Remain available to report to management, EPA and emergency services Follow instructions from combat authority LOG THE INCIDENT Log incident in The Vault via web portal including as much information about the incident EMERGENCY CONTROLLER / WARDENS EMERGENCY CONTROLLER GENERAL MANAGER, MANAGING DIRECTOR ENVIRONMENT MANAGER / OFFICER SITE MANAGER EMERGENCY CONTROLLER EMERGENCY CONTROLLER SITE MANAGER POST INCIDENT INVESTIGATE Workplace Manager and investigator to investigate cause of incident. Review incident and implementation of the REPORT Provide statutory reports Report to relevant mangers for action Follow up completed actions SAFETY OFFICER ENVIRONMENT OFFICER SAFETY OFFICER ENVIRONMENT OFFICER

5 Description and Likelihood of Hazards A review of the major environmental risks was undertaken for Bungowannah. This risk analysis is shown in Appendix 1. The risks were assessed according to the following criteria: Description and impact Likelihood Contributing circumstances that can increase the risk Routine preventative action Safety equipment Action to be taken in the event of an incident (refer to flow chart) Mechanism for providing early warnings to neighbours of a pollution incident of this nature

6 Incident Management Plan Standard Operating Procedure (SOP) Rivalea also have a Standard Operating Procedure (Incident Management SOP #16) which details procedures which defines the process for reporting and investigating all incidents attached as Appendix 2. Procedures for notifying the NSW Environment Protection Authority The manager in charge of the site will be designated as the principle coordinator for managing the response with the EPA. Manager in charge is defined as the most senior manager in charge of operational control at the time of the pollution incident and has authority to enact this plan. Key personnel identified in incident management Site Contact Details Position Name Business Hours Mobile A/H Manager- Dave Harrison (02) Riverina Contracting Site Manager Alan Spooner (02) Assistant Manager Peter McCormack (02) Supervisor David May Company Position Name Business Hours Mobile A/H Head Office (Corowa) Corowa Gatehouse (24hr) Managing Director Paul Pattison General Manager Mark Hogan Safety Environment, Quality Environmental Ian Longfield Officer (Technical) Environmental Hugh Erwin Officer Safety Manager Darren Forrester Safety Officer Troy Kennedy Safety Officer Vanessa Forrest External Agencies Position Name Business Hours Mobile A/H Environment 24 Hour hotline to report Protection Authority pollution incidents (EPA) Fire and Rescue NSW Emergencies. (Local Control Centre 24 Hrs. #)

7 NSW Ministry of Health (diverts to Albury Base Hospital)- ask for Public Health Officer on call, WorkCover NSW Greater Hume Shire Council NSW Police Business Hours Emergencies. Albury Station Procedure for advising occupant/s of neighbouring properties Advising residents or occupants of neighbouring properties will be accomplished by door knocking at the discretion of the combat authority or appropriate Rivalea manager. Areas for particular note are listed in the table below: Name Distance (meters) Direction Resident SW Resident SW Resident SW Resident S Resident SE Resident SE Resident SE Resident SE Resident SE Resident SE Resident SE Resident SE Resident W Resident SW Resident SW Resident SW Resident W Description Name Distance (meters) Direction Town Albury E Town Howlong NW Rural Church St. Mark s 2200 W Major watercourse Murray River 3000 S Watercourse Long Flat Creek 100 S Public Road Riverina Highway 1200 S Incident recording and review Rivalea s incident management procedure is documented in SOP #16 Appendix 2. The company maintains an incident management system called The Vault.

8 Inventory of potential pollutants A manifest including dangerous goods and all inventory at the site is attached as Appendix 3. Stormwater Plan Stormwater from the site is directed into drains on the east and west of the piggery where the stormwater eventually enters into Long Flat Creek. Any stormwater that that is captured by the effluent treatment lagoons passes through the system to the long-term storage lagoons where it is then able to evaporate. These dams are checked regularly to ensure their integrity and reliability. Training Training procedure All personnel in charge or who may be delegated site responsibility will be trained in implementing this plan. Training will be conducted annually at this site by the Environmental Officers. Training topics Location and accessibility of the plan Assessing the threat of harm from a pollution incident Integrity Emergency Response Plan Notifying the EPA of an incident Notifying other relevant authorities of the incident Deploying company resources to contain a pollution incident Mobile phones to be programmed with numbers Training records All training records will be kept in Preceda, Rivalea s training data base. Review of Pollution Incident Response Management Plan This plan will be reviewed annually by Rivalea s Safety, Environment and Quality group. The review dates and reminders are triggered in the Environment Monitoring reminders site on the company s intranet SharePoint system. The Plan and its implementation will be reviewed after any pollution or emergency events and updated where deficiencies are found.

9 Appendix 1- Hazard Identification and Risk Analysis Description The Risk Vehicle accident Fuel spill Chemical spill Fire, oil and fuel spill, offal, liquid feed, chemical spill. Pollution of surface water, fire. Contaminated soil. Pollution of surface water, contaminated soil, fire, What can happen? (Event) Fuel/chemical spill entering the stormwater system Damage to bowser and fill equipment. Mobile tank movement spill Chemical seepage into stormwater runoff. Contributing Circumstances Poor traffic management plan, weather conditions, mechanical failure, driver fatigue Vehicle collision with bowser. Operator error. Mobile tank accident. Poor storage, lack of training, vehicle accidents.cement base/bund not intact/correct size, movement and transport of chemicals, incorrect segregation (acids and alkalis) What can happen? (Circumstances) Potential spill into the stormwater system, fire and smoke may impact on residents, odour, cause other accidents, health risk of offal spill. Potential spill into the stormwater system, potential fire Potential spill into stormwater. Fire, explosion, toxic fumes. Operational controls Sealed roads, signage, traffic flows, hi viz clothing for onsite staff, speed limits, training, weighbridge Bollards around bowser. Oil and chemical storage room. Concrete floor, mesh and tin walls. All chemicals stored in these area. Emergency response plans, SOP's Probability Consequences Level of risk Possible Major 6 M Possible Minor 4 M Possible Major 6 M Ranking of risk

10 Work Instructions, Inspections. Fire Effluent offsite discharge Industrial gases Air and water pollution, toxic fumes from building materials, chemicals Surface water contamination. Discharge to atmosphere. Offsite discharge of chemical residue, smoke and ash, Contaminated water offsite Ammonia leak. Oxygen, CO2, lack of maintainance of fire fighting sytem. Poor maintenance of machinery, non adherence to hot work procedures, Total Fire Ban days, lack of training, Excessive rainfall, dam wall failure, pipe rupture, poor design Incorrect storage, fire, operator error, poor Environmental pollution, human harm, damage to plant and equipment (from fire and water used in the fire fighting) Lagoon storage overflow, discharge off site into stormwater Evacuation of processing and production Fire detection and suppression systems, fire extinguishers and regular inspection of the fire fighting system, Fire truck oniste, Fire water tank at abattoir, emergency management procedures, Storage designed to meet 90 percentile wet year, Inspections, Managed irrigation system, distance from water courses Large buffer area, detection Likely Critical 12 H Possible Minor 4 M Almost Certain Major 12 H

11 Odour emissions Persistent odour event Acetylene, LPG, Argon Breakdown in treatment system, plant, biological changes, prolonged power outage maintenance, training Chemical use impacting on biology of treatment lagoons. Power outage preventing flushing pumps from operating. Mechanical breakdown. Excessive buildup of solids reducing treatment efficiency, Unusually stable weather conditions. facilities, potential for human harm to site staff Odour emissions impacting on neighbours and community amenity devices, emergency response plans, testing of LPG tanks, maintenance agreements. Monitoring and inspections, buffer distances, maintenance. Standby generators available Almost Certain Minor 8 M

12 Appendix 2- SOP 16 Incident Management INCIDENT MANAGEMENT Written By: Safety Manager Approved By: General Manager SEQ 1 PURPOSE AND SCOPE This procedure defines the process for reporting and investigating all incidents, near misses and occupational illnesses, including how incident related immediate action, classification and corrective action are conducted effectively. All incidents involving employees, contractors and people arising from any activity involving any product or equipment at any workplace are required to be reported. 2 RESPONSIBILITIES AND OVERVIEW Unless otherwise specifically stated, the workplace manager ensures the tasks in this procedure are performed effectively for their area of responsibility. The workplace Manager is the person who has the day to day operational and decision making role in that work area.

13 3 DEFINITIONS Incident Emergency Near Miss Incident Serious accident Serious Near Miss incident Notifiable incident A system failure such as a fatality, injury, occupational illness, plant, equipment or environmental damage Any significant event threatening life, property or the environment. An epidemic, fire, explosion, chemical spill or natural disaster An event that could have caused an incident but did not. A system failure resulting in a fatality or injury or occupational illness resulting in hospitalisation for more than observation, or an environmental problem requiring significant clean up or evacuation. An event that could have resulted in a serious incident but did not. Incident required within the applicable regulations to be notified to the appropriate workplace authority within each jurisdiction 4 PROCEDURE 4.1 Employees at the scene of an incident must take appropriate action to help any injured person if safe to do so or activate the emergency response plan (ERP) in the event of an emergency 4.2 Employees must report the incident or emergency (a) (b) (c) (d) Employees directly involved must immediately notify the workplace manager who will inform the Safety Manager or Environmental Officer Safety Manager will determine whether the incident is reportable to the Work Cover Authority Environmental Officer will determine whether the incident is reportable to the EPA In conjunction with the people involved and/or witnesses, complete an incident report form using the online reporting system (The Vault) available on the home page of SharePoint. If an internet connection is unavailable, call the SEQ administrator who will arrange to log the details into the online reporting system. 4.3 Perform the required statutory reporting (a) (b) Before performing any statutory reporting contact the Safety Manager, who will after consultation with Rivalea corporate legal counsel, advise and provide the applicable state statutory reporting guidelines Report all incidents to the relevant state authorities as per the applicable statutory reporting guidelines including: Victorian Statutory Reporting Guidelines New South Wales Statutory Reporting Guidelines

14 South Australia Statutory Reporting Guidelines Queensland Statutory Reporting Guidelines 4.4 Investigate the incident or emergency (a) A cursory investigation of all incidents or emergencies to assessed the risk rating of each incident to determine one of the following ratings. High, Medium or Low risk. Using the drop down box within The Vault to register the rating (b) (c) (d) All incidents and emergencies rated as Medium or High require a full investigation. Nominate an investigator for any medium risk or an investigation team for any high risk incidents or emergencies. Document the details of the investigators on the incident reporting database The investigator conducts an investigation (incident investigation guidelines) to establish and report on the: contributing factors of the incident or emergency corrective action that will prevent recurrence (e) The investigator updates the incident report and the records of the investigation 4.5 Implement the corrective action When the investigator s report has been formally submitted: (a) (b) (c) (d) (e) take corrective action appropriate to the magnitude and severity of the incident or emergency send the corrective actions to those responsible for implementing them from The Vault monitor and report the progress with the corrective actions monthly in the OH&S committee meeting and via performance measurement those responsible for implementing the corrective actions close out their corrective actions in the Vault ensure the risk register in The Vault is updated to reflect the changes to the risk controls resulting from the incident investigation 4.6 Ensure employees are trained Provide training to: (a) (b) supervisors and managers for the online system of reporting incidents all employees for reporting work related, incidents or emergencies

15 (c) all those involved in investigations in the skills and techniques for required successful investigations. 4.7 External incident investigation (a) (b) Comply with any requests by authorities to undertake a full investigation The managing director ensures any investigations by authorities receive the full support of Rivalea and its employees. 4.8 Advise the relatives (a) (b) (c) For fatal accidents, ensure the police advise the immediate family If the incident is not fatal, advise the injured employees immediate family (via the police if they have been involved) or in person (with a trauma counsellor, as you deem necessary) Offer condolences and assistance to the immediate family and maintain contact to ensure they are aware of all the steps being taken 4.9 Trauma debriefing and counselling Contact the Health Manger and request appropriate trauma debriefing and counselling for all affected employees (where deemed necessary). 5 FORMS Risk registers Victoria statutory reporting Queensland Statutory Reporting NSW Statutory Reporting Incident Reporting Database Incident Investigation Guidelines SA Statutory Reporting

16 Appendix 3- Potential Pollutants Stored at the Site Potential Pollutant Description/use Quantity Quick Bayt Fly-bait 2kg Bromakil Rat-bait 15kg Raid Fly and insect killer 6x400g Citrolem Disinfectant 20L Laundry powder Cleaning 15kg Plus foam Concentrated detergent 25L Viraban Disinfectant 20kg Extreme black Disinfectant 2 x 25L Nu Quat Kleen Disinfectant 25L Lightning Hand Cleaner Hand cleaner 25L Tru Blue 11 spray Animal health 20L N-Dem Insecticidal lotion 20L Tail paint aerosol Animal marking 48x500mL Round-up Herbicide 20L Hammer weed killer Herbicide 1L Ally weed killer Herbicide 1kg Diesel Fuel 1000L Unleaded petrol Fuel 75L Elgas LPG Gas 100L Argoshield light gas Gas 3x23kg Effluent Solid and liquid effluent from the sheds

17 Storage of potential pollutants Chemical Storage