EPA PRIMP Pollution Incident Response Management Plan

Transcription

1 EPA PRIMP Pollution Incident Response Management Plan QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 1

2 AMENDMENT REGISTER Version Number Page Numbers Subject Date QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 2

3 Table of Contents Amendment Register 2 1. Introduction Background Definition of Pollution Incident.4 3. Description of likelihood 4 4. Pre-emptive action.5 5. Inventory of Pollutants Contact Details Notification of external parties Communication with Neighbours and the local community Minimising harm to persons on the premises Actions to be taken during or immediately after a pollution incident Details of natural water flow (including Map) Pictorial of lay out New flow map to control run off from Neighbouring properties Lay out of new ponds Lay out of storm water flow and location of potential pollutants on the premises Training Availability of the PIRMP Testing of the PIRMP Reference Annual review Incident response activity report Form Incident Investigation and Analysis Form Recommended Corrective Actions Form 3 16 Mock Forms...17 QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 3

4 Commitment Management at Manildra Meat Company are fully committed to the protection of all its employees, staff, business partners, traders and the environmental and surroundings. 1. Introduction This Pollution Incident Response Management Plan (PIRMP) covers key actions: to minimise occurrence of pollution incident and manage a pollution incident if one occurs Background Manildra Meat Company is located approximately 3km to the north west of the township of Cootamundra. Manildra Meat Company is a slaughter processing plant of beef and sheep for the production of meat and meat by-products. 2. Definition of pollution Incident A pollution incident is an incident or set of circumstances during or as a consequence of which there is or is likelyto be a leek, 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 a set of circumstances in which a substance has been placed or disposed of on premises, but does not include an incident or set of circumstances involving only the emission of any noise. 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: (a) Harm to the environment is material if: (i) It involves actual or potential harm to the health or safety of human beingsor to ecosystems that is 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 include the reasonable cost and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigation or make good harm to the environment. 3. Description of likelihood Potential pollution incidents identified include Air Pollution Incident: Escape of significant smell or smoke, control smell and smoke reduction activity through new plant and equipment design for the reduction. Water Pollution Incident: Escape of water off site into a tributary to a larger body of watere.g. The Muttama creek, control: earthworks program and the pollution reduction program being implemented in 2012 in consultation with EPA the preparation and implementation of a wastewater management plan of the abattoir. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 4

5 Chemical Pollution Incident: All chemicals are stored under shelter and in case of spillage a capture area of a greater volume is facilitated for the retention of the spillage through portable bunding and this one function is monitored on a weekly basis through the Quality Assurance System and overseen by the Company Environmental Officer appointed. Control measures as described above have been implemented for sustainable operation of the company and its activities these greatly reducing the likelihood of an incident. Likelihood of these incidents occurring is very low due to purpose built control facility in place. 4. Pre-emptive actions to be taken: In an event of a fuel spill on site from a vehicle the company has a spill containment kit located in the workshop. All chemical storage vessels are stored in a manner that reduces the likelihood of rupture causing spill and protecting surrounding environment. Fire containment water tank has been installed and is fitted with a fire pumping system that is serviced monthly by an outside contractor. 5. Inventory of pollutants: Fuels Max Quantity MSDS Provided Diesel 1500 ltrs ULP 500 ltrs Hydraulic oil 205 ltrs Lubricants Max Quantity MSDS Provided Gear Oil 615 ltrs Gasses Max Quantity MSDS Provided Natural Gas Oxy & Acetylene Pipped in Up to 2 sets Safety equipment used to control and location Safety equipment used to control and location Safety equipment used to control and location Cleaning Chemicals Max Quantity MSDS Provided Diverclean C3 Up to 150 ltrs yes Yes HP powder clean Up to 30 kg yes Yes Surefoam Up to 250 ltrs yes Yes Spectrum Up to 250 ltrs yes Yes Sodium Hypochlorite Up to 250 ltrs yes Yes Nu White Up to 250 ltrs yes Yes Safety equipment used to control and location QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 5

6 6. Contact Details: In an event of an emergency, spill or an event that has the potential to contaminate the environment, people, property the below table must be contacted. Name Position 24hrs Work Number Len Jones Director John O Loughlin Operations Manager Bill Scott Business Manager Steve Johnson Finance Control David Large Production Manager Peter Nolan QA Manager Notification of external parties: Appropriate Relevant Authorities (ARA) The following table outlines the contact details and correct sequence for notification in the event of a notifiable pollution incident. After the company management have been notified the relevant authorities must be notified in the sequence in the table below. 1 Emergency services ( if dealing with an emergency) Police Fire Ambulance 2 EPA Environmental Line Hospital Work Cover Rescue If an emergency Communicating with neighbours and the local community: Once determination of incident has been established by the available management team (called The Incident Control). The Incident Control Team are responsible for the communication with authorities, neighbours and community providing early warning and updates to owners and occupiers of premises who may be affected. Property Owner Location Direction from this site Phone Numbers Estate of Mr K & Mr L Derrick West (02) Mr Peter McClintock East (02) QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 6

7 9. Minimising harm to persons on the premises: All staff and contractors are inducted before commencement of any works on site. The induction covers procedures for minimising the chance of a pollution incident occurring. Minimising the impact of an incident to persons must be given the highest priority. In the event that a pollution incident requires the evacuation of the site, actions will be completed in accordance with the site evacuation procedure. This is covered at the point of induction and can be found in the Manildra Meat Company Pty Ltd induction manual. 10. Actions to be taken during or immediately after a pollution incident. Scope Outline actions or prompt a clear process of thought for instructions to reduce or control any pollution incident. Evacuation needs to be considered if harm can come to those in the area. Early warnings At the time of discovery of an incident it is essential the company Environmental Officer and management team is contacted. The contact details are listed in Contact Details of this document section 6. Control Measures, in an event of pollution an assessment of the situation must be carried out for the correct course of action to be taken, for example, this may involve quick thinking and deployment of the spill kit to eliminate or reduce any damage to the environment, persons or property. Licensees are required to report pollution incidents IMMEDIATELY (without delay)to theappropriate Relevant Authorities (ARA). See section 7. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 7

8 11. Details of natural water flow. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 8

9 12. Pictorial of lay out. North This photo was taken in August and works have been conducted since. Photo will be updated after the Slaughter Floor roof is on and the location of water tanks is agreed on. This photo is to be read in conjunction with the following map in section 13, outlining the water flow for the improvements in catchment. Manildra Meat Company QA Department: QA Documents\EPA\Pollution Incident Response Management Plan EST 87 Page 9

10 13. New flow map to control run off from neighbouring properties. Manildra Meat Company QA Department: QA Documents\EPA\Pollution Incident Response Management Plan EST 87 Page 10

11 Layout of new ponds. Arrows (white) show new flow of treated water into the holding reservoirs and black lines indicate general direction of irrigation lines. The 2 diagrams 1 & 2 represent the new dams constructed for flow control. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 11

12 15. Layout of storm water flow and location of potential pollutants on the premises. The nearest water way from the production site is approximately 800 meters to the east. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 12

13 16. Training Requirements of the PIRMP will be outlined in the site induction for all new employees and contractors. A toolbox talk outlining the key components of the PIRMP will be presented to all existing staff. The objective of this training will be to ensure all staff and contractors are aware of the key steps to manage and or report through the correct channels a pollution incident. Maintenance staff will be trained in areas of concern to that area e.g. fuel spill, gas leak, byproduct spillage and is overseen by the Maintenance Manager. Records will be maintained.and kept in the Training Department. 17. Availability of the PIRMP A copy of the PIRMP (electronic and hard copy) will be kept at the premises. Manildra Meat Company will provide a copy on request to an Authorised Officer. 18. Testing Of PIRMP The PIRMP will be tested routinely at least once a year. The testing of the plan will be carried out in such a manner to ensure the plan is capable of being implemented in a workable and effective manner. The testing will use two methods, desktop simulation and practical exercise or drills covering all components of the plan, including the effectiveness of training. The testing will be recorded and recommendations made for improvement, as part of a continuous improvement process. 19. References Environmental Protection Authority 2012, Guideline for the Preparationof Pollution Incident Response Management Plan. 20. Annual Review In addition to the testing of the PIRMP a desk audit will be conducted against the updated requirement found at, QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 13

14 21. Incident Report Form INCIDENT REPORT AND DETAIL FORM Time reported : Emergency services required If applicable tick one Date: Police Fire Medical Circle one EPA notified? Yes No Hospital notified? Yes No Work cover notified? Yes No Rescue required? Yes No Personal Injury Plant Damage Environmental Issue Date of the incident: Location of Incident: Reported by: Name: Occupation: Date: Reported to: Name: Occupation: Date: Person involved and brief Description of Incident: Name: Occupation: Date: Other person involved or witness: Equipment involved: Name: Occupation: Date: Name: Occupation: Date: Name: Occupation: Date: Immediate Corrective Action Taken: Sketch of Incident Scene: include all relevant information. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 14

15 INCIDENT REPORT AND DETAIL FORM Investigation Team: Leader: Signature: Date: Leader: Signature: Date: Leader: Signature: Date: Attachments: Photo Witness Statement Incident Brief Tick one Other Detailed Description of incident including the sequence of events leading up to the incident. CONTRIBUTING FACTORS Did this factor (or its inadequacy/failure) contribute to the incident? PEOPLE PLANT SURROUNDS PROCEDURE/PROCESS 1. Communication 7. Abnormal Operation 12. Hazard Identification 2. Drugs or Alcohol 8. Guards and Barriers 13. Job Safety 3. Rushing 9. Maintenance 14. Permits 4. Slip/Lapse 10. Materials and Tools 15. Procedures 5. Fatigue 11. PPE 16. Housekeeping 6. Training 17. Workplace Conditions 18. Other Tick the appropriate Box or Boxes. Descriptions of Contributing Factor (please write corresponding number in the box, and then provide reasoning) ROOT CAUSE What system could we improve to reduce the likelihood of this type of incident? QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 15

16 INCIDENT REPORT AND DETAIL FORM Corrective Action: Action: Name of person who initiated Action: What time Action was taken: Description: Entered into pulse action required system Name: Description: Entered into pulse action required system Name: Description: Entered into pulse action required system Name: Description: RECOMMENDED LONG TREM CORRECTIVE ACTION Reference Number: Reference Number: Reference Number: KEY ISSUES FROM THIS INCIDENT THAT SHOULD BE SHARED WITH OTHERS Include information like was it shared with staff and a brief description on how it was shared SIGN OFF Name Signature Date Supervisor Shift supervisor QA Manager Work Health and Safety Officer Plant Manager QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 16

17 Form 1 INCIDENT REPORT AND DETAIL FORM Time Reported Date : Emergency Services Required Police Fire Medical If Applicable Tick One Circle One EPA Notified? Yes No Hospital Notified? Yes No Work Cover Notified? Yes No Rescue Required? Yes No X X x Personal Injury Plant Damage X Environmental Issue Date of Incident : Location of Incident : Fuel Storage Shed Reported by : Name: J.Bloggs Occupation: Driver Date: Reported to : Name: M.Shonk Occupation: Supervisor Date: Person involved and Brief Name: J.Bloggs Occupation: Driver Date: Description of Incident : Other Persons involved or Witnesses : Equipment Involved : Immediate Corrective Action Taken : Fuel Spill Name: H.Ford Occupation: Labourer Name: Occupation: Name: Occupation: Diesel Fuel Pump and Diesel Fuel Tank Utilise Emergency Fuel Spill Kit Sketch of Incident Scene: Include all relevant information. Fuel/Oil Storage Shed Diesel Tank and Pump Fuel Spill area. Truck Nozzle fell out of the fuel tank on the truck. The driver attempted to stop the flow getting covered in diesel fuel in the process. The witness used the Emergency Fuel Spill Kit to prevent excessive fuel contamination of the surrounding area. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 17

18 Form 2 INCIDENT INVESTIGATION & ANALYSIS Investigation Team: Leader: F.Kruger Signature: Date: Leader: J.Einstien Signature: Date: Leader: S.Weaver Signature: Date: Attachments: Photos Witness Statement Incident Brief Other Detailed Description of Incident including the Sequence of Events leading up to the Incident. Truck driver was refuelling the truck and walked off, the fuel nozzle fell out and was not observed by the truck Driver. A passing witness alerted the driver to the fuel spill. In his hast to stop the spill the driver was soaked in diesel fuel resulting in the need for medical attention. The witness quickly enabled the Emergency Fuel Spill Kit which reduced the environmental damage caused by the Spilt fuel. CONTRIBUTING FACTORS-did this factor (or its inadequacy/failure) contribute to the incident? PEOPLE PLANT SURROUNDS PROCEDURE/PROCESS 1. Communication. X 10. Abnormal Operation. 15. Hazard Identification. 2. Drugs or Alcohol. 11. Guards and Barriers. 16. Job Safety Analysis. X 3. Fatigue. 12. Maintenance. 17. Permits. X 4. Rushing. 13. Materials or Tools. X 18. Procedures. 5. Slip / Lapse. 14. PPE. 19. Housekeeping. 6. Training, Skills. 20. Workplace Conditions. Tick Appropriate Box/es. 21. Other.. Description of Contributing Factor (Please write corresponding number in the box, then provide reasoning.) Driver fatigue due to late nights 3 4 Rushing to stop fuel spill 10. Abnormal operation- the fuel nozzle should not have been left unattended. 18. Caused through not following correct company procedures. ROOT CAUSE What SYSTEM could we improve to reduce the likelihood of this type of incident? Retraining with emphasis on correct procedures to be implemented, safety stop valve to be fitted to fuel delivery nozzle and an emergency stop switch to be installed. QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 18

19 Form 3 RECOMMENDED CORRECTIVE ACTIONS Corrective Action: Action: Emergency Fuel Spill Kit enabled. By Who? J.Bloggs By When? Immediate action. Description: The Emergency Fuel Spill Response Kit was utilised to prevent further spillage of fuel and any Spreading of fuel contaminants to the surrounding area. Entered into pulse action required system by; (name) : (reference number) Corrective Action: Action: By Who? By When? Description: Entered into pulse action required system by; (name) : (reference number) Corrective Action: Action: By Who? By When? Description: Entered into pulse action required system by; (name) : (reference number) Corrective Action: Action: By Who? By When? Description: Entered into pulse action required system by; (name) : (reference number) Corrective Action: Action: By Who? By When? Description: Entered into pulse action required system by; (name) : (reference number) RECOMMENDED LONGER TERM CORRECTIVE ACTION Description: Fitting of emergency stop valves and emergency stop switches are to be installed along with a Dead Mans Switch to the fuel delivery system. KEY ISSUES from this incident that should be shared with others: Was this shared with other shifts/staff/rooms? No Yes Describe how it was shared: SIGN OFF Name: Signature: Date: Supervisor: X X X Shift Supervisor: X X X QA Manager: X X X WHS Department: X X X Plant Manager: X X X QA Department: QA Documents\EPA\Pollution Incident Response Management Plan Page 19

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