Contaminant spills - emergency response

Transcription

1 WQPN 10, February 2006 Contaminant spills - emergency response Purpose Many industrial chemicals and contaminated wastewaters pose a risk to the environment if inappropriately stored, handled or discharged. The use of a comprehensive emergency response plan can help lessen environmental impacts, minimise the cost and frequency of production downtime, aid site clean-up, reduce occupational health and safety incidents and enhance community attitudes. The plan should also help prevent accidental fluid spills, leaks, and emergencies that could pollute the atmosphere, groundwater, soil, wetlands or waterways. The Department of Water is responsible for managing and protecting the State s water resources. It is also a lead agency for water conservation and reuse. This note offers: the Department s current views on land development in drinking water source catchments; guidance on acceptable practices used to protect the quality of Western Australian water resources; and a basis for the development of a multi-agency guideline designed to balance the views of industry, government and the community, while sustaining a healthy environment. This note provides a general guide on issues of environmental concern, and offers potential solutions based on professional judgement and precedent. The recommendations made do not override any statutory obligation or Government policy statement. Alternative practical environmental solutions suited to local conditions may be considered. Regulatory agencies should not use the note s recommendations without a site-specific assessment of any project s environmental risks. Any conditions set should consider the values of the surrounding environment, the safeguards in place, and take a precautionary approach. This note shall not be used as the department s policy position on a specific matter, unless confirmed in writing. Scope This note applies to any chemical spillage or contaminated water that may pose a threat to water resources (including aquatic ecosystems and water supply sources), which may affect human health, amenity, environmental or economic values. Chemicals of particular focus are acids and alkalis, metal salts, nutrients, petroleum products, organic solvents, pesticides, surfactants, tainting substances (eg phenols), carcinogens and sewage. These contaminants include: those described in the current Schedules of the Poisons Act 1964; those listed in Schedule Classes 3 to 9 of the Explosive and Dangerous Goods Act 1961, Classification Order of 1988; and 1 of 13 pages Contaminant spills emergency response

2 any substance, if released into the environment at above background concentrations, presents or has the potential to present a harmful risk to human health, disrupt ecological processes, affect any environmental value, or impact on the aesthetic appeal of waters. This note recommends the preparation, maintenance and implementation of an effective Emergency Response Plan (ERP) by anyone who stores, transports, handles or uses chemicals or other substances that have the potential to contaminate water resources. Emergencies may arise as a result of equipment malfunctions, operating accidents, employee malpractice, fires, natural events (eg storms, earthquakes), and occasionally as result of civil disturbances and unauthorised site access by intruders. Sensitive water resources An ERP is particularly important near sensitive water resources. Water resources considered most sensitive to contamination are described in Appendix D. Within Public Drinking Water Source Areas (PDWSA), this Department uses source protection strategies that include three levels of priority classifications for management of catchment land. Management strategies differ for each priority classification. For more information, see our Water Quality Protection Note: Land use compatibility in Public Drinking Water Source Areas, available via the Internet (see Appendix A). Within proclaimed Waterways Management Areas, written approval from this Department is needed for any land use that may affect water quality or its amenity. For activities near wetlands or waterways with recognised conservation or social values, advice should also be sought via one of our regional offices. The Swan-Canning Cleanup Program, which supports the objectives of the Swan River Trust Act 1988, aims to protect the ecology and amenity of the Swan-Canning Estuary through monitoring of river health, reducing contaminant inputs and enhancing waterway protection. The cumulative effects of human activity puts pressure on the waterway quality, while an inadequate response following contaminant spills adds to these pressures. For more information, contact the Swan River Trust or visit Type of contaminant spill posing an environmental concern The risk that contaminants pose to water resource quality and values varies based on factors including: nature of the contaminant and its toxicity to living things; spill volume; timeliness and effectiveness of spill management measures; contaminant s persistence in the environment whether it will evaporate, be filtered out in soils, degrade on contact with soil micro-organisms, or move under the influence of gravity or rainfall to cause harm; location of the spill relative to sensitive receptors in the environment; mobility of the contaminant (including solubility, viscosity, adsorption to soil particles, and the influence of rainfall); 2 of 13 pages Contaminant spills emergency response

3 whether the contaminant will react with substances present in the environment and the subsequent outcome; and risk of downstream harm to living things from exposure to contaminant residue (ie the degree of toxicity ranging from mild discomfort through to death). This Department s objectives are to prevent, reduce and mitigate the entry of harmful contaminants into wetlands and waterways. Recommendations 1. A comprehensive ERP should be prepared, maintained and used by anyone handling, managing or using toxic or hazardous substances. It should be easy to read, logically formatted and provide sufficient detail. The ERP should establish any necessary links between site emergency response protocols and the State s emergency management structures and advisory committees such as the State Flood Warning Consultative Committee, the WESTPLAN-HAZMAT Coordinating Committee and the National Plan Western Australian State Committee for Combating Marine Oil Pollution. 2. Operational plans should ensure that the user is able to quickly and effectively respond in the event of a contaminant spill or other serious emergencies. The effectiveness of an emergency response system depends on the documentation of the response process, the availability of adequate resources and training of those responsible for its implementation. The plan should support the concepts of spill Prevention, Preparedness, Response and Recovery. These concepts are described in more detail in the following pages. 3. The ERP should be periodically reviewed (at least every five years) to ensure it remains up to date and effective. 4. The most important concern after making the site safe should be to contain then recover as much of the spilt chemical as practical prior to any escape of residues into the environment. The main ERP steps are described below. Prevention 5. The site operator should aim to eliminate or reduce the probability of an unplanned release of contaminants and reduce the degree of damage that could occur to the environment. In situations where a spill risk exists, the following management measures should be arranged: a. Use chemical alternatives. Where practical substitute a chemical that has a lower toxicity, mobility in the environment or persistence in toxic form. b. Store chemicals on hardstand flooring on safe racks or pallets in secure and weatherproof buildings. c. Place spill risk facilities away from sensitive environments with a sufficient buffer to allow for effective intervention prior to water pollution occurring. d. Use secondary spill control facilities such as bunded containment compounds. e. Avoid risk related activities at times when weather conditions may magnify any harm caused by a spill eg outdoor unloading during rainfall. 3 of 13 pages Contaminant spills emergency response

4 f. Where practical, ensure all drainage structures can be sealed to halt the passage of spilt fluids. g. Ensure all employees and contractors are trained on safe procedures and good environmental practice. Preparedness 6. An ERP is important for any organisation handling potentially polluting substances. An effective ERP means being well prepared for accidents and emergencies. It should include: a. An assessment of risk scenarios leading to spills and the probable impacts eg drums falling off pallets during forklift handling. b. Site incident response manuals, including the provision and maintenance of relevant Material Safety Data Sheets (MSDS) in locations accessible to incident management staff. c. Staff training in incident response protocols. d. Continuous availability of suitable equipment to protect workers and mitigate the effects of chemical spills. e. Installation and maintenance of warning and emergency contacts signage. All chemical containers should be labelled with the contents and supplier s safe use instructions. f. Plans for containment and disposal of contaminated fluids if there is a large spill or fire. Plans should be available for site drainage systems and where they discharge should be defined. Content of Emergency Response Plans (ERP) 7. The following details should be included in the ERP: a. Purpose of the plan State the aim, objectives, application and extent of the plan. b. A contaminant inventory This details the types and quantities of chemicals/contaminants stored or handled on-site. A MSDS for each chemical should be available. c. A site layout diagram This should show the location of contaminant storage and use points, emergency equipment (including fire control), access ways, escape paths and assembly points. d. Description of potential emergencies Determine what incidents are likely to occur and the associated possible impacts both on and off the site. Contaminant pathways to environmental receptors should be determined. Define the actions that may aggravate or limit the environmental impacts. Develop action plans for each scenario. Action plans should include both on-site and off-site mitigation measures such as working with Government agencies to block stormwater drains. e. Risk assessments These should be prepared by defining incident triggers, the probable frequency of a spill occurrence (eg once a year), the probable scale of an incident (eg a 200 litre spill), and the 4 of 13 pages Contaminant spills emergency response

5 impact thresholds i.e. the concentration of chemicals that may cause pollution (for more information see Appendix A, references 4a and 4c). Factors such as dilution, soil filtration and stormwater impact should be considered and applied in a conservative manner. Importantly there are considerable penalties under the Environmental Protection Act 1986 for unlawful discharges and pollution. f. Employee safety the prime concern Adequately trained and equipped staff should respond immediately to contaminant spills. All other staff, in response to an alarm, should evacuate the area to a designated safe zone or as directed by the agency that has taken charge of the emergency response such as the Fire and Emergency Services Authority. g. Allocate responsibility An Emergency Response Manager (ERM) should be appointed to implement the ERP. The roles of key support staff could be defined using a flow chart. Ensure all staff are effectively trained to carry out their assigned function. A 24-hour roster should be available so trained staff can respond at any time. h. Communications An effective round-the-clock communications system is essential. Individual action cards should be prepared for personnel with roles and responsibilities under the ERP. i. Backup resources Trained staff and equipment should always be available to deal with emergencies. Such equipment may include personal protective gear, monitoring equipment, absorbent litter or sand, fire-fighting equipment, access to earth-moving machinery and waste containment skips. Where necessary, stand-by contracts should be arranged and contacts defined for those expected to fulfil the emergency response role. j. Test emergency procedures The ERP should be periodically tested to ensure the organisation is prepared, and response procedures work in an adequate and timely manner. Changes to the ERP should be made if tests demonstrate procedures can be improved. Exercises can include desktop incident simulation, practice evacuations, communication system tests and team training. k. Notification of authorities Procedures for contacting emergency services, and regulatory agencies in the event of significant emergencies should be defined including who will contact the emergency services, under what conditions and the relevant all hours phone numbers. Examples of those to be contacted include: the Fire and Emergency Services Authority, police, ambulance, this Department s Response and Audit Branch or our nearest regional office in remote areas (see section Response to incidents or emergencies), water services authority and local government. l. Notification of neighbours A contact list of neighbours and the circumstances under which they need to be notified should be maintained. A cooperative approach can assist in an emergency response situation. 5 of 13 pages Contaminant spills emergency response

6 m. Evacuation In situations where people s health or well-being may be at risk, a procedure should be prepared describing who, when, where, and how people will be evacuated and accounted for and how the evacuation protocol applies. Periodic evacuation drills are recommended. n. Incident Investigation Staff should report both actual incidents and near misses to the designated ERM. An incident review should follow to assess and correct any procedural defects discovered during the emergency (see section Emergency response review). o. Media interest Effective media communication (press, radio, television and Internet) can be a key element both in implementing the ERP for major incidents and dealing with community interest during and after the incident. Adequate attention should be given to this issue prior to an incident occurring so the site operator is seen to be an honest, competent, caring and valued member of the community. Response to incidents or emergencies 8. The type of response will depend on the nature and amount of substances discharged, the environmental values (water users and ecosystems) present in the surrounding area and the risk of transmittal of the hazard to a receptor. Emergency response can be managed using a three-tier Impact Classification system (described below) based on a risk assessment of the potential severity of environmental impact. 9. The following three-tier Impact Classification (high, moderate and low) is aimed at indicating the severity of the incident, so that appropriate resources can be deployed in response to the emergency. a. High Impact Incident. This applies to any one or more of the following situations: There is a significant and immediate threat to human life or property. Located within any proclaimed Public Drinking Water Source Area, including Underground Water Pollution Control Areas, declared Catchment Areas and Water Reserves. Could result in significant or immediate harm to native fauna and flora. Observable harm has occurred to environmental receptors eg fish deaths. Located within water catchments that have recognised conservation or scientific values. The incident has the potential to persistently contaminate soil or water resources. b. Moderate Impact Incident. This applies to any one or more of the following situations: There is a significant (but not immediate) threat to human life, amenity or property. 6 of 13 pages Contaminant spills emergency response

7 Located outside any proclaimed Public Drinking Water Source Area, but within close proximity to private water supply sources. Chronic or long-term harm to native fauna and flora may result. Long-term (but not immediate) observable impact may occur to environmental receptors. c. Low Impact Incident. This applies to any one or more of the following situations: No perceived threat to human life or property. Located outside sensitive environments eg areas with recognised water resource values. Poses no immediate or long-term threat to environmental receptors. 10. Recommended minimum response is listed in Table 1. Table 1 - Emergency response classifications Incident a impact class Time to start clean up Notify authorities b Review ERP Environmental monitoring needed High Immediate Immediate Yes Yes Moderate Immediate As soon as possible (within 24 hours) Low c Immediate Via periodic report No No Table 1 explanatory notes: Yes Dependent on the effectiveness of the clean-up a. This table is generic and site-specific variations may apply based on contaminant toxicity, its fate/ travel time in the environment and/or the sensitivity of downstream environmental receptors. b. In the event of a spill where contaminants may be discharged into the environment causing pollution or environmental harm, please contact the Department of Environment s Response and Audit Branch (contact details are listed at Appendix C). c. For very small spills of paints, fuels, lubricants, or hydraulic oils (i.e. less than ten litres) no recovery action from soils (after the spill site is made safe) could be an acceptable response provided the spill is more than fifty metres from any surface waterbody and groundwater depth exceeds five metres. Support when combating spill incidents 11. In the event of a contaminant spill that may harm the environment (including water resources) use the contacts provided in Appendix C: a. In Perth region: advise the Department of Environment s Response and Audit Branch phone ; 7 of 13 pages Contaminant spills emergency response

8 b. In Country areas: advise our nearest regional office, go to this Department s internet site and select Contact us, use the local phone book or contact our Perth office for the appropriate phone number; and c. In Public Drinking Water Source Areas: advise the Water Corporation. 12. The Department of Environment records information received on significant contaminant spills on its Incidents and Complaints Management System (ICMS). The Department s duty Incident Response Officer (IRO) will assess the nature and scale of the incident and the vulnerability of the receiving environment then decide if an officer should visit the incident site. The aim of an inspection would be to further assess the environmental hazards and provide advice to the site incident response manager on appropriate action. 13. Immediate environmental risks should be removed and a follow-up audit of the clean up may be required. Personnel from either the Department of Environment s Response and Audit Branch or an appropriate regional office may undertake this visit. 14. The IRO may need to liaise with specialty groups within agencies as follows: Issue or location Agency Branch Phone (business hours) Water resources data Department of Resource Information Water Branch Public Drinking Water Source Areas Water Source Protection Branch Wetlands and Waterways Department of Catchment Management Environment Branch Waste disposal Waste Management Branch Contaminated site management Land and Water Quality Branch Unlawful activities Legal Services Swan-Canning Estuary at risk: Swan River Trust Emergency response review 15. After a significant incident or near miss, an internal review of the effectiveness of the ERP and a risk assessment of the workplace should occur. These reviews help to determine how similar emergencies can be avoided and subsequently improve the effectiveness of the ERP. Following an incident, necessary changes should be made to improve the ERP, response personnel training updated and validation exercises undertaken. This is all aimed at avoiding or minimising the impact of future incidents. Typical questions that should be asked during the review are: a. What can be learned from what has happened? b. How do we avoid repeating mistakes? c. How do we assess what is and is not working? d. What are the implications not only on site operations, but also on the whole business or industry? e. Are ERP and response program revisions needed? f. How do these questions get answered? 8 of 13 pages Contaminant spills emergency response

9 Additional detail is available at the following United States Internet web pages: More information We welcome your views on this note. Feedback provided on this topic is held on our file This note will be updated periodically as new information is received or industry/activity standards change. Updates are placed on the Department s web page then select Water Quality Protection Notes. To comment on this note or for more information, please contact the Water Source Protection Branch, phone (08) (business hours), fax (08) or use Contact us at the Department s Internet site, citing the note topic and version. The State Government in October 2005 announced the formation of the Department of Water. From January 2006, the Department of Water has assumed primary responsibility for managing the State s water resources. Once the Department of Water is legally established, it will replace many of the present functions of the present Water and Rivers Commission and operate in parallel (with separate powers) to the Department of Environment. The custodian and recommendations made in this note will then change to match the assigned responsibilities of the departments of Environment or Water. Swan Canning Cleanup Program Telephone: (08) Facsimile: (08) Floor 4, The Atrium 168 St Georges Terrace Perth Western Australia Telephone: (08) Facsimile: (08) Floor 4, The Atrium 168 St Georges Terrace Perth Western Australia Telephone: (08) Facsimile: (08) Level 1, Hyatt complex 20 Terrace Rd East Perth Western Australia 6004 Appendices Appendix A References and further reading 1. National Environmental Protection Council National Environmental Protection (Assessment of Site Contamination) Measure 1999, see Internet site 2. Australian Department of Environment and Heritage National Chemical Information Gateway, see web page 3. Standards Australia a. AS 2444 Portable fire extinguishers and fire blankets - selection and location. b. AS/NZ Std Water Quality Sampling Guidelines; 9 of 13 pages Contaminant spills emergency response

10 c. AS/NZ Std Guide to sampling and investigation of potentially contaminated sites management. d. A/NZ Std Risk management. see web page 4. Australian Government - National Water Quality Management Strategy guideline series: a. Australian and New Zealand Guidelines for Fresh and Marine Water Quality, b. Australian and New Zealand Guidelines for Water Quality Monitoring and Reporting, 2000 see Internet site c. Australian Drinking Water Guidelines, 2004, see Internet site d. Implementation guidelines, To obtain a copy, send an to [email protected], or request one from your local library service. 5. National Occupational Health and Safety Commission National Standard (NOHSC: 1015) Storage and handling of Workplace Dangerous Goods, 2001, see Internet site 6. Department of Consumer and Employment Protection (WA) Guidelines for the Preparation of an Emergency Plan, S310, see internet site then select Resources Safety> Dangerous Goods> Guidance material and publications > Dangerous Goods Storage. 7. Department of Environment (WA) a. Environmental Management Systems Guidebook Steps in Emergency Response 1999; see web page b. Contaminated site assessment: Reporting of known or suspected contaminated sites; Site classification scheme; Assessment levels for soils, sediment and water; Development of sampling and analysis programs; The use of risk assessment in contaminated site assessment; see web page then select Publications>Guidelines. 8. Department of Water (WA) a. Water Quality Protection Notes: Land Use Compatibility in Public Drinking Water Source Areas; Contamination investigations in sensitive environments; see web page then select Water Quality Protection Notes of 13 pages Contaminant spills emergency response

11 b. Perth Groundwater Atlas, see Internet site then select Water information>perth Groundwater Atlas. 9. Swan River Trust Control Measures to reduce sewage overflows into the Swan and Canning Rivers 1997, see Internet site and select Resources and publications. Appendix B Statutory requirements and approvals covering this activity include: What is regulated Statute Regulatory agency Development approval Town Planning and Development Act 1928 Local government (council) Department for Planning and Infrastructure Impact on the values and ecology of natural waters Regulation of prescribed premises Unauthorised discharges Licence to discharge waters into managed waterways Industrial sites in public drinking water source areas Discharges affecting the Swan-Canning Estuary Storage of fuels, solvent, explosive and dangerous goods Emergency response planning Management of human wastes, community health issues Discharge to sewer (industrial waste permit) or to main drain Environmental Protection Act 1986 Part IV Environmental Impact Assessment Environmental Protection Act 1986 Part V Environmental Regulation Environmental Protection (Unauthorised Discharges) Regulations 2004 Waterways Conservation Act 1976 Metropolitan Water Supply Sewerage and Drainage Act 1909 Country Areas Water Supply Act 1947 Swan River Trust Act 1988 Explosives and Dangerous Goods (EDG) Act 1961 EDG Regulations 1992 Fire and Emergency Services Authority of WA Act 1998 Health Act 1911 Metropolitan Water Supply Sewerage and Drainage Act 1909 Country Towns Sewerage Act 1947 Minister for the Environment advised by the EPA Department of Environment regional office Department of Water regional office Swan River Trust Department of Consumer and Employment Protection Fire and Emergency Services Authority Local Government; Department of Health Water Corporation or other designated water services provider 11 of 13 pages Contaminant spills emergency response

12 Appendix C Emergency contact details (all hours) Contact Phone numbers (all hours) Life or property emergencies (ambulance, fire or police) 000 Chemical analyses Chemistry Centre (WA) Environmental incidents/emergencies Response and Audit Branch, Department of Environment Explosive and Dangerous Goods Branch, Department of Consumer and Employment Protection Fire and Emergency Services Authority Police (non life-threatening incidents) Poisons Information Centre State Emergency Service Swan River Trust (Swan and Canning rivers only) Water Corporation (water supply catchment pollution emergencies) Contacts for specific issues (business hours) Issue Agency Contact group Contact details Environmental health, waste management and disposal Local government authority (council or shire office) Environmental Health Section Storage, transport and use and of hazardous chemicals Pollution prevention Sampling, preservation and analyses of water samples Swan-Canning Cleanup Program Department of Consumer and Employment Protection Department of Environment Chemistry centre (Department of Industry and Resources) Swan River Trust Dangerous Goods Safety Branch Perth head office or a local regional office Emergency response or Environmental chemistry Swan Canning Clean-up Program See local phone directory - white pages or visit Ph: or visit Ph: or visit Ph: Fax: or visit Ph: or visit Sewer connection Water Corporation Customer Services Ph: or visit APPENDIX D - Sensitive water resources Clean water resources, used for drinking water, sustaining aquatic and terrestrial ecology, industry and aesthetic values, along with breathable air, rank as the most fundamental and important needs for viable communities. These water resources should remain within specific quality limits, and therefore require stringent and conservative protection measures. Guidance on water quality parameters necessary to maintain water values are published in the National Water Quality Management Strategy Guidelines (see internet site then select Inland Waters>Water Quality) 12 of 13 pages Contaminant spills emergency response

13 The Department of Water strives to improve community awareness of catchment protection measures for surface water and groundwater aquifers as essential elements in a multi-barrier protection approach to maintain the quality of water resources and their values. To be considered sensitive, water resources must support one or more of the environmental values described below. Any activity or a land use will pose a risk to water quality if contaminants are able to be washed or leached into sensitive water resources in discernible quantities. These water resources may be shallow groundwater accessed by water supply wells, surface waterways, estuaries, or wetlands. Community support for these values, setting of management objectives for water resources and implementation of a practical attainment strategy are seen as key elements in protecting and restoring the values of these water resources. Sensitive water resources include: a. Those proclaimed or assigned as Public Drinking Water Source Areas (ie Water Reserves, Catchment Areas or Underground Water Pollution Control Areas) via the Metropolitan Water Supply, Sewerage and Drainage Act 1909, the Country Areas Water supply Act 1947 or the Health Act b. Those used as private drinking water supply sources (ie for human or stock consumption). c. Waters with specific quality necessary to support commercial or industrial activities eg aquaculture, food processing or crop irrigation. d. Wetlands and waterways pristine or conservation-valued, (not highly disturbed, unless subject to active management to restore historic environmental values), and detailed as follows: policy areas covering water resources defined via Part III of the Environmental Protection Act 1986 eg Environmental Protection (Swan Coastal Plain Lakes) Policy 1992; waterways managed under the Waterways Conservation Act 1976, ie the Avon, Peel- Harvey, Leschenault, Wilson Inlet and Albany Waterways Management Areas; the Swan-Canning Estuary and adjoining lands administered via the Swan River Trust Act 1988; wetlands of regional, national and international importance, including but not limited to Conservation category wetlands (CCW) and Resource Enhancement category wetlands (REW), Environmental Protection (Swan Coastal Plain Lakes) Policy 1992, and wetlands listed within A Directory of Important Wetlands in Australia (see the Australian Department of Environment and Heritage Internet site which also provides information on Ramsar convention sites): and groundwater aquifers that sustain important ecological functions. e. Locations where surface water or water drawn from the ground water table may be consumed or inhaled affecting people s health or well-being, eg garden, recreation facility or irrigation sources. f. Surface waterbodies and wetlands meeting recognised cultural or social needs, eg water resources used for community swimming, fishing or valued for their visual appeal. Where a conflict arises between this Department s recommendations and any proposed activity that may affect a sensitive water resource, this note may be used to assist negotiations with stakeholders. The negotiated outcome should not result in a greater risk to water quality than if the Department s recommended protection measures were used of 13 pages Contaminant spills emergency response