Rooty Hill Regional Distribution Centre (RDC) CONSTRUCTION WASTE MANAGEMENT PLAN

Transcription

1 Rooty Hill Regional Distribution Centre (RDC) CONSTRUCTION WASTE MANAGEMENT PLAN Final (Version 0) September 2011

2 Contents 1. Introduction Background Purpose of this Plan 1 2. Legislative and Regulatory Compliance Relevant Legislation Guidelines and Standards 4 3. Environmental Aspects, Impacts and Risks Waste Minimisation Hierarchy Environmental Aspects Major Waste Streams Classification of waste streams Environmental Risk Assessment Environmental Control Measures and Procedures Training Inspections, Monitoring, Auditing and Reporting Inspections and Monitoring Auditing Review and Improvement of the CWMP Environmental Management Review Continual Improvement 18 Appendix A Waste Management Register 19 Sinclair Knight Merz Construction Waste Management Plan

3 Document history and status Revision Date issued Reviewed by Approved by Date approved Revision type Draft 23/06/11 J. Ball L. Montesin 24/06/11 Practice review Initial Draft 24/06/11 R Savage L. Montesin 24/06/11 Initial Client Review Final Draft V1 29/06/11 L Montesin L Montesin 29/06/11 Issued for Tender Final Draft V2 04/07/11 L Montesin L Montesin 04/07/11 Incorporate Holcim comments Final (Version 0) 12/09/11 L Montesin L Montesin 12/09/11 Final Distribution of copies Revision Copy no Quantity Issued to Initial Draft Via 1 R Savage Final Draft V1 Via 1 Issued for Tender Final Draft V2 Via 1 R Savage Final (Version 0) Via 1 R Savage Printed: 19 September 2011 Last saved: File name: Author: Project manager: Name of organisation: Name of project: Name of document: 19 September :48 AM I:\ENVR\Projects\EN02872\Technical\Rooty Hill RDC\Construction Environmental Management Plans\Waste Management Plan\EN _Waste Management Lisa Montesin Lisa Montesin Holcim Rooty Hill Regional Distribution Centre Construction Waste Management Plan Document version: Final (Version 0) Project number: EN Sinclair Knight Merz Construction Waste Management Plan i

4 1 Introduction 1.1 Background The Rooty Hill Regional Distribution Centre (RDC) located at Kellogg Road, Rooty Hill within the Blacktown Local Government Area (LGA) will allow Holcim to receive construction material by rail from quarries located outside of the Sydney Basin, blend the materials to meet customer specifications and distribute these by road to the Sydney market. The construction materials received will include single size crushed aggregate, blended crushed aggregates and natural/manufactured sand, typically used for the manufacture of concrete and asphalt as well as a variety of other uses in the civil and construction industries. Holcim currently supplies the bulk of these materials through the Penrith Lakes Development Corporation (PLDC), however the resource at this site is nearly depleted and the facility will wind down to closure by mid The site is 15 hectares and is bound by the Main Western Railway Line to the south, the Nurragingy Reserve to the East, the OneSteel Mini Mill and other industrial developments to the west and industrial land to the North. Angus Creek, a tributary of the Eastern Creek, flows through the southern portion of the site. The site was chosen due to the unique access opportunities that include rail (Main Western Railway) and road (M7 Motorway). Once operational, the Rooty Hill RDC will operate 24 hours a day, seven (7) days a week and will be capable of handling up to four (4) million tonnes per annum of product. The main elements of the Project are listed below: Regional office building and quarry and concrete testing laboratory. Rail sidings of 1,100 metres in length with aggregate unloading facility located in the middle of the siding. On ground Concrete Storage Bins and Load out facility. Radial stacker as a contingency mechanism to allow trains to be unloaded and returned to the rail system if there is a malfunction with the operation of the main storage system, or if materials at the unloading station are contaminated. Blending plant/pug mill to mix road base with cement or lime and water at a capacity of 400 tonnes per hour. Conveyor system, linking the unloading station to the storage and truck loading facilities. Workshop, stores, site offices, truck wash down, truck refuelling, weighbridges, paving and parking. A 200,000m 3 per annum capacity concrete batching plant. A road/conveyor bridge over Angus Creek to link the northern and southern sections of the site. 1.2 Purpose of this Plan The purpose of this CWMP is to assess, and where possible reduce, the amount of waste produced during the construction phase of the Project. This plan will assess how the waste will be dealt with in the most environmentally sustainable way. The CWMP contains the following information: Relevant legislation and guidelines for waste management of the Project. Sinclair Knight Merz Construction Waste Management Plan 1

5 The systems, procedures and initiatives proposed to address the management of waste materials generated during the construction phase of the Project. Safeguards, mitigation measures and monitoring to manage waste impacts during construction. Roles and responsibilities of those involved in the design and implementation of waste management controls. An effective monitoring, auditing and reporting framework to assess the effectiveness of the controls implemented. This Construction Waste Management Plan (CWMP) is a sub plan to the Construction Environment Management Plan (CEMP) and forms part of the overall Construction Environmental Management System (EMS) for the Project. Sinclair Knight Merz Construction Waste Management Plan 2

6 2 Legislative and Regulatory Compliance 2.1 Relevant Legislation Key environmental legislation relating to waste management includes the following: Waste Avoidance and Resource Recovery Act 2001 (WARR Act). Contaminated Land Management Act 1997 (CLM Act). Protection of the Environmental Operations Act 1997 (POEO Act). Protection of the Environment Operations (Waste) Regulation Commonwealth Hazardous Wastes (Regulation of Exports and Imports) Act Environmentally Hazardous Chemicals Act Minister s Conditions of Approval Approval of this Project was granted by the Department of Planning in 2006 (Application No. 05_0051), with a modification to the Project approved in Minister s Conditions of Approval (MCoA) were issued for the approval and modification and those conditions relevant to construction waste have been incorporated in this Plan and are detailed in Table 2-1. Table 2-1 Minister s Conditions of Approval McoA 2.36 Requirement The Proponent shall not cause, permit or allow any waste generated outside the site to be received at the site for storage, treatment, processing, reprocessing or disposal or any waste generated by the project to be disposed of at the site, except as expressly permitted by a licence under the Protection of the Environment Operations Act Note: The above condition only applies to the storage, treatment, processing, reprocessing or disposal of waste at the premises if it requires an environment protection licence under the Protection of the Environment Operations Act Document Reference This document 1.1. Statement of Commitments This plan considers the requirements in the Statement of Commitments (SoC) from the Environmental Assessment (including Submissions Report and revised Statement of Commitments). The commitments relevant to the management of waste are summarised in Table 2 2. Table 2-1 Statement of Commitments SoC Commitment The EMP will address the waste for both construction and operation of the proposed ROC. Safe waste disposal practices of materials such as concrete slurry, sewerage, cleared vegetation and garbage, will be applied. Waste management on site will be in accordance with Blacktown City Council Site Waste Management Plan for the RDC. Waste management on site will include the following controls: Inform all contractors and sub-contractors working on the site prior to the Document Reference This document Section 4 Sections 3 and 4 Section 4 Sinclair Knight Merz Construction Waste Management Plan 3

7 SoC Commitment commencement of work, of their responsibility to reduce waste where possible; All personnel will receive instructions on what waste materials can be recycled and where the appropriate bins/hoppers are located; Fit secure lids to binds for food waste to prevent scavenging from birds and animals; and Conduct regular litter patrols to ensure litter is effectively controlled on site. Document Reference 2.3 Guidelines and Standards Key guidelines and standards relevant to management of waste for this project are detailed in Table 2 3: Table 2-3 Statement of Commitments Document Name Blacktown City Council Site Waste Management Plan Waste Classification Guidelines 2008 NSW Government s Waste Reduction and Purchasing Policy (WRAPP) Description Requires the waste streams to be monitored and volumes and end-receivers to be recorded. Guidelines on current waste management legislation specifying classification of waste and management of waste. This policy is designed to promote ecologically sustainable development within all NSW State Government Agencies. The aim is to reduce the amount of waste to landfill by encouraging the more efficient use of scarce natural resources. It requires all State agencies to develop a Waste Reduction and Purchasing Plan to demonstrate procedures to minismise waste generation in four areas (paper products, office equipment and components, vegetation and construction and demolition material). The policy also requires priority to be given to purchasing items with recycled content and the recycling of certain wastes. Sinclair Knight Merz Construction Waste Management Plan 4

8 3 Environmental Aspects, Impacts and Risks 3.1 Waste Minimisation Hierarchy The Waste Avoidance and Resource Recovery Act 2001 (WARR Act) and the Protection of the Environmental Operations Act 1997 (POEO Act) govern the issues of waste generation, reuse, recycling, transport and disposal and establish a waste minimisation hierarchy (Figure 3 1) that prioritises waste solutions, according to how successfully they conserve natural resources. The first priority is given to reducing the overall amount of waste, followed by the reuse and then recycling of any wastes that are unavoidably created, with disposal as a last resort. The aim is to extract the maximum practical benefits from the products and to manage waste in the best possible way. Figure 3-1 Waste Minimisation Hierarchy Avoid: Waste avoidance by reducing the quantity of waste being generated. This is the simplest and most cost effective way to minimise waste. It is the most preferred option in the Waste Management Hierarchy and is therefore ranked first. Reuse: Reuse occurs when a product is used again for the same or similar use with no reprocessing. Reusing a product more than once in its original form reduces the waste generated and the energy consumed, which would have been required to recycle. Recycle and Reprocess: Recycling involves the processing waste into a similar non waste product consuming less energy than production from raw materials. Recycling spares the environment from further degradation, saves landfill space and saves resources. Dispose: Removing waste from worksites, compounds and offices and dumping in a licensed landfill site, or other appropriately licensed facility. Sinclair Knight Merz Construction Waste Management Plan 5

9 3.2 Environmental Aspects Major Waste Streams The environmental aspects are those operations that may result in an environmental impact. Numerous waste streams would be produced during the construction of the Project, these are summarised in Table 3 1 and include potential reuse options for each. 3.3 Classification of waste streams Classifying wastes into groups that pose similar risks to the environment and human health facilitates their management and appropriate disposal. Six waste classes are used: Special waste Liquid waste Hazardous waste Restricted solid waste General solid waste (putrescible) General solid waste (non putrescible). Where waste cannot be avoided, reused or recycled it will be classified and appropriately disposed of. The classification of waste is based on the Waste Classification Guidelines (OEH 2008). The guideline outlines how to assess waste, waste classification and sets out management options for the disposal of classified waste. Waste classification will involve one or more of the following steps, as also shown in Figure 3 2: 1) Establish if the waste should be classified as special waste. 2) If not special waste, establish whether the waste should be classified as liquid waste. 3) If not special waste or liquid waste, establish whether the waste is of a type that has already been classified. To simplify the classification process, the OEH (Environment Protection Authority (EPA) Branch) has pre classified a number of commonly generated wastes. 4) If the waste is not special waste, liquid waste or pre classified, establish if it has certain hazardous characteristics and can therefore be classified as hazardous waste. 5) If the waste does not possess hazardous characteristics, it needs to be chemically assessed to determine what class of waste it is. If the waste is not chemically assessed, you must manage the waste as if it were hazardous waste. 6) If the waste is chemically assessed as general solid waste, a further test is available to determine whether the waste is putrescible or non putrescible. This test determines whether the waste is capable of significant biological transformation. If you do not wish to undertake this test, you must manage the waste as if it were general solid waste (putrescibles). Sinclair Knight Merz Construction Waste Management Plan 6

10 Table 3-1: Proposed Waste Reuse, Recycling and Disposal Arrangements Further information on the responsibilities for the waste management including segregation, reuse, recycling and disposal and classification is provided in Section 4. Key Waste Stream Segregation Areas / Containers Reuse / Recycling / Disposal Method Waste Type (from OEH Guidelines) Suggest Receiving Facility Waste Separation On site Topsoil Weed-free and suitable for reuse on site or off site Stockpile areas Where possible, reserve land for topsoil stockpiling for duration of Project for use in landscaping. Inert On-site For further details on weed management refer Vegetation Management Plan Spoil from excavations - suitable for reuse on site or off site (based on engineering suitability and waste classification, i.e. VENM) Stockpile areas Beneficial reuse on site Based on Contamination Investigation Report findings On-site Other spoil from earthworks Trucks Used on site for landscaping / earth-bunding Contaminated Soils Trucks Off site disposal at approved facility Based on Contamination Assessment Findings Based on Contamination Assessment Findings On-Site To be determined Paper / Cardboard / Plastic Glass / bottles / cans Suitably sized bins (minimise no. of truck movements) Suitably sized bins (minimise no. of truck movements) Off site recycling Inert Chullora Waste & Recycling Centre Off site recycling Inert Chullora Waste & Recycling Centre Sinclair Knight Merz Construction Waste Management Plan 7

11 Table 3-1: Proposed Waste Reuse, Recycling and Disposal Arrangements Further information on the responsibilities for the waste management including segregation, reuse, recycling and disposal and classification is provided in Section 4. Key Waste Stream Segregation Areas / Containers Reuse / Recycling / Disposal Method Waste Type (from OEH Guidelines) Suggest Receiving Facility Cleared vegetation / green waste Compactors Chip and Reuse on site Green Waste On-Site or M. Collins and Sons (02) Concrete Products Suitably sized bins (minimise no. of truck movements). Maximise quantity recycled by return of excess to the concrete plant Crushed and reused as backfill or as road base for site access / used for site levelling or stabilisation / sent off site. Inert Metropolitan Recycling (02) Timber (formwork) Suitably sized bins (minimise no. of truck movements) Reuse on site where possible / off site recycling Inert Rockdale Waste & Recycling Centre Steel (reinforcement) Suitably sized bins (minimise no. of truck movements) Off site recycling Inert Tak Son Recycling (02) Veolia NSW Construction Waste Recovery (02) Asphalt Suitably sized bins (minimise no. of truck movements) Reused for road base during construction or off site recycling Inert Metropolitan Recycling (02) Hydrocarbons (oils / grease) Sealed drums / containers, bunded area Off site recycling Non-aqueous liquid waste Trans Pacific Nationwide Oil (02) Sinclair Knight Merz Construction Waste Management Plan 8

12 Table 3-1: Proposed Waste Reuse, Recycling and Disposal Arrangements Further information on the responsibilities for the waste management including segregation, reuse, recycling and disposal and classification is provided in Section 4. Key Waste Stream Segregation Areas / Containers Reuse / Recycling / Disposal Method Waste Type (from OEH Guidelines) Suggest Receiving Facility Paints / solvents Sealed drums / containers, bunded area Off site disposal at approved facility Non-aqueous liquid waste Chullora Waste & Recycling Centre General Solid Waste Suitably sized bins (minimise no. of truck movements) Off site disposal at approved facility Solid Chullora Waste & Recycling Centre Chemical wastes Suitably sized bins (minimise no. of truck movements) lined with heavy duty plastic and covered Off site disposal at approved facility Various depending on type of chemicals Chullora Waste & Recycling Centre Printer Cartridges Suitably sized bins (minimise no. of truck movements) Off site recycling Hazardous Chullora Waste & Recycling Centre Sanitary wastes n/a Sewer is available / remove from site for licensed disposal prior to connecting to sewer n/a n/a Sinclair Knight Merz Construction Waste Management Plan 9

13 Assess and classify the waste according to the OEH Waste Guidelines Step 1: Is the waste special waste? Special Waste Asbestos Refer to POEO Act Waste Regulation Part 4, Management of Special Waste Step 2: Is it Liquid Waste? Non spadable, 60 deg C Non Trackable Recycled dru ms, refer to POEO Waste Regulations Schedule 1 Trackable Exceeds DG Thresholds, Sydney Water Limits. Refer to POEO Act Waste Regulations Schedule 4 Part 1 & 3 Step 3: Is it Pre classified? Pre classified VENM, Hazardous Wastes, Restricted Wastes, General Waste & Putrescible & Non putrescible. Step 4: Contains Hazardous Chemicals? Meets Dangerous Goods Classification for classes 1.2, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1 and 8. Step 5: Chemical Assessment? TCLP and SCC testing required. Step 6: Is it Putrescible? Putrescible test required. Figure 3-2 Waste Classification Flowchart Sinclair Knight Merz Construction Waste Management Plan 10

14 3.4 Environmental Risk Assessment A risk assessment has been undertaken in accordance with Holcim s Safety, Health & Environmental Guideline 3.1 Risk Management risk to identify the level of risk that Stage 1 and Stage 2 construction activities may present to waste management. The results of this risk assessment are provided in Appendix D of the CEMP. The following points summarise the key activities identified in the risk assessment relevant to waste management for Stage 1 and Stage 2 construction works. Littler (e.g. food waste, packaging) from site amenities reaching local waterways. Leakage of toner cartridges. Leakage of effluent from site amenities. Excessive use of water resources. Excess packaging material deliveries increasing waste generated Inappropriate disposal of excavated material. Inappropriate disposal of waste items which may be hazardous. Fuel and oil spills during plant and equipment maintenance and the associated disposal of contaminated material. Disposal of concrete washout from concreting activities. Disposal of green waste (including weeds). The location and storage of waste on site prior to disposal. Sinclair Knight Merz Construction Waste Management Plan 11

15 4 Environmental Control Measures and Procedures The following environmental control measures and safeguards will be implemented in order to minimise waste generated during with construction of the Project. Table 4 1 includes a reference number and the relevant phase and timing for each control measure and safeguard. The table also divides the Project site into four distinct management zones so control measure and safeguard can be targeted to a particular area within the Project site, provides a source and/or reference for each control measure and safeguard and the respective responsibility for implementation. Table 4-1 Environmental Control Measures and Safeguards for the Management of Waste. Phase Location No. Control Measures and Safeguards Design/ Planning Site Preparation Construction Timing Angus Creek Corridor Zone Southern Zone Northern Zone Office and Laboratory Zone Responsibility WM1 WM2 WM3 WM4 WM5 Waste management and minimisation will form part of the induction program (which includes environmental due diligence training). All Project and site personnel will be trained in the requirements of this document including minimising wastes, recognising which types of materials are recyclable and their obligations to use recycling facilities provided on site. Specific locations for waste management (e.g. sorting area locations, recycling bin locations, material stockpile locations) will be established on site Waste management areas will be adequately managed to prevent sediment runoff and dust generation. Construction Method Statements (CMS) will include practices to minimise waste generation and to maximise recycling and reuse of materials including spoil, concrete, oils, greases, lubricants, timber, glass, cleared vegetation and metal and will be reviewed by the EO prior to the commencement of works (Hold Point). Packaging minimisation and reuse initiatives will be implemented as part of the procurement. Prior to starting on site / Ongoing EO / Contractor Ongoing EO / Contractor Ongoing Contractor Prior to start of construction and ongoing Contractor Ongoing Contractor Sinclair Knight Merz Construction Waste Management Plan 12

16 Phase Location No. Control Measures and Safeguards Design/ Planning Site Preparation Construction Timing Angus Creek Corridor Zone Southern Zone Northern Zone Office and Laboratory Zone Responsibility WM6 WM7 WM8 WM9 WM10 WM11 Segregated waste disposal containers for the collection and recycling/disposal of all waste streams generated during the construction works will be provided onsite. Waste disposal containers will have clear signage and instructions for use to avoid cross-contamination. No rubbish shall be disposed of on site. Waste will be disposed to an appropriate licensed facility. A Waste Management Register of all waste collected for disposal and / recycling, including amounts, data and time and details and location of disposal will be maintained at all times(appendix A) Prior to disposal of non-recyclable liquid and non-liquid waste, it will be classified based on the Waste Classification Guidelines (OEH 2008). Note, classification may take 1-2weeks depending on analysis required. All waste being transported off site must be covered. The transportation must be appropriately licensed to carry that material. Recycled materials will be considered for use in concrete, roadbase, asphalt and other construction materials Ensure that waste is not mixed with spoil. Spoil unsuitable for onsite will be used in landscaping where practical. Ongoing Contractor At all times Contractor At all times Contractor At all times Contractor Ongoing Contractor Ongoing Contractor WM12 Toilets will be serviced regularly. Ongoing Contractor WM13 The site will be cleaned of any litter Ongoing EO / Contractor WM14 Topsoil will be stockpiled and reused for landscaping Ongoing Contractor WM15 Stored stockpiles will be protected from water and wind erosion by using appropriate erosion controls such as spreading with weed-free hydro seed or by covering with a geotextile fabric. This treatment will be used on any pile that will be in place for a period Ongoing Contractor Sinclair Knight Merz Construction Waste Management Plan 13

17 Phase Location No. Control Measures and Safeguards Design/ Planning Site Preparation Construction Timing Angus Creek Corridor Zone Southern Zone Northern Zone Office and Laboratory Zone Responsibility WM16 WM17 WM18 longer than 4 weeks. Storage of all hazardous substances and dangerous goods will be in accordance with MSDS requirements in a bunded area. Solid and hazardous wastes will be contained and separated from inert waste. Any hazardous waste (e.g. asbestos) will be managed and handled by an appropriately licensed contractor and transported for disposal to a OEH(EPA) approved site Any material contaminated by spills i.e. fuel, oil, lubricants etc, including empty fuel, oil and chemical containers, will be stored in a sealed secure container within a bunded area and will be transported to a waste disposal site approved by the OEH to accept such material. Ongoing Contractor Ongoing Contractor Ongoing Contractor WM19 Incompatible wastes will not be mixed. Ongoing Contractor WM20 Storage areas would be located away from waterways and the stormwater system. Ongoing Contractor WM21 Biodegradable products will be used wherever practicable. Ongoing EO / Contractor WM22 WM23 WM24 Regular collection of wastes will ensure air emissions are at a satisfactory level. Inappropriate waste and wastewater management systems will be regularly inspected and audited. Designated concrete washout areas will be provided and used. Washout on site will be minimised where ever possible. Responsible for ensuring this Plan is implemented by site staff. Undertake and assess data from inspections, monitoring and reporting and provide project-wide advice to ensure consistent approach and outcomes are achieved. Ongoing EO / Contractor Ongoing Contractor Ongoing EO WM25 Fit secure lids to binds for food waste to prevent scavenging from birds and animals Ongoing Contractor Sinclair Knight Merz Construction Waste Management Plan 14

18 Phase Location No. Control Measures and Safeguards Design/ Planning Site Preparation Construction Timing Angus Creek Corridor Zone Southern Zone Northern Zone Office and Laboratory Zone Responsibility WM26 Conduct regular litter patrols to ensure litter is effectively controlled on site. Ongoing Contractor Sinclair Knight Merz Construction Waste Management Plan 15

19 5 Training All employees, contractors and utility staff working on site will undergo site induction training (which includes environmental due diligence training) and environmental training in relation to waste management issues. The induction will address: This management plan. Relevant legislation. Waste minimisation. Waste recognition and recycling. Available recycling facilities. Energy and water minimisation measures. Records would be kept of all personnel undertaking the site induction and training, including the contents of the training, date and name of trainer/s. Key staff will undertake more comprehensive training relevant to their position and/or responsibility. This training may be provided as toolbox training or specific training tailored by the EO. Further details regarding the content of staff induction and training are outlined in the CEMP. Sinclair Knight Merz Construction Waste Management Plan 16

20 6 Inspections, Monitoring, Auditing and Reporting 6.1 Inspections and Monitoring Regular monitoring will be undertaken to track waste management on site. This will be through a series of formal and informal inspections at regular intervals. Table 6-1 Inspections and Monitoring Activity Resources Responsibility Frequency Daily Site inspections (work area) Weekly Environmental Inspection Waste removal activities off site Site Diary Environmental Site Inspection Checklist Monthly Register for Waste Materials (Appendix A) Contractor EO Contractor Daily Issues recorded in Site Diary (by exception) Weekly Monthly 6.2 Reporting A quarterly report will be produced by the EO to summarise all monitoring results. This report will be reviewed by the ER and the PM. 6.3 Auditing Audits (both internal and external) would be undertaken to assess the effectiveness of environmental controls and compliance with this plan, MCoA and other relevant guidelines. Any audit of this plan would be part of an overall audit of the Construction Environmental Management System (EMS). The following elements may be included in the audit of the overall CEMP: Compliance with statutory obligations. Compliance with Holcim environmental standards, guidelines, specifications and contract conditions. Compliance with the CEMP and sub plan. Adequacy of monitoring and operational reports. Completion of environmental actions. Adequacy of environmental training records. Adequacy of environmental records, checklists and document management systems. Preparation of environmental reports. Recording and completion of corrective actions following environmental incidents and complaints. Achievement of environmental performance objectives. Implementation of actions from previous audits. A schedule for internal audits providing frequencies and responsibilities is provided as part of the CEMP. Any audit of this plan will be as part of an overall construction environmental management systems audit. Sinclair Knight Merz Construction Waste Management Plan 17

21 7 Review and Improvement of the CWMP 7.1 Environmental Management Review The effectiveness and proper implementation of the CWMP will be reviewed by Holcim every twelve months or sooner as necessary. Review will be undertaken by the management team. The review will comprise: Reviewing the results of audits. Evaluation of the system, which improvements and corrective actions will be sought. Evaluation of the operation of the CWMP. 7.2 Continual Improvement Continual improvement of the CWMP will be achieved by the continual evaluation of environmental management performance against environmental policies, objectives and targets for the purpose of identifying opportunities for improvement. The continual improvement process will: At least annually: Review the adequacy of this plan. Consider any recent developments in practices and technology to ensure Best Management ideals are followed to minimise waste generation and maximise reuse and recycling. At least quarterly: Review monitoring results and identify areas of opportunity for improvement of environmental management which leads to improved environmental performance. At least monthly (or as incidents / non conformances occur): Determine the root cause or causes of non conformances and deficiencies. Develop and implement a plan of corrective and preventative action to address non conformances and deficiencies. Verify the effectiveness of the corrective and preventative actions. Outcomes of these reviews shall be documented and retained for the duration of the project. Sinclair Knight Merz Construction Waste Management Plan 18

22 Appendix A Waste Management Register Sinclair Knight Merz Construction Waste Management Plan 19

23 Waste ID No. Date/ Time Waste Classification (inert, solid or hazardous) Description of Waste (e.g. concrete, asphalt, vegetation) Waste Management Register Amount/ Volume Treatment Method (can it be recycled/ re-used) Mode of transport Receival Facility Signature/ Receipt No. Sinclair Knight Merz Construction Waste Management Plan 20