Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Kentgrove Retirement Village
Sewage Treatment Plant
Pollution Incident Response
Management Plan
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Version: 5.0
Page 1 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Executive Summary
The pollution incident response management plan (PIRMP) details the actions that will take
place should a pollution incident occur at the premises.
The PIRMP is to be read in conjunction with relevant safety documentation developed for the
site. This includes a listing of safety data sheets (SDS) and risk assessment for all chemicals
stored and used at the site.
Version control
Version
Change from previous
Date
0.1
initial
15 Aug
2012
1.0
Amended, document control
1 Sept
2012
2.0
Minor changes
18 Dec
2012
3.0
Minor changes
22 Apr
2014
4.0
Minor changes
26 Aug
2015
5.0
Addition of SCADA and minor
changes
24 May
2016
Comment
Management Plan Approval
This incident response management plan has been reviewed and approved by:
Name
Position
Date
Ted Richardson
Maintenance Manager Uniting
24 May 2016
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Page 2 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Contents
Executive Summary .............................................................................................................. 2
Background........................................................................................................................... 4
Updates incorporated into this edition ................................................................................... 4
Description and Likelihood of Hazards .................................................................................. 5
Pre-emptive actions to be taken ............................................................................................ 9
Inventory of Pollutants......................................................................................................... 10
Safety Equipment................................................................................................................ 11
Contact Details.................................................................................................................... 11
Agencies to Notify – Contact Details ................................................................................... 11
Communication with Neighbours and Local Community ...................................................... 12
Minimising Harm to Persons on the Premises ..................................................................... 12
Retirement Village Layout ................................................................................................... 13
Locality Map ........................................................................................................................ 14
Actions to be taken during or immediately after a pollution incident..................................... 15
Staff Training ...................................................................................................................... 15
Risk Assessment Matrix ...................................................................................................... 16
Annual Pollution Incident Response Exercise ..................................................................... 17
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Page 3 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Background
The regulatory requirements under the Protection of the Environment Operations Act require
the licensee possessing an Environment Protection Licence (EPL) to have a pollution
incident response management plan (PIRMP). The Kentgrove Retirement Village discharges
treated sewage from its sewage treatment plant to the waters of a branch of Blue Gum
Creek under the terms of EPL 2342.
Under the legislation, a pollution incident includes a leak, spill, escape or deposit of a
substance as a result of which pollution has occurred. Pollution can take the form of water
pollution (causing a change to the quality of waters); air pollution (emission of an air impurity
including odours, fumes, gases and mists); and land pollution (includes causing degradation
or harm or placing a substance onto land). Pollution within the boundaries of the site must be
reported and the management plan must address the risk of each of these forms of pollution
incident.
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 beings or to
ecosystems that is not 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 regulation) and
(b) loss includes the reasonable costs and expenses that would be incurred in taking all
reasonable and practicable measures to prevent, mitigate or make good harm to the
environment.
The types of pollution incident which are addressed in this plan are limited to those which
are part of normal site activities. For example odours from the treatment plant may be
detectable at residences within the retirement village from time to time. This is not
considered to be a pollution incident under the requirements.
Updates incorporated into this edition
This edition of the PIRMP includes a revision of the hazards and risks presented by the
following system changes:
 Installation of a SCADA system to provide 24 hour off-site monitoring of system


performance and to provide alarm notification to personnel involved with operation
and maintenance of the treatment plant.
The SCADA system incorporates a UPS and electrical surge protection.
Installation of an electrical surge protection system on the main treatment plant
electrical supply.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Description and Likelihood of Hazards
The main hazard to the environment arising from the operation of the treatment plant is the
potential for a discharge of partially treated sewage which may be discharged from the
treatment plant. The discharge would enter the adjoining downstream property which
contains an intermittent watercourse leading to the waters of Blue Gum Creek. Partially
treated sewage contains nutrients and biota which may impact aquatic life in Blue Gum
Creek.
There is a hazard to the environment arising from the rupture of the various site storage
tanks, pipe lines and spills from handling treatment chemicals in external areas. Details of all
site storage tanks and chemicals is given in this plan. The hazard of rainwater picking up
pollutants from the various storages and handling arrangements is addressed by storage of
some of the chemicals under cover as solids or the surface water management system
which ensures that all contaminated surface water is captured and remains onsite by the
sealed surfaces. As a result, these scenarios present a very low risk to the environment.
A hazard associated with the treatment plant to the environment arises from the potential for
odours to be released at a concentration which causes annoyance to neighbouring
residents. Given the close proximity of the treatment plant to residents of the retirement
village and the much greater distance to neighbouring residents, there is almost no likelihood
of odours reaching a level that is detectable by the latter residential neighbours.
There are other hazards arising from treatment plant operations which may be caused by
events outside the premises. The plant relies upon an external supply of electricity for its
operation. A loss of the electrical supply would simply interrupt operation of the control
system, aeration and pumping activities. No discharge of partially treated sewage is likely
because when the final discharge pump is turned “off” the maturation pond has
approximately 120kL of storage before an overflow would occur. In dry weather this amounts
to over 10 days storage.
Performance of the treatment plant is now monitored on a 24 hour basis. The new SCADA
system incorporates a UPS together with electrical surge protection. This means that alarm
signals will be sent when there is a loss of treatment plant operation including power
interruption.
Following an electrical storm, surge protection has also been installed on the main power
supply to the treatment plant. The surge protection system was installed to reduce the risk of
damage being caused to electrical equipment as a result of power surges including lightning
strikes.
A 20kL emergency storage tank on the site provides emergency storage of untreated
sewage from the wet well in the event that both wet well pumps fail or a loss of electrical
supply takes place for more than 8 hours.
Although the site is located in an area where there is a high risk of bushfire, a bushfire is not
likely to cause any changes to treatment plant activities unless the bushfire causes a loss of
electrical supply.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Pollution incident scenarios and the likelihood and consequences to the environment are
presented in the following table.
Pollution Incident Scenario
1. Rainfall event causes overflow of
maturation pond
2. Infiltration of roof water into
sewerage reticulation system causing
reduction in effective treatment of
sewage
3. Pond discharge pump fails to start
with overflow partially treated sewage
4. Pond discharge pump fails to stop
and exceed daily discharge volume
5. Loss of control of biological
wastewater treatment system due to
chemicals discharged into sewer by
residents of the village.
6. Development of bulking sludge in
the aeration tank. Exceedance of
licence limits for discharge.
7. UV disinfection unit fails to operate
– elevated coliforms in discharge
8. Aeration blower fails to operate due
to motor failure or belt failure –
elevated nutrient concentration in
discharge
9. Alum dosing pump fails to operate
– nutrient reduction reduced
10. Transfer pumps from wet well fail
to start due to float failure or pumps
both fail (note: two pump system with
high level alarm)
11. Rupture of liquid alum storage
tank – intercepted by concrete and
brick walls
12. Rupture of sludge storage tank –
intercepted by concrete and brick
walls
13. Computer control system failure –
detected by SCADA system and
alarm transmitted to personnel
14. Electrical supply system failure –
wet well pumps fail to operate + no
aeration + no discharge pump –
duration less than 12 hours
Detected by SCADA system and
alarm triggered to personnel
15. Aeration tank decant valve fail to
operate or manual butterfly valve
blocks discharge – aeration tank
overflows to maturation pond
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
Likelihood
Very Unlikely
Consequence
Minor
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Major
3
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Insignificant
6
Unlikely
Insignificant
6
Unlikely
Minor
5
Unlikely
Minor
5
Unlikely
Moderate
4
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Risk Ranking
6
Version: 5.0
Page 6 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Pollution Incident Scenario
Likelihood
16. High pressure drop in series sand
Unlikely
filters due to algal growth
17. Clogging of fabric filter due to
Unlikely
excessive algal growth in pond
18. Rupture of pipe work associated
Unlikely
with sand filters, UV system and
fabric filter
19. Loss of sewage or partially treated Very unlikely
sewage into groundwater due to leak
in underground pipe work or inground portion of tanks and
maturation pond
20. Spillage of treatment chemicals in
Unlikely
external areas of treatment plant
21. Release of odours causing
Very unlikely
annoyance to neighbouring residents
22. Loss of electrical supply
Unlikely
23. Bushfire in locality
Likely
24. Major rainfall event causes
Likely
exceedance of licence daily discharge
flow limit of 50kL
25. Power surge on electrical supply
Very unlikely
or lighting strike causes equipment
damage not blocked by surge
protection equipment
Consequence
Minor
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Risk Ranking
5
Insignificant
6
Insignificant
6
Major
4
Minor
5
Minor
6
Insignificant
Insignificant
Insignificant
6
5
5
Moderate
5
Discussion of operational factors to reduce the risk of the above scenarios:
1. The maturation pond acts to intercept any potential discharge of partially treated
sewage. The maturation pond is operated with a freeboard of at least 500mm which
means that an overflow discharge from the maturation pond due to a rain event is
extremely unlikely.
2. An intensive program to detect rainwater infiltration into the sewerage system has
resulted in infiltration now being negligible. The maturation pond provides a very
large surface for rainfall capture. An estimated 350L of rainfall is captured per mm of
rainfall. This has a major effect on daily discharge volumes when heavy rainfall
occurs.
3. Although there is only one final discharge pump, the maturation pond is operated
with at least 500mm freeboard which provides a buffer against an overflow between
plant inspections.
4. The suction line foot valve to the discharge pump is approximately 400mm below the
liquid level in the maturation pond. A faulty float valve on the discharge pump could
either cause the pond to overflow (if the pump fails to start) or would reduce the level
of treated effluent to 400mm below the normal level (if the pump fails to stop).
5. Residents of the village are advised that the treatment plant requires them not to
discharge strong chemicals into toilets.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
6. The UV system contains three bulbs and has an indicator light to show when all
bulbs are operating. The bulbs are changed after approximately 8,000 hours
operation. (Every 5 years.) The tubes are cleaned as required,
7. The system has indicator lights to show when aeration is taking place. Blower
operation is confirmed by the noise from the blower and visual inspection of the
effluent inside the aeration tank. The SCADA system records blower hours operation
each day. Failure to provide aeration is detectable by remote monitoring of DO levels
in the aeration tank via the SCADA system.
8. Operation of the alum dosing pump can be observed when aeration is taking place.
The dosing pump can also be tested by plugging it into a standard 240V outlet. A
spare dosing pump is kept on-site in the storage unit where the blowers are located.
9. Failure of the wet well transfer pumps causes sewage to back-up at toilets within the
Retirement Village. The SCADA system will send a high level alarm to operational
personnel. Complaints from residents ensure this is detected most likely within two
days. A 20kL emergency storage tank is available to storage of untreated sewage.
Transfer of raw sewage to the emergency storage tank would be arranged by pump
hire.
10. The sludge storage tank is located above the maturation pond and filtration media.
Rupture of the tank would be immediately apparent upon inspection. No off-site
discharge is likely to occur as existing concrete and brick walls would intercept the
liquid flow.
11. The alum storage tank is located above the maturation pond and filtration media.
Rupture of the tank would be immediately apparent upon inspection. No off-site
discharge is likely to occur as existing concrete and brick walls would intercept the
liquid flow.
12. Failure of the computer controller to the treatment plant would be detected as a
backup in sewage within toilets in the village. The SCADA system would send an
alarm signal to operation personnel.
13. Bulking sludge is evidenced by high SV30 and is caused by change in bacterial
population in the aeration tank which does not settle. Treatment to address this
situation includes making changes to aeration levels, lime dosing and adding liquid
chlorine (as hypochlorite) to the aeration tank.
14. Failure of the decant valve to open would cause the wet well pumps to stop
transferring raw sewage to the aeration tank. A high level in the wet well will cause
the SCADA system to send and alarm signal to operational personnel.
15. The two sand filters are operated in series in the discharge from the maturation pond.
The filters are individually back washed on a fortnightly basis or as required based
upon pressure reading under flow.
16. The final fabric filter was installed to assist with algae removal when conditions in the
maturation pond favour algal growth. It provides additional filtration of algae which
passes through the sand filters.
17. Rupture of tanks or product lines or spillages are all collected and captured by the
bunding and surface water management system. None of the contaminants from this
type of incident can escape on-site capture by the surface water system.
18. Leakage of underground sewerage systems is a recognised low risk scenario for all
sewerage systems.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
19. Spillage of chemicals in external areas of the treatment plant where chemicals are
transferred are captured within the boundary fence of the treatment plant due to its
layout and paving arrangement. There is no likely discharge off site.
20. Odours from the treatment plant are first detected by residents of the village before
they are of sufficient strength to be detected by neighbours (across Jones Road).
Hazards to human health arising from the treatment plant include the potential for the
release of odorous gasses on residents of the retirement village plus potential health impacts
on employees on the site. The risk of odours impacting the health of neighbours is
considered to be minor as past experience has shown odours to be only a source of
annoyance and not causing health impacts.
The other hazard to human health arising from the treatment plant is the potential for
impacts on humans entering or having primary or secondary contact with the waters of Blue
Gum Creek. There is also the possibility that the waters downstream of the discharge may
be used for irrigation of crops for human consumption. There are no known approved water
access licences in Blue Gum Creek catchment downstream of the site. Public access to the
downstream waters of Blue Gum Creek is precluded for over a kilometre as the stream is
located in private properties. By this time, the impact of any discharge of partially treated
sewage from the treatment plant is unlikely to be any different to that from other nutrient
sources within the catchment.
Pre-emptive actions to be taken
The above risk scenarios are reflected in the design, operation, monitoring and maintenance
of the treatment plant.
The computer controller includes alarm functions and logging of operating hours of certain
parameters as a means of detecting plant malfunction. A SCADA system provides 24 hour
monitoring of treatment plant operations. These can be monitored off-site. The SCADA
system includes alarms which are sent via text message to operational personnel.
The plant aeration cycle is controlled by a DO probe. The control system incorporates an
over-ride switch so that in the event of a failure of the DO probe, the aeration can be
operated using a timer system.
A twice weekly sampling and testing program is completed. This involves testing of the final
discharge and the decant discharge for a range of parameters. This program of testing was
specified by NSW Public Works.
Samples of treated sewage are submitted for analysis on a monthly basis as required under
the Environment Protection Licence (EPL). A sample is also submitted for analysis for the
level of dissolved phosphorus. This has been useful in optimising the performance of the
plant to lower the total phosphorus concentration.
Aeration tank operations are also monitored for SV30 to determine the level of sludge
development in the aeration tank. This is used to determine the need to operate/adjust the
operation of the sludge transfer pump which transfers settled sludge from the aeration tank
to the sludge storage tank.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Page 9 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Inventory of Pollutants
Liquid Pollutants
Pollutant
Liquid Alum
Storage Description
Black polyethlyene
vertical cylindrical
roofed tank
Raw sewage
In Ground Concrete
Wet Well
7kL
Partially treated
sewage
Part above and below
ground open circular
aerated sewage tank
88kL
Partially treated
sewage
In ground rectangular
open concrete-lined
maturation pond
360kL
Sludge
Above ground roofed
sludge storage tank
14kL
Cupricide
20L pail under roofed
enclosure
20L
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
Capacity of Storage
1.4kL
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Comments
A rupture of the tank
or leak from the dosing
system pipework
would be fully
contained on site by
the layout of the
structures.
A rupture of the tank
would be contained by
the surrounding earth.
A rupture of the tank
would be retained on
site by the raised wall
of the maturation pond
which is below the
tank.
A rupture of the
maturation pond would
be partly captured by
its in-gound
construction.
The contents of the
maturation pond can
discharge by overflow
or pump operation.
A rupture of the tank
or leak from the dosing
system pipework
would be fully
contained on site by
the layout of the
structures.
Used for algae control
in Maturation Pond to
supplement use of
chlorine.
Version: 5.0
Page 10 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Solid Pollutants
Description
Powdered hydrated lime
25kg bags
Powdered sodium carbonate
25kg bags
Solid Calcium hypochlorite
10kg pails 12 off or 120kg
screw lid containers
Storage Location
Stored in secure locked
garage
Stored in secure locked
garage
Stored in secure locked
garage
Comments
Up to 40 off 25kg bags at
any time
Up to 40 off 25kg bags at
any time
Powdered chlorine is kept on
site to control algae
development in the
maturation pond and to
control bulking sludge in the
aeration tank.
Safety Equipment
Safety equipment to be worn at the premises when required comprises the following items:





elbow length PVC gloves
Safety glasses for eye protection
Safety footwear – boots
Dust mask – P2
Safety Data Sheets (MSDS) for all products and chemicals stored on site.
Contact Details
Treatment plant operations supervision:
Les Johnston
Director, Environmental Performance Australia
0422 481 550
Responsible for initial response to an environmental incident including notification of
authorities
Treatment plant operations contract management: Alex Davies 0412268841
(including clean-up financial authorisation) Programmed Facility Management
Agencies to Notify – Contact Details
Agency
Environment Protection Authority
Baulkham Hills Council
Hornsby Public Health Unit
WorkCover
Fire and Rescue
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
Contact Phone Number
131 555
ph (02) 9843 0555
ph (02) 9477 9400 Fax (02)9482 1358
ph 131 050
000 (if not already notified)
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Communication with Neighbours and Local Community
The village retains a list of phone numbers of its residents. These are not published in this
document for reasons of confidentiality. In the event of an emergency, each of the immediate
residents would be contacted by phone or visited and details of the emergency will be
provided. Neighbours to the village will be contacted by personal visitation.
Minimising Harm to Persons on the Premises
The site has emergency evacuation procedures for the Kentgrove Village.
The emergency assembly point is located at the front of the Main Office.
An emergency shower and eye wash is provided.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Page 12 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Retirement Village Layout
Kenthurst Road
Retirement Village
Boundary (excludes
transformer yard)
Treatment Plant Entrance
Treatment Plant
Plant Discharge Point
Jones Road
Aerial Map NSW Department of Lands 2012
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Approver:…Ted Richardson
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Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Locality Map
Kentgrove Retirement Village
Locality Map NSW Department of Lands 2012
© Environmental Performance Australia Pty Ltd
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Approver:…Ted Richardson
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Page 14 of 17
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Actions to be taken during or immediately after a pollution incident
In the event of a pollution incident, contact must be made to the five authorities by the
Treatment Plant Operations Supervisor or their representative on the site. The contact is to
be made immediately after the pollution incident takes place.
The following response procedure must be followed when a pollution incident occurs:
Step 1: Person aware of or witnessing the incident or their supervisor is to assess harm to
people.
Step 2: If potential harm exists, organise exclusion of other site staff from area of potential
harm. The use of the evacuation siren may be required if a site evacuation is required.
Step 3: Stop spill if safe to do so.
Step 4: Advise supervisor of incident for them to contact the five authorities as outlined
above.
Step 5: Deploy containment systems.
Step 6: Obtain assistance from other site staff to clean up.
Step 7: Supervisor to arrange assistance from off-site clean up organisations.
Step 8: Supervisor to contact neighbouring residents if possible harm exists or provide list of
contact telephone numbers for use by emergency services personnel if they attend site.
Staff Training
There are three elements comprising the staff training associated with an environmental
incident response management at the site. These are: an initial site induction for all new
employees and contractors working at the site, a toolbox talk for persons involved with
environmental incident response at the site and an annual simulation exercise.
The initial site induction for personnel involved with the operation of the treatment plant
which is to be completed prior to commencement of working at the plant.
The toolbox talk for staff involved with pollution incident response consists of working
through this PIRMP.
Representative personnel involved with operation of the site must be part of an annual
exercise involving the simulation of a pollution incident at the site. Following the exercise, the
form below must be completed and kept in the Site File. Lessons learned are to be used to
revise this plan.
© Environmental Performance Australia Pty Ltd
Custodian:…Les Johnston…….
Approver:…Ted Richardson
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Page 15 of 17
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Risk Assessment Matrix
The following scenario likelihood and consequence is based upon the principles contained in Australian and New Zealand Standard AS/NZ
4360:2004 – Risk Management. The risk scores of 1, 2 or 3 are considered to represent a high risk category. Scores of this level necessitate
detailed assessment and planning to develop appropriate measures to mitigate the
risk. Scores of 4 or 5 are classed as a medium risk.
Scores of this level can be mitigated by relatively standard measures. A score of 6 is a low risk and requires little if any specific procedures to
address this level of risk.
Consequence:
CATASTROPHIC:
MAJOR:
MODERATE:
MINOR:
INSIGNIFICANT:
Major prosecution, long
term irreversible impacts
Environmental
fine
for
breach of legislation, or
notable
impacts
to
sensitive areas, potentially
irreversible
impacts,
extended duration.
Moderate
environmental
impact,
community
concern or complaints, or
duration of more than one
month, reversible impacts.
Minimal
environmental
impact
/
community
concern, or Short term
duration, reversible.
Minor
or
impacts
VERY LIKELY: almost certain
1
1
2
3
4
LIKELY: in most cases
1
2
3
4
5
UNLIKELY: might occur
2
3
4
5
6
VERY UNLIKELY to ever occur
3
4
5
6
6
Likelihood:
© Environmental Performance Australia Pty Ltd
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Approver:…Ted Richardson
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Page 16 of 17
negligible
Pollution Incident Response Management Plan
Kentgrove Retirement Village
Issue date:
24 May 2016
Review date:
24 May 2018 or before
Annual Pollution Incident Response Exercise
Date of exercise:
______________________________________
Persons present:
______________________________________
______________________________________
______________________________________
Results of exercise:
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
Lessons learned:
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
__________________________________________________
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Approver:…Ted Richardson
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Page 17 of 17