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 UNCONTROLLED COPY WHEN PRINTED 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 4 of 17 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 5 of 17 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 UNCONTROLLED COPY WHEN PRINTED 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 7 of 17 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 8 of 17 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 UNCONTROLLED COPY WHEN PRINTED 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) UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 11 of 17 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 © Environmental Performance Australia Pty Ltd Custodian:…Les Johnston……. Approver:…Ted Richardson UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 13 of 17 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 Custodian:…Les Johnston……. Approver:…Ted Richardson UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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 Custodian:…Les Johnston……. Approver:…Ted Richardson UNCONTROLLED COPY WHEN PRINTED Version: 5.0 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: __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ © Environmental Performance Australia Pty Ltd Custodian:…Les Johnston……. Approver:…Ted Richardson UNCONTROLLED COPY WHEN PRINTED Version: 5.0 Page 17 of 17
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