S2S Pollution Incident Response Management Plan Newcastle Inner City Bypass – Shortland to Sandgate S2S-PL-GL-PIR-001-00 Page 1 of 38 TABLE OF CONTENTS 1. INTRODUCTION ............................................................................................................................ 3 2. SCOPE AND PURPOSE ................................................................................................................ 3 3. DESCRIPTION AND LIKEIHOOD OF HAZARDS ......................................................................... 4 3.1. 4. PRE-EMTIVE ACTIONS TO BE TAKEN........................................................................................ 6 4.1. Preparedness .......................................................................................................................... 6 4.1.1. Large spills and leaks (chemicals, fuel, hazardous liquids) ............................................ 7 4.1.2. Bitumen spills, site run-off ............................................................................................... 7 4.1.3. Concrete Works (ie wet curing run-off entering waterway, concrete wash outs) ............ 8 4.1.4. Storage of liquids (chemicals, fuel, hazardous materials)............................................... 8 4.1.5. Acid Sulphate Soils ......................................................................................................... 8 4.2. 5. Risk Assessment ..................................................................................................................... 4 Inventory of pollutants ............................................................................................................. 9 4.2.1. Hazardous substances register....................................................................................... 9 4.2.2. Material Safety Data Sheet (MSDS) ............................................................................... 9 4.2.3. Handling and storage of hazardous substances ............................................................. 9 4.2.4. Waste handling and storage ......................................................................................... 10 4.2.5. Erosion and sediment ................................................................................................... 10 4.2.6. Air quality....................................................................................................................... 11 4.3. Safety equipment .................................................................................................................. 12 4.4. Contact details....................................................................................................................... 12 4.5. Communicating with neighbours and the local community ................................................... 13 4.6. Minimising harm to persons on the premises ....................................................................... 14 4.7. Training of Emergency Response Personnel ....................................................................... 14 4.8. Testing Plans......................................................................................................................... 15 EMERGENCY PROCEDURES .................................................................................................... 16 5.1. Notification............................................................................................................................. 16 5.2. Pollution Incident Response Procedures .............................................................................. 19 5.3. Clean Up ............................................................................................................................... 22 APPENDIX A – ENVIRONMENTAL ASPECTS AND IMPACTS RISK ASSESSMENT ..................... 23 APPENDIX B – MINIMUM SAFTEY EQUIPMENT ON SITE ............................................................... 33 APPENDIX C – APPROVED PROJECT SEDIMENT BASINS ............................................................ 35 APPENDIX D – POLLUTION INCIDENT NOTIFICATION FORM........................................................ 37 Page 2 of 38 1. INTRODUCTION This Pollution Incidence Response Management Plan (PIRMP) has been prepared for the Newcastle Inner City Bypass (NICB) - Shortland to Sandgate section of the Hunter Expressway project. The Shortland to Sandgate section will provide a four-lane divided carriageway extension of the Newcastle Inner City Bypass for 1.8 km between Shortland and Sandgate. This extension will pass underneath Sandgate Road at Shortland, bridge over Deepbridge Creek and the main northern railway line, run past the western side of Sandgate Cemetery and join the Pacific Highway at Sandgate. This extension of the existing Jesmond section will provide improved access between the developing western parts of Newcastle, regional produce markets and the port of Newcastle. The scope of this PIRMP covers the 1.8 km route between Shortland and Sandgate only. The PIRMP has been developed by the Shortland to Sandgate Alliance (S2S) in response to amendments to the Protection of the Environment Legislation Amendment Act 2011 as set out in Part 5.7A of the POEO Act. The plan provides a guide for the operations, actions and notifications to be carried out in the event of a pollution incident and/or emergency as application. Whilst deviation from the plan should be avoided, all events shall be managed according to the specific conditions of the incident. As part of the development of the PRIMP a risk assessment was undertaken to identify current and future environmental risks associated with the project. As part of the risk assessment it was identified what preventative measures are in place and what further measures need to be implemented, the emergency response processes and notification requirements. 2. SCOPE AND PURPOSE The PRIMP provides an easily interpreted reference document that ensues that pollution incidents can be managed and responded to in an appropriate manner. The PRIMP documents the risk assessment process implemented at S2S and the activities that create pollution risks associated with the project. The top five risks which will remain current to the completion of the project have been identified and form the focus of the Plan. All risks and any subsequent pollution incidents however would be managed through the implementation of this Plan. The PRIMP details the pre-emptive actions that have been implemented on the project these include: specific measures implemented to minimise the risk of an incident occurring due to spillage, storage of hazardous materials or fire; inventory of potential pollutants on site; minimum safety equipment requirements; communication with the community; minimising harm to persons; training of personnel and; Page 3 of 38 Testing of the PRIMP. The PIRMP also details the procedures to be used in the event of a pollution incident including notification requirements. The PIRMP links to existing safety, environmental and emergency systems and plans already in place at the S2S project. 3. DESCRIPTION AND LIKEIHOOD OF HAZARDS 3.1. Risk Assessment Environmental risks associated with the Project have been identified using the Risk Assessment Process. The risk assessment process was developed to identify, describe and rate potential hazards. All environmental risks currently identified for the project have been outlined in Appendix A of the PIRMP. Appendix A shall be updated if future risks are identified. The following tables outline the risk assessment process using three steps to identify the appropriate management measures required. Table 3.1 is used to determine the likelihood that the aspect will have an impact on the environment. Table 3.2 is used to determine the potential consequence rating of the risk identified From these two tables, a risk rating can then be assigned by using Figure 3.1 to determine how severe the potential impact will be. Table 3.3 can then be used to assess what level of management each type of risk will require. Where a significant risk to the environment has been identified, environmental protection measures to reduce the risk to an acceptable level shall be implemented. Aspects with a medium or low risk shall also have practicable management measures implemented if these can further reduce risk. Table 3.1 Likelihood criteria Occurrence (likelihood) Description A Rare/improbable The event may only occur in exceptional circumstances. B Unlikely/remote The event may occur at some time (about once every five years). C Possible The event is likely to occur at some time (about once every year). D Likely The event will probably occur in most circumstances (at least once every six months). E Almost certain The event is expected to occur in most circumstances (at least once every month). Page 4 of 38 Table 3.2 Consequence Criteria 1 Consequence (impact) Description Insignificant/negligible Short-term disturbance with minor environmental release or damage that is non-reportable. No impact outside site boundary. No community complaints or media reports. 2 Minor violation of regulation or guideline with minimal damage to the environment and small clean-up. Minor/low Immediately contained on site. Local government action, minor community complaints. Potential or actual breach of legislation. 3 Violation of regulation or guideline with moderate damage to the environment and significant clean-up costs. Moderate Release of pollution off site. Detrimental media reports, community concerns and complaints. 4 Significant environmental damage – potentially permanent. Major Release of pollution off site. Significant loss of environmental resources. Detrimental media reports in the national or state media, organised community concern. High likelihood of EPA fine or court action. 5 Long-term environmental harm. Catastrophic Permanent irreparable damage to the environment. Sustained detrimental state and national media reports. Sustained community outrage. Penalty Infringement Notice/court action. A B Likelihood C D E Risk Severity Consequence 1 Priority 2 High 3 Moderate 4 Low 5 Figure 3.1 Risk Rating Table 3.3 Risk Severity Risk severity Management required Priority Immediate management action required. Page 5 of 38 High Priority management action warranted. Moderate Management action warranted. Low Management action should be considered, particularly for low-level impacts that nevertheless occur on a continual basis. The Environment Manager in consultation with the person(s) responsible for the activity will determine how the risks can be successfully remedied to ensure sound environmental management. This may include updating the CEMP or associated documents (e.g. Daily Hazard Pre-start Risk Assessments, Job Safety and Environmental Assessments, Work Method Statements (WMS), Environmental Construction Method Statements (ECMS)) to cover any further identified management measures and mitigation strategies. Job Safety Environmental Analyses (JSEA) details the specific safety and environmental risks and controls for each work area or specific construction activity for the Project As part of the development of the PRIMP a risk assessment was undertaken to identify the current top five risks associated with the project. A copy of the risk assessment is provided in Appendix A. The top five risks identified were: 1) 2) 3) 4) 5) Large spills i.e. diesel truck accident on/off site Bitumen spills, site run-off Concrete Works (i.e. wet curing entering waterways, concrete wash outs, etc.) Storage of liquids (chemicals, fuel, hazardous materials) Acid sulphate leachate 4. PRE-EMTIVE ACTIONS TO BE TAKEN 4.1. Preparedness The key to effective prevention of incidents is risk assessment, procedure development, monitoring and training. During construction activities, S2S’s inspections and preventive actions include: activity specific and daily risk assessments; development of work procedures and construction method statements in consultation with relevant S2S staff such as work teams, environment team members and senior management; daily inspections of active work sites; completion of routine environmental checklists; issue and quick close-out of non-compliance notices; ongoing environmental training; environmental audits of work sites, subcontractors and compliance issues; Page 6 of 38 community notification and construction updates; Work Method Statements (WMS) and/ or Work Packs provide the structure for documenting major areas of the work including risk and quality and align design and constructability early in the process. The Work Packs draws together or references other related documentation (including JSEAs and ECMS) to demonstrate to all stakeholders that all relevant issues have been considered in planning the works; and Activities associated with potential or major environmental incidents are identified in the respective management plans i.e. Soil and Water Management Sub Plan. In addition the following specific measures will also be implemented to minimise the risk of an incident occurring due to spillage, storage of hazardous materials or fire. 4.1.1.Large spills and leaks (chemicals, fuel, hazardous liquids) Plan and implement works involving the use of chemicals, dangerous goods or other potential contaminants, to minimise the possibility of pollution. Use and store chemicals and dangerous goods strictly in accordance with relevant legislation, manufacturer instructions and the MSDS. Establish transport, handling, storage and application methods (with the relevant method statement) to prevent chemical, fuel and lubricant spillage on or around the site. Keep adequate quantities of emergency response materials, such as oil spill kits, absorbent materials, sand bags, flocculating agents and pH buffer solutions, readily available and in designated compounds. Also keep oil-spill kits in emergency response, superintendents’ and the Environmental Manager’s vehicles and vehicles that carry substantial quantities of chemicals. Provide temporary bunding for refuelling or maintenance of plant and equipment, mixing cutting oil with bitumen or any other activity that could result in spilling a chemical, fuel or lubricant (where the activity occurs in a location with direct drainage to a waterway or environmentally sensitive area).. Ensure chemical drums removed from bunded areas are not left unattended. The major response to spills and leaks will involve containing the offending material. Where safe to do so, install containment measures such as sandbags, booms, earth bunds or cut drains to capture and retain spilled material and prevent it from leaving site, entering any watercourse or impacting on vegetation stands. 4.1.2.Bitumen spills, site run-off When monitoring the progress of product transfer ensure that kettle levels are observed and kettles are bunded to contain any spills Ensure spill kits and emergency response equipment is available on site to facilitate an immediate response to an incident and help ensure the safety of public and property. Ensure vehicles are not parked under tree drip line. Stockpiled material not placed within 5 meters of trees. Keep ignition sources 15 meters away from cutter and bitumen. Bituminous products (i.e. primes, primer seals, seals, tack coat, etc.) not applied if rain is likely. Stationary vehicle driver operator to spot and guide the moving vehicle to the refuelling position. Page 7 of 38 Refuelling to be conducted at a minimum of 20 meters from any water course To prevent truck roll over identify poor road shoulder conditions and mark as hazards with cones, ensure truck is not overloaded, and tips slowly to allow aggregate to run out tail gate and when loading and unloading plant ensure the plant is parked on a level area Ensure regular plant maintenance 4.1.3.Concrete Works (i.e. wet curing run-off entering waterway, concrete wash outs) Designated concrete wash out bays to be provided and used for concrete work. Concrete bays to be constructed to minimise ingress of rainfall and site run-off. Concrete wash out bays to be maintained to ensure adequate capacity. Concrete driver/operator to inducted into concrete washout locations. Concrete surfaces to be protected prior to initial set where rainfall is likely. Ensure spill kits and emergency response equipment is available on site to facilitate an immediate response to an incident and help ensure the safety of public and property. Ensure vehicles are not parked under tree drip line. Stockpiled material (concrete waste) not placed within 5 meters of trees. Wet curing of bridge structures to be undertaken using minimal water volumes to avoid run-off of excess water. Any areas of potential water run-off are bunded to contain material for testing prior to discharge. Refuelling to be conducted at a minimum of 20 meters from any water course Ensure regular plant maintenance 4.1.4.Storage of liquids (chemicals, fuel, hazardous materials) Bund and cover all liquid storage areas – ensure 120% of liquids stored can be captured within the bund. Ensure that storage areas are not within 20 m of a natural or built drainage line, flood-prone areas or on slopes steeper than 1:10 or near vegetated areas. Monitor and drain water captured in the bunded storage area (as required) after each rain event to ensure bund capacity is maintained at all times. Arrange appropriate treatment or removal if the water is not suitable for discharge. Any water discharged from site must be prior approved through the HEA Water Movement Permit (WMP) system. Contact Environment Staff for WMP. Ensure records are kept of water quality checks, discharges and any remedial actions taken. Ensure adequate ventilation of stored materials Remove potential ignition sources from storage area (minimum 20m) Material Safety Data Sheets (MSDS’s) to be maintained and readily available 4.1.5.Acid Sulphate Soils Potential areas of acid sulphate soils to be identified in accordance with the project specific Acid Sulphate Soil Management Sub Plan (ASSSP) Page 8 of 38 Establish bunded acid sulphate soil treatment areas in accordance with the ASSSP (construction to minimise ingress of rainfall and site run-off) Sample and test potential acid sulphate soils to determine pH and associated liming rates for treatment (pH neutralisation) Verification testing of treated acid sulphate soils for effective neutralisation Monitor bund for signs of water build-up within bund or potential leachate. Treat water within bund prior to discharge (in accordance with the Water Movement Permit system). Ensure ready availability of agricultural lime prior to exposure of acid sulphate soils. Storage of agricultural lime shall be elevated off the ground and covered to ensure no rainfall run-off from stored agricultural lime. MSDS to be readily available for stored agricultural lime (including provision of appropriate personal protective equipment for safe handling). 4.2. Inventory of pollutants 4.2.1.Hazardous substances register A Hazardous Substances Register has been developed for the project. This is being maintained by the Safety Manager and will be made available to Emergency services as required. The Hazardous Substances Register includes an indication of quantities stored on the site. The first aid officer shall be notified of the location of the register and have ready access if the need should arise. 4.2.2.Material Safety Data Sheet (MSDS) The Safety Manager will ensure that Material Safety Data Sheets for all hazardous substances on the site’s Hazardous Substances register are available to Emergency Services as required. The first aid officer shall ensure all relevant MSDS’s and the Register of Hazardous Substances is available in the first aid rooms. An electronic Register will also be available in the Oracle Applications Express data base. 4.2.3.Handling and storage of hazardous substances Hazardous and dangerous substances (including all fuels, oils, lubricants and chemicals) brought onto the worksite are only to be handled or stored within designated bunded areas to ensure retention of any spills or leaks. Storage and bunding for areas for hazardous liquids is to conform with AS1940 – Storage and Handling of Flammable Liquids and AS/NZS 4452 – Storage and Handling of Toxic Substances. Storage of hazardous solids is to be in accordance with the MSDS and where practicable is to be undercover within bunded areas. Requirements associated with AS1940 and AS/NZ 4452 includes but is not limited to: Page 9 of 38 Storage areas shall be secured against unauthorized entry. A supply of water shall be available at a nearby location, for personal hygiene. adequate ventilation shall be provided for all storage and handling areas Packages shall not be kept near substances with which they are incompatible or with which they may react dangerously. Packages shall be kept away from sources of heat. Packages shall be kept securely closed when not in use. Packages shall be kept in such a manner as to avoid spillage. Appropriate spillage-retention measures shall be provided at locations where packages are likely to be opened or their contents transferred. The contents of a package shall not be transferred to any other container for storage, unless the latter is suitable for the storage of the toxic substance and is clearly marked. Appropriate control measures shall be instituted for any process involving product transfer operations, e.g. decanting or filling. Appropriate personal protective equipment shall be worn by any person involved in product transfer operations. any spills or leaks shall be cleaned up immediately, and disposed of appropriately according to the standard 4.2.4.Waste handling and storage Where waste is required to be handled and stored onsite prior to onsite reuse or offsite recycling/disposal in accordance with the Waste Management Sub Plan and the following measures apply: spoil, topsoil and mulch are to be stockpiled onsite in allocated areas, where appropriate, and mitigation measures for dust control and surface water management will be implemented as per the Air Quality Dust Management Sub Plan and the Soil & Water Management Sub Plan Liquid wastes are to be stored in appropriate containers in bunded areas until transported offsite. Bunded areas will have the capacity to hold 120% of the liquid waste volume. hazardous waste will be managed by appropriately qualified and licensed contractors, in accordance with the requirements of the Environmentally Hazardous Chemicals Act 1985 and the EPA waste disposal guidelines all other recyclable or non-recyclable wastes are to be stored in appropriate covered receptacles (e.g. bins or skips) in appropriate locations onsite and contractors commissioned to regularly remove/empty the bins to approved disposal or recycling waste disposal sites are to be shown on site VMPs 4.2.5.Erosion and sediment Page 10 of 38 Erosion and sediment shall be managed in accordance with the Soil and Water Management Sub Plan (SWMSP) this includes but is not limited to the following: maximise the diversion of clean stormwater run-off from entering disturbed work areas maximise the retention of stabilised areas (i.e. vegetated ground cover, existing pavements, etc.) and existing drainage structures (i.e. retain kerb & gutter and stormwater infrastructure where possible during construction) re-stabilise disturbed work areas as soon as practicable progressively construct works to ensure re-sealing of disturbed work surfaces (i.e. smooth drum rolling), natural sheet flow run-off (i.e. avoid concentrated scouring and/or unnecessary pooling) staging of works to minimise area/period of disturbance and potential erosion construct sediment basins to suit construction staging requirements to ensure adequate capacity maximise the diversion of stormwater run-off containing suspended solids to sediment basins where practicable, re-use captured stormwater meet project water quality standards (as per EPL 13264) prior to release o pH between 6.5 & 8.5, and o TSS below 50mg/L, and; o no visible grease or oil obtain an approved water movement permit prior to release floats and other devices including hard (fail safe) controls used at the pump/pipe inlet adequate scour protection to be provided at the pump/pipe outlet basin must be discharged within 5 days of the cessation of rainfall All basins are designed to meet the 80th percentile (5 day) rainfall depth (mm) value taken from the Newcastle area. This equates to 30.5mm for the 5 day rainfall event after which over topping may occur. All basins must be treated to project water quality standards prior to release. A list of approved sediment basins and discharge locations can be found in Appendix B 4.2.6.Air quality All air quality shall be managed in accordance with the air quality management sub plan (AQMSP). Precautions to minimise the generation of dust will include: Spraying of earthworks, roads and other surfaces as necessary with water or other suitable liquids, Providing dust suppression equipment to any on-site materials batching plant, Sealing of temporary haul roads, Applying dust block or similar material to exposed surfaces so as to supress possible generation of dust during periods of high winds. Page 11 of 38 Compacting exposed surfaces in the event of high winds, and Modification of operations during high or unfavourable wind conditions. 4.3. Safety equipment The Safety Manager shall ensure that emergency equipment is available at each site, and appropriately located and maintained in good working order. Minimum emergency equipment at all sites is identified in Appendix C. Consideration will also be given to the establishment of a set of emergency equipment located centrally and available to all sites. On some of the larger sites, there may also be an equipped first aid shed that can be utilized in an emergency. All S2S vehicles are also equipped with a Type C first aid kit as a minimum which is to be kept fully maintained at all times. Materials for handling environmental spills, etc. will include oil spill kits and sand bags, together with other items as deemed to be appropriate. Specialised equipment available for an emergency response will be maintained in a “fit for purpose” state and in a readily available. Other equipment available for incident response needs to be identified at each site, for example, specific construction vehicles and other equipment types available on site. On call equipment will be obtained through hire companies. The Safety Manager, in consultation with the Environment Manager, shall maintain a list of safety and environmental emergency response equipment held in the project store, ensure the ongoing availability of an adequate stock of consumable equipment and ensure all emergency equipment is being inspected, tested and maintained as necessary. 4.4. Contact details Organisation Name Number/s Other details S2S Emergency Controller; TBA by Construction Manager in the event of an Emergency Chris Prowse 0418 228 640 Safety Andrew Aylett 0417 944 096 Environment Matt Quinn 0408 885 281 Traffic Roads & Maritime Services Interface Manager Jason Laverty 0408 604 042 Project Alliance Director Peter Chatburn 0418 233 905 Environmental Manager Tracey Doczy 0411 952 658 Environmental & Community Co-ordinator Andrew Aylett 0417 944 096 or delegate to notify relevant authorities in the event of a ‘material harm’ Page 12 of 38 Development Manager Greg Fell 0417 436 418 NSW Police 000 NSW Fire Brigade 000 NSW Ambulance Service 000 Hospital John Hunter Hospital 02 4921 4960 Rural Fire Services 000 SES 132 500 Poisons Information 131 126 EPA Cameron Perry EPA Pollution Line Community liaison Notify in the event of ‘material harm’ Address: Lookout Road New Lambton NSW 2305 4908 6808 131 555 NSW I&I (Fisheries) Scott Carter 02 4916 3931 0419 185 508 Local contractor services (e.g. waste collection, spill clean-up) Thiess Services; Richard Hepworth 0418 967 265 Jemena (Gas Utility) Thomas Bourke 131 909 WorkCover 131 050 Public Health Unit 02 4924 6477 City of Newcastle 02 4974 2000 Hunter Water 1300 657 000 Notify in the event of ‘material harm’ Notify in the event of ‘material harm’ Notify in the event of ‘material harm’ 4.5. Communicating with neighbours and the local community Information prepared for distribution to the community will be tailored to the needs of the target group and approved by the RMS before release. It may address progress, traffic disruptions and controls, temporary detours, work outside normal hours and may be provided as: a community notice; advertisements (e.g. progress updates, road closures, disruption to traffic); newsletters; brochures; internet updates; noticeboard information; door nocking; or A display/information area. Key community groups along the upgrade include: interest groups (environmental and commercial); adjacent residential communities (e.g. Shortland and Sandgate); Page 13 of 38 Sandgate Cemetery; and Hunter Wetland Centre Australia. In the event of a pollution incident affected community members will be notified of any measures they can undertake to minimise the risk of harm. This will be carried out by emergency services or S2S personnel as relevant. Measures to minimise harm may include but is not limited to the following: shutting windows and doors; remaining inside; avoiding the use of water in creeks; and evacuating if instructed by emergency services 4.6. Minimising harm to persons on the premises In the event of an emergency that is likely to cause harm to persons the Emergency Response Management Plan shall be followed. Document number HEA-PL-GL-ICR-001-0001. 4.7. Training of Emergency Response Personnel The Project Manager, in consultation with the Safety Manager, Environmental Manager and relevant Zone Manager, will determine the specific competencies required to respond to an emergency situation on each site and the training required to achieve the level of expertise required. Training needs for emergency response will conform to all PAA requirements including any environmental emergency response training. An example of the kinds of environmental incident response competencies (training requirements) required of key personnel is provided at Table 4.7. Training will be provided to: provide (or refresh) specific skills such as emergency response drills, evacuations, fire wardens, first aid, etc.; enable the proficient use of specialised equipment; ensure detailed familiarity with the provisions of this Plan and supporting procedures; ensure learnings from mock evacuation and other emergency management exercises are communicated; and ensure knowledge of legislative and statutory requirements. All S2S personnel and subcontractors will also receive some training to ensure that they are fully aware of their roles and responsibilities in the event of an emergency situation arising. This training will generally be provided through Site Inductions o provided to all employees & subcontractors prior to commencement on site; and Page 14 of 38 o content includes basic emergency procedures and incident reporting. Toolbox Meetings o mainly covers safety issues but can be used as refresher training on response procedures, dealing with the public, locations and use of response equipment. Specific training will also be provided to Emergency Response Teams to ensure their roles and responsibilities in relation to construction site significant incidents / emergencies are understood and they are fully trained in responding to construction site emergencies. Table 4.7 Example of environmental incident response competencies Training Requirement Position Incident Response Storage and handling of Chemicals Oil Spill Clean Up Concrete Washdown Dealing with Media Management Alliance Project Director X X Project Manager X X X Safety Manager X X X Traffic Manager X Environment Manager X X X CEC X X X Emergency Response Teams X X X Safety Coordinators X X X Environmental Officers X X X X X X X 4.8. Testing Plans Environmental response procedures may be tested in areas where a pollution risk is present, such as in workshops. Personnel involved in emergency response activities will be provided with specific training. An up-to-date list of emergency response personnel and organisations will be maintained at the main office and compounds. Testing of the plan will be undertaken every 12 months to ensure that information in the plan is accurate and capable of being implemented effectively. Page 15 of 38 5. EMERGENCY PROCEDURES The definition of a pollution incident is: A pollution incident is an incident or set of circumstances during or as a consequence of which there is or is likely to be a leak, spill or other escape or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise. 5.1. Notification The Environmental Manager will notify the EPA Regional Manager (and/or EPA Pollution Line on 131 555) immediately (i.e. promptly and without delay) of pollution incidents which have occurred in the course of the project’s activities, in the following circumstances (i.e. incident which cause or threaten material harm): If the actual or potential harm to the health or safety of human beings or ecosystems is not minor. If actual or potential loss or property damage (including clean-up costs) associated with a pollution incident exceeds $10,000. Pollution incidences that could constitute material harm include such things as: sediment basin discharge that does not meet project water quality standards; chemical spill into a waterway; dust plume from construction area; uncontrolled discharge of water from Potential Acid Sulphate (PASS) treatment area that does not meet project water quality standards; and Exposure of contaminated materials. Furthermore, the following parties shall be notified; 1) Ministry of Health (via the local Public Health Unit (PHU)) - (02) 4924 6477 2) WorkCover - 13 10 50 3) Local Council a. City of Newcastle (CoN) – (02) 4974 2000. 4) Fire and Rescue NSW - 000 Refer to Figure 5.1 for notification procedure flowchart. Additionally the S2S’s RMS Interface Manager will be notified verbally within 2 hours and in writing within 24 hours of any pollution incidents involving the EPA. Page 16 of 38 All incidents shall be notified to RMS (i.e. Interface & Environment Manager) via the Alliance incident reporting system (e.g. HSE reporting system) in accordance with RMS Incident Management and Reporting Procedure (April 2012 or updated version) and Thiess HSE system. All incidents shall be recorded within the S2S Monthly Environment Report. Notification to the community will be conducted using methods outlined in Section 4.5. Page 17 of 38 Notification Process Team members are responsible for contacting those persons in the boxes immediately below Incident Occurs Site Personnel notify Foreman Foreman /Superintendent Environment Co-ordinator to notify the following as appropriate for immediate assistance Andrew Aylett 0417 944 096 Traffic Community Safety Environment Manager or delegate Matt Quinn Andrew Aylett Chris Prowse Tracey Doczy 0408 885 281 0417 944 096 0418 228 640 0411 952 658 Potential or actual affected community Project Emergency Response Team (determines if CMP need to be activated) Local Council Fire and Rescue Ministry of Health via Public Health unit Refer to CMP Figure 5.1 Notification procedure flow chart Page 18 of 38 WorkCover EPA 5.2. Pollution Incident Response Procedures The general procedure for all pollution events is shown in Figure 5.2. For specific incident type flowcharts see: - Figure 5.3 for managing spills Figure 5.4 for managing sediment control devices Figure 5.5 for managing major spills Incident occurs. Contact the Foreman for the area. Implement initial incident management procedures such as contain the leak/spill, protect drainage lines etc. Contact Environment Team Contact Construction Manager or Superintendent if Environment team members are not available. Is the incident routine, significant or major? Routine Incident (e.g. minor hydraulic spill contained on the formation) Clean–up with onsite resources Significant Incident (e.g. overclearing, spills that leave the site) Major Incident (e.g. over-clearing in EEC, spills that escape into waterways) Stop works and wait until Senior Management attends site. Implement containment strategies as directed. Stop works and wait until Senior Management attends site. Implement containment strategies as directed. EM notifies Client, EMR and Regulatory Agencies as required. EM notifies Client, EMR and Regulatory Agencies as required. Implement addition site management procedures as directed and complete HEA incident and investigation report. Figure 5.2 Emergency Response Procedures The following flow charts relate to management procedures for spills, remediation of sediment controls and major chemical spills in Figures 5.3, 5.4, and 5.5 respectively. Page 19 of 38 PRIOR TO ANY ACTION, IDENTIFY MATERIALS INVOLVED & OBTAIN PERSONAL PROTECTIVE EQUIPMENT Action Responsibilities Comments 1 Stop further leak Person causing/finding leak If leak from oil drum, roll drum so that leak area is uppermost. If leak from pipe, close valve etc. 2 Inform supervisor Supervisor/Person Stop human and vehicular traffic and isolate area. 3 Determine the site of theleak 4 Form barrier around leak/spill Foreman / Superintendant Use foam barrier material in kit. Use soil/sand if kit not available. 5 Stop the spreading of leak Foreman / Superintendant Transfer fuel/oil from spill drum into another drum etc. 6 Put barrier around drains/outlets Foreman / Superintendant Seal drain grates by putting sand bags etc. around them. 7 Obtain oil spill kit *and apply oil absorbent on spill Foreman / Superintendant Use “absorbent W” orequivalent. 8 Clean up/remove absorbent material to bin ** Foreman / Superintendant Use “Chem -Oil -A-Way” or equivalent for clean-up of area. Use brush/pan provided in kit . 9 Clean up hard surface by excavating contaminatedsoil Foreman / Superintendant Stockpile contaminated material in designated area 10 Clean up soft surface by excavating contaminatedsoil Foreman / Superintendant Stockpile contaminated material in designated area 11 Inform Environmental Manager and fill in Incident Log Form Environmental Manager Record incident and review procedures Supervisor For major leaks notify superintendent. If spill has escaped offsite/into creek/ring Environmental Manager immediately * oil spill kit available at both compounds . ** bin located at Construction Compounds. Figure 5.3 Environmental Management Procedures for Spills Page 20 of 38 Action Responsibilities Comments 1. Inform area supervisor of problem/ exact location and the magnitude. Person causing/ discovering the problem Assess whether the problem can be promptly rectified. 2. If uncontrollable, notify sediment control crews. Foremen/superintendents State the magnitude of the problem and the materials required. . Divert flow away from existing waterways. Foremen/superintendents and available machinery Stop vehicular traffic and construct an earth bund or diversion drain. 4. Form a barrier around the affected area. Establish emergency berm (earth or sandbags) to trap sediment or reduce flow. Emergency response unit - 5. Work on the restoration of original control device. Foremen/superintendents/ Operators Stem the flow and replace damaged control device. 6. Assess impact and devise remedial action for affected waterway and embankment. Environmental Manager Proceed with water quality monitoring. 7. Apply buffering solutions/agents if required. Emergency response unit Monitor effects of this application 8. Clean away sediment build-up deposits before leaving area. Foremen/superintendents /Operators Use available machinery. 9. Record all stages of event on Environmental Incident Report form and investigate causes. Environmental Manager/ Foremen/superintendents Witness accounts/ photographs/ monitoring results 10. Review remedial actions and find out if response process can be improved. Environmental Manager/ Foremen/Superintendents Initiate change in the process if required. 11. Review incident to determine if environmental system failure. Improve system if required. Environmental Manager/ Foremen/superintendents Initiate change in system if required. Figure 5.4 Procedures for the Remediation of Sediment Control Devices Page 21 of 38 In the event of a major chemical spill or exposure, the following procedure should be implemented: Safety first STOP WORK IN THE SPILL AREA; AND EVACUATE THE AREA IF NECESSARY; Notify the Environment Co-ordinator and Superintendent; Notify the relevant emergency services - Dial 000 and provide as much detail as possible including o location of emergency, o nature and size of spill, o UN numbers and/or chemicals involved; Control the Spill ATTEMPT TO CONTROL THE SPILL OR EXPOSURE IF IT IS SAFE TO DO SO, e.g. SHUTTING OFF VALVES ETC; DO NOT ATTEMPT TO CONTROL THE SPILL IF IT IS NOT SAFE TO DO SO!!!! If chemical spill enters or is likely to enter a watercourse, contact Waterways Authority and the EPA to engage a clean-up crew to attend the site; Environment Co-ordinator to ensure appropriate internal S2S management are notified; Environment Manager (or delegate) to ensure appropriate external environment authorities are notified; Environment Manager to ensure that the appropriate investigation and reporting processes are put in place. Figure 5.5 Responses to Major Chemical Spill or Exposure 5.3. Clean Up In the event of a pollution incident clean up actions will be established this may involve the removal of used spill kits and disposal in appropriate bins, the removal of sediment. If a pollution incident occurs resulting in material harm the clean-up process will be managed by appropriately qualified and licensed contractors as necessary (e.g. liquid wastes/ asbestos waste) and in accordance with the requirements of the EPA waste disposal guidelines. Page 22 of 38 APPENDIX A – ENVIRONMENTAL ASPECTS AND IMPACTS RISK ASSESSMENT Page 23 of 38 Table A-1: Summary of environmental aspects and impacts Risk (pre-control) Category Environmental general Activities/ hazard Culture Impact/risk description Poor environmental culture leading to increased environmental incidents Risk impact Risk likelihood Risk category 4 - Major D - Unlikely Medium Reference to sub plan where required mitigation measures are documented Construction Environmental Management Plan Construction Noise and Vibration Management Sub Plan Soil and Water Management Sub Plan Construction Air Quality Management Sub Plan Historical Heritage Management Sub Plan Indigenous Heritage Management Sub Plan Waste Management and Re-Use Sub Plan Hazard and Risk Management Sub Plan Flora and Fauna Management Sub Plan Spoil Management Sub Plan Performance Poor non-conformance systems 3 - Moderate D - Unlikely Medium Construction Environmental Management Plan Construction Noise and Vibration Management Sub Plan Soil and Water Management Sub Plan Construction Air Quality Management Sub Plan Historical Heritage Management Sub Plan Indigenous Heritage Management Sub Plan Waste Management and Re-Use Sub Plan Hazard and Risk Management Sub Plan Flora and Fauna Management Sub Plan Spoil Management Sub Plan Performance Issues not actioned 4 - Major C - Possible High Construction Environmental Management Plan Performance Issues are not identified 4 - Major D - Unlikely Medium Construction Environmental Management Plan Performance Poor relationships with relevant 3 - Moderate C - Possible Medium Construction Environmental Management Plan Page 24 of 38 Risk (pre-control) Category Activities/ hazard Impact/risk description Risk impact Risk likelihood Risk category Government Agencies and Councils. Reference to sub plan where required mitigation measures are documented Construction Noise and Vibration Management Sub Plan Soil and Water Management Sub Plan Construction Air Quality Management Sub Plan Historical Heritage Management Sub Plan Indigenous Heritage Management Sub Plan Waste Management and Re-Use Sub Plan Hazard and Risk Management Sub Plan Flora and Fauna Management Sub Plan Spoil Management Sub Plan Design Management Plan Performance Breach of Environmental Protection Licence 4 - Major C - Possible High Construction Noise and Vibration Management Sub Plan Soil and Water Management Sub Plan Construction Air Quality Management Sub Plan Performance Noise and vibration Working hour conditions not complied with. 3 - Moderate C - Possible Medium Construction Environmental Management Plan Performance Failure to comply with applicable legislation. 3 - Moderate C - Possible Medium Construction Environmental Management Plan General Exceedance (complaint) of construction noise limits within approved working hours 2 - Minor B - Likely Medium Construction Noise and Vibration Management Sub Plan General Structural damage due to vibration (Sandgate Cemetery) 4 - Major C - Possible High Construction Noise and Vibration Management Sub Plan General Inadequate consideration of noise impacts from construction traffic 2 - Minor C - Possible Medium Construction Noise and Vibration Management Sub Plan Piling Noise impacts on sensitive receivers during construction 2 - Minor C - Possible Medium Construction Noise and Vibration Management Sub Plan Construction Noise and Vibration Management Sub Plan Page 25 of 38 Risk (pre-control) Category Aboriginal cultural heritage Historical heritage Activities/ hazard Impact/risk description Risk impact Risk likelihood Risk category Reference to sub plan where required mitigation measures are documented General Generating complaints due to out of hours work activities 2 - Minor C - Possible Medium Construction Noise and Vibration Management Sub Plan Notifications Failure to notify local community of noisy works resulting in complaints 2 - Minor C - Possible Medium Construction Environmental Management Plan Disturbance / destruction of unidentified Aboriginal objects and places 3 - Moderate D - Unlikely Medium Indigenous Heritage Management Sub Plan Poor relationships with Aboriginal communities 3 - Moderate D - Unlikely Medium Indigenous Heritage Management Sub Plan Failure to notify appropriate authorities in case of unidentified Aboriginal relics disturbance 3 - Moderate E - Rare Medium Indigenous Heritage Management Sub Plan Disturbance / destruction of identified historical heritage objects and places (Sandgate Cemetery) 3 - Moderate Construction Noise and Vibration Management Sub Plan Vegetation clearing. Removal, stockpiling and re-spreading of soil. Site establishment - site compounds, access points and access routes. . Adjustments of existing public utilities. Site re-vegetation. Vegetation clearing. Removal, stockpiling and re-spreading of soil. Site establishment - site compounds, access points and access routes. Construction Environmental Management Plan C - Possible Medium Adjustments of existing Page 26 of 38 Historical Heritage Management Sub Plan Risk (pre-control) Category Activities/ hazard Impact/risk description Reference to sub plan where required mitigation measures are documented Risk impact Risk likelihood Risk category Disturbance / destruction of unidentified historical heritage objects and places 2 - Minor D - Unlikely Low Historical Heritage Management Sub Plan Failure to notify appropriate authorities in case of historical heritage relics disturbance 2 - Minor D - Unlikely Low Historical Heritage Management Sub Plan Structural damage to historical heritage items (Sandgate Cemetery) 3 - Moderate Inadequate protection of identified historical heritage sites (Sandgate Cemetery) 2 - Minor D - Unlikely Low Historical Heritage Management Sub Plan Impacts on adjacent properties from dust and emissions from heavy construction machinery & traffic 3 - Moderate C - Possible Medium Construction Air Quality Management Sub Plan Reduced visibility / safety due to dust in air 2 - Minor C - Possible Medium Construction Air Quality Management Sub Plan Poor stockpile management 2 - Minor C - Possible Medium Construction Air Quality Management Sub Plan public utilities. Site re-vegetation. Air quality Vegetation clearing. Removal, stockpiling and re-spreading of soil. Site establishment - site compounds, access points and access routes. Adjustments of existing public utilities. Site re-vegetation. Plant and equipment maintenance. Construction Environmental Management Plan C - Possible Medium Historical Heritage Management Sub Plan Noise & Vibration Management Sub Plan Spoil Management Sub plan Spoil Management Sub Plan Soil & Water Management Sub Plan Page 27 of 38 Risk (pre-control) Category Activities/ hazard Impact/risk description Risk impact Risk likelihood Risk category Reference to sub plan where required mitigation measures are documented Landscape Management Plan Flora and fauna Vegetation clearing Site establishment - site compounds, access points and access routes. Removal, stockpiling and re-spreading of soil. Health impacts (i.e. breathing or eye irritation) if elevated levels persist. 3 - Moderate C - Possible Medium Safety Management Plan Inadequate dust suppression measures 2 - Minor C - Possible Medium Construction Air Quality Management Sub Plan Poor maintenance of plant / equipment 2 - Minor C - Possible Medium Construction Air Quality Management Sub Plan Clearing, removal and disturbance of threatened species or populations including riparian vegetation outside of approval. i.e. access tracks/ ancillary sites. 4 - Major C - Possible High Flora & Fauna Management Sub Plan Damage to vegetation or areas outside of designated construction sites and work compounds. 4 - Major C - Possible High Flora & Fauna Management Sub Plan Sediments illegally entering waterways. 4 - Major B - Likely High Flora & Fauna Management Sub Plan Death of animals during clearing. 2 - Minor C - Possible Medium Flora & Fauna Management Sub Plan Loss and degradation of fauna habitat. 2 - Minor B - Likely Medium Flora & Fauna Management Sub Plan Temporary blockage of fish passage during construction. 3 - Moderate D - Unlikely Medium Flora & Fauna Management Sub Plan Encounter of unidentified threatened flora/fauna. 2 - Minor C - Possible Medium Soil and Water Management Plan Spreading of Chytrid fungus off site. 3 - Moderate C - Possible Medium Green and Golden Bell Frog Management Sub Plan Soil & Water Management Sub Plan Page 28 of 38 Risk (pre-control) Category Activities/ hazard Site re-vegetation Impact/risk description Introduction and spreading of noxious weeds and feral fauna species. Risk impact Risk likelihood Risk category 2 - Minor C - Possible Medium Reference to sub plan where required mitigation measures are documented Flora & Fauna Management Sub Plan Spoil Management Sub Plan Soil & Water Management Sub Plan Waste Vegetation clearing. Adjustments of existing public utilities. Removal, stockpiling and re-spreading of soil. Operation of site compound. Plant and equipment maintenance. Vehicle wash down. Concreting activities. . Site re-vegetation. Poor soil preparation for re-vegetation \ failure 4 - Major Excess generation of waste during construction activities including building materials, excess unsuitable spoil material, vegetation material. 4 - Major Inappropriate management and storage of waste 3 - Moderate Inappropriate disposal of waste 3 - Moderate B - Likely High Spoil Management Sub Plan Soil & Water Management Sub Plan B - Likely High Waste Management & Re-Use Sub Plan Spoil Management Sub Plan D - Unlikely Medium Waste Management & Re-Use Sub Plan Spoil Management Sub Plan D - Unlikely Medium Waste Management & Re-Use Sub Plan Spoil Management Sub Plan Failure to adopt waste hierarchy 2 - Minor D - Unlikely Low Waste Management & Re-Use Sub Plan Construction Framework Environmental Management Plan Non-compliance with legislation 2 - Minor D - Unlikely Low Construction Environmental Management Plan Waste Management & Re-Use Sub Plan Page 29 of 38 Risk (pre-control) Category Soil and water Activities/ hazard Vegetation clearing. Removal, stockpiling and re-spreading of soil. Site establishment - site compounds, access points and access routes. Adjustments of existing public utilities. Impact/risk description Reference to sub plan where required mitigation measures are documented Risk impact Risk likelihood Risk category Inappropriate spill and spill absorbent material management 2 - Minor D - Unlikely Low Erosion and subsequent sedimentation leading to water contamination and fish kills. 3 - Moderate Inadequate management of Potential Acid Sulphate Soils leading to water and soil pollution. 4 - Major C - Possible High Acid Sulphate Soils Management Sub Plan Inadequate provision of bunding leading to soil and water pollution 3 - Moderate B - Likely High Soil & Water Management Sub Plan Unauthorised release of water particularly during heavy rain events. 3 - Moderate B - Likely High Soil & Water Management Sub Plan Inadequate management of contaminated soils leading to water, soil and air pollution. 2 - Minor D - Unlikely Low Soil & Water Management Sub Plan Water, soil and air pollution from inappropriate disposal of contaminated soils, surface water and/or groundwater. 2 - Minor D - Unlikely Low Soil & Water Management Sub Plan Slow progressive re-vegetation leading to erosion. 3 - Moderate B - Likely High Soil & Water Management Sub Plan Soil and Water Management Sub Plan Hazard and Risk Management Sub Plan B - Likely High Soil & Water Management Sub Plan Spoil management Sub Plan Hazard & Risk Management Sub Plan Operation of site compound. Landscape Management Plan Page 30 of 38 Risk (pre-control) Category Activities/ hazard Impact/risk description Reference to sub plan where required mitigation measures are documented Risk impact Risk likelihood Risk category Poor construction works staging leading to erosion and sedimentation. 4 - Major C - Possible High Failure to separate clean and dirty water on site leading to water pollution. 3 - Moderate C - Possible Medium Soil & Water Management Sub Plan Use of incorrect / ineffective flocculants leading to water pollution. 3 - Moderate B - Likely High Soil & Water Management Sub Plan Potential disposal of contaminated groundwater from excavation works. 3 - Moderate D - Unlikely Medium Soil & Water Management Sub Plan Mud tracking 2 - Minor A - Almost Certain High Soil & Water Management Sub Plan Construction Environmental Management Plan Soil & Water Management Sub Plan Spoil Management Sub Plan Inadequate water resources 3 - Moderate C - Possible Medium Soil & Water Management Sub Plan Management of erosion and sedimentation controls. Inadequate ESC resources leading to poor management of erosion and sedimentation controls. 3 - Moderate D - Unlikely Medium Soil & Water Management Sub Plan Plant and equipment maintenance. Failure of plant / equipment leading to soil and water pollution 2 - Minor C - Possible Medium Soil & Water Management Sub Plan Vehicle wash down. Handling, storage and disposal of hazardous materials. Accidental spills and leaks of oils, lubricants, fuels, chemicals, herbicides or other pollutants onsite or into nearby watercourses. 2 - Minor C - Possible Medium Soil & Water Management Sub Plan Sediment basin construction Slow sediment basin installation. 3 - Moderate D - Unlikely Medium Soil & Water Management Sub Plan Insufficient clearing footprint to allow basin construction 4 - Major B - Likely High Soil & Water Management Sub Plan Poor design and location of sediment 3 - Moderate C - Possible Medium Soil & Water Management Sub Plan Waste Management & Re-Use Sub Plan Page 31 of 38 Risk (pre-control) Category Activities/ hazard Impact/risk description Risk impact Risk likelihood Risk category Reference to sub plan where required mitigation measures are documented basins. Concreting activities. Concrete wastes and washing out concrete mixers as well as slurry from saw cutting impacting upon adjacent water quality. 3 - Moderate D - Unlikely Medium Soil & Water Management Sub Plan Topsoils storage locations and management Insufficient space for storage of topsoil 4 - Major A - Almost Certain Extreme Soil & Water Management Sub Plan B - Likely High Poor vegetation establishment due to dispersive/sodic soils 3 - Moderate Insufficient space for sediment basin installation 3 - Moderate Spoil Management Sub Plan Soil & Water Management Sub Plan Landscape Management Plan B - Likely High Page 32 of 38 Soil & Water Management Sub Plan APPENDIX B – MINIMUM SAFTEY EQUIPMENT ON SITE 33 The following minimum emergency equipment will be available 50 x Clean up Fuel / Oil Absorbent Spill Pads; 3 x Clean up Fuel / Oil Absorbent Water Booms; 9 kg Dry Chemical Powder Fire Extinguishers (number depends on site) The following minimum emergency equipment will be available at the main compound Fully equipped First Aid Room including 1 x “A” Standard First Aid Kit (fixed) 1 x “A” Standard First Aid Kit (portable); 1 x “B” Standard First Aid Kit (portable); Automatic Defibrillator Equipment (portable) 9kg Dry Chemical Powder Fire Extinguishers The following minimum emergency equipment will be available at each compound kitchen 1 x “B” Standard First Aid Kit 9kg Dry Chemical Powder Fire Extinguisher 1 x Fire Blanket The following minimum emergency equipment will be available at each crib room 9kg Dry Chemical Powder Fire Extinguisher 1 x Fire Blanket 34 APPENDIX C – APPROVED PROJECT SEDIMENT BASINS 35 Basin Name Location Description SB3.10E Eastern side of Cut 1 at chainage 3100 SB3.58W Western side of Fill 2 at chainage 3910 SB3.91W Western side of Fill 1 at chainage 3581 SB4.45W Western side of Fill 3 at chainage 4450 Comment Permanent basin. Not yet constructed. Permanent and construction basin. Under construction Permanent and construction basin. Under construction Permanent basin. Not yet constructed. 36 APPENDIX D – POLLUTION INCIDENT NOTIFICATION FORM 37 38
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