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Revision 01 – 11-Apr-2017Prepared for – Allied Mills Pty Ltd – ABN: 24 000 008 739

Allied Mills Pty Ltd11-Apr-2017

Annual EnvironmentalManagement Report 2016Allied Mills, Kingsgrove

AECOM Annual Environmental Management Report 2016


Annual Environmental Management Report 2016Allied Mills, Kingsgrove

Client: Allied Mills Pty LtdABN: 24 000 008 739

Prepared byAECOM Australia Pty Ltd17 Warabrook Boulevard, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, AustraliaT +61 2 4911 4900 F +61 2 4911 4999 www.aecom.comABN 20 093 846 925

11-Apr-2017

Job No.: 60337172

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Quality InformationDocument Annual Environmental Management Report 2016

Ref 60337172

Date 11-Apr-2017

Prepared by Adam Plant, Gabriel Wardenburg

Reviewed by Ian Richardson

Revision History

Rev Revision Date DetailsAuthorised

Name/Position Signature

A 03-Apr-2017 DRAFT Gabriel WardenburgPrincipal EnvironmentalScientist

B 07-Apr-2017 DRAFT Gabriel WardenburgPrincipal EnvironmentalScientist

01 11-Apr-2017 FINAL Gabriel WardenburgPrincipal EnvironmentalScientist



Table of Contents1.0 Introduction 12.0 Terms of Reference 23.0 Standards, Performance Measures and Statutory Requirements 34.0 Environmental Actions 5

4.1 Noise 74.2 Air Quality 94.3 Stormwater 114.4 Traffic 124.5 Landscape Management 144.6 Waste Management 154.7 Hazards and Site Safety 16

5.0 Analysis of Environmental Monitoring Results 175.1 Annual Production 17

5.1.1 Monitoring Results 175.1.2 Identification of Trends 17

5.2 Noise 185.3 Traffic 19

5.3.1 Monitoring Results 195.3.2 Identification of Trends 20

5.4 Waste 225.4.1 Monitoring Results 225.4.2 Identification of Trends 23

6.0 Non-Compliance, Incidents and Complaints 256.1 Non-compliances Recorded during the Current Reporting Period 256.2 Incidents Recorded During the Current Reporting Period 296.3 Complaints Received During the Current Reporting Period 30

7.0 Recommendations and Action Plan 328.0 Conclusion 399.0 References 41

Appendix AEnvironmental Management Plan A



Project AcronymsAcronym Meaning

AEMR Annual Environmental Management Report

Allied Mills Allied Mills Pty Ltd

DMS Deflagration Management Strategy

DP&E Department of Planning and Environment

EMP Environmental Management Plan

GRC Georges River Council

IEA Independent Environmental Audit

IHA Independent Hazard Audit

LGA Local Government Area

SEE Statement of Environmental Effects

TMP Traffic Management Plan

TSH&E Training, Safety, Health and Environment

WMP Waste Management Plan



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1.0 IntroductionThis Annual Environmental Management Report (AEMR) has been prepared by AECOM Australia PtyLtd (AECOM) on behalf of Allied Mills Pty Ltd (Allied Mills). The AEMR provides an overview ofenvironmental activities occurring at the Allied Mills operated Kingsgrove food processing site (theSite), and has been prepared in accordance with Condition 7.1 of the Development Consent DA 143-06-01 (as modified) (the Consent). This AEMR covers the period from 1 January 2016 to 31 December2016.

The food processing plant was originally expanded in 2001 by Goodman Fielder. The expansioninvolved the construction of new bulk silos and an additional packing line. In 2002 the Site waspurchased by Allied Mills who now manage all site activities undertaken in the manufacture anddistribution of a range of grain based baking supplies and food ingredients. The Site is located at Lot 1DP 20025, 4 The Crescent, Kingsgrove, NSW within the Georges River Council (GRC) LocalGovernment Area (LGA) (refer to Figure 1).

This AEMR identifies the environmental standards, performance measures, and statutoryrequirements which have been established for the site and considers the environmental performanceof site activities against these criteria. This report also provides a summary of results recorded inaccordance with the Environmental Management Plan (EMP) and other supporting management plansand strategies produced for the site. These include:

· Noise Management Strategy

· Air Quality Management Strategy

· Stormwater Management Strategy

· Traffic Management Plan

· Landscape Management Plan

· Waste Management Plan

Finally the AEMR identifies all complaints or incidents of non-compliance recorded during the reportingperiod and summarises the actions taken to resolve such issues. The information contained within thisAEMR has been provided by Allied Mills site management personnel.

Figure 1 Site Location



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2.0 Terms of ReferenceCondition 7.1, Schedule 2 of the Consent requires Allied Mills to prepare and submit an AEMR for theapproval of the Director-General and Council. Table 1 details the requirements of Condition 7.1 andcross-references the sections of this AEMR containing the requisite information.Table 1 Consent Requirements and Cross-reference to AEMR Section where each requirement is addressed

DA Condition Requirement AEMR Cross-reference

7.1 Twelve months after commissioning the foodprocessing plant, and annually thereafter for theduration of the development, the Applicant mustsubmit an Annual Environmental ManagementReport to the Director-General and the Council.This report must:

This AEMR

(a) Identify all the standards, performancemeasures, and statutory requirements thedevelopment is required to comply with.

Section 3.0

(b) Review the environmental performance of thedevelopment to determine whether it iscomplying with these standards, performancemeasures, and statutory requirements.

Section 4.0 and 5.0

(c) Identify all the occasions during the previousyear when these standards, performancemeasures, and statutory requirements have notbeen complied with.

Section 6.1

(d) Include a summary of any complaints madeabout the development, and indicate whatactions were taken (or are being taken) toaddress these complaints.

Section 6.3

(e) Include the detailed reporting from theEnvironmental Monitoring Program (seeConditions 6.1 - 6.5), and identify any trends inthe monitoring over the life of the project.

Section 5.0

(f) Where non-compliance is occurring, describewhat actions are or will be taken to ensurecompliance, who will be responsible for carryingout these actions, and when these actions willbe implemented.

Section 7.0



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3.0 Standards, Performance Measures and StatutoryRequirements

Condition 1.2 of the Consent requires the Applicant to carry out the development in generalaccordance with the DA and subsequent modifications to the Consent (Notice of Modification dated 17April 2012), the Statement of Environmental Effects (SEE) prepared for the Site (Benbow Associates,2001), and the conditions of the Consent issued by the Minister.

Under the conditions of the Consent, the Applicant is required to prepare and implement variousmanagement plans for the site, as detailed in Table 2. This includes an EMP which specifies relevantstatutory requirements and sets standards and performance measures for relevant environmentalissues; these are in addition to those identified within the conditions of the Consent. The current EMPhas been submitted to the Department of Planning and Environment (DP&E) and includes thefollowing:

· Noise Management Strategy;

· Air Quality Management Strategy;

· Stormwater Management Strategy;

· Traffic Management Plan;

· Landscape Management Plan; and

· Waste Management Plan.

The EMP and supporting documents therefore provide the basis for assessing environmentalperformance of the Site. The EMP also specifically addresses all environmental monitoringrequirements and activities in relation to the Site.Table 2 Management Plans Required by Development Consent DA 143-06-01

ConsentReference

Management PlanRequired Version / Date Approval Status

3.1 ConstructionManagement Plan

N/A – Construction activities werecarried out by Goodman Fielderprior to Allied Mills takingpossession of the Kingsgrove siteand the consent conditions.

N/A

3.3 Construction SafetyStudy

N/A – Construction activities werecarried out by Goodman Fielderprior to Allied Mills takingpossession of the Kingsgrove siteand the consent conditions.

N/A

3.5 EnvironmentalManagement Plan

Final V03.1, 29 March 2017,revised by Allied Mills.

Final V03, 17 November 2015,revised by Allied Mills.

Final V01, 24 May 2012, preparedby SKM.

EMP revised (Final V03.1),DP&E will be provided withthe document duringAEMR submission, asconfirmed with DP&E.

EMP revised (Final V03),DP&E notified on25 November 2015.

Final V01 submitted toDP&E on 25 May 2012.Resubmitted to DP&E on 3June 2013. EMP approvedby DP&E on 4 August2014.



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ConsentReference

Management PlanRequired Version / Date Approval Status

4.17 Traffic ManagementPlan

Appendix E of EnvironmentalManagement Plan.

As per EnvironmentalManagement Plan.

4.26 Waste ManagementPlan

Appendix G of EnvironmentalManagement Plan.


4.29 LandscapeManagement Plan

Appendix F of EnvironmentalManagement Plan.


5.1 Fire Safety Study Report # 21069FSS, prepared byEnvironmental Audits of Australia(EAA).

Submitted to NSW DP&Eand NSW Fire Brigades on24 October 2001.

5.2 DeflagrationManagementStrategy

Deflagration Strategy Support,May 2014, prepared by AECOMAustralia (AECOM, 2014).

DP&E Hazard Audit 2015(DP&E, 2015) noted somerecommendations from theDMS report had not yetbeen closed. Additionalevidence was submittedand DP&E confirmed (letterdated 17 December 2015)that outstanding actionshad been adequatelyaddressed.

5.3(a) Emergency Plan Revision 1, 17 January 2014,revised by SKM.

Emergency Plan, 27 August 2012,prepared by SKM.

Submitted to DP&E on6 September 2012.Resubmitted to DP&E on29 May 2013.Revised and submitted toDP&E on 7 February 2014.Approved by DP&E on8 April 2014.

5.3(b) Safety ManagementSystem

Made up of numerous documentsand procedures within the sitedocument database.

Allied Mills submitted adocument mapping thecontents of its SafetyManagement System(SMS) against therequirements of HazardousIndustry Planning AdvisoryPaper (HIPAP) No. 9(DP&E, 2011a). DP&Eapproved the SMSmapping document on28 October 2015.

6.1 EnvironmentalMonitoring Program

Section 9.2 of EnvironmentalManagement Plan.




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4.0 Environmental ActionsThis section of the report describes the environmental actions that have been carried out during thecurrent annual reporting period (1 January 2016 to 31 December 2016) and what actions are likely tobe carried out in the following year. To describe the actions that have been carried out, AECOM hasconsidered the environmental undertakings that the Applicant has committed to fulfil under the EMPand supporting documents, and provided details on the applicant’s compliance with theserequirements.

The tables in the following sections set out the environmental areas of concern and the mattersrelevant to the implementation of the conditions of consent and or performance measures identified inthe EMP and supporting documents. They describe the actions that have been carried out in relationto those matters over the past year, what actions are likely to be carried out in the following year, andillustrate whether the site is currently meeting (or is in progress of meeting) the condition of theConsent, or commitment made in the EMP.

The primary method of monitoring for the site is through opportunistic observation and weekly sitewalk overs which incorporate visual inspection and testing of critical infrastructure. The results of theseinspections are summarised in Environmental Inspection Reports which allow for accurate detailing ofany major issues or observations made during the walk over. Other monitoring for specific issues (forexample, traffic and waste) is undertaken in accordance with the EMP. This detailed monitoring isdiscussed and analysed in Section 5.0.

The overall manufacturing activities on the Site were relatively unchanged from 2015, with nomodifications that are considered pertinent to the AEMR.

A compliance audit inspection was undertaken by DP&E on 28 May 2015 (DP&E Hazard Audit 2015).The DP&E Hazard Audit 2015 identified a number of hazard related non-compliances and maderecommendations in response to these non-compliances. Following this audit, Allied Mills undertookadditional actions to address the recommendations as documented in the 2015 AEMR. Itemsconsidered to be outstanding from the 2015 AEMR in the 2016 reporting period have been presentedin Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0.

An Independent Environmental Audit (IEA) was undertaken by GHD in 2016 in accordance with theconditions of the Consent which state ‘Within 12 months of commissioning the food processing plant,and every three years thereafter, unless the Director-General directs otherwise, the Applicant mustcommission and pay the full cost of an Independent Environmental Audit’. The previous IEA wasprepared in 2013, making the next version due in 2016. Any non-compliance reported in the IEA isprovided in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed inSection 7.0.

An Independent Hazard Audit (IHA) was undertaken by GHD in 2016 in accordance with theconditions of the Consent which state ‘Twelve months after the commencement of operations, andevery three years thereafter, unless the Director-General directs otherwise, the Applicant mustcommission and pay the full cost of a comprehensive hazard audit’. The previous IHA was preparedin 2013, making the next version due in 2016. Any non-compliance reported in the IHA is provided inSection 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0.



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4.1 NoiseTable 3 reports on environmental actions that have been carried out during the reporting period in relation to noise. It is anticipated that the relevant conditionsand commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the NoiseManagement Strategy.

Table 3 Summary of Noise Management Actions Undertaken during 2016

Consent Condition /Performance Measure

Relevant Condition, Performance Measure orSafeguard Actions carried out in 2016 Meeting Condition

or Commitment?Consent Condition 4.5 Noise emissions from operations at the site must not

exceed the following criteria:Three noise complaints were made during thereporting period.A noise audit was undertaken in January 2016involving attended noise measurement relating tothe blower plant room that showed the noiseemission contribution from the blower plant roomexceeded the acceptable noise criteria at night at anearby residence. Corrective actions wereinstigated, specifically the installation of an acousticlouvre on the blower plant, and attended noisemonitoring has since been completed and reportedthat the site was compliant with noise requirementsas per the sites conditions of consent. Furtherdetails are provided in Section 5.2.

The noise auditidentified a potential

exceedance atnearby residences.Noise attenuationwas installed in

September 2016and subsequentnoise monitoring

confirms compliancewith conditions of

the Consent.

Consent Condition 6.3 Should noise complaints be received, the Director-Generalmay direct the Applicant to commission and pay the fullcost of a noise audit. Should any noise audit demonstratean exceedance of the project specific residential noiselimits outlined in Condition 4.5, the Applicant shall employmitigation measures to reduce noise impacts from the site,to the satisfaction of the Director-General.

Three noise complaints were made during thereporting period and a noise audit wascommissioned in January 2016. The noise auditidentified a potential exceedance at nearbyresidences. Noise attenuation was installed inSeptember 2016 and subsequent noise monitoringconfirms compliance with conditions of the Consent.

ü



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or Commitment?EMP PerformanceMeasure (Table 4-1)‘Noise’

No nuisance noise will be emitted from the Kingsgrovesite.

Three noise complaints were made during thereporting period and a noise audit commissioned.Noise attenuation was installed in September 2016and subsequent noise monitoring confirmscompliance with conditions of the Consent.

Noise management measures are implemented atthe site. The production area and processingequipment are fully enclosed within existingbuildings, to minimise noise emissions from siteoperations.

Drivers are instructed to avoid using compressionbraking and hard acceleration when on the identifiedheavy vehicle haulage route for the Site.

Three noisecomplaints weremade during thereporting period.Noise attenuationwas installed in

September 2016and subsequentnoise monitoring

confirms compliancewith conditions of

the Consent.



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4.2 Air QualityTable 4 reports on environmental actions that have been carried out during the current reporting period in relation to air quality. It is anticipated that therelevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance withthe Air Quality Management Strategy.

Table 4 Summary of Air Quality Management Actions Undertaken during 2016

Consent Condition /Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition

or Commitment?Consent Condition 4.12 Alarms and shut off valves shall be installed on silos to

prevent overfilling.Alarms and cut off valves were installed on thesilos prior to commissioning. During the reportingperiod these systems were tested periodically andmaintained to ensure correct operation, with twoincidents noted.A high level alarm did not activate causing 150+litres of oil to overflow from the oil silo. There wasno spill to drains or external to site. This spill wascontained in the oil silo room.A suction blower stopped due to a silo being full,however the full signal did not alert outside,allowing the transfer pipe to block and flour to spillon the driveway. The spill was contained on sitehowever the incident was logged due to thepotential to discharge into drains.

ü

Consent Condition 4.13 Dust emissions from equipment must comply with the CleanAir (Plant and Equipment) Regulation 1997.

Vehicles and equipment exhausts were visuallymonitored (periodically) to ensure that release ofblack/white smoke did not exceed 10 seconds.

ü

Consent Condition 4.14 Emissions from vehicles associated with the site mustcomply with the Clean Air (Motor Vehicles and Motor VehicleFuel) Regulation 1997.

Vehicles and equipment exhausts were visuallymonitored (periodically at entry onto Site) toensure that release of black/white smoke did notexceed 10 seconds.A preventative maintenance system for all plantand machinery is implemented to ensure vehiclesassociated with the Site comply with theseguidelines.

ü



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or Commitment?Consent Condition 4.15 All activities in or on the premises must be carried out in a

manner that will minimise the generation, or emission fromthe premises, of wind-blown or traffic generated dust usingthe measures proposed in the SEE.

The majority of plant / equipment are containedwithin enclosed buildings to reduce the possibilityof dust emissions.

ü

Consent Condition 4.16 All areas in or on the premises must be maintained in amanner that will minimise the generation, or emission fromthe premises, of wind-blown or traffic generated dust, usingthe measures proposed in the SEE.

Trafficable areas onsite are sealed to reduceexposure to dust and site speed limits areenforced. Landscaping is in place in areas thathave not been sealed.

ü

EMP PerformanceMeasure (Table 4-1) ‘Dust’

No visible dust or odours noted leaving the Kingsgrove site. No air quality incidents or complaints wererecorded during the reporting period.

ü



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4.3 StormwaterTable 5 reports on environmental actions that have been carried out during the current reporting period in relation to stormwater. It is anticipated that therelevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance withthe Stormwater Management Strategy.

Table 5 Summary of Stormwater Management Actions Undertaken during 2016


or Commitment?Consent Condition 4.6 A spill tank must be placed beneath coupling points of the

edible oil tanker and the above ground edible oil tank.Occasional spot checks confirmed spill trays wereused on trucks in accordance with the stormwatermanagement strategy.

ü

Consent Condition 4.7 Tankers supplying edible oil must use brake interlocks. Brake interlocks are a condition of entry to the sitefor edible oil tankers.

ü

Consent Condition 4.8 Bunding must be provided around the edible oil tank, with aminimum capacity of 110% the volume of the tank.

The bund capacity and condition was checkedduring weekly visual inspection activities.

ü

Consent Condition 4.9 Stormwater isolation valves must be installed at allstormwater exit points from the site.

The correct function of isolation valves waschecked regularly. Stormwater pits were checkedweekly during routine visual inspections andmaintenance undertaken when necessary (e.g.removal of leaves and debris).

ü

EMP PerformanceMeasure (Table 4-1)‘Stormwater’

No pollution of nearby waterways. No water pollution incidents or complaints wererecorded during the reporting period.

ü



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4.4 TrafficTable 6 reports on environmental actions that have been carried out during the current reporting period in relation to traffic. It is anticipated that the relevantconditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with theTraffic Management Plan.

Table 6 Summary of Traffic Management Actions Undertaken during 2016



or Commitment?Consent Condition 4.17 The Applicant must prepare and implement a Traffic

Management Plan for the development. The Planmust:a. Describe the routes which will be used by

trucks associated with the development;b. Outline the hours during which trucks will

operate in the vicinity of the site;c. Indicate the average and maximum number of

daily and weekly truck movements which willbe associated with the proposed development;

d. Describe in detail what measures andprocedures will be implemented to:- Minimise the number of trucks which will

be used to transport goods;- Minimise noise and vibration associated

with truck traffic;- Ensure tucks travel in a safe manner;- Minimise road damage;- Minimise air pollution from exhaust; and- Record and respond to complaints

regarding traffic.e. Incorporate monitoring to ensure the

requirements of the Traffic Management Planare being met (refer to Condition 6.4).

A Traffic Management Sub-Plan is included in Revision 3.1of the Environmental Management Plan dated 29 March2017. The plan was prepared as per requirements ofconsent condition 4.17.The Environmental Management Plan Revision 3.1,including the Traffic Management Sub-Plan, is provided inAppendix A.

ü



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or Commitment?Consent Condition 4.19 The Applicant shall review and, where necessary,

update the Traffic Management Plan annually aspart of the AEMR, and also as directed by the DG.

Traffic Management Plan included in Revision 3.1 of theEnvironmental Management Plan dated 29 March 2017.A review of traffic conducted by a Level 3 RMS safetyauditor has been undertaken on and around theKingsgrove site. Allied Mills are waiting on the finaldocument to be provided, however this reviews turningcircles, pedestrian access around site and traffic flow.

ü

Consent Condition 6.4 The Applicant must monitor compliance with theTraffic Management Plan described in Condition4.17. Monitoring must occur within three months ofcommissioning the mixing plant, and every sixmonths thereafter.

All site activities were undertaken in accordance with theTraffic Management Plan during the reporting period.Records are kept of delivery and dispatch vehicles that areon site to inform scheduling activities. Traffic monitoringdata is presented in Section 5.3 of the AEMR along with ananalysis of the results and comparison to historical data toidentify any evident trends.

ü

EMP PerformanceMeasure (Table 4-1)‘Traffic’

No notable impact to the surrounding communityfrom traffic generated at the Kingsgrove site.

No traffic related incidents or complaints occurred in thereporting year.

ü



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4.5 Landscape ManagementTable 7 reports on environmental actions that have been carried out during the current reporting period in relation to land management. It is anticipated thatthe relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordancewith the Landscape Management Plan.

Table 7 Summary of Landscape Management Actions Undertaken during 2016


Relevant Condition, Performance Measure orSafeguard Actions carried out in 2016

MeetingCondition orCommitment?

Consent Condition 4.29 The Applicant must prepare and implement a detailedLandscape Management Plan for the development. Thisplan must:· Describe in detail how the site will be

landscaped, including the location and species ofall planting; and

· Explain how this landscaping will be managedand maintained over time.

Landscaping activities were undertaken in accordance withthe Landscape Management Plan. Landscaping wasmanaged and maintained by a contractor on a fortnightlybasis. Regular maintenance activities undertaken duringthe current reporting period included:· Slashing / mowing of grassed areas;· Trimming /shaping of shrubs;· Collection of fallen branches and debris; and· General maintenance works as required.

ü

Approved byDP&E on 4 August

2014

EMP PerformanceMeasure (Table 4-1)‘Aesthetic Impacts /Landscaping’

No aesthetic impact to the surrounding community. No landscaping related complaints were recorded duringthe reporting period.

ü



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4.6 Waste ManagementTable 8 reports on environmental actions that have been carried out during the current reporting period in relation to waste management. Waste generated asa result of site activities is managed in accordance with the Waste Management Plan. Allied Mills will continue to review the waste requirements of the site onan annual basis and update the Waste Management Plan if required.

Table 8 Summary of Waste Management Actions Undertaken during 2016

Consent Condition /Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016


Consent Condition 4.26 The Applicant must prepare and implement a WasteManagement Plan for the development in consultation withCouncil. This plan must describe in detail the wastemanagement system, including:a. The types and quantities of waste which will be generated

at the site; andb. How waste will be stored on-site, transported, and

disposed of off-site.

A Waste Management Sub-Plan is included inRevision 3.1 of the Environmental ManagementPlan dated 29 March 2017. The plan wasprepared as per requirements of consentcondition 4.26.

The Environmental Management Plan Revision3.1, including the Waste Management Sub-Plan,is provided in Appendix A.

ü

EMP PerformanceMeasure (Table 4-1)‘Waste’

All waste to be correctly stored on site and disposed of by anappropriately licenced contractor.

No waste related incidents or complaints wererecorded during the reporting period.

ü



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4.7 Hazards and Site SafetyTable 9 reports on environmental actions that have been carried out during the current reporting period in relation to hazard management. Hazards and sitesafety are currently managed by the site Deflagration Management Strategy (DMS) and the Emergency Management Plan. The DMS Report covers themanagement of dusts, control systems, extraction systems and fail-safe systems employed, whilst the Emergency Management Plan details emergencyprocedures for the site.

Table 9 Summary of Hazard Management Actions Undertaken during 2016

Consent Condition /Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016


Consent Condition 5.4 Dangerous Goods storage must be in accordance with theAustralian Dangerous Goods Code, relevant Australian Standards,and WorkCover requirements. Spill clean-up kits and proceduresmust be made available and used in the event of a spill.

A WorkCover Notification ofHazardous Chemicals has beencompleted for the Site (NDG035076,13 February 2015). Should anysignificant changes occur to thequantity, location or manner ofstorage of the relevant chemicals,WorkCover will be notified of theamendment.

Spill kits are stocked and provided atthe edible oils station.

ü

Consent Condition 8.3 Twelve months after the commencement of operations, and everythree years thereafter, unless the Director-General directsotherwise, the Applicant must commission and pay the full cost of acomprehensive hazard audit.

GHD undertook an IndependentHazard Audit during the reportingperiod (2016a). The findings of theaudit and recommendations madeare provided in Section 6.1 andSection 7.0 of this AEMR.

ü



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5.0 Analysis of Environmental Monitoring ResultsIn accordance with Schedule 2, Condition 7.1(e) of the Consent, this section presents an analysis ofthe detailed environmental monitoring undertaken during the reporting period and identification of anytrends in the results compared to previous years. In order to compare current monitoring resultsagainst historical results, only environmental aspects with specific, quantified monitoring results areincluded in this section (noise, transport and waste monitoring).

Other environmental aspects included as part of the Environmental Monitoring Program (air quality,stormwater and landscaping) do not have quantifiable results and a review of the Site’s performanceagainst these aspects is provided previously in Section 4.0.

5.1 Annual Production5.1.1 Monitoring Results

Annual production is limited under Schedule 2, Condition 1.3 of the Consent to 150,000 tonnes perannum. Production output remained within the approved limits during the reporting period at 58,912tonnes and is presented for each month in Table 10.Table 10 Production output during the reporting period

Month Monthly production (tonnes)

January 2016 4,917

February 2016 5,198

March 2016 5,133

April 2016 4,036

May 2016 4,918

June 2016 5,363

July 2016 4,703

August 2016 4,453

September 2016 5,789

October 2016 4,375

November 2016 4,693

December 2016 5,334

Total 58,912

5.1.2 Identification of Trends

A comparison of annual production for the current reporting period against historical records isprovided in Table 11 and shown graphically in Figure 2. Total annual production has decreasedmarginally compared to 2015 and is approximately 15% less than the 2013 production. Overallproduction trends however remain relatively consistent and well within the approved limit of 150,000tonne per annum for the site.



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Table 11 Historic Annual Production Volumes

Year Total annual production

2013 69,142

2014 61,000

2015 60,065

2016 58,912

Figure 2 Historic Annual Production Volumes

5.2 NoiseNoise monitoring is required to be undertaken upon receipt of a substantiated community complaintregarding noise. The AEMR captures both any outstanding resolution of noise complaints from theprevious reporting year as well as noise complaints that occur in the reporting year. Further details ofactions taken are detailed in Section 4.1.

With respect to previous reporting year noise complaint resolution, in October 2015 a noise complaintwas made regarding an intermittent noise heard by nearby residents over the previous year. AlliedMills commissioned an external noise audit which was undertaken in January 2016, involving attendednoise measurement relating to the blower plant room. Attended noise measurements showed that thenoise emission contribution from the blower plant room exceeded the acceptable noise criteria at nightat nearby residence. Noise control recommendations were made, providing various options. Acousticlouvres were chosen as the control measure and installed on the 29 September 2016. During thefabrication of the louvres temporary measures were taken, specifically the temporary covering of theplant vent. Updates of the noise assessment and actions were communicated to DP&E on the 26August and 21 November 2016.

Three noise complaints were registered in the reporting year as detailed below.

The first was registered on the 5 January 2016 when council advised they had received a complaintfrom a community member. The complaint was associated with the previous noise issue identified in2015. As previously detailed for the 2015 complaint, a noise impact assessment was prepared andactions taken to resolve the issue, specifically the temporary covering of an identified vent andsubsequent installation of an acoustic louvre.



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The second was registered on the 23 September 2016 when council advised they had received acomplaint from a community member from a noise occurring on the 10 September 2016. A review ofsite operations identified that a vent cover previously installed to minimise noise was temporarilyremoved at the time of the complaint due to over-heating issues. At the time of the complaint anacoustic louvre was still being fabricated and was subsequently installed on the 29 September 2016.

The third noise complaint was registered on the 28 November 2016 when council advised they hadreceived a complaint from a community member of a grinding noise especially at night. The noise wassimilar to that experienced in January and started again in September, around the time of the previouscomplaint relating to the removal of the vent cover. Since this time an acoustic louvre had beeninstalled. Noise monitoring was undertaken between the 27 and 31 of October at residential receivers.The monitoring reported that the site was compliant with noise requirements as per the sitesconditions of the Consent. A further partition was installed in the blower room which alleviated noiseissues, as confirmed by the affected resident.

5.3 Traffic5.3.1 Monitoring Results

The site records the total number of truck movements each month, from which weekly and daily truckmovements can be extrapolated. Total monthly truck movements and average weekly / daily truckmovements for the reporting period are presented in Table 12 along with the monthly production data.

At the previous request from the DP&E an estimate of potential traffic movements at the full approvedproduction capacity of 150,000 tonnes per annum was undertaken. It is noted that traffic generation isnot directly correlated with production, as deliveries of raw materials and final product may differdepending on the product. However an estimate of potential maximum truck movements has beencalculated based on the traffic and production data for the 2016 reporting period. This was estimatedby calculating the average of the monthly truck/tonne, and multiplying this by the full productionvolume of 150,000 tonnes. Potential maximum truck movements at full production capacity areincluded in Table 12 and Table 13.

It is noted that traffic projections were presented in the Traffic Impact Statement (Rhodes ThompsonAssociates, 2001) prepared as part of the SEE for expansion of the Site. The maximum number oftrucks per day was projected to be 97 during the day and afternoon shifts and 12 during the night shift,with a total of 109 daily truck movements. This equates to a total of 763 truck movements per week,3,315 truck movements per month, and 39,785 truck movements per annum. These projections arealso shown in Table 12 and Table 13 for comparison with the current year’s reporting data. It is alsonoted that the Consent for the project does not specify a limit on truck movements, however Condition4.17 requires the Traffic Management Sub-Plan (TMP) to ‘indicate the average and maximum numberof daily and weekly truck movements which will be associated with the proposed development ’. TheTraffic Management Sub-Plan included in Revision 3.1 of the Environmental Management Plan dated29 March 2017, provided in Appendix A, includes the same traffic values reported in the SEE asprovided above.

For the purposes of this AEMR, truck movements during the reporting period have been compared tothe potential maximum truck movements at full production capacity calculated based on the 2016reporting data. The Traffic Management Sub-Plan has been revised in the current period toincorporate projected maximum traffic volumes. Once the revised TMP is approved (by DP&E), futureAEMRs would report against these projected maximum traffic volumes.



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Table 12 Truck movements during the reporting period

MonthTotal monthlytruckmovements

Averageweekly truckmovements

Averagedaily truckmovements

Monthlyproduction(tonnes)

Projected maximum predicted inTraffic Impact Statement andTraffic Management Sub-Plan

3,315 763 109 150,000(Annual)

Potential maximum at fullproduction, based on 2016 data

1,413 326 46 150,000(Annual)

January 2016 543 135 18 4,917February 2016 557 139 19 5,198March 2016 489 122 16 5,133April 2016 488 122 16 4,036May 2016 510 128 16 4,918June 2016 469 117 16 5,363July 2016 653 163 21 4,703August 2016 638 160 21 4,453September 2016 525 131 18 5,789October 2016 595 119 19 4,375November 2016 555 111 19 4,693December 2016 556 111 18 5,334Total 58,912


Historically, traffic movements recorded as part of day to day operations have been limited tomovements generated as a result of product delivery and dispatch; in accordance with the TrafficManagement Plan (TMP). During review of the TMP (undertaken during the current reporting period)the distinction between product loads bound for the warehouse and bulk tanker loads (bound for bulkdelivery) has been clarified. Consequently monitoring activities have been expanded beyond productdispatch to reflect all production related traffic movements to and from site.

A comparison of traffic monitoring data for the current reporting period against historical trafficmonitoring results is provided in Table 13 and is shown graphically in Figure 3. The total number ofannual truck movements recorded increased during the current reporting period, however total annualproduction was lower. Whilst the increase in recorded truck movements relates partially to expandedmonitoring efforts, product movements accounted for a high proportion (4,966 of 6,578) of movementsidentified in Table 13. This highlights the fact that traffic generation does not directly correlate toproduction levels and may fluctuate depending on market demand and supply chain requirements.

Traffic movements remain well below the projected maximum traffic movements estimated for a fullproduction scenario, as shown in Figure 3. The potential average monthly value provided in the figureis calculated from the potential annual value from the below table divided by twelve months.



21

Table 13 Comparison of historical truck monitoring data

YearAnnual totaltruckmovements

Average weeklytruck movements

Total annualproduction

Projected maximum predicted inTraffic Impact Statement andTraffic Management Sub-Plan

39,785 763 150,000

Potential maximum at fullproduction, based on 2016 data

16,953 326 150,000

2013 3,893 75 69,142

2014 3,775 73 61,000

2015 3,840 74 60,065

2016 6,578 127 58,912

Figure 3 Comparison of historical monthly truck monitoring data for most recent three years

Note: The Traffic Impact Statement (2001) predicted a maximum of 3,315 trucks per month



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5.4 Waste5.4.1 Monitoring Results

Allied Mills continues to source recycled options where possible for the removal of waste from the Site.All paper waste and putrescible waste is removed from site and recycled. Waste streams include thefollowing:

· General Waste (putrescible) is the waste generated from the production process and mainlycomprises edible (for animals) material from flush outs through cleaning. This material is recycledby being sold to farmers to feed animals.

· General Waste (non-putrescible) includes general site waste and paper waste which is recycled.These recyclables and wastes are removed off site by licensed contractors.

· Hazardous Waste includes small quantities of chemical waste generated from analytical testing inthe test baking/laboratory area. These wastes are removed off site by a licensed contractor.

· Liquid Waste is in the form of oil used in food manufacturing. This is generated in small quantitiesduring overflow from receival or transfer processes. This is collected by an oil recycling company.

· Special waste generated from plant maintenance and removed from site by a licenced contractor.

· There continues to be no restricted waste generated at the Site.

Monthly waste quantities generated for each waste stream during the current reporting period areprovided in Table 14. The proportion of General Waste (non-putrescible) that was recycled ordisposed of to landfill for the current reporting period is provided in Table 15. Average weeklyquantities provided in the table are from the Waste Management Sub-Plan (WMP) as provided inRevision 3.1 of the Environment Management Plan dated 29 March 2017, provided in Appendix A.



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Table 14 Monthly waste quantities generated during the reporting period

Month

Waste Stream

General Waste(putrescible)(tonnes)

GeneralWaste (non-putrescible)(tonnes)

HazardousWaste(litres)

LiquidWaste(litres)2

SpecialWaste

RestrictedWaste

Monthly quantitiesfrom predictions inWMP1

30 33 9 217 43 0

January 2016 17.6 22.14 0 0 0 0

February 2016 15.5 24.66 0 370 0 0

March 2016 21.2 25.36 0 140 0 0

April 2016 20.8 32.66 0 0 360L 3 0

May 2016 18.5 21.08 0 0 0 0

June 2016 18 20.26 0 0 0 0

July 2016 30.6 24 20 560 0 0

August 2016 27.3 27.96 0 0 0 0

September 2016 31.8 19.42 0 470 0 0

October 2016 33.4 24.64 0 0 0 0

November 2016 28.5 17.65 0 140 0 0

December 2016 22.2 26.84 0 0 0 0

Total 285.4 286.67 20 1680 360 01 Waste Management Sub-Plan as provided in Revision 3.1 of the Environment Management Plan provides indicative weeklyquantities, from which these monthly quantities have been calculated.2 Liquid Waste predictions have been converted from kg to litres using a specific gravity of 0.92.3 Old machine oil from the maintenance department during clean-up

Table 15 Proportion of General Waste (non-putrescible) recycled or disposed of to landfill during the reporting period

ParameterGeneral Waste (non-putrescible)

Non-recyclable (disposed of tolandfill) Recycled

Total (tonnes) 122.9 163.8Percentage of total 42.9% 57.1%Average weekly (tonnes) 2.4 3.2


A comparison of annual waste quantities for the current reporting period against historical results isprovided in Table 16. The quantity of General Waste (putrescible) generated at the Site has increasedeach year since 2012, with 2016 having the highest annual quantity to date, however this remainslower than the Waste Management Sub-Plan predictions.

There are a number of historic factors which have influenced this trend within previous reportingperiods, including:

· A change to the supply method for some ingredients (from bulk tanker to bags which results in anincrease in paper waste for recycling). It is hoped that this supply will revert to bulk tanker in thefuture but the timing of this is not certain.



24

· Commissioning and production on the Line 3 mixing and packing line (which has involved anincrease in the number of bagged ingredients used on site during the commissioning process).

· Some re-bagging of finished product to assist the business resulted in approximately 36,000 bagsbeing added to recycled waste.

· Wastage data has been obtained directly from waste collectors allowing for more accurate data tobe collected.

During the current reporting period a review of operations resulted in diversification of productsproduced and other process improvements; prompting adaptation of the site inventory. The type andquantity of stock held on site was optimised, with surplus materials contributing to general and liquidwaste streams. Allied Mills continues to investigate new recycling initiatives aimed at recyclingplastics, pallets and reducing waste generated through the current bagging process.

Of the general waste (non-putrescible) generated on site during the reporting period, approximately43% was disposed of to landfill and 57% was recycled.

The quantity of Hazardous Waste generated on Site has continued to decrease since 2013, with 2016having the lowest annual quantity to date and below the quantity predicted in the Waste ManagementSub-Plan.

The quantity of Liquid Waste generated at the Site has also varied in the last four years with noapparent trend. The quantities of Liquid Waste removed off site in 2013 and 2014 were higher than thepredictions made in the Waste Management Sub-Plan, whilst 2015 and 2016 were below. 2013 and2014 levels were a result of 3 isolated incidents, the outcomes of which are addressed in previousAEMR periods. Liquid waste is removed from site by licenced subcontractor and recycled inaccordance with industry best practice.Table 16 Comparison of historical waste monitoring data

Year

Waste StreamGeneralWaste(putrescible)(tonnes)

GeneralWaste (non-putrescible)(tonnes)

HazardousWaste(litres)

LiquidWaste(litres)2

SpecialWaste

RestrictedWaste

Annual quantities frompredictions in WMP1 364 390 104 2600 520 0

2013 144 258 111 5,241 0 0

2014 146 265 70 2,625 0 0

2015 170 277 50 165 0 0

2016 285 287 20 1,680 360 01 Waste Management Sub-Plan as provided in Revision 3.1 of the Environment Management Plan provides indicative weeklyquantities, from which these annual quantities have been calculated.2 Liquid Waste predictions have been converted from kg to litres using a specific gravity of 0.92.



25

6.0 Non-Compliance, Incidents and ComplaintsUnder Condition 8.1 of the Consent, the proponent is required to notify the DP&E of any accident orpotential incident with actual or potential off-site impacts on people or the biophysical environment. Asummary of non-compliance is required under Condition 7.1 (f) which states “Where non-complianceis occurring, describe what actions are or will be taken to ensure compliance, who will be responsiblefor carrying out these actions, and when these actions will be implemented.”

General responsibilities and actions for responding to non-compliances are detailed in the EMP.These include:

· The Training, Safety, Health and Environment (TSH&E) Coordinator is to be informedimmediately;

· The TSH&E Coordinator must identify an appropriate corrective action;

· The TSH&E Coordinator must communicate the appropriate corrective action to the SiteManager;

· The Site Manager must then implement the corrective action or delegate authority over the actionto an appropriate person;

· Any non-compliance and the actions taken are to be recorded and included in the AEMR; and

· If the non-compliance constitutes a pollution event that may cause material environmental harm,the emergency response procedure will be followed and the appropriate government authoritieswill be notified immediately.

All incidents and complaints are recorded in the Incident Reporting Database:

· The date and time, of the complaint or incident;

· The means by which the complaint or incident was made;

· Any personal details that were provided, or;

· Any action(s) taken by the Allied Mills Kingsgrove in relation to the complaint or incident, includingany follow up contact with complainant/reporter; and

· If no action was taken by Allied Mills Kingsgrove in relation to the complaint or incident, thereason(s) why no action was taken.

6.1 Non-compliances Recorded during the Current Reporting PeriodThe Independent Hazard Audit 2016 and Independent Environmental Audit 2016 identified non-compliances for the reporting period. These non-compliances are summarised in Table 17, togetherwith any non-compliances reported for the site not listed in such documents. Recommendations madeand the actions taken by Allied Mills to rectify these non-compliances are provided in Section 7.0.

Table 17 Summary of Non-compliances for the Site

Details of Non-Compliance Audit FindingGeneral non-compliances not reported in audits, reports or similarNo general non-compliances for 2016 AEMR

Independent Hazard Audit 2016NC5.1, 3.4.5/3, The clearance space around theFire Indicator Panel does not comply with therequirement of AS 1670.1-1995.

Obtain advice from the Fire Brigade, the localCouncil or an independent fire engineer todetermine whether the reduction in spacingcompromises access to the FIP panel. Implementrecommendations from the advice.



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Details of Non-Compliance Audit FindingIndependent Environmental Audit 2016Compliance with the Condition of Approval requirements

3.6 The Applicant must ensure that a copy of theEnvironmental Management Plan is submitted toCouncil and is publicly available.

The original Environmental Management Planwas sent to the Council via email in 2013. Arevised Environmental Management Plan,Revision 3.1, was sent to Council on 29 March2017.

The plan was not publically available on the AlliedMills web-site during the audit period. However, itwas loaded onto the Allied Mills website followingthe IEA in 2016.

No further action is required to address this non-compliance.

4.17(d). The Applicant must prepare andimplement a Traffic Management Plan for thedevelopment.

The plan does not detail what measures are usedto “Minimise the number of trucks which will beused to transport goods”.A Traffic Management Sub-Plan is included inRevision 3.1 of the Environmental ManagementPlan dated 29 March 2017, and provided inAppendix A. Section 5 of the Traffic ManagementSub-Plan details the measures to minimise thenumber of trucks.

4.18 The Applicant must develop the TrafficManagement Plan in consultation with the RTAand Council.

A Traffic Management Sub-Plan is included inRevision 3.1 of the Environmental ManagementPlan. The revised plan was submitted to theRMS on the 29 March 2017.

Feedback was received from the Roads andMaritime Services (formerly RTA) regarding theTraffic Management Plan indicating that nofurther input was required as the Crescent andsurrounding streets en-route to the site areregulated by Council.

4.22 Trucks servicing the site during constructionand operations must not park on The Crescent atany time.

Trucks accessing the site were monitored byvideo camera to monitor and prevent parking onThe Crescent.It is noted that Allied Mills received a trafficcomplaint in the previous reporting year (2December 2015) when an external utility provider(unrelated to Allied Mills) shutdown part of TheCrescent, without notice. Allied Mills spoke to thedriver and informed his company that he was nolonger welcome to deliver goods to the Site.No further action is required to address this non-compliance

4.24 The Applicant shall implement therecommendations of the “Traffic OperationsAssessment” prepared by Sinclair Knight Merzprovided in support of DA 143-06-01 MOD 2, anddated 7 November 2011, specifically:(a) parking restriction signage in the vicinity ofGate A on the Crescent;

Advanced signage has been added to theentrance at Gate A and the angle of the existingtraffic light head was modified to improve thesightline for incoming drivers.Allied Mills submitted a request for thecarriageway centre-line and “No Parking” signageto the Georges River Council. However the



27

Details of Non-Compliance Audit Finding

(b) a carriageway centre-line in the vicinity ofGate A; and(c) advance signage or a secondary traffic lighthead in the vicinity of Gate A,in consultation with Council, and to thesatisfaction of the Director-General, within 6months of the approval of DA 143-06-01 MOD 2.

Council advised on 24 July 2013 that they did notsupport the application.

6.1 The Applicant must prepare and implement adetailed Environmental Monitoring Program forthe development in consultation with the EPA.

This requirement was addressed in the AlliedMills Kingsgrove - Environmental ManagementPlan (SKM, V03, 17 November 2015)It is noted that the Environmental ManagementPlan was approved by DPE however the EPAwas not consulted in the development of theenvironmental monitoring programIt is noted that the site surrendered itsEnvironmental Protection Licence in 2001 hencethe EPA no longer regulates this premises.

Compliance with the SEE requirements

14. It is further recommended that the site willdevelop an environmental management system(EMS). The EMS should be developed with theguidance of the ISO 14001 series of standardsand should include but not be limited to:a) Environmental Management Plan (EMP)b) Emergency Planc) Fire Manifestd) Training Program

The site does not have a specific EMS, howeverthe site does have in place the followingdocuments that address each of the items raisedin the SEE:· Environmental Management Plan (EMP)· Emergency Plan· Fire Manifest· Training Program

Compliance with the request for modifications requirements

6. It is recommended that parking restrictions areput in place in the vicinity of the access to prohibitparking during the delivery hours specified in theTraffic Management Plan, i.e. 6.30am to 8.00pm.Furthermore, centre line markings could beintroduced to ensure vehicles travellingnorthbound on The Crescent do not cross into theopposite carriageway and occupy the spacerequired for vehicles exiting the site.

The recommendations of the audit weresubmitted to Council for consideration butultimately not endorsed based on Council’sconsideration of the existing traffic environment.As these recommendations affect a public roadCouncil endorsement is required to support anyfurther action.

For site bound traffic, parking restrictions areimplemented in accordance with the TrafficManagement Plan in the vicinity of the access toprohibit parking during the delivery hours (i.e.6.30am to 8.00pm).

Advanced signage has been erected at the siteentrance advising operators not to que in thedriveway.

There is no exit from Gate B in accordance withthe TMP.

7. Re-align the existing pedestrian route alongthe northern edge of the site, resulting in one lesscrossing of the vehicular route and greatervisibility for drivers to pedestrians. Thisrecommendation is relative to both one and two-way traffic movements;

Allied Mills advised that realignment of thepedestrian route was considered however itwould result in the loss of parking places andwould not necessarily improve pedestrian safetyon the site.



28


A review of traffic conducted by a Level 3 RMSsafety auditor has been undertaken on andaround the Kingsgrove site. Allied Mills arewaiting on the final document to be provided,which reviews turning circles, pedestrian accessaround site and traffic flow.

Details of a shared pedestrian zone have beenincluded in the TMP based on the preliminaryfindings of the traffic review.

7. Introduce parking restrictions in the vicinity ofGate A which prohibits vehicles parking between6.30am and 8.00pm, when delivery vehicles enterthe site. In addition, considerationshould also be given to the introduction of acarriageway centre line at these locations. Thesemeasures are relative to both one and two-waytraffic movements;

For site bound traffic, parking restrictions areimplemented in accordance with the TrafficManagement Plan in the vicinity of the access toprohibit parking during the delivery hours (i.e.6.30am to 8.00pm).

Advanced signage has been erected at the siteentrance advising operators not to que in thedriveway.

2013 IEA Recommendation

Request for Modification - 7. Allied Mills toconfirm its finalised approach to pedestrianmanagementwith DP&I.

Open.Allied Mills advised that realignment of thepedestrian route was considered however itwould result in the loss of parking places andwould not necessarily improve pedestrian safetyon the site.A review of traffic conducted by a Level 3 RMSsafety auditor has been undertaken on andaround the Kingsgrove site. The outcomes of thereview have informed the Traffic ManagementPlan and a shared pedestrian zone has beenadopted as a result.

ISE 2001 - 4.3. Air quality standards andcalibration requirements be formally recorded:· Ensure calibration method is appropriate;

suggest that written advice is sought andpresented for the next audit.

· Ensure that during maintenance calibrationis conducted regularly (e.g. at everymaintenance instance if this is deemedappropriate) and recorded. This could bedone by adding a calibration point to themaintenance sheet that states the date,confirms calibration was conducted and theresult.

Closed

Calibration of the particulate monitors wasundertaken in December 2013 however acalibration point was not added to themaintenance sheet.

It is noted that the Site is taking practicablemeasures to prevent or minimise air. Clarificationwas provided to DP&E on 30 September 2016and endorsed by DP&E representative on9th December 2016.

Maintenance and calibration procedures havebeen included in the maintenance schedule forthe site.

DP&E Audit 2015N1. Some recommendations from the most recentIHA (September 2013) have not been closed.

The Proponent should implement all outstandingrecommendations from the most recent IHA. Anaction plan should be submitted to theDepartment to detail how each outstanding



29


recommendations was closed.

An IHA was undertaken by GHD in 2016. Anynon-compliance reported in the IHA is provided inSection 6.1 of this AEMR, with the actionsundertaken by Allied Mills discussed inSection 7.0.

Finding is considered to be closed.

N2. The most recent IHA was carried out inSeptember 2013. This audit was undertaken byAECOM and included 17 recommendations. Atthe time of the site inspection in May 2015, theaudit report had not been fully accepted by theDepartment for the following reasons:· Insufficient information was provided making

it difficult to establish which operations andelements of the SMS had been audited.

· The report did not include information onchanges that had occurred since the 2010IHA.

· The report did not include the status of eachrecommendation from the 2010 IHA.

· The report did not acknowledge or provideupdate on the fact that the 2010 IHA wasconditionally approved by the DP&E subjectto provision of additional information.

An IHA was undertaken by GHD in 2016. Anynon-compliance reported in the IHA is provided inSection 6.1 of this AEMR, with the actionsundertaken by Allied Mills discussed inSection 7.0.

Finding is considered to be closed.

N3. Some recommendations from the most recentDeflagration Management Strategy Report(December 2013) have not been implemented.Failure to implement the approved DMS is anaction carried over from the findings of theDP&E’s 2013 compliance audit.

The Proponent should implement all outstandingrecommendations from the most recentDeflagration Management Strategy Report(Appendix C). An action plan should be submittedto the Department to detail how each outstandingrecommendations was implemented.

Additional evidence was submitted and DP&Econfirmed (letter dated 17 December 2015) thatoutstanding actions had been adequatelyaddressed.

N4. The development consent requires that adocument setting out a comprehensive SMS besubmitted to the DP&E. Following the 2013compliance campaign, Allied Mills submitted adocument that ‘mapped’ the contents of theirSMS against the requirements included in HIPAPNo. 9. The SMS ‘map’ has not been approved bythe DP&E.

Allied Mills should submit additional information tothe DP&E to demonstrate compliance withCondition 5.3(b) of the Consent.

Allied Mills submitted a document mapping thecontents of its Safety Management System (SMS)against the requirements of Hazardous IndustryPlanning Advisory Paper (HIPAP) No. 9 (DP&E,2011a). DP&E approved the SMS mappingdocument on 28 October 2015.

6.2 Incidents Recorded During the Current Reporting PeriodA summary of the incidents reported during the current reporting periods is provided below in Table18. Complaints are not categorised as incidents for the purposes of this report section; complaints arediscussed in Section 6.3.



30

Table 18 Summary of Incidents for the Site

Date Details Action Taken

February 2016 High level alarm did not activatewhich caused 150+ litres of oil tooverflow from silo. There was no spillto drains or external to site.Contained in oil silo room.

Spill contained on site however incidentlogged as potential to discharge into drains.Overflow alarm maintenance undertaken.

July 2016 Minor oil spill contained to site.Manual handling error of a smallcalibration oil container while exitingroom.

Staff involved in incident have been re-trained in manual handling procedures.

August 2016 Flour spill on driveway. Suctionblower stopped due to the silo beingfull, however the full signal did notalert outside, allowing the transferpipe to block up. When the pipe wasdisconnected from the truck theresidual pressure pushed flour outand onto the driveway.

Spill contained on site however incidentlogged as potential to discharge into drains.Full level alarm maintenance undertaken.

September2016

Exhaust vent leaking small amount ofdust onto driveway.

Filter bag has been placed on the unit.

November2016

Fire alarm false alert. Sensor waspossibly set off by dust as there wasno fire. Fire brigade attended site.

Fire brigade arrived checked but couldn’t findthe faulty sensor. Reset zone back to normaland fire brigade chief gave the ok to return towork.

6.3 Complaints Received During the Current Reporting PeriodThree complaints were recorded for the Site during the current reporting period. One complaint wasassociated with that registered in October and have been progressed together. A summary ofcomplaints received relevant to the ongoing operation of the site, along with the action taken by AlliedMills staff to address any issues, is shown in Table 19.

Table 19 Summary of Historical Complaints Received for the Site

Date Complaint Received Action Taken

28 November2016

Noise: Complaint lodged with Councilregarding grinding noise, especiallyat night.

Noise monitoring was undertaken betweenthe 27 and 31 of October at residentialreceivers. The monitoring reported that thesite was compliant to noise requirementsas per the sites conditions of the Consent.

An additional partition was installed in theblower room which eliminated this issue(based on feedback from the affectedresident).

23 September2016

Noise: Complaint lodged with Councilregarding a noise from the site. Sitestaff identified that the cover placedon the blower vent previously toattenuate noise was temporarilyremoved due to heating issues.

An acoustic louvre was installed on theblower vent on 29 September 2016 toattenuate noise from the source. Noisemonitoring after installation confirmedacceptable levels and no other mitigationwas required.

21 October Noise: Complaint lodged with Council A noise audit was undertaken in January



31

Date Complaint Received Action Taken

2015 and 5January 2016

regarding noise heard at night/earlymorning on an intermittent basis overthe past year. Additional informationprovided on 5 January 2016 led tothe identification of a potential sourceof noise on the Site (ventilation ductfor the blowers on level 5).

2016 for the likely noise source, the blowerplant. Attended noise measurementsshowed exceedances at night at nearbyresidence. Noise control recommendationswere made and an acoustic louvre wasinstalled on the 29 September 2016.During the louvres fabrication a temporarycover was installed on the vent. Noisemonitoring after installation confirmedacceptable levels and no other mitigationwas required.



32

7.0 Recommendations and Action PlanTable 20 provides a summary of the recommendations made during audits and similar workundertaken during the reporting period, as well as recommendations identified through the AEMRprocess (such as resolving complaints) identified as general recommendations. The actions taken orproposed to be undertaken to address each of the recommendations are provided, along with theperson responsible for ensuring the actions are carried out and the proposed timing.

The table presents outstanding items from the previous reporting year as provided in the 2015 AEMRand as requested in DP&E correspondence dated 4 March 2016. General comments are providedupfront, whilst those associated with an audit/report carried out in the previous AEMR reporting yearare provided under the audits/reports heading.

The table provides outstanding recommendations and plans from the DP&E Hazard Audit 2015 fromthe 2015 AEMR. Items that were considered to be closed during 2015 AEMR have not beenreproduced in this AEMR; only actions outstanding in the current reporting year.

The recommendations as an outcome of the Noise Impact Assessment 2016 are presented in Table20 along with the actions taken to address each of the issues.

The non-compliance recommendations as an outcome of the IHA 2016 and IEA 2016 are presented inTable 20 along with the actions taken to address each of the issues.

In addition to the audits listed above, the DP&E provided written correspondence dated 4 March 2016stating that the department is generally satisfied that the 2015 AEMR meets requirements of Condition7.1 of the Consent, however detailed items that should be addressed in future AEMRs. These itemsare presented in Table 20 along with the actions taken to address each of the issues.

Allied Mills commits to the actions set out in Table 20 in order to ensure compliance with theconditions of the Consent.



33

Table 20 Recommendations and Action Plan

Reference Recommendation Action Required / Undertaken PersonResponsible Timing

General recommendations and actions not covered within audits, reports or similar as detailed in the following sectionsSection 5.3 Upon completion and approval of the Traffic

Management Plan, update the projectedmaximum traffic volumes.

Traffic Management Sub-Plan included inRevision 3.1 of the EnvironmentalManagement Plan. The maximum trafficvolumes are consistent with previousreported values and hence remainunchanged in this AEMR.

Ros Herron March 2017

Completed

Section 5.4 Upon completion and approval of the WasteManagement Plan, update the projectedwaste quantities.

Waste Management Sub-Plan included inRevision 3.1 of the EnvironmentalManagement Plan. The maximum wastevolumes were updated from previousvalues and these values have beenincluded in this current AEMR.


Completed

2015 AEMR – General actionsSection 4.1 Table 3Section 6.3 Table 19

A noise audit is to be undertaken toinvestigate the noise source of a complaintregistered on 21 October 2015.

A noise audit was undertaken in January2016 for the likely noise source, the blowerplant. Attended noise measurementsshowed exceedances at night at nearbyresidence. Noise recommendations weremade and an acoustic louvre was installedon the 29 September 2016. During thelouvres fabrication a temporary cover wasinstalled on the vent. Insulation was alsoinstalled on the air intake.

Ros Herron September 2016

Completed

Section 4.4Section 5.3

It is recommended that the Plan be updatedto include the average and maximumnumber of daily and weekly truckmovements associated with production atfull capacity.

The average and maximum number ofdaily and weekly truck movementsassociated with production at full capacityhas been provided in Section 5.3 of thisAEMR.

Ros Herron AEMR submission

Completed



34


Section 5.4 It is therefore recommended that the WasteManagement Plan be revised to providemore accurate estimates of the wastequantities generated at the Site.

A revision to the Waste Management Planhas been undertaken. Due to thepreparation of the IndependentEnvironment Audit in 2016, it was decidedto delay the lodgement of the plan to theDP&E so as to include anyrecommendations or modifications as anoutcome of the audit. An extension of timefor the submission of the AEMR and theEMP was granted by the DPE on 24th

February 2017. It is expected that therevised plan would be lodged in the firstquarter of 2017.


Ongoing

2015 AEMR – DP&E Hazard Audit 2015 – Outstanding actionsSection 6.1N1

The Proponent should implement alloutstanding recommendations from the mostrecent IHA. An action plan should besubmitted to the Department to detail howeach outstanding recommendations wasclosed.

The Action Plan has been submitted toDP&E on various occasions as theproposed actions were updated.An IHA was undertaken by theindependent consultancy GHD in 2016.

Ros Herron December 2016

Completed

Section 6.1N1 R2 (IHA 2013):

Review cleaning procedure for level 5 for alloverhead cleaning.Review level 5 pre-weigh hopper design anddetermine if changes will reduce dustescaping this area.

Cleaning procedure was updated andsighted by DP&E.The level 5 hopper design was reviewedby DP&E, and the modification completedin 2016.

Paul Maher November 2016

Completed

Section 6.1N2

The next IHA (which is due in 2016) shouldbe undertaken by an independent externalaudit team or auditor in accordance with theHIPAP No. 5 requirements and Condition8.3 of the Consent.

An IHA was undertaken by theindependent consultancy GHD in 2016 inaccordance with the conditions of theConsent and DP&E Hazard Audit 2015.

Ros Herron November 2016

Completed

Section 6.1N3

The Proponent should implement alloutstanding recommendations from the mostrecent Deflagration Management StrategyReport (Appendix C). An action plan should

DP&E Hazard Audit 2015 (DP&E, 2015)noted some recommendations from theDMS report had not yet been closed.Additional evidence was submitted and

Ros Herron December 2016

Completed



35


be submitted to the Department to detailhow each outstanding recommendationswas implemented.

DP&E confirmed (letter dated17 December 2015) that outstandingactions had been adequately addressed.

Section 6.1N4.

The development consent requires that adocument setting out a comprehensive SMSbe submitted to the DP&E. Following the2013 compliance campaign, Allied Millssubmitted a document that ‘mapped’ thecontents of their SMS against therequirements included in HIPAP No. 9. TheSMS ‘map’ has not been approved by theDP&E. Allied Mills should submit additionalinformation to the DP&E to demonstratecompliance with Condition 5.3(b) of theConsent.

Allied Mills submitted a document mappingthe contents of its Safety ManagementSystem (SMS) against the requirements ofHazardous Industry Planning AdvisoryPaper (HIPAP) No. 9 (DP&E, 2011a).DP&E approved the SMS mappingdocument on 28 October 2015.

Ros Herron October 2015

Completed

Noise Impact Assessment 2016Section 4.1 The roof exhaust outlet be treated with the

installation of an internally lined duct.Noise monitoring after installation of thelouvres showed acceptance to requiredcriteria and as such no further mitigationwas required.

Paul Maher September 2016

Action Completed

Section 4.2 Plant room intake opening mitigation options1. Install acoustic louvre2. Acoustically treated ductwork

An acoustic louvre was installed on theplant intake opening on 29 September2016

Paul Maher September 2016

Action Completed

Independent Hazard Audit 2016NC5.1, 3.4.5/3 The clearance space around the Fire

Indicator Panel does not comply with therequirement of AS 1670.1-1995.

Obtain advice from the Fire Brigade, thelocal Council or an independent fireengineer to determine whether thereduction in spacing compromises accessto the FIP panel. Implementrecommendations from the advice.

Ros Herron June 2017

Ongoing



36


Independent Environmental Audit 2016R1 Revise the Traffic Management Plan to

document the measures that will be put inplace to “Minimise the number of truckswhich will be used to transport goods”.

A Traffic Management Sub-Plan isincluded in Revision 3.1 of theEnvironmental Management Plan dated 29March 2017, and provided in Appendix A.Section 5 of the Traffic Management Sub-Plan details the measures to minimise thenumber of trucks.


Completed

R2 Submit a copy of the revised TrafficManagement Plan to Roads and MaritimeServices.

A Traffic Management Sub-Plan isincluded in Revision 3.1 of theEnvironmental Management Plan dated 29March 2017. The Plan is currently beingsent to RMS.


Completed

R3 To prevent ongoing non-compliance of trafficmanagement controls at entrance to the site,submit an application to DP&E to modify thiscondition to reflect the current agreed status.

Submit an application to DP&E to modifythis condition to reflect the current agreedstatus.

Ros Herron June 2017Ongoing

R4 Submit a copy of the EnvironmentalMonitoring Program to the EPA.

Environmental Monitoring Program Sent toEPA 1.11.16.

Ros Herron January 2016

Action CompletedR5 Undertake a gap analysis of corporate and

environmental policies and procedures anddevelop a site EMS.

Develop a site EMS. Ros Herron June 2017

Ongoing

R6 To prevent ongoing non-compliance of trafficmanagement controls related to pedestrianroutes on-site, submit an application toDP&E to modify this condition.

Allied Mills advised that realignment of thepedestrian route was considered howeverit would result in the loss of parking placesand would not necessarily improvepedestrian safety on the site.Submit an application to DP&E to modifythis condition.

Ros Herron June 2017

Ongoing

R7 Incorporate periodic calibration of air Site to engage contractor to finalise Paul Maher December 2016



37


monitoring equipment into the site’smaintenance schedule.

approach to calibration of air monitors andupdate maintenance procedures asrequired. Incorporate periodic calibrationof air monitoring equipment into the site’smaintenance schedule.

Completed

DP&E Correspondence dated 4 March 2016Page 1 All non-compliances against conditions of

consent must be reported in addition toreporting non-compliances arising fromaudits (or similar) undertaken during thereporting period.

All non-compliance at the site, not limitedto those in audits or similar, are provided inSection 6.1 of this AEMR.


Completed

Page 1 The Department requests that allsubsequent AEMRs include a sectionsummarising the status of actions arisingfrom the previous AEMR.

The status of actions arising from theprevious AEMR are provided in Section 7of this AEMR.


Completed

Page 1 Submit to the Department for approval anyproposed mitigation measures that arisefrom the noise audit undertaken in 2016.

Proposed mitigation were submitted to theDepartment on 26 August and asubsequent email confirming theinstallation of the mitigation on 21November 2016.

Ros Herron At completion of thenoise audit

Completed

Page 1 Update the Traffic Management Plan andWaste Management Plan as recommendedin Section 8.0 of the Report.

An updated Traffic Management Sub-Planis included in Revision 3.1 of theEnvironmental Management Plan dated 29March 2017.

An updated Waste Management Sub-Planis included in Revision 3.1 of theEnvironmental Management Plan dated 29March 2017.


Completed



38

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39

8.0 ConclusionThe Allied Mills Kingsgrove site operates a comprehensive environmental management program. Theresults of the AEMR for the current period demonstrate that the environmental performance of the siteis generally meeting expectations, and indicate that site personnel are following site procedures andmeeting their environmental responsibilities. A review of current environmental actions indicates thatthe site is routinely monitored on a weekly basis and this process has been demonstrated to ensurethe effective management and maintenance of infrastructure and activities on site.

The results of the detailed monitoring undertaken for traffic and waste have been included in thisAEMR. Traffic movements at the Site appear to be generally stable and are well below the levelspredicted in the SEE for the expansion of the Site. Waste quantities have been variable, with thequantity of General Waste (putrescible) generated at the Site increasing each year since 2012, with2016 having the highest annual quantity to date, however remains lower than the Waste ManagementSub-Plan predictions.

An updated Traffic Management Sub-Plan is included in Revision 3.1 of the EnvironmentalManagement Plan dated 29 March 2017 provided in Appendix A. An updated Waste ManagementSub-Plan is also included in Revision 3.1 of the Environmental Management Plan.

Outstanding items from the DP&E Hazard Audit in 2015, as detailed in the 2015 AEMR, have beenaddressed in this 2016 AEMR, with all items being closed out. During the reporting period both anIndependent Environmental Audit and an Independent Hazard Audit were undertaken by GHD in2016, with non-compliances identified and the recommendations made reported in this AEMR.

Non-compliances, incidents and complaints are handled through a site review process managedthrough the incident reporting database. The database ensures that all identified issues are accuratelydetailed and appropriately addressed in a timely manner.

The improved monitoring and analysis of waste and traffic data has identified further opportunities forimproved performance. For example, Allied Mills have started initiatives to review waste managementand look at opportunities to recycle plastics and export wooden pallets. This is evidence of thecontinuous improvement and corrective action process implemented at the site.

The results of the current AEMR demonstrate that the environmental actions currently undertaken onsite are adequate to effect compliance with the standards, performance measures, and statutoryrequirements the development is required to comply with. Allied Mills will continue to engage with thelocal community, Council, the DP&E and other regulatory authorities when required to ensure theefficient operation of the facility and to prevent or minimise harm to the environment.



40




41

9.0 ReferencesAECOM (2014) AMA Kingsgrove Processing Plant, Risk Management: Deflagration Strategy Support.Newcastle, AECOM Australia.

Benbow Associates (2001) Statement of Environmental Effect (SEE) for the Proposed Expansion toExisting Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove. Sydney, Dick Benbow &Associates Pty Ltd.

Day Design Pty Ltd (2016) Noise Impact Assessment – Blower Room allied Mills, 4 The Crescent,Kingsgrove, NSW, Peakhurst NSW, Day Design Pty Ltd.

DP&E (2015) Allied Mills Kingsgrove, 2015 Compliance Audit Campaign, Compliance Audit ReportAugust 2015. NSW: Department of Planning & Environment.

DP&E (2012) Notice of Modification - DA143-06-01 MOD 2. NSW: Department of Planning &Infrastructure.

DP&E (2011a) Hazardous Industry Planning Advisory Paper (HIPAP) No. 9 Safety Management.NSW: Department of Planning.

DP&E (2011b) Hazardous Industry Planning Advisory Paper (HIPAP) No. 5 Hazard Audits Guidelines.NSW: Department of Planning.

DP&E (2001) Determination of a development application for state significant & integrateddevelopment - File No. S01/00876. NSW: Department of Urban Affairs & Planning.

GHD (2015a) Follow-up Verification Audit for 2013 IHA4121. Sydney, NSW, GHD Pty Ltd.

GHD (2015b) Kingsgrove Hazardous Area Consultation - Close out Report. Sydney, NSW, GHD PtyLtd.

GHD (2016a) Allied Mills, Kingsgrove – Independent Hazard Audit, GHD Pty Ltd.

GHD (2016b) Allied Mills, Kingsgrove – Independent Environmental Audit, GHD Pty Ltd.

Rhodes Thompson Associates (2001) Traffic Impact Statement, Proposed Industrial Expansion Ref:21-070R (3), prepared by Rhodes Thompson Associates on behalf of Goodman Fielder Ltd.

SKM (2015c) Allied Mills Kingsgrove Environmental Management Plan. St Leonards NSW: SinclairKnight Merz.



42




AAppendix AEnvironmental

Management Plan



A-1

Appendix A Environmental Management Plan

Uncontrolled when printed.

Document Name KV-Environmental Management Plan Status In Production

SAP Document Number Effective Date 29.03.2017 Revision No. 3.110002331 Print Date 11/04/2017 Page 1 of 72

1. Overview of Environmental Management Plan (EMP)To ensure that all adverse impacts on the environment resulting from operations at the Kingsgrovesite are identified, assessed and, as far as is reasonably practicable, minimised. The site will follow theAllied Mills Environmental Management Policy and the Site Environmental Management Plan (EMP)and work within the Development Application 143-06-01 (as modified) for the site and the Conditionsof Consent pertained within this DA.

2. ReviewThis document will be reviewed annually and updated if required as part of the review process.

3. ResponsibilitiesResponsibilities, as set out in Section 8 below.

Number Document Name Location.10002331 Kingsgrove Environmental Monitoring Forms. Site Document10000348 Kingsgrove Emergency Response Plan Site Document10000036 AM Environmental Management Plan Central Document10000037 Waste Management Central Document

4. Plans4.1 Traffic Management PlanThe site shall follow the traffic Management plan as set out in this EMP.As a summary,No site employees shall park on The Crescent, and must utilise the staff parking area at the rear ofthe site.No trucks that are delivering or picking up product from the Kingsgrove site can park on TheCrescent prior to entering the site. The Kingsgrove site will control and monitor this by schedulingtrucks so they are spread across the day and week to reduce congestion of trucks onto the site. Thesite has cameras viewing The Crescent that are linked to the despatch department who can monitorthe traffic and trucks in the area.The Kingsgrove site utilises a traffic light system, with green indicating trucks can enter the site, while ared light indicates no site access for trucks. Street signage notifies trucks of this entry requirement.The warehouse Manager shall provide truck movement figures for each month and record them inthe site shared drive. The site Manager shall review the data on truck movements.The National logistics department shall provide the site with the bulk truck movement figures for eachmonth. The site shall record these in the site shared drive under environmental truck movements.

4.2 Landscape Management PlanThe Environmental Management Plan contains details for the site landscaping including a landscapemap and outline of the plant species on site. The Kingsgrove site shall maintain the site vegetationwith regular maintenance by a gardening contractor.

4.3 Waste Management PlanThe site has identified waste streams and removal of waste from the site. Where possible, waste willbe recycled to reduce the impact of waste on the environment. This includes putrescible waste(offal product), general waste, recycled waste, liquid waste and hazardous waste. Waste removalcontractors provide waste data per month. Monthly wastage will be recorded for the site in theKingsgrove computer shared drive.

4.5 Environmental Monitoring Requirements:4.5.1 Weekly MonitoringEach week the site will complete a monitoring program for the site. This will cover the monitoringrequirements for emissions, traffic, wastage, noise, landscaping, air quality and stormwater. Therequirements for this monitoring are documented in the EMP under Section 9, Table 9-2.Monitoring Form Located in this document




4.5.2 Noise ManagementThe site will operate in a manner to avoid excess noise. As per the site conditions of consent, the sitewill record any noise complaints in the rapid induct system. Where a substantiated noise complaint isreceived, the site will implement measures to reduce noise. Refer to Appendix B – NoiseManagement Strategy of this EMP

4.5.3 Air Quality ManagementThe site shall control air quality management by:Visually inspecting vehicles for no black or white smoke from exhausts longer than 10 seconds. Thiswill be done periodically as part of the weekly monitoring program.The dust collector monitoring probes will be serviced as per the internal preventative maintenanceprogram.The dust collector monitoring probes will be serviced by an external contractor as per themaintenance schedule.The site dust collector systems and filters will be serviced as per the site preventative maintenanceschedule.

4.5.4 Stormwater ManagementThe site will conduct occasional spot checks of the oil tankers to ensure the drivers are using spill traysunder the couplings to prevent spills.Oil tankers must be fitted with interlock brakes as part of entry and operation on the site.Regular inspections of bunding around oil tanks will be undertaken to ensure capacity of the bund ismaintained. Inspection of the isolation valves and drains wardens will be part of the weeklymonitorin.

4.6 Reporting Requirements:4.6.1 Environmental Impact reporting:In the case of an environmental Spill or issue that causes or has the potential to cause off siteenvironmental harm, the environmental notification script shall be completed as per appendix I ofthis EMP. Records are provided as an attachment to this document.

4.6.2 Annual Environmental Management ReportThe site must complete an Annual Environmental Management Report (AEMR) and submit this to theDP&E each February. This report covers the activities for the site for the previous calendar yearagainst the DA Conditions of Consent for the site. This document is to be prepared by a third partyconsultant.

4.6.3 Environmental and Hazard AuditsThe site must undertake a third party Environmental and Hazard audit every three years. These auditsare to be conducted by an approved third party auditor.The DP&E must approve the auditor prior to the audits commencing. This requires the CV’s and to besubmitted to the DP&E Attorney General for approval.The audits must be completed by July and quotes and approval should start in May to ensuresufficient time to arrange and complete the audits.The audit reports must be submitted to the DP&E as follows:Hazard Report: Within one month of the audit being completed.Environmental Report: Within two months of the audit being completed.If an extension to the submission of reports or the time of the audits it required, a written request shallbe submitted to the DP&E.




5. RecordsData Form or Record Minimum Retention Period Who Holds/Secures the

Data Form or RecordRetained for Legal or KnowledgePreservation

Weekly Monitoring Form 3 Years OHS& Training Coordinator Knowledge

Environmental Training /Induction Records

4 Years Rapid Induct / Training &OHS Coordinator

Knowledge

Environmental IncidentNotification script

7 Years Training & OHS Coordinator Legal




PAGE i

Contents1. Introduction 5

1.1. Environmental Management Plan purpose 51.2. Environmental Management Plan scope 51.3. Environmental Management Plan objectives 61.4. Preparation of this EMP and Sub-Plans 6

2. Overview of site operations 72.1. Bulk deliveries 72.2. Truck docks / driveway 72.3. Offices / kitchens and laboratories 82.4. Production floor 82.5. Silos 82.6. Oil storage 8

3. Legislative and regulatory requirements 103.1. Conditions of Development Consent (CDCs) 103.2. Legislation 113.3. Standards and guidelines 11

4. Environmental aspects 135. Environmental impacts and controls 14

5.1. Overview 145.2. Environmental management strategies 145.3. Environmental management sub-plans 145.4. Site induction and training 15

6. Communications and reporting 166.1. Reporting 166.2. Communications 166.3. Complaints management 16

7. Emergency response 177.1. Incident response 177.2. Incident reporting 17

8. Environmental management responsibilities 198.1. Environmental roles and responsibilities 198.1.1. Site Manager 208.1.2. National Work Health Safety and Environmental (WHSE) Manager and Coordinator 218.1.3. Production Managers 218.1.4. Warehouse Manager 21




PAGE ii

8.1.5. Maintenance Manager 218.1.6. Employees, Contractors and Delivery Drivers 228.1.7. Environmental Contractors 22

9. Monitoring, inspection & auditing environmental performance 239.1. Overview 239.2. Environmental monitoring program 239.3. Inspections and audits 259.3.1. Audit action plan 259.4. Non-compliances 25

10. Environmental reporting 2611. Management review 27Appendix A Conditions of Development Consent 29Appendix B Noise Management Strategy 43Appendix C Air Quality Management Strategy 44Appendix D Stormwater Management Strategy 45Appendix E Traffic Management Sub Plan 46Appendix F Landscape Management Sub Plan 56Appendix G Waste Management Sub Plan 63Appendix H Environmental Inspection Report Template 69Appendix I Environmental Incident Notification Script 70Appendix J Emergency Contacts 72




PAGE iii

Document History and StatusRevision Date issued Reviewed by Approved by Date approved Revision type

Draft V01 20/04/2012 B Ison G Moylan 27/04/2012 Project manager

Draft V02 27/04/2012 J Ball B Ison 24/05/2012 Practise / Project director

Version V03 17/11/15 R. Herron CAR 14-15-0446

Revision 3.1 29.03.2017 H. Lam, OCetindemir

R. Herron 29.03.217 CAR’s 0502, 0489, 0736,1029

Printed: 11 April 2017

Last saved: 29 March 2017 09:44 AM

Name of organisation: Allied Mills Kingsgrove

Name of document: Allied Mills Kingsgrove – Environmental Management Plan

Document version:Final Rev 3.1 Notice previous revision 3 was documentedoutside the SAP system. Dated 15.11.2015




PAGE iv

GlossaryTerm Definition

AEMR Annual Environmental Management Report

CBD Central Business District

CDC Conditions of Developmental Consent

dBA Decibels (A-weighted)

DCP Development Control Plan

DMS Deflagration Management Strategy

DoP Department of Planning

DP&I Department of Planning and Infrastructure

EMP Environmental Management Plan

EPA Environmental Protection Agency

EPL Environmental Protection License

HCC Hurstville City Council

LAeq Equivalent continuous A-weighted noise level

LGA Local Government Area

LMP Landscape Management Plan

POEO Act Protection of the Environment (Operations) Act

SEE Statement of Environmental Effects

TSH&ECoordinator

Training, Safety, Health and Environment Coordinator

TMP Traffic Management Plan

WMP Waste Management Plan




PAGE 5

1. IntroductionAllied Mills manufactures and distributes a wide range of food ingredients; in particulargrain based baking supplies. The Kingsgrove site receives bulk deliveries of flour, oil andother ingredients and processes these into the products including:

n flours for items such as bread, pastry, cake, biscuit, noodle and culinary applications

n pre-mixes for bread, cake, donut and culinary applications

n other specialty flours, batters, coatings and grain products

The Kingsgrove site is located at 4 The Crescent, Kingsgrove NSW, which is within theGeorges River Council Local Government Area (LGA), 12 kilometres to the south of theSydney Central Business District (CBD). The site is adjacent to the M5 East Motorway,Crescent Road, Vanessa Street and existing light industrial facilities. The site occupies anarea of 24,490 m2. The site produces approximately 80,000 tonnes per year of productand employs approximately 100 people.

1.1. Environmental Management Plan purpose

This Environmental Management Plan (EMP) has been developed to fulfil therequirements of conditions 3.5(a)-(h) of the development consent (S01/00876). The EMPprovides an environmental management framework and strategies to minimise potentialenvironmental impacts arising from site operations. It includes specific managementmeasures to ensure operations at the site have minimal environmental impact and risk,and where possible, enhanced environmental outcomes.

This plan:

n captures environmental issues and mitigation measures already identified andassessed through the environmental documents relating to the operations of the site

n includes management measures, procedures, monitoring, auditing, reporting andallocates responsibility in relation to the operation’s of the facility

n provides Allied Mills with measures that will be used to manage environmental risksand opportunities

1.2. Environmental Management Plan scope

This plan is the lead document dictating environmental performance for Allied Millsoperations at Kingsgrove. It covers all areas where physical works will occur, or areas thatmay be impacted by works, and is applicable over the full duration of operation at the site.It clearly identifies accountabilities for implementation of control measures and actions,monitoring, auditing/inspections and reporting.




PAGE 6

Sub-plans to address specific significant environmental issues associated with the projectare shown in Section 5.

All Allied Mills staff and sub-contractors are required to operate fully under the auspices ofthis plan and sub-plans.

1.3. Environmental Management Plan objectives

The objectives of this plan are that:

n all environmental requirements contained in statutory approvals, and other legalcontrols relevant to Allied Mills operation are clearly defined and mechanisms forimplementation specified

n an environmental management system is established that meets the Conditions ofDevelopment Consent (CDC)

n all roles and responsibilities are set to ensure certainty of delivery

n all processes for auditing, monitoring and reporting on performance and effectivenessof the EMP are defined

n other objectives identified within environmental documents are met

1.4. Preparation of this EMP and Sub-Plans

All environmental management requirements specified as being the responsibility of AlliedMills in the CDCs have been considered and addressed in preparing this plan. This planhas also been designed to address Allied Mills expectations and requirements, andadequately address risks and stakeholder concerns. Consultation with all stakeholders willbe undertaken as per the requirements of the CDCs.




PAGE 7

2. Overview of site operationsThe Allied Mills site at Kingsgrove involves the preparation of food ingredients from bulkgrain based product. The site is a pre-mix plant utilising ingredients from both external andinternal suppliers and blending those ingredients to produce a finished product. Productsproduced at the site are distributed in a powdered form to be mixed and baked off-site bythe retail division or customers.

The processes at Kingsgrove involve blending mainly dry products into pre-mixes andcake mixes. Vegetable oil is used as an additive in pre-mixes for the fast food industry,and liquid carbon dioxide is used to cool some products that contain vegetable oil.

The processing equipment and storage of ingredients is totally housed within existingbuildings. By fully enclosing the production area, opportunities for loss of product to theexternal environment are significantly reduced with uncontrolled emissions of noise anddust being captured. Activities outside the buildings are limited to solid waste recyclingand storage and unloading of bulk deliveries.

The main areas of the plant are described further below, and a site map is provided atFigure 2-1.

2.1. Bulk deliveries

Bulk deliveries of flour products are received adjacent to the storage silos on the southernboundary of the site. Deliveries are typically made by an articulated flour tanker, and pipeddirectly into the onsite flour silos using blower housed inside the Allied Mills building, assuch the operation of truck mounted blowers is not required. The onsite road at this pointis one direction, as bulk delivery trucks are required to enter through the southern gate(Gate B) and exit through the northern gate (Gate A).

2.2. Truck docks / driveway

The loading / unloading dock has room for two trucks at any time, and an additionalwaiting bay, located adjacent to the LPG storage tanks in the north of the site. Oildeliveries are made at a point on the northern wall of the building, adjacent to the oilstorage area. Trucks are required to enter through the northern access gate (Gate A) andreverse into the docks to load or unload, they then exit through the same northern gate. Aforklift operates in this area; however this plant is not equipped with a reversing beeper.




PAGE 8

2.3. Offices / kitchens and laboratories

The second floor of the building contains the office areas and test kitchen, whilstadditional office space and a laboratory are located on the ground floor in the north east ofthe building.

2.4. Production floor

The production area is a large open space located in the eastern wing of the site. Thisspace contains dry mixing machinery, blowers, conveyors and packing equipment, inaddition to other machinery. Workers in this area are required to wear hygiene and safetyequipment, including hair nets and eye and ear protection.

2.5. Silos

The flour silos on the site are approximately 15 m tall and housed internally in the southeastern area of the main building. The area is negatively pressurised and both the silosand building contain vents for the controlled released of potential explosive energy.

2.6. Oil storage

This bunded area is housed internally and holds approximately six edible oil tanks, with atotal capacity of approximately 92,000 L. Trucks delivering the oil are required to beequipped with brake interlocks, which will only allow oil to leave the truck when the brakeis activated, thus helping to prevent accidental spills.




PAGE 9

n Figure 2-1 Allied Mills Kingsgrove site layout plan.




PAGE 10

3. Legislative and regulatory requirements3.1. Conditions of Development Consent (CDCs)

The CDCs were issued as part of the development consent for the Kingsgrove site. Theseconditions specify a number of measures for implementation during construction andoperation of the site. This EMP has been developed specifically to address therequirements of condition 3.5 of the development consent. The requirements of condition3.5 and the relevant sections of this document where these requirements are met, isidentified in Table 3-1.

n Table 3-1 Condition 3.5 requirementsCondition Condition requirements EMP section

3.5 The Applicant must prepare and implement an EnvironmentalManagement Plan for all future operations at the site. This planmust:

ThisDocument

3.5a) Describe the proposed operations Section 2

3.5b) Identify the relevant statutory requirements that apply to theoperation of the development

Section 3

3.5c) Set standards and performance measures for each of therelevant environmental issues

Section 4

3.5d) Describe what actions and measures will be implemented tomitigate the potential impacts of the development, and to ensurethat the development meets these standards and performancemeasures

Section 5

3.5e) Describe what measures and procedures will be implemented to:

n Register and respond to complaints;

n Respond to potential emergencies, such as plant failure

Section 6 and

Section 7

3.5f) Describe the role, responsibility, authority, and accountability ofall the key personnel involved in the operation of thedevelopment

Section 8

3.5g) Incorporate the detailed Environmental Monitoring Program Section 9

3.5h) Include the following:n Management strategies for the control of noise, dust and

stormwatern A Traffic Management Plan

n A Landscape Management Plan

n A Waste Management Plan

Appendix B toAppendix G




PAGE 11

Appendix A tabulates all of the CDC requirements and identifies where each requirementis addressed in this plan and/or related documents.

3.2. Legislation

Allied Mills has an obligation to comply with the relevant provisions of all legislation andregulations relating to operations of the site. The relevant legislation and the requiredapprovals for the Kingsgrove site are identified in Table 3-2.

n Table 3-2 Legislative requirementsRelevantlegislation

Overview of legislation Approvals / requirements

EnvironmentalPlanning &Assessment Act1979 & Regulation2000

Sets out the planningrequirements for developmentsand the factors that must betaken into account concerning theimpact of an activity on theenvironment.

The Department of Infrastructureand Planning has providedconditions for the developmentconsent.

Protection of theEnvironmentOperations Act(POEO Act) 1997

Provides a licensing frameworkfor potentially polluting premisesor activities.

An EPL (2794) was in place forthe site for air emissionmonitoring, but was surrenderedin 2001.

Legal duty to immediately notifythe EPA of potentialenvironmental harm

Incident notification procedures inSection 7.1 to be followed inevent of a spill.

Occupational Healthand Safety Act 2001

Provides a licensing frameworkfor the storage and handling ofpotentially dangerous goods.

The Kingsgrove site is licensed tostore LP Gas and carbon dioxidein bulk under licenceNDG035076.

Clean Air Regulation1997 (POEO Act)

Provides emission standards fora variety of different air pollutants.

Plant and equipment to bemaintained in a proper andefficient manner.

3.3. Standards and guidelines

The key standards and guidelines relevant to the management of the site include:

n Australian Standard – AS2890.1-1993 ‘Car park design’

n Australian Standard – AS2890.2-1989 ‘Commercial parking’

n Australian Standard – AS2430.2-1986 ‘Classification of hazardous areas Part 2 –Combustible Dust’




PAGE 12

n Australian/New Zealand Standards – AS2381.1-1999 ‘Electrical Equipment forExplosive Atmospheres – Selection, Installation and Maintenance Part 1 – GeneralRequirements’

n Department of Planning and Infrastructure – Hazardous Industry Planning paper No 1– Industry Emergency Planning Guidelines

n Department of Planning and Infrastructure – Hazardous Industry Planning paper No 2– Fire Safety Study Guidelines

n Department of Planning and Infrastructure – Hazardous Industry Planning paper No 5– Hazard Audit Guidelines

n Department of Planning and Infrastructure – Hazardous Industry Planning paper No 9– Safety Management

n EPA – Industrial Noise Policy 2000

n EPA – Environmental Criteria for Road traffic Noise 1999

n Department of Housing – Managing Urban Stormwater – Soils and Construction 1998

n Workcover – OHS Regulation 2001 – Storage and handling of dangerous goods




PAGE 13

4. Environmental aspectsDick Benbow & Associates prepared the ‘Statement of Environmental Effects (SEE) forthe proposed expansion to the existing manufacturing facilities at Goodman FielderLimited Kingsgrove’. The SEE identified the aspects of the Allied Mills Kingsgrove site(formerly the Goodman Fielder site) that may impact upon the surrounding environment.The potential environmental aspects of the Kingsgrove site and the adopted performancemeasures are detailed in Table 4-1.

n Table 4-1 Environmental aspects and performance measuresEnvironmentalaspect

Standards / performance measures

Noise No nuisance noise will be emitted from the Kingsgrove site.

Dust No visible dust or odours noted leaving the Kingsgrove site.

Stormwater No pollution of nearby waterways.

Traffic No notable impact to the surrounding community from traffic generated atthe Kingsgrove site.

Aesthetic Impacts/Landscaping

No aesthetic impact to the surrounding community.

Waste All waste to be correctly stored on site and disposed of by anappropriately licenced contractor.




PAGE 14

5. Environmental impacts and controls5.1. Overview

This plan is the overarching plan for environmental management. Under this plan,individual management strategies and sub plans have been developed to address theenvironmental aspects that were identified within the SEE, or as required by the CDCs.

5.2. Environmental management strategies

The environmental management strategies comprise the environmental safeguards usedto achieve the performance measures identified in Table 4-1. For each EnvironmentalManagement Strategy, the following approach has been undertaken:

n Identification of potential risks

n Assessment of potential risks (using a scale of Negligible, Low, Moderate and High)

n Identification of Environmental Objectives

n Identification of major compliance requirements

n Define monitoring requirements and responsibilities

n Development of mitigation measures

A list of the Environmental Management Strategies developed for the site and where theycan be found within this document is shown in Table 5-1.

n Table 5-1 Environmental management strategiesStrategy EMP Section

Environmental Noise Appendix B

Air Quality Appendix C

Stormwater and Wastewater Appendix D

5.3. Environmental management sub-plans

The purpose of sub-plans is to guide operational activities in a concise manner, byspecifying measures to manage impact on the environment.

A register of sub-plans is provided in Table 5-2 .




PAGE 15

n Table 5-2 Environmental management sub-plansSub-plan Doc reference

Traffic Management Plan Appendix E

Landscape Management Plan Appendix F

Waste Appendix G

5.4. Site induction and training

Allied Mills will ensure that all those who will be working at the Kingsgrove site willundertake site induction training prior to commencing work on site. The objective of theinduction training is to ensure all personnel have the appropriate awareness andcompetence for aspects relevant to their positions/role including environmentalmanagement. The site induction and training courses will cover:

· The content and intent of the EMP

· The importance of conformance with the EMP, and roles and responsibility in achievingconformance with the EMP

· Significant onsite and offsite environmental issues

· Incident Management including location of environmental incident notification script,actions to be undertaken, responsibilities during an incident, communication lines andemergency services to be contacted

· The potential consequences of departure from specified operating procedures

The records will be available in rapid induct and include names of trainees, trainingprovided and date of training. The training records will be kept for 4 years and will bemade available for audit.




PAGE 16

6. Communications and reporting6.1. Reporting

The Site Manager is responsible for managing the environmental reporting program andarranging specialist consultants to prepare reports, as required.

6.2. Communications

Weekly operational meetings will be held to discuss environmental issues, such asenvironmental performance, monitoring results, independent audit findings and will alsoallow operational personnel to forecast potential issues (eg night works).

6.3. Complaints management

In the event that Allied Mills receives a complaint regarding the works at the Kingsgrovefacility, the complainant shall be referred to the Site Manager or National WHSE Manager.Allied Mills shall collect the following details and document them in the Incident ReportingDatabase:

n date and time of the complaint;

n means by which the complaint was made;

n any personal details of the complainant which were provided, or if no such detailswere provided, a note to that effect;

n the nature of the complaint;

n action taken by Allied Mills in relation to the complaint, including any follow-up contactwith the complainant, and

n if Allied Mills took no action in relation to the complaint, the reasons why no actionwas taken.

The Site Manager will be responsible for coordinating any environmental monitoringrequired in response to a complaint, and for ensuring that the monitoring results arereceived in a timely manner. All records collected that relate to a complaint will be savedand available for audit for four years.




PAGE 17

7. Emergency response7.1. Incident response

In the event of an environmental incident that causes material environmental harm, theSite Manager must be notified; Allied Mills will collect initial basic information on theEnvironmental Incident Notification Script (included in Appendix I) and then immediatelycontact the following organisations in accordance with the recent amendments to thePOEO Act:

n Emergency services ‘000’ (whether the incident presents an immediate threat topeople or property or not)

n Georges River Council ‘(02) 9330 6400’ (Georges River Council is only available8.30am – 5.00pm Mon – Fri)

n EPA ‘131 555’n Ministry of Health – SESI Randwick ‘(02) 9382 8333’n WorkCover Authority ’13 10 50’

Allied Mills will document the time each of the above organisations were notified andinclude these details in the incident report.

7.2. Incident reporting

All environmental incidents are to be reported immediately to the Site Manager orProduction Manager. The Site Manager (or Production Manager) will then be required tofollow the above notification procedures.

In accordance with Condition 8.1 of the CDC, any incident or potential incident that hasactual or potential offsite impacts must have a report supplied to the Director-General,within 24 hours. The immediate report must outline the basic facts of the incident includingbut not limited to:

n Description of the incident (including times)

n Expected receiver (people, environment, waterbodies)

n Estimated quantities of any spills

n Immediate actions implemented (including times)

n Details of any notifications to Government Departments (including times)

A further detailed report is also to be compiled in accordance with Condition 8.1 of theCDC, which investigates the cause of the incident (or potential incident) and identifies any




PAGE 18

preventative measures that can be implemented. This report is to be submitted to theDirector-General with no later than 14 days after the incident or potential incident.

Any records of incident or potential incidents are to be logged and maintained in the RapidInduct Database as required by Condition 8.2 of the CDC.




PAGE 19

8. Environmental management responsibilities8.1. Environmental roles and responsibilities

The organisational structure of the Allied Mills Kingsgrove facility is shown in Figure 3-1.

n Figure 3-1 Allied Mills organisational structure

Site Manager

ProductionManagers

WarehouseManager

MaintenanceManager

Pre-Mix Plantemployees

WasteContractors

DeliveryDrivers

MaintenanceContractors




PAGE 20

The responsibilities and authorities of the key management positions are described below:

n Site Manager – directly responsible for management of operations of the site,including environmental aspects, incident response and the day to dayimplementation of the EMP

n Production Managers – Supervise production activities in accordance with the EMP. Isresponsible to notify the Site Manager of any environmental issues

n Warehouse Manager – Records and monitors truck movements through dock areaand reports environmental issues to the Site Manager.

n All employees, contractors and delivery drivers – To ensure their own actions are inaccordance with this EMP; to ask a supervisor if they are unsure of theirenvironmental responsibilities; to inspect, monitor and report (where relevant) on theenvironmental impacts of their own work activities or those they observe at the site

The contact information for the key responsibilities is included in 0.

8.1.1. Site Manager

The Site Manager is the Company's designated 'Management Representative', and inexercising this authority is responsible for:

n ensuring implementation of the Management System for the site

n ensuring that personnel responsible for inspection, monitoring and other activities aretrained and have the necessary skills, resources and authority

n developing improvements and correcting defects or shortcomings as appropriate

n review and audit as required of subcontractors' quality, environmental and safetysystems

n Communicating and providing detail to Company Secretary to act as Company’sspokesperson in the event of an incident under the Protection of the EnvironmentOperations Act 1997

n Ensure all personnel are aware of the environmental incident response proceduresand each individual’s notification responsibilities

n facilitate an induction and training program for all persons involved with site activities

n have the authority to require reasonable steps to be undertaken to avoid or minimisethe unintended (or adverse) impacts and failing the effectiveness of such steps to stopwork immediately if an unacceptable impact on the environment is likely to occur

n implement this EMP across the site including the organisation of suitably qualifiedpersonnel to fulfil the requirements of the Environmental Monitoring Program




PAGE 21

n undertake weekly site inspections to identify and action any corrective/preventativemeasures as appropriate

n manage the procedures for receiving and responding to complaints and inquiries inrelation to the environmental performance of operations

n organise the production and submittal the Annual Environmental Management Reportto Department of Planning and Environment (DP&E)

8.1.2. National Work Health Safety and Environmental (WHSE) Manager andCoordinator

The National WHSE Manager and Coordinator will assist the site with reporting andindependent environmental and hazard audits.

8.1.3. Production Managers

The Production Managers are required to immediately notify the Site Manager of anyspills, any visible dust or odours leaving the Kingsgrove site, or any other potentialenvironmental concerns that may arise. If the Site Manager is unavailable the ProductionManager must complete the basic information on the Environmental Incident NotificationScript (Appendix I) and contact the relevant regulators.

8.1.4. Warehouse Manager

The Warehouse Manager is required to immediately notify the Site Manager of any spills,any visible dust or odours leaving the Kingsgrove site, or any other potentialenvironmental concerns that may arise. If the Site Manager is unavailable the WarehouseManager must complete the basic information on the Environmental Incident NotificationScript (Appendix IError! Reference source not found.) and contact the relevant regulators.

The warehouse manager is also required to coordinate and monitor the movements ofdelivery vehicles and waste contractors to the Kingsgrove site, to ensure the drivers arenot creating a nuisance in the surrounding community in line with the requirementsdetailed within Appendix E.

8.1.5. Maintenance Manager

The Maintenance Manager is required to immediately notify the Site Manager of anyspills, any visible dust or odours leaving site the Kingsgrove site, or any other potentialenvironmental concerns that may arise. If the Site Manager is unavailable theMaintenance Manager must complete the basic information on the Environmental IncidentNotification Script (Appendix IError! Reference source not found.) and contact the relevantregulators.




PAGE 22

The Maintenance Manager is also required to ensure that the contractors used formaintenance works are appropriately inducted and working in accordance with the EMPrequirements.

8.1.6. Employees, Contractors and Delivery Drivers

Employees, Contractors and Delivery Drivers are required to carry out their work inaccordance with site inductions or specific contract instructions and in an environmentallysound manner. All site personnel are to attend the site induction before they commenceany work at the Kingsgrove site. Each member of personnel must notify their supervisor orthe Site Manager immediately upon noticing any spill or potential environmental hazard. Iftheir supervisor or Site Manager is unavailable, they must complete the basic informationon the Environmental Incident Notification Script (Appendix I) and contact the relevantregulators.

8.1.7. Environmental Contractors

Environmental contractors are engaged for specialist environmental support roles. Theseresources include:

n landscaping sub-contractor to undertake landscaping works

n independent environmental and hazard auditors

n noise specialist for complaint monitoring and reporting

n GIS, database and other software as required during the course of the project

n other resources as required during the course of the project

A register of specialist environmental personnel is kept by Allied Mills. All environmentalcontractors are required to complete the site induction and carry out their works inaccordance with this EMP. Environmental Contactors must notify their supervisor or theSite Manager immediately upon noticing any spill or potential environmental hazard.




PAGE 23

9. Monitoring, inspection & auditing environmentalperformance

9.1. Overview

Section 6.1 of the CDC outlines the requirements of the Environmental MonitoringProgram. As outlined in Section 8.1.2 of this document, the Site Manager is required tocoordinate the environmental monitoring program to ensure its effective implementation.The requirements of condition 6.1 and the relevant sections of this document where theserequirements are met, is identified in Table 9-1.

n Table 9-1 Condition 6.1 requirementsCondition Condition requirements EMP

Section

6.1 The Applicant must prepare and implement a detailedEnvironmental Monitoring Program for the development inconsultation with the EPA. The program must:

Thisdocument

6.1a) Identify what environmental issues will be monitored; Section 4

6.1b) Set standards and performance measures for theseenvironmental issues;

Section 4

6.1c) Describe in detail how these issues will be monitored, who willconduct the monitoring, how often the monitoring will beconducted, and how the results of this monitoring will berecorded and reported to the Director-General and other relevantauthorities;

Table 9-2

6.1d) Indicate what actions will be taken, or procedures followed, if anynon-compliance is detected;

Section 9.4

6.1e) Include the following:

n A Noise Compliance Monitoring Program to determine levelof compliance with the noise criteria; and

n Traffic Monitoring.

nAppendix B

nAppendix E

9.2. Environmental monitoring program

An environmental monitoring program has been developed to address each of theenvironmental aspects and their performance measures, identified in the SEE andoutlined in Section 4 of this plan. A brief summary of the monitoring program and wherefurther information is available has been outlined in Table 9-2.




PAGE 24

n Table 9-2 Environmental monitoring program

Environmentalaspect

Performancemeasure

Monitoringmethod

Monitoring frequency Deliverable Responsibility Further information

Noise No nuisance noisewill be emitted fromthe Kingsgrove Site.

As appropriate Upon receiving asubstantiatedcommunity complaint

NoiseMonitoringreport, AEMR

Site Manager Appendix B NoiseManagement Strategy

Air Quality No visible dust orodours noted leavingthe Kingsgrove site.

Staffobservations ofdust and odours

Constantly duringoperating hours

Corrective/Preventativeactions

All Personnel Appendix C Air QualityManagement Strategy

Stormwater No pollution ofnearby waterways.

Site inspection ofbunding andisolation valves

Weekly Corrective/Preventativeactions

Site Manager orDesignated person.

Appendix D StormwaterManagement Strategy

Traffic No notable impact tothe surroundingcommunity fromtraffic generated atthe Kingsgrove site.

Truck movementrecords

Daily TruckDockets

Warehouse Manager Appendix E TrafficManagement Plan

Aesthetic/Landscaping

No aesthetic impactto the surroundingcommunity.

Landscaping tobe maintained

Fortnightly N/A Site Manager Appendix F LandscapeManagement Plan

Waste All waste to beeffectively stored onsite.

Site inspection ofwastereceptaclesacross the site

Weekly Corrective/Preventativeactions

Site Manager orDesignated person.

Appendix G WasteManagement Plan

Note – An example of an Environmental Inspection Report Template is attached as Appendix I.




PAGE 25

9.3. Inspections and audits

The Site Manager is responsible for ensuring effective environmental inspections arecarried out. Each week the Site Manager or Designated Person conducts a site safety andenvironment walk around the site to identify any safety or environmental issues. Anyissues identified are to be documented (an example of the Environmental InspectionReport is attached as Appendix H) and actioned appropriately. Weekly site inspectionrecords will be maintained and will be available for audit. Any actions completed toaddress issues identified in the weekly site inspections, will also be documented andavailable for audit.

Independent environment and hazard audits are to be organised by the Site Managerevery three years and must be carried out in accordance with the Condition 7.3 of thedevelopment consent.

9.3.1. Audit action plan

Auditees review any adverse findings with appropriate personnel and develop a correctiveaction plan to address and close out findings. Where necessary, an investigation into thecauses of any non-conformance is undertaken. Corrective action plans include actions tobe taken, estimated completion date and responsibilities.

9.4. Non-compliances

If a Non - compliance is identified during the Environmental monitoring program, weeklysite inspection, an independent audit or any other method, the following process is to befollowed:

n The Site Manager is to be informed immediately

n The Site Manager must identify an appropriate corrective action and then implementthe corrective action or delegate authority over the action to an appropriate person.

n Any non-compliance and the actions taken are to be recorded and included in theAnnual Environmental Management Report (AEMR)

n If the Non-Compliance constituted a pollution event that may cause materialenvironmental harm, the emergency response procedure would be followed and theappropriate government authorities would be notified immediately




PAGE 26

10. Environmental reportingAllied Mills will compile an Annual Environmental Management Report (AEMR) incompliance with Condition 7.1 of the CDC. This report will:

n Identify the standards, performance measures, and statutory requirements theKingsgrove site is required to comply with;

n Review the environmental performance of the Kingsgrove site to determine whether itis complying with these standards, performance measures and statutoryrequirements;

n Identify all the occasions during the previous year when the Kingsgrove site did notcomply with these standards, performance measures and statutory requirements;

n Include a summary of any complaints made about the Kingsgrove site, and indicatewhat actions were taken (or are being taken) to address these complaints;

n Include the detailed reporting from the Environmental Monitoring Program, andidentify any trends in the monitoring over the life of the project; and

n Where a non-compliance has occurred, describe what actions are or will be taken toensure compliance, who is responsible for carrying out these actions, and when theseactions will be implemented.

The AEMR will be for the period from January to December for each year; and will besubmitted to the Director-General and the Georges River Council by the end of February.If the review by the Director-General identifies some additional matters to be addressed,any reasonable requirements will be complied with.




PAGE 27

11. Management reviewThe CDC’s have outlined a number of tasks that require consistent reviews and ifnecessary updates. The conditions of consent have also detailed a number of deliverablesto review the performance of the Allied Mills site and determine the effectiveness ofenvironmental at the site. The tasks outlined within the CDC’s have been set out inTable 11-1, along with the frequency of the task and the estimated date of the nextrevision. The Kingsgrove Safety Audit Schedule will detail the next review period.

n Table 11-1 Management plan peviews

Condition Management plan Task Frequency Next review

3.7 EnvironmentalManagement Plan(including Sub Plans)

Review Annual (orfollowing asignificantincident)

Februaryeach year

4.19 Traffic Management Plan Review Annual (orfollowing asignificantincident)

Februaryeach year

7.1 Annual EnvironmentalManagement Report(AEMR)

Issue AEMR Annually Februaryeach year

7.3 IndependentEnvironmental Audit

CommissionAudit

Every three years As per EMPKV-REC-001

8.2 Incident Register Update register As necessary N/A

8.3 Independent HazardAudit

CommissionAudit

Every three years As per EMPKV-REC-001




PAGE 28

Referencesn Conditions of Development Consent (dated 2001) issued by the Department of Urban

Affairs and Planning.

n DA No. 143-06-01 submitted to the Department of Urban Affairs and Planning;

n SEE, titled ‘Statement of Environmental Effects for the Proposed Expansion toExisting Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove’, dated 20June 2001, and prepared by Dick Benbow and Associates Pty Ltd on behalf ofGoodman fielder;

n Environmental Management Plan, Goodman Fielder, Kingsgrove NSW, October 2002,prepared by ERM.

n Traffic Impact Statement ‘Proposed Industrial Expansion Lot 1, DP 200215, TheCrescent, Kingsgrove. Ref 21-07OR (3)’, dated August 2001, and prepared byRhodes Thompson Associates on behalf of Goodman Fielder;

n Construction Management Plan, prepared by A W Edwards, supplied to GoodmanFielder, 04 October 2002

n Traffic Management Plan, prepared by Rhodes Thompson and Associates, 2002.

n Site Incident Logs

n Dangerous Goods Licence No. 35 / 035076 , expiry date 3/5/2012, issued byWorkCover, NSW

n Fire Safety Study, Goodman Fielder Ltd, 4 The Crescent, Kingsgrove, Doc #21069FSS.doc, Prepared by Environmental Audits of Australia, Oct 2001

n Deflagration ( Explosion) Management Strategy for Goodman Fielder KingsgrovePlant, Report # 52004, Prepared by Environmental Audits of Australia, June 2002




PAGE 29

Appendix A Conditions of Development ConsentCondition Description of requirements/commitment Implementation EMP Reference1.1 The applicant must implement all practicable measures to prevent or

minimise any harm to the environment that may result from the construction,operation and where relevant, the decommissioning of the development.

The Kingsgrove site is to remain a well operated andmaintained site. This document has been developed toaddress all of the conditions of consent or direct toappropriate plans

This Document

1.2 The applicant must carry out the development generally in accordance withthe:

- -

1.2 a) DA No. 143-06-01 submitted to the Department of Urban Affairs andPlanning;

The DA contains the CDC’s. This document has beendeveloped to address all of the conditions of consent ordirect to appropriate plans

This Document

1.2 b) SEE, titled ‘Statement of Environmental Effects for the Proposed Expansionto Existing Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove’,dated 20 June 2001, and prepared by Dick Benbow and Associates Pty Ltdon behalf of Goodman fielder;

The environmental aspects identified in the SEE areaddressed in this plan.

Section 4

1.2 c) The Traffic Impact Statement ‘Proposed Industrial Expansion Lot 1, DP200215, The Crescent, Kingsgrove. Ref 21-07OR (3)’, dated August 2001,and prepared by Rhodes Thompson Associates on behalf of GoodmanFielder;

The onsite parking provisions have been maintained andthe multi-direction internal roadway is to be clearly definedin accordance with the updated “Traffic OperationsAssessment”.

“TrafficOperationsAssessment” 7November 2011

1.2 d) Additional information supplied to the Department by Dick Benbow andAssociates on 16, 24, 27 and 28 August 2001;

Use of articulated trucks in place of B-doubles has beenimplemented. Minimal sugar grinding is conducted at thesite.

-

1.2 e) Additional information supplied to the Department by Goodman Fielder on 4September 2001;

States that production volumes of 150,000 tonnes/yr, willnot increase daily traffic volumes. Traffic numbers complywith traffic statement. Allied Mills have not exceeded150,000t/yr production.

-

1.2 f) Relevant prescribed conditions in clause 78 of the Environmental Planningand Assessment Regulation 1994; and

This clause outlines the procedure for public display of theproposed development prior to construction. Given thatconsent has been granted for this development, it wouldindicate that Clause 78 has been met

-

1.2 g) These conditions. The Kingsgrove site is well operated and maintained. Thisdocument has been developed to address all of theconditions of consent or direct to appropriate documents

This Document




PAGE 30

Condition Description of requirements/commitment Implementation EMP Reference1.3 The production of the entire site will be limited to a total of 150,000 tpa. Noted and conforms. -

1.4 Not Used - -

1.5 Before any construction work starts, the Applicant must obtain a constructioncertificate for the proposed development from the Principle CertifyingAuthority.

Certificate number CP 41141-1, issued by Trevor R Howseand Associates

CertificateCP41141-1

1.6 Before any commencement of operations, the Applicant must obtain anoccupation certificate for the development from the Principle CertifyingAuthority.

Certificate number CP 21141-1 AR issued by Trevor RHowse and Associates

CertificateCP21141-1 AR

2.1 Throughout the life of the development, the Applicant must secure, renew,maintain and comply with all the relevant statutory approvals applying to thedevelopment.

Refer Conditions 3.2, 3.4, 4.20, 4.27, 5.2 and 6.5 -

2.2 The Applicant must ensure that all contractors and sub contractors are awareof, and comply with the conditions of this consent and the approvedConstruction Management Plan (See conditions 3.1 and 3.2).

A site induction has been prepared that identifies theCDC’s requirements including incident response, dust andnoise issues.

Section 5.4

2.3 Prior to construction on any aspect of the development commencing, theApplicant must certify in writing to the satisfaction of the Director General,that it has obtained all the necessary statutory approvals for the constructionwork, and complied with all the relevant conditions of this consent and / orany other statutory requirements for this development pertaining to thataspect of the development to be constructed. The necessary statutoryapproval includes a permit under Part 3A of the Rivers and ForeshoresImprovement Act 1948.

N/A - Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of theKingsgrove site and the CDC’s.

-

2.4 Prior to commencement of operations of the food processing plant, theApplicant must certify in writing to the satisfaction of the Director General,that it has obtained all the necessary statutory approvals for the operations,and complied with all the relevant conditions of this consent and / or anyother statutory requirements for this development.


-

3.1 The Applicant must prepare and implement a Construction ManagementPlan for the development. This plan must:


-

3.1 a) Describe the proposed construction works and associated traffic; N/A - Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of theKingsgrove site and the CDC’s.

-

3.1 b) Outline the proposed construction work program; N/A - Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of the

-




PAGE 31

Condition Description of requirements/commitment Implementation EMP ReferenceKingsgrove site and the CDC’s.

3.1 c) Identify all the relevant statutory requirements and conditions of consent thatapply to the construction phase of the development;


-

3.1 d) Set standards and performance measures for each of the relevantenvironmental matters associated with the construction work;


-

3.1 e) Describe what actions and measures will be implemented to mitigate thepotential impacts of the construction works, and to ensure that these workswill comply with the relevant standards and performance measures;


-

3.1 f) Describe in details what measures and procedures will be implemented to : N/A - Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of theKingsgrove site and the CDC’s.

-n Manage construction traffic; -n Manage construction noise, including noise monitoring as indicated in

Condition 6.2;-

n Mitigate any potential dust impacts; -n Prevent soil contamination; -n Register and respond to complaints during the construction period; -n Respond to any emergencies; and -n Respond to the discovery of any archaeological relics or sites during the

site works.-

3.1 g) Explain how the environmental performance of the construction works will bemonitored, and what actions will be taken if any non compliance is detected;


-

3.1 h) Describe the role, responsibility, authority, accountability and reporting of keypersonnel involved in the construction of the development;


-

3.1 i) Include a Soil and Erosion Control plan which describes what measures willbe used to minimise soil erosion and the discharge of sediment and otherpollutants to nearby land, water or drains during the construction activity.This plan must be prepared in accordance with the requirements for plans inthe Department of Housing’s publication ‘Managing Urban Storm water, Soilsand Construction’ and council requirements;


-

3.1 j) Include a detailed Storm water Management Plan for the development, tomitigate the impacts of storm water runoff from the development and its

N/A - Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of the

-




PAGE 32

Condition Description of requirements/commitment Implementation EMP Referenceoperations; Kingsgrove site and the CDC’s.

3.1 k) Include a detailed Landscape Management Plan (See Conditions 4.29 -4.31)

Refer to Conditions 4.29-4.31 -

3.2 No construction work may occur on any aspect of the proposal before theConstruction Management Plan for that particular aspect of the developmenthas been approved by the Director General.


-

3.3 The Applicant must prepare a Construction Safety Study for the proposeddevelopment, in accordance with the Department’s Hazardous IndustryPlanning Advisory Paper No 7 ‘Construction Safety Guidelines’.


-

3.4 No construction work may occur before the Construction Safety Study hasbeen approved by the Director General.


-

3.5 The Applicant must prepare and implement an Environmental ManagementPlan for all future operations at the site. This plan must:

This Document. This Document

3.5 a) n Describe the proposed operations; An overview of site operations has been provided. Section 2

3.5 b) n Identify all the relevant statutory requirements that apply to theoperation of the development;

A review of the statutory requirements relating to theoperations has been completed.

Section 3

3.5 c) n Set standards and performance measures for each of the relevantenvironmental issues;

Standards/performance measures for relevantenvironmental issues have been defined.

Section 4

3.5 d) n Describe what actions and measures will be implemented to mitigate thepotential impacts of the development, and to ensure that the developmentmeets these standards and performance measures;

Mitigation measures to minimise impacts of thedevelopment have been defined.

Section 5

3.5 e) n Describe what measures and procedures will be implemented to: - -n Register and respond to complaints A complaint management procedure has been outlined Section 6.3n Respond to potential emergencies, such as plant failure An emergency response procedure has been developed Section 7

3.5 f) Describe the role, responsibility, authority, and accountability of all the keypersonnel involved in the operation of the development;

Roles, responsibilities, authorities and accountabilities ofkey personnel have been defined.

Section 8

3.5 e) Incorporate the detailed Environmental Monitoring Program (see Conditions6.1-6.5); and

Refer to Conditions 6.1-6.5 -

3.5 h) Include the following: - -n Management strategies for the control of noise, dust and storm water; Management strategies for each of the defined

environment aspects have been developed.Appendix B,Appendix C andAppendix D

n A Traffic Management Plan (see Conditions 4.17-4.20); Refer to Conditions 4.17-4.20 Appendix En A Landscape Management Plan (see Conditions 4.29-4.31); and Refer to Conditions 4.29-4.31 Appendix F




PAGE 33

Condition Description of requirements/commitment Implementation EMP Referencen A Waste Management Plan (see Conditions 4.26-4.28). Refer to Conditions 4.26-4.28 Appendix G

3.6 The Applicant must ensure that a copy of the Environmental ManagementPlan is submitted to Council and is publicly available.

Allied Mills will supply a copy of the EMP to Council forpublic exhibition after it has been approved by the Director-General.

-

3.7 The Applicant must review and update the Environmental Management Planregularly, or as directed by Director-General.

Annual reviews of this plan are to be completed (orfollowing a significant incident).

-

3.8 The Environmental Management Plan must be approved by the Director-General before the mixing plant may be commissioned.

Allied Mills will submit the EMP to the Director-General forapproval.

-

4.1 Unless otherwise agreed with the Director-General, construction activities willbe restricted to the following times.n Monday to Friday 7am to 5pm;n Saturday 8am to 5pm;n No construction work to take place on Sunday or Public Holidays

No construction activities are currently taking place -

4.2 Construction activities may be conducted outside the times specified inCondition 4.1, if:(a) a delivery of material is required, outside the hours specified, by Police oranother authority for safety reasons; and/or(b) the operation or personnel or equipment is endangered;and prior notification is provided to the Council within a reasonable time limit.


4.3 The approved hours may be varied with the prior written consent of theCouncil only where it is satisfied that the amenity of residents in the localitywill not be adversely affected. If the approved hours are varied under thiscondition, the Applicant is to provide the Department with a copy of theCouncil’s written consent.


4.4 Construction noise must not exceed the construction noise levels outlined inthe EPA Environmental Noise Control Manual. In applying these noisecriteria, the background noise level should be measured and interpreted asspecified in the EPA Industrial Noise Policy.


4.5 Noise emissions from the operations at the Goodman Fielder facility must notexceed the following criteria:Project-Specific Residential Noise Limits:

Receiver Noise Limits (LAeq) dB(A)

Day(7am-6pm)

Evening(6pm-10pm)

Night(10pm-7am)

Residents to the North- 48 42 41

A noise management strategy has been developed toensure compliance with the residential noise limits defined.

Appendix B




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Condition Description of requirements/commitment Implementation EMP ReferenceWest (Baranbali St and Sth

Tallawarra St)Residents to the North

(Armitree St) 44 42 37

Residents to the West(North Tallawarra St) 47 44 37

4.6 A spill tank must be placed beneath the coupling points of the edible oiltanker and the above ground edible oil tank.

60L spill trays are carried by each edible oil tanker. Appendix D

4.7 Tankers supplying edible oil must use brake interlocks. As a condition of entry to the site, all edible oil tankers musthave brake interlocks installed

Appendix D

4.8 Bunding must be provided around the edible oil tank, with a minimumcapacity of 110% the volume of the tank.

Current bunding around the edible oil tankers has thecapacity to hold 168% of the volume of the tanks. (Tankcapacity 38ML, bund capacity 64ML)

Appendix D

4.9 Storm water isolation valves must be installed at all points where storm waterfrom the site can enter the council storm water mains. These valves must beclosed in the event of a fire or spill.

Two stormwater isolation valves are currently installed atthe site. Weekly inspections are completed by the TSH&ECoordinator to confirm they are functioning appropriately.

Appendix D

4.10 The above storm water protection features (Condition 4.6 to 4.9) must beoperational before the mixing plant is commissioned.

All measures are currently operational and are regularlymaintained.

-

4.11 Not Used - -4.12 The Applicant shall install alarms and shut-off valves on silos to prevent over-

filling.Alarms and shut off valves are installed on silos to preventoverfilling

Appendix C

4.13 Dust emissions from equipment must comply with applicable standards setout in Table B of the Clean Air (Plant and Equipment) Regulation 1997.

Equipment are enclosed within buildings (all silo vents, bagfilters etc). Monitoring conducted for internal areas. Thebulk delivery emergency vent is the only external dustsource (35mm vent, rarely used and is regularlymaintained). The silo rooms are also under negativepressure.

Appendix C

4.14 Emissions from vehicles associated with the proposed development mustcomply with applicable requirements of the Clean Air (Motor Vehicle Fuels)Regulation 1997 under the Protection of the Environment Operations Act1997.

Vehicles are visually monitored entering the site to ensurethat release of black/white smoke from vehicle does notcontinue for longer than 10sec. All vehicles associated withthe site are to be appropriately maintained and registered.

Appendix C

4.15 All activities in or on the premises must be carried out in a manner that willminimise the generation, or emission from the premises, of wind-blown ortraffic generated dust using the measures proposed in the SEE.

As above, the majority of activities are within enclosedbuildings.

Appendix C

4.16 All areas in or on the premises must be maintained in a manner that willminimise the generation, or emission from the premises, of wind-blown or

All trafficable areas of the premises are sealed, theremaining areas are vegetated.

Appendix C




PAGE 35

Condition Description of requirements/commitment Implementation EMP Referencetraffic generated dust, using the measures proposed in the SEE.

4.17 The Applicant must prepare and implement a Traffic Management Plan forthe development. This Plan must:

A Traffic Management Plan (TMP) has been prepared andimplemented.

Appendix E

4.17 a) Describe the routes which will be used by trucks associated with thedevelopment;

The TMP shows the routes to be used by trucks associatedwith the development.

Appendix E

4.17 b) Outline the hours during which trucks will operate in the vicinity of the site; The TMP outlines the hours of operation. Appendix E4.17 c) Indicate the average and maximum number of daily and weekly truck

movements which will be associated with the proposed development;The TMP provides details of the truck movementsassociated with the Allied Mills site.

Appendix E

4.17 d) Describe in detail what measures and procedures will be implemented to: - Appendix En Minimise the number of trucks which will be used to transport goods; The largest size trucks available to use in accordance with

Council guidelines are used to minimise the number oftrucks.

Appendix E

n Minimise noise and vibration associated with truck traffic; All vehicles used must be fully registered and regularlymaintained. Driver behaviour is also covered during the siteinduction process.

Appendix E

n Ensure trucks travel in a safe manner; Driver behaviour is covered during the site inductionprocess.

Appendix E

n Minimise road damage; Driver behaviour is covered during the site inductionprocess.

Appendix E

n Minimise air pollution from exhaust; and All vehicles used must be fully registered and regularlymaintained.

Appendix E

n Record and respond to complaints regarding traffic Details on the complaint handling process are includedwithin the TMP.

Appendix E

4.17 e) Incorporate monitoring to ensure the requirements of the TrafficManagement Plan are being met (refer to Condition 6.4).

The TMP includes details on the monitoring of heavyvehicle traffic associated with the site.

Appendix E

4.18 The Applicant must develop the Traffic Management Plan in consultationwith the RTA and Council.

The TMP has been developed in accordance with RTA andCouncil guidelines.

-

4.19 The Applicant shall review and, where necessary, update the TrafficManagement Plan annually as part of the AEMR, and also as directed by theDirector-General

Annual reviews (and if necessary updates) of the TMP willbe completed by Allied Mills.

-

4.20 The Traffic Management Plan must be approved by the Director-Generalbefore the expanded facility is commissioned.

The TMP will be submitted to the Director-General forapproval.

-

4.21 Before the plant may be commissioned, the Applicant must design andconstruct a new parking area providing a minimum total of 70 parking spaceson the site. Employees and visitors must not park on The Crescent.

There are currently 74 parking spaces at the site. Theinduction includes instructions that vehicles are not to beparked on the Crescent.

Figure 2-1




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Condition Description of requirements/commitment Implementation EMP Reference

4.22 Trucks servicing the site during construction and operations must not park onThe Crescent at any time.

Truck arrivals are scheduled to avoid delays and reducecongestion at the site. The induction package instructs thatvehicles are not to be parked on the Crescent.

Section 8.1.4

4.23 The carpark design must conform with AS 2890.1-1993, and commercialparking must conform with AS 2890.2-1989.

The carpark conforms with the relevant standards. -

4.24 The Applicant shall implement the recommendations of the “TrafficOperations Assessment” dated 7 November 2011 and prepared by SinclairKnight Merz, specifically

The recommendations of the SKM assessment are to beimplemented within 6 months of DP&I acceptance andissuance of MOD2

-

a) Parking restriction signage in the vicinity of Gate A on the Crescent;b) A carriageway centre-line in the vicinity of Gate A on the Crescent;

andc) Advance signage or a secondary traffic light head in the vicinity of

Gate A,In consultation with council, and to the satisfaction of the Department, within6 months of the approval of DA 143-06-01 MOD2.

4.25 The Applicant must ensure that any external lighting associated with thedevelopment is mounted, screened, and directed in such a manner so as notto create a nuisance to surrounding land uses. The lighting must be theminimum level of illumination necessary.

All adjacent land uses are industrial/commercial andoperate normal business hours. Lighting is directed inwardand does not create a nuisance to neighbouring properties.

-

4.26 The Applicant must prepare and implement a Waste Management Plan forthe development in consultation with Council. This plan must describe indetail the waste management system, including- The types and quantities of waste which will be generated at the site; and- How waste will be stored on-site, transported, and disposed of off-site.

A Waste Management Plan has been developed for theKingsgrove site that details the types and quantities ofwaste at the site and how the waste is stored, transportedand disposed of offsite.

Appendix G

4.27 The Waste Management Plan must have been approved by the Director-General before the mixing plant may be commissioned.

The Waste Management Plan is currently being submittedto the Director-General

-

4.28 After reviewing the Waste Management Plan, the Director-General mayrequire the Applicant to address certain matters identified in the plan. TheApplicant must comply with any reasonable requirements of the Director-General.

Allied Mills will address any reasonable requirementsraised from the Director-General’s review of the WasteManagement Plan

-

4.29 The Applicant must prepare and implement a detailed LandscapeManagement Plan for the development. This plan must;- Describe in detail how the site will be landscaped, including the locationand species of all planting; and

A Landscape Management Plan (LMP) has beendeveloped that outlines the location and species of plantson the site. The LMP also details the landscapingmaintenance program at the Allied Mills site.

Appendix F




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Condition Description of requirements/commitment Implementation EMP Reference- Explain how this landscaping will be managed and maintained over time.

4.30 The Landscape Management Plan must be developed in consultation withCouncil. The Plan must have been approved by the Director-General beforecommissioning the facility.

The LMP has been developed in accordance with Councilguidelines.

-

4.31 After reviewing the Landscape Management Plan, the Director-General mayrequire the Applicant to comply with any reasonable requirements of theDirector-General.

The LMP will be submitted to the Director-General forapproval.

-

4.32 If, in the opinion of a Department of Land and Water Conservation officer,any activity is being carried out in such a manner that it may damage ordetrimentally affect a watercourse/foreshore, or damage or interfere in anyway with any work, such activity on that section of the watercourse/foreshoreshall cease immediately upon oral or written direction of such officer.

Condition noted and any direction will be followed if thesituation ever arises.

-

4.33 Work as executed survey plans shall be forwarded to the DLWC uponrequest.

Condition noted and any direction will be followed if thesituation ever arises.

-

4.34 Operations shall be conducted in such a manner as not to causeenvironmental damage on or off the site, not increase the erosion of adjacentwatercourse/foreshore banks. The Applicant shall carry out any instructionsgiven by the DLWC with a view to preventing damage and to restore the site.

There is no runoff directly from the site into the nearbystormwater drain (the RTA owned drain is concrete lined),two stormwater drainage lines collect stormwater from thesite and direct it the drainage lines.

-

4.35 Work to be carried out in accordance with the plans presented to DLWC. Works have been carried out generally in accordance withthe plans, however no record of these being submitted toDLWC.

-

4.36 The rehabilitation of any area affected by the proposal is to be in accordancewith any approval of direction issued by the DLWC, and is the responsibilityof the permit holder and the owner and occupier of the land.

The requirement to rehabilitate any area which has beenaffected by the development has been noted and will becomplied with if necessary. Currently there has been noneed to rehabilitate any area of the site.

-

5.1 The Applicant must prepare a detailed Fire Safety Study covering all of theoperations at the site to demonstrate BCA compliance. The Study mustcover all aspects detailed in the Department’s Hazardous industry PlanningAdvisory Paper No.2 “Fire Safety Study Guidelines” and the NSWGovernment “Best Practice Guidelines for Contaminated Water Retentionand Treatment Systems”. The Study must address, but not be limited to firesafety issues associated with dust explosions and storage of vegetable oils.The Fire Safety Study must be submitted to the Director-General forapproval, in consultation with the NSW Fire Brigades. Approval must beobtained before the issues of construction certificates.

A Fire Safety Study was prepared for Allied Mills (formerlyGoodman Fielder Ltd) by Environmental Audits of Australia(EAA), Report # 21069FSS. This report was submitted toNSW DoP and NSW FB on 24th October, 2001.

Fire SafetyStudy Report #21069FSS

5.2 At least one month prior to the commencement of commissioning, or within A Deflagration Management Strategy (DMS) was prepared Deflagration




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Condition Description of requirements/commitment Implementation EMP Referencesuch period as otherwise agreed by the Director-General, the Applicant shallprepare and submit for the approval of the Director-General a DeflagrationManagement Strategy. The Strategy shall be prepared and implemented withthe aim of minimising situations conductive to explosions involving finecombustible particulates. The Strategy shall include, but not necessarily belimited to:

for Allied Mills (formerly Goodman Fielder Ltd) byEnvironmental Audits of Australia (EAA), Report # 52004.Comments were received from DP&I on 11/08/2011, andaddressed in an update to the 2010 SKM Risk Auditsubmitted on 10/05/2012.

ManagementStrategy (DMS)Report #52004

5.2 a) Identification of materials stored and/or handled at the development that maybe involved in deflagration incidents, including the location, quantity andstate(temperature, moisture, agitation etc) of such materials;

A summary of materials stored at the site and details of thelocation, quantity and state are included in the DMSReport.

DMS Report

5.2 b) A description of the processes used to handle fine particulate combustibles,with specific consideration of components of such processes involvingagitation, electricity and heat;

The DMS Report covers the management of dusts, controlsystems, extraction systems and fail safe systemsemployed.

DMS Report

5.2 c) Details of how the development will meet the requirements of relevantAustralian Standards including AS2430.2-1986 Classification of HazardousAreas Part 2 – Combustible Dusts and AS/NZS 2381.1-1999 – ElectricalEquipment for Explosive Atmospheres – Selection, Installation andMaintenance Part 1 – General Requirements;

The classification of hazardous areas at the site is coveredin Section 4 of the DMS Report.

DMS Report

5.2 d) Protocols and procedures for the handling of fine combustible particulates,including consideration of process atmospheric composition, sparkavoidance and measures to minimise the formation of suspended particulateclouds;

Dust suppression, extraction and filtrations systemsprovided at the site are covered in the DMS Report.

DMS Report

5.2 e) Protocols and procedures for periods of operation during which a greaterpotential for deflagration exists, including start-up and shut-down (bothcontrolled in an emergency);

The protocols and procedures for operating at high risktimes (such as start-up and shut-down) are covered in theDMS Report.

DMS Report

5.2 f) Details of how dust levels in the building will be monitored, and how the dustcollection system will be maintained; and

Brief discussion of dust monitoring and collection in theDMS Report, although systems are enclosed and externaldust monitoring covered under maintenance andhousekeeping procedures in ENABLE SMA database

DMS Report

5.2 g) Details of training programs to ensure that all relevant employees are awareof the potential for deflagration and the measures implemented to minimisedeflagration incidents.

Training programs covered under Allied Mills Internal e-procedures system - ENABLE.

DMS Report

5.3 No later than one month prior to the commencement of commissioning, orwithin such period otherwise agreed with the Director-General, the Applicantshall prepare and submit for approval of the Director-General the studies setout under (a) and (b) below. Commissioning shall not commence untilapproval has been given by the Director-General.

An Emergency Response Plan (ERP) has been preparedand documented for the site.

EmergencyResponse Plan




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a) A comprehensive Emergency Plan and detailed emergency proceduresfor the site, prepared by a duly qualified person or team. This Plan shouldinclude details procedures for the safety of all people in the vicinity of the sitewho may be at risk from operations at the site. The Plan shall be inaccordance with the Department’s Hazardous Industry Planning AdvisoryPaper No.1 – Industry Emergency Planning Guidelinesb) A document setting out a comprehensive Safety Management System,covering all operations onsite and associated transport activities involvinghazardous materials. The document shall clearly specify all safety-relatedprocedures, responsibilities and policies, along with details of mechanismsfor ensuring adherence to procedures. Records shall be kept onsite and shallbe available for inspection by the Director-General upon request. The SafetyManagement System shall be developed in accordance with theDepartment’s Hazardous Industry Planning Advisory Paper No.9 – SafetyManagement.

Made up of numerous Allied Mills safety documents/ andprocedures within the Document Management System.

SAP

5.4 Dangerous Goods storage must be in accordance with the AustralianDangerous Goods Code, relevant Australian Standards, and Work Coverrequirements. Spill cleanup kits and procedures must be made available andused in the event of a spill.

Refer SKM audit findingsA WorkCover NSW licence has been received for the site(lic no 35/035076, exp date 3/5/2012). Spill kits are stockedand provided at the edible oils station

DangerousGoods Licence

6.1 The Applicant must prepare and implement a detailed EnvironmentalMonitoring Program for the development in consultation with the EPA. Theprogram must:

An Environmental Monitoring Program has been developedin this plan.

Section 9.2

6.1 a) Identify what environmental issues will be monitored; The environmental aspects that could pose issues areidentified.

Section 4

6.1 b) Set standards and performance measures for these environmental issues; Standards/performance measures are identified in thisplan.

Section 4

6.1 c) Describe in detail how these issues will be monitored, who will conduct themonitoring, how often the monitoring will be conducted, and how the resultsof this monitoring will be recorded and reported to the Director-General andother relevant authorities.

The environmental monitoring program has been brokendown into the relevant aspects and is presented in thisplan.

Table 9-2

6.1 d) Indicate what actions will be taken, or procedures followed, if any non-compliance is detected; and

A noise management strategy has been developed toconform with the noise criteria in Condition 4.5

Section 9.4

6.1 e) Include the following:n A Noise Compliance Monitoring Program (see below) to determine the

level of compliance with the noise criteria in Condition 4.5; andn Traffic Monitoring

n A noise management strategy has been developed toconform with the noise criteria in Condition 4.5; and

n A Traffic Management Plan has been developed forthe site.

Appendix B

Appendix E




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6.2 The Applicant must conduct noise monitoring during the construction phaseat the site boundaries and the nearest potentially affected residential areas.Monitoring must be conducted in accordance with EPA guidelines.

Construction activities were carried out by GoodmanFielder prior to Allied Mills taking possession of theKingsgrove site and the CDC’s.

-

6.3 If substantiated community noise complaints occur, the Director-General maydirect the Applicant to commission and pay the full cost of a noise audit.Should any noise audit demonstrate an exceedance of the project specificnoise limits outlined in Condition 4.5 (using distance attenuationcalculations), the Applicant shall employ mitigation measures to reduce noiseimpacts from the site, to the satisfaction of the Director-General.

A noise management strategy has been developed tocomply with the limits of Condition 4.5.

Table 9-2; andAppendix B

6.4 The Applicant must monitor compliance with the Traffic Management Plandescribed in Condition 4.17. Monitoring must occur within three months ofcommissioning the mixing plant, and every six months thereafter.

Monitoring is conducted daily by the site entry system. Appendix E

6.5 The Environmental Monitoring Program must have been approved by theDirector-General before the plant may be commissioned.

The Environmental Monitoring Program is being submittedto the Director-General with this plan for approval.

-

6.6 The Environmental Monitoring Program, the Director-General may requirethe Applicant to address certain matters identified in the program. TheApplicant must comply with any reasonable requirements of the Director-General.

Allied Mills will comply with any reasonable requirements ofthe Director-General.

-

7.1 Twelve months after commissioning the food processing plant and annuallythereafter for the duration of the development, the Applicant must submit anAnnual Environment Management Report to the Director-General and theCouncil. This report must:

An Annual Environmental Management Report (AEMR) willbe compiled and issued to the Director-General andCouncil.

Section 10

7.1 a) Identify all standards, performance measures, and statutory requirements thedevelopment is required to comply with;

The AEMR will identify all standards and statutoryrequirements (provided in this plan)

Sections 3 and4

7.1 b) Review the environmental performance of the development to determinewhether it is complying with these standards, performance measures andstatutory requirements.

The AEMR will review the performance of Allied Millsagainst the standards and statutory requirements providedin this plan.

Sections 3 and4

7.1 c) Identify all the occasions during the previous year when these standards,performance measures, and statutory requirements have not been compliedwith;

The AEMR will identify any non-conformances detectedduring the previous year.

Section 9.4

7.1 d) Include a summary of any complaints made about the development andindicate what actions were taken (or are being taken) to address thesecomplaints;

The AEMR will include a summary of any complaintsrecorded during the previous year.

Section 6.3

7.1 e) Include the detailed reporting from the Environmental Monitoring program(see Condition 6.1-6.6), and identify any trends in the monitoring over the lifeof the project; and

The AEMR will include the detailed reporting from theEnvironmental Monitoring Program

Section 9




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7.1 f) Where non-compliance is occurring, describe what actions are or will betaken to ensure compliance, who will be responsible for carrying out theseactions, and when these actions will be implemented.

The AEMR will include a summary of any actions taken inresponse to an identified non-compliance in the previousyear.

Section 9.4

7.2 After reviewing the Annual Environmental Management Report, the Director-General may require the Applicant to address certain matters identified in thereport. The Applicant must comply with any reasonable requirements of theDirector-General.

Allied Mills will comply with any reasonable requirementsissued by the Director General in response to the AEMR.

-

7.3 Within 12 months of commissioning the food processing plant, and everythree years thereafter, unless the Director-General directs otherwise, theApplicant must commission and pay the full cost of an IndependentEnvironmental Audit. The Independent Environmental Audit must:

Allied Mills will commission an Independent EnvironmentalAudit of the food processing plant every three years.

Anenvironmentalaudit wascompleted bySKM in July2010.

7.3 a) Be conducted by a suitably qualified, experienced, and independent personwhose appointment has been endorsed by the Director-General;

Allied Mills will ensure that the auditor is suitably qualified,experienced and independent, and approved by the DP&Iprior to commissioning..

-

7.3 b) Be consistent with ISO 14010 – Guidelines and General Principles forEnvironmental Auditing, and ISO 14011 – Procedures for EnvironmentalAuditing or updated version of these guidelines/manuals;

The audit will be consistent with the requirements ofISO19011:2003 – Guidelines for quality and/orenvironmental management systems auditing (or anupdated version of the guidelines).

-

7.3 c) Assess the environmental performance of the development, and its effectson the surrounding environment;

The audit will include an assessment of the environmentalperformance of the development and its effects on thesurrounding environment.

-

7.3 d) Assess whether the development is complying with the relevant standards,performance measures, and statutory requirements;

The audit will assess if Allied Mills are complying withrelevant standards, performance measures and statutoryperformance.

-

7.3 e) Review the adequacy of the Applicant’s Environmental Management Plan,and Environmental Monitoring Program; and if necessary:

The audit will review the adequacy of Allied Mills EMP andEnvironmental Monitoring Program.

-

7.3 f) Recommend measures or actions to improve the environmental performanceof the plant, and/or the environmental management and monitoring systems.

The audit will (if necessary) provide actions to improve theperformance of the plant.

-

7.4 Within 2 months of commissioning the audit, the Applicant must submit acopy of the audit report to the Director-General. After reviewing the report,the Director-General may require the Applicant to address certain mattersidentified in the report. The Applicant must comply with any reasonablerequirements of the Director-General.

Allied Mills commissioned SKM to complete an initialenvironmental audit of its Kingsgrove operations in July2011. Due to the initial audit requiring extensive searchingto locate key documents the initial timeframe to submit tothe Director-General was unable to be met.

SKMenvironmentalaudit wassubmitted on 22October 2011

8.1 Within 24 hours of any accident or potential incident with actual or potential An Incident Reporting process has been developed which Section 7.2




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Condition Description of requirements/commitment Implementation EMP Referenceoff-site impacts on people or the biophysical environment, a report must besupplied to the Department outlining the basic facts. A further detailed reportmust be prepared and submitted following investigations of the causes andidentification of necessary additional preventative measures. This reportmust be submitted to the Director-General no later than 14 days after theincident or potential incident.

includes the compilation of an immediate (within 24 hours)basic report and a detailed investigation (within 14 days), inthis plan.

8.2 The Applicant must maintain a register of accidents, incidents and potentialincidents. The register must be made available for inspection at any time bythe independent hazard auditor (refer to condition 8.3) and the Director-General.

An incident log is maintained on site. Section 7.2

8.3 Twelve months after the commencement of operations, and every threeyears thereafter, unless the Director-General directs otherwise, the Applicantmust commission and pay the full cost of a comprehensive hazard audit. Thehazard audit must:

Allied Mills will commission an Independent Hazard Auditof the food processing plant every three years.

A hazard auditwas completedby SKM in July2010.

8.3 a) Be conducted by a suitably qualified, experienced, and independent personwhose appointment has been endorsed by the Director-General;

Allied Mills will ensure that the auditor is suitably qualified,experienced and independent and endorsed by DP&I priorto comissioning.

-

8.3 b) Be conducted in accordance with the Department’s Hazardous IndustryPlanning Advisory Paper No.5 “Hazard Audit Guidelines”;

The audit will be consistent with the requirements of theNSW DoP Hazard Audit Guidelines (HIPAP #5), (or anupdated version).

-

8.3 c) Include, but not be limited to, a review of the site safety management systemand a review of all entries made in the incident register since the previousaudit;

The audit will as a minimum a review of the site safetymanagement system and all entries in the incident logsince the previous audit.

-

8.4 Within one month of commissioning the audit, the Applicant must submit acopy of the audit report to the Director-General. After reviewing the report,the Director-General may require the Applicant to address certain mattersidentified in the report. The Applicant must comply with any reasonablerequirements of the Director-General.

Allied Mills commissioned SKM to complete an initialhazard audit of its Kingsgrove operations in July 2011. Dueto the initial audit requiring extensive searching to locatekey documents the initial timeframe to submit to theDirector-General was unable to be met.

SKM hazardaudit wassubmitted on 22October 2011

9.1 If the Applicant Hurstville City Council, and/or any NSW Government agency,other than the Department of Urban Affairs and Planning, cannot agree onany aspect of this consent, other than a General Term of Approval, thematter may be referred by any of these parties to the Director-General or, ifnecessary, the Minister, whose determination on the dispute shall be bindingon all parties.

All parties have agreed on the consent conditions. -




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Appendix B Noise Management StrategyPotential Impacts: Noise from operations causes community complaints

Risk: Community Complaints – Low – most works are within enclosed buildings and surrounding land use includes otherindustrial businesses and a major highway.

Environmental Outcomes The site will be run in a manner so that environmental noise is not a nuisance to nearby residents by ensuring thatappropriate noise management practices are implemented onsite.

Major ComplianceRequirements:

Conditions 4.5 of Development Consent – Noise CriteriaNoise emissions from operations at the site must not exceed the following criteria:

Receiver Noise Limits (LAeq) dBADay (7am – 6pm) Evening (6pm – 10pm) Night (10pm – 7am)

Residents to the NW(Baranbai St and SthTallawarra St)

48 42 41

Resident to the N (ArmitreeSt) 44 42 37

Residents to the W (NthTallawarra St) 47 44 37

Condition 6.3 of Development Consent – Noise Compliance Monitoring Program

If substantiated community noise complaints occur, the Director-General may direct the Applicant to commission and paythe full cost of a noise audit. Should any noise audit demonstrate an exceedance of the project specific residential noiselimits outlined in Condition 4.5 (using distance attenuation calculations), the Applicant shall employ mitigation measures toreduce noise impacts from the site, to the satisfaction of the Director-General.

Monitoring: Noise monitoring will be undertaken by a suitably qualified specialist and results will be provided to Allied Mills.

Mitigation MeasuresReference Control Measures Action By Timing Sign-off/Date

CDC Cond. 4.5 Plant/equipment are to be contained within enclosedbuildings as much as possible.

Site Manager Before Commissioning Completed

CDC Cond. 6.3 If a community complaint/enquiry is received regardingnoise from the site, Allied Mills will organise for anappropriate noise monitoring program to be instigated.

Site Manager As necessary Within one week ofreceiving complaint




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Appendix C Air Quality Management StrategyPotential Impacts: · Dust from site activities causes community complaints

· Dust from site activities causes water pollutionRisk: · Community Complaints – Low – as works are contained within enclosed buildings and all roads/driveways are sealed.

· Water Pollution – Low – as dust generation from works is minimal and contained within the site.Environmental Outcomes The site will be operated in a manner that minimises air emissions from the property

Major ComplianceRequirements:

Condition 4.12 – Alarms and shut off valves shall be installed on silos to prevent overfilling;Condition 4.13 – Dust emissions from equipment must comply with the Clean Air (Plant and Equipment) Regulation;Condition 4.14 – Emissions from vehicles associated with the site must comply with the Clean Air (Motor Vehicles andMotor Vehicle Fuel) Regulation;Condition 4.15 – All site activities are to be carried out in a manner to minimise generation (or emission) of wind-blown ortraffic generated dust; andCondition 4.16 – All areas at the site are to be carried out in a manner to minimise generation (or emission) of wind-blownor traffic generated dust.

Monitoring: Visual monitoring of the site for dust generation by Allied Mills staff


CDC Cond. 4.12 Alarms and shut-off valves are installed on silos to preventoverfilling. Test and maintain alarms and shut off valves toensure operations.

Site Manager BeforeCommissioning

Completed

CDC Cond. 4.13; CleanAir (Motor Vehicles &Motor Vehicle Fuels)Regulation 1997

Visually monitor vehicles equipment exhausts to ensure thatrelease of black/white smoke does not exceed 10sec. Maintainplant. Do not use plant which exceeds limit.

Site Manager orDesignated Person

As necessary As necessary

CDC Cond. 4.14; CleanAir (Motor Vehicles &Motor Vehicle Fuels)Regulation 1997

Visually monitor vehicles entering the site to ensure that releaseof black/white smoke from vehicle does not continue for longerthan 10sec. All vehicles associated with the site are to beappropriately maintained and registered.

WarehouseManager


CDC Cond. 4.15 The majority of plant/equipment are contained within enclosedbuildings to reduce the possibility of dust emissions. Silo roomsare also maintained under negative pressure to minimise dustemission potential.


Completed

CDC Cond. 4.16 All trafficable areas onsite are sealed to reduce exposure to dustand site speed limits are enforced. Landscaping is in place inareas that have not been sealed.


Completed




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Appendix D Stormwater Management StrategyPotential Impacts: · Water pollution from spills entering stormwater system

Risk: · Water Pollution – Moderate – appropriate controls are in place, but procedures must be followed

Environmental Outcomes The site activities will not adversely impact the water quality of the council’s stormwater mains

Major ComplianceRequirements: Condition 4.6 – A spill tank must be placed beneath coupling points of the edible oil tanker and the above ground edible oil

tank;Condition 4.7 – Tankers supplying edible oil must use brake interlocks;Condition 4.8 – Bunding around edible oil tank must have a minimum capacity of 110%;Condition 4.9 – Stormwater isolation valves must be installed at all stormwater exit points from the site;

Monitoring: Maintenance inspection’s of isolation valves, use of spill tray’s and truck brake interlocks.


CDC Cond. 4.6 Each truck carries a spill tray with a capacity of approx60L. Occasional spot checks to ensure the spill trays arebeing used.

Site Manager orDesignatedPerson


CDC Cond. 4.7 Brake interlocks are a condition of entry to the site foredible oil tankers.


Annually Trucks Registration

CDC Cond. 4.8 The edible oil storage tanks at the site can hold 38ML ofproduct, the bund capacity around the storage tanks is64ML. Regular inspections are required to ensurecapacity of bunding is maintained


Weekly Weekly HS&EInspection

CDC Cond. 4.9 Two isolated systems are operational at the site. Regularinspections are completed to ensure the systems arefunctioning



Best Practice Regular cleaning maintenance of stormwater pits Site Manager orDesignatedPerson





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Appendix E Allied Mills Kingsgrove

Traffic Management Sub Plan

n Revision 3.1

n Effective: 29.03.2017




PAGE 47

Contents1. Introduction 5

1.1. Environmental Management Plan purpose 51.2. Environmental Management Plan scope 51.3. Environmental Management Plan objectives 61.4. Preparation of this EMP and Sub-Plans 6

2. Overview of site operations 72.1. Bulk deliveries 72.2. Truck docks / driveway 72.3. Offices / kitchens and laboratories 82.4. Production floor 82.5. Silos 82.6. Oil storage 8

3. Legislative and regulatory requirements 103.1. Conditions of Development Consent (CDCs) 103.2. Legislation 113.3. Standards and guidelines 11

4. Environmental aspects 135. Environmental impacts and controls 14

5.1. Overview 145.2. Environmental management strategies 145.3. Environmental management sub-plans 145.4. Site induction and training 15

6. Communications and reporting 166.1. Reporting 166.2. Communications 166.3. Complaints management 16

7. Emergency response 177.1. Incident response 177.2. Incident reporting 17

8. Environmental management responsibilities 198.1. Environmental roles and responsibilities 198.1.1. Site Manager 208.1.2. National Work Health Safety and Environmental (WHSE) Manager and Coordinator

218.1.3. Production Managers 218.1.4. Warehouse Manager 21




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8.1.5. Maintenance Manager 218.1.6. Employees, Contractors and Delivery Drivers 228.1.7. Environmental Contractors 22

9. Monitoring, inspection & auditing environmental performance 239.1. Overview 239.2. Environmental monitoring program 239.3. Inspections and audits 259.3.1. Audit action plan 259.4. Non-compliances 25

10. Environmental reporting 2611. Management review 27Appendix A Conditions of Development Consent 29Appendix B Noise Management Strategy 43Appendix C Air Quality Management Strategy 44Appendix D Stormwater Management Strategy 451. Introduction 502. Heavy Vehicle Route 503. Hours of Operation 534. Daily Deliveries and Dispatch 535. Mitigation Measures 54

5.1. Complaint/Incident Management 54

6. Truck Monitoring 556.1. Site Entry and Exit 55

7. Management Review 571. Introduction 602. Site Landscaping 603. Landscape Maintenance 634. Council Landscaping Requirements 635. Management Review 641. Introduction 672. Waste Streams 673. Onsite Storage 684. Waste Disposal 705. Management Review 70




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Appendix H: Environmental Inspection Report Template 71Appendix J Emergency Contacts 74




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1. IntroductionAllied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). Theoperation of this plant requires the delivery of flour, oil and other ingredients to process these intovarious products and the dispatch of final product. The delivery of these materials is the subject ofconditions 4.17 to 4.20 of the conditions of developmental consent (CDC), which this TrafficManagement Plan (TMP) has been developed to address. The CDC’s and the sections within this TMPwhere the conditions are addressed are listed within Table 3-1.

n Table 1-1 Condition of Consent RequirementsCondition Condition Requirements TMP Section

4.17 The Applicant must prepare and implement a Traffic Management Plan for thedevelopment. This Plan must:

This Document

4.17 a) Describe the routes which will be used by trucks associated with the development; Section 2

4.17 b) Outline the hours during which trucks will operate in the vicinity of the site; Section 3

4.17 c) Indicate the average and maximum number of daily and weekly truck movements whichwill be associated with the proposed development;

Section 4

4.17 d) Describe in detail what measures and procedures will be implemented to: -

n Minimise the number of trucks which will be used to transport goods; Section 5

n Minimise noise and vibration associated with truck traffic; Section 5

n Ensure trucks travel in a safe manner; Section 5

n Minimise road damage; Section 5

n Minimise air pollution from exhaust; and Section 5

n Record and respond to complaints regarding traffic. Section 5.1

4.17 e) Incorporate monitoring to ensure the requirements of the Traffic Management Plan arebeing met (refer to Condition 6.4).

Section 6

4.18 The Applicant must develop the Traffic Management Plan in consultation with the RTA andCouncil.

Section 6

4.19 The Applicant shall review and, where necessary, update the Traffic Management Planannually as part of the AEMR, and also as directed by the Director-General.

Section 7

4.20 The Traffic Management Plan must be approved by the Director-General before theexpanded facility is commissioned.

Section 7

2. Heavy Vehicle RouteIn accordance with the planning guidelines from the Roads and Maritime Services (RMS) andGeorges River Council, access to the site with articulated trucks should refrain from using local roadsand remain as much as possible on state and regional roads (based on the HCC road classifications).King Georges Road is a designated state road and Kingsgrove Road, Vanessa Street, ToorongaTerrace and Commercial Road are designated regional roads, the only local road delivery trucks to




PAGE 51

Allied Mills will utilise is The Crescent. There are two alternatives (shown on Figure 2-1) that willminimise the use of local roads for delivery to the site which are:

1) From King Georges Road – delivery trucks would turn onto Tooronga Terrace and continue ontoVanessa Street, then turn left into The Crescent to enter the Allied Mills site.

2) From Kingsgrove Road – delivery trucks would turn onto Commercial Road and continue ontoVanessa Street, then turn right into The Crescent to enter the Allied Mills site.




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n Figure 2-1: Allied Mills, Kingsgrove - Heavy Vehicle Haulage Route




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3. Hours of OperationThe site may utilise despatch and delivery truck accesing the site over a 24 hour period dependingon the needs of the site. This will assist with ensuring mitigation measures minimise the impacts oftraffic accociated with the site.

Employee hours of work are:n 6:30 am to 8:00pm Day Shiftn 2:30 pm to 10:30 pm Afternoon Shiftn 10:30 pm to 6:30 am Night ShiftThe plant normally operates 24 hour day, 6 days a week. However, on occasion the plant is requiredto operate for 24 hours a day, 7 days a week.

4. Daily Deliveries and DispatchA traffic impact statement (ref: 21-070R(3), Rhodes Thompson Associates 2001) was prepared withprojection truck movements at full manufacturing capacity.

To comply with 4.17 c) of the Conditions of Consent:The traffic management plan has used the above reference to calculate the projected truckmovement at full manufacturing capacity of 150,000T per annum. Refer Table 4.1

· Table 4.1 – Predicted truck movements for Site

Truck Movement Total Monthly TruckMovements

Average WeeklyTruck Movements

Average Daily TruckMovements.

Projected maximum truckmovement as predicted inTraffic Impact Statement

3,315 763 109




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5. Mitigation MeasuresIn order to minimise the impacts of traffic associated with the bulk delivery of ingredients anddispatch of product to and from the Allied Mills site, the following procedures are required prior toentry.

n Allied Mills endevours to dispatch trucks with full loads where possible to minimise the numberof trucks accessing the site.

n All vehicles must be registered;

n All vehicles must be maintained in an adequate manner;

n All drivers must be licensed to operate vehicles and must obey all road rules;

n Drivers are to avoid using compression braking and hard acceleration when on ToorongaTerrace, Vanessa Street, Commercial Road or The Crescent; and

n Drivers are to avoid using high beam lights when on Tooronga Terrace, Vanessa Street,Commercial Road or The Crescent.

The above mitigation measures are included within the site induction and/or subcontractoragreements, which transport companies must complete prior to delivering products to the site.

5.1. Complaint/Incident Management

Allied Mills Kingsgrove shall report any complaints or incidents into the Incident Reporting Database. The Incident Reporting Database shall record, but not necessarily be limited to:

a) the date and time, of the complaintb) the means by which the complaint/incident was madec) any personal details that were provided, or if no details were provided, a note to that effectd) the nature of the complaint/incidente) any action(s) taken by the Allied Mills Kingsgrove in relation to the complaint/incident,

including any follow up contact with complainant/reporter.f) if no action was taken by Allied Mills Kingsgrove in relation to the complaint/incident, the

reason(s) why no action was takenThe Incident reporting Database shall be made available for inspection by relevant statutoryauthorities on request.




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6. Truck Monitoring6.1. Site Entry and Exit

The site has two entry gates located on The Crescent. Gate A is the entry point for delivery / dispatchtrucks, couriers and staff/visitor vehicles. Gate B is the entry gate for bulk tankers which unload atthe bulk out loading point on the southern side of the site. A site layout plan with traffic directionand pedestrian pathways is provided as Figure 2-1.

Gate A is the exit point for all site traffic. The location of the bulk out loading facility does not allowvehicle access to the southern side of the site when a truck is unloading. For this reason, Gate Bcannot be used as an exit point for traffic.

The site boundary has a security fence and gates which are only operational by access swipe tags orcontrolled entry via the main office. Only site employees have access swipe cards. All other entry isvia an access button at the gate. The site traffic is under constant surveillance using CCTV cameraslocated around the site.

Records are kept of the delivery / dispatch vehicles that are on the site as well as of staff and visitors.The times and volumes of traffic are recorded and used for scheduling purposes to ensure thatdeliveries to the plant run efficiently and this in turn ensures the traffic volumes on public roads arenot too imposing to the surrounding neighbours.

6.2 Pedestrian Access

Pedestrian access and walkways are identified around the site using walkways and barriers toidentify the route pedestrians are to use. From the carpark located at the rear of the site,pedestrians can access the main buildings using pedestrian walkways and shared zones allowingacess to the production facility and office administration area.A shared zone is identified by a cross hatching on the ground and sign posted areas.




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n Figure 6-1 Allied Mills Kingsgrove site layout plan.




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7. Management ReviewIn accordance with the requirement of Condition 4.19 of the CDC, this TMP will be reviewed annuallyby Allied Mills. Where necessary the report will be updated to reflect any relevant changes.

A management review may also be required in response to a request from the Director-General. Insuch cases, a review will be completed and any updates will be provided to the Director-General forapproval. Prior to the commissioning of the expansion to the sites capacity (beyond those approvedwithin the conditions of consent), the TMP will be reviewed and submitted to the Director-General,in accordance with Condition 4.20 of the CDC.




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Appendix F: Allied Mills Kingsgrove

Landscape Management Plan

n Revision: 3.1





, Page 59

Contents1. Introduction 602. Site Landscaping 603. Landscape Maintenance 634. Council Landscaping Requirements 635. Management Review 64




, Page 60

1. IntroductionAllied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). The sitewas inherited from Goodman Fielder and requires compliance with conditions 4.29 to 4.31 of theconditions of developmental consent (CDC’s) (S01/00876), which this Landscape Management Plan(LMP) has been developed to address. The conditions of consent and the sections within this LMPwhere the conditions are addressed are listed within Table 3-1.

n Table 0-1 Condition of Consent RequirementsCondition Condition Requirements EMP Section

4.29 The Applicant must prepare and implement a detailed Landscape Management Plan forthe development. This plan must;- Describe in detail how the site will be landscaped, including the location and species of allplanting; and- Explain how this landscaping will be managed and maintained over time.

This Document

Section 2Section 3

4.30 The Landscape Management Plan must be developed in consultation with Council. ThePlan must have been approved by the Director-General before commissioning the facility.

Section 4

4.31 After reviewing the Landscape Management Plan, the Director-General may require theApplicant to comply with any reasonable requirements of the Director-General.

Section 5

2. Site LandscapingAllied Mills acquired the Kingsgrove site from Goodman Fielder in 2003. The existing vegetation atthe site has been maintained throughout the operations by Allied Mills, but a surveyed landscapeplan was not provided. In accordance with the requirements of the Hurstville City Council (HCC)Development Control Plan (DCP), indigenous species have been maintained as much as possible (fullrequirements of the HCC DCP are included in Table 4-1). A list of species used in landscaping at thesite is provided at Table 2-1.

The site contains a mix of native and exotic plant species arranged and planted in a natural andmaintained garden landscape. Forty-six tree, shrub and groundcover species were identified duringsite investigations. There were also numerous unidentified grass, herb and bryophyte species withinmaintained lawn areas.

A general layout plan of the landscaping at the Allied Mills site is provided in Figure 2-1.

n Table 2-1 Landscaping Species

Plant Category Species Native IntroducedTrees Swamp Oak (Casuarina glauca) x

Lemon-scented gum (Corymbia citriodora) xSpotted Gum (Corymbia maculata) xEucalyptus sp. (unidentified – plant material unavailable) xTallowwood (Eucalyptus microcorys) x




, Page 61

Plant Category Species Native IntroducedSwamp Mahogany (Eucalyptus robusta) xNarrow-leaf Red Gum (Eucalyptus sp.) xForest Red Gum (Eucalyptus tereticornis) xJacaranda (Jacaranda mimosifolia) xBracelet Honey-myrtle (Melaleuca armillaris) xBroad-leaved Paperbark (Melaleuca quinquenervia) xPrickly-leaved Tea Tree (Melaleuca styphelioides) xPoplar (Populus sp.) x

Shrubs Japanese Boxwood (Buxus microphylla var. japonica) xCameilla sp. cultivar xUnknown Cactus (Cactaceae) xCallistemon sp. cultivar xCrimson Bottlebrush (Callistemon citrinus) xRough Lemon (Citrus x taitensis) xBlueberry Ash (Elaeocarpus reticulates) xCumquat (Fortunella japonica) xGrevillea sp. cultivar xJuniper sp. xLantana (Lantana camara) xOrange Jessamine (Murraya paniculata) xPandanus sp. xSweet Pittosporum (Pittosporum undulatum) xCocos Palm (Syagrus romanzoffiana) xLilly Pilly (Syzygium sp.) xXanthorrhoea sp. xUnidentified (plant material unavailable) x

Ground Layer African Lily (Agapanthus praecox subsp. orientalis) xAsparagus Fern (Asparagus scandens) xWild Aster (Aster subulatus) xCobbler’s Peg (Bidens pilosa) xCouch Grass (Cynodon dactylon) xBlue Flax-lily (Dianella caerulea) xButterfly Iris (Dietes bicolor) xGrevillea 'Poorinda Royal Mantle' xMat-rush (Lomandra longifolia) xJapanese Honeysuckle (Lonicera japonica) xHexham Scent (Melilotus indicus) xFishbone Fern (Nephrolepis cordifolia) xMondo Grass (Ophiopogon japonicas) xStar Jasmine (Trachelospermum jasminoides) x




, Page 62

n Figure 2-1: Allied Mills, Kingsgrove – Landscaping General Layout Map




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3. Landscape MaintenanceThe existing vegetation at the Allied Mills site is currently maintained fortnightly to ensure theamenity to the surrounding community and site workers are not impacted in accordance with theHCC DCP 1 requirements.

A landscaping sub-contractor is commissioned by Allied Mills on a fortnightly basis to maintain thesite landscaping. This includes the management of weeds, mowing of grassed areas,trimming/shaping of shrubs, collection of fallen branches and other maintenance works as required.

4. Council Landscaping RequirementsHCC has outlined the landscaping requirements for light industry in Section 5.3.5 of the DCP 1. Therequirements of Section 5.3.5 are outlined in Table 4-1.

n Table 4-1 HCC DCP 1 - Landscaping RequirementsSection Section Requirements LMP Section

5.3.5.1 General -

a) Development applications are to be accompanied by a landscape plan prepared bya suitably qualified landscape architect or designer.

Section 2

b) A survey plan is to accompany a development application indicating the preciselocation of existing trees, their condition, species and crown size, and which treesare proposed to be removed.

Section 2

c) Landscaping includes both hard and soft works. Hard works include things such aspaving, ramps, terracing, retaining walls etc. Soft works refer to vegetation (grass,shrubs, trees etc) and earthworks.

Section 2

d) Landscaping design is to generally incorporate species indigenous to the area andthose which will not cause damage to adjacent buildings and driveways. Plants toavoid are those which have a short life, drop branches, gum or fruit, or whichinterfere with underground pipes.

Section 2

5.3.5.2 Streetscape (Front Setback Area) -

a) Landscaping is to be provided in the front setback area to soften the appearance ofbuildings and enhance the streetscape.

Existing vegetation alreadyin Front Setback Area

b) Landscaping is to be provided where the site abuts access streets, service roads,railway lines or residential development.

N/A

c) Species that will grow to a height consistent with the building are to be included. The existing vegetation isthe height of the building

5.3.5.3 Significant Trees -

a) Buildings, driveways and service trenches are to have a minimum setback of 4metres from trees and groups of trees which have been assessed as significant.

N/A – site acquired withexisting vegetation.




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b) Protective measures are required around trees during site works and construction.Such measures are to be submitted with the development application.


5.3.5.4 Amenity -

a) An outdoor eating and sitting area is to be provided within sites at the rate of 1m2per employee, with a minimum total area of 10m2.


b) Trees planted on site should provide shade in summer and allow sunlight in winterand should be positioned appropriately.


5. Management ReviewThis LMP will be reviewed and updated as necessary by Allied Mills.

In accordance with the requirement of Conditions 4.31 of the CDC, if the Director-General has anyreasonable requests in relation to this plan, Allied Mills will ensure the request is complied with andthis LMP will be updated to reflect any changes.




PAGE 65

Appendix G: Allied Mills Kingsgrove

Waste Management Plan

n Revision: 3.1





PAGE 66

Contents1. Introduction 672. Waste Streams 673. Onsite Storage 684. Waste Disposal 705. Management Review 70




PAGE 67

1. IntroductionAllied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). Theoperation of this plant requires the delivery of flour, oil and other ingredients to process these intovarious products. Following the processing of the wastes various waste streams are produced. Thedevelopment consent (S01/00876), requires these waste streams to be managed appropriately. ThisWaste Management Plan (WMP) has been developed to address conditions 4.26 to 4.28 of thedevelopment consent. The conditions of consent and the sections within this WMP where theconditions are addressed are listed within Table 3-1.

n Table 0-1 Condition of Consent RequirementsCondition Condition Requirements WMP Section

4.26 The Applicant must prepare and implement a Waste Management Plan for thedevelopment in consultation with the Council. This Plan must describe in detail the wastemanagement system, including:

This Document

4.26 a) The types and quantities of waste which will be generated at the site; and Section 2

4.26 b) How waste will be stored onsite, transported and disposed of offsite. Section 2 to

Section 4

4.27 The Waste Management Plan must have been approved by the Director-General beforethe mixing plant may be commissioned.

Section 5

4.28 After reviewing the Waste Management Plan, the Director-General may require theApplicant to address certain matters identified in the plan. The Applicant must comply withany reasonable requirements of the Director-General.

Section 5

2. Waste StreamsThe works at the Allied Mills site generates multiple waste streams. Details of the waste streams andthe volumes generated are shown in Table 2-1.

NOTE: Special waste is defined as non-hazardous but requires specific waste removal. Ie maintenance oilwaste, paint etc.

n Table 2-1 Allied Mills Waste StreamsWaste Stream Average Weekly Quantity Onsite Storage Vessel

Special waste 10Lt Sealed DrumLiquid waste 50Lt Sealed DrumHazardous waste 2.0Lt Plastic storage containerRestricted waste Nil NaGeneral waste (putrescible) 7 tonnes Bulka bagsGeneral waste (non putrescible) 7.5 tonnes Skip bin / Top loader bin




PAGE 68

3. Onsite StorageThe waste streams identified in Table 2-1 are stored at various locations across the Allied Mills site.The storage locations and the various receptacles used to store the waste streams are identified onFigure 2-1.




PAGE 69

n Figure 3-1: Allied Mills, Kingsgrove – Onsite Waste Storage Locations




PAGE 70

4. Waste DisposalThe Waste streams identified in Table 2-1 are disposed of by the waste contractors within Table 4-1.The waste contractors are licenced to remove the product and are responsible for ensuring thewastes are removed to an appropriate facility.

Allied Mills will endevour to utilise waste contractors who offer recycling options for waste streamsgenerated on the site.

n Table 4-1 Allied Mills Waste Removal ContractorsWaste Stream Waste Removal Contractor Comments

General Waste (nonputrescible)

Veolia Waste ServiceGrima Waste ServiceCentacare Industries

General waste (putrescible) Michael Mizzi Offal. Recycled

Hazardous waste Toxfree EPA Licence (NSW) No. 12628Liquid waste Auscol (Graincorp) - oil EPA Licence (NSW) No. 2550

5. Management ReviewIn accordance with the requirement of Condition 3.7 of the development consent, this WMP will bereviewed annually (or following a significant incident) by Allied Mills. Where necessary the reportwill be updated to reflect any relevant changes.

A management review of the WMP will be completed prior to any modifications/expansions of themixing plant. In accordance with Condition 4.27, the revised WMP will be submitted to the Director-General prior to the commissioning of the modified mixing plant.

A management review may also be required in response to a request from the Director-General. Insuch cases a review/update will be completed and provided to the Director-General for approval, inaccordance with Condition 4.28 of the development consent.




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Appendix H: Environmental Inspection ReportTemplate

WEEKLY ENVIRONMENTALMONITORING REPORTInspection Date:Inspector Name(s):Inspection Location(s):

MONITORING PROGRAM: (refer to Table 9-2 of the Allied Mills EMP forperformance criteria)Area Monitoring Criteria Compliant

Noise Any excessive noise noted. Yes / NoAny noise complaints in previous week. Yes / No

Air QualityAny black/white exhaust smoke from vehiclesover 10 sec. Yes / NoAny visable dust exiting manufacturing building. Yes / No

Stormwater

Are spill trays being used under oil receivalcouplings on oil tankers.

Yes / No /NA

Is oil bunding around oil tanks in good conditionand no oil leaks. Yes / NoAre isolation valves blocked or obstructed. Yes / NoAre stormwater drain wardens damaged or full ofrubbish Yes / No

Traffic Are trucks parked on The Crescent waiting to enter Yes / NoAesthetic /Landscaping

Are gardens and landscaping in good condition. Isdust blowing on site from unsealed grounds.

Yes / No

Waste Is waste area tidy and bin capacity acceptable. Yes / NoOther Yes / NoActions for any Non Compliance

AreaAction Taken - ie Maintenance request raised, CARraised, email sent, fixed during walk Comments

Comments / Photos / Other




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Appendix I: Environmental Notification Script

Environmental Incident Notification ScriptCollect the following Basic Information:

Ref Incident Details

A Person Reporting:B Position of Person Reporting:C Incident Time/Date:D Event Type:E Estimated Volume:F Pollutant Type:

G Nature and Location of Incident:

H Initial Response:

Contact the following Regulating Authorities (in order) using the below script and record detailson the back of this form:

Hi, my name is _____(A)________, and I am the _____(B)______ from the Allied Mills Food

Processing Plant at 4 The Crescent, Kingsgrove NSW.

I am calling to inform you that at _____(C)______ our facility had a _____(D)______ of

approximately _____(E)______ of _____(F)______ that occurred at _______(G)______. Our

initial response has included _____(H)______

Actual/Potential Spill/Leak/Escape/Deposit

Basic

Info

rmat

ion

Complete this section

Georges River Council (02) 9330 6400

Regulator Phone NumberEmergency Serv ices 000

131 555Ministry of Health – SESI Randwick (02) 9382 8333WorkCover Authority 13 10 50

EPA Pollution Line




PAGE 73

Record details of the conversation with each regulator on the following:Regulator: Time Contacted:Contact made:

Name:Position:

Regulator: Time Contacted:Contact made:

Name:Position:


Name:Position:


Name:Position:


Name:Position:

Regulators Recommendations/Directives:

Georges River CouncilSpoke with a person or left a message (circle one)

PersonContacted:

Emergency Serv icesSpoke with a person or left a message (circle one)

PersonContacted:Regulators Recommendations/Directives:


EPA Pollution LineSpoke with a person or left a message (circle one)

PersonContacted:

Ministry of Health – SESI RandwickSpoke with a person or left a message (circle one)

PersonContacted:



WorkCover AuthoritySpoke with a person or left a message (circle one)

PersonContacted:




PAGE 74

Appendix J Emergency ContactsOrganisation Position Contact

NumberNotes

Emergency Services Police, Fire,Ambulance

000

Georges River Council (02) 9330 6400 Only available Monday to Friday 8.30am to 5pm

EPA Pollution Line 131 555

Ministry of Health SESI Randwick (02) 9382 8333

WorkCover Authority 13 10 50

Allied Mills – Kingsgrove Site Manager 0401 700 879

Allied Mills – Kingsgrove Production Manager 0401 700 887

Allied Mills – Kingsgrove Production Manager 0401 701 073

Allied Mills – Kingsgrove Warehouse Manager 0401 700 942

Allied Mills – Kingsgrove Maintenance Manger 0423 479 743

Allied Mills – National National WHSEManager

0401 700 860

Allied Mills – National National WHSECoordinator

0408 367 344



A-2

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