app i pollution incident response management plan · rev. i (28/2/2019) page 2 of 54 details of...
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Environmental Management Sub-Plan
Appendix I – Pollution Incident Response
Management Plan
Bringelly Road Upgrade Stage 1
Rev. I (28/2/2019) Page 2 of 54
DETAILS OF REVISION AMMENDMENTS TO POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN
Plan Control
The latest version of this Plan will be available for all Project personnel, either electronically through the site
network or in hard copy in the site files.
The Project Environmental Site Representative (ESR) in conjunction with the Project Manager, will maintain,
review and update this plan at least annually.
Amendments
Each new revision to the plan will be distributed to all relevant personnel.
The revision number is noted in the footer of each page.
The document will be allocated a new revision number when any changes are made. When a new revision to
the document is created, a notification email will be distributed to all project personnel by the Project Manager
or Project Environmental Site Representative advising of the update.
The Project Manager is responsible for the implementation of the plan and will approve all amendments as
detailed above.
Revision Date Description Page Clause
A 03/03/2015 Initial Submission All All
B 30/03/2015 Updated with RMS comments All All
C 01/07/2015 3 Month Review All All
D 09/11/2015 General Review All All
E 02/05/2016 General Review All All
F 07/11/2016 General Review All All
G 15/06/2017 General Review All All
H 11/05/2018 General Review All All
I 28/02/2019 General Review – updated contact details, site map, DRSABCD, minor formatting and other changes
1, 7, 8, 7,8,25,26 App1&3
Authorised by:
Date: 01/03/2019
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Pollution Incident Response Management Plan
Bringelly Road Upgrade Stage 1
Table of Contents
1 Emergency Contacts ................................................................................................................................ 5
1.1 Roles and responsibilities .............................................................................................................. 7
1.1.1 Project Manager and Environment Site Representative / Safety Manager ................................... 7
1.1.2 Superintendent / Foreman ............................................................................................................. 7
1.1.3 Employees, Contractors & Visitors................................................................................................. 8
2 Incident Anticipation, Planning and Response ......................................................................................... 9
2.1 Background .................................................................................................................................... 9
2.2 Preparedness; Risk Assessment and Pre-Emptive Actions to Prevent Pollution Incident Risks 10
2.3 Summary of Pollution Types ........................................................................................................ 11
2.4 Risk Assessment .......................................................................................................................... 12
2.5 Notification .................................................................................................................................... 13
2.6 Incident Investigation ................................................................................................................... 14
3 Project Maps ........................................................................................................................................... 16
4 Incident Response Procedure ................................................................................................................ 17
4.1 Internal Communications - key names and contacts ................................................................... 17
5 Emergency Response Planning ............................................................................................................. 18
5.1 Medical Emergency ...................................................................................................................... 18
5.2 Spillage of Hazardous Liquids/Petroleum/Chemicals .................................................................. 18
5.3 Excavation and Disposal of Contaminated Material .................................................................... 18
5.3.1 Excavation .................................................................................................................................... 18
5.3.2 Removal of sewage system ......................................................................................................... 18
5.3.3 Transport ...................................................................................................................................... 19
5.3.4 Personnel ..................................................................................................................................... 19
5.4 Refuelling or maintenance and clean of plant and equipment ..................................................... 19
5.5 Sediment control resulting from large rainfall events ................................................................... 19
5.6 Laden dirty water runoff, resulted from a unforeseeable event ................................................... 20
5.7 Excessive Dust ............................................................................................................................. 20
5.8 Bush Fire ...................................................................................................................................... 20
5.9 Injured animals ............................................................................................................................. 20
5.10 Early Warnings and Communications to Neighbours .................................................................. 20
5.11 Availability and Location of This Plan .......................................................................................... 23
5.11.1 Website information ..................................................................................................................... 23
5.11.2 Privacy Protection ........................................................................................................................ 23
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6 Training – Summary and Reference to Project Procedure .................................................................... 24
7 Updating of Plan ..................................................................................................................................... 24
8 Testing and Implementation ................................................................................................................... 25
8.1 Testing of the PIRMP ................................................................................................................... 25
8.2 Implementation of the Plan .......................................................................................................... 25
Appendix 1 Project Map ............................................................................................................................. 27
Appendix 2 Risk Assessments ................................................................................................................... 29
Appendix 3 St John Ambulance First Responder Chart ............................................................................ 53
List of Tables
Table 1 PIRMP Requirements and Reference in this document ....................................................................... 9
Table 2 List of Typical Main Pollutants in Road Construction ......................................................................... 11
Table 3 POEO (General) Regulation 2009 Requirements .............................................................................. 12
Table 4 External Emergency Contacts - not an immediate threat ................................................................... 14
Table 5 External Emergency Contacts - immediate threat .............................................................................. 14
Table 6 List of Typical Main Pollutants and Potential Neighbour Impacts and Early Warnings ...................... 20
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1 Emergency Contacts
SITE LOCATION:
Bringelly Road: King Street to Camden Valley Way
MAIN COMPOUND LOCATION:
111 Cowpasture Road South;
Leppington
EMERGENCY NUMBERS
FIRE BRIGADE 000
AMBULANCE 000
POLICE 000
LOCAL EMERGENCY SERVICES
Fire Station Fire Brigade NSW
162 Greenway Drive
Horningsea Park NSW 2170
9608 0574
Police Station Police Station 33 Moore St
Liverpool NSW 2170 9821 8444
Medical Centre All Care Carnes Hill
Medical Centre
Cnr Kurrajong & Cowpasture Rds
Horningsea Park NSW 2171
9607 2220
Hospital Liverpool Hospital Elizabeth Street
Liverpool NSW 2170 9828 3000
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AGENCY/STAKEHOLDER CONTACT NUMBERS
For Immediate Contact following a Pollution Incident (see section 2.5)
EPA Pollution Hotline 131 555
NSW Fire and Rescue 1300 729 579 (000)
Horningsea Park Fire Station, 162 Greenway Dr, Horningsea Pk
(02) 9608 0574
Poisons Information 13 11 26
SafeWork NSW
(Parramatta)
13 10 50
(9841 8550)
NSW Ministry of Health
(Liverpool Public Health Branch) 9828 3130
Liverpool Council 1300 362 170
Camden Council 4654 7777
Other Useful contacts in an Emergency
Dial Before You Dig 1100
Poisons Information 13 11 26
Telstra 1800 653 935
Endeavour Energy 13 10 03
Jemena Gas 13 19 09
APA 1800 020 584
Water NSW 1800 061 069
Fisheries NSW 1300 550 474
POSITION NAME NUMBER
Project Manager (PM)
Environmental Site Representative (ESR)
Safety Coordinator
General Foreman
Senior Project Engineers
RMS Project Manager
RMS Project Engineer
RMS Surveillance Officer
Foremen
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First Aid Officers
1.1 Roles and responsibilities
BMD Constructions’ Project Team organisational structure and overall roles and responsibilities are outlined
in the CEMP. Specific responsibilities for the implementation of this Pollution Incident Response Management
Plan (PIRMP) are detailed below.
1.1.1 Project Manager and Environment Site Representative / Safety Manager
1.1.1.1 General Requirements
• Be fully conversant with the requirements of this Plan
• Ensure the PIRMP is fully implemented, monitored and adjusted to suit the requirements of the operations
system and the client’s requirements
• Ensure the requirements of the Management System are fully complied with when administering the
PIRMP
• Ensure all employees are conversant with their responsibilities and duties under the PIRMP
• Responsible to notify relevant stakeholders and government authorities
1.1.1.2 Communication
• Ensure the spill response flowchart, emergency contact numbers and details and any other bulletin or
information pertaining to emergency plans and management is placed on noticeboards
1.1.1.3 Training
• Educate supervisory personnel in accordance with plan requirements, statutory obligations, and relevant
procedures
• Ensure staff and contractors have been inducted into BMD safety and environmental management
systems and procedures
1.1.2 Superintendent / Foreman
The Superintendent / Foreman are responsible for the day to day operations of the project, ensuring project
operations comply with all relevant obligations for the period of this contract. The Superintendent / Foreman
will be inducted into BMD Integrated Management Systems and Procedures, they will also receive a higher
level of Project specific Emergency Preparedness and Incident Management training while onsite.
1.1.2.1 General Requirements
• Being familiar with the requirements of this PIRMP.
• Ensuring incidents are managed and strictly supervised in accordance with the PIRMP, company policies
and procedures
• Being familiar with legislation and codes of practice relevant to this role, and ensuring the requirements
of the same are bought to the attention of interested parties and implemented as is practicable across the
Project site
• Understanding process and location of spill kits
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1.1.2.2 Communication
• Ensuring the requirements of the PIRMP are communicated to all personnel, subcontractors and where
appropriate, visitors to site through on site daily Pre-Start meetings, Site Inductions, weekly Toolbox
Meetings and Work Method Statement (WMS) review on commencement of new works with the potential
to impact personnel and the environment
• Any external contact will be communicated to the client via the Project Manager or their delegate
1.1.3 Employees, Contractors & Visitors On identification of an occurrence requiring emergency response each employee has the responsibility to immediately notify the site supervisor or delegate. In the event of a serious situation the employee shall utilise this “Plan” to make direct contact with the closest emergency service required (e.g. spill clean-up service)
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2 Incident Anticipation, Planning and Response
2.1 Background
This Plan has been prepared in order to guide and direct the response by the Bringelly Road Upgrade – Stage
1 Project Team to an incident or emergency, be it environmental or safety in nature. The Plan has been
modified following a review by independent consultants to assess compliance with the POEO Act 1997 Part
5.7A; Duty to Prepare and implement Pollution Incident Response Management Plans, and POEO (General)
Regulation 2009 Part 3A, carried out on the 5th November 2014.
Plan preparation is a requirement for holders of Environment Protection Licences (EPLs). BMD holds EPL
20466 for road construction on this Project.
Key areas which this Plan covers are described in Table 1 below; PIRMP Requirements.
Table 1 PIRMP Requirements and Reference in this document
Section Description Reference
POEO Act Part 5.7
153A Duty of Licence holder to prepare PIRMP Whole document
153C Information to be included and procedures or actions to take after an
incident and coordinating with authorities
2, 3, 4, 5, Appendix 3
153D Keeping of plan 5.9
153E Testing of plan 8.1
153F Implementation of plan 8.2
POEO (Gen) Reg 2009
98C(a) Hazard Assessment 2.2, Appendix 2
98C(b) Likelihood assessment 2.2, Appendix 2
98C(c) Pre-emptive Action 2.2, Appendix 2
98C(d) An inventory of potential pollutants on the premises or used in carrying
out the relevant activity
2.2, Appendix 2
98C(e) Pollutant Inventory Quantities 2.2, Appendix 2
98C(f) Safety equipment such storage containers, spill kits, and PPE will be
located near the source of chemical/fuel for easy access.
2.2, Appendix 2
98C(g) Staff Contacts explanation 1
98C(h) Authority Contacts 1, Table 4
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98C(i) Early Warnings to Neighbours 2.2, Appendix 1
98C(j) Minimising the risk of harm to any persons will be risk assessed daily as
per activity within an area by the site Foreman. Items for consideration
may include evacuation point, appropriate PPE requirements, site
accessibility, etc.
2.2, Appendix 2
98C(k) Map locations of pollutants 3, Appendix 1
98C(l) Early Warnings General 5.10
98C(m) Training of Staff 0
98C(n) Timing of Testing 8.1
98C(o) Updating of Plan 7
98C(p) Plan Testing 8.1
98D(1) Availability of Plan 5.11
98D(2) Publishing Plan Parts 5.11
98D(3) Procedures under the Act 2.1, All Appendices
98D(4) Privacy Protection 5.11.2
98E(1) Testing of the Plan 8.1
98E(2) Minimum Testing Requirements 8.1
EPA Bunding and Spill Management Guidelines
4 Minimising the risk of spills to the environment 2.2
RMS Code of Practice for Water Management
2 Best Practice Principle Whole document
2.2 Preparedness; Risk Assessment and Pre-Emptive Actions to Prevent Pollution Incident Risks
This chapter deals with the POEO (General) Regulation 2009’s sections 98(a) to 98(f) and partially covers
s98(j). These sections deal with the hazard, likelihood and pre-emptive actions which are similar processes to
undertaking a risk assessment and providing appropriate control measures to prevent or minimise these risks.
The key to effective prevention of incidents is risk assessment, procedure development, monitoring and
training. During construction activities, BMD’s inspections and preventive actions will include:
• Risk Register updated generally on a 3-monthly basis;
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• activity specific and daily risk assessments, inclusive of associated environmental risk, safety of workers,
and emergency evacuation;
• development of work procedures, construction method statements and environmental work method
statements in consultation with relevant BMD staff such as work teams, environment team members and
senior management;
• daily inspections of active work sites;
• completion of routine environmental checklists;
• issue and quick close-out of non-compliance notices;
• ongoing environmental training;
• environmental audits of work sites, subcontractors and compliance issues.
Environmental and safety information on hazardous substances (e.g. SDS) will be available at the main site
office and where such substances are stored. Personnel involved in emergency response activities will be
provided with specific training. An up-to-date list of emergency response personnel and organisations will be
maintained at the main office and compounds.
Additionally, a more detailed assessment of the above issues and more are included in s2.4 and Appendix 2.
2.3 Summary of Pollution Types
Road construction has by its nature a limited list of typical pollution types which require consideration (see
Table 2 below). The Project CEMP addresses these in more detail.
Table 2 List of Typical Main Pollutants in Road Construction
Description Comments
Air Based Emissions
Dust From use of plant and equipment, moving across dry surfaces. Covered under G36
and CEMP Sub Plan.
Fire Small bush fires and other fires are covered under G36 and CEMP. Fire is not
considered an environmental incident, but the smoke from the fire can be and can
affect neighbours.
Noise Emitted by plant and equipment. Covered under G36 and the CEMP Sub Plan. Noise
is not considered a pollution incident and not covered further under this Plan.
Odour Odour is generally associated with laying of asphalt and is managed under the CEMP
under complaints.
Water Based Emissions
Fuel (diesel and
petrol), lubricants
and hydraulic oils
For plant and equipment operations. Covered under G36 s6.12 and the CEMP
Paints and surface
coatings
Potential for lead based paint on existing bridge over the Upper Canal. Surface
coatings in many cases must be applied on site. Covered under G36 and the CEMP
Pesticides Control of weeds and pests: Covered under G36 and the CEMP
Concrete wash out Wash out of concrete vessels: Covered under G36 and the CEMP, EWMS
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Bitumen materials Application of spray seal and laying of asphalt.
Effluent Removal and relocation of sewage septic systems from existing properties. Effluent
to be disposed as being Liquid Waste in accordance with the EPA Waste
Classification Guidelines – Part 1: Classification of waste. The demolition
subcontractor to be licence to manage the removal of the sewage septic system
structure and dispose the material at a licence waste facility.
Soils and erosion General site issue for exposed soils: Covered under G36, G38 and G40, CEMP and
Soil and Water Management Sub Plan. Project is guided by ‘General road
construction handbook, BLUE BOOK Managing Urban Stormwater: Soils and
Construction’.
Bentonite slurry Produced as a result of underbore activity. Free liquid is recycled through the
underbore process in a contained environment and the solid is removed to a
designated stockpile area to be dried out and reused as general fill material. Excess
liquid will be managed in accordance with G36, G38 and G40, CEMP and Soil and
Water Management Sub Plan. The bentonite product is non-hazardous.
Potential Asbestos
Containing Material
Demolition of existing buildings/structures and unexpected finds: Covered under G36,
G38, G40, Contractors Environmental Management Plan, Contaminated Land
Management Sub-Plan and Soil and Water Management Sub-Plan. Works to be
undertaken in accordance with The Code of Practice: How to Safely Remove
Asbestos prepared by Safe Work Australia and WorkSafe NSW’s guidelines to
managing asbestos.
2.4 Risk Assessment
To improve the effectiveness of the Plan, Table 3 below set out the requirements under the POEO (General)
Regulation 2009:
Table 3 POEO (General) Regulation 2009 Requirements
Section Item heading Covered by
98C(a) Hazard assessment: Hazard and Likelihood Risk assessment and Corrective
Control Measures tables
98C(b) Likelihood assessment: Hazard and Likelihood Risk assessment and Corrective
Control Measures tables
98C(c) Pre-Emptive Action: Hazard and Likelihood Risk assessment and Corrective
Control Measures – Control measures and corrective action
98C(d) Pollutant Inventory Types:
List of Polluting Substance Storages/Uses At Site Initial
Assessment – Name/description, Covered under Hazardous
Chemicals?
98C(e) Pollutant Inventory Quantities:
List of Polluting Substance Storages/Uses At Site Initial
Assessment – Amount Stored (maximum or estimated
Maximums stored)
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98C(f) Safety Equipment: List of Polluting Substance Storages/Uses At Site Initial
Assessment- Ref to Safety Coverage
98C(i) Early Warnings Neighbours: List of Polluting Substance Storages/Uses At Site Initial
Assessment – Need for early warnings to neighbours
98C(j) Staff Safety: List of Polluting Substance Storages/Uses At Site Initial
Assessment – Ref to Safety Coverage
98C(k) Maps location of pollutants:
List of Polluting Substance Storages/Uses At Site Initial
Assessment Location of Storage, Map reference (supports
section 3 Maps and maps in Appendix 1)
The controls are covered in Appendix 3 Risk Assessments. They are broken down into the following:
• Main Activities of Environmental Hazard:
o Clearing and grubbing o Bridge demolition and construction o Building demolition o Road construction o Utility works o Erosion and sedimentation o Chemical storage and use o General Concrete Works
• Each activity in the above list is assessed on the types, quantities, usage and storages of potential
pollutions listed by its:
o Chemical type o Is it a Dangerous Good? o Max Quantity on site o Location description o Map Reference o Potential impact on neighbours o Pre-emptive measures o Use of safety equipment
• A risk assessment is undertaken based on the RMS risk matrix which considers: o Hazard identification o Risk assessment o More detailed control measures for specific hazard/incident
If the risk assessment process was found to be unacceptable or review of an incident resulted in changes to the risks, alternative and improved pre-emptive measures will be considered.
2.5 Notification
The ESR or Superintendent/Foreman will make a decision based on RMS Environmental Incident
Classification and Reporting Procedure what level of notification and callout is initially required for the incident.
Larger incidents may require higher levels of notification and the need for external resources to manage the
incident and protect soil, water and biodiversity.
The ESR or PM will immediately notify the authorities listed in the below table of pollution incidents on or
adjacent to the site where material harm* to the environment is caused or threatened.
*That is, environmental harm or potential harm to the health or safety of human beings (from environmental
hazards) or to ecosystems that is not trivial; or that result in actual or potential loss or property damage of an
amount over $10,000.
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If there is not an immediate threat to human health or the environment
Table 4 External Emergency Contacts - not an immediate threat
Emergency Contact / Organisation Contact Details
EPA Pollution Hotline 131 555
Liverpool / Camden Council 1300 362 170 / 4654 7777
*Water NSW 1800 061 069
NSW Ministry of Health
(Liverpool Public Health Branch) 9828 3130
SafeWork NSW 131 050
NSW Fire and Rescue 1300 729 579
*Only to be contacted in an event impacting on the Upper Canal
If there is an immediate threat to human health or the environment
Table 5 External Emergency Contacts - immediate threat
Emergency Contact / Organisation Contact Details
NSW Fire and Rescue 000
EPA Pollution Hotline 131 555
*Water NSW 1800 061 069
NSW Ministry of Health
(Liverpool Public Health Branch) 9828 3130
SafeWork NSW 13 10 50
Liverpool / Camden Council 1300 362 170 / 4654 7777
*Only to be contacted in an event impacting on the Upper Canal
The Principal will be verbally notified immediately (by phone) and, in any case in writing within 24 hours, of
any incidents which have been reported to the EPA under Part 5.7 of the POEO Act.
The Principal will be verbally notified of any Category 1 environmental incidents within 1 hour of the incident
occurring. Category 1 incidents are potentially the most serious and generally reflect breaches of
environmental legislation (refer RMS Environmental Incident Classification and Reporting Procedure’s Section
1 for more detailed information).
2.6 Incident Investigation
All incidents will be documented, investigated and action plans established to prevent a reoccurrence. RMS
incident classification categorisation is to be included within the BMD report form details. Where lessons are
learnt from the investigation or current procedures are identified as being ineffective, the CEMP or associated
documents will be revised by the ESR to include the improved procedures or requirement. An environmental
investigation includes the following basic elements:
• identifying the cause, extent and responsibility of the incident
• identifying and implementing the necessary corrective action
• identifying the personnel responsible for carrying out the corrective action
• implementing or modifying controls necessary to avoid a repeat occurrence of the
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• incident
• recording any changes in written procedures required
• advising the environmental authority (i.e. EPA) if any substantial pollution has occurred.
All personnel are required to report all incidents or near hits (misses), as it is regarded as a valuable method
of addressing shortcomings in procedures, training or equipment, and is an opportunity for improvement.
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3 Project Maps
This section covers the POEO (General) Regulation s98E(k) requirements which are:
A detailed map (or set of maps) showing the location of the premises to which the licence relates, the
surrounding area that is likely to be affected by a pollution incident, the location of potential pollutants on
the premises and the location of any stormwater drains on the premises.
As the Project is staged the maps include:
• An overall map of the entire project area covered by the EPL
Project Specification G36 requires that the contractor prepare the necessary documentation including the
detailed maps required under the POEO (General) Regulation 2009.
Other maps for the project relevant to this PIRMP are listed in the Emergency Spill Response Plan for this
project.
Appendix 1 shows the entire project alignment and include the EPL boundary, outside premises likely to be
affected by a pollution incident, location of potential pollutants outside project boundary, and site facilities.
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4 Incident Response Procedure
4.1 Internal Communications - key names and contacts
Incident Occurs
Is there a potential risk to environment, health and/or safety?
If possible, prevent/control/remove the risk and/or provide appropriate first aid/support.
Evacuate or isolate the area and prevent access if area unsafe. For environmental incidents involving
spills follow Emergency Spill Response Plan.
Call 000 in the event of a medical emergency and designate appropriate person to direct ambulance from the public road to
the incident location.
Immediately notify BMD supervisor via phone or radio.
Foreman and ESR/Safety Co-ordinator to inspect the area/accident.
Foreman and Project Manager to determine if further action is required.
Project Manager and ESR/Safety Co-ordinator to determine if immediate reporting to EPA/SafeWork NSW and other regulatory bodies is required.
Note: to be immediately notified in the event of actual or potential harm to the environment or health of site personnel (see section 2.4)
Complete the BMD and RMS Incident report
Foreman to manage any works to prevent further damage/harm.
Toolbox work crew and/or site personnel if required
Immediately notify RMS of incident via phone. An incident report is to be provided
within 48 hours.
Complete the BMD and RMS incident report, undertake investigation and
determine management and/or remediation measures to be implemented on site
No
No
Yes
Yes
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5 Emergency Response Planning
5.1 Medical Emergency
(SEE ST. JOHN’S AMBULANCE FIRST AID RESPONDER CHART INCLUDED AT APPENDIX 3)
1. Check for any threatening situation and control it if safe to do so
2. Remain with casualty (unless there is no other option) and provide appropriate support
3. Do not move any casualties unless in a life threatening situation
4. Notify the Foreman and the first aider
5. Notify the ambulance if not already done and designate people to direct them from the public road to the
incident location.
6. If necessary arrange clear path for emergency vehicles to the incident location, e.g. grader/dozer may clear
path
7. Provide support to first aider and/or emergency services if required
5.2 Spillage of Hazardous Liquids/Petroleum/Chemicals
1. Identify the source and if possible minimise/stop further spillage. IN ALL CASES, ASCERTAIN FIRST
WHETHER IT IS SAFE TO TACKLE THE SITUATION. IF UNCERTAIN, CONTACT EMERGENCY
PERSONNEL AND EVACUATE AND SECURE THE AREA.
2. Stop work in the area and notify Foreman/Supervisor.
3. Under instruction of Foreman/Supervisor and if safe to do so, isolate the contaminated area to ensure that
hazardous material does not spread to other areas. In the case of oil or other contaminant spill unable to be
contained by adjacent spill kit, the immediate area shall be bunded to prevent spread of spill.
4. In the event of a spill from plant, the plant shall be shut down immediately, and shall not be moved until the
spill can be contained and leaking part plugged / fixed.
5. If spillage occurs in the vicinity of creeks or stormwater drains, all measures must be taken to ensure that the
creeks or inlets are protected (e.g. a temporary dam is acceptable) to restrict hazardous substance entering
downstream.
6. Contaminant shall be soaked up with appropriate spill kit material and disposal of contaminated material shall
occur at an approved disposal site. If hazardous materials cannot be completely restricted and removed
from the site by equipment available then the local fire department is to be contacted.
7. Call: 000 or if using a digital mobile phone: 112.
8. Contaminated absorbent material shall be stored in a suitable bunded off and covered area or regulated
waste bin within the site compound until disposal to an approved regulated waste disposal centre.
9. All spills shall be notified to the Site Superintendent and ESR as soon as practicable and incident report
actioned.
5.3 Excavation and Disposal of Contaminated Material
If the excavation and disposal of contaminated material is required, a toolbox meeting should be held to highlight
the correct procedure. Refer to Unexpected Discovery of Contaminated Material Procedure within Soil and Water
Management Plan.
5.3.1 Excavation
• Clean fill material to be separated from contaminated material.
• Do not stockpile contaminated material on pavements
• Attempt to prevent spillage of contaminated material onto pavements. Keep pavements clean where trucks
are being loaded to prevent material being transported off site by wheels of truck.
5.3.2 Removal of sewage system
• All liquid and solid waste to controlled pumped out.
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5.3.3 Transport
• Clean vehicles of dirt, if required, to prevent transport of material off site.
• Any spillages to be cleaned as quickly as practicable.
• Cover all loads securely.
• Chemical drums for disposal to be transported in accordance with the Dangerous Good Act 1985.
• Disposal receipts must be collected from landfill and returned to Foreman for each load.
5.3.4 Personnel
• No unauthorised personnel (i.e. not directly involved with the work) should enter excavation.
• Avoid direct contact with any contaminated soil or water that has come into contact with contaminated soil.
• Eating, drinking, smoking or any other hand to mouth practice should be avoided.
• Wash hands with cleaning agent prior to eating or drinking.
• Boots to be cleaned before leaving site.
• Symptoms of chemical exposure including headache, dizziness, nausea and irritation of the respiratory tract,
eyes or skin should be reported to the Foreman or the first aider.
5.4 Refuelling or maintenance and clean of plant and equipment
• Fuel cart/truck operator and mechanic to contact BMD foreman on arrival before entering site to determine
whether site access is permitted and the locations of plant and equipment for refuelling.
• Fuel cart/truck and mechanic to park parallel to the plant or equipment, away from any other obstructions.
• Refuelling and maintenance of all plant and equipment must be conduct on level impermeable surface, where
possible.
• Plant or equipment must be switch-off before and during refuelling operation and maintenance.
• No refuelling or maintenance of plant and equipment near drainage inlets or the like, including swale drains
and sediment basins.
• Spill kit, Safety Data Sheet and fire extinguisher must be accessible on the fuel cart/truck and mechanical
truck.
• Drip tray or absorbent pads to be placed underneath where the nozzle refuels the machine/plant to contain
leaks, including extracting oil and changing filters during maintenance. Dispose all waste material in
accordance with legislative requirements.
• If a spill or leak occurs, contact BMD foreman who will inform BMD ESR for an initial investigation to
determine the severity of the incident. RMS will be notified of the incident immediately, and written notification
will be forwarded to the RMS within 24 hours.
• Designated concrete washout facility will be provided onsite or concrete agitators will be instructed to return
back to their concrete batch yard for washout.
• Bitumen spray bars and asphalt pavers to cleaned of loose material at a location away from waterways before
leaving site.
• Check and clean tyres before leaving site to minimise tracking of material on to public road.
5.5 Sediment control resulting from large rainfall events
• In the case of an environmental emergency event the Foreman shall be notified immediately and the following
procedures shall be followed. Personal safety shall be given priority under all circumstances.
• Check all erosion and sediment control devices for conformance
• Diversion drains shall be cut into exposed batter slopes to direct sheet flows and divert concentrated runoff
to stabilised channels.
• Emergency silt fence, straw bales, diversion drains or “water runoff” velocity check dams shall be placed to
minimise impact.
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5.6 Laden dirty water runoff, resulted from a unforeseeable event
Such event may be a failed valve or gasket connected to an existing old watermain.
• Water cart and / or sucker truck to be available for immediate use to remove turbid water
• Stockpile of sandbags available to be used to create a dam like structure or diversion drain to minimise the
turbid water from entering any waterbody or stormwater drains
• Contact Sydney Water immediately to provided assist by shutting down watermain upstream and
downstream.
5.7 Excessive Dust
• In the case of excessive dust, water shall be applied to the areas causing dust problems.
• Operations shall not cease until such time as dust generation is controllable.
• Consider wind direction, strength and location of sensitive receptors.
• Utilise appropriate dust minimisation measures such as scraping haul roads / cuts to underlying wetter layers,
proactive shut down of areas not being worked for extended periods of time, or using dust suppressing
additives in water carts.
5.8 Bush Fire
• Should a bush or grass fire occur the local fire authorities shall be contacted.
• Water trucks may also be used, when safe, to assist in the case of such an event.
5.9 Injured animals
• Any fauna injured as a result of work operations should be notified to the ESR who will contact WIRES or the
local vet (as per Flora and Fauna management Plan).
A list of names and phone numbers of emergency services is prominently displayed in the Site Office, and crib
hut for quick reference in the event of an emergency. The importance of this emergency response plan shall be
reiterated during toolbox talks.
5.10 Early Warnings and Communications to Neighbours
Key stakeholders and residents were sent a community update in January 2015 detailing the commencement and
breakdown of project stages of the Bringelly Road Upgrade Stage 1. RMS have and will continue to provide key
stakeholders and residents of project updates via the monthly Community Update newsletter.
The contractor will prepare an environment Action Table as part of the CEMP that details the cases where
contact with community may be needed and how this contact will be managed.
The project map in the Emergency Spill Response Plan shows the location of neighbouring properties.
An assessment of the typical pollution incident types has been undertaken to consider the potential impacts on
neighbours. This resulted in the early warning actions located in Table 6 below.
Table 6 List of Typical Main Pollutants and Potential Neighbour Impacts and Early Warnings
Air Based Emissions
Description Potential Risks Early Warning actions
Dust Air quality issues Loss of amenity Community complaints
In extreme cases contact neighbours via doorknock process and ask them to close windows and doors and stay inside until further notice
Fire Air quality issues Threat to safety
In extreme cases contact neighbours via doorknock process and ask them
Rev. I (28/2/2019) Page 21 of 54
to close windows and doors and stay inside until further notice. For larger fires, coordinate with combat agencies.
Noise Loss of amenity Community complaints
Not required under PIRMP. Communicate with neighbours on as needs basis as per CEMP
Odour Air quality issues Loss of amenity Community Complaints
In extreme cases contact neighbours via doorknock process and ask them to close windows and doors and stay inside until further notice
Spill type emissions
Fuel including diesel and petrol based fuels
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice. For larger spills coordinate with combat agency.
Lubricants and hydraulic oils
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Pesticides Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice. For larger spills coordinate with combat agency.
Paints and surface coatings
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Concrete alkali washings
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Bitumen and cutting products
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Other chemicals Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Soils and erosion
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Bentonite slurry Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Contaminated materials uncovered
Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Wastes Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them
Rev. I (28/2/2019) Page 22 of 54
to avoid use of the water until further notice
Tannins Water quality issues if spill enters waterway Community complaints
In extreme cases contact neighbours via doorknock process and ask them to avoid use of the water until further notice
Ongoing community relations under the CEMP will ensure the community is kept up to date on pollution
incidents and other matters. Such actions will also advise on the website information and how to respond to
such incidents if required.
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5.11 Availability and Location of This Plan
The POEO (General) Regulation 2009 s98D(1) states:
(1) A plan is to be made readily available:
(a) to an authorised officer on request, and
(b) at the premises to which the relevant licence relates, or where the relevant activity takes place, to any
person who is responsible for implementing the plan.
This Plan is located at:
• The BMD Site office
On the BMD project webpage (http://www.bmd.com.au/the-bmd-way/environment/)
In any event the availability of this Plan will be made available by locating printed copies in the same locations
as the Environment Protection Licence (EPL) is located.
5.11.1 Website information
This Pollution Incident Response Management Plan will be uploaded on to the BMD project website as a
requirement under the Protection of the Environment Operations Act 1997 (POEO Act) and the Protection of the
Environment Operations (General) Regulation 2009 s98D:
(2) A plan is also to be made publicly available in the following manner within 14 days after it is prepared:
(a) in a prominent position on a publicly accessible website of the person who is required to prepare the plan,
(b) if the person does not have such a website--by providing a copy of the plan, without charge, to any
person who makes a written request for a copy.
3) Subclause (2) applies only in relation to that part of a plan that includes the information required under:
(a) section 153C(a) of the Act, and
(b) clause 98C (1) (h) and (i) or (2) (b) and (c) (as the case requires).
The internet link below is where the PIRMP can be download and viewed by the public.
http://www.bmd.com.au/the-bmd-way/environment/
5.11.2 Privacy Protection
Unlike the EPL this Plan is to only be available to those who are to implement the Plan. This is made clear by
The POEO (General) Regulation 2009 s98D(3) which States
4) Any personal information within the meaning of the Privacy and Personal Information Protection Act 1998
is not required to be included in a plan that is made available to any person other than a person referred to in
subclause (1).
Where components of the Plan are considered to contain sensitive private information then only those cleared
should be permitted access to the full Plan. Alternative Plans with such sensitive information removed (e.g.
contact phone numbers and names) can be more widely distributed. Full plans will be made available to the
relevant government agencies, on request or during an incident response activity.
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6 Training – Summary and Reference to Project Procedure As part of RMS G36 Environmental Protection (Management Systems) the Contractor’s Environment Management Plan the following induction and training must include where applicable the following:
• Purpose and objections of the CEMP
• Requirement of due diligence and duty of care
• Condition of environmental licenses, permits and approvals
• Environmental emergency plans
• Management and reporting processes for environmental incidents
• Lessons leant from environmental incidents
• Environmental controls that are identified in the CEMP and its supplementary plan
• Site specific issues including, but not limited to erosion and sediment control, boundaries for vegetation clearing, locations of refuse bins, washing, refueling and maintenance of vehicles, plant and equipment.
• Environmentally sensitive areas
• Use of spill kits to contain any chemical, fuel or oil spills To also satisfy the requirements under this PIRMP the training is to also include:
• Awareness of the PIRMP
• Where this Plan can be accessed
• Pollution incident classification and reporting under this plan
• Spill response actions under this plan
• Other incident response actions under this plan
• Early warnings internally and to neighbours where appropriate
• Specific procedures in dealing with potential pollution incidents e.g. pump out of sedimentation basins Section 13 of the CEMP outlines the requirement for all project personnel, subcontractors, consultants and visitors to be familiar with the environmental management obligations and requirements of the project, especially the requirements of this plan. The information will be communicated at the site specific induction, on occasion a specific environmental training (as per Table 14 of the CEMP) will be carried out, discussed at the daily site briefing, and monthly mentioned at toolbox talks. All records of induction, training, site briefing and toolbox talks will be held on file for at least four years after the date of Final Completion and will be available to the RMS and to the EPA officers on request.
7 Updating of Plan Effective date: April 2015 Review date This Plan will be updated according to the following:
• One month after the Contractor Environment Management Plan has been accepted by RMS; or
• Periodically throughout construction; or
• Within one month of a Category 1 Incident; or
• As identified after testing of the Plan (see section 8).
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8 Testing and Implementation
8.1 Testing of the PIRMP The POEO (General) Regulation 2009 98E states for testing of the Plan:
1) The testing of a plan is to be carried out in such a manner as to ensure that the information included in the plan is accurate and up to date and the plan is capable of being implemented in a workable and effective manner. 2) Any such test is to be carried out: (a) routinely at least once every 12 months, and (b) within 1 month of any pollution incident occurring in the course of an activity to which the licence relates so as to assess, in the light of that incident, whether the information included in the plan is accurate and up to date and the plan is still capable of being implemented in a workable and effective manner
Testing of the Plan will be integrated into other emergency and incident testing and training programs. Testing of the Plan cannot be properly undertaken or designed until the CEMP has been prepared for that Stage of development of the project. Initial testing of the plan will be undertaken within 6 months of the acceptance of the CEMP. Design of the testing will be undertaken 1 month before the testing is conducted. Records of the testing will be required by the RMS on the contractor. Testing dates This Plan will be updated according to the following:
• Initially 6 months month after the Contractor Environment Management Plan has been accepted by RMS, or
• Or before one month after a Category 1 Incident. Further details will be available under the Incident and Emergency Response Management Plan for the Project. Recording of Testing A detailed record of the testing of the Plan will be prepared after each testing of the plan is undertaken. If the test identifies any shortcomings in the Plan, especially the implementation of the spill response procedures, the Plan will be corrected or appropriate non-conformance actions will be undertaken.
8.2 Implementation of the Plan The POEO Act 1997 s153F requires the Plan be implemented if a pollution incident occurs. A pollution incident is defined under clause 147 of part 5.7 of the POEO Act 1997 as: Meaning of material harm to the environment
1. For the purposes of this Part: a. harm to the environment is material if:
i. it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, or
ii. it results in actual or potential loss or property damage of an amount, or amounts in aggregate, exceeding $10,000 (or such other amount as is prescribed by the regulations), and
b. loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment.
2. For the purposes of this Part, it does not matter that harm to the environment is caused only in the premises where the pollution incident occurs.
$2 million maximum fines apply for failing to implement the Plan.
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Hence if a pollution incident occurs:
• It must be responded to according to this Plan and its reference documents.
• An incident response report/audit must be completed
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Appendix 1 Project Map
Rev. I (28/2/2019) Page 28 of 54
WaterNSW – Upper Canal
Bonds Creek
Scalabrini Creek
Kemps Creek Main Site Compound
EPL Boundary
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Appendix 2 Risk Assessments
This Plan uses a risk assessment process to demonstrate the existing risk control methods are effective
in preventing and minimising environmental harm from pollution incidents. If unacceptable risks are
identified new control measures will be introduced. The modular format permits the use of common
activities associated with road construction to be used in future PIRMP documents.
The modules used for this Plan for the Project include:
• Clearing and grubbing
• Road construction
• Soil and water management
• Chemical storage and use
Each module uses a standard risk matrix used by RMS in its REF.
Each module lists the type of use or storage for the pollutant/s being considered.
Each of the above is considered for a range of hazards and their control method considered. Also
considered in the above process is:
• Impact on neighbours
• Safety
• Location
• If the pollutant is a hazardous chemical
Risk Matrix
Environmental risks associated with RMS and its contractor’s activities use the following table.
RMS Environmental Risk Matrix
Pro
bab
ilit
y (
Lik
elih
oo
d)
Severity (level of impact)
1
Insignificant
2
Minor
3
Moderate
4
Major
5
Catastrophic
5 Almost Certain H H E E E
4 Likely M H H E E
3 Moderate L M H E E
2 Unlikely L L M H E
1 Rare L L M H H
Risk Factors: E =Extreme, H = High, M = Moderate, L = Low
The hazards, likelihood and pre-emptive measures assessments which follow the above table in
assessing the environmental risks associated with the hazards identified.
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Clearing and Grubbing
Purpose
This risk module forms part of the PIRMP for the Bringelly Road Upgrade Stage 1 project. The activities
associated with this module are related only to clearing and grubbing.
Activities
Clearing and Grubbing involves:
• Clearing of vegetation
• Clearing of minor built structures
• Clearing of rubbish and other
• Grubbing of trees and stumps
• Mulching
• Stockpiling of mulch
• Removal of Mulch
This risk module describes the main hazards to human health or the environment associated with
clearing and grubbing. The first table in the risk module lists the potential pollutants. The second table
describes the potential pollution incidents with pre-emptive actions to be taken to minimise or prevent
any risk of harm to human health or the environment. In the case of actual or threatened material harm
to the environment or human health procedures must be followed for contacting authorities as in RMS
Environmental Incident Classification and Reporting Procedure. For incidents where pollution has the
potential to impact on the community, early warning systems as described in section 6 of this document
are to be initiated.
Further details on the risk assessment and appropriate control methods can be found in the following
documents:
• CEMP
• Review of Environmental Factors (REF) 2011 and addendum REF 2013
• Environmental Work Method statements
The module has been written to cover general environmental hazards and their controls. As the
construction process is fluid, new documentation may better reflect the risks and controls. Primarily
this will be captured in the CEMP.
Rev. I (28/2/2019) Page 31 of 54
LIST OF POLLUTING SUBSTANCE STORAGES/USES AT SITE INITIAL ASSESSMENT – CLEARING AND GRUBBING
Project Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineers, Foreman, ESR Date February 2019
Name / description
Hazardous Chemicals
Amount stored
Location of storage
Map reference
Need for early warning1 Pre-emptive action ref
Ref to safety coverage
Ref to Hazard and likelihood assessment
CHEMICALS (raw materials and products which can cause pollution)
Noxious Weeds No variable variable variable no See CEMP, G36 N/A See item 1
Oils and fuel from vehicles
Yes < 1000 L variable variable no See CEMP, G36 See SMP See road construction and chemical module
MATERIALS (eg stockpiles, silos, bulk solids etc.)
Mulch no variable variable variable Only in extreme wind where dust threatens to impact on community
See CEMP, G36, G38
N/A See item 2 and 3
Soil Erosion no variable variable variable Only in extreme cases where erosion materials threaten to impact on health of waterway
See CEMP, G36, G38
N/A See item 4
rubbish and other Only for asbestos waste
variable variable variable If asbestos is found and fibres enter waterway or become airborne and threaten to impact on community
See CEMP, CLMP, SWMP, G36
See SMP See item 5
Unexpected find of contaminates
Asbestos containing materials
variable variable variable If asbestos is found to be airborne, it may impact
See CEMP, CLMP, SWMP, G36
See SMP See item 6
1 Early warnings relate to informing neighbours who may be affected by the emission of this substance. If this substance is of a type and quantity which may reach neighbors
then early warning assessment of actions is required to be undertaken.
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the environment and community.
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HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – CLEARING AND GRUBBING
Project Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineers, Foreman, ESR Date March 2015
Name / ref of pollutant/
chemicals
Description of Hazard / Incident leading to hazard
L
evel o
f im
pact
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures
Corrective Action
Resp
on
sib
le
Pers
on
1.Noxious weeds
Improper disposal of noxious weeds causing contamination of land
2 2 L Negligible. Contractor to remove and dispose in accordance with Camden council regulations
Staff training
CEMP G40 2.4 – contractor to write clearing and grubbing plan
Contractor waste management plan
Ecologist report prepared on location of weeds and marked in drawings as per G40
contractor
2.Mulching Generation of dust 2 3 M Unlikely but possible
CEMP clearing and grubbing plan
Staff training contractor
Generation of tannins – contaminating waterway with high BOD
3 3 H Unlikely but possible
Reduce volume of mulch to be managed at any one time -RMS Enviro Direction ‘Management of Tannins from Vegetation Mulch’
CEMP
Staff Training
contractor
3.Mulch Stockpiling
Dust 2 3 M Unlikely but possible
CEMP clearing and grubbing plan
RMS Stockpile site management guideline EMS-TG-10
Staff training
contractor
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Name / ref of pollutant/
chemicals
Description of Hazard / Incident leading to hazard
L
evel o
f im
pact
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures
Corrective Action
Resp
on
sib
le
Pers
on
3.Mulch Stockpiling
Generation of tannins – contaminating waterway with high BOD
3 3 H Unlikely but possible
Reduce volume of mulch to be managed at any one time -RMS Enviro direction ‘Management of Tannins from Vegetation Mulch’
Stockpile management plan and layout to be developed prior to stockpiling to ensure location of piles.
CEMP
Staff Training
contractor
Fire 3 2 M Unlikely but
possible RMS Stockpile site management guideline EMS-TG-10
CEMP
Staff Training in turning stockpiles
contractor
4.Soil Erosion Erosion from cleared land entering waterway
3 2 M Unlikely but possible
clearing not to be done within 15m water courses until immediately before construction in that area
CEMP soil and water plan
G38 Erosion and sediment control
contractor
5.Rubbish and other
Improper disposal of waste causing contamination of land or water
2 2 L Unlikely but possible
Contractor to remove and dispose in accordance with council regulations
Staff training
CEMP G40 – contractor to write clearing and grubbing plan
Contractor waste management plan
contractor
6. Unexpected find of contaminates
Clearing of vegetation, topsoil stripping, and illegal dumping
3 2 M Unlikely but possible
Unexpected Discovery of Contamination Procedure to be enacted
Staff training
Contaminated Land Management Plan
contractor
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Soil and Water Management Plan
Name / ref of pollutant/
chemicals
Description of Hazard / Incident leading to hazard
L
evel o
f im
pact
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures
Corrective Action
Resp
on
sib
le
Pers
on
7.Plant and equipment leaks and spills
Spills into waterways from plant and equipment (e.g. hydraulic hose leaks, concrete loading, leaks from vehicles and road plant.)
3 3 H May impact on surface water quality if it goes off site
Project Team to ensure that chemical, fuel and lubricant storage areas must be suitably located inside a HazChem container in a secure protected area with an impermeable floor to minimise the impact of any spillage or contamination on the Site and adjoining areas. The HazChem container must be able to contain 120% of the total volume of the stored materials. Do not locate storage areas within 40 metres of natural or built drainage lines, flood prone areas, or on slopes steeper than 1:10. The Hazchem container is be located within the boundary of the main site compound and at nominated satellite site facilities. A fully equip spill kit shall be available and accessible and all the material safety data information for any chemical or fuel to be used or stored adjacent to the HazChem container.
Sedimentation basins act as capture / additional containment
Spill response measures implemented as per CEMP or Appendix 3 of this Plan
Auditing of implementation of G36 by contractor
Contractor
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Soil and Water Management
Purpose
This risk module forms part of the PIRMP for the Bringelly Road Upgrade Stage 1 project. The activities associated with this module are related only to soil and water management.
Activities
Soil and water management involves:
• waste water discharge from dewatering, surface washing, grit blasting, saw cutting, drilling, washing vehicles and plant, batching plants, casting yards, washing out of concrete mixers and concrete trucks and any other activities which add pollutants to water;
• prevention of mud and litter being deposited on trafficked roadways;
• maintenance and cleaning of sediment control works;
• protection of soil and other stockpiles from erosion by wind and rain;
• extraction of water for construction purposes; and
• excavation in waterways.
• management of any sedimentation basins including measures for flocculation and dewatering
• Sensitive crossings
This risk module describes the main hazards to human health or the environment associated with soil and water management. The first table in the risk module lists the potential pollutants. The second table describes the potential pollution incidents with pre-emptive actions to be taken to minimise or prevent any risk of harm to human health or the environment. In the case of actual or threatened material harm to the environment or human health procedures must be followed for contacting authorities as in RMS Environmental Incident Classification and Reporting Procedure. For incidents where pollution has the potential to impact on the community, early warning systems as described in section 6 of this document are to be initiated.
Further details on the risk assessment and appropriate control methods can be found in the following documents:
• CEMP
• Review of Environmental Factors (REF) 2011 and addendum REF 2013
• Environmental Work Method statements
The module has been written to cover general environmental hazards and their controls. As the construction process is fluid, new documentation may better reflect the risks and controls. Primarily this will be the CEMP, sub-plans and/or Environmental Work Method Statements.
Rev. I (28/2/2019) Page 37 of 54
LIST OF POLLUTING SUBSTANCE STORAGES/USES AT SITE INITIAL ASSESSMENT – SOIL AND WATER MANAGEMENT
Site Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineer, Foreman, ESR Date February 2019
Name / description Hazardous Chemicals
Amount stored
Location of storage
Map ref Need for early warning*
Pre-emptive action ref Ref to safety coverage
Ref to Hazard and likelihood assessment
CHEMICALS (raw materials and products which can cause pollution)
hydrocarbon spills
Yes variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, Environmental Fact Sheet 09 plant refuelling, RTA environmental handbook for road and bridge works
See SMP See chemical module, road construction module and item 1.
stabilised pavements
No variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
See SMP See chemical module
precoat aggregates and spray sealing
Yes variable variable variable Only in extreme cases where spills or run off threaten to impact on health of waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
See SMP See chemical module and items 1 and 3
Bentonite slurry No variable variable variable Only in extreme cases where spills or run off threaten to impact on health of waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
See SMP See chemical module
MATERIALS (eg stockpiles, silos, bulk solids etc.)
sediment no variable variable variable Only in extreme cases where sediment threatens
See CEMP, G36, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
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to impact on health of waterway
Name / description Hazardous chemical
Amount stored
Location of storage
Map ref Need for early warning
Pre-emptive action ref Ref to safety coverage
Ref to Hazard and likelihood assessment
earthworks in soils with naturally occurring issues such as acid sulphate soils, saline soils or high levels of other sulphide minerals (which may result in high concentrations of heavy metals in runoff).
no variable variable variable Only in extreme cases where odour threatens to impact on community or run off materials threaten to impact on waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
N/A See item 4
general earthworks in soils with contamination issues
no variable variable variable Only in extreme wind where dust threatens to impact on community or erosion materials threaten to impact on waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
See SMP See item 5
concrete works (including batching operations)
variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, RTA Environmental Handbook for road and bridge works
See SMP See item 6
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Name / description Hazardous chemical
Amount stored
Location of storage
Map ref Need for early warning
Pre-emptive action ref Ref to safety coverage
Ref to Hazard and likelihood assessment
AQUEOUS (eg dams, wastewater tanks, other water storage area)
waste water discharge from surface washing
Only if it contains a hazardous chemical spill
variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
waste water discharge from dewatering
Only if it contains a hazardous chemical spill
variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
waste water discharge from grit blasting
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
waste water discharge from saw cutting
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
waste water discharge from drilling
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
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Name / description Hazardous chemical
Amount stored
Location of storage
Map ref Need for early warning
Pre-emptive action ref Ref to safety coverage
Ref to Hazard and likelihood assess-ment (next table)
waste water discharge from washing vehicles and plant
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
See COH and SMP See items 1. 2. And 3.
waste water discharge from batching plants,
no N/A N/A N/A N/A N/A N/A N/A
waste water discharge from casting yards
no N/A N/A N/A N/A N/A N/A N/A
washing out of concrete mixers and concrete trucks
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
N/A See items 1. 2. And 3.
waste water discharge from any other activities which add pollutants to water
no variable variable variable Only in extreme cases where spills threaten to impact on health of waterway
See CEMP, G36, Environmental Fact Sheet 03 Spill Management and Response, RTA Environmental Handbook for road and bridge works
See COH and SMP See items 1. 2. And 3.
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Name / description Hazardous chemical
Amount stored
Location of storage
Map ref Need for early warning
Pre-emptive action ref Ref to safety coverage
Ref to Hazard and likelihood assessment
SUBSTANCES IN PROCESSES (substances which could be emitted)
rubbish and litter Only for asbestos waste
variable variable variable If asbestos is found and fibres enter waterway or become airborne and threaten to impact on community
See CEMP, G36 See SMP See item 5
* Early warnings relate to informing neighbours who may be affected by the emission of this substance. If this substance is of a type and quantity which may
reach neighbours then early warning assessment of actions is required to be undertaken.
HAZARD AND LIKELIHOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – SOIL AND WATER MANAGEMENT
Site Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineer, Foreman, ESR Date February 2019
Name / ref of pollutant/
chemicals
Description of Hazard / Incident leading to hazard
Level o
f im
pact
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures
Corrective Action
Resp
on
sib
le
Pers
on
1.Wastewater discharge off site from sediment basins
Insufficient treatment with gypsum leading to Breach of EPA licence limit of Solids 50mg/L
4 4 E Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design Staff induction and training Environment Incident Classification and reporting procedure
contractor
Incorrect lime or HCl addition leading to low pH discharge and breach of EPA licence
4 2 H Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design Staff induction and training Environment Incident Classification and reporting procedure
contractor
Rev. I (28/2/2019) Page 42 of 54
Incorrect lime or HCl addition leading to high pH discharge and breach of EPA licence
4 2 H Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design Staff induction and training Environment Incident Classification and reporting procedure
contractor
Insufficient oil/grease removal leading to breach of EPA licence condition of no visible oil/grease
4 3 E Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design Staff induction and training Environment Incident Classification and reporting procedure
contractor
1.Wastewater discharge off site from sediment basins cont.
Discharge of chemical spill material from sediment basin eg pesticides
5 1 H possible CEMP and SWMP, G38 Use of BLUE BOOK during design Staff induction and training Environment Incident Classification and reporting procedure
contractor
Pumping of water containing solids higher than 50 mg/l eg by pump being left unattended
4 4 E possible CEMP and SWMP, G38
Use of BLUE BOOK during design
regular inspections
Staff induction and training
Environment Incident Classification and reporting procedure
2.Wastewater overflow from sediment basins
Failure / collapse of basin wall causing sediment laden material to move off site
4 2 H Unlikely but possible
1.CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Failure / collapse of basin wall causing excessive erosion
4 2 H Unlikely but possible
1.CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Failure/ collapse of basin wall causing contamination of waterway
3 3 H Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training
contractor
Rev. I (28/2/2019) Page 43 of 54
Environment Incident Classification and reporting procedure
Insufficient emptying of basin prior to previous rain event causing overflow off site
2 2 L Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Rev. I (28/2/2019) Page 44 of 54
HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – SOIL AND WATER MANAGEMENT
Name / ref of pollutant/ chemicals
Description of Hazard / Incident leading to hazard
Level
of
imp
act
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures Corrective Action
Resp
on
sib
le
Pers
on
2.Wastewater overflow from sediment basins cont.
Insufficient emptying of basin prior to previous rain event causing overflow off site
2 2 L Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Extreme rain event causing overflow off site
1 2 L Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Overflow of basin containing chemical spill leaving site
4 1 H Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Overflow incident contained on site
4 1 M no CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting p
contractor
Rev. I (28/2/2019) Page 45 of 54
HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – SOIL AND WATER MANAGEMENT
Name / ref of pollutant/ chemicals
Description of Hazard / Incident leading to hazard
Level
of
imp
act
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures Corrective Action
Resp
on
sib
le
Pers
on
3.Untreated run off
Failure of erosion or sediment controls causing sediment laden material to leave site
3 3 H Unlikely but possible
CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
Failure of erosion or sediment controls but run off remains on site
2 3 M no CEMP and SWMP, G38 Use of BLUE BOOK during design regular inspections Staff induction and training Environment Incident Classification and reporting procedure
contractor
4.Acid sulphate soils
Acid sulphate soils not identified and run off leaves site and contaminates land
4 2 H Unlikely but possible
CEMP and SWMP, G38 Staff induction and training Environment Incident Classification and reporting procedure RTA Environmental Handbook for road and bridge construction
contractor
Acid sulphate soils not identified and run off leaves site and contaminates waterway
4 2 H Unlikely but possible
CEMP and SWMP, G38 Staff induction and training Environment Incident Classification and reporting procedure RTA Environmental Handbook for road and bridge construction
contractor
Rev. I (28/2/2019) Page 46 of 54
HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – SOIL AND WATER MANAGEMENT
Name / ref of pollutant/ chemicals
Description of Hazard / Incident leading to hazard
Level
of
imp
act
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures Corrective Action
Resp
on
sib
le
Pers
on
5.Rubbish and other
Improper disposal of waste material found in soil, causing contamination of land or water
3 2 M Unlikely but possible
Contractor to remove and dispose in accordance with council regulations Staff induction and training CEMP and SWMP, G38 Contractor waste management plan Environment Incident Classification and reporting procedure
contractor
6. concrete first flush
Not reused in plant or treated in situ and leaves site causing contamination of land
2 3 M no CEMP and SWMP, G38 Staff induction and training Washout facility provided onsite or instruct concrete agitator truck to wash at their concrete batch yard. Environment Incident Classification and reporting procedure
contractor
Discharged to sediment basin and contaminates waterway
3 3 H Unlikely but possible
CEMP and SWMP, G38 Staff induction and training Washout facility provided onsite or instruct concrete agitator truck to wash at their concrete batch yard. Environment Incident Classification and reporting procedure
contractor
Rev. I (28/2/2019) Page 47 of 54
HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – SOIL AND WATER MANAGEMENT
Name / ref of pollutant/
chemicals
Description of Hazard / Incident leading to hazard
L
evel of
imp
act
Lik
ely
hoo
d
Priori
ty
Impact
on
neig
hb
ours
Control Measures
Corrective Action
Responsib
le
Pers
on
7.Plant and equipment leaks and spills
Spills into waterways from plant and equipment (e.g. hydraulic hose leaks, concrete loading, leaks from vehicles and road plant.)
3 3 H May impact on surface water quality if it goes off site
G-36 s6.12 requires: CEMP to ensure that chemical, fuel and lubricant storage areas must be suitably located inside a HazChem container in a secure protected area with an impermeable floor to minimise the impact of any spillage or contamination on the Site and adjoining areas. The HazChem container must be able to contain 120% of the total volume of the stored materials. Do not locate storage areas within 40 metres of natural or built drainage lines, flood prone areas, or on slopes steeper than 1:10. The Hazchem container is be located within the boundary of the main site compound and at nominated satellite site facilities. A fully equip spill kit shall be available and accessible and all the material safety data information for any chemical or fuel to be used or stored adjacent to the HazChem container.
Sedimentation basins act as capture / additional containment
Spill response measures implemented as per CEMP or s4.5 of this Plan
Auditing of implementation of G36 by contractor
Contractor
8.Sensitive Crossings
Contamination of waterway during construction activities for crossing of waterway
4 3 E Possible Staging of construction activities
Follow hierarchy of erosion prevention 1st and trapping and removing sediment 2nd
RTAs code of practice for Water Management
CEMP Erosion and Sediment Control Plans, G38
Managing Urban Stormwater: Soils and Construction Vol 1 (Landcom 2004)
contractor
Rev. I (28/2/2019) Page 48 of 54
Vol 2D Main Road Construction (DECCW, 2008)
Progressive Erosion and Sediment Control Plans prepared and implemented prior to works commencing at or near waterways in accordance with relevant EWMS
Rev. I (28/2/2019) Page 49 of 54
Road Construction Purpose This risk module forms part of the PIRMP for the Bringelly Road Upgrade Stage 1 project. The activities associated with this module are related only to Road Construction. Activities Road Construction:
• Excavation;
• Removal of material to spoil,
• filling,
• compacting,
• construction and trimming;
• paving;
• sweeping;
• Line marking
• Setting up site compound This risk module describes the main hazards to human health or the environment associated with road construction. The first table in the risk module lists the potential pollutants. The second table describes the potential pollution incidents with pre-emptive actions to be taken to minimise or prevent any risk of harm to human health or the environment. In the case of actual or threatened material harm to the environment or human health procedures must be followed for contacting authorities as in RMS Environmental Incident Classification and Reporting Procedure. For incidents where pollution has the potential to impact on the community, early warning systems as described in section 6 of this document are to be initiated. Further details on the risk assessment and appropriate control methods can be found in the following documents:
• CEMP
• Review of Environmental Factors
• Environmental Work Method statements
The module has been written to cover general environmental hazards and their controls. As the construction process is fluid, new documentation may better reflect the risks and controls. Primarily this will be the CEMP.
Rev. I (28/2/2019) Page 50 of 54
LIST OF POLLUTING SUBSTANCE STORAGES/USES AT SITE INITIAL ASSESSMENT – ROAD CONSTRUCTION
Site Name: Bringelly Road Upgrade Stage 1 Responsible person: Engineer, Foreman, ESR Date February 2019
Name / description Hazardous chemicals
Amount stored
Location of storage
Map reference
Need for early warning*
Pre-emptive action ref.
Ref to safety coverage
Ref to Hazard and likelihood assessment
CHEMICALS (raw materials and products which can cause pollution)
Oils and fuel from vehicles (bulk stores see chemicals section)
Yes Up to 10,000L in tanker, 100L max in plant, 20L container
In tankers, mobile plant and equipment, HazChem container
variable Only when spill occurs directly into waterways leaving site. Rare event
See CEMP, G36 See SMP Plant and equipment or See chemical module for bulk quantities
MATERIALS (eg stockpiles, silos, bulk solids etc.)
Fill No variable variable variable Only in extreme wind where dust threatens to impact on community
See CEMP, G36 See SMP See item 1, 2, 3
Road base No variable variable variable Only in extreme cases where erosion materials threaten to impact on health of waterway
See CEMP, G36 See SMP See item 1, 2, 3
Sand and Gravel No variable variable variable Only in extreme wind where dust threatens to impact on community
See CEMP, G36 See SMP See item 1, 2, 3
Bitumen and asphalt Partial Yes for hot mix Class 9
variable variable variable Only in extreme wind where dust threatens to impact on community
See CEMP, G36 See SMP See item 4
Concrete No variable variable variable No See CEMP, G36 See SMP See item 4
Line marking paint/ surface coatings
Yes possibly Class 3
variable variable variable No See CEMP, G36 See SMP See chemicals module details
Rubbish and other
Only for asbestos waste
variable variable variable Low Waste materials are generally solid. Litter or spills in to waterways most at issue.
See CEMP, G36 See SMP
* Early warnings relate to informing neighbours who may be affected by the emission of this substance. If this substance is of a type and quantity which may reach
neighbours then early warning assessment of actions is required to be undertaken.
Rev. I (28/2/2019) Page 51 of 54
HAZARD AND LIKELY HOOD RISK ASSESSMENT AND CORRECTIVE CONTROL MEASURES – ROAD CONSTRUCTION
Name / ref of pollutant/ chemicals
Description of Hazard / Incident leading to hazard L
evel o
f
imp
act
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures Corrective Action
Resp
on
sib
l
e P
ers
on
1.Earth-moving: Road base Sand Gravel and soils during movement
Potential impacts on waterways from erosion, contamination, etc. From various activities e.g. culvert extension and reconstruction, sediment basins, spills
3 2 M Unlikely but possible
1. CEMP soil and water plan 2. G38 Erosion and sediment control 3. Staff training
contractor
2.Stockpiles: Road base Sand Gravel And soils Erosion and Sediment
Large scale excavation works, large batters, Spoil Stockpiling, Road Base Stockpiling, Sand and gravel Stockpiling
3 3 H Unlikely but possible
1. CEMP 2. RMS Stockpile site management guideline EMS-TG-10 3. Staff training 4. G38 Erosion and Sediment Control
contractor
3.Dust from Earth-moving and stockpiles
Dust due to Large scale excavation works and Stockpiles
4 2 H Likely 1. CEMP 2. G38 Erosion and sediment control 3. RMS Stockpile site management guideline EMS-TG-10 4. Staff training
contractor
Rev. I (28/2/2019) Page 52 of 54
Name / ref of pollutant/ chemicals
Description of Hazard / Incident leading to hazard L
evel o
f
imp
act
Lik
ely
ho
od
Pri
ori
ty
Imp
act
on
neig
hb
ou
rs
Control Measures Corrective Action
Resp
on
sib
l
e P
ers
on
4.Plant and equipment leaks and spills
Spills into waterways from plant and equipment (e.g. hydraulic hose leaks, concrete loading, leaks from vehicles and road plant.)
3 3 H
May impact on surface water quality if it goes off site
G-36 s6.12 requires: CEMP to ensure that chemical, fuel and lubricant storage areas must be suitably located and HazChem container in a secure protected area with an impermeable floor to minimise the impact of any spillage or contamination on the Site and adjoining areas. The bunded area must be able to contain 120% of the total volume of the stored materials. Do not locate storage areas within 40 metres of natural or built drainage lines, flood prone areas, or on slopes steeper than 1:10. The Hazchem container is be located within the boundary of the main site compound and at nominated satellite site facilities. A fully equip spill kit shall be available and accessible and all the material safety data information for any chemical or fuel to be used or stored adjacent to the HazChem container. Sedimentation basins act as capture / additional containment Spill response measures implemented as per CEMP or s4.5 of this Plan Auditing of implementation of G36 by contractor
Contractor
5.Setting up site compound
Litter or sewerage causing pollution of land or waterway
2 2 L
Negligible G4 CEMP Licence sewage sucker truck to be engaged.
Contractor
Erosion run off from clearing of land
2 3 M
Unlikely 1. G4 2. CEMP
Contractor
Dust from vehicles
2 3 M
Unlikely 1. Sealed access roads 2. Gravel parking areas 3. G4 4. CEMP
Contractor
Rev. I (28/2/2019) Page 53 of 54
Appendix 3 St John Ambulance First Responder Chart