rooty hill regional distribution centre (rdc) - holcim · blending plant/pug mill to mix road base...
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Rooty Hill Regional Distribution Centre (RDC)
EMERGENCY RESPONSE PLAN
Final (Version 2) June 2012
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Contents 1. Introduction 4
1.1. Background 4 1.2. Purpose of this Plan 5 1.3. Structure of this Plan 6 1.4. Definitions 6
2. Legislative and regulatory compliance 8 2.1. Relevant legislation 8
3. Types of Incidents and Emergencies 11 4. Prevention 12
4.1. Risks Assessment 12 4.2. Control 12
5. Preparedness 13 5.1. Training 13 5.2. Desktop and Field exercises 14 5.3. Communication 14 5.4. Monitoring inspection, auditing and reporting 15 5.5. Resources 15 5.6. Roles and responsibilities 16 5.7. Contacts 16
6. Response 17 6.1. Activation of Response Plans 17 6.2. Notification of Environmental Incidents and Emergencies 17
7. Recovery 19 8. Review and improvement of this Plan 20
8.1. Environmental Management Review 20 8.2. Continual Improvement 20
Appendix A Notification of Environmental Harm Procedure 21 Appendix B Environmental Incident Response Procedure 22 Appendix C Spill Management Flow Chart 23 Appendix D Holcim’s Safety Health and Environmental (SHE) Guideline 5.1 24
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Document history and status Revision Date issued Reviewed by Approved by Date approved Revision type
Initial Draft 20/07/2011 R Savage L Montesin 02/08/2011 Initial Draft for discussion
Final Draft V1 24/08/2011 J Ball L Montesin 13/09/2011 Practice Review
Final V0 13/09/2011 R Savage L Montesin 21/09/2011 Final Review
Final V1 31/01/2012 L Montesin L Montesin 31/01/2012 Address changes in legislation
Final V2 29/6/2012 A Smith S Moseley 29/6/2012 Revised for Stage 2
Distribution of copies Revision Copy no Quantity Issued to
Initial Draft Via email 1 R Savage
Final Draft V1 Via email 1 J Ball
Final V0 Via email 1 R Savage
Final V1 Via email 1 R Savage/ G Poljak
Final V2 Hard Copy 2 R Savage/ G Poljak
Printed: 2 July 2012
Last saved: 28 June 2012 02:34 PM
File name: I:\ENVR\Projects\EN03142\Deliverables\Reports\ERP Stage 2\EN03142_Rooty Hill RDC_ ERP_Final V2_150612.docx
Author: Lisa Montesin / Alice Busby Smith
Project manager: Andrew Smith
Name of organisation: Holcim
Name of project: Rooty Hill Regional Distribution Centre
Name of document: Emergency Response Plan
Document version: Final (Version 2)
Project number: EN03142
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Table of Amendments
Section Amendment
General Update for revised agency names e.g. RTA to RMS, OEH to EPA etc
Table 2-2 Amend to reflect EPL may be required
Section 2.4 Update to reflect new OHS laws
Section 5.6 Roles & responsibilities amended to align with CEMP
Section 8.2. 3rd dot point Amended to be “as incidents/non-conformances apply”
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1. Introduction
1.1. Background
The Rooty Hill Regional Distribution Centre (RDC) located at Kellogg Road, Rooty Hill within the Blacktown Local Government Area (LGA) will allow Holcim to receive construction material by rail from quarries located outside of the Sydney Basin, blend the materials to meet customer specifications and distribute these by road to the Sydney market. The construction materials received will include single size crushed aggregate, blended crushed aggregates and natural/manufactured sand, typically used for the manufacture of concrete and asphalt as well as a variety of other uses in the civil and construction industries. Holcim currently supplies the bulk of these materials through the Penrith Lakes Development Corporation (PLDC), however the resource at this site is nearly depleted and the facility will wind down to closure by mid 2014.
The site is 15 hectares and is bound by the Main Western Railway Line to the south, the Nurragingy Reserve to the East, the OneSteel Mini Mill and other industrial developments to the west and industrial land to the North. Angus Creek, a tributary of the Eastern Creek, flows through the southern portion of the site. The site was chosen due to the unique access opportunities that include rail (Main Western Railway) and road (M7 Motorway).
Once operational, the Rooty Hill RDC will operate 24 hours a day, seven (7) days a week and will be capable of handling up to four (4) million tonnes per annum of product.
The main elements of the Project are listed below:
Regional office building and quarry and concrete testing laboratory.
Rail sidings of 1,100 metres in length with aggregate unloading facility located in the middle of the siding.
On‐ground Concrete Storage Bins and Load out facility.
Radial stacker as a contingency mechanism to allow trains to be unloaded and returned to the rail system if there is a malfunction with the operation of the main storage system, or if materials at the unloading station are contaminated.
Blending plant/pug mill to mix road base with cement or lime and water at a capacity of 400 tonnes per hour.
Conveyor system, linking the unloading station to the storage and truck loading facilities.
Workshop, stores, site offices, truck wash down, truck refuelling, weighbridges, paving and parking.
A 200,000m3per annum capacity concrete batching plant.
A road/conveyor bridge over Angus Creek to link the northern and southern sections of the site.
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1.2. Purpose of this Plan
The purpose of this Emergency Response Plan (ERP) is to provide a framework to effectively prevent, prepare for, respond to and recover from all incidents and/or emergencies in an appropriate manner. This includes identifying:
Relevant legislation and guidelines for managing incidents and/or emergencies.
The relationship of this Plan to other plans and procedures applicable to the Project.
Procedures that will prevent or minimise the chances of incidents and/or emergencies occurring in the first instance and avoid or reduce the potential environmental and human health consequences in the event that an incident and/or emergency occurs.
Roles and responsibilities for managing and responding to incidents and/or emergencies.
Contact telephone numbers and 24 hour contact procedures for managing and responding to incidents and/or emergencies.
A monitoring, auditing and reporting framework to assess the effectiveness of this Plan.
This ERP is applicable to all activities during the construction phase of the Project and has been prepared to satisfy the Minister’s Conditions of Approval (MCoA), the Statement of Commitments (SoC), and applicable environmental legislation and guidelines. The ERP will be updated for the operational phase of the Project.
This ERP should be read in conjunction with the Project Safety Management Plan (SMP). The ERP and SMP are over arching documents that provide direction for all parties involved in construction activities to effectively manage OH&S and environmental regulations.
The Contractor is required to prepare a Contractor’s ERP in accordance with the requirements noted in this ERP.
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1.3. Structure of this Plan
This Plan covers each of the four key elements of incident and emergency management in a dedicated section. These elements are:
Prevention: the measures to be taken to prevent an incident and/or emergency or lessen its impacts.
Preparedness: the measures to be taken to prepare all personnel and resources to respond to an incident and/or emergency.
Response: the immediate actions and procedures to be taken to effectively respond to an incident and/or emergency.
Recovery: the medium to long term actions to be taken to recover from anincident and/or emergency.
1.4. Definitions
Incident: an unplanned event that has caused harm or has the potential to cause harm. The term ‘incident’ can be used in relation to both environmental and safety issues Emergency: an event, actual or imminent, which endangers or threatens to endanger life, property or the environment, and which requires a significant and coordinated response. Contractor: Means person/ persons engaged by Holcim (Australia) for the construction of the Rooty Hill RDC. The engagement can be by a written contract or pursuant to an oral request. This includes contractors’ sub‐contractors and their employees who are doing work for the benefit of Holcim (Australia). Environmental Incidents
An environmental incident is an unexpected event that may result in harm to the environment and requires some action to minimise the impact or restore the environment. For the purposes of this ERP, the following definitions have been derived from the Protection of the Environmental Operations Act 1997:
In accordance with Section 147 of this Act the meaning of material harm to the environment is below:
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”
It should be noted that Under Section 148 of the Protection of the Environment Operations Act 1997 (POEO Act), Holcim have a duty to notify the NSW Environment Protection Authority (EPA)and each relevant authority (i.e. NSW Health, NSW Fire and Rescue, WorkCover, NSW Police and the local council) immediately about a pollution incident occurring in the course of an activity that causes or threatens “material harm to the environment”.
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Environmental incidents and/or emergencies will be recorded, reported and investigated using Holcim’s Safety Health and Environmental (SHE) Guideline 5.1 (refer Appendix D). Under Holcim’s SHE requirements there are five levels of incidents and/or emergencies as noted in the following table. Under this matrix all incidents will be classified as minor, significant, serious, severe or a disaster.
Section 5.3 provides further information on the responsibilities for classification of incidents using this matrix. For any incident classified as significant (or above) it will be the responsibility of the Environmental Officer (EO) in consultation with the Environmental Representative (ER) to determine when immediate notification to the EPA and each relevant authority is required under Section 147 of the POEO Act (i.e. when actual or potential loss or damage to property exceeds $10,000).
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2. Legislative and regulatory compliance 2.1. Relevant legislation
The key environmental legislation of relevance to environmental incidents is as follows:
Protection of the Environment Operations Act 1997 (PoEO Act).
Dangerous Goods (Road and Rail Transport) Act 2008.
Environmentally Hazardous Chemicals Act 1985.
Contaminated Land Management Act 1997.
Rural Fires Act 1997.
2.2. Minister’s Conditions of Approval
Approval of this Project was granted by the Department of Planning in 2006 (Application No. 05_0051), with a modification to the Project approved in 2011. Minister’s Conditions of Approval (MCoA) were issued for the approval and modification and those conditions relevant to emergency response have been incorporated in this Plan and are detailed in Table 2‐1.
Table 2-1Minister’s Conditions of Approval (MCoA)
MCoA Requirement Document Reference
2.40 The Proponent shall provide appropriate fire-fighting equipment at the site, and shall ensure appropriate volumes of emergency supplies of water (for fire fighting purposes), is provided at the site at all times during operations to ensure an appropriate response to any fire event.
Section 5
6.1
The Proponent shall notify the DEC* and the Director General of any incident with actual or potential significant adverse off-site impacts on people or the biophysical environment as soon as practicable after the occurrence of the incident (“initial notification”). The Proponent shall provide written details (“written report”) of the incident to the DEC* and the Director General within seven days of the date on which the incident occurred.
Section 6.2 Appendix A
6.2 The Proponent shall meet the reasonable requirements of the Director General to address the cause or impact of any incident, as it relates to this approval, reported in accordance with condition 6.1 of this approval, within such period as the Director General may require.**
Section 6.2
* Department of Environment and Conservation. Now the NSW Environment Protection Authority (formerly the Office of Environment and Heritage). ** Note: Condition 6.2 does not limit or preclude the DEC* from requiring any action to address the cause or impact of any incident, in the context of the DEC's* statutory role in relation to the project.
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2.3. Statement of Commitments
This plan considers the requirements in the Statement of Commitments (SoC) from the Environmental Assessment (including Submissions Report and revised Statement of Commitments). The commitments relevant to the management of waste are summarised in Table 2‐2.
Table 2-2Statement of Commitments (SoC)
SoC Commitment Document Reference
14.1 Prior to commencement of construction an Emergency Response Plan (ERP) will be prepared for the site which will describe the general policy and approach to be adopted by Readymix (Holcim) when managing and responding to an emergency or incident at the site. The ERP will contain a specific definition of ‘incident’ and ‘environmental incident’ which is to be consistent with the definition of ‘incident’ in the POEO Act.
Section1.2,1.3 and 1.4
14.2 In accordance with Part 5.7 of the POEO Act, the Site Manager must immediately notify the NSW DEC1and each relevant authority of ‘incidents’ which occur in the course of operations of the RDC where material harm to the environment is caused or threatened, immediately after they become aware of the incident or threatened material harm2.
Section 1.4 and Appendix A
14.3 Initial notification of an ‘incident’ (as defined) is to be made by telephoning the NSW DEC’s1 Pollution Line and each relevant authority (e.g. NSW Heath, NSW Fire and Rescue, WorkCover, NSW Police and the local council)3.
Section 6.2 Appendix A
14.4 The DEC1 may require a written report regarding an incident and the following information may be required by the DEC1:
The time, date, nature, duration and location of the incident; The location of the place where pollution is occurring or is likely to occur; The nature, the estimated quantity or volume and the concentration of any pollutants
involved; The circumstances in which the incident occurred (including the cause of the incident, if
known); The action taken or proposed to be taken to deal with the incident and any resulting
pollution or threatened pollution; and Other relevant information.
Section 6.2 Appendix A
14.5 The Site Manager will assess specific incidents taking into consideration the impact(s) on the environment to determine what response is required or to assist in responding to the impact. The Site Manager would contact an outside agency if required.
Section 6.2 Appendix A
14.6 All employees working on the site will be responsible for ensuring that the Site Manager is informed of any environmental incidents. All environmental incidents would be recorded on an Environmental Incident Report form. As required by Part 5.7 of the POEO Act and the Environment Protection Licence (EPL)5, the Site Manager must immediately notify the NSW DEC1and each relevant authority of incidents, or the threat of material harm to the environment, as soon as practicable after they become aware of the incident or threat of material harm4.
Section 6.2 Appendix A Appendix B
14.7 The management strategies for responding to and controlling incidents/emergencies will include the following:
General procedures Provide adequate resources including staffing and fire fighting equipment; Training of staff so that a high level of preparedness is maintained by all people who
could be involved in an emergency; Provide a first aid station which would be fully equipped and maintained at the site with
trained first aid staff on the site at all times; and Periodic review and update of emergency procedures for the site.
Fire procedures Consultation has been initiated with the NSW Rural Fire Service and this would be
ongoing;
Section 5
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SoC Commitment Document Reference
Consult with adjoining landholders; Undertake hazard reduction as required; Provide fire fighting equipment at site buildings; Provide clear signposting and access for all fire fighting equipment; Make available water for fire fighting from water holding tanks or mains; and Regularly inspect and maintain fire fighting equipment.
Chemical storage and handling procedures Store all chemicals in appropriately bunded areas in accordance with their Material
Safety Data Sheets (MSDS) and the relevant Australian Standards; and Store all fuels or flammable solvents in adequately ventilated areas.
14.8 All environmental incidents are to be recorded on an Environmental Incident Report form. Section 7.1 and Appendix C of this Plan
14.9 An Environmental Incident Folder is to be maintained and shall contain the following: Copies of work instructions on how to deal with particular situations; Incident contact names/numbers; and Environmental Incident Report form containing all the details required in the “Notification
of Environmental Harm” procedure.
Section 7
1 Department of Environment and Conservation has been renamed the NSW Environment Protection Authority (EPA – formerly the Office of Environment and Heritage. 2 SoC 14.2 updated to address changes to notification requirements under the POEO Act 1997 (i.e. the requirement to notify pollution events threatening material ham to the environment immediately rather than as soon as practical after becoming aware). 3 SoC 14.3 updated to address changed to notification requirements under the POEO Act 1997 (i.e. the requirement to notify each relevant authority in addition to the EPA Branch). 4 SoC 14.6updated to address changes to notification requirements under the POEO Act 1997 as noted above. 5 The project does not currently have an EPL (subject to change) 2.4. Guidelines and standards
The key guidelines, codes of practice and standards of relevance to environmental incidents are as follows:
Work Health and Safety Act 2011
Storing and handling liquids: Environmental protection. Participant’s manual. A guide to managing environmental risks associated with the storage and handling of liquid substances (Department of Environment and Climate Change, 2007).
Environmental Compliance Report. Liquid Chemical Storage, Handling and Spill Management. Part B. Review of Best Practice and Regulation (Department of Environment and Conservation, 2005).
Storage and handling of dangerous goods: Code of practice (WorkCover NSW, 2005).
Australian Dangerous Goods Code, 7th Edition (National Transport Commission, 2007).
AS 1940: 1993 The Storage and Handling of Flammable and Combustible Liquids.
AS/NZ Standard 4360:1999 Risk Management.
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3. Types of Incidents and Emergencies Emergency situations that may occur on the Project that are covered by the ERP include but are not limited to the following:
Fires including the spread of wildfire into the Project site from the Angus Creek Corridor, the Nurragingy Reserve and surrounding bushland.
Medical emergencies (e.g. electrocution).
Adverse weather conditions and/or natural disasters such as severe weather and, storm damage, flood and earthquakes.
Hazardous substance and dangerous goods incidents (including spill and/or leaks of oils and fuels during refuelling of plant and equipment).
Structural instability or collapse.
Bomb threats (including phone and written threats, suspicious packages and letter bombs).
Explosion.
Collision including between road vehicles etc.
Terrorism.
Disturbance of the high pressure gas main, water, sewer or other underground service, resulting in service disruption and potential for explosions, fire, property damage and human injury.
Incidents that may occur on the Project that are covered by the ERP include but are not limited to the following:
Public safety issues and complaints from the general public and stakeholders.
Failure of erosion and sediment control measures leading to an uncontrolled release from the worksite.
Unauthorised clearing and trimming of vegetation.
Harm and/or injury to fauna.
Inappropriate disposal of waste.
Spills of hazardous substances and/or dangerous goods.
Inappropriate storage and handling of hazardous substances and/or dangerous goods.
Disturbance of previously unidentified contaminated material and/or heritage items (Indigenous and/or Non‐Indigenous).
It should be noted that additional types of potential incidents and/or emergencies may be identified through the Contractor’s OH&S Hazard Identification and Risk Assessment Process which includes the development of a risk register (refer Section 4.1). In addition the processes and procedures for the management of complaints from the general public and stakeholders are addressed in the Community Consultation Strategy (CCS).
Appendix B provides further details on the management of unauthorised disturbance to vegetation, harm and/or injury to fauna, inappropriate disposal of waste and the management of previously unidentified contaminated material and/or heritage items.
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4. Prevention Carefully planned and controlled execution of construction works is the key method employed to prevent incidents and emergencies occurring on the Project. In summary, preventative measures include:
Adequate works planning including the OH&S Hazard Identification, Risk Assessment Process and Work Method Statements (WMS).
Implementation and maintenance of all control measures noted in the WMS and/or Construction Environmental Management System (EMS).
Compliance with all legislative and industry requirements.
Compliance with all applicable internal project system procedures.
Compliance with the requirements of the Project Safety Management Plan.
Compliance with the requirements of the Project Construction Environmental Management Plan and its related issue specific management plans and procedures.
Compliance with this ERP.
4.1. Risks Assessment
An environmental risk assessment carried out during development of the Construction EMS (refer Appendix D of the CEMP) identified a number of key risk areas related to environmental management (e.g. spills).
The Contractor will complete an OH&S Hazard Identification and Risk Assessment Process which includes the development of a risk register using Holcim’s Safety Health and Environmental (SHE) Guideline 3.1 Risk Management as a guide. The Contractor will review and update this register when a new hazard is identified during construction (e.g. during a site inspection or a “Take 5”).
Safe Work Method Statements (SWMS) will be developed for all medium and high risk activities.
4.2. Control
The key mechanism which will be utilised to prevent the occurrence of likely incidents and emergencies rests in the thorough planning of work to be performed, involvement of key personnel in the construction decision making process and consistent application of the project quality system.
The Project quality system constitutes principally of a structured system involving functional management plans and associated procedures. In order to maintain effective control over project construction activity and prevent likely incidents or emergencies from occurring, consistent compliance with project system requirements must be ensured through auditing, monitoring, inspections and training.
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5. Preparedness The Contractor will prepare for potential environmental incidents by:
Developing procedures and protocols for handling incidents and emergencies including identifying resources and equipment require for effective emergency response, roles and responsibilities and key contacts.
Providing adequate and ongoing training to all personnel.
Conducting desktop and field exercises.
Regular auditing and inspections of construction activities.
Ongoing and effective communication.
Ongoing liaison with response authorities (including emergency services).
Ongoing compliance checks with OHS requirements by the contractor.
Maintaining current documentation so potential incidents and emergencies can be properly managed.
5.1. Training
All personnel working on site will receive adequate training on how to prevent, prepare for, respond to and
recover from an incident and emergency. This will be part of the Project Induction, and toolbox talk(s). The
following information will be conveyed to staff:
The requirements under the Emergency Response Plan (including the incident and emergency communication protocol).
Response required responding to medical emergencies.
Response to manage environmental emergencies.
The name and contact numbers for the Project Manager(s) and the EO.
Emergency contact numbers for external and site personnel.
Requirements for conducting risk assessments to identify environment and safety hazards during preparation of method statements.
Locations of sensitive sites.
Vehicle parking and speed limits.
Plant refuelling, maintenance and clean down requirements.
Location of the spill kit(s) and their operating requirements.
Storage and handling requirements of hazardous materials and dangerous goods.
Legislative requirements relating to emergency response and notification; and
Training programs will ensure that all staff who may be in doubt of their specific roles and responsibilities will complete a “Take 5” which is a personal risk management tool to identify, assess and control hazards that may be present or develop as part of the immediate work environment, the intended work practice or a combination of both. The “Take 5” checklist covers the following elements:
Stop, look, walk around.
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Think through the task.
Identify hazards.
Control and communicate.
Do the job safety
Records will be kept of all personnel undertaking the site induction and training, including the contents of the training, date and name of trainer/s.
Key staff will undertake more comprehensive training relevant to their position and/or responsibility. This training may be provided as “toolbox” training or at a more advanced level by the EO and/or a Contactor representative.
Further details regarding the content of staff induction and training are outlined in the Construction Environmental Management Plan (CEMP).
5.2. Desktop and Field exercises
Combined safety and environmental desktop and field exercises will be carried out during the construction phase. Exercises will involve responding to a simulated event and will be coordinated by the Contractor. Additional exercises will be scheduled throughout the construction phase, the exact timing will be determined based on the outcomes of the initial exercise.
Post exercise debriefing sessions will be conducted in conjunction with Holcim’s Project Manager and EO (where required) to assess the exercise against objectives. Debriefs will assist and identify improvements to the plan, procedures and training.
5.3. Communication
All training programs will promote coherent, simple and clear communication during an incident or emergency. The Contractor will not to use long communication chains and must ensure all personnel are mindful of the language barriers between ages and races.
Incident and emergency communications within the Contractor’s ERP will follow the framework presented in this ERP that provides an appropriate level of response to any planned or unplanned incident occurring on the Project site.
It is the responsibility of the EO in consultation with the ER to classify the level of environmental incident, as per the categories provided in Section 1.4and to determine if there is “actual or potential material harm to the environment” and to implement appropriate response plan. In the event of an actual or potential environmental incident the contractor must follow the Notification of Environmental Harm Procedure provided in Appendix A of this ERP.
Notifications to WorkCover under the NSW OH&S Regulation are addressed in Section 16 of the SMP.
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5.4. Monitoring inspection, auditing and reporting
Audits (both internal and external) would be undertaken to assess the effectiveness of environmental controls and compliance with this plan, MCoA and other relevant guidelines. Any audit of this plan would be part of an overall audit of the Construction Environmental Management System (EMS). The following elements may be included in the audit of the overall CEMP:
Compliance with statutory obligations.
Compliance with Holcim environmental standards, guidelines, specifications and contract conditions.
Compliance with the CEMP and sub plan.
Adequacy of monitoring and operational reports.
Completion of environmental actions.
Adequacy of environmental training records.
Adequacy of environmental records, checklists and document management systems.
Preparation of environmental reports.
Recording and completion of corrective actions following environmental incidents and complaints.
Achievement of environmental performance objectives.
Implementation of actions from previous audits.
A schedule for internal audits providing frequencies and responsibilities is provided as part of the CEMP.
5.5. Resources
Resources and equipment will be located on‐site to enable quick response and management of incidents and/or emergencies. Resources and equipment will include:
Adequate numbers of trained first aid personnel. The number of trained first aid personnel available on site will be, as a minimum, as per legislative requirements. In addition, if required and identified during project risk assessment, extra qualified and trained first aid personnel will be made available on the project.
First Aid and emergency rescue equipment, including chemical showers (if required) and eye baths, are to be located within an area of easy accessibility to enable prompt and effective treatment when required
Fire fighting equipment including fire extinguishers will be clearly marked and will be located in all workshop areas/amenities/main offices/ on major plant/ fuel storage areas where relevant.
Water for fire fighting from holding tanks or mains.
Spill kits that include (at a minimum) mini booms, pillows, pads, absorbent particulate, disposal bags and gloves.
Material Safety Data Sheet (MSDS) for all substances that will be used and stored on‐site.
While it may seem logical to locate resources close to a potential spill site, it is not good practice because a spill may damage the spill kit or impair the ability to access it. To ensure the safety of all site personnel, resources would be located in a safe area away from a potential incident site.Training and signage will ensure that personnel are familiar with the location of where these resources are kept.
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5.6. Roles and responsibilities
The Environment Officer (EO), as delegate of the Environmental Representative (ER), will be responsible for the day‐to‐day management of on‐site air quality environmental control and monitoring procedures. With assistance from key personnel including the Project Manager and from the construction Contractor’s team (i.e. foreman, construction manager) the EO will:
Deliver the appropriate emergency response measures to mitigate environment impacts;
Develop and implement practical and effective environmental procedures for all aspects of construction
as identified for mitigation or a potential risk, with further detailed control procedures to be devised in
conjunction with the construction contractors.
Ensure compliance with emergency procedures through visual inspection, staff training, checklists and
auditing and corrective action where required.
review, and modify where required, the emergency response plan on a regular basis; and
Monitor community and stakeholder feedback and monitoring results.
Specific responsibilities for incident and emergency response will be noted in the Contractor’s ERP. This will include the role and responsibilities of the Emergency Controller, OH&S Manager, ER, EO, Foreman etc.
5.7. Contacts
A contacts list shall be posted in a prominent position in all project offices and amenities. The CEMP contains the numbers of key personnel and emergency services.
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6. Response The response phase of this plan details incident and emergency procedures and provides the protocol for notifying appropriate authorities following the occurrence of an incident or emergency.
Specific emergency response procedures will be developed by the Contractor and will be reviewed by Holcim prior to the commencement of construction.
6.1. Activation of Response Plans
The Contactor will develop an ERP to address possible incidents and emergencies note in Section 3 and those addressed in the risk assessment process.
The response arrangements of this plan are to be activated by the Contractor who will consider the following:
Safety of personnel.
Communication in accordance with communication protocol.
Type of substance involved and whether multiple substances are involved that could react with one another.
In the case of a spill, the size of the spill and the source of the leak.
Unusual features such as foaming, odour, fire etc.
In the case of a release, if the material can be cleaned up on the site by site personnel or if other resources are required.
Required resources to deal with the environmental incident.
The procedures for cleaning up small chemical, fuel or oil spills/ leaks that occur on the Project site is described in the Spill Management Procedure. A flow chart summarising this procedure is presented in Appendix B.
6.2. Notification of Environmental Incidents and Emergencies
The Contractor must notify the Holcim Project Manager, ER and EO of all actual and potential environmental incidents and/or emergencies during the construction phase in accordance with the Contractors Environmental Incident Response Procedure (Refer Appendix B).
The EO will follow the Notification of Environmental Harm Procedure (Refer Appendix A) and will complete a STARS Environmental Incident Notification Form.
In accordance with Minister’s Condition of Approval (MCoA) 6.1 the ER or the EO (with approval from the ER) will notify the EPA and the Director‐General of Department of Planning and Infrastructure (DoPI) of any incident with actual or potential significant offsite impacts on people or the biophysical environment (i.e. incidents threatening material harm to the environment) immediately after the occurrence of the incident (“initial notification”). The ER or the EO (with approval from the ER) will provide written details (“written report”) to the EPA and DoPI within seven (7) days of the date in which the incident occurred.
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In accordance with MCoA 6.2 all reasonable requirements of the Director‐General of DoPI related to the cause or impact of the incident will be addressed by the Holcim and the Contractor. It should also be noted that this MCoA does not limit or preclude the EPA from requiring any action to address the cause of impact of any incident in context with EPA statutory role in relation to the project.
All emergency responses will be conducted as detailed in the Contractor’s ERP. This Plan describes the actions that will be taken during incidents, details of personnel responsible for preventing, preparing for and responding to incidents and includes ‘out of hours’ contact details. The Contractor’s ERP must be consistent with this ERP and will be reviewed by Holcim prior to construction commencing.
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7. Recovery The EO will liaise with the Contractor to ensure all environmental incidents and/or emergencies are recorded, reported and investigated in accordance with the SHE Guideline 5.1 Incident Reporting, Recording and Investigating. This includes completing a Root Cause Analysis (RCA) for all incidents and emergencies classified as Category 2 and above and completion of the STARS Environmental Incident Notification Form.
The Contactor will maintain an Environmental Incident and Emergency Folder which will contain the following information:
Copies of work instructions on how to deal with a particular situation
Incident contact names /numbers.
Environmental Incident Report Form containing all details required in the “Notification of Environmental Harm” Procedure (refer Appendix A).
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8. Review and improvement of this Plan 8.1. Environmental Management Review
The effectiveness and proper implementation of the ERP will be reviewed by Holcim every twelve months or sooner as necessary. Review will be undertaken by the management team. The review will comprise:
Reviewing the results of audits.
Evaluation of the system, which improvements and corrective actions will be sought.
Evaluation of the operation of the ERP.
8.2. Continual Improvement
Continual improvement of the ERP will be achieved by the continual evaluation of environmental management performance against environmental policies, objectives and targets for the purpose of identifying opportunities for improvement. The continual improvement process will:
At least annually:
− Review the adequacy of this plan.
− Consider any recent developments in practices and technology to ensure Best Management ideals are followed to minimise waste generation and maximise reuse and recycling.
At least quarterly:
− Review monitoring results and identify areas of opportunity for improvement of environmental management which leads to improved environmental performance.
As incidents / non‐conformances occur:
− Determine the root cause or causes of non‐conformances and deficiencies.
− Develop and implement a plan of corrective and preventative action to address non‐conformances and deficiencies.
− Verify the effectiveness of the corrective and preventative actions.
Outcomes of these reviews shall be documented and retained for the duration of the project.
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Appendix A Notification of Environmental Harm Procedure
Notification of Environmental Harm Procedure
Version 2 Notification of Environmental Harm Procedure 1
Scope: This flowchart describes the process Holcim will follow to determine whether an environmental incident has caused
actual or potential material harm to the environment and whether the Environment Protection Authority (EPA), Department
of Planning and Infrastructure (DoPI) and each relevant authority require notification under MCoA 6.1.
Environmental Incident Occurs (Actual or Potential)
The Holcim PM and EO in conjunction with the Environmental Representative (ER) to assess the
potential implications of the environmental incident in accordance with the POEO Act 1997 (Part 5.7 – Duty to
Notify Pollution Incidents Sections 147‐153).
Holcim have a duty to notify the OEH (Environment Protection Authority (EPA) Branch) under Section 148 of the Protection of the Environment Operations Act 1997 immediately after becoming aware a pollution incident has caused or threatened material harm to the environment. Under Section 147 of this Act the meaning of material harm to the environment is below:
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
Contractor to inform Holcim PM and the EO of all actual and/or potential environmental incidents in accordance with the process documented in the Contractors Environmental Incident Response Procedure (refer Appendix B of the ERP).
The environmental incident must be categorised in accordance with the consequence categories and definitions provided in Attachment 5.1B of the SHE Guideline 5.1 Incident Reporting Recording and Investigation (NB: a Root Cause Analysis (RCA) must be conducted for all category 2 incidents and above).
Minor Environmental Incident No harm to ecosystems or humans or trivial in nature (No obligation
to notify OEH or DoPI).
Investigate and provide recommendations for action
or improvement.
EO with assistance from the Contractor (where required) will complete the STARS Environmental Incident Notification Form and will ensure the Contractor appropriately closes out any corrective actions. STARS form is sent to the Holcim PM for entry into the data base and appropriate internal reporting.
In the event of a spill Initiate Spill Response Procedure (refer Appendix C of the ERP).
Minor
Major
This may involve assistance from emergency services (e.g. NSW Fire and Rescue). The Contractors Emergency Response Plan will outline processes and procedures for notifying emergency services.
EO with assistance from the Contractor (where required) will complete the STARS Environmental Incident Notification Form and will ensure the Contractor appropriately closes out any corrective actions. STARS form is sent to the Holcim PM for entry into the data base and appropriate internal reporting. In accordance with MCoA 6.1 a
written report is to be provided to the OEH and DoPI within seven (7)
days of the date the incident occurred.
Employ pollution containment measures and re‐establish environmental controls.
Contractor to cease all work in affected area (if required), check safety and account for all personnel, then immediately notify the Holcim Project Manager
(PM) and Environmental Officer (EO).
Employ pollution containment measures and/or re‐establish
environmental controls.
Investigate and provide recommendations for action or
improvement.
This report will have appropriate review (this may include legal review) and internal signoff prior to being sent to OEH and DOPI.
Severity?
POEO Act Offence? The ER to immediately notify
EPA on 131 555, the Director‐General of DoPI (refer MCoA 6.1) and each relevant authority (e.g. NSW
Health, NSW Fire and Rescue, WorkCover, NSW
Police and the local council).
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Appendix B Environmental Incident Response Procedure
ENV I RONMENTA L I N C I D ENT RE SPONSE PROCEDURE
What is an ENVIRONMENTAL INCIDENT? Uncontrolled discharge of water off site (resulting from failure of sediment and erosion
control measures) Intentional release of dirty water off site Fire Oil and Chemical spill(s) Working outside approved construction hours Unauthorised clearing and trimming of native vegetation Harm to native fauna Disturbance to previously unidentified contaminated material and/or heritage items
(Indigenous and/or non‐Indigenous) An environmental incident is an unexpected event that may result in harm to the
environment and requires some action to minimise the impact or restore the environment
STOP WORK, SECURE THE AREA In the first instance stop work immediately Make sure you are safe and anyone working around you is safe Secure the area Implement Contractor Emergency Response Plan
CONTRACTOR TO NOTIFY HOLCIM PM and EO Call your supervisor immediately. Your supervisor will immediately notify the
following: Holcim Project Manager ........................................ Richard Savage ....... 0419 476 397 Environmental Officer ............................................ David Opperman .... 0449 644 446
WHAT HAPPENS NEXT? Holcim will implement the Notification of Environmental Harm procedure. This will
include an investigation into how and why the incident occurred. REMEMBER if someone from an external authority approaches you to ask questions –
please direct them to the Holcim PM or EO.
Uncontrolled discharge of water offsite: 1. Attempt to control the discharge of water, only if safe to do so. 2. If the wall of a sedimentation basin has failed call a watercart to start pumping water from the
basin to reduce the amount of water. 3. If a water pipe has burst – find where the water is being pumped from and turn it off. 4. Attempt to direct water to an area where it can be contained (e.g. to a sediment basin). 5. Notify your supervisor.
Intentional release of dirty water offsite: 1. Turn the pump / low flow off. 2. Contain the dirty water in a bunded area. 3. Block off the access of the dirty water from entering the clean water system. 4. Notify your supervisor.
Fire:1. Evacuate the area. 2. Secure the area. 3. If fire is large and out of control notify supervisor to call emergency services immediately. 4. If fire can be contained, attempt to control fire with fire extinguishers and watercart. 5. Notify your supervisor.
Oil or Chemical SpillRefer to the Environmental Spill Response Procedure (Appendix C of the ERP).
Working outside approved construction hours 1. Approved construction hours are 7am to 6pm Monday to Friday and 8am to 1pm Saturdays. 2. Work can only take place outside these hours with approval from Holcim Project Manager or
Environmental Officer.
Damage clearing and trimming of native vegetation 1. Notify your supervisor immediately if you notice any damage to native vegetation in the Angus
Creek riparian corridor (which is fenced with exclusion fencing).
Harm to native fauna1. Cease all work in the area where the fauna is likely to be affected. 2. Make a visual assessment on the condition of the animal (i.e. is it injured?) avoiding physical
contact. 3. Notify your supervisor.
NOTE: Work can only recommence once the incident has been assessed by the Holcim PM
and EO and the approval has been given by the Holcim PM or EO
Disturbance to previously unidentified contaminated material and/or heritage items1. Stop work in vicinity of the find and establish protection for the site. 2. Notify your supervisor.
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Appendix C Spill Management Flow Chart
Environment Spill Response Procedure
Scope: This environmental spill response procedure details the steps to be followed in the event of an oil or fuel spill or a hazardous substance incident on site.
Ensure a Root Cause Analysis (RCA) is conducted for all category 2 incidents and above in accordance with SHE
Guideline 5.1 Incident Reporting, Recording and Investigation and Attachment 5.1G completing an effective incident
investigation handbook.
Ensure the STARS Environmental Incident Notification Form is fully completed.
Remove any traffic diversions as soon as the area becomes safe.
If possible, transfer all remaining fuel, oil or chemical out of damaged tanks or lines to appropriate holding tanks, utilising
appropriate Personal Protective Equipment (PPE).
Provide details regarding location and material spilt. Holcim PM and EO to investigate and determine personnel safety hazards (including traffic control). The EO is to notify the
Environmental Representative (ER).
All spills should be considered hazardous unless the nature of the spills is clear and obvious. If the nature of the spill is not clear, the NSW Fire Brigade (000) should be contacted.
Contractor to complete the STARS Environmental Incident Notification Form
(attachment M of CEMP).
Remove safety controls put in place during the spill
Clean up (i.e. deploy absorption and containment materials to minimise the
spread of the spill)
Dispose of contaminated spill kit equipment appropriately and replace used
spill kit components.
Removed used absorbent material from the site as soon as practicable or within 24 hours of the spill occurring.
Place contaminated clean up equipment in the designation oil waste container for disposal. Do not place used materials
back in the spill kit.
The ER with assistance from the EO and PM to classify the incident in accordance with the 5 SHE categories and definitions. Notify Office of Environment and Heritage (OEH)
as appropriate.
Implement the Notification of Environmental Harm Procedure (refer Appendix A of the ERP).
Erect barriers around the spill to prevent the spill from entering into drains and water bodies and maintain them in place until the spill has been cleaned up. Place absorbent
material from the spill kit on the spill and allow the spill to be fully absorbed.
Notify the Holcim Project Manager (PM) and Environmental Officer (EO)
Find the source of the spill and contain to stop further spread, and protect drains and
waterways, only if safe to do so.
Oil, fuel or chemical spill on land on site
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Appendix D Holcim’s Safety Health and Environmental (SHE) Guideline 5.1
Attachment 5.1C2 Issue Date: August 2010 © Holcim (Australia) Pty Ltd 1/3
STARS Environmental Incident Notification Form
Site Incident No. / STARS Reference
Part 1 – Person Involved Details (Place an X in the box before the employment status & complete details) Employment Status Surname
Direct Employee
Independent Contractor Given Name
Supervised Contractor
Third Party Job Agency (required for contractors)
Not Applicable
Part 3 – Incident Details Select Report Source (Place an X in the box before the report source)
What date did the incident occur? (DD/MM/YYYY) Contractor
/ / Emlpoyee Name
What time did the incident occur? 24h (HHMM) EPA fine
EPA Notice
When was the incident reported? (DD/MM/YYYY) EPA Visit / Advice
/ / External Audit
Part 4 – Who reported the incident External Person
Person Reported by Surname Internal Audit
Other
Person Reported by Given Name
Person Reported by Contact Number
Select Type of Incident (Place an X in the box before the incident type)
Select Type of Material (Place an X in the box before the material type)
Select Type of Spillage (Place an X in the box before the spillage type)
Air Emission Acid Air Emmision - Dust
Blast Shock, Rock Fly Etc Admixtures Air Emmision - Noise
Inc Wast Disposal Etc Aggregate Air Emmision - Odour
License Admin, EPA Report Airborne Dust Breach of Licence / Approval
Metal Fatigue Cement Fire / Explosion
Neighbour Complaint Concrete Ground Vibration
Noise Emission Concrete Slurry Groundwater Contamination
Soil Contamination Contaminated Soil Other
Traffic On and Off Site Flyash Overpressure
Waste Fuels / Oil Soil Contamination
Water Emission General Waste Spill into Stormwater Drain
High PH Water Spill into Waterway
Not Applicable Spill onto Ground
Other Stormwater Overflow during Rainfall
Other Chemicals
Sand
Sediment-Laden Water
Silica Dust
Tailings / Slimes
Washout Waste
Attachment 5.1C2 Issue Date: August 2010 © Holcim (Australia) Pty Ltd 2/3
Part 5 - Consequence (Place an X in the box before the consequence) Consequence Consequence Definition
1 - Minor Any complaint from the public, or on or off-site incident immediately contained/cleaned up, and environmental cost less than $5,000
2 - Significant On or off site release causing minor harm and promptly contained/cleaned up, or on the spot fine, or administrative penalty up to $10K, or local media enquiry, or remedial action required by authorities, or environmental cost between $5,000 and $25,000
3 - Serious Off-site release with short term detrimental effect on environment, or prosecution likely, or administrative penalty between $10K and $25K, or regional, state, or national media coverage, or environmental cost between $25,000 and $250,000 or any externally notifiable incident.
4 - Severe Toxic release off site with prolonged detrimental effect on the environment, or prosecution expected, or administrative penalty between $25K and $250K, or State or national media headline coverage, or environmental cost between $250,000 and $2.5m.
5 - Disaster Toxic release off site with major detrimental effect on environment, or high level prosecution expected, and administrative penalty in excess of $250K, or sustained high level media and community pressure expected, and/or environmental cost >$2.5m
Part 6 – Incident Details Is this a notifiable incident to external authorities (for example EPA, etc) Yes No If yes, which external authorities need to be notified? (refer to SHE Guidelines) Endorsed by your Safety Manager? Yes No
Indicate if the incident occurred On-site or Off-site? On / Off Site On-site and Neighbours Wholly Off-site Wholly On-site
What site does this incident need to be linked to? Site Name
Where Off-site did this incident occur? Customer Site Elsewhere In Transit
Where was the physical location of the incident? (for example, boiler room, etc) Location
Please describe what happened (facts only, maximum 250 characters)
Did the incident involve a toxic release? Yes No
Has the spillage / emission been contained? Yes No Partially
Is a clean up required? Yes No
What immediate actions were taken to prevent re-occurrence?
Attachment 5.1C2 Issue Date: August 2010 © Holcim (Australia) Pty Ltd 3/3
Is there a potential for prosecution? Yes No
Were there any witnesses? Yes No Please record the witness or witnesses names, (separated with a ;)
Part 7 – Notification (Notification is to be as soon as possible after the incident but within 24 hours to a licensed STARS Administrator)
Person contacted Name Sent by the following method (place an X in the box before method used)
SHE Coordinator Email
National Admin Assistant Fax
Safety Manager PA Quarries PA Concrete PA Humes