BBA-PLN-1000-1400-0002-D-00 Construction Stormwater Management Plan 1 of 9 BELL BAY PULP MILL MANAGEMENT PLAN Revision Date Revision Description Prepared Reviewed Approved A0 8 November 2007 For submission to DEM IW JD JC B0 17 December 2007 Revised and resubmitted to DTAE for approval following DTAE verbal comments on revision A0 IW JD CF C0 25 January 2008 Review of document as a stand-alone document following DPIW comments on B0 GB JD CF D0 31 January 2008 Revised following DTAE comments JRD JD CF BBA reference number of this document: BBA-PLN-1000-1400-0002-D-00 Project phase(s): Construction x Commissioning Operations Plan: LU1 3SW4.1 Construction Stormwater Management Plan (CSMP) Purpose: To manage construction stormwater at the mill site to ensure that construction activities do not produce stormwater runoff that may cause erosion and raise turbidity levels in receiving waters or transport contaminant spills into receiving waters, including surface water and groundwater. Objectives: Objectives include, but are not limited to: Maintain or improve existing surface water quality during construction, consistent with the requirements of the Tasmanian State Policy on Water Quality Management 1997. Maintain the integrity and flow characteristics of streams that need to be temporarily disturbed for the construction of infrastructure. Maintain existing levels of flood protection and maintain the amenity of the riparian environment. Design stormwater drainage systems to ensure that water quality objectives are not exceeded in the event of a major spill of potentially contaminating material Contain accidental spills of contaminants. Scope: This CSMP covers the management of construction stormwater at the mill site for the duration of construction activities in relation to the pulp mill activity. The plan is in accordance with the Pulp Mill Permit (3SW4.1 to 4.6) including the relevant sections of the DIIS sections 4.7 and 4.8 of Volume 2. A Stormwater Management Design Plan (SMDP) for the construction of the permanent stormwater infrastructure (LU1 –Part 2-GeorgeTown-planning page 28 of 201, sequential page 41, permit condition 2.49) will be prepared separately and submitted to George Town Council prior to commencement of construction of this activity. An Operational Stormwater Management Plan (OSMP) (LU1 – Part 3-Section 3, permit condition 3SW5.1) will be prepared separately and submitted to the Director of Environmental Management at least 60 days prior to the commencement of commissioning activities in relation to the pulp mill activity. Targets: LU1 3SW 11.1 1. Ensure that vehicle access routes are controlled and avoid environmentally sensitive areas and that use of heavy machinery within waterways and riparian areas is minimised. 2. Ensure that there is no diversion or pumping of water from the waterways for construction purposes, unless otherwise agreed by DTAE and DPIW. 3. Achieve the Urban Stormwater: Best Practice Environmental Management Guidelines performance Management Plan
Transcript
BBA-PLN-1000-1400-0002-D-00 Construction Stormwater Management Plan 1 of 9
BELL BAY PULP MILL
MANAGEMENT PLAN
Revision Date Revision Description Prepared Reviewed Approved
A0 8 November 2007 For submission to DEM IW JD JC
B0 17 December 2007 Revised and resubmitted to DTAE for
approval following DTAE verbal comments on revision A0
IW JD CF
C0 25 January 2008 Review of document as a stand-alone document following DPIW comments on
B0 GB JD CF
D0 31 January 2008 Revised following DTAE comments JRD JD CF
BBA reference number of this document: BBA-PLN-1000-1400-0002-D-00
Project phase(s): Construction x Commissioning Operations
Plan:
LU1 3SW4.1
Construction Stormwater Management Plan (CSMP)
Purpose: To manage construction stormwater at the mill site to ensure that construction activities do not produce stormwater runoff that may cause erosion and raise turbidity levels in receiving waters or transport contaminant spills into receiving waters, including surface water and groundwater.
Objectives: Objectives include, but are not limited to:
� Maintain or improve existing surface water quality during construction, consistent with the requirements of the Tasmanian State Policy on Water Quality Management 1997.
� Maintain the integrity and flow characteristics of streams that need to be temporarily disturbed for the construction of infrastructure.
� Maintain existing levels of flood protection and maintain the amenity of the riparian environment.
� Design stormwater drainage systems to ensure that water quality objectives are not exceeded in the event of a major spill of potentially contaminating material
� Contain accidental spills of contaminants.
Scope: This CSMP covers the management of construction stormwater at the mill site for the duration of construction activities in relation to the pulp mill activity. The plan is in accordance with the Pulp Mill Permit (3SW4.1 to 4.6) including the relevant sections of the DIIS sections 4.7 and 4.8 of Volume 2.
A Stormwater Management Design Plan (SMDP) for the construction of the permanent stormwater infrastructure (LU1 –Part 2-GeorgeTown-planning page 28 of 201, sequential page 41, permit condition 2.49) will be prepared separately and submitted to George Town Council prior to commencement of construction of this activity.
An Operational Stormwater Management Plan (OSMP) (LU1 – Part 3-Section 3, permit condition 3SW5.1) will be prepared separately and submitted to the Director of Environmental Management at least 60 days prior to the commencement of commissioning activities in relation to the pulp mill activity.
Targets:
LU1 3SW 11.1
1. Ensure that vehicle access routes are controlled and avoid environmentally sensitive areas and that use of heavy machinery within waterways and riparian areas is minimised.
2. Ensure that there is no diversion or pumping of water from the waterways for construction purposes, unless otherwise agreed by DTAE and DPIW.
3. Achieve the Urban Stormwater: Best Practice Environmental Management Guidelines performance
Management Plan
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LU1 3WW 20.1
LU1 3WW 20.2
objective of a suspended solid discharge concentration of not greater than 50 mg/L at the point of drainage discharge into streams (other than the Tamar estuary). In any discharge from pulp mill site (other than via the authorised discharge point 1 (Bass Strait outfall)) the concentration of a pollutant (parameter) must not exceed the limit specified in the following table:
Parameter Limit
Total Suspended Solids (TSS) 50 mg/l
BOD 15 mg/l
TPH 0.5 mg/l
Oil and grease 5 mg/l
4. Ensure that Protected Environmental Values of stream and water bodies are not compromised by
construction works.
5. Spills contained before significant impact on water quality or flora and fauna is caused.
Technical Documents: The following background studies, research documents and assessments have been used to identify the
key environmental aspects:
Reference Document Title
http://www.gunnspulpmill.com.au/iis/ Bell Bay Pulp Mill Draft IIS and Appendices
The following technical documents have been used to assist in identifying appropriate operational controls:
Availability Document Title
EPA Victoria Environment Protection Authority Publication 275 – Construction Techniques for Sediment Pollution Control
EPA Victoria Environment Protection Authority Publication 480 – Environmental Guidelines for Major Construction Sites
EPA NSW Landcom – Managing Urban Stormwater, Soils and Construction Volume 1 (Blue Book)
Victoria Stormwater Committee
Victoria Stormwater Committee – Urban Stormwater: Best Practice Environmental Management Guidelines
DPIW Waterways & Wetlands Works Manual 2003
Hobart Regional Councils Guidelines for Soil and Water Management 1999
Hobart Regional Councils The Soil and Water Management Code of Practice for Hobart Regional Councils 1999
Launceston City Council The Soil and Water Management Code of Practice for Launceston City Council 2000
Board of Environmental Management and Pollution Control
Environmental Management Goals for Tasmanian Surface Waters – Tamar Estuary and North Esk Catchments December 2005
Key Issues: Any construction activity involving earthworks and where vegetation cover has been removed will potentially have an increased risk of erosion and sediment runoff. Erosion and consequent sedimentation can have detrimental effects on water quality, habitat inundation, land degradation and can significantly affect the efficiency and integrity of construction.
The technical documents and the environmental risk assessment have identified the following key environmental issues:
� Protection of existing water quality.
� Prevention or control of erosion by surface water run off.
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Environmental risks include:
� Erosion and loss of topsoil and subsoil material and sediment discharge into waterways
� Reduction in the potential for rehabilitation success
� Threat to construction activity efficiency
� Infrastructure exposure
� Stability issues associated with earthworks and vegetation removal
� Increased cost of rehabilitation activities
� Dust emissions from construction activities
MANAGEMENT MEASURES Component Integrated Construction Stormwater Management System
Measures
Permit Conditions LU1 3SW4.3 a
LU1 3SW4.2
LU1 3SW4.3 b
Construction Stormwater Management Strategy The stormwater management strategy will involve total containment of runoff from construction areas in a system of diversion drains, sediment fences and sedimentation ponds. Sedimentation ponds will be designed to hold either a 1 in 20 year design storm (in the case of long term temporary sedimentation ponds with an expected life of over 1 year) or a 1 in 2 year design storm (in the case of short term temporary sedimentation ponds with an expected life of up to 1 year). Erosion and sediment controls shall be constructed as soon as possible after the start of vegetation clearing and before the bulk earthworks associated with the mill site. DIIS Volume 2 sections 4.7 and 4.8 The Construction Stormwater Management Plan details the management measures that will be implemented to address the following requirements of sections 4.7 and 4.8 of volume 2 of the DIIS as follows: 4.7 Water Quality and Hydrology 4.7.1 Groundwater Where earthworks activities intercept groundwater aquifers any water flows will be diverted by way of temporary drains to sedimentation ponds. Interception of groundwater will be avoided in the design of the earthworks platforms as far as is practical. Any contaminants, such as those generated as a result of a chemical or hydro-carbon spill will be contained through the spill response procedure and within the temporary drainage structures designed to contain water runoff from site. The spill response and clean up protocols are detailed in BBA-OCO-1000-1400-0016-B-02 Spill Management 4.7.2 Drainage and Catchments The mill site is located on the crest of a small ridgeline and will have minimal impact on the drainage and water catchments. The access road and chip conveyor cross Williams Creek and erosion and sedimentation controls will be implemented as detailed in this plan to minimise environmental and water quality effects. This plan addresses the temporary drainage works that will be constructed for the mill site access road across Williams Creek. These temporary works will be used for the vegetation clearing and the initial stage of the bulk earthworks. The design of the permanent drainage works will be incorporated in the Stormwater Management Design Plan. 4.7.3 Management Measures This Construction Stormwater Management Plan details the management measures that will be put in place to minimise the impact of the construction on surface and groundwater systems. 4.8 Estuarine Ecology
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LU1 3SW3.1 a to d
3SW4.3 d
This Construction Stormwater Management Plan details the management measures to be put in place to prevent erosion and sediment discharge into the Tamar River and to prevent and contain accidental spills during construction (vegetation clearing and earthworks) Sedimentation Pond Design The design and operation of these ponds will be undertaken in accordance with Sedimentation Pond Design Procedure BBA-MPR-1000-1400-0002. The sedimentation ponds will meet the following requirements: (a) discharge from ponds will occur via a stable spillway that is not subject to erosion; (b) all pond walls will be stable and constructed in such a manner as to prevent erosion; (c) ponds will be regularly cleaned out to ensure that the pond design capacity is maintained; and (d) Sediment removed from the ponds will be deposited in such a manner and location as to ensure that sediment will not be transported off the site by surface run-off. Re-use of stormwater and groundwater The water trapped in these ponds will be reused for dust suppression, compaction or watering of rehabilitation areas or mulched areas with water trucks and sprinkler systems. Once all diversion drains and sedimentation ponds are in place no surface waters will outfall into the existing streams on the mill site except as follows: � A storm event exceeds the design storm for the sediment ponds on site. Sediment ponds are
designed and built with stable outlets � During periods of regular rain when sediment ponds are full or filling, and there is no need for re-use
of the water for dust suppression, it will be necessary to flocculate the water in the sediment ponds to facilitate settling out of suspended colloids, and then, once it meets the relevant water quality requirements, pump the water either to the nearest receiving water course, or to a well vegetated area within the boundary of the construction site. This reduces the risk of a subsequent rain event causing the sediment ponds to overflow with dirty water. This will be a last resort, with re-use of water being the preferred option under normal conditions. No intentional discharge will be allowed without a Site Environmental Officer first testing the water to check if it meets the water quality requirements and issuing an internal Permit to Discharge Form (BBA-FRM-1000-1400-0001)
In both circumstances the water quality of the discharged water will be monitored as described below in the Monitoring Program Where the water table is encountered during construction activity, a groundwater specialist will inspect the affected area and report to BBA who will implement appropriate management measures. These measures may involve diversion of groundwater flows to the surface water drainage system. The discharge point for overflows from the stormwater sedimentation ponds are detailed on the Site Environmental Plans (SEP’s). Management Measures Management measures to achieve environmental outcomes are described in the project’s Construction Environmental Management Plan (CEMP) Operational Controls: Operational Controls BBA-OCO-1000-1400-0001-B-02 Erosion and Sediment Control, BBA-OCO-1000-1400-0002-B-02 Soil and Water Management, and BBA-OCO-1000-1400-0016-B-02 Spill Management. These documents have been submitted separately for approval as part of the CEMP, and copies are attached to this Plan. Site Environmental Plans For the mill site, the site specific management measures are described in its Site Environmental Plan: BBA-SEP-1670-1400-0003-C-00 Pulp mill site and access road – plan BBA-SEP-1000-1400-0004-B-01 Pulp mill site and access road – table.
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These documents have been submitted separately for approval as part of the CEMP, and copies are attached to this Plan. For all other construction areas, Site Environmental Plans will similarly be progressively prepared and submitted for approval prior to construction commencing.
Component Monitoring Program
Measures
Permit Conditions LU1 3SW4.2 LU1 3SW4.3 c LU1 3WW20.1,
20.2
Monitoring is described in the project’s Construction Monitoring Plan: BBA-PLA-1000-1400-001H Construction monitoring plan. This plan forms part of the CEMP and has been submitted separately for approval. Extracts of the Monitoring Plan relevant to stormwater at the mill site are provided below. Surface water – Objectives The primary objectives of the monitoring program are to measure any changes in water quality in surface waters in the areas surrounding the pulp mill and associated infrastructure that may result from BBA construction activities and enable BBA to take corrective action to minimise and mitigate those impacts. Surface water – Background This project involves land based construction activities associated with the mill, landfill, reservoir, and pipelines. In principal the ANZECC approach will be used, where applicable and as a guide, to assess typical background levels (reference levels) of various parameters that may be released by the disturbance of soil/sediments during construction. Control and impact sites shall be monitored prior and during construction activities and the 80th and 20th percentile calculated for the baseline data and trigger values determined, which if exceeded involves the implementation of additional mitigation controls. Review of the various construction activites and their locations identify construction activities at the mill are of note because surface water runoff, if not properly managed, has the potential to impact on water quality. Gunns monitoring data associated with surface water streams on the mill and landfill sites as well as extensive data provided by Tasmanian Department of Primary Industries and Water will provide a robust data set enabling the determination of trigger values for the receiving environments. The receiving environments and current water monitoring locations are :- Stream discharging into Dirty Bay (SW9,10,11) Confluence of Williams Creek and the Tamar Estuary (SW1,2,3,4,5,6,7,8) Refer Figure 1 for current water quality monitoring locations. Surface Water – Monitoring Baseline monitoring: The first baseline pre – construction monitoring event of major streams on the pulp mill and landfill sites occurred September 2006 and monthly monitoring commenced February 2007 with a sampling strategy designed to assess water quality soon after rain events and at low flows. If there are no rain events then samples are taken during the last week of the month giving every opportunity to catch a rain event. The year 2007 was drier than usual. This monthly monitoring strategy shall continue throughout the next 2.5 years construction phase (subject to annual reviews and changes by regulatory authorities) before commencement of operations. There are six surface water sampling locations associated with the landfill site and another six with the pulp mill site – Refer Figure 1. Comprising upstream control sites (SW1,7,9,10,12) and downstream impact sites (SW2,3,4,5,6,8,11). At each sampling event stream flows are noted, the more significant streams have minimalist flow monitoring structures such as weirs etc allowing the estimation of volumetric surface flows. At a location on a water-course downstream of the landfill (SW4) and at another on a stream intercepted by the mill footprint (SW11) an automatic water sampler and water depth monitoring instrument, installed January 2008, will trigger sampling to assess mass pollutant loads from these areas. The pollutant loads from the mill and landfill sites will be associated with washed insoluble and soluble fugitive emissions from firstly construction then mill/landfill activities. These streams will not receive any runoff waters from the mill/landfill sites except during infrequent significant rain events during the construction phase only. Essentially these devices will assess first flush mass emission data (fugitive dust deposition) during major earthworks associated with construction then baseline pre-operational data over about 2 years before commencement of operations. Baseline monitoring methodology: Those analytes considered appropriate to baseline pre construction monitoring of surface streams
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associated with the mill, landfill and reservoir are:- - pH - conductivity - turbidity - dissolved oxygen - total alkalinity - oil and grease - total petroleum hydrocarbons - total dissolved solids - total suspended solids
Water samples are collected monthly (commenced February 20071) from up to 12 sites over the mill and landfill areas and have been analysed for all the above parameters with the exception of total petroleum hydrocarbons which was analysed September 2006, February and August 2007. As of January 2008 total petroleum hydrocarbons are included in the monthly analytical suite. Construction monitoring: The construction water quality monitoring is designed to assess quality of stormwater runoff from construction areas associated with the entire project. The pre-construction baseline monitoring detailed for land activities continues, at the same frequency and for the same parameters, during construction monitoring. Construction monitoring methodology: During construction outfalls from the sedimentation ponds/traps, and upstream and downstream of creek crossings shall be monitored daily when the ponds are outfalling, or when there is a flow in the creek for:-
If turbidity when correlated to 50 mg/L suspended solids equals or exceeds 50 mg/L a water sample shall be collected and analysed over night to validate or otherwise the results in accordance with the Permit.
Also during construction, in accordance with storm water emission limits, daily water samples shall be collected from sedimentation ponds at the mill site and analysed for:-
- total suspended solids - BOD - TPH - oil and grease
The rules for unintentional decanting or intentional pumping from these ponds (for significant rain events as described above) to the offsite environment are:
- Suspended solid levels < 50 mg/L3 or ; - Turbidity of outfall is less than the turbidity of surface water flows in the
receiving water course upstream of the construction zone, where this is not the result of poor stormwater management practices upstream.
In direct accordance with LU1/3WW20.1 daily water samples during construction shall be collected at the sample locations depicted in Figure 1 Surface Water Sample Sites and analysed for:
- pH - salinity/conductivity - turbidity - dissolved oxygen - temperature - Total petroleum hydrocarbons.
Quality Control: Water samples during the construction phase will be sampled, monitored and managed with reference to
1One extensive sampling event (in situ and chemical testing) occurred September 2006.
2 Where there is evidence or possibility of a hydrocarbon spill. 3 Testing of various soil types from the construction sites will allow the establishment of an approximate correlation between turbidity and suspended solids.
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the AS/NZS 5667.1:1998 Water quality – Sampling Part 1: Guidance on the design of sampling programs, sampling techniques and the preservation and handling of samples.
In situ monitoring instruments shall be calibrated before and immediately after the monitoring run and calibration records maintained Samples for laboratory analyses shall be shipped with appropriate chain of custody documentation. All analyses shall be performed by a NATA accredited laboratory. A Consultant Environmental Chemist shall audit the laboratory and field monitoring protocols to ensure compliance with best practice environmental monitoring methods.
The water quality monitoring will be recorded on a works program log sheet. Photographic records will also be taken which show easily recognizable monitoring points and provide indication of turbidity levels.
Before any controlled discharge, that is intentional pumping or draining of water from site, a Permit to Discharge (BBA-FRM-1000-1400-0001) must be completed and signed by a Site Environmental Officer, who must ensure that the quality of the water to be discharged meets the above requirements and that there is no other possible use for the water.
Surface Water: Responsibilities and Reporting
Activity Responsibility Timing To
Baseline Monitoring pre and during construction
activities
Gunns Environmental Manager
Monthly BBA Environmental Manager
Director of Environmental Management.
Monitoring the water quality of stormwater flows from various construction sites.
BBA Environmental Manager
At commencement of construction.
Appropriate BBA Construction Supervisors.
Controlled discharge. BBA Site Environmental Officer
Appropriate BBA Construction Supervisors. Director Environmental
Management. Management
A summary report of all monitoring and non conformances, if any.
BBA Environmental Manager
90 days after completion of construction.
Gunns Environmental Manager.
Director Environmental Management. Management.
Groundwater - Objectives The primary objectives of the monitoring program are to assess potential impacts on ground water resulting from BBA construction activities and enable BBA to take corrective action to minimise the potential for and mitigate the effects of any hydrocarbon spills on the ground water. Groundwater - Background
Baseline Monitoring:
During 3rd quarter of 2006 baseline monitoring of thirteen bores for an extensive range of chemical parameters commenced, an additional 10 bores have been installed during the 4th quarter of 2007. The bores are located down gradient of the mill and landfill footprints and there are some bores located well away from the impact zones which will be control bores for construction and life of the project.
The Initial Hydrogeological Assessment Report prepared by Environmental, Engineering and Groundwater Geologists – William C. Cromer Pty Ltd in association with Pitt and Sherry has been submitted and approved by the Director of Environmental Management.
During Construction Monitoring:
The program associated with the construction is firstly a risk based assessment of areas where the
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water table may intercept the construction activity. A specialist will inspect the entire construction foot print assess groundwater levels in problem areas and report to the BBA who will implement appropriate management measures. Secondly implementation of monthly monitoring of existing 13 groundwater bores immediately off the mill footprint and 10 bores associated with the landfill during the construction phase involving establishment of major foundations. Refer to attached Figure 2 for location of bores.
Thirdly a significant hydrocarbon spill at any construction site may trigger the installation of additional bores to assess impact on the groundwater in the immediate area and/or more frequent hydrocarbon monitoring of adjacent bores. Groundwater - Monitoring methodology Baseline Monitoring: The baseline monitoring covers parameters applicable to construction activities which are:-
- standing water level - pH - conductivity - turbidity - redox potential - total petroleum hydrocarbons as well as oil and grease;
as well as parameters associated with potential emissions from the operating mill. The monitoring frequency varies pending location of the bore and risk. During Construction Monitoring: Monthly monitoring of all bores within the active construction footprint as well as down gradient of it will be monitored/sampled for:-
- standing water level - pH - conductivity - turbidity - redox potential - total petroleum hydrocarbons as well as oil and grease
Quality Control: Low flow pumping technique is used for sampling with each bore having dedicated sample tubing which eliminates the risk of cross contamination. The flow is discharged via a flow cell with a field water quality instrument monitoring all parameters listed except standing water level and petroleum hydrocarbons. Once stabilised the instrument readings are recorded. The field water quality instrument is calibrated at the beginning and end of each day. Samples for hydrocarbon analyses are taken in laboratory supplied containers, packed in eskys with chiller blocks and shipped with appropriate chain of custody documentation to a NATA accredited laboratory.
Groundwater – Responsibilities and Reporting
Activity Responsibility Timing To
Initial Hydrological Assessment and Conceptual Model
Gunns Environmental Manager
Before construction. It has been submitted.
Director – Environmental Management
Groundwater Monitoring as required.
BBA Environmental Manager
As required.
Gunns Environmental Manager
Director – Environmental Management
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Component Major commitments and implementation timetable for key aspects of the plan
Activity Responsibility Timing
Surface water monitoring to be carried out at specified locations. BBA Environmental Manager
Daily.
Groundwater monitoring to be carried out at specified locations. BBA Environmental Manager
Monthly.
Sediment basins and drains to be installed in accordance with BBA-SEP-1670-1400-0003-C-00 Pulp mill site and access road.
BBA Environmental Manager
As soon as practicable after site clearing.
Storm water to be re-used on site in preference to direct discharge off site.
BBA Construction Supervisor
Ongoing.
Measures
Permit Conditions LU1 3SW4.3 f
Groundwater specialist to inspect area where groundwater is encountered and appropriate measures to be implemented.
BBA Environmental Manager
When groundwater is encountered
Component Evaluating Performance & Reporting
Measures
Permit Conditions LU1 3SW4.3 h
The basis for evaluating performance is comprised of:
• The Construction Surface water and Groundwater monitoring plan described above,
• A regular inspection program using environmental checklists
• Reporting
• Assessment of monitoring results
• Corrective action and recording of corrective actions.
• Modification of procedures, management measures and methods, as necessary, following identification of any problems or possible improvements.
Refer to: CEMP Appendix K – Environmental Reporting Program. BBA-CKL-1000-1400-001A Erosion and Sediment Control Checklist BBA-CKL-1000-1400-002A Soil and Water Management Checklist BBA-CKL-1000-1400-016A Spill Management Checklist
Figures:
• Figure 1: Surface Water Sites – Mill
• Figure 2: Ground Water Sites - Mill
Appendices:
• BBA-OCO-1000-1400-0001 Erosion and Sediment Control,
• BBA-OCO-1000-1400-0002 Soil and Water Management, and
• BBA-OCO-1000-1400-0016 Spill Management.
• BBA-CKL-1000-1400-001A Erosion and Sediment Control Checklist
• BBA-CKL-1000-1400-002A Soil and Water Management Checklist
