Carbon Fibre Management at Aircraft Crash Sites

Prepared for

Department of DefenceDepartment of DefenceDepartment of DefenceDepartment of Defence

Environmental Environmental Environmental Environmental Manager’s GuideManager’s GuideManager’s GuideManager’s Guide

Carbon Fibre Management at Aircraft Crash SitesCarbon Fibre Management at Aircraft Crash SitesCarbon Fibre Management at Aircraft Crash SitesCarbon Fibre Management at Aircraft Crash Sites

Final Final Final Final

SeptemberSeptemberSeptemberSeptember 2002002002005555 Reference:Reference:Reference:Reference: 327109327109327109327109: 00|01: 00|01: 00|01: 00|01

September 2005 Ref: 327109: 00|01 i Final

Department of Defence Environmental Manager’s Guide Carbon Fibre Management at Aircraft Crash Sites

CH2M HILL Australia Pty Ltd Level 7, 9 Help Street CHATSWOOD NSW 2067 Phone 02 9950 0200 Fax 02 9950 0600

This document may only be used for the purpose for which it was commissioned; and in accordance with the Terms of Engagement for the commission. This document should not be used or copied without written authorisation from CH2M HILL Australia Pty Ltd.

September 2005 Ref: 327109: 00|01 iii Final


Revision # Date Description of Change

0 19/04/05 Draft Structure

1 25/04/05 Draft Report

2 20/06/05 Internal Review

A 22/06/05 Client Review

B 15/09/05 Final

September 2005 Ref: 327109: 00|01 v Final


Executive Summary

Background

This Environmental Manager’s Guide for Carbon Fibre Management at Aircraft Crash Sites has been developed to assist the Department of Defence (DoD) in the implementation of current best-practice to minimise the environmental impacts arising from this issue. Development of an Environmental Manager’s Guide for this issue has resulted from an assessment of environmental aspects and impacts undertaken within the framework of the DoD wide Environmental Management System (EMS) across Australian DoD activities. This guide presents best management practice information based on Australian and international (predominantly United States) experiences on the management of carbon fibre at aircraft crash sites. The information obtained has been assisted by observations from several locations in the vicinity of Delamere Range Facility and RAAF Base Tindal, NT, where management of carbon fibre from aircraft crashes has been undertaken. The principles of best-management presented in this guide that are based on literature, practical remediation experiences and observations of the management of carbon fibre at Australian DoD facilities is generally applicable at other locations in Australia where DoD has responsibility for the management of carbon fibre caused by aircraft crashes.

Objectives

The objectives of this Environmental Manager’s Guide are to:

•••• Provide a best practice guideline for the management of carbon fibre at aircraft crash

sites to minimise environmental impacts;

•••• Place the management of this issue within the context of DoD’s legal obligations;

•••• Assess the potential pollutants of concern and their release potential, fate and

transport within the environment;

•••• Provide guidance on the implementation of this guide including environmental roles

and responsibilities within DoD, training requirements and record keeping

approaches; and

•••• Incorporate experiences and observations in the management of carbon fibre from a

case study assessment undertaken in the vicinity of Delamere Range Facility, NT and

RAAF Base Tindal, NT.

Content of this Environmental Manager’s Guide

This guide contains information on:

•••• Dealing with historical or legacy issues relating to aircraft crash sites;

•••• Preparing a site to deal with aircraft crash events;

vi Ref: 327109: 00|01 September 2005 Final

Department of Defence Environmental Manager’s Guide

Carbon Fibre Management at Aircraft Crash Sites

•••• Appendices containing detailed and specific management practices that can be

applied to minimise the impacts to environmental aspects arising from carbon fibre

pollution caused by aircraft crashes, including an identification of management

requirements during and after the event;

•••• Information on responsibilities for personnel involved in the implementation of the

guide;

•••• Training, monitoring, reporting and corrective action requirements;

•••• A process for continual improvement in the environmental management of such

events; and

•••• A case study of the management of carbon fibre at aircraft crash sites at Australian

DoD facilities.

First Response The SEA/REO should be notified as soon as an incident occurs. The SEA/REO can:

•••• Assist in providing advice to rescue operations of the fastest and most appropriate

route to a crash site to avoid unnecessary delay and collateral environmental damage;

•••• Advise personnel to approach the crash site from an up-wind direction;

•••• Advise potential affected down-wind receptors - mobile receptors should be removed

from downwind affected areas;

•••• Confirm that fixant spray is available at the crash site to be applied to carbon fibre

components and contaminated soils to minimise further release or spread of carbon

fibres;

•••• Confirm that the use of aqueous film forming foam (AFFF) is to be minimised and

ensure that watercourses are protected from AFFF and run-off laden with carbon

fibre and other crash pollutants;

•••• Minimize walking, working, or moving materials to reduce airborne particulates,

fibres and dust;

•••• Remove wreckage in a manner that minimises adverse environmental impacts; and

•••• Confirm that sealing materials such as shipping containers, plastic wrap and duct

tape are available to seal cooled components during recovery.

Communication and Management Principles In responding to an aircraft crash, the SEA/REO should consider the following and advise the recovery team accordingly:

•••• Get advice from ENVHO regarding the actual hazardous materials that may be

encountered on the specific aircraft involved in the incident. Note that for preference,

specific information should be obtained from the aircraft’s base or SAFETYMAN Vol

3, Part 2 - Aircraft Accident OHS Information. However, this Environmental

Manager’s Guide provides some indication of the likely materials to be encountered;

September 2005 Ref: 327109: 00|01 vii Final


•••• With regards to advanced composite material (ACM) contamination including carbon

fibre, SEA/REO’s have the responsibility to:

•••• Coordinate remediation and restore the crash site to original environmental

condition or better.

When removing wreckage and undertaking site restoration the following should be considered:

•••• The use of a specialised contractor will most likely be required. Clean-up contractors

should be selected based on appropriate OH&S standards and experience with the

handling of hazardous fibres and/or materials;

• Clean up and subsequent remediation is to occur on all properties affected by crash debris. Clean-up should occur in consultation with the property owner’s requirements but should include as a minimum:

o Removal of all aircraft debris from the area. These materials are to be placed

in a suitably confined area for transportation (eg plastic lined shipping container) to ensure risks of exposure to humans is minimised;

o Removal of all hazardous materials; and o Validation sampling of affected areas and provision of a validation report.

• Materials should be: o Treated as per the manufacturers Materials Safety Data Sheet (MSDS); o Sufficiently cool to touch by hand; o Wrapped in thick plastic wrap with edges sealed with duct tape; o Placed in a hard stand area, covered where possible; o Restricted in access to authorised personnel only, fitted with appropriate PPE; o Removed with the use of HEPA vacuum equipment, if available; and o Removed by excavating the minimum amount of soil (nominally 50mm of top

soil) from the crash site and surrounding effected area.

•••• Clean-up works should be undertaken as soon as access is possible;

•••• Once the bulk of crash debris has been removed, validation sampling should be

undertaken by a qualified environmental consultant. A detailed soil sampling,

validation and remediation plan must be developed specifically for the locations

affected; and

•••• Following visual inspection and the results of validation sampling, the crash site area

should be restored with locally compatible soil layers/topsoil. Restoration should

extend to any temporary work areas or access tracks in accordance with site or

landowner requirements.

SEA/REO’s should keep themselves abreast of development in carbon fibre crash site

management whenever possible. Information exchanges with other military units such as

the Directorate of Air Force Safety (DAFS), Directorate of Flying Safety- ADF (DFS-ADF) or

overseas military units such as those in the United States are a useful source for identifying

any process improvements in clean-up procedures.

September 2005 Ref: 327109: 00|01 1 Final


Table of Contents

1 What are Environmental Manager’s Guides?..........................................................................1

1.1 Guide Development...............................................................................................................1

1.2 Structure of this guide ...........................................................................................................1

1.2.1 Environmental Aspects and Impacts .....................................................................................2 1.2.2 Environmental Management Sub-plans ................................................................................2 1.2.3 Risk ............................................................................................................................2

1.3 Content of Environmental Manager’s guide......................................................................7

2 Aircraft Crash Site Management ...............................................................................................9

2.1 Overview.................................................................................................................................9

2.2 A note on Occupational Health and Safety........................................................................9

2.3 Pollutants of Potential Concern .........................................................................................11

2.3.1 Advanced Composite Materials (ACM) ..............................................................................16

2.4 Release Potential ..................................................................................................................17

2.5 Environmental and Human Health...................................................................................19

3 Legislative Context .....................................................................................................................21

3.1 DoD’s environmental obligations......................................................................................21

3.2 Environmental Legislation and Guidelines......................................................................21

3.2.1 Legislation ..........................................................................................................................21 3.2.2 Commonwealth Environmental Protection and Bio-diversity Conservation Act, 199922 3.2.3 Statutory Legislation, Regulations, Guidelines, Licences, Permits, Consents and

Approvals ..........................................................................................................................23 3.2.4 Aircraft Crash Site Management specific approvals licences, permits, consents...........25

4 Life-Cycle Approach to Aircraft Crash Site Management ..................................................27

4.1 Dealing with Legacy issues ................................................................................................27

4.2 Setting up in preparation for management of aircraft crashes......................................28

4.2.1 Minimum requirements .........................................................................................................29

4.3 Operating requirements of an Aircraft Crash Site Management ..................................29

4.3.1 Notification ..........................................................................................................................30 4.3.2 Initial response ........................................................................................................................30 4.3.3 Recovery ..........................................................................................................................32 4.3.4 Environmental DoD Method Statements.............................................................................34 4.3.5 Quality Assurance of inputs and outputs............................................................................35

4.4 Closure of an impacted Aircraft Crash Site......................................................................35

5 Implementation of guide...........................................................................................................36

5.1 Management Organisation Chart ......................................................................................36

2 Ref: 327109: 00|01 September 2005 Final



5.2 Responsibilities and Authorities of Project Personnel....................................................36

5.2.1 Base Commander ....................................................................................................................36 5.2.2 Senior Environmental Advisor .............................................................................................37 5.2.3 Regional Environmental Officer ...........................................................................................37 5.2.4 Contractor ..........................................................................................................................37

5.3 Environmental training and competence .........................................................................38

5.3.1 Qualifications and competence .............................................................................................38 5.3.2 Training programs ..................................................................................................................38

5.4 Communication and complaints management................................................................39

5.4.1 Internal communication.........................................................................................................39 5.4.2 Inquiries and complaints handling procedure ...................................................................39

5.5 Environmental records and reporting ..............................................................................39

6 Continual Improvement............................................................................................................41

6.1 Environmental Objectives, Measures and Targets for Continual Improvement ........42

6.2 Environmental inspections and audits .............................................................................42

6.3 Non-conformances...............................................................................................................43

6.4 Corrective procedures .........................................................................................................43

6.5 Process improvements.........................................................................................................43

7 References ....................................................................................................................................45

List of Figures

Figure 1.1 Context of Environmental Manager’s Guides within DoD

Figure 1.2 Relationship of Environmental Manager’s Guides to DoD EMS and Aspects and Impacts

Figure 1.3 How to Implement this guide

Figure 2.1 Location and quantum of hazardous materials on typical military jet (F/A-18)

Figure 2.2 Scanning Electron microscopy image of carbon fibre in crash site fragments - before burning

Figure 2.3 Scanning Electron microscopy image of carbon fibre in crash site fragments - after simulated bushfire (burning at 750oC for 10 mins)

Figure 2.4 Scanning Electron microscopy image of carbon fibre in crash site fragments - after fire showing potential cleaving of fibres to within respirable size

Figure 6.1 Continual Improvement mechanism for management of guide issues

Figure F.7.1 Example of Carbon Fibre contamination at Delamere

Figure F.7.2 Carbon Fibre Containment Materials



List of Tables

Table 2.1 Indicative PPE required for interaction with ACM (always seek specialist advice)

Table 2.2 Hazardous materials on board a typical military fighter plane (F/A–18 example)

Table 3.1 Summarised DoD obligations under the EPBC Act applicable to the management of carbon fibre at aircraft crash sites

Table 3.2 Topics governed by Australian legislation that have environmental requirements

Table 3.3 Licences, permits, consents and approvals that may be relevant to Aircraft Crash Site Management.

List of Appendices

Appendix A Environmental Management Sub-plans for Operation of Carbon Fibre Management of aircraft crash sites

A1 Waste Management

A2 Air Quality

A3 Noise and Vibration

A4 Erosion, sedimentation and run-off

A5 Chemical Storage and Use

A6 Surface Water Quality

A7 Soil and Groundwater Quality

A8 Flora and Fauna

Appendix B Environmental Actions Table

Appendix C Site Containment Characteristics for ACM disposal locations

Appendix D Environmental Inspection Checklist for Aircraft Crash Site Management

Appendix E Case Study of Environmental Management of Aircraft Crash Site Management at DoD facility




Abbreviations

ACM Advanced Composite Materials (not Asbestos Containing Materials)

AFFF Aqueous film-forming foam

CF Carbon Fibre

DoD DoD

EDMS Environmental DoD Method Statements

EM Environmental Manager

EMR Environmental Management Representative

EMS Environmental Management System

EMSP Environmental Management Sub-Plan

GPS Global Positioning System

guide Environmental Manager’s Guide to the management of an issue

HEPA High Efficiency Particulate Air (HEPA filters are designed to remove 99.97% of all airborne pollutants 0.3 microns or larger)

JSA Job Safety Analysis

JSEA Job Safety Environmental Analyses

NCR Non Conformance Report

OH&S Occupational Health and Safety

PPE Personal Protective Equipment

REF Review of Environmental Factors

REO Regional Environmental Officer

SEA Senior Environmental Advisor



1 What are Environmental Manager’s Guides?

Environmental Manager’s Guides are documents that outline major steps necessary

for the prevention and management of pollution issues on any given site arising from

specific activities and practices across Australian Department of Defence (DoD) sites.

The ultimate objective of this guide is to prevent pollution on DoD sites arising from aircraft crashes thereby avoiding or minimising the environmental impacts and potential cost, human and environmental implications of pollution events and any required remedial action. This guide provides information for use by SEA’s and REO’s to assist them to make informed decisions regarding the management of carbon fibres resulting from aircraft crashes.

1.1 Guide Development

Development of this Environmental Manager’s Guide has resulted from an

assessment of environmental aspects and impacts undertaken within the framework

of the DoD wide Environmental Management System (EMS) across Australian DoD

activities. This assessment has identified Aircraft Crash Site Management as having

key environmental impact or polluting potential.

As a result, this guide provides advice to those responsible for management of such

incidents including but not limited to Base Commanders, DoD environmental

officers: Senior Environmental Advisors (SEA’s), Regional Environmental Officers

(REOs) and Rangers on the environmental management of carbon fibre at aircraft

crash sites.

The principles of best-management presented in this guide that are based on

literature, practical remediation experiences and observations of the management of

carbon fibre at Australian DoD facilities is generally applicable at other locations in

Australia where DoD has responsibility for the management of carbon fibre caused

by aircraft crashes. It is acknowledged however, that specific details relating to

settings, conditions and operations vary from site to site and the effective

implementation of this guide is dependent on interpretation of provided information

by the relevant SEA/REO at the incident site.

1.2 Structure of this guide

This guide is structured to provide management advice that addresses key

environmental aspect and provides some guidance as to those environmental aspects

that may be most affected by Aircraft Crashes, and specific guidance in relation to

Advanced Composite Material (ACM) such as carbon fibre.

However, the practical on-site management of carbon fibre at aircraft crash sites on

each site requires a site risk based assessment of the aspects that may be affected by

incident so that the order of implementation can be prioritised to make best use of

available time and resources.




This guide is structured in accordance with:

• AS/NZS ISO 14001:1996 Environmental Management Systems (EMS) –

Specification with guidance for use;

• DoD’s Environmental policies regarding Environmental Stewardship and

Environmental Management Systems;

• Principles of ecological sustainable development (ESD); and

• Accepted best practice management procedures.

Understanding the structure of environmental management within DoD will assist in

understanding the context of the guides and aid their effective implementation:

1. The Context of Environmental Manager’s Guides within the DoD (refer

Figure 1.1).

2. The relationship of guides to the DoD EMS and Aspects and Impacts (refer

Figure 1.2).

3. How the guide is used to affect change in the field (refer Figure 1.3).

1.2.1 Environmental Aspects and Impacts

The Base Environmental Management Plan (EMP) or EMS is the key guidance

document for the management of pollution issues on Base. Environmental Manager’s

Guides provide a more detailed plan for managing specific pollution issues as

identified in the aspects and impacts register across DoD facilities Australia wide and

as reflected in the Base EMS. It is intended that these plans integrate with other Base

plans relating to Design, Procurement, Quality Assurance and Occupational Health

and Safety. Where an EMP or EMS is not in effect, this Environmental Manager’s

Guide should take precedence for the purpose of environmental protection.

1.2.2 Environmental Management Sub-plans

Sub-plans have been prepared as part of this guide specifically for the management of

environmental aspects associated with Aircraft Crash Site Management.

Sub-plans are presented in Appendix A. The tabulated format is designed for easy

use by site personnel and lists in summary the environmental aspects and impacts for

Aircraft Crash Site Management, defines objectives and targets, obligations,

management programs, monitoring and reporting requirements and performance

indicators.

1.2.3 Risk

The sub-plan action tables provided in Appendix A of this Guide can be assigned a

risk assessment. Each element can be assessed for consequence and likelihood of risk

within a matrix to provide a scored level of risk on which implementation priorities



can be based. This Guide is designed for a broad range of sites and therefore can not

include a meaningful risk assessment at a site specific level. Site based risk

assessments are recommended to be undertaken by SEA/REO’s for sites within their

control.

Key areas of risk, which can be generally applied to carbon fibre management at

aircraft crash sites are so follows:

• Carbon fibres, once burned and/or mechanically damaged in crash

operations and poorly executed recovery operations are degraded to

respirable size which can have adverse health and environmental effects;

• Full and complete information should be made available to the SEA/REO

about the extent to which the aircraft carbon fibre has been affected and

spread. Poor or incomplete information may result in a partial assessment of

the environmental effects and result in inappropriate handling and

management resulting in possible longer term liability or cost; and

• Carbon fibres once burned or mechanically damaged become small and light.

This makes their spread very easy, particularly in areas that continue to

receive mechanical impacts (bombing ranges, arable land, and construction

sites). Full and complete collection and containment is required and disposal

at an appropriately licensed landfill or site location where placement of the

material can be monitored and controlled to ensure materials do not become

re-exposed to the environment.




Figure 1.1 Context of Environmental Manager’s Guides within DoD

Minister for Defence

Owner Support Executives

- Capability Development Group - Finance - Defence Science & Technology Organisation

Output Executives

- Vice Chief of the Defence Force - Navy - Army - Air Force - Strategy

- Intelligence and Security

Enabling Executives

Defence MaterielOrganisation

Corporate Services

InfrastructureGroup

InfrastructureDivision

Information Systems - IT Market Testing - Information Services - Applications

Development

National OperationsDivision

Infrastructure AssetDevelopment

Environment, Heritageand Risk

Strategic Planning andEstate Development

Regions and Bases

- General Services Delivery

- Defence Legal Service - Personnel Services Delivery - Business Services

Directorate of EnvironmentalManagement Systems

Directorate of EnvironmentalStewardship

Defence EnvironmentalManagement System

Base EnvironmentalManagement Plan or

Environmental ManagementSystem

Environmental Manager'sGuides

Defence Regional

ManagerOther Regions

SeniorEnvironmental

Advisor

GarrisonSupportServices

ComprehensiveMaintenanceContractor

ManagingContractor

RegionalEnvironmental

Officer(s)

- Planning - Tech. Services

Pathway of directrelationship to

project

Pathway ofassociated

relationship to

project

Unrelated (in-direct)

pathways of otherDefence activities

Legend

Pollution Prevention

Base Trainingactivities and

exercises

AnticipatedRelationship

Directorates of

- Sustainability Strategies - Heritage Management



Figure 1.2 Relationship of Environmental Manager’s Guides to DoD EMS and Aspects and Impacts

Department of DefenceEnvironment Heritage and Risk Branch

Environmental Management System

Environmental Policy

Department of Defence

OH&S Tiger Team

Occupational Health and Safety System

Pollution Topic

RelatedEnvironmental

Manager's Guides

Base EMS

Base EMPs

(to be phased out with EMS)

Site Environmental Management of Issues

Task/Activity Specific Job Safety Analysis

Site Safety Plan


Quality Systems


Procurement Systems

Task/Activity Specific Environmental

Management Actions

Task/Activity Specific Job SafetyEnvironmental Analysis

Task/Activity performed with appropriate

OH&S and Environmental Management

Controls

Aspects and Impacts Register for Site/Base

Aspects and Impacts Register across Defence

Sites

RiskAssessment and

identification of

activities with highpollution

risk




Figure 1.3 How to Implement this guide

Do I have a Site

EMP or EMS

Defence EMS

Site/Base EMS or

EMP

Do I have a

prioritisedAspects and

Impacts

Register?

No

EnvironmentHeritage and Risk

Group

Yes

No

Is there an

EnvironmetnalManager's

Guide for your

issue of

concern?

Yes

No or

Dont Know

Yes

Environmental

Manager's Guides What concernsyou?

Dealing with

Legacy

contaminationissues on site

How to Close the

issue/decomission

Preventing Pollution

happening from

current activities

Setting Up for the

first time

After its happened

While its happening

Just about to start

Identify the

Aspect you wish

to address



1.3 Content of Environmental Manager’s guide

This guide contains the following broad components:

• Dealing with historical or legacy issues relating to aircraft crash sites;

• Preparing a site to deal with aircraft crash events;

• Appendices containing detailed and specific management practices that can

be applied to minimise the impacts to environmental aspects arising from

carbon fibre pollution caused by aircraft crashes, including an identification

of management requirements during and after the event;

• Information on responsibilities for personnel involved in the implementation

of the guide;

• Training, monitoring, reporting and corrective action requirements;

• A process for continual improvement in the environmental management of

such events; and

• A case study of the management of carbon fibre at aircraft crash sites at

Australian DoD facilities.

This guide specifies required levels of environmental performance for Aircraft Crash

Sites and takes into account to the extent possible various Commonwealth, DoD,

Service, contractual, legislative and base specific requirements. However these will

vary from base to base and need to be customised accordingly within the context of

the advice contained in this guide.

It is important to note, and instrumental to the successful implementation of this

guide, that SEA/REO’s know and work within the constraints placed upon them in

terms of the surrounding State or Territory and local requirements, whilst still acting

within their roles and responsibilities in regards to Base Management Practices.

The requirements of this guide are applicable to all personnel, subcontractors and

suppliers associated with Aircraft Crash Site Management.

Such personnel are bound to comply with the requirements of this guide (as far as is

applicable). Specific roles and responsibilities are discussed in detail in Section 5.2.



2 Aircraft Crash Site Management

2.1 Overview

Whilst unfortunate, aircraft crashes do occur from time to time. The aircraft involved

are generally of military design and contain high levels of sophistication in design

and technology. The aircraft’s components contain a variety of synthesised materials

that have the potential to pollute the environment (refer Section 2.3).

Following a crash, military and civilian rescue personnel will become involved. The

priority will be to rescue human life, extinguish any fire and recover any sensitive

materials. However, environmental management has a key role throughout this

process in ensuring effective and appropriate environmental management and

SEA/REOs should be involved from the outset.

Aircraft investigations will often be required so immediate final disposal will often

not be possible. An interim storage location will be required and the proper selection

and preparation of this area, as well as the final disposal destination are vital in

minimising the spread of pollution and unnecessary contamination.

From an environmental management perspective this has some advantages as it

reduces the footprint of the impact zone. However, the aircraft travels at high

velocity and may leave a large crater that will contain residual crash debris.

Conversely, however a pilot may not have such ability and wreckage may be located

in a long narrow or fan-shaped impact zone that can cover some considerable area. In

either case, elements of debris will often be projected randomly in all directions, some

up to hundreds of meters away. The plane may also have unspent fuel and may also

be carrying armaments. These factors often result in a fire occurring upon impact.

During such fires, any unspent fuel load is often burned off – little can be done to

contain the plume except to provide a buffer and allow these volatiles to burn off.

However, planes also contain carbon fibre composite materials on the leading edges

of wings and other components (refer to Section 2.3). The properties of carbon fibre

change once burned. As the composite material burns, gases, vapours, and solid

particles are released into the smoke plume.

Aircraft crash sites may be adversely impacted by a range of hazardous and

radioactive chemicals, armaments and associated compounds (see Table 2.2). Due to

the unique nature of these chemicals and associated materials, a range of contaminant

-specific specialist advice must be called upon to deal with the environmental and

human health risks that may exist. This guide has been developed to address a crash

site where the remaining issue has been determined to be from carbon fibre and

associated Advanced Composite Material (ACM).

2.2 A note on Occupational Health and Safety

This guide reports the environmental impacts and environmental management

requirements of aircraft crash related hazardous substances. Key to these are

Advanced Composite Material (ACM) such as structures consisting of carbon fibre.




By necessity, testing and/or management of these materials will require personnel to

work in close proximity with or handle these materials.

Specialist OH&S advice (eg consultation with ROSCO) should always be sought

beforehand regarding the appropriate level of Personal Protective Equipment to be

worn when interacting with ACM. SAFETYMAN Vol 3 part 1 provides detailed

information with respect to safety procedures to be observed in the event of an

aircraft crash. A rough guide is provided in Table 2.1.

Table 2.1 Indicative PPE required for interaction with ACM (always seek specialist advice)

Recommended minimum PPE*

�: recommended use

�: do not use

Type of exposure Self Contained

Breathing

Apparatus

Full protective clothing

including protective co

veralls

Full face respirator with dual

cartridge high efficiency

HEPA organic and vapour

cartridge

Coated hooded

tyvek

suit w

ith

booties

Leather w

ork gloves (outer)

Disposable or reusable nitrile

gloves (inner)

Safety boots

Burning or smouldering ACM � � � �

Handling broken or splintered ACM � � � � �

Initial 600m clearance zone � � � �

*Material Sourced from 62D Airlift Wing Instruction 21-04, 2004, Advanced Composite Materials Mishap Response -

Attachment 2

Typical entry/exit procedures for personnel actively involved in clean-up of ACM at

the crash site are similar to those for handling asbestos and might include:

• Set up tent/trailer/exclusion zone for checking/donning/removing PPE;

• Use High Efficiency Particulate Air (HEPA) filtered vacuums to remove

advanced composite contaminants from outer clothing, work glove boots,

headgear, and equipment. If HEPA vacuum is not available, comprehensively

wipe or brush off as much contamination as possible (USAF 62D Airlift Wing

Instruction 21-04, 2004);

• Wash hands, forearms, and face prior to moving out of the work areas, and

certainly before eating, drinking or smoking, or any strenuous exercise;

• Wrap and seal contaminated clothing and dispose of as contaminated waste;

• Shower (in cool water) when leaving the site to preclude injury from loose

fibres.



Where possible, it is advised that clean-up using manual labour be minimised in

preference for use of machinery that has enclosed and HEPA air-conditioned

cabins.

2.3 Pollutants of Potential Concern

Military aircraft, particularly fighter jets and helicopters, contain many materials

which are deemed to be hazardous and have the potential to cause pollution. A list of

these materials, estimated quantities and their locations for a fighter jet (F/A-18) are

provided in Table 2.2. The location of these materials on an F/A-18 fighter jet are

shown in Figure 2.1. This list is generic in nature, listings by specific aircraft can be

found in SAFETYMAN Volume 3, Part 2 – Aircraft Accident OHS information or for

United States of America built aircraft Technical Order 00-105E-9 which is available

for download via the www.robins.af.mil website.

Table 2.2 Hazardous materials on board a typical military fighter plane (F/A–18 example)

Type Substance Description Quantity

Location

Nitrogen Often used in hydraulic systems and to inflate aircraft tyre and shock struts. It is also used to cool some avionics and may be in a cryogenic liquid form.

Throughout aircraft including shock struts and wheels.

Oxygen Used for life support. Can be gaseous or liquid form. Bottles can be pressurised to several thousand PSI and liquid oxygen (LOX) will be in the form of a cryogenic liquid.

Various locations throughout the aircraft.

HALON Used for fire suppression.

Various locations depending on extinguisher type and function.

Gases

BCF Used for fire suppression.

Various locations depending on extinguisher type and function.




Aviation Turbine Fuel (AVTUR)

Used in jet (turbine powered) aircraft. Most often located in and between the wings. A small aircraft may have less than 2000L where a large aircraft may have 75,000L or more on takeoff.

Fighter aircraft have significant fuel storage area in the fuselage (main body) while transport aircraft tend to carry most of their fuel in their wings.

Aviation Gasoline (AVGAS)

Used in piston engined aircraft. This is essentially high octane petrol.

As for AVTUR.

Hydraulic oil Used to power flight controls and the undercarriage. There may be up to 80L on a large aircraft.

Throughout the airframe and undercarriage components.

Fuels, Lubricants and Liquids

Engine Oil Used to lubricate the engines. Some engines may contain up to 20L each.

Each engine.

Asbestos Asbestos may be present in small amounts in seals and gaskets.

Small amounts in various components throughout the airframe.

Advanced Composite Fibres (ACF)

ACF includes Kevlar, Fibreglass, Carbon Fibre and Boron and other composite fibres and is used throughout modern airframes. Each aircraft varies greatly as to the type and quantity but some airframes used over 500kg of carbon fibre and 100kg of other ACF types.

Throughout airframe including fuselage and wing surfaces and fairings.

Materials

Cadmium Use to plate components to prevent corrosion.

Small amounts in components throughout airframe.



Beryllium Beryllium is used throughout the airframe in bushings and electronic components.

Small amounts in bushings and electronic components.

Magnesium Used as lightweight alloy with aluminium or in its pure form in some applications. Magnesium will burn with an intense white light and may evolve hydrogen when mixed with water

Throughout airframe.

Paints Each aircraft is painted inside and out for both corrosion protection and looks. This paint may release toxic chemicals when burned.

All aircraft surfaces.

Tritium gas light sources (TGLS)

Used for its luminescent properties tritium is a gas that disperses rapidly once released. Being an isotope of hydrogen it reacts readily with oxygen to form water molecules. If a TGLS is found to be broken evacuate the area for 10 minutes to allow the tritium to disperse.

Small amounts in switches and lights.

Radioactive

Thorium Used in some older aluminium allows for strength also used to coat glass in modern laser or infrared systems.

Engine casings and some airframe components.




Batteries Various Batteries of all types can be found throughout an aircraft. Used for starting, allowing data to be stored without the engines on, or as emergency backups.

Throughout aircraft.

Pressurised cylinders

Various There are a number of pressurised cylinders located throughout most aircraft, whether used for shock absorbers, oxygen, accumulators, fire extinguishers, wheels and tyres or other uses.


Explosives Various Military aircraft may carry external or internal explosive ordnance. Explosives are also used in emergency escape and survival systems such as fire extinguishers and line cutting devices on winches and cargo systems.




Figure 2.1 Location and quantum of hazardous materials on typical military jet (F/A-18)




Figures sourced from SAFETYMAN Vol 3, Pt 2

2.3.1 Advanced Composite Materials (ACM)

ACM include fibres manufactured from glass, boron/tungsten, carbon/graphite

(carbon fibre), Kevlar and Nomex. The fibres are spun and arranged in bundles of

fibres which are woven into thin sheets that are layered and bonded with epoxy

resins and epoxy resin hardeners. Solvents used in their manufacture include

acetone, methyl-ethyl ketone (MEK) and methyl iso-butyl ketone (MibK).

ACM can be found on aircraft including but not limited to the following military use

fighter, transport and training planes: F/A-18 Hornet, F-111, F14 Tomcat, F15 Eagle,

F16 Falcon, PC9, C130 Hercules, Caribou, AP-3C Orion and the following helicopters:

Blackhawk, Seahawk and Sikorsky S76. Figure 2.1 provides an indication of the

locations where ACM’s are likely to be found.

Carbon Fibre (CF) is a type of ACM. Carbon fibre is light weight, has extremely high

specific stiffness with very high strength in both tension and compression and a high

resistance to corrosion, creep and fatigue. Consequently it is used widely in military

aircraft and is likely to continue to be used. However, the impact strength of CF is

lower than glass with particularly brittle characteristics.

When CF is burned, the fibre bundles spread apart longitudinally and may also

reduce in diameter. The fibres are extremely small and light and may be released in

vapours and smoke. When CF receives a mechanical impact, the material is

extremely brittle and breaks down into fragments, these fragments can present a

penetration injury risk when handling. With repeated mechanical impact continues to

break down into smaller and smaller pieces ultimately liberating fibres in dust

(Kwiecen, 2002).



Carbon fibres are very light, can become easily airborne, and may be respirable,

particularly at diameters less than 3 microns (3 µm). Plume dissipation under windy

conditions increases dispersion area. Fire exposed carbon fibres break into shorter

lengths and smaller diameters, increasing the probability for respirability and ease of

transport.

2.4 Release Potential

ACM fibres are most readily released as the result of a crash, fire or explosion.

During a fire, the chemical constitution of the fibres is altered and fibres are released.

The released fibres are readily transported in the air column and are easily suspended

(eg via wind or helicopter down wash).

Figure 2.2 Scanning Electron microscopy image of carbon fibre in crash site fragments - before burning

Fibre diameter range 6.9-7.3 microns. Magnification x 1500. Scale bar 10 microns Source: Queensland University of Technology, 2002




Figure 2.3 Scanning Electron microscopy image of carbon fibre in crash site fragments - after simulated bushfire (burning at 750

oC for 10 mins)

Fibre diameter range reduced from 6.9-7.3 microns to 4.4-5.3 microns after oxidation at 750oC for 10 minutes. Magnification x 1500. Scale bar 10 microns. Note pitting in fibres, reduced diameter and broken fragments. Source: Queensland University of Technology, 2002

Figure 2.4 Scanning Electron microscopy image of carbon fibre in crash site fragments - after fire showing potential cleaving of fibres to within respirable size

Fibre diameter uniform 7 microns. Magnification x 5000. Scale bar 20 microns. Note cleavage of fibres – the resulting reduced diameter fibres would fall into the respirable range. Source: Queensland University of Technology, 2002



2.5 Environmental and Human Health

• The effects of respirable components of ACM over the long term are believed

to be similar to those associated with exposure to asbestos, the symptoms of

which may not present themselves for 20-30 years;

• Inhaled carbon fibre particulate, particularly of diameters less than 3µm

cannot be expelled efficiently;

• Absorbed pyrolysis (i.e. chemical change by combustion) products on carbon

fibres can allow toxic debris to enter the body, causing decreases in respiratory

efficiency and increases passageway irritation;

• The combined effect of inherently sharp and stiff individual carbon fibres

promotes easy dermal penetration, particularly during manual handling of

CF;

• Partially pyrolyzed fibres easily break into smaller segments. Rubbing of

exposed skin areas increases the affected area. Typical exposure requires

medical attention for dermatitis.



3 Legislative Context

3.1 DoD’s environmental obligations

In accordance with the Defence Environmental Management Strategic Plan, DoD

personnel have the following general duties with respect to environmental

stewardship:

• General duty to avoid polluting;

• Duty to use pollution control equipment and keep it in proper working order;

• Duty to preserve the natural and cultural heritage environment of DoD sites;

• General duty to prevent offensive noise from occurring; and

• Duty to use noise control equipment and to ensure that it is properly

maintained.

Obligations may also be addressed in Environmental Management Sub-Plans

(EMSPs) (Appendix A), other project plans or by way of other

documentation/actions.

Key obligations derived from the above documentation are summarised in an

Environmental Actions Table as an attachment to this guide (refer to Appendix B).

3.2 Environmental Legislation and Guidelines

It is essential that all personnel associated with DoD activities comply with legal,

contractual and other environmental requirements as outlined below.

3.2.1 Legislation

DoD properties are assets of the Commonwealth of Australia and consequently are

subject to Commonwealth legislation. In addition, DoD sites operate within the

context of the Australian State or Territory within which they are situated and are

consequently also linked to the legislation that operates in that State or Territory.

This link between Commonwealth and State/Territory becomes clear when it

becomes necessary to use support services, suppliers, waste transporters, disposal

facilities and other off-base services. These services are provided by private

enterprises operating and in many cases licensed by the statutory authorities in that

State or Territory. Consequently, their actions and what they are permitted to do, or

not to do, are dictated by State and Territory legislation and Regulation. This in turn

will determine what they will or will not accept from DoD establishments in turn

requiring DoD to provide materials in a form acceptable to those support services. In

some cases Commonwealth exemptions do exist.




3.2.2 Commonwealth Environmental Protection and Bio-diversity Conservation Act, 1999

The principal Commonwealth environmental legislation that affects DoD Sites and

their activities is the Commonwealth Environmental Protection and Biodiversity

Conservation (EPBC) Act 1999.

Under this Act, DoD sites must comply with the requirements generally outlined in

Table 3.1 with respect to environmental aspects. These requirements must be

adhered to al all times, including during remediation of air craft crash sites:

Table 3.1 Summarised DoD obligations under the EPBC Act applicable to the management of carbon fibre at aircraft crash sites

Environmental

Aspect General DoD requirement under the EPBC Act

Soil Erosion Must not;

• perform an action that will substantially alter natural landscape features,

• cause subsidence or instability,

• cause substantial erosion,

• undertake actions that involve medium or large-scale excavation of soil or minerals.

Soil

Contamination

Must not;

• substantially disturb contaminated or acid-sulphate soils,

• use, store, transport, or dispose of large quantities of flammable, explosive, toxic, radioactive, carcinogenic, or mutagenic substances.

Water Must not;

• generate chemicals, nutrients, or other pollutants which will reduce local water quality,

• measurably reduce the quantity, quality or availability of surface or ground water,

• channelise, divert or impound rivers or creeks or substantially alter drainage patterns,

• measurably alter water table levels,

• adversely effect in any way, listed Ramsar wetlands.

Air Must not;

• generate smoke, fumes, chemicals, or other pollutants which will substantially reduce local air quality,

• increase atmospheric concentrations of gases which will contribute to the greenhouse effect or ozone damage.

Waste Must not, dispose of waste that will, or in a manner that will;

• increase the load of nutrients, chemicals or other pollutants to waterways,

• contaminate soils.



Environmental

Aspect General DoD requirement under the EPBC Act

Indirect off-site

impacts

Must not;

• cause a down stream or down wind impact such as chemicals being washed down stream or sediment traveling down stream to impact upon natural environments;

• cause upstream impacts such as those that are associated with the production of energy.

3.2.3 Statutory Legislation, Regulations, Guidelines, Licences, Permits, Consents and Approvals

SEA/REOs should be familiar with the relevant legislative requirements associated

with the site activities undertaken including, Regulations, Guidelines, Licences,

Permits, Consents and Approvals, relevant to the State or Territory in which the site is

located.

Due to the dynamic nature of the Australian legislative framework, a list of relevant

environmental legislative requirements has not been provided in this document. It is

possible that over time such legislative requirements may be subject to review,

amendments, insertions, supersession or withdrawal; hence it is imperative that

SEA/REOs and other personnel (where required) make constant reference to live and

on-line tools displaying the latest amendments and documents in circulation for each

State and Territory.

The types of legislative documents potentially relevant to DoD site activities, which

are specific to and vary between States and Territories can include the following:

• Acts

• Regulations;

• Policies;

• Standards;

• Guidelines;

• Codes of Practice;

• Protocols; and

• Information Bulletins.

Specific national guidelines of relevance include:

• ANZECC, 1992, Australian and New Zealand Guidelines for the Assessment

and Management of Contaminated Sites.

• ANZECC, 1995, Draft Guidelines for the Analysis of Contaminated Soils.




• ANZECC, 2000, Australian and New Zealand Guidelines for Fresh and

Marine Water Quality, October 2000.

• NEPC, 1999, Guideline on the Investigation Levels for Soil and Groundwater

NEPM, 1999.

• NEPC, 1999, Guideline on Health-Based Investigation Levels, NEPM, 1999.

• NEPC, 1999, Guideline on Data Collection, Sampling Design and Reporting,

NEPM, 1999

• Environmental and Public Health Council (EPHC) Guidelines for the Non-

Occupational Exposure to Asbestos, in press, June 2005.

SEA/REOs should note that Commonwealth and State legislation is subject to

constant updates and amendments, and therefore document control procedures must

be adhered to when working with, circulating and/or referencing legislative

documents.

SEA/REOs should also ensure currency of legislation by referencing DoD’s on-line

Environmental Legislation Tool on an on-going basis. This tool is located at:

http://www.intranet.defence.gov.au/environment (then clicking on Legal & Other

Requirements then National Legal Register)

SEA/REOs should be aware that the language used in legal documents such as Acts

and Regulations that stipulate environmental responsibilities and obligations can be

confusing. In such circumstances, it is recommended that advice of a suitably

qualified legal practitioner or environmental consultant is sought to ensure accurate

interpretation and application of this material.

Table 3.2 provides a list of topics for which legislative requirements are in place

across Australia. Virtually all States and Territories and/or the Commonwealth, have

Acts and Regulations which relate to the topics listed below. Most of these

encompass environmental considerations and can be triggered by DoD activities and

practices and hence deserve acknowledgement at the site/base level. Although some

topics may not appear to be directly relevant, they all have requirements for

environmental protection and management, which can be relevant to adopted site

activities and practices.

Table 3.2 Topics governed by Australian legislation that have environmental requirements

Topic

• Aboriginal lands • Major infrastructure

• Airports • Marine Parks

• Archaeology • Mine subsidence

• Blasting • National Parks

• Buildings • Native title

• Bushfires • Native Vegetation

• Catchment management • Natural Resources



Topic

• Clean air • Nature Conservation

• Clean Waters • Noise Control

• Coastal protection • Noxious weeds

• Conservation • Nuclear activities/radiation control

• Contaminated lands • Ozone

• Crown lands • Planning/Town planning

• Dangerous Goods/hazardous chemicals

• Rivers and Foreshores

• Defence • Sea installations

• Environmental Protection measures

• Soil Conservation

• Explosives • Threatened Species

• Fisheries • Tree protection

• Flora and Fauna • Vehicle emissions

• Greenhouse Gas • Waste avoidance/minimisation

• Heritage • Water

• Integrated planning • Waterways

• Irrigation • Wilderness

• Land Management • Wildlife

• Local Government • World Heritage

3.2.4 Aircraft Crash Site Management specific approvals licences, permits, consents

Table 3.3 provides an indication of the type of statutory approvals, licences/permits

or consents that may be required when dealing with Aircraft Crash Site Management.

Whilst it is not necessary for DoD to gain statutory licenses and approvals for on site

activities, subcontractors that are engaged by DoD must operate within the relevant

legislation, approvals and licences for that particular state or territory.

Specific advice should be sought from the DFS-ADF Aircraft Accident Investigation

Team (AAIT) leader regarding the relevance of these approvals prior to proceeding.




Table 3.3 Licences, permits, consents and approvals that may be relevant to Aircraft Crash Site Management.

Type of Activity that may require approval

Potential

approvals/licenses When required

Permission to enter landowner’s property

Landowner permission Prior to accessing damaged aircraft

Solid waste transportation and disposal (hazardous waste)

EPA waste transport certificates

Curfew transport certificate

Prior to /at the time of transportation

Disposal of CF waste at state operated landfill

Waste disposal certificate Prior to collection of material (to permit adequate preparation) and prior to dumping

Storage of chemicals (fire fighting materials and fixants etc.)

Licenses or permits to store dangerous

License or permit to be sought prior to establishment of storage facility

Discharge to surface water bodies

Discharge Permit or licence from state EPA

License required prior to operation

Important note: No chemical discharges to stormwater or surface water bodies are permitted under any circumstances.



4 Life-Cycle Approach to Aircraft Crash Site Management

4.1 Dealing with Legacy issues

At sites where aircraft accidents have previously occurred, clean-up procedures may

have been undertaken with varying degrees of rigour. As a result, a crash site may

still contain ACM residue. A case study of resolving carbon fibre pollution from an

active DoD site is provided in Appendix E. To determine this, the following step-

wise process should be undertaken:

• Do a historical review to determine if aircraft have crashed on the site;

• If so, determine the precise location from site records or anecdotally by talking

to experienced site personnel. Determine when and what type of aircraft

crashed, any armaments carried and whether it caught fire;

• Assess the nature of the crash investigations, debris recovery and any

associated clean-up. In most cases site ‘clean-up’ may have occurred by on-

site burial. It is important to determine the level of containment undertaken

and hence the level of potential pollutant mobility.

Pollutant mobility will primarily depend on the ground conditions.

Saturation and contact with the water table will assist in soluble pollutant

migration if the materials have not been plastic wrapped or contained in some

other way. Highly impermeable bedrock or soil layers such as clay may assist

in preventing pollutant migration;

• Assess the potential for re-exposure based on the containment conditions and

the ongoing and intended use of the land at the burial site. Factors such as

unsuitable containment or ongoing disturbance of the site may warrant a

carefully managed re-location of the material to a better or consolidated

location;

• Should relocation be necessary, the key steps to be taken are:

• Set up a new location for the material’s long-term management, where

possible using best practice management and close down or

decommission current legacy sites. New sites should be fully

contained to ensure that the new site does not become a pollution

source itself and rehabilitation at the former site must be thorough to

ensure that the pollution impact is not multiplied.

• Careful forward consultation and planning. Make contact with

personnel within the Environment Heritage and Risk Branch of CSIG

to ensure effective information sharing throughout the clean-up

process.

ACM by nature has the potential to spread very easily by wind, water run-off or

vehicle movement. This fact needs to be taken into consideration when investigating

the history of the site as it will be important in determining the extent of the spread of




the ACM migration. Other practices such as weapons testing and ground levelling,

which occur at range sites have the potential to increase the spread of the ACM.

4.2 Setting up in preparation for management of aircraft crashes

Subject to appropriate approvals and central co-ordination, REO’s should prepare

their Regions in the event that an aircraft crash occurs within their area of operations.

This may be on-base but is most likely to be off-base.

SEA/REO’s should familiarise themselves with the airfield Emergency Plan (AEP)

and be a member of the Base Emergency Response Committee (Base EMC) that

applies to their site. As a member of the EMC the SEA/REO can:

• Identify and liaise with personnel responsible for initial response of an aircraft

crash. It is important that the SEA/REO is informed at the outset of the event.

Prompt initial action is very important in managing the accident in an

environmentally appropriate and cost effective way;

• Contribute to the development and planning of response planning; and

• Ensure environmental requirements are written into the AEP.

Sites that regularly experience activities undertaken by military aircraft in simulated

combat or training exercises should prepare themselves for the possibility of an

aircraft crash.

Such sites should identify a suitable crash debris disposal location. A detailed guide

to site containment characteristics for ACM disposal locations is provided in

Appendix C. Preference should be assigned in the following order:

• Collection and preparation for disposal at a commercial waste disposal facility

that is approved by the State or Territory in which the event occurs and is

licensed to take the type of waste. How crash debris is to be packed and

transported in a way that is acceptable to the facility should be ascertained up-

front to minimise delays in the event that a crash occurs. Such enquiries

should be undertaken discretely and not unnecessarily to avoid unwarranted

alarm. It is important to confirm that crash debris has been declassified before

its release for licensed disposal and the disposal facility has appropriate

security clearances;

• Collection and consolidation of the waste material in a suitable defined and

contained burial cell on DoD lands (refer Appendix C);

• Collection of material and burial at the site of the incident (impact zone).

The site or base from which aircraft are dispatched and the site or base closest to

which aircraft are to fly on operation or to land should be equipped with the

following equipment and consumables. Materials and equipment are most

appropriately held with the fire fighting section. If not currently listed, these items

should be added to the base Crash Response Kit (Safety Manual Vol 3, Part 1 Ch 12,

Annex F):



• Adequate supply of Aqueous Film Forming Foam (AFFF)1 for the aircraft

incident as defined in the CASA Manual of Standards 139, Sub-chapter H,

Chapter 7. The maximum dilution possible to achieve effective fire control

should be used; and

• Fixant solution. This material may include:

o Liquid poly-acrylic acid (PAA) ; or

o Acrylic floor wax solution mixed with water in a 10:1 water to wax ratio.

Fixant solution is applied once the fire is extinguished and the extinguished material

has reduced in temperature to less than 150oC. The fixant solution is sprayed onto all

burned ACM and onto areas containing scattered and settled debris;

• Soil tackifiers (such as polychem, J-tack, terra-tack) to hold materials to the soil

or sand (application rate approximately 3.2L/m2);

• Suitable plastic wrap material (minimum 0.2mm thick) and masking tape to

contain shattered and splintered parts and to hold recovered fragments; and

• Suitable temporary transport and holding location for wrapped parts (eg

shipping containers, shed with concrete floor, hangar).

4.2.1 Minimum requirements

In order to minimise pollution events resulting from aircraft crashes, when setting up

a disposal site, disposal site identification is critical. Appendix C identifies the key

questions to ask and the ideal requirements for setting up an on-site disposal location.

As many of these requirements as possible should be satisfied in order to proceed.

If there is any doubt as to whether the site is appropriate for the activity or further

information is required, such additional information gathering/studies should be

conducted before proceeding. It is strongly recommended to contact the CSIG

and/or an appropriately experienced consultant to gain specific site related advice.

Greater adverse environmental impact may occur if disposal occurs in a poorly

selected location without adequate controls than if disposal were undertaken

elsewhere or temporarily deferred. The environmental and financial costs of

remediating poorly selected sites can be considerable.

4.3 Operating requirements of an Aircraft Crash Site Management

Responses to aircraft crashes generally follow the following phases:

• Notification;

• Response;

1 AFFF has known environmental impacts that include persistence, bio-accumulation and toxicity, discharge of glycol ethers

used in foam formulations and upsetting the balance of biodegradation mechanisms in Sewage Treatment Plants and can cause significant adverse environmental degradation to sensitive receiving waters if there are uncontrolled releases. Separate advice is available to SEA/REOs on this topic.




• Withdrawal; and

• Recovery.

The following steps can be undertaken by SEA/REOs at each stage to ensure effective

environmental management of an aircraft crash incident.

NOTE: The task/action statements listed below are in approximate order; however,

many actions occur simultaneously and some may deviate from sequence. All should

be considered. The actions include activities for an event occurring off-base and on-

base. SAFETYMAN Vol 3 Part 1 should be consulted prior to entering an aircraft

crash site.

4.3.1 Notification

1. SEA/REO has previously provided input as part of the EMC in contingency

planning discussions with appropriate personnel to prepare the site and

surrounds in the event of an incident (refer Section 4.2).

2. SEA/REO is notified as soon as an incident occurs and must:

• Assist in providing advice to rescue operations of the fastest and most

appropriate route to a crash site to avoid unnecessary delay and collateral

environmental damage;

• Advise personnel to approach the crash site from an up-wind direction;

• Advise potential affected down-wind receptors - mobile receptors to be

removed from downwind affected areas;

• Confirm that fixant spray is available at the crash site to be applied to

carbon fibre components and contaminated soils to minimise further

release or spread of carbon fibres;

• Confirm that the use of aqueous film forming foam (AFFF) is to be

minimised and ensure that watercourses are protected from AFFF and

run-off laden with carbon fibre and other crash pollutants;

• Minimize walking, working, or moving materials to reduce airborne

particulates, fibres and dust;

• Remove wreckage in a manner that minimises adverse environmental

impacts; and

• Confirm that sealing materials such as shipping containers, plastic wrap

and duct tape are available to seal cooled components during recovery.

4.3.2 Initial response

All response approaches are to be made from an upwind position – this base of

operations should move with changes in wind direction. The first emergency

services units on site will:

1. Take actions necessary to preserve human life.



2. Extinguish any fire and mark any hazards such as explosive devices (rescue

and base personnel are required to minimise use of AFFF and to use fixant

sprays. AFFF is to be prevented from entering waterways).

3. With permission of the OIC AAIT, protect and recover any sensitive or

classified materials.

Helicopters should not be permitted to fly or hover over the crash site at altitudes less

than 150m as rotor wash will re-suspend fibres that spread contamination; and

Provide advice regarding the most appropriate location to establish an area for debris

storage and removal. To avoid further contamination, this may often be a section of

the impact zone.

Withdrawal:

• Assist with aircraft investigation, identify or contribute to decision making in

selection of a suitable location for temporary storage/accident investigation of

aircraft wreckage (if not determined in planning); and

• Identify waste disposal location(s), handling and transportation requirements

of ACM.

Response:

In responding to an aircraft crash, the SEA/REO should consider the following and advise the recovery team accordingly:

• Get advice from ENVHO regarding the actual hazardous materials that may

be encountered on the specific aircraft involved in the incident. Note that for

preference, specific information should be obtained from the aircraft’s base or

SAFETYMAN Vol 3, Part 2 - Aircraft Accident OHS Information;

• Contamination control:

o Approach the incident site from an up-wind direction, protect water

courses from sedimentation caused by earthworks, AFFF and run-off

laden with CF and other crash site pollutants;

o Minimize walking, working, or moving materials to reduce airborne

particulates, fibres and dust;

o Wreckage removal; and

o Site restoration.




4.3.3 Recovery

Once the aircraft wreckage has been released by the AAIT the following cleanup

and/or decontamination actions will need to be carried out:

• Use of a specialised contractor will most likely be required. Clean-up

contractors should be selected based on appropriate OH&S standards and

experience with the handling of hazardous fibres and/or materials.

SEA/REO’s should seek evidence from contractors that the personnel

involved in the clean-up have been appropriately trained to deal with the

materials to be handled. Persons without such training (DoD, civilian or

contractors) must not be used. Contractors should be reputable and should

sign confidentiality deeds. If such contractors are not available, seek specialist

advice from an appropriately qualified company/consultancy;

• Contractors are required to submit an application/work method for an

Environmental Clearance Certificate (ECC) and develop and provide an

Environmental Control Plan (ECP) for the works;

• Clean up and subsequent remediation is to occur on all properties affected by

crash debris. Clean-up should occur in consultation with the property

owner’s requirements but should include as a minimum:

o Removal of all aircraft debris from the area. These materials are to be

placed in a suitably confined area for transportation (eg plastic lined

shipping container) to ensure risks of exposure to humans is minimised;

o Removal of all hazardous materials; and

o Validation sampling of affected areas and provision of a validation report.

Materials should be:

• Treated as per the manufacturers Materials Safety Data Sheet (MSDS);

• Sufficiently cool to touch by hand;

• Wrapped in thick plastic wrap with edges sealed with duct tape;

• Placed in a hard stand area (crash investigation area) if necessary that is

prepared as follows:

o Impervious hardstand (eg concrete). Seals in concrete slabs are to be

appropriately sealed/caulked beforehand so that ACM cannot lodge in

cracks or crevices;

o Slab should be further protected by taping to the floor sufficient plastic

sheeting (duct taped at joints) to contain the entire area of ACM

material/pieces to be stored there; and

o Covered building (eg hangar, shed) to protect from wind and rain.



• Restricted access to authorised personnel only, fitted with appropriate PPE;

• Removed with the use of HEPA vacuum equipment, if available;

• Removed by excavating the minimum amount of soil (nominally 50mm of top

soil) from the crash site. The immediate surrounds (approx 30m radius) will

contain the highest concentration of material but debris spread up to 75-100m

away or even further may also be encountered and will require removal.

Manual walking and inspection of the scraped area should follow with further

scraping to minimum required depth to remove any further material. A

greater depth of soil will need to be removed from the initial impact area;

• Where full clean up of the crash site is prevented due to excessive rain, aircraft

remains are to be removed as described above. Soil from the crash site is to be

scraped as described above and temporarily stockpiled on site. This stockpile

of soil is to be covered and secured to prevent exposure. Fences/barriers

should be erected around the crash site to prevent personnel or stock entering

the area. Due consideration is to be given to stockpiles for erosion and

sedimentation control in terms of up and down gradient diversion and

detention basins to capture run-off;

• Clean-up works should resume as soon as access is possible;

• Once the bulk of crash debris has been removed, validation sampling should

be undertaken. Appropriate soil sample validation may require specialised

techniques including electron microscopy of soil samples. It is recommended

that the services of a suitably qualified environmental consultant be engaged

to undertake validation testing and reporting. A detailed soil sampling,

validation and remediation plan must be developed specifically for the

locations affected; and

• Following visual inspection and the results of validation sampling, the crash

site area should be restored with locally compatible soil layers/topsoil.

Restoration should extend to any temporary work areas or access tracks in

accordance with landowner requirements.

Rugged terrain

Under ideal situations, helicopters or low flying aircraft should not be used to

extinguish or suppress fires as their operation within 150m above the crash site can

unnecessarily mobilise ACM fibres.

In the event that an aircraft crash occurs in rugged terrain that is difficult to access,

the use of helicopters may the most appropriate vehicle for access, fire fighting and

recovery. Where ever possible the helicopters should approach from the upwind side

and should keep their rotor wash away from the clearance zone. If a route needs to

be cleared to access the crash site then the SEA/REO should be consulted to

determine the route that will cause the least amount of collateral environmental

damage. Restoration works should be undertaken upon completion.




4.3.4 Environmental DoD Method Statements

Environmental DoD Method Statements (EDMSs) are documents that SEAs/REOs

may choose to produce for specific DoD activities that can give rise to

environmentally significant impacts.

If produced, the EDMSs would address the environmental issues that are specific to

that method of undertaking the activity. The information contained within the

statement is dependant upon the nature of the activity. Indicative information is

included in Appendix A.

EDMSs, or the applicable elements of these, may be integrated within Work Method

Statements that are used by operational personnel. This integration assists in

maintaining document familiarity with site personnel, minimizing the number of site

reference documents and adoption of a holistic approach to construction and

environmental management.

Environmental Management sub-plans

Each environmental aspect associated with Aircraft Crash Site Management is

addressed in Appendix A.

Each table within Appendix A includes the following information regarding Aircraft

Crash Site Management:

• The Purpose of the action;

• Specific environmental elements relating to the aspect;

• Potential impacts of Aircraft Crash Site Management on the aspect;

• The objective of what is the desirable outcome from management of this issue;

• Targets identifying specific site related outcomes;

• Relevant legislation, guidelines and other obligations that will assist in setting

performance targets;

• Relevant associated plans and documentation;

• Management strategies and controls for three phases of activity:

o Prior to doing the activity;

o While the activity is occurring; and

o After the activity has been completed.

• Requirements for monitoring, reporting and documenting the activities;

• Corrective actions to be taken in the event of unforseen circumstances;

• Specific Responsibilities; and



• Timeframes for action.

The items shown in Appendix A are generally applicable for use at all incident sites

but should be reviewed and modified as necessary to suit local environmental

conditions.

4.3.5 Quality Assurance of inputs and outputs

DoD sites with an integrated EMS in place should have the necessary and robust

environmental records, procedure and data management requirements already

available to ensure effective quality control and ongoing management of information.

The effectiveness of such a system is highly dependant on the diligence of DoD

personnel (and especially the SEA/REOs) in the collection and management of

required environmental information in accordance with the requirements of the site

EMS.

Quality assurance of inputs and outputs is also influenced by the selection of

consultants and contractors. It may be prudent for SEA/REOs to pre-select/pre-

qualify appropriately skilled and experienced consultants and contractors for the task

that meet the requirements of DoD’s Environment and Heritage panel and that have

appropriate systems for quality control.

4.4 Closure of an impacted Aircraft Crash Site

Closure of an impacted aircraft crash site entails concluding all activities that will

return the site to its condition and/or landuse prior to the crash occurring. Following

successful clean-up and closure, the site may return to the original landuse.

Closure of an aircraft crash site involves:

• Obtaining documentation from a suitably qualified consultant/auditor that all

impacts sites have been effectively cleaned up and validated;

• Validation reporting is to be obtained for each clean-up site and should contain:

o all information gathered during the clean up and disposal of materials, including digital photographs and the original copies of any laboratory tests; and

o Validation reports should provide information of all contaminants of concern including but not limited to ACM/CF, heavy metals, radiation and hydro-carbons.

• Confirmation that the activities that are to occur on the clean-up and ultimate

disposal sites are consistent with the land-use and that re-disturbance of the

material is not likely and that its location is well known, mapped and

recorded on DoD records and those of other affected stakeholders (eg.

Landowners, state/territory regulatory authorities); and

• Undertaking a post-event review to assess the sequence of events and

activities that were undertaken, asses what was effective and not effective

during the process and revise processes and documentation accordingly.




5 Implementation of guide

5.1 Management Organisation Chart

To ensure effective implementation of pollution prevention measures, SEAs/REOs

should refer to the most current revision of a management organisation chart specific

to the personnel that would be involved in management of an aircraft crash (eg.

EMC).

5.2 Responsibilities and Authorities of Project Personnel

All DoD staff have individual responsibility statements that include, where

appropriate, their general responsibilities for environmental management.

In reality, SEA/REO’s may not have the direct executive role in the implementation

of this guide. The base commander (or similar executive) will have that role and all

pollution abatement technology will be his/her responsibility to procure and install.

The SEA/REO’s responsibility in such instances is to provide the necessary

information to the Base Commander so that informed decisions can be made and the

best and most cost effective use of resources can be made.

Specific environmental management responsibilities for key personnel that will be

assigned to the aircraft crash site are detailed in the following sections.

To ensure site personnel are familiar with their personal environmental obligations

whilst on site, relevant points of the guide will be included in the delivery of standard

DoD site inductions. Signatures demonstrating acknowledgement of environmental

responsibilities by personnel involved in crash site management should be contained

with induction records.

5.2.1 Base Commander

The responsibilities of the Base Commander include but are not limited to the

following:

• Communicate the management of Aircraft Crash Sites between CSIG and

Military activities on the base;

• Liaise with SEA/REO to gain an understanding of the site environmental

issues;

• Ensure that guide requirements are fully implemented and in particular, that

environmental management requirements are considered alongside all other

DoD/military requirements (such as integration within Work Method

Statements as applicable); and

• Manage verbal and written communication with respect to any environmental

issues.



5.2.2 Senior Environmental Advisor

The responsibilities of the SEA include but are not limited to the following:

• Ensure that site personnel are familiar with the requirements specified in this

guide and that these requirements are identified within any Environmental

Management Plan (EMP) or Environmental Compliance Certificate prepared

to undertake activities involving carbon fibre clean up;

• Allocate resources to meet guide requirements.

• Liaise with DoD including Base Commander and government authorities as

required with respect to environmental issues;

• Assist all site staff with issues concerning project environmental matters;

• Review and endorse the disposition of Environmental Management Non-

Conformance Reports (EM-NCR’s); and

• Co-ordinate the activities of specialist environmental consultants.

5.2.3 Regional Environmental Officer

The responsibilities of the REO include but are not limited to the following:

• Undertake site response planning, inspections of the site and clean-up works

as necessary;

• Identify and communicate site environmental issues to the Base Commander;

• Ensure continued compliance with the DoD Environmental Policy, this guide

and associated Project Environmental Documents;

• Review and endorse the disposition of EM Non-Conformance Reports (EM-

NCR’s);

• Assist in ensuring site personnel and contractors incorporate environmental

management requirements and mitigations into Work Method Statements and

JSEAs where applicable;

• Ensure monitoring records are reviewed and any compliance issues

addressed; and

• Undertake audits and inspections as required.

5.2.4 Contractor

The responsibilities of specialist contractors and/or DoD Engineers/Foreman/

Superintendent include but are not limited to the following:

• Co-ordinate implementation of the guide under direction from the REO;

• Prepare Environmental DoD Method Statements (EDMSs) where required or

Work Method Statements that include the relevant components of EDMSs;




• Ensure that employees/sub-contractors receive site specific environmental

awareness inductions prior to working on site;

• Co-ordinate implementation and maintenance of pollution control measures;

• Identify any new environmental risks as works progress and notify the

SEA/REO;

• Communicate with all personnel and subcontractors regarding compliance

with the guide and other environmental documents;

• Ensure records are maintained and completed as stated;

• Identify resources, as required, for implementation of the guide;

• Assist in the investigation of environmental complaints;

• Comply with the relevant requirements of this guide, sub-plans, Work

Method Statements, JSEAs, Commonwealth and State legislation o other

environmental management guidance as instructed by a member of the

project’s management;

• Where required, undertake environmental risk assessment of works prior to

commencement;

• Participate in the mandatory DoD project/site induction program; and

• Report any respond appropriately to environmental incidents.

5.3 Environmental training and competence

5.3.1 Qualifications and competence

All personnel directly involved in the project, including those with environmental

management responsibilities, will be appropriately qualified or competent to

undertake the tasks of the position to which they have been appointed.

5.3.2 Training programs

DoD personnel, subcontractors and unaccompanied visitors will be required to

participate in a project/site induction which will address relevant project

environmental issues.

Specific environmental training will be provided if and when required as identified

by the SEA/REO.

Records will be maintained detailing the attendees and content of all

induction/training.



5.4 Communication and complaints management

5.4.1 Internal communication

Effective communication between all levels of DoD management, employees and

external parties is of paramount importance to the implementation and maintenance

of the environmental management program. Both successes and failures should be

communicated.

5.4.2 Inquiries and complaints handling procedure

Unless otherwise advised by project management, project staff and sub-contractors

are not authorized to discuss project related matters with members of the public or

the media.

All community inquiries and complaints related to DoD activities will be referred to

the Base Emergency Management Committee or the OIC AAIT.

5.5 Environmental records and reporting

Key Environmental records that should be retained as a minimum are as follows:

• Most recent revisions of Environmental Manager’s Guides (this document),

sub- plans, environmental procedures, EDMSs, Environmental Work

Instructions, Inspection and Test Plans and records of changes to these

documents;

• Minutes of meetings at which environmental management is discussed;

• Results of internal and external environmental audits and site inspections;

• Environmental non-conformances and associated corrective actions;

• Environmental complaints and corrective actions;

• Monitoring data and reports;

• Calibration records for all testing and monitoring equipment demonstrating

calibration in accordance with manufacturer’s specifications;

• Site inspection reports; and

• Records of environmental accidents and incidents.

Other environmental records could include:

• Induction/training records; and

• Approvals, certification and permits/licences/approvals issued by statutory

authorities.

Specific records required for clean-up activities include:

• Records of waste transportation documentation;




• Site photographs with dates and descriptions of events and status;

• Details of aircraft type and associated hazardous materials; and

• Global Positioning System (GPS) coordinates for the crash site including the

extent of the spread of debris and the nearest sensitive receptors.

All of the above records should be stored such that they are legible, identifiable,

readily retrievable and protected against damage or loss.

Reporting should be undertaken between all stakeholders on a regular basis

throughout the process. As a minimum this is to include the Base Emergency

Management Committee and the AAIT.

SEA/REO’s need to liaise with AAIT so that site photographs and GPS records can be

obtained after the crash investigations are complete.

A pro-forma for an Environmental Inspection Checklist indicating the types of

information that should be recorded for carbon fibre management is provided in

Appendix D.



6 Continual Improvement

In order to achieve continual improvement with resultant stabilization of site

environmental impacts, the following three steps are necessary:

1. Collect and review data.

2. Monitor trends and abnormalities in the data and determine explanations for

these trends and abnormalities.

3. Develop corrective procedures to address abnormalities.

Brief descriptions of the necessary components to achieve effective continual

improvement are identified below.

A mechanism for SEA/REOs to ensure that the successful management of

environmental issues related to Aircraft Crash Site Management are incorporated

within ongoing management practices is provided in Figure 6.1.

Figure 6.1 Continual Improvement mechanism for management of guide issues

Defence EMS

Activity WorkMethod

Statement

Activity/Training Siterequirements

Activity WorkPlan

NonConformanceReport where

applicable

Co

ncep

t

Desi

gn

EIA

an

d A

pp

ro

va

lA

cti

vit

y P

lan

nin

g a

nd

co

nfo

rma

nce

mo

nit

ori

ng

Au

dit

ing

(in

tern

al

an

d e

xte

rna

l)

an

dcorre

ctiv

e

act

ion

Base TrainingActivities

EnvironmentalManagementAction Plans/Thin Guides

Base EMS/EMP

SEA, SEO orRanger

determinescompliance

Internal Audit

External Audit

AuditRecommenda

tionsSOPs,Procedures,

Forms

Job Safety(and

Environmental) Analysis

After event

During eventBefore Event

Site checksDone dailyReportedweekly

Site Training/Activities




6.1 Environmental Objectives, Measures and Targets for Continual Improvement

Sub-Plans to this guide (Appendix A) contain specific objectives/targets which take

into account generally applicable legal and contractual obligations. The relative

success of environmental management for this issue will be determined by

performance against these criteria.

A systematic review of Environmental Manager’s Guide and Sub-plan objectives,

measures and targets should occur when:

• There are any changes in DoD’s corporate environmental policy; or

• There are changes in legislation that have a bearing on project works or

environmental performance standards; or

• A request/direction is made by environmental regulators ; or

• Significant demonstrable improvement has been made in the management of

carbon fibre management at crash sites as documented in a robust and

thorough way from a reliable source; or

• There has been notable deviation from the construction design or operational

methodology/process from that for which the guide sub-plans were prepared;

or

• Relevant project environmental objectives, measures or targets have not been

met or repeatedly met.

This approach will ensure that objectives and targets remain relevant and can effect

improvements in environmental performance.

6.2 Environmental inspections and audits

General surveillance of long-term aircraft crash sites will be necessary to verify that

routine environmental pollution control maintenance is being conducted and that

additional control measures are not required.

It should not generally be necessary to monitor cleaned and validated crash sites,

however complaints by landowners should be promptly investigated. Advice from a

suitable qualified consultant should be sought where issues arise;

Disposal sites on DoD property should be inspected and reported to the EMS, at least

annually to verify that ACM/CF/other hazardous material is not mobilising or being

re-suspended due to site activities. Clear access to disposal sites should be retained.

Internal and external audits will be carried out and reported to verify compliance

with the environmental management program.

Where required, subcontractors will be required to participate in audits to be

conducted and make appropriate personnel available as required



6.3 Non-conformances

All environmental management non-conformances should documented on a Non-

Conformance Report and a register of all non-conformances maintained. Non

conformances include:

• Any exceedance of documented environmental performance targets or breach

of the requirements;

• Any other error, misadventure or incident resulting in environmental damage,

which is in contravention of the principles of ESD and DoD’s environmental

stewardship, is significant, costly or harmful to DoD’s reputation; or

• Cumulative or repeat near miss events that have not resulted in but have the

potential to result in environmental damage which is significant, costly or

harmful.

6.4 Corrective procedures

Reviews of non-conformances are undertaken in order to identify

• Remedial actions to be taken to eliminate the particular non-compliance;

• Corrective actions to be taken to provide reasonable assurance that the non-

compliance will not re-occur;

The guide, sub-plans, Work Method Statements, Job Safety (Environmental)

Analyses, procedures and other relevant documentation may be revised wherever

appropriate to reflect the identified corrective actions.

6.5 Process improvements

SEA/REO’s should keep themselves abreast of development in carbon fibre crash site

management whenever possible. Information exchanges with other military units

such as the Directorate of Air Force Safety (DAFS), Directorate of Flying Safety- ADF

(DFS-ADF) or overseas military units such as the United States are a useful source for

identifying any process improvements in clean-up procedures.

Information transfer and training

Base Commanders, SEAs and REO’s should be aware of DoD’s practice of regularly

rotating base personnel (nominally 2 to 5 years). To minimise the potential loss of

knowledge and maintain continuity in the management of CF on the site, the

SEA/REO has a role in proactively managing the transfer of site specific

environmental information. This may be achieved by liaising with appropriate senior

military and civilian personnel to provide suitable training and awareness. A process

should be established with base operational personnel to ensure transfer of

knowledge on:

• The existence or history of any crash events on the base;




• The location of documentation/maps/reports showing the location of any

burial sites or crash sites;

• Any ongoing management requirements of such sites;

• The need for readiness of materials to deal with such an event.

For effective implementation and transfer of knowledge, Base Commanders/site

managers should review this guide.



7 References

ANZECC, 1992, Australian and New Zealand Guidelines for the Assessment and

Management of Contaminated Sites.

ANZECC, 1995, Draft Guidelines for the Analysis of Contaminated Soils.

ANZECC, 2000, Australian and New Zealand Guidelines for Fresh and Marine Water

Quality, October 2000.

Kwiecen, W (12 August 2002), Report on Comparison of combusted and non combusted

carbon fibres residual from the Delamere FA18 crash site in NT, Queensland University of

Technology, Faculty of Science, School of Natural Resource Science, Brisbane.

MGT Environmental Consulting Pty, Ltd, 2002, Analytical report Number 154212 for

URS Darwin Office Job Number 12343, Oakleigh Victoria.

National Aeronautics and Space Administration (NASA), 1980, Risk to public from

carbon fibres released in civil aircraft accidents. Prepared by Risk Analysis Program

Office, Langely research center, Hampton, Virginia.

NEPC, 1999a, Guideline on the Investigation Levels for Soil and Groundwater NEPM,

1999.

NEPC, 1999b, Guideline on Health-Based Investigation Levels, NEPM, 1999.

NEPC, 1999c, Guideline on Data Collection, Sampling Design and Reporting, NEPM,

1999.

Springer, G.S., Mashtizadeh, S.A., & Keller, A.B, 1981, Electrical Hazards posed by

graphite fibres. In G. S. Springer (Ed), Environmental effects on composite materials

(pp160-165), Westprot, CT : Technomic Publishing.

Safety Manual (SAFETYMAN), Vol 3, Part 1 - Defence Aviation Safety Manual.

Safety Manual (SAFETYMAN), Vol 3, Part 2 - Aircraft Accident OHS Information.

USAF HQ 62D AIRLIFT WING, January 2004, 62D Airlift Wing Instruction 21-04,

Advanced Composite Materials Mishap Response.


Appendix A Environmental Management Sub-

plans for Operation of Carbon Fibre Management of aircraft sites

September 2005 Ref: 327109: 00|01 1 Appendix A


Waste Management

Objective: To store, handle and transport waste in a way which minimises environmental impacts. To effectively manage solid waste in accordance with legislative requirements.

Targets:

• Reuse of non-hazardous solid waste, where possible.

• No pollution of environment from storage and transportation of waste.

• Waste tracking accountability (documentation) for all wastes. Inputs and outputs are continually monitored.

• Any operational issues impacting output/performance are identified and rectified.

• Monitoring results are recorded and retained. Aspects: Hazardous waste storage and disposal. Non-hazardous waste storage and disposal

Potential Impacts:

• Inappropriate containment and disposal of solid waste material from crash sites may lead to land and/or surface water/groundwater contamination and have associated health and safety implications.

• Inadequate containment provisions for solid wastes may result in releases into the environment and OH&S risks.

Monitoring/reporting requirements:

• Waste Management Register (GPS coordinates).

• Collection of waste disposal dockets/transportation documents (if going to commercial licensed landfill).

• Location of solid waste disposal areas recorded on Site Plan and kept up to date.

• During clean-up - Daily visual inspections of stockpiles/storage areas. Issues recorded in daily inspection forms and rectified.

• During clean-up - Formal weekly inspections of solid waste storage areas and findings recorded on weekly checklist.

• Induction & training records.

• Laboratory analysis reports.

Table A.1 Waste Action Plan

Environmental Management Requirement Responsibility Timing/Frequency

Preparatory Activities

Develop and review procedures for storage, handling and management of wastes (both hazardous and non-hazardous).

SEA/REO Annually

2 Ref: 327109: 00|01 September 2005 Appendix A



Environmental Management Requirement Responsibility Timing/Freque

ncy

Identify/maintain register of local suitably qualified consultants and contractors SEA/REO Annually

Identify (discretely & sensitively) availability of commercial facilities to accept crash debris and associated hazardous materials and the handling and transport requirements of such facilities

SEA/REO

Annually

Identify/revise suitable locations for on-site disposal if necessary and plan with Base Commander to ensure such areas are not taken over by other priorities

SEA/REO

Base Commander

Annually

Ensure waste containment and waste control provisions are planned/ in place in readiness. Base commander Annually

Provide adequate training to all site operators and personnel responsible for handling wastes. Base commander Annually

During clean-up Activities

Ensure non-ACM hazardous materials (eg. Radio-active material, armaments etc) are cleared and removed in accordance with waste management practices

SEA/REO Prior to ACM clean-up work

Ensure waste containment facilities are readily available and accessible. Supervisor Daily

Ensure adequate identification and segregation of contaminated and non-contaminated waste. Stockpiles to have appropriate protections and run-off controls

SEA/REO

Contractor

Daily

Ensure materials for waste is stored in appropriately bunded and roofed storage areas. SEA/REO/ Supervisors/ Operator

Weekly

Ensure clean-up, validation and restoration of all affected crash site locations SEA/REO As soon as possible after crash event - until complete

Ensure no burial or disposal of solid waste (both hazardous and non-hazardous) on-site. SEA/REO/Base Commander

Weekly

Ensure hazardous waste is handled and transported by appropriately licensed contractors. SEA/REO/Base Commander

Weekly



Environmental Management Requirement Responsibility Timing/Freque

ncy

Maintain information relating to waste management, including type, quantity, disposal method and waste transport documentation in a waste management register. Provide report to SEA/REO.

SEA/REO Weekly

Maintain waste transport documentation for all hazardous waste transported and disposed off-site and provide report to SEA/REO.

SEA/REO Weekly

Store and dispose hazardous waste according to relevant guidelines. SEA/REO Weekly

Implement and review housekeeping practices on-site. Supervisor Weekly

Ensure any liquid waste is stored in appropriate container with secondary containment provisions.

Supervisor Daily

Post clean-up Activities

Ensure nature, quantity, source location and other details of waste are recorded on site and sealed in with any buried waste

SEA/REO Prior to final burial

Identify and prepare post-crash investigation site SEA/REO Prior to moving to investigation location




Air Quality

Objective: To have no impact on existing air quality

Targets:

• Zero complaints

• No adverse health impacts

• No adverse environmental impacts

• Minimal dust generation from burning, cleaning, transportation, maintenance and other related burning activities.

Aspects: Burning Dust generation

Potential Impacts:

• Impact on aesthetics.

• Irritation or disturbance to neighbouring properties and other sensitive receptors.

• Release of air pollutants into atmosphere

• Adverse health effects (respiration of particles and pyrolised products)


• Corrective actions/maintenance records.

• Record of complaints.

• Record of incidents.

Table A2 Air Quality Action Plan



Know site history, prevailing wind directions by time of day/season and potential for presence of ACM prior to authorising ECC’s for disposal/disturbance activities

SEA/REO Prior to issue of ECC

Ensure dust suppression resources are provided on-site if dust generating activities are expected to occur during a disturbance / disposal activity.

Supervisor Daily

Inspect all pollution control equipment and ensure all equipment is in place and adequately functioning. Implement corrective action if maintenance issues identified.

Supervisor Daily




During Clean-up Activities

Prevent helicopter activity within 500m of the crash site to avoid rotor wash disturbance

SEA/REO/Base Commander

At all times

Ensure machinery to be used has HEPA filters SEA/REO/Contractor Prior to commencing clean-up

Apply fixants and soil tackifiers to waste material as soon as cool enough to do so Fire Controller As soon as material cooled to less than 150oC

Minimize walking, working, or moving materials to reduce airborne particulates, fibres and dust until fixants applied

Contractor At all times

Ensure all activities are undertaken from up-wind. If crash fire occurs, evacuate areas downwind in the smoke plume/fall-out zone

SEA/REO

Fire Control officer

Throughout fire

Keep dust-generating activities to a minimum during dry and windy conditions. Cease all works that have the potential to generate dust in excessively windy conditions and/or use fine water mist sprays to suppress the dust.

Supervisor When required

Minimise clearance burning of vegetation in crash zone and if necessary, keep fires as ‘cool’ as possible

Supervisor Throughout operation

Ensure all pollution control devices/equipment are operational Supervisor Daily

Post Clean-up Activities

Undertake ‘emu bob’ to verify clearance of ACM, repeat soil scraping or hand picking as necessary

SEA/REO

Contractor

Prior to validation testing

Ensure transported material is completely plastic wrapped and sealed Supervisor Daily

Ensure stockpiles/waste storage areas are stabilised and appropriately covered. Supervisor When required

Ensure disturbed land areas are stabilised to prevent air borne dust. Supervisor When required

Maintain records of any air quality related complaints and report to SEA/REO. Supervisor Monthly




Noise and Vibration

Objective: To minimise impact of noise on environment, workers and community.

Targets:

• No noise complaints.

• No vibration complaints.

• No impacts on sensitive environmental receptors.

• Noise levels comply with relevant guideline, license or permit requirements/limits.

Aspects: 24 hour clean-up/investigation activities Excavation of disposal locations Transportation activities

Potential Impacts:

• Adverse noise impacts on nearby residents and sensitive receptors (including environment)

• Noise complaints. Monitoring/reporting requirements:

• Noise monitoring results.

• Records of complaints.

• Reports on site inspection and observations.

Table A3 Noise and Vibration Action Plan



Schedule delivery of all reasonable resources required for clean-up during daylight hours

SEA/REO

Contractor

Preparations

Ensure any clearance disposal/disturbance activities are in compliance with relevant noise guidelines. Where no guidelines are in place or noise levels are unknown, initiate discussions with relevant State or Territory environment protection authority.

Supervisor/SEA/RE/ Base Commander

When required.

Carry out noise compliance checks on all major equipment (including pollution control devices) to ensure the noise emission levels meet the relevant Australian standards. Repair or remove noisy equipment from the site if noise levels are exceeded.

Supervisor/SEA/REO Weekly


Maximise use of daylight hours to undertake clean-up – avoid night-time work SEA/REO/Contractor Daily

Conduct boundary noise monitoring if applicable SEA/REO/Supervisor During clean-up




Post-Clean-up Activities

Maintain records of and follow-up any noise complaints SEA/REO/public relations officer/ Supervisor

Following clean-up activity




Erosion, Sedimentation and Runoff

Objective: To prevent erosion and sedimentation caused by clean-up works To prevent impacts on soil, surface water bodies and stormwater systems.

Targets:

• No loss of soils as a result of erosion.

• No runoff from grounds with potential to cause contamination of surface water bodies.

• No sedimentation of waterways and stormwater systems. Aspects:

• Ground disturbance.

• Discharges to land.

• Heavy rainfall.

• Waste stockpiling.

Potential Impacts:

• Soil contamination.

• Soil erosion.

• Sediment/ACM contaminant transport and deposition in waterways or other land areas.

• Loss of vegetation. Monitoring/reporting requirements:

• Status of erosion control measures.

• Records of regular visual inspections of discharge points and exposed work/operational areas.

• Records of identified areas with erosion and/or sedimentation impact.

Table A1 Erosion, Sedimentation and Runoff Action Plan



Know the soil physico-chemical properties of the region and assess suitability/risk regarding recovery activities and suitability for use as disposal site

SEA/REO Preparatory exercise


Develop an Erosion and Sedimentation Control Plan (ESCP) for implementation during clean-up activities. The ESCP should include:

• Measures for the minimisation of erosion and sedimentation arising from earthmoving activities.

• Controls to prevent contaminated runoff leaving the site and/or entering stormwater systems and surface water bodies.

• Controls to direct clean runoff around the crash site areas.

• Requirements for vegetation rehabilitation and/or preservation in high erosion areas.

Supervisor/ SEA/REO

Prior to commencement of clean-up activities.




Ensure all waste storage areas, chemical storage areas and areas in which chemicals are used are bunded and covered to avoid contaminated surface runoff.

Supervisor Daily

Lightly spray grounds (with water or soil tackifiers) where erosion and dust generation is likely

Supervisor Daily

Ensure sediment and erosion control/flow retardation provisions are not damaged and remain in place.

Supervisor Daily


Ensure any areas where vegetation clearing and erosion is occurring is identified, marked on a map (with AMG coordinates), monitored and continually updated.

SEA/REO Quarterly

Ensure identified areas where vegetation clearing and erosion is occurring is rehabilitated and effectively managed.

SEA/REO/

Supervisor

When required

Collect contaminated sediment, dewater and dispose of with other ACM waste Contractor Prior to final closure of disposal location

During periods of rainfall greater than 20mm per day, inspect all erosion control facilities and equipment.


Stabilise soils as soon as practicable after disturbance. Supervisor After disturbance

Progressively rehabilitate all disturbed/eroded areas to the extent practicable. SEA/REO/

Supervisor

When required




Chemical Storage & Use

Objective: To prevent any adverse environmental impact arising from the storage and use of chemicals (including AFFF, fixants, dangerous/hazardous substances). To ensure all chemicals are stored and used in a safe and compliant manner.

Targets:

• No spills, leaks or overflows.

• No runoff from chemical storage areas into surface water bodes and stormwater systems.

• Compliance against relevant chemical storage guidelines, licenses and permitting requirements.

Aspects:

• Storage of chemicals.

• Use of chemicals.

• Transportation and vehicle movement.

Potential Impacts:

• Soil, groundwater and/or surface water contamination.

• Stormwater contamination.

• Impact on flora and fauna.

• Impact on human health.


• Maintain an incident database.

• Maintain material safety data sheets (MSDSs).

• Record of volumes stored and used.

• Records of licences, approval or permits relevant to the storage, handling and use of chemicals.

• Environmental monitoring results (including soil, groundwater, stormwater, and/or surface waters)

• Inspection records of chemical storage areas and related equipment.

Table A5 Chemical Storage & Use Action Plan

Environmental Management Requirement Responsibility Timing/ Frequency


Ensure fixants and soil tackifiers are kept on premises/kept by appropriate personnel for use in the event of a crash

Base commander

Annually

Ensure only the required quantity of fuel or chemicals is made available at the site. Supervisor When required

Ensure fuels are stored in an appropriate containment unit with secondary containment provisions.

Base OHS officer

Daily

Conduct inspection of all chemical storage areas and associated equipment. Maintain records of inspection outcomes.

Supervisor Weekly



Environmental Management Requirement Responsibility Timing/ Frequency


Provide and maintain MSDSs in all chemical storage areas and at points of use. SEA/REO/ Supervisor

When required

Ensure all liquid/chemical waste is stored in an appropriate and sealed container and within a concrete bunded area.

Supervisor As required

Ensure any spills or releases of chemicals are contained and removed as soon as possible using provided spill containment facilities.

Supervisor As required


Ensure any waste chemicals are disposed off-site in accordance with relevant requirements. SEA/REO/ Supervisor

As required

Ensure any chemical spills or releases are contained and cleaned up. Supervisor As required




Surface Water Quality

Objective: To manage crash site clean-up such that impacts on surface water quality is minimised. To protect the beneficial uses of the receiving waters.

Targets:

• No complaints relating to water quality.

• No impact on the beneficial uses of surface waters.

• No release of chemicals or waste from crash site or clean-up activities into surface water bodies.

Aspects:

• Accumulation of crash debris in creek-lines/waterbodies

• Discharges and surface water runoff into local surface water bodies.

• Accidental discharges or releases from burning grounds during operation.

Potential Impacts:

• Rainfall and surface water run-off from crash site discharging to water bodies and adjacent environments.

• Turbidity, silting and contamination of water courses.

• Degradation of water course habitat.

• Contamination of surface water from accidental release or overflow of hazardous materials (such as fuels).


• Visual inspections of discharge points and observations recorded.

• Maintain an incident database.

• Maintain a complaints database.

• Points at which runoff and or discharge into surface water bodies are likely to occur.

• Equipment inspection and maintenance reports.

• Monitoring results from points of discharge to surface water environments.

• Water quality test results (both input and output water quality).

Table A6 Surface Water Quality Action Plan



Ensure all containment and control provisions are in place and are not damaged. Supervisor Preparatory activity

Understand watercourse, water quality and downstream users SEA/REO Preparatory activity


Deploy booms downstream in affected water-courses, remove debris as soon as possible. Notify potentially effected downstream users.

SEA/REO

Contractor

As soon as possible after crash if relevant




Ensure water and/or fire retardant chemicals (where used) are confined to specific areas and no surface runoff occurs, where practicable.


Store all chemicals, oils, fuels stored on-site within a bunded area. Spill kits must be located in these areas.

Supervisor Prior to storing fuels/oils


Ensure routine water quality sampling and analysis is conducted at all points of discharge into the environment. Results should be assessed against relevant guidelines, license or permit requirement.

SEA/REO As required and in accordance with relevant monitoring plans and after rain




Soil and Groundwater Quality

Objective: To protect the beneficial uses of soil and groundwater.

Targets:

• No adverse impacts on the groundwater quality.

• No change to structural integrity of existing structures.

• No adverse impacts on the land environment. Aspects:

• Discharges to land.

• Deposition of solid and liquid waste from crash debris disposal.

• Leaching from buried waste.

Potential Impacts:

• Contamination of groundwater.

• Contamination of soil.

• Vegetation loss.


• Sampling and analysis of soil and groundwater.

• Visual inspections of land to identify any areas of potential concern.

• Record of environmental sampling results.

Table A7 Soil and Groundwater Action Plan



Conduct visual inspection of land areas where discharges have/are occurring and record any signs of water logging, salinity, vegetation loss, discolouration, staining, odour and other evidence of potential contamination.

SEA/REO Annual review

Conduct groundwater sampling and analysis from any existing groundwater monitoring wells in the area, where applicable. Review records/install groundwater bore to understand groundwater quality and quantity and location of aquifers.

SEA/REO When required (in accordance with an implemented groundwater monitoring plan)


Select any disposal location carefully to avoid potential interface with groundwater table at any time if possible.

SEA/REO

Contractor

Prior to disposal

Use water for extinguishing fires, where possible. Supervisor When required




Monitor depths of recovery activities to avoid interface with groundwater SEA/REO

Supervisor

During removal of material from crash site

Use suitable sealed containers and plastic wrap and duct tape seal ACM contaminated components before disposal on site or at licensed landfill to prevent leachate issues

SEA/REO

Contractor

During clean-up and Prior to disposal

Store all chemicals, oils, fuels stored on-site within a concrete bunded area. Spill kits must be located in these areas.

Supervisor Prior to storing fuels/oils

Post- clean-up activities

Conduct visual inspection of crash site and record status following clean-up. Make comparisons with baseline annual statusing and implement any corrective or preventative actions.

SEA/REO Monthly after completion of clean-up for 12 months then review

Continue monitoring of groundwater and report any changes in status. SEA/REO When required and identified by environmental consultants/professionals.




Flora and Fauna

Objective: To minimise disturbance to flora and fauna. Minimise impacts on terrestrial and marine/aquatic flora and fauna. Minimise the propagation and abundance of noxious weeds and feral animals Preserve the natural and cultural heritage environment

Targets:

• No harm to sensitive areas or detrimental change to flora and fauna.

• Minimal damage or destruction of vegetation.

• No spread of existing, or introduction of new, weed species.

Aspects: � Vegetation clearing (manual and burning) � Burning activities causing land disturbance

Potential Impacts: o Destruction of habitat. o Introduction or proliferation of noxious or environmental

weeds. o Permanent loss or damage to vegetation or fauna.

Monitoring/reporting requirements: � Site Inductions � Waste Management Register � Visual inspections. Issues recorded in diary and rectified � Site Plan/aerial photographs � Record of burning activities conducted. � Flora and fauna register on site

Table A8 Flora and Fauna Action Plan



Identify procedures for management of injured wildlife/stock in the event of discovery at a crash site

SEA/REO Preparatory activity


Manage injured wildlife humanely and in accordance with pre-determined wildlife management procedures (eg. Contact with WIRES or local veterinarian)

SEA/REO Contractor

In the event injured fauna encountered




Undertake any burning activities for vegetation clearing with caution and consideration of liberating ACM and of the effects of fire regimen for native vegetation regeneration cycles and spreading of weeds

SEA/REO/ROSCO Contractor Fire Control Officer

Prior to clearance burning to improve ACM recovery activities

If threatened flora and fauna is identified on-site at any time, advice should be sought from the relevant authority with respect to appropriate action to ensure control and/or minimisation of potential impact. Any required permit/consent(s) shall be obtained and shall be accompanied by appropriate supporting documentation.

SEA/REO Base Commander

When required.

Post- clean-up activities

Any areas identified as having been impacted should be rehabilitated and revegetated, as appropriate and as soon as practicable. Endemic species should be used.

SEA/REO Contractor

When required.

Inspect all mature trees and other vegetation on-site and records signs of damage, degradation and/or loss. Maintain logs of all inspections and implement corrective actions where degradation or damage has been identified.

SEA/REO Contractor

Immediately after crash

All weed removal is to be undertaken in accordance with relevant state environmental policies or guidelines.

Contractor When required

Weed debris and weed-contaminated debris is to be disposed of at an approved waste management centre.

Contractor When required


Appendix B Environmental Actions Table

September 2005 Ref: 327109: 00|01 1 Appendix B


Environmental Actions Table

Item

No.

Issue/Activity Responsibility Frequency Reference Record Notes

1 Environmental Inspections

Environmental aspect base-lining

SEA/REO/Ranger Weekly Section 5.1 Environmental Inspection

Checklist

Regular surveillance of sites to be undertaken to

ensure suitable baseline information and to assess

adequacy of environmental management measures.

2 Review of crash site risk at base and

preparedness review

SEA/REO

Base Commander

Annual Section 4 Site contingency planning and

Standing Orders

Annual review of site resources, training and

documentation to ensure site can respond quickly

and appropriately in the event of a crash

3 Environmental Manager’s Guide

Review

SEA/REO When required Section 6.1 Revised guide Document to be reviewed as and when new

information that is robust and verifiable comes to

hand regarding improved management of ACM

4 Environmental Legislation Register DoD

Environmental

Manager

On-going Section 3.2 Review and refer to on-line legislative tools to

identify any changes in legislation at least on a

monthly basis.

5 Construction EMP and or ECC

Approval

SEA/REO Prior to any

ACM clean-up

works or

associated

processes

Section 4.2 Letter or similar ECC to be submitted to SEA/REO prior to any

contractor works regarding ACM clean-up

CEMP to be submitted to DoD for approval.

6 Work Method Statements/ Job Safety

Environment Analyses

SEA/REO/

Contractors

Prior to any

ACM clean-up

works or

associated

processes

Section 4.2 File records of WMS/JSEA

signed by actual workers,

SEA/REO, and site

supervisor/contractor as a

minimum

Preliminary assessment of proposed works to be

prepared prior to commencement and setup and

implement proposed controls in accordance with

DoD environmental requirements before works

commence.

7 Environmental Risk Assessment

(Subcontractors)

SEA/REO At planning

and design

phase

Section 4.2 Report Format Environmental risk assessment to be conducted by

environmental professionals at the onset of the

project.

8 Environmental Incident All As required Section 5.5 Incident Report Form Report major incidents to SEA/REO. An incident

investigation to be conducted and written report

compiled.

2 Ref: 327109: 00|01 September 2005 Appendix B



Item

No.

Issue/Activity Responsibility Frequency Reference Record Notes

9 Maintenance Inspections Contractor Daily with

weekly report

Section 6.5 Maintenance Inspection Record

Sheet

Results from routine preventative and corrective

maintenance activities should be recorded in

Maintenance Inspection Record Sheets.

10 Corrective Actions SEA/REO Weekly Section 6.4 Corrective Action Record Sheet Corrective Actions to be recorded and distributed

for actioning by nominated dates and signed off

when completed.

11 Environmental Audits SEA/REO As per audit

schedule

Section 6.2 Audit Schedule Audits of environmental performance and

compliance with stated procedures/approvals to be

conducted in accordance with schedule.

12 Community enquiries/complaints Media liaison

officer (with input

from SEA/REO)

As required Section 5.4 Complaints Register Enquiry/Complaints pro forma to be completed.

13 Air quality management SEA/REO/Contract

or

As required Appendix A Environmental Checklist Implement air quality improvement or mitigation

measures as detailed

14 Noise management SEA/REO/Contract

or

As required Section 6,

Appendix D

Environmental Checklist Implement noise mitigation measures as detailed.

15 Waste management and recycling SEA/REO/Contract

or

As required Section 6,

Appendix A

Environmental Checklist Implement waste management measures as stated.

16 Waste material tracking SEA/REO/Contract

or

Weekly Section 5.5

& Appendix

A

Waste Management Register Complete form and submit to SEA/REO weekly.

17 Surface water quality management SEA/REO/Contract

or As required Appendix

A& D

Environmental Sub-plans and

Checklist

Implement measures as required.

18 Groundwater management SEA/REO/Contract

or As required Appendix A

& D


Checklist


19 Soil and Groundwater quality

management

SEA/REO/Contract


& D


Checklist


20 Flora and Fauna SEA/REO/Contract


& D


Checklist



Appendix C Site Containment Characteristics for

ACM disposal locations

September 2005 Ref: 327109: 00|01 1 Appendix C


Aspect Question to ask prior to

establishment Ideal criteria

Soil Type What is the regional soil type for the site?

Low permeability soil. Typically soils with higher clay content tend to be low in permeability.

Hydrogeology What is the depth to groundwater in the areas? What is the status of groundwater quality below the proposed site?

Locations with depths to groundwater greater than 8 m is preferable, however an assessment of vulnerability of the groundwater environment must be made with consideration to the current condition of groundwater quality and the geological characteristics. ACM burial areas should ideally not come into contact with local groundwater.

Topography What is the positioning of the site? Is there a surface waterbody proximal to the site? What is the location of the waterbody relative to the proposed site? Are there any sensitive land uses (wetlands, schools, residential premises etc) proximal to the proposed site? Is there a buffer zone between the proposed site and neighbouring land users?

Sites on well draining higher ground No surface body in immediate vicinity of proposed site. Where there is a surface body it is located up-gradient to the site. No or minimal sensitve land users and receptors proximal to the proposed site. An adeqaute buffer zone (roads, large distance, dense trees along boundary etc) between proposed site and neighbouring propoerties.

Drainage Which direction does the site drain? What is the receiving environment from the site surface run-off?

Site surface run-off ideally should not drain into sensitive receptors such as wetlands or other environmentally signifciant areas.

Rainfall What is the annual rainfall in the region? High/average/low?

Rainfall will influence the levels of ground saturation. Consider seasonal wet and dry periods and avoid flooding and periods of saturation at the burial location.

Wind What is the prevailing wind direction in the proposed area.

Ideally burial locations should be located down wind from other site uses such as base offices, townships, school, residential properties etc.

2 Ref: 327109: 00|01 September 2005 Appendix C





Access Is there provision (existing or potential) for adequate access to and from the site? What are the main access ways to the proposed site?

There should be adequate provision for defined access ways to prevent/minimise environmental disturbance and impact. Major access ways and routes to and from the proposed site should typically be away from high residential traffic areas.

Waste facilities Is there existing infrastructure for waste storage, handling and disposal? Is there sufficient space for installation of necessary waste storage areas (both hazardous and non-hazardous)? Is there sufficient room for expansion?

Waste storage, handling and disposal facilities and systems available. Sufficient space with suitable buffer zone from other activities and land users. Other events may occur and it will be best to co-locate the debris in adjacent cells. Ensure the site provides capability for expansion without requiring expansion and impact on sensitive surrounding aspects.

Vegetation What is the status of vegetation cover across the proposed site? High density/medium density/sparse? Are threatened species affected? Are noxious weeds present?

An area with low density – sparse vegetation is preferred for the management of erosion issues. Minimal disturbance to the land is preferrable. No impact/clearing of native species. Prevent re-vegetation by noxious weeds.

Fauna Are there any protected or sensitive flora and fauna in the proposed areas?

No protected or sensitive flora and fauna.

Noise What are the background noise levels in the proposed area?

Excavations and material movement is to be undertaken so that any noise generated is not audible outside the property boundary and/or is within permissable limits relative to the background noise levels.

Heritage Does the proposed site have any heitage or cultural significance?

No disturbance of heritage or cultural significance.

Neighbours What is the nature of the activities conducted on neighbouring properties?

Ideally activities are similar in nature (ie. Commercial or industrial) and no sensitive uses (such as residential).

Commonwealth requirements

Are there any specific Commonwealth requirements or restrictions associated with the proposed site?

No Commonwealth restrictions or requirements associated with the site.

September 2005 Ref: 327109: 00|01 3 Appendix C




State/Territory requirements

Are there any specific State or Territory requirements or restrictions associated with the proposed site (such as areas of state significance etc).

No State or Territory restrictions or requirements associated with the site.

Local requirements

Are there any specific local requirements or restrictions associated with the proposed site (such as council planing restrictions).

No local restrictions or rerquirements associated with the site.


Appendix D Environmental Inspection Checklist for

Aircraft Crash Site Management

September 2005 Ref: 327109: 00|01 1 Appendix D


Environmental Inspection Checklist

Carbon Fibre Management at Aircraft Crash Site: Work Area: Weather: Date / /

Acceptable

Item

Issue Yes

No

N/A

Comments/Remedial Actions

Flora and Fauna Management

Wildlife management procedures in place

Protection fence around preserved vegetation

Health and condition of vegetation

Clearance burning appropriate

1

No animals/birds nesting/found on site

Erosion/Sedimentation / Water Control

Effectiveness of sediment controls (silt fences, etc)

Soil/waste stockpiles in designated locations, away from water bodies, contained and identified.

Cut-off and diversion drains in good condition

Stockpiles stabilised

Wheel wash/vehicle decontamination bay effective

2

Collected contaminated sediment appropriately disposed

Water Quality

Quality of any offsite water discharges or runoff

Controls in place to prevent contamination of waterbodies

Use of AFFF and other chemicals minimised

No oil spills or significantly or newly stained soil

De-watering in controlled manner

No visible oil sheen on water

3

Deployable floating booms available

Dust control / Air Quality

Use of fixants and soil tackifiers or water sprays as necessary

Helicopters and other dust generating machinery avoided

Vehicles fitted with HEPA filters

No visible dust at disturbed areas

Work approaches from upwind/downwind receptors protected

Minimise/avoidance of burning activities

Dust controls available

4

Trucks covered

Noise Emission

No excessive noise from plant

5

Machinery turned off when not in use

Waste Management

Clearance obtained for non-ACM hazardous waste

Identify off-site commercial waste disposal location

Identify suitable on-site waste disposal locations

Waste management materials and resources in place

6

Disposal locations, transporters, contractors and personnel appropriately experienced, licensed and trained

2 Ref: 327109: 00|01 September 2005 Appendix D



Acceptable

Item

Issue Yes

No

N/A

Comments/Remedial Actions

Bin/Skip capacities (i.e. emptying required?)

Waste materials disposed of correctly

Clean topsoil stockpiled for restoration

Validation reporting obtained prior to returning to original operation

Waste information sheet sealed with buried waste

No litter remaining on site after clean up

Fuels/Chemicals

Fixant and soil tackifiers kept on site in readiness

Spill kits – check contents

7

Fuels/Chemicals (not in use) stored in bunded area with MSDSs available

Amenity (Community)

Downwind/downstream receptors notified

Media informed of accurate information through appropriate internal channels

8

Signage in place where required

Contaminated Soil

Contaminated soil appropriately stored/stockpiled

Material tracking records up to date

9

Validation records for all new materials to site

Heritage 10

Aboriginal/European heritage items encountered notified to appropriate authority

Close Out ڤ Remedial Actions Completed and Closed

Out

Name: Signed: Date: / /


Appendix E Case Study of Environmental

Management of Aircraft Crash Site Management at DoD facility

September 2005 Ref: 327109: 00|01 1 Appendix E


CLASSIFIED INTERIM GUIDANCE – IMMEDIATE RESPONSE TO IDENTIFIED CARBON FIBRE (CF) HAZARD AT DELAMERE RANGE FACILITY (DRF) Prepared by CH2MHILL Australia as guidance for Delamere Range Facility, NT – May 2005 1. PURPOSE:

To provide rapid initial guidance in relation to the management of the immediate

environmental and occupational health and safety issues arising from identified

Carbon Fibre (CF) hazards at the Delamere Range Facility (DRF), NT.

2. BACKGROUND: Carbon fibre (CF) contamination has occurred as a result of debris from various aircraft crashes either at the DRF, or as a result of debris being relocated to the Range.

Figure F.7.1 Example of Carbon Fibre contamination at Delamere

While remediation of the Range has been performed over a number of years, it is apparent from inspection of the area of concern (PAPA1) that CF is still present in significant quantities at the surface. This CF hazard has a potential to pose an unacceptable risk to the environment, including Defence personnel involved with the Range’s ongoing management. While a long-term strategy is required to address the identified CF problem, an urgent immediate response has been prepared to prevent any potential for exposure of the CF to the Range staff.

3. SUGGESTED CF MANAGEMENT STRATEGY: Management strategies for the remediation of areas containing carbon fibre (CF) at DRF are presented in four (4) stages. Stages 1 and 2 should be implemented immediately and stages 3 and 4 as soon as possible: Stage 1 – avoidance of further disturbance Avoid disturbance of the areas within PAPA1 in which CF has been identified. Disturbance includes most notably the use of the current drag bar procedures, but

2 Ref: 327109: 00|01 September 2005 Appendix E



also includes other vehicle disturbance and, where possible, further bombing disturbance activities. The area identified as containing exposed CF is approximately a 90 degree sector from the 6 o'clock (180 degrees) position clockwise through to 9 o'clock (the 270 degree) position where the target tank is located at the centre of the clock/circle. If possible, practice bombing should be relocated to an area to the east of the Tank Target in PAPA 1, or to ROMEO 2, until final remedial works and validation (as further outlined below) are completed. Where use of PAPA1 and drag-bar activities must be undertaken, restrict this activity to an arc of 270 degrees, from the 9 o'clock position (270 degrees) in a clockwise direction through to the 6 o'clock position (at 180 degrees). The use of drag bar or other disturbance in the affected sector will only serve to further spread and fragment the CF on the surface and increase the risk of exposure and potentially exacerbate subsequent clean-up requirements. Stage 2 – change to defined bombing area If bombing use of PAPA 1 cannot be avoided, it is suggested that if possible, the central tank target and the reflective targets be moved no less than 75 meters to the east of their present position to minimise the likelihood of bombs disturbing the affected sector. This relocation may permit the practice of drag barring of bombed areas to continue with minimised risk of further disturbance of the CF present on the soil surface in the identified CF impacted area (to the south west of the Tank target) Stage 3 – immediate removal of CF impacted area within PAPA1 Remove the existing surface debris from PAPA1. Appropriate detailed work-planning, PPE, training, isolation/exclusion, as would be used for handling asbestos materials, should be developed and adopted. The methodology to be used would be along the lines of the following:

• Preparation of detailed work plans and OH&S plans for approval prior to implementation of any works;

• Preparation of the work area with appropriate Exclusion Zones, monitoring, management, etc.;

• Prepare suitable plastic lined shipping container(s) to receive the material and locate these immediately adjacent to the area where material will be scraped to. The plastic within the container should form a complete seal around the material placed inside it through use of duct tape or similar at joins.

• Scrape a (nom.) 50mm layer (or otherwise defined based on further investigations) from the surface in the affected sector. This may be limited to a distance from the target tank of approximately 75-100 meters (the extent of the existing drag bar circles). The use of an excavator rather than a grader is recommended to ensure any CF fragments are not compacted further before being scraped. Where possible, machinery cabins should be fully enclosed and air-conditioned preferably with HEPA cabin filters;



• A note on fuel reduction burning: Whilst this practice may degrade existing CF further to smaller potentially more respirable fibres, it may be necessary to perform a fuel reduction burn to enable an effective collection of surface material without unnecessarily gathering large volumes of vegetation and increasing the area required at the new storage location. Fires should be carefully controlled using appropriate authorisation and supervision. Typical grass fires approach 750oC and should not adversely affect the properties of carbon fibre. Extremely hot fires are to be avoided;

• Place the scraped soil material containing the CF fragments into the plastic lined shipping container(s);

• Undertake a detailed 'emu bob' of the contaminated sector to remove any residual material remaining from the scraping and report on site’s inspected surface. Collected materials should be placed in the shipping containers with the other material. This procedure should be monitored by a suitably experienced environmental consultant and where instructed, it may be necessary to scrape further material until no residual material is evident. This emu bob should, as a minimum, be extended beyond the 75m drag bar radius out to 200m from the target tank within the 180-270 degree sector;

• Prepare a weatherproof/laminated information sheet that can be sealed inside the container with the material that identifies its nature, volume, date of disposal, coordinates of origin;

• Seal the information sheet in the container with the sealed material;

• Move the container to the new disposal location north of Range Control (see separate notes on this area). Use of the filled shipping containers to form the perimeter of the underground cell. This serves to provide an effective and readily demarcated area of steel shipping containers that can be easily detected after burial using electro-magnetic techniques which will safeguard any loss of data or records and make any future recovery a more simplistic operation. The shipping container perimeter would form an internal void which would be filled with the other material recovered from the crash site. This would include CF and aircraft debris material covered following a thorough scan of the scraped quadrat for residual materials. Once complete the disposal location would be buried with at least 1m of clean compacted cover over the top restoring to existing surface grade;

• Record and map the coordinates of the extent of each container. Provide these details and a copy of the information sheet to the REO and retain a copy on site.

Validation should be undertaken and documentation received before active use of this sector is resumed. Stage 4 – Longer Term Management In the longer term, but as soon as possible, it is recommended that the two mass burial locations within PAPA 1 be relocated to the new disposal location. Their current location within an active bombing range and subject to the range maintenance practice of drag barring has a high likelihood of this material being re-exposed over time, particularly given their burial depth of 0.3 - 1.0m. Exposure will result in a




recurring problem at this location with likely interruptions to bombing practices and possible exposure of CF to range personnel. The procedure for relocation of the buried material in PAPA1 should follow the same general procedure outlined above for surface removal in terms of container preparation, documentation and burial requirements. It is suspected a much greater volume, and hence number of containers will be required to contain this material. It may be necessary to expand the excavation of the material removed beyond the immediate extent visible in the hole (laterally and depth wise) to ensure full relocation of the material. It will be necessary to undertake a final emu bob of the surroundings before final sealing and burial of the containers. The holes should be backfilled with clean compacted fill. Supervision of this activity by a suitably qualified/experienced environmental consultant is strongly recommended. Validation of successful relocation from within the scraped areas including receipt of documentation is recommended before active use of this area is resumed.



CLASSIFIED ADVICE TO RETURN INTERIM CARBON FIBRE (CF) STORAGE AREA AT RAAF BASE TINDAL (FOR POST-CRASH INVESTIGATION PURPOSES) TO ACTIVE USE PURPOSE:

This information is provided as early indicative guidance to REO for release of the interim crash debris storage area within a hangar at RAAF Base Tindal.

INTERIM STORAGE ISSUES FOR REO’S CONSIDERATION: This information includes issues relating to the preparation, selection, use and decontamination of an interim storage facility, such as a hangar used for post-crash investigation and debris interim management. The interim advice outlines four components

1. General preparation and sequencing of activities 2. Pre-transfer phase 3. Transfer phase 4. Post transfer phase

This information is provided to assist REO in development of a rapid response to the crash debris management, noting that a squadron hangar is required urgently for return to Defence capability purposes. It is recommended that this initial information by used to focus the immediate response that is being developed and implemented by other consultants. The REO is welcome to adjust this indicative information to meet the detailed and site-specific requirements of this work. The final works should be cleared defined, implemented and verified by the environmental consultant working on the debris management problem. Finally, it is important to tune the final work to accommodate the level of risk, time and resource constraints and practicability issues. These considerations need to be developed in consultation with the REO and Base Command.

1. GENERAL PREPARATION AND SEQUENCING OF EVENTS: The general site preparation and logistics would follow:

1. Get the right equipment, especially vacs and filters; 2. Prep of area – exclusion zones; 3. Preparation of containers – inspection, seals, labelling; 4. Placement of debris into containers; 5. Careful lifting of groundsheet with duct tape repair of any rips; 6. Remove groundsheet and place into container; 7. Dry vac investigation area; 8. Wet wax wash and wet vac with validation sample collection; 9. Final wash with validation samples; 10. Reporting.

It is recommended that this sequence be confirmed and expressed using a flow diagram.




2. PRE DEBRIS TRANSFER PHASE: This phase estimates the nature and extent of the debris within the storage facility, defines roles and responsibilities, and establishes the equipment requirements for subsequent stages.

a. Roles and responsibilities for effective Chain-of-Command (recommend a simple

organisation chart) DoD (REO to customise)

1. Base Commander a. CSOps Commander b. Disposal Site Manager c. CSIG Base Coordinator

i. SEA ii. REO iii. Transport Group Staff iv. Ops Group Staff

Other 2. Cleaners (HEPA vac’s, replacement liner) 3. Transport Contractor 4. Waste Contractor (qualified contractor for excavation/burial) 5. Environmental Consultant (monitoring/ lab contractor

management/ validation/ report)

b. Definition of Works Exclusion zones (Recommend drawing to define exclusion zones, as per hazmat guidelines)

• Use hazmat/asbestos exclusion zones approach

• Exclusion Zone monitoring and Reporting

c. Personnel and training

• Use asbestos-trained contractors

• Seek ROSCO advice for DoD personnel requirements

d. Typical equipment list (needs to be reviewed and enhanced by consultant, based on final plan):

• Appropriate signage (PPE, hazard, exclusion, authorised personnel, contact information, duration of activity);

• Shipping Container(s) (appropriate for task);

• Containment media (heavy duty plastic wrap, duct tape, spill kit, drain covers/isolation, perimeter bunding);

• Monitoring equipment – see below;

• Vacuum equipment (HEPA capable, wet/dry with removable filters);

• Wash-down fluid (wax mix per USAF guidelines).



Figure F.7.2 Carbon Fibre Containment Materials

e. Internal Hangar Monitoring considerations

• Personal air quality fibre monitoring (per Asbestos code);

• Boundary fibre monitors (stationary monitors);

• Removable HEPA vac filters for validation testing;

• Surveillance and reporting by REO or Consultant or Contractor

f. Stormwater isolation – suggest use of standard spill solation response techniques

g. Air emissions – may not be required, provided internal monitoring is

implemented (item e above) and all works are completed inside covered investigation area.

h. Transfer vessel sizing (volumetric / mass estimations)

The consultant needs to confirm estimated volumes and masses that are currently stored to ensure that adequate shipping containers are ordered and prepared.

i. Transfer vessel containment (internal) An inspection by the consultant of the shipping containers should be completed to ensure that they adequate for the proposed transport and final disposal/containment purposes. This inspection should occur prior to delivery to the interim storage location if possible and the process needs to be clearly documented with approvals.

j. Worker Safety Precautions (H&S) – suggest separate guidance from ROSCO k. Labelling

The labels need to be of a nature and extent that meets with requirements of longevity for the long-term burial and containment. If the containers are subsequently excavated, future DoD personnel should be able to clearly




understand each container’s contents from labelling and documentation that is somehow included with each container.

l. Waste Management including licences, approvals, tracking

The containers need to be labelled to conform to appropriate waste transport regulations.

m. Chain-of-Custody

Standard Chain-of-custody documentation to track the transport and final placement of each shipping container needs to be implemented before commencement of any works.

n. Contingency planning

The pre-debris transfer phase needs contingency planning, primarily associated with the supply and delivery of appropriate equipment.

o. Readiness Report

When the site is ready for the transfer activities, a “readiness report” should be provided to REO to allow approval to proceed to the next phase.

3. DURING DEBRIS TRANSFER

It is suggested that the guidance be updated taking into consideration the following supplementary issues:

1. Prior Equipment checks 2. Sequencing (see Section 1 above) 3. Chain-Of-Custody transfers 4. Pre-works inspection to assess condition of storage area (caulking in hangar

slabs) 5. Confirmation of Transportation Licences, Approvals, curfews 6. Confirmation of adequacy of shipping containers for storage and disposal

uses. 7. Contingency planning

4. POST DEBRIS TRANSFER AT INTERM STORAGE SITE At the completion of the removal of the debris, the interim storage area needs to be decontaminated and released for reuse. It is noted that storage area needs to be released as a matter of urgency for Defence capability purposes and so some suggestions for interim release of the area are noted below.

a. Decontamination

• Slab Decon – see Section 1 on sequencing. (HEPA vac, wet vac, final wash and validation sampling of wash-waters);

• Losses to slab cracks Site inspections should be undertaken to note poor quality seals between slabs in the interim storage area. The potential for CF and other contamination entering these slab spaces needs to be addressed as part of the decontamination program – suggested sequencing should address this risk.

b. Validation of Work Area in interim storage area



• See Section 1 on sequencing – needs to be clearly described by consultant prior to commencement of works.

• Needs to focus on outcome of delivering interim storage area (hangar) back to DoD as quickly as possible with no residual unacceptable risks;

• Needs to be scientifically-defensible validation report.

c. Interim Reuse of Areas

• Placement of interim plastic liner while awaiting validation results Interim storage areas such as hangars may be urgently required for other DoD-related activities. While the best-case scenario for release of the area (hangar) would be to wait for validation results from the lab and the consultant’s validation report, the interim reuse of the area could be enabled by the placement and sticking down of a sturdy plastic liner across the area of concern to allow limited access by suitably briefed DoD personnel.

Once the validation report has been provided, and if it confirms the area as clean, the plastic liner could be removed and disposed of as general waste. In the unlikely event that any problems were identified in the validation reporting, an appropriate contingency plan could be implemented.

Date post:	13-Feb-2017
Category:	Documents
Upload:	vuminh
View:	229 times
Download:	4 times