5. Response to an incident ................................................................................... 12 5.1. Assess ...................................................................................................... 12 5.2. Contain ..................................................................................................... 12 5.3. Notify ........................................................................................................ 12 5.4. Clean up ................................................................................................... 12
6. Review and Improvement of the PIRMP: .......................................................... 13 7. Training ............................................................................................................ 14
A Pollution Incident Response Management Plan (PIRMP) is a statutory requirement for holders of an Environment Protection Licence (EPL). The specific requirement is called for in the Protection of the Environment Operations Act 1997 (POEO Act) and the Protection of the Environment Operations (General) Regulation 2009, (POEO G Regulation). This Pollution Incident Response Management Plan (PIRMP) has been prepared to assist Fulton Hogan and site personnel to report, manage and communicate a pollution incident and to support a coordinated management response in the event that an incident may occur. This PIRMP may be further supported by the Site Environment Management Plan (EMP) and the Site Emergency Response Plan (ERP).
1.2. Introduction
The Eastern Creek site is licenced by the Environment Protection Authority for Crushing, Grinding and Separating, in particular for crushing and resizing of Reclaimed Asphalt Pavement (RAP) for re-use in construction of roads and flexible pavements. The site also houses a laboratory that supports Fulton Hogan’s asphalt manufacturing processes.
1.3. Purpose
The primary purpose of the plan is to identify and manage the risk of pollution incidents, plan the site response to pollution incidents, to facilitate coordination with the relevant response agencies and to communicate to the general community in the immediate vicinity if required. The objectives of the plan are to:
minimise and control the risk, and respond to a pollution incident at the site through the early identification of risks and the development of planned actions to minimise and manage those risks;
ensure timely communication about pollution incidents to site personnel, Environment Protection Authority (EPA), relevant response agencies/authorities and the community who may be affected by the impacts of a pollution incident; and
ensure that the plan is implemented by trained staff, identifying persons responsible for implementing it, and ensuring that the plan is regularly tested for accuracy, currency and suitability.
This PIRMP (plan) applies, as a guide, to all staff involved in the Crushing, Screening or Separating of RAP (Reclaimed Asphalt Pavement) and Fulton Hogan contractors undertaking work on the Eastern Creek site. The plan will be implemented if a pollution incident that causes, or threatens to cause, material harm to human health or the environment should occur. The site is located at Honeycomb Drive, Eastern Creek, NSW and holds Environment Protection Licence Number 494. This plan is to clearly define the requirements of Fulton Hogan to report and respond to pollution incidents in accordance with the POEO Act 1997 and the POEO (General) Regulations 2010.
1.5. Responsibilities
All Fulton Hogan staff and contractors are responsible for cooperating with this plan and, in particular, specific responsibilities identified for specific roles. The plan identifies the general roles and responsibilities of Fulton Hogan staff and sub-contractors on site shall be required to cooperate with and manage pollution incidents in accordance with this plan.
All supervisors and managers are responsible for ensuring that personnel are aware of the PIRMP, the responsibilities, identified for roles where appropriate, and for the training of staff.
QSE Manager is responsible for:
Assisting with advice, reporting and response process;
Ensuring the Plan is made available to all staff responsible for implementing the plan and authorised officers under the POEO Act;
Giving advice on whether environmental incidents need to be reported to external agencies;
Assisting in the notification of pollution incidents to the relevant authorities;
Assistance with the implementation of response actions to pollution incidents when incidents of a certain nature occur;
Ensuring that training responsible for activating about their roles in the plan;
Key environmental legislation relating to pollution incident response management includes:
Protection of the Environment Operations Act 1997 (POEO Act);
Protection of the Environment Operations (General) Regulation 2010; and
Protection of the Environment Operations (General) Amendment (Pollution Incident Response Management Plans) Regulation 2012.
2.2. Guidelines and Standards
Environmental guidelines: Preparation of pollution incident response management plans, 2012.
2.3. Legislative requirements
The specific requirements for pollution incident response management plans are set out in Part 5.7A of the POEO Act and the POEO (G) Regulation. A summary of the key requirements are:
holders of environment protection licences must prepare a pollution incident response management plan (section 153A, POEO Act);
the plan must include the information detailed in the POEO Act (section 153C) and be in the form required by the POEO(G) Regulation (clause 98B);
licensees must keep the plan at the premises to which the environment protection licence relates or, in the case of trackable waste transporters and mobile plant, where the relevant activity takes place (section 153D, POEO Act);
licensees must test the plan annually in accordance with the POEO(G) Regulation (clause 98E); and
if a pollution incident occurs in the course of an activity so that material harm to the environment is caused or threatened, licensees must immediately implement the plan (section 153F, POEO Act).
3. Hazards, Likelihood and pre-emptive actions to prevent pollution incident risks
3.1. Hazards
Bitumen products are manufactured from hydrocarbons with the primary ingredient requiring storage at elevated temperatures to maintain a fluid viscosity. Although bitumen based products are in general terms “non-hazardous” they are potentially harmful to the environment. All storage facilities on site are bunded and the internal water collection system ensures that under normal operating conditions minor and moderate spillages are able to be contained to the site. Fulton Hogan acknowledges that under extreme event conditions, and aggravated circumstances, the potential for a pollution incident, that may result in material harm to the environment, does exist.
Potential hazards that require risk treatment on the site include;
Fire and explosion resulting in air pollution.
Spills, leaks of hydrocarbons, acids and alkalis to ground, stormwater and waterways
Odour emission
Airbourne dust including asbestos
3.2. Pollution Incidents
A pollution incident is defined as follows: “an incident or set of circumstances during or as a consequence of which there is or likely to be a leak, spill or other escapes or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise”.
3.3. Pollution incidents that are to be notified
A pollution incident is required to be notified to the EPA and appropriate regulatory authorities (ARA) if there is a risk of ‘material harm to the environment’, which is defined in section 147 of the POEO Act as: (a) harm to the environment is material if:
(i) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, or
(ii) it results in actual or potential loss or property damage of an amount, or amounts in aggregate, exceeding $10,000 (or such other amount as is prescribed by the regulations), and
(b) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment.
Each of the following response agencies need to be informed of pollution incidents quickly, so action can be coordinated to prevent or limit harm to the environment and human health generally:
Environment Protection Authority (EPA) if they are not the ARA;
Pollution incidents that could potentially occur at the work site and are covered by this plan include:
material, such as waste materials, fuel etc. that travel beyond the site boundary causing or potentially causing adverse impact to the environment or community; and
discharge of waters from site not in accordance with the site Environment Protection Licence condition.
small spills that do not leave the site boundary and are cleaned up without material environmental harm or residual environmental impact are most likely not required to be notified to the EPA or other authorities, however all such incidents are to be recorded and reported in accordance with organisational requirements.
an environmental incident may include a major spillage or leak, failure of a pollution control device such as a bund or basin, major settlement, or catastrophic events i.e. flood or fires.
3.5. Prevention
Fulton Hogan’s approach is to carry out daily work activities in a planned and controlled manner, taking into account potential environmental risks, to prevent pollution incidents from occurring at the site. Preventive measures include:
completion of site specific Workplace Risk Assessments (WRA);
completion of site specific Aspects & Impacts Registers
implementation and maintenance of identified control measures;
compliance with legislative and regulatory requirements, including the site Environment Protection Licence;
implementation of, and compliance with, requirements of the site Environmental Management Plan; and
implementation and compliance with the requirements of this plan.
3.6. Risk Assessment
The risk management approach has been utilised to identify and assess environmental aspects associated with site activities and to identify appropriate mitigation strategies to minimise the likelihood of environmental incidents associated with each aspect. This process involves:
1. Identifying the risk/aspect 2. Analysing the risk/aspect (determining likelihood and consequence) 3. Evaluating the risk/aspect 4. Treating the risk
Aspects are assessed based on the risk assessment matrix and the tables displayed over the page.
Five levels of classification are adopted and described in the Risk Assessment Matrix as:
Insignificant
Minor
Significant
Major
Catastrophic
See below and over the page for Risk Assessment Matrix steps. Step 1 – Assess the potential consequence of the unwanted event (or what could have occurred for an incident):
Potential Consequence
Insignificant Minor Significant Major Catastrophic
Ris
k T
yp
e
Environment No impact on
or off site
On-site impact
requiring routine internal
remediation
Off-site impact
requiring internal
remediation OR on-site
impact requiring
substantial internal
remediation
Impact on- or off-site requiring specialist external
remediation
Impact on- or off-site with long term effect OR requiring
The Emergency Wardens are assigned the responsibility to coordinate and facilitate initial response to an emergency incident in a particular area of the workplace until such time as responsibility is transferred to the Emergency Coordinator (EC) or attending emergency services. Responsibilities include:
Assess the situation;
Isolate / secure the incident;
Ensure Emergency services are notified;
Communicate with staff;
Control all movement in vicinity of the emergency;
Ensure external agencies are directed at site entrances;
Coordinate orderly evacuation of personnel to the designated muster area;
Ensure all personnel are accounted for;
Duties as directed by the EC;
Assist in action required to recover from the incident as required; and
Ensure that the site visitors register is taken to the emergency assembly point.
4.2. Emergency Coordinator (EC)
In the event of an incident within boundaries of the workplace that requires engagement of this Pollution Incident Response Management Plan, the Emergency Coordinator (EC) will assume control. Specific responsibilities of the EC include coordinating or facilitating the following:
Directing tasks of the Emergency Response Team for the duration of the incident / accident or until such time as relevant emergency service provider assumes control of the situation;
If necessary the establishment of the emergency control centre, communication with emergency personnel and external parties and ensure the recording of events and issues as they unfold;
Advise and keep the Workplace Manager informed of the nature, extent and current status of the emergency;
As necessary, advise the Emergency Services of the nature and extent of the emergency and current status;
Advise all workplace personnel of the extent of the emergency/incident outline responsibilities, engage their assistance and delegate tasks when required;
Ensure appropriate medical treatment has been arranged for injured persons;
Ensure that Chemical, Hazardous Substance and Dangerous Goods Registers and manifests are available to Emergency Services if required;
Ensure a register of all Safety Data Sheets (SDS) is available on site;
Assign specific tasks to appropriate personnel to restrict access to the site to all non-essential personnel other than responding emergency services at the nominated site entrance;
The wardens and emergency coordinators for this site are as follows:
EC
PRAVIN NARAYAN
EW
(PRODUCTION)
MARK ABRAHAMS
EW
(LABORATORY)
LUKE REYNOLDS
4.3. Emergency Response Team (ERT)
Eastern Industries have appointed a Divisional Emergency Response Team (ERT) to assist the Emergency Warden(s) and the Emergency Coordinator in managing any significant incident or emergency on site. The ERT will assist the Emergency Wardens(s) and Emergency Coordinator in the management of the incident, internal & external consultation and communication, in action to recover from the incident as required and assist in carrying out the incident investigation. The Eastern Industries ERT for this site is as follows:
METRO DIVISION
RICHARD JENKINS MARK WHEATLEY PRAVIN NARAYAN GM NOMINATION
Continual improvement of this plan will be achieved by the annual evaluation of the implementation of the PIRMP, evaluation of environmental incidents and the testing of this plan. The continual improvement process will be designed to:
identify areas of opportunity for improvement of pollution incident which leads to improved environmental performance;
determine the root cause or causes of non-conformances and deficiencies;
develop and implement a plan of corrective and preventative action to address non-conformances and deficiencies;
verify the effectiveness of the corrective and preventative actions;
document any changes in procedures resulting from process improvement; and
make comparisons with objectives and targets.
Testing of this plan is required to be undertaken, as a minimum, once every 12 months. Testing is to be carried out in such a manner as to ensure that the information in this plan is relevant, up to date, and that the plan is capable of being implemented in a workable and effective manner. The plan will be similarly reviewed within one calendar month of having been implemented and after an unplanned significant incident. Personnel involved in emergency response activities will be provided with specific training. An up-to-date list of emergency response personnel and organisations will be maintained at the main office.
All employees working on site will undergo site induction training and environmental training with the objective of improving awareness and practice of positive environmental management including minimising the potential for pollution incidents and pollution incident response. Environmental training and induction will address:
this plan;
individual responsibilities;
notification requirements;
pollution incident response personnel; and
spill minimisation measures and spill response.
Records will be kept of all personnel undertaking the site induction and training, including the contents of the training, date and name of trainer/s. Key staff may undertake more specific training relevant to their position and/or responsibility. Records will be kept of all personnel undertaking the PIRMP training, including the contents of the training, date and name of trainer/s. Key staff will undertake more comprehensive training relevant to their position and/or responsibility. This training may be provided as “toolbox” training or at a more advanced level by the QSE Manager and/or National Environmental Manager or specified provider/s.
