The Northern Road Stage 5 - Appendix A - Transport for NSW

Document Review

Pos,t,on Name

Project Manager tJ \L (�

CPB Contractors Pty Ltd \.J...Yf}A-Y

Environmental Site Representative Cicror1

CPB Contractors Pty Ltd ;f,A ( ff ( � fl ,,.

Roads and Maritime Environmental Manager

Roads and Maritime Representative

Environmental Representative

Distribution of controlled copies

Copy Issued to

no

1 Project Manager

2 Project Environmental Site Representative

3 Construction Manager

4 Quality Manager

Signature

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Date

••• CPB CONTRACTORS

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A HCHIIIIIOF llllCII-UC GIIOVP

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Title: Construction Environmental Management Plan - The Northern Road Upgrade between Littlefields Road and Glenmore

Parkway

ID: TNR5-EN-MPL-CEMP Version: 3 Date Published: 4/03/2019

Management System - Uncontrolled Document when Printed

Page 2 of 177

Cameron Weller 15/3/19

ttu2

Stamp


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Copy

no. Issued to Version

5 Community Relations Manager

6 Roads and Maritime Project Manager

7 Roads and Maritime Environment Manager

8 Environmental Representative


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Details of Revision Amendments

Document Control

The Project Manager is responsible for ensuring that this document is reviewed and approved.

The Environmental Site Representative is responsible for updating this document to reflect changes to

environmental, legal and other requirements, as required.

Amendments

Any revisions or amendments must be approved by the Project Manager before being distributed /

implemented.


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List of emergency and key contacts

Position Name Phone

*24-hour community

information line

N/A 1800 703 457

*Environmental Site

Representative

(24-hour contact for the EPA)

Ciaran McAleer M 0455 494 163

*Project Manager

(24-hour contact for the EPA)

Nick Fryday M 0424 485 763

*Superintendent Simon Baldwin M 0427 966 968

Community Relations Manager Augusta Goldsmith M TBA

Environmental Representative Cameron Weller

M 0428 271 496

[email protected]

Roads and Maritime Senior

Project Manager (24-hour

contact)

Jeff Gilham 1800 703 457

[email protected]


Environmental Officer

Anthony Eland 1800 703 457

[email protected]


Environmental Officer

Owen Clark 1800 703 457

[email protected]

Roads and Maritime

Community and Stakeholder

Engagement Advisor

Kamini Parashar 1800 703 457

[email protected]

mailto:[email protected]



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Environment Protection

Authority (EPA) pollution

hotline

N/A 131 555

Fire and Rescue NSW 000

(for pollution incidents that

present an immediate threat to

human health or property)

1300 729 579

(for pollution incidents that do not

present an immediate threat to

human health or property)

NSW Police

Penrith Local Area Command

Sergeant Matt Shirvington (02) 4721 9415

The Ministry of Health Wollongong Hospital

252 Loftus Street,

Wollongong

(02) 4222 5000

SafeWork NSW ~ 131 050

WaterNSW ~ 1300 662 077

Penrith City Council ~ 4732 7777

(8.30 am-4 pm weekdays)


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Contents

1. Introduction .................................................................................................................................................. 23

1.1 Context and purpose ........................................................................................................................ 23

1.2 Background ...................................................................................................................................... 24

1.3 Consultation ..................................................................................................................................... 26

1.4 CEMP Acceptance ........................................................................................................................... 29

1.5 Distribution ....................................................................................................................................... 29

1.6 Revision ........................................................................................................................................... 30

2. Project Description ...................................................................................................................................... 32

2.1 Construction Activities and Sequence .............................................................................................. 32

2.2 Compound and ancillary facilities ..................................................................................................... 39

3. Planning ....................................................................................................................................................... 42

3.1 Project environmental obligations .................................................................................................... 42

3.2 Legal and other requirements .......................................................................................................... 42

3.3 Approvals, permits and licensing...................................................................................................... 53

3.4 Environmental aspects and impacts................................................................................................. 54

3.5 Environmental policy and culture ..................................................................................................... 59

3.6 Objectives and targets ..................................................................................................................... 60

3.7 Project refinements .......................................................................................................................... 63

3.8 Ancillary facilities assessment criteria and management plan ......................................................... 64

3.9 Sustainability .................................................................................................................................... 66

4. Implementation and operation ................................................................................................................... 70

4.1 Environmental Management Sub Plans and Strategies ................................................................... 73

4.2 Environmental Work Method Statements and Work Packs .............................................................. 74

4.3 Roads and Maritime-nominated hold points ..................................................................................... 76

4.4 Internal Approvals/Permit Systems .................................................................................................. 79 4.5 Erosion and sediment control plans ................................................................................................. 81

4.6 Working hours .................................................................................................................................. 81

4.7 Environmentally sensitive area plans ............................................................................................... 84

4.8 Resources, roles, responsibilities and authority ............................................................................... 85

4.9 Sub-contractor management ............................................................................................................ 94

5. Competence, training and awareness ....................................................................................................... 97

5.1 Environmental induction ................................................................................................................... 97

5.2 Toolbox talks, training and awareness ........................................................................................... 100

5.3 Daily pre-start meetings ................................................................................................................. 101

5.4 Task-specific Environmental Training ............................................................................................ 102

5.5 Communications Training .............................................................................................................. 103


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6. Communication ......................................................................................................................................... 104

6.1 Internal communication .................................................................................................................. 104 6.2 External and government authority communication ....................................................................... 104

6.3 Community liaison and notification ................................................................................................. 105

7. Incidents and emergencies....................................................................................................................... 111

7.1 Incident and emergency management ........................................................................................... 111

7.2 Incident Notifications ...................................................................................................................... 114 7.3 CPB Contractors’ Safety, Health & Environment (SH&E) Incident Management System .............. 116

7.4 Incident investigations .................................................................................................................... 116

8. Inspections, monitoring and auditing ...................................................................................................... 117

8.1 Environmental inspections ............................................................................................................. 117

8.2 Environmental monitoring .............................................................................................................. 118

8.3 Auditing and reporting .................................................................................................................... 124 8.4 Compliance Tracking Program ....................................................................................................... 130

8.5 Pre-Construction compliance ......................................................................................................... 132

8.6 Construction Compliance Report ................................................................................................... 133

8.7 Pre-Operation Compliance Report ................................................................................................. 133

8.8 Other reporting ............................................................................................................................... 134

8.9 Non-conformity, corrective and preventative actions...................................................................... 150

9. Review and improvement ......................................................................................................................... 151

10. Documentation .......................................................................................................................................... 153

10.1 Environmental records ................................................................................................................... 153

10.2 Document control ........................................................................................................................... 153

Tables

Table 1-1 Consultation requirements .................................................................................................... 28

Table 2-1 Main Phases of Construction ................................................................................................ 34

Table 3-1 Conditions of Approval relevant to CEMP ............................................................................. 43

Table 3-2 Likelihood criteria .................................................................................................................. 55

Table 3-3 Consequence criteria ............................................................................................................ 56

Table 3-4 Risk severity .......................................................................................................................... 57

Table 3-5 Environmental objectives and targets ................................................................................... 61

Table 3-6 Sustainable Procurement Requirements, Objectives and Targets ....................................... 68

Table 4-1 Environmental management sub plans ................................................................................. 73


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Table 4-2 Roads and Maritime hold points ............................................................................................ 77

Table 8-1 Summary of Environmental Monitoring ............................................................................... 119

Table 8-2 Audit Requirements ............................................................................................................. 127

Table 8-3 Compliance Reporting ......................................................................................................... 131

Table 8-4 Summary of Reporting Requirements ................................................................................. 135

Appendices

Appendix A1 Legal and Other Requirements

Appendix A2 Environmental Aspects and Impacts

Appendix A3 Environment and Sustainability Policies

Appendix A4 Document Register

Appendix A5 Initial CPB Project Organisational Chart

Appendix A6 Environmentally Sensitive Area Plans

Appendix A7 Environmental Incident Classification and Reporting

Appendix A8 Group Procurement Policy

Appendix A9 Dealing with Third Parties Policy

Appendix B1 Construction Traffic and Transport Management Plan

Appendix B2 Construction Flora and Fauna Management Plan

Appendix B3 Construction Noise and Vibration Management Plan

Appendix B4 Construction Soil and Water Management Plan

Appendix B5 Construction Heritage Management Plan

Appendix B6 Construction Air Quality Management Plan

Appendix B7 Construction Waste, Energy and Resource Management Plan

Appendix B8 Construction Ancillary Facilities Management Plan

Appendix B9 Construction Community Involvement Plan


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Appendix B10 Construction Contaminated Land Management Plan

Appendix B11 Pollution Incident Response Management Plan

Appendix B12 Other Management Measures

Appendix B13 Construction Sustainability Management Plan


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Acronyms and abbreviations

Phrase Definition

ACM Asbestos Containing Material

Ancillary facility Temporary facility for construction, including for example an office and

amenities compound, construction compound, batch plant (concrete or

bitumen), materials storage compound, maintenance workshop, testing

laboratory or material stockpile area.

AS/NZS ISO Australian/New Zealand Standard of International Standards Organisation

AS/NZS ISO

14001:2004

Australian/New Zealand Standard of International Standards Organisation

14001 (2004). Refers to the standard that specifies requirements for an

effective environmental management system.

CAFMP Construction Ancillary Facilities Management Plan (Appendix B8)

CAP

Construction Area Plan

This CPB document is prepared during the construction planning for each

major work area to inform the broader Project team, including the relevant

functional support teams, of the scope and work overview. It outlines the

execution and delivery stages and includes general construction method,

risk assessment, constructability reviews, logistics and discipline

interfaces.

CAQMP Construction Air Quality Management Plan (Appendix B6)

CCHMP Construction Cultural Heritage Management Plan (Appendix B5)


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Phrase Definition

CCIP Construction Community Involvement Plan (Appendix B9

CCLMP Construction Contaminated Land Management Plan (Appendix B10)

CCTV Closed circuit television

CEMP Construction Environmental Management Plan (this document)

CEMS/ CMS Contractors Environmental Management System. This is referred to the

CMS – CPB Management System for CPB Contractors Pty Ltd.

CFFMP Construction Flora and Fauna Management Plan (Appendix B2)

CLM Act Contaminated Land Management Act 1997

CNVMP Construction Noise and Vibration Management Plan (Appendix B3)

CoA Condition/s of Approval

Compliance audit

Verification of how implementation is proceeding with respect to a

construction environmental management plan (CEMP) (which incorporates

the relevant approval conditions).

Construction

Includes all physical work required to construct the CSSI, other than the

following low impact work:

a) survey works including carrying out general alignment survey,

installing survey controls (including installation of global

positioning system (GPS), installing repeater stations) and building

and road dilapidation surveys;


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Phrase Definition

b) investigations including investigative drilling and excavation

including unexploded ordinance clearance and associated work;

c) establishment of ancillary facilities in accordance with conditions

Condition A15, A16, and A17 of the approval, including

constructing ancillary facility access roads and providing utilities to

the facility, and any ancillary facility boundary fencing required

under the conditions of this approval;

d) operation of ancillary facilities if the ER has determined the

operational activities will have minimal impact on the environment

and community;

e) minor clearing and relocation of native vegetation as identified in

the documents listed in Condition A1

f) installation of mitigation measures including erosion and sediment

controls and fencing;

g) property acquisition adjustment works including installation of

property fencing, access tracks and relocation and adjustments of

utilities to property including water supply and electricity;

h) relocation and connection of utilities where the relocation or

connection has a minor impact to the environment as determined

by the ER;

i) work associated with the Sydney Water pipeline cut-ins (that

doesn’t meet (h) above) where a Construction Environmental

Management Plan/Environmental Work Method Statement has

been approved by the Environmental Representative. The pipeline

cut-in works include preparation works, excavation, piling and cut-

ins;

j) archaeological testing under the Code of practice for

archaeological investigation of Aboriginal objects in NSW

(DECCW, 2010) or archaeological monitoring undertaken in

association with [a]-[i] above to ensure that there is no impact on

heritage items;


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Phrase Definition

k) archaeological investigations including testing and salvage of

archaeological objects in accordance with a salvage strategy

prepared in accordance with the conditions of this approval;

l) other activities determined by the ER to have minimal

environmental impact which may include construction of minor

access roads, temporary relocation of pedestrian and cycle paths

and the provision of property access; and

m) maintenance of existing buildings and structures required to

facilitate the carrying out of the CSSI.

However, where heritage items (excluding for work outlined (j) or (k)

above), or threatened species, populations or ecological communities

(within the meaning of the EP&A Act) are affected or potentially affected

by any low impact work, that work is Construction, unless

(i) otherwise determined by the Secretary in consultation with

OEH or DPI Fisheries (in the case of impact upon fish, aquatic

invertebrates or marine vegetation); or

(ii) the work is in accordance with an Ancillary Facilities

Management Plan, approved by the Secretary, under

condition A16.

The low impact work described in this definition becomes Construction

with the approval of a Construction Environmental Management Plan

CPB Contractors CPB Contractors Proprietary Limited

CRM CPB Community Relations Manager

CSMP Construction Sustainability Management Plan (Appendix B13)

CSSI Critical State Significant Infrastructure


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Phrase Definition

CSWMP Construction Soil and Water Management Plan (Appendix B4)

CTMP Construction Traffic Management Plan (Appendix B1)

CWEMP Construction Waste and Energy Management Plan (Appendix B7)

DEC Department of Environment and Conservation (NSW) (former)

DECC Department of Environment and Climate Change (NSW) (former)

DEOH Defence Establishment of Orchard Hills

DIPNR Department of Infrastructure, Planning and Natural Resources (NSW)

(former)

Ecological sustainable

development (ESD)

Using, conserving and enhancing the community’s resources so that the

ecological processes on which life depends are maintained and the total

quality of life now and in the future, can be increased (Council of

Australian Governments, 1992).

EIS Environmental Impact Statement

EMS Environmental Management System

Environmental aspect Defined by AS/NZS ISO 14001:2004 as an element of an organisation’s

activities, products or services that can interact with the environment.

Environmental impact

Defined by AS/NZS ISO 14001:2004 as any change to the environment,

whether adverse or beneficial, wholly or partially resulting from an

organisation’s environmental aspects.


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Phrase Definition

Environmental incident

An unexpected event that has, or has the potential to, cause harm to the

environment and requires some action to minimise the impact or restore

the environment.

Environmental

objective

Defined by AS/NZS ISO 14001:2004 as an overall environmental goal,

consistent with the Sustainability Policy, that an organisation sets itself to

achieve.

Environmental Policy Statement by an organisation of its intention and principles for

environmental performance

Environmental

Representative (ER)

A suitably qualified and experienced person independent of project design

and construction personnel employed for the duration of Construction. The

principal point of advice in relation to all questions and complaints

concerning environmental performance.

EP&A Act NSW Environmental Planning and Assessment Act 1979

EPA NSW Environment Protection Authority

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

EPL NSW Environment Protection Licence under the Protection of the

Environment Operations Act 1997

ERG

Environmental Review Group – comprising representatives of: Roads and

Maritime, Environmental Representative, Project delivery team, regulatory

authorities (EPA, DPI – Fishing and Aquaculture, NOW) and Councils

(Liverpool City Council and Penrith City Council,).


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Phrase Definition

The ERG will be maintained for the duration of the Project and will meet

regularly and undertake environmental inspections. The role the ERG is to

provide proactive advice on environmental management issues and review

the environmental performance of the Project.

ESA Environmentally Sensitive Areas

ESCP Erosion and Sediment Control Plan

ESR CPB Environmental Site Representative. Also known as CPB Environment

Manager.

EWMS Environmental Work Method Statements - “Environmental Work Method

Statement” (EWMS) means a component of the CEMP and/or CEMS that

addresses environmental management issues relevant to a specific site

and/ or activity.

Federal-CoA Condition of the Federal Department of the Environment and Energy

Approval Division

GREP NSW Government Resource Efficiency Policy

Hold Point Is a verification point that prevents work from commencing prior to

approval from Roads and Maritime.

ITP Inspection and Test Plans

ITS Intelligent Transport System

LDP Land Disturbance Permit


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Phrase Definition

LGA Local Government Area

Minister, the NSW Minister for Planning

MNES Matters of National Environmental Significance

Non-compliance Failure to comply with the requirements of the Instrument of Approval or

any applicable license, permit or legal requirements.

Non-conformance Failure to conform to the requirements of Project system documentation

including this CEMP or supporting documentation.

NOW (NSW) Office of Water

NRAR Natural Resources Access Regulator (previously DPI-Water and DOI

Water)

NSW-CoA Condition of the NSW DP&E Infrastructure Approval

NSW Heritage Council Heritage Council of NSW or its delegate

NSW Infrastructure

Approval

The Infrastructure Approval for the Northern Road Upgrade issued by the

NSW Government on 30 May 2018

OACEMP

Roads and Maritime’s Overarching and DP&E approved CEMP:

The Northern Road Upgrade – Mersey Road, Bringelly to Glenmore

Parkway, Glenmore Park Overarching Construction Environmental

Management Plan, September 2018,

OEH (NSW) Office of Environment and Heritage


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Phrase Definition

OOHW Out of hours work

Operation

Means the operation of the State Significant Infrastructure (SSI), but does

not include commissioning trials of equipment or temporary use of parts of

the SSI during construction.

PESCP Progressive Erosion and Sediment Control Plan

PIRMP Pollution Incident Response Management Plan (Appendix B11)

POEO Act Protection of the Environment Operations Act 1997

Principal, the NSW Roads and Maritime Services

Project, the

or TNR5

The Northern Road Upgrade between Littlefields Road and Glenmore

Parkway – also known as TNR5.

RAP Registered Aboriginal Party

REMM Revised Environmental Management Measures as provided in the Final

EIS / SPIR

Roads and Maritime NSW Roads and Maritime Service

Roads and Maritime

Environmental

Representative (also

referred to as Roads

and Maritime

Environment Manager)

The environmental responsibilities of the Roads and Maritime

Environmental Representative include (but are not limited to) the following:

Evaluate and advise on compliance with environmental requirements


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Phrase Definition

Review and approve any environmental management plans for the Project

or related activities that are not required to be approved by the Secretary

of DP&E.

SAP Sensitive Area Plan

Secretary of DP&E Secretary of the NSW Department of Planning and Environment

SEARs Secretary’s Environmental Assessment Requirements

SPIR Submissions and Preferred Infrastructure Report

SSI

State Significant Infrastructure as defined in the Instrument of Approval;

Construction and operation of approximately 16 kilometres of The

Northern Road between Mersey Road, Bringelly and Glenmore Parkway,

Glenmore Park.

Sustainability Policy Statement by an organisation of its intention and principles for

environmental performance.

Task Observation

A Task Observation is an activity that involves the review of a task being

performed to determine if the task is being conducted in accordance with

the relevant Work Pack and / or Safe Work Method Statement.

It is also used to identify deficiencies in awareness, knowledge, process or

equipment

TNR The Northern Road

UXO Unexploded Ordnance


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Phrase Definition

Work Pack

A Work Pack is a collective set of documents that provides an integrated

and planned method of delivering elements of the work with consideration

to all necessary factors including safety, environmental, quality,

community, legislative, production and cost.

WSIP Western Sydney Infrastructure Plan

WSPGA Western Sydney Priority Growth Area


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THIS PAGE LEFT BLANK INTENTIONALLY

Title: Construction Environmental Management Plan - The Northern Road Upgrade between Littlefields Road and

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1. Introduction

1.1 Context and purpose

This CPB Contractors Pty Ltd (CPB) Construction Environmental Management Plan (CEMP)

outlines how we will achieve environmental management obligations and outcomes on The

Northern Road Upgrade (Stage 5) between Littlefields Road and Glenmore Parkway (the

Project or TNR5) by the application of the CPB Contractors Environmental Management

System (EMS).

An Overarching Construction Environmental Management Plan (OACEMP) The Northern

Road Upgrade – Mersey Road, Bringelly to Glenmore Parkway, Glenmore Park Overarching

Construction Environmental Management Plan, September 2018, and associated sub plans

have been prepared by Roads and Maritime and approved by the Department of Planning

and Environment. The strategies defined in the OACEMP have been developed to address

the NSW and Federal conditions of approval and the management measures presented in

the Environmental Impact Statements (EIS) and Submissions and Preferred Infrastructure

Report (SPIR). The OACEMP includes general requirements for implementation, monitoring

and auditing which have been further developed and included within this CEMP where

relevant to construction activities.

This CEMP and sub-plans have been prepared to comply with the NSW Minister for

Planning’s Instrument of Approval for The Northern Road, and Project’s Federal approval in

accordance with section 130(1) of the Environment Protection and Biodiversity Conservation

Act 1999. A detailed description of the Project is provided in Section 2 of this CEMP.

This CEMP has been prepared by CPB Contractors in accordance with the following:

Roads and Maritime QA Specifications

Overarching Construction Environmental Management Plan, The Northern Road

Upgrade – Mersey Road, Bringelly to Glenmore Parkway, Glenmore Park, September

2018

Guideline for the Preparation of Environmental Management Plans (Department of

Infrastructure, Planning and Natural Resources, 2004), and

AS/NZS ISO 14001

ISO 9001: Quality Management Systems

AS/NZS 4801: Safety Management Systems

The purpose of this CEMP is to provide a structured approach to the management of

environmental issues during construction of the Project. Implementing this CEMP effectively


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will ensure that the Project team meets regulatory and policy requirements in a systematic

manner and continually improves its performance.

In particular this CEMP:

Describes the Project in detail including activities to be undertaken and relative timing

Provides specific mitigation measures and controls that can be applied on-site to avoid

or minimise negative environmental impacts

Provides specific mechanisms for compliance with applicable policies, approvals,

licences, permits, consultation agreements and legislation

Describes the environmental-management related roles and responsibilities of Project

personnel

States the objectives and targets for issues which are important to the environmental

performance of the Project

Outlines a monitoring regime to check the adequacy of controls as they are implemented

during construction.

This CEMP meets the requirements of the Project’s CoA. CoA relevant to the CEMP are

shown in Table 3-1.

1.2 Background

The upgrade of The Northern Road is part of the Western Sydney Infrastructure Plan

(WSIP), which is jointly funded by the Australian and NSW governments. The WSIP is a 10-

year, $3.6 billion plan which involves major road and transport linkages to capitalise on the

economic gains from developing the Western Sydney Airport at Badgerys Creek and the

Western Sydney Priority Growth Area (WSPGA) whilst boosting the local economy and

liveability of western Sydney. The Northern Road Upgrade – Mersey Road, Bringelly to

Glenmore Parkway, Glenmore Park Project (the Northern Road Project) comprises the

upgrade of 16 km of The Northern Road (TNR).

The Northern Road Project is an integral element in the many changes either planned or

already underway in western Sydney. The Northern Road Project is located approximately

45 km west of the Sydney central business district and traverses the local government areas

of Penrith in the north and Liverpool in the south.

The Northern Road Project has been assessed under both State and Federal planning

approval pathways. The Northern Road Project was declared by the NSW Minister for

Planning to be critical State significant infrastructure (CSSI) development under Schedule 5

of the State Environmental Planning Policy (State and Regional Development) 2011 on 31

March 2017. The Secretary’s Environmental Assessment Requirements (SEARs) for the


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Northern Project were issued on 28 July 2015 and amended SEARs were issued on 9 March

2016. The Project was assessed under Part 5.1 of the Environmental Planning and

Assessment Act 1979 (NSW) (EP&A Act).

The Northern Road Project has the potential to significantly impact on Matters of National

Environmental Significance (MNES) including Environment Protection and Biodiversity

Conservation Act 1999 (EPBC Act) listed Cumberland Plain Shale Woodlands and Shale-

Gravel Transition Forest. The Northern Road Project will also impact on areas of

Commonwealth land associated with the Defence Establishment Orchard Hills (DEOH) and

land purchased by the Australian Government for the Western Sydney Airport. Accordingly,

the Northern Road Project was referred to the then Australian Government Department of

the Environment (now Department of the Environment and Energy (DoEE)). The Northern

Road Project was declared by the Federal Minister for the Environment and Energy to be a

‘controlled action’ under the EPBC Act and Commonwealth Environmental Impact Statement

Guidelines were issued in August 2016.

A single Environmental Impact Statement (EIS)/Draft EIS was prepared for the Northern

Road Project to satisfy the environmental assessment requirements of both Part 5.1 of the

EP&A Act and Part 8 of the EPBC Act. The EIS was placed on public exhibition between 21

June 2017 and 2 August 2017.

A Submissions and Preferred Infrastructure Report (SPIR) was prepared to provide

responses to issues raised during exhibition of the initial EIS, to propose Northern Road

Project design refinements and to provide revised environmental management measures

(REMMs) for the Northern Road Project. The SPIR was submitted to the NSW Minister for

Planning. A Final EIS satisfying the requirements of the EPBC Act was

Approval for the Northern Road Project under the EP&A Act was granted by the Minister for

Planning on 30 May 2018. Approval for the Northern Road Project under the EPBC Act was

granted by the Federal Minister for the Environment and Energy on 15 June 2018.

Roads and Maritime Services is planning and delivering the Northern Road Project. It is

being constructed in three separate stages under three separate Construction contracts:

Stage 4 - Mersey Road, Bringelly, to Eaton Road, Luddenham

Stage 5 - Littlefields Road, Luddenham, to Glenmore Parkway, Glenmore Park

Stage 6 - Littlefields Road, Luddenham to Eaton Road, Luddenham

Further detail of the proposed Project staging is provided in the Project Staging Report,

which has been prepared in accordance with NSW Condition of Approval (NSW-CoA) A10.

The Stage 5 Project (TNR5) is being delivered by CPB Contractors Pty Ltd under a construct

only contract.


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1.3 Consultation

The CEMP is to be developed in consultation with the Environmental Representative to

ensure that the Project documents encompass all necessary information and provide

practical management measures to reduce and avoid environmental impact.

Extensive consultation for the Project commenced during the Project development phase

and continued during the environmental assessment of the concept design. The primary

objective of consultation was to keep stakeholders well informed and involved during each

stage of Project development.

Further consultation with relevant stakeholders and government authorities has continued

through the development of this CEMP and sub plans.

Key stakeholders include:

Department of Planning and Environment (DP&E)

Environment Protection Authority (EPA)

Emergency Services

Office of Environment and Heritage (including Heritage Division) (OEH)

The Heritage Council of NSW

NSW Health

Department of Primary Industries – Fisheries and Aquaculture (DPI)

Local Councils – Liverpool City Council and Penrith City Council

NSW Office of Water (NOW)

Local Aboriginal Land Councils, Aboriginal stakeholders.

Consultation with stakeholders during the development of the CEMP, in accordance with

CoA C4 and C6 will include meetings where required to discuss the content of the CEMP.

The CEMP will also be distributed to stakeholders. Records of the meetings and any written

correspondence from the Agency Representatives will be maintained. The Project Team will

review comments received and update the CEMP prior to submission to DP&E for approval.

Consultation will continue throughout the Project Works with relevant stakeholders and

government authorities including DP&E. The outcomes of this consultation will be

documented where relevant in subsequent revisions of the CEMP and the management

review and is described further in Section 9.

Project representatives will continue to consult with all key stakeholders throughout the

construction phase of the Project.


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1.3.1 Consultation for the preparation of the CEMP

Consultation with relevant stakeholders and Government agencies was undertaken as part

of the development of this CEMP and sub plans in accordance with the requirements of the

Infrastructure Approval. The agencies required to be consulted under the Infrastructure

Approval are listed in Table 1-1. Consultation will be ongoing throughout the Project as

required.


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Table 1-1 Consultation requirements

CoA no. CEMP Plan Agency to be consulted CEMP Reference

A16 Ancillary Facilities

Management Plan

EPA, Penrith City Council Appendix B8

C4(a)

Traffic and transport

Management Sub-Plan

Penrith City Council,

Appendix B1

C4(b) Noise and vibration

Management Sub-Plan


Appendix B3

C4(c) Biodiversity Management

Sub-Plan

OEH and DPI Fisheries Appendix B2

C4(d) Water, soil and

contamination Management

Sub-Plan

DoI Water, DPI Fisheries,


Appendix B4

Appendix B10

C4(e) Heritage Management Sub-

Plan

OEH, Penrith City

Council,

Registered Aboriginal

Parties

Appendix B5

C9(c) Water, soil and

contamination Monitoring

Program

DPI, DoI Water Appendix B4

Appendix B10

E12 Historical Archaeological

Salvage Strategy

Heritage Council of NSW Appendix B5

E15 Unexpected Heritage Finds

Procedure

Heritage Council of NSW Appendix B5


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1.4 CEMP Acceptance

This CEMP will be approved by the Project Manager and Environmental Site Representative

prior to submission to Roads and Maritime Services.

The CEMP and sub plans will go through a review and update process as described in

Roads and Maritime Specification G36 to ensure the CEMP and associated documents have

been developed in accordance with the DP&E approved OACEMP: The Northern Road

Upgrade – Mersey Road, Bringelly to Glenmore Parkway, Glenmore Park Overarching

Construction Environmental Management Plan, September 2018.

A hold point shall be submitted in accordance with G36 Section 3.1 Preparation and

submission of CEMP. Roads and Maritime shall consider the documents prior to authorising

the release of the Hold Point. Roads and Maritime may request additional information for

inclusion in the CEMP before authorising the release of the Hold Point.

1.5 Distribution

This CEMP is available to all personnel and sub-contractors via the Project document control

management system.

The document is uncontrolled when printed. One controlled hard copy of the CEMP and

supporting documentation will be maintained by the Project Environmental Site

Representative (ESR) at the Project office.

Registered copies and revised documents will be distributed to:

Project Manager;

Project Environmental Site Representative;

Construction Manager;

Quality Manager;

Communications Manager;

Environmental Representative;

Roads and Maritime Project Manager; and

Roads and Maritime Environment Manager.

This CEMP will be made available for public inspection on request. Confidential information,

which may include the location of threatened species, Aboriginal objects or places and


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personnel contact details, will be removed from all documents provided or made available to

the public.

1.6 Revision

A document review process ensures that environmental documentation, including this

CEMP, is updated as appropriate for the specific works that are occurring on-site.

This CEMP will be reviewed:

at least annually during management reviews (Section to Section 9 for further details)

following reportable environmental incidents

on identification of new risks, including risks identified during risk register updates

when non-compliances are identified that are not considered minor in nature

following environmental audits that identify matters that require attention

in response to Project changes (including modifications)

within one month of any of the above occurrences, or as otherwise agreed with the

Secretary, and/or

as part of a continuous improvement process.

Should the document review process identify any issues or items within the documents’ that

are either redundant or in need of updating, it is the responsibility of the Environmental Site

Representative (ESR), or delegate, to prepare the revised documents. This shall be carried

out in consultation with key stakeholders as relevant. Consultation records shall be

maintained by the ESR.

Any revisions to the CEMP will be endorsed by the ER. The ER can approve minor changes

to the CEMP, including those that:

are editorial in nature eg staff and agency/authority name changes.

do not increase the magnitude of impacts on the environment when considered

individually or cumulatively.

do not compromise the ability of the Project to meet approval or legislative requirements.

The revised document will be issued to the Roads and Maritime Project Manager (or

delegate) for certification of the changes.


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Revised versions of the CEMP will be made available through the processes described in

Section 1.5.


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2. Project Description

The Northern Road Upgrade between Littlefields Road and Glenmore Parkway consists of a

6.7km upgrade to The Northern Road within the existing road corridor South of Littlefield’s

Road and North of Glenmore Park, and includes complex interchange upgrades from and

including Littlefield’s Road to Bradley Street. The key features are:

upgrade and widening of approximately 6.7 km of existing The Northern Road from

Littlefields Road, Luddenham to Glenmore Parkway, Glenmore Park

wide central median to allow future widening south of Bradley Street

new traffic light intersections at Littlefields Road, Kings Road, Chain-O-Ponds Road,

Defence Facility Orchard Hills and Bradley Street

left-in left-out intersections at Gates Road, Grover Crescent and Longview Road

side street improvements and u-turn facilities at Vineyard Road extension and Gates

Link Road, Littlefields Road extension and Chain-O-Ponds Road

construction of footpaths and shared pedestrian/cycle paths

adjustment of utilities and construction of ITS

landscaping

property adjustment.

The upgrade of The Northern Road, between Littlefield’s Road, Luddenham and Glenmore

Parkway, Glenmore Park is required to facilitate future land development planned as part of

the WSIP. A significant part of the Project runs adjacent to the Defence Establishment

Orchard Hills (DEOH) site, located along the eastern side of the proposed alignment and

requires land acquisition (Commonwealth Land).

2.1 Construction Activities and Sequence

In reference to CoA A11 Staging, the delivery of the Project will not be staged. That is, the

Project will be constructed in its entirety as one complete Project in the shortest duration.

However, different construction phases will be implemented during construction. The main

construction phases for integrated traffic and construction management are shown in Table

2-1.

Construction hours and circumstances where construction activities may be undertaken

outside of standard construction hours will be detailed and assessed further in the

Construction Noise and Vibration Management Plan in Appendix B3 of this CEMP. Activities

to be undertaken outside of standard working hours will be regulated by the Project

Environmental Protection Licence (EPL).


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Onsite delivery of the Project is expected to commence in February 2019 and be completed

in June 2021. The construction period is expected to be approximately 24 months, however

complete site demobilisation is expected to be approximately up to 28 months.

Works will follow a typical construction sequence of environmental surveys and installation of

protection measures, site establishment, traffic arrangements, services relocations, clear

and grub, cut and fill or imported fill, drainage, intelligent transport systems (ITS) and

lighting, pavement works, barriers, asphalt surfacing, line marking, landscaping and finishing

works.

Title: Construction Environmental Management Plan- The Northern Road Upgrade between Littlefields Road and Glenmore Parkway



Page 34 of 177

Table 2-1 Main Phases of Construction

Construction activity Proposed Activities Plant and equipment Indicative

Commencement

Construction Stage 1

(Pre-construction/ Early

works)

Road work (widening

and new roads) and

intersections

Progressive stabilisation

Environmental pre-construction surveys including: pre-clearing, heritage

and pre-condition inspection reporting

Installation of temporary traffic barriers, temporary access arrangements,

environmental controls

Setting up the main Site Compound

Clearing and Grubbing the ‘Construction Stage 1’ construction footprint area

Relocation of Sydney Water services

Intersection and DEOH U-turn bay

Northbound carriageway works, kerb and getter works

Commence works at Gates Road/The Northern Road works behind

temporary barriers

Commence construction of Kings Hill Road and new Vineyard Road

Progressive revegetation and landscaping works throughout Construction

Stage 1.

Light vehicles

Trucks

Generators

Cranes

Bobcats

Excavators

Water carts

Feb 2019




Page 35 of 177


Utility Relocations/

Clearing/ Earthworks/

Drainage

Road work (widening

and new roads) and

intersections


Clearing and grubbing for Construction Stage 2 footprint area

Continue construction of all new The Northern Road/Local Road

intersections and DEOH access

Construction of new southbound carriageway between CH 80 and CH 6660

including drainage and kerb and channel works

Continue utility relocation works

Asphalt and road furniture works on completed southbound works except

for wearing course

Construction of Littelfield’s Road east and west

Longview Road works will be completed and reopened to traffic

Vineyard Road and Kings Hill Road connection completed


Stage 2.

Light vehicles

Trucks

Compactors

Generators

Cranes

Bobcats

Excavators

Bulldozers

Water carts

Graders

Vibrating rollers

Spray sealing

equipment

Paving machines

Concrete saws

Compactors

Sept 2019




Page 36 of 177

Concrete pumps

Concrete trucks


Road work (widening

and new roads) and

intersections


Clearing and grubbing for Construction Stage 3 footprint area

Continue construction of all new The Northern Road/Local Road

intersections and DEOH access

Construction of new northbound carriageway between CH 80 and CH 6660,

including drainage, and kerb and channel works

Complete utility relocation works

Asphalt and finishing works on completed northbound works including

wearing course

Close existing Gates Road/The Northern Road intersection to eastbound

and westbound traffic and detour traffic via new link road between Littlefield

Road/Gates Road

All works for the new Gates Road intersection completed


Stage 3.

Excavators

Bulldozers

Water carts

Graders

Dump trucks

Vibrating rollers

Spray sealing

equipment

Paving machines

Concrete saws

Compactors

Cranes

Concrete pumps

Concrete trucks

June 2020




Page 37 of 177

Completion Stage Placement of asphalt wearing course

Completion of road furniture works including permanent line marking and

road signage

Landscaping works

Commission new signalised intersections

Complete works for Littlefield’s and Gates Road Link

Complete works for Kings Hill Road and Longview Road Link

Site demobilisation

Progressive revegetation and landscaping works throughout the Completion

Stage.

Dump trucks

Concrete trucks

Hydro-mulching

equipment

Cranes

Water cart

Apr 2021

Title: Construction Environmental Management Plan- The Northern Road Upgrade between Littlefields Road and

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Figure 2-1 The Northern Road Upgrade between Littlefields Road and Glenmore Parkway


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2.2 Compound and ancillary facilities

An ancillary facility, as defined in the Infrastructure Approval, is “a temporary facility for

Construction of the Project including an office and amenities compound, Construction

compound, material crushing and screening plant, materials storage compound,

maintenance workshop and testing laboratory and material stockpile.”

As the OACEMP contains a template stockpile management protocol and a stockpile

management procedure, CPB Contractors have prepared a template Stockpile Management

Protocol (Appendix B4 CSWMP). Any temporary material stockpile areas located within the

Construction footprint are not considered to be an ancillary facility, in accordance with the

Infrastructure Approval definition. Any stockpile area located outside the Construction

footprint will be classified as an ancillary facility and will be required to comply with the

requirements for ancillary facilities

A number of temporary ancillary facilities will be required to support construction of the

Project. Typically, these facilities include:

Office accommodation

Staff amenities

Light vehicle parking

A plant and equipment maintenance workshop

Materials and chemical storage

The EIS identified a number of compounds and ancillary facilities that would be required for

the construction of the Project, including locations for hardstand areas, temporary building

and offices, parking areas, material laydown and storage areas.

The EIS stated that the final type, location and number of ancillary facilities would be

determined by the construction contractor and identified in the Ancillary Facilities

Management Plan. The EIS assess eight (8) locations in proximity to the Project construction

activities. CPB Contractors propose to use all locations assessed as part of the EIS relevant

to Stage 5 works. The location of the ancillary facilities assessed in the EIS relevant to Stage

5 activities is provided in Figure 2-2.

Lot 1/DP 109697 (also known as C16 as nominated in the EIS) will be used for the main site

compound for the Project.


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Figure 2-2 Location of ancillary facilities relevant for Stage 5 activities.

C21

C20

C19

C18

C17

C16

C15

C14


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In accordance with CoA A16, Appendix B8 of this CEMP details the location, composition

and purpose of compound and ancillary facilities required for the Project. An assessment of

the compound and ancillary facilities against the ancillary facility assessment criteria

required by CoA A15 is also provided. A summary of the assessment criteria for ancillary

facilities is provided in Section 3.7.2.

For sites that do not meet the CoA A15 criteria, additional assessments shall be prepared

and submitted to DP&E seeking the Secretary of DP&E approval.

CoA A17 also provides an approval pathway for minor ancillary facilities (e.g. lunch sheds,

office sheds, and portable toilet facilities) that do not meet the requirements of CoA A15.

Further information about minor ancillary facilities is provided in Section 3.7.3.


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3. Planning

3.1 Project environmental obligations

All construction personnel working on the Project have the following general obligations:

Minimise pollution of land, air and water

Use pollution control equipment and keep it in proper working order

Preserve the natural and cultural heritage environment

Give notice to Roads and Maritime and relevant authorities of a non-Aboriginal or

Aboriginal heritage discovery

Minimise the occurrence of offensive noise. Where a noise management level has been

exceeded, undertake review and investigate what reasonable and feasible actions can

be implemented

Be a good neighbour to surrounding land users

Keep the community informed of Project milestones, upcoming activities and duration of

relevant aspects of the works

Use equipment with noise control features where available and ensure that it is properly

maintained

Take all feasible and reasonable steps to ensure compliance with the requirements of

this CEMP.

3.2 Legal and other requirements

A register of legal and other requirements for the Project is contained in Appendix A1. This

register will be maintained as a checklist. This register will be reviewed at regular intervals

(e.g. during management reviews) and updated with any applicable changes. Any changes

made to the legal requirements register will be communicated to the wider team where

necessary through toolbox talks, specific training and other methods detailed in Section 5.

3.2.1 CoA relevant to the CEMP

This CEMP has been prepared in accordance with the Project’s CoA. CoA relevant to the

CEMP are shown in Table 3-1 Conditions of Approval relevant to .


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Table 3-1 Conditions of Approval relevant to CEMP

CoA Requirement Reference

NSW CoA requirements

A2 The CSSI must be carried out in accordance with all

procedures, commitments, preventative actions, performance

criteria and mitigation measures set out in the EIS as

amended by the SPIR unless otherwise specified in, or

required under, this approval.

This document

A16 Before establishment of any ancillary facility (other than

minor ancillary facilities described in Condition A17), the

Proponent must prepare an Ancillary Facilities Management

Plan which details the management of the ancillary facilities.

The Ancillary Facilities Management Plan must be prepared

in consultation with the EPA and the relevant council(s) and

submitted to the Secretary for approval one month prior to

installation of ancillary facilities. The Ancillary Facilities

Management Plan must detail the management of the

ancillary facilities and include:

(a) a description of activities to be undertaken during

Construction (including scheduling of construction)

(b) a program for ongoing analysis of the key environmental

risks arising from the activities described in subsection (a) of

this condition, including an initial risk assessment undertaken

prior to the commencement of Construction of the CSSI; and

(c) details of how the activities described in subsection (a) of

this condition will be carried out to:

i. meet the performance outcomes stated in the documents

listed in Condition A1; and

Appendix B8

Ancillary Facility

Management Plan


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ii. manage the risks identified in the risk analysis undertaken

in subsection (b) of this condition.

A27 A Compliance Tracking Program to monitor compliance with

the terms of this approval must be prepared, taking into

consideration any staging of the CSSI that is proposed in a

Staging Report submitted in accordance with Condition A11

and Condition A12 of this approval.

Compliance

Tracking Program

A30 A Pre-Construction Compliance Report must be prepared

and submitted to the Secretary for information no later than

one month before the commencement of Construction or

within another timeframe agreed with the Secretary. The Pre-

Construction Compliance Report must include:

(a) details of how the terms of this approval that must be

addressed before the commencement of Construction have

been complied with; and

(b) the proposed commencement date for Construction.

Pre-Construction

Compliance

Report

A32 Construction Compliance Reports must be prepared and

submitted to the Secretary for information every six (6)

months from the date of the commencement of Construction

or within another timeframe agreed with the Secretary, for the

duration of Construction. The Construction Compliance

Reports must include (as applicable):

(a) a results summary and analysis of environmental

monitoring

(b) the number of any complaints received, including a

summary of main areas of complaint, action taken, response

given and proposed strategies for reducing the recurrence of

such complaints

Construction

Compliance

Reports


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(c) details of any review of, and minor amendments made to,

the CEMP as a result of construction carried out during the

reporting period

(d) a register of any consistency assessments undertaken

and their status

(e) results of any environmental audits and details of any

actions taken in response to the recommendations of an

audit

(f) a summary of all incidents notified in accordance with

Condition A40 and Condition A43 of this approval; and

(g) any other matter relating to compliance with the terms of

this approval or as requested by the Secretary.

A33 A Pre-Operation Compliance Report must be prepared and

submitted to the Secretary for information no later than one

month before the commencement of operation or within

another timeframe agreed with the Secretary. The Pre-

Operation Compliance Report must include:

(a) details of how the terms of this approval that must be

addressed before the commencement of Operation have

been complied with; and

(b) the commencement date for Operation.

Pre-Operation

Compliance

Report

A35 An Environmental Audit Program for independent

environmental auditing against the terms of this approval

must be prepared in accordance with AS/NZS ISO

19011:2014 - Guidelines for Auditing Management Systems

and submitted to the Secretary for information no later than

before the commencement of works or within another

timeframe agreed with the Secretary.

Section 8.3


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B6 A Complaints Management System must be prepared and

submitted to the Secretary for information prior to the

commencement of any works in respect of the CSSI and be

implemented and must be maintained for the duration of

works and for a minimum for 12 months following completion

of Construction of the CSSI.

Construction

Community

Communication

Strategy

C1 A Construction Environmental Management Plan (CEMP)

must be prepared in accordance with the Department of

Infrastructure, Planning and Natural Resources Guideline for

the Preparation of Environmental Management Plans

(DIPNR; 2004) to detail how the performance outcomes,

commitments and mitigation measures specified in the

documents listed in Condition A1 will be implemented and

achieved during all stages of Construction.

This Plan

C2 The CEMP must provide:

(a) a description of activities to be undertaken during

Construction (including the scheduling of construction)

(b) details of environmental policies, guidelines and principles

to be followed in the Construction of the CSSI

(c) a schedule for compliance auditing

(d) a program for ongoing analysis of the key environmental

risks arising from the activities described in subsection (a) of

this condition, including an initial risk assessment undertaken

before the commencement of Construction of the CSSI

(e) details of how the activities described in subsection (a) of

this condition will be carried out to:

i. meet the performance outcomes stated in the documents

listed in Condition A1; and

This Plan


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ii. manage the risks identified in the risk analysis undertaken

in subsection (d) of this condition.

(f) an inspection program detailing the activities to be

inspected and frequency of inspections

(g) a protocol for managing and reporting any:

i. Incidents; and

ii. non-compliances with this approval and with statutory

requirements.

(h) procedures for rectifying any non-compliance with this

approval identified during compliance auditing, incident

management or at any time during Construction:

(i) a list of all the CEMP Sub-plans required in respect of

Construction, as set out in Condition C4. Where staged

Construction of the CSSI is proposed, the CEMP must also

identify which CEMP Sub-plan applies to each of the

proposed stages of Construction.

(j) a description of the roles and environmental

responsibilities for relevant employees and their relationship

with the ER

(k) for training and induction for employees, including

contractors and sub-contractors, in relation to environmental

and compliance obligations under the terms of this approval;

and

(l) for periodic review and update of the CEMP and all

associated plans and programs.


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The following CEMP Sub-plans must be prepared in

consultation with the relevant government agencies identified

for each CEMP Sub-plan and be consistent with the CEMP

referred to in Condition C1:

Table 3: CEMP Sub-Plan Consultation Requirements

CEMP Sub-Plans

C5 The CEMP Sub-plans must state how:

(a) the environmental performance outcomes identified in the

documents listed in Condition A1, as modified by these

conditions, will be achieved

(b) the mitigation measures identified in the documents listed

in Condition A1 as modified by these conditions will be

implemented

(c) the relevant terms of this approval will be complied with

(d) the identification of the relevant environmental specific

training and induction processes for construction personnel;

and

(e) issues requiring management during Construction, as

identified through ongoing environmental risk analysis, will be

managed.

CEMP Sub-Plans


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C9 The following Construction Monitoring Programs must be

prepared in consultation with the relevant government

agencies identified for each Construction Monitoring Program

to compare actual performance of construction of the CSSI

against performance predicted performance.

Table 4: Construction Monitoring Program Consultation

Requirements

Construction

Monitoring

Programs.

The monitoring

programs have

been included in

the relevant sub-

plans.

C10 Each Construction Monitoring Program must provide:

(a) details of baseline data available

(b) details of baseline data to be obtained and when

(c) details of all monitoring of the Project to be undertaken

(d) the parameters of the Project to be monitored

(e) the frequency of monitoring to be undertaken

(f) the location of monitoring

(g) the reporting of monitoring results

(h) procedures to identify and implement additional mitigation

measures where results of monitoring are unsatisfactory; and

(i) any consultation to be undertaken in relation to the

monitoring programs.

Construction

Monitoring

Programs.

The monitoring

programs have

been included in

the relevant sub-

plans.

E1 In addition to the performance outcomes, commitments and

mitigation measures specified in the documents listed in

Condition A1, all reasonably practicable measures must be

Appendix B6

Construction Air


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implemented to minimise the emission of dust and other air

pollutants during the Construction and operation of the CSSI.

Quality

Management Plan

E9 Impacts to heritage, unless approved, must be avoided and

minimised. Where impacts are unavoidable, works must be

undertaken in accordance with the Construction Heritage

Management Sub-plan required by Condition C4(e).

Appendix B5

Construction

Heritage

Management Plan

E12 A detailed Historical Archaeological Salvage Strategy must

be prepared before any Historical archaeological salvage is

undertaken within the CSSI boundary, if not already included

within the EIS or SPIR. Any Salvage Strategy not included in

the EIS or SPIR, must be prepared in consultation with the

Heritage Council of NSW and submitted to the Secretary for

information at least one month prior to the commencement of

excavation and salvage works.

Appendix B5

Construction

Heritage

Management Plan

E18 A detailed Aboriginal Cultural Salvage Strategy must be

prepared before any Aboriginal cultural salvage is

undertaken within the CSSI boundary, if not already included

within the EIS. Any Salvage Strategy not included in the EIS

or SPIR, must be prepared in consultation with OEH and

RAPs (as relevant) and submitted to the Secretary for

information at least one month prior to the commencement of

excavation and salvage works.

Appendix B5

Construction

Heritage

Management Plan

E21 An Unexpected Human Remains Procedure must be

prepared to manage unexpected human remains finds in

accordance with NSW statutory requirements, any guidelines

and standards prepared by the OEH. The Procedure must

outline the process for consulting with the RAPs in the event

that previously unidentified Aboriginal heritage is discovered.

The Procedure must be prepared by a suitably qualified and

Appendix B5

Construction

Heritage

Management Plan


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experienced heritage specialist in Consultation with OEH and

submitted to the Secretary for information no later than one

month prior to the commencement of Construction or within

another timeframe agreed by the Secretary.

Federal CoA requirements for the OACEMP and sub-plans

1 The approval holder must undertake the action, including

those parts of the action that occur on Commonwealth Land,

in accordance with all conditions in the NSW Infrastructure

Approval.

OACEMP, this

CEMP & sub

plans

11 The person taking the action must maintain accurate records

substantiating all activities associated with or relevant to the

conditions of approval, including measures taken to

implement all management plans required by this approval,

and make them available upon request to the Department

(DoEE). Such records may be subject to audit by the

Department (DoEE) or an independent auditor in accordance

with section 458 of the EPBC Act, or used to verify

compliance with the conditions of approval. Summaries of

audits will be posted on the Department’s (DoEE’s) website.

The results of audits may also be publicised through the

general media.

OACEMP

Sections 6.7 and

6.4

Audit Program

(separate

document)

&

This CEMP

Section 8 and

Section 10

12 By 30 June of each year after the commencement of the

action, the person taking the action must publish a report on

their website addressing compliance with the conditions of

this approval over the previous 12 months, including

implementation of any management plans as specified in the

conditions. Non-compliance with any of the conditions of this

approval must be reported to the Department (DoEE) at the

same time as the compliance report is published.

This CEMP

Section 8.6


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13 The person taking the action must provide the Department

with a copy of each approved or finalised document provided

to the DP&E Secretary in accordance with conditions A27 to

A43 on the NSW Infrastructure Approval.

Note: These conditions relate to documenting and reporting

compliance and non-compliance with the conditions of the

NSW Infrastructure Approval.

OACEMP

Sections 6.3, 6.4

and 5.6

14 Upon the direction of the Minister, the person taking the

action must ensure that an independent audit of compliance

with the conditions of approval is conducted and a report

submitted to the Minister. The independent auditor must be

approved by the Minister prior to the commencement of the

audit. Audit criteria must be agreed to by the Minister and the

audit report must address the criteria to the satisfaction of the

Minister.

OACEMP Section

6.4

Audit Program

(separate

document)

3.2.2 Roads and Maritime requirements

The contract and Project specifications which detail environmental requirements and

measures to be implemented by CPB Contractors are identified below.

Roads and Maritime QA Specification G1 – Job Specific Requirements provides a

summary of the requirements of the overall job including environmental issues;

Roads and Maritime QA Specification G36 – Environmental Protection identifies the

environmental protection management process that must be followed by Roads and

Maritime and its contractors;

Roads and Maritime QA Specification G38 – Soil and Water Management identifies the

process to be followed by Roads and Maritime and its contractors in relation to soil and

water management issues.

Roads and Maritime QA Specification G40 – Clearing and Grubbing identifies the

process to be followed by Roads and Maritime and its contractors in relation to clearing


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of all vegetation, both living and dead, all minor built structures, all rubbish and other

materials which are unsuitable for use in Project and the grubbing of trees and stumps.

The CEMP has been developed to address the requirements contained in the above

specifications.

3.3 Approvals, permits and licensing

A number of approvals, permits and licenses have and/or will be obtained for the Project.

Appendix A1 contains a register of all relevant environmental approvals, permits and

licenses. The register will be maintained by the Environmental Site Representative and will

be reviewed prior to the commencement of construction and/or stages of construction, and

at regular intervals during construction and at least annually as part of the management

review.

The following approvals and licences have been or will be obtained by Roads and Maritime:

Infrastructure Approval under Part 5.1 of the EP&A Act – SSI 7127 granted by the

Minister for Planning on 30 May 2018

A Commonwealth controlled action approval from the Department of the Environment

and Energy under Part 8 of the EPBC Act - EPBC 2016/7696

An EPL under Schedule 1 of the Protection of the Environment Operations Act 1997

(POEO Act) for ‘road construction’ and for ‘extractive activity’ where the Project meets

the criteria. The EPL for TNR Stage 5 will be transferred to CPB Contractors.

CPB Contractors will obtain the following licences and approvals:

Road Occupancy Licence (ROL) under Section 138 of the Roads Act 1993

An aquifer interference approval under the Water Management Act 2000 as necessary if

Construction requires intersection of a groundwater source.

In accordance with CoA B11, all necessary licences, permits and approvals required for the

development of the Project will be obtained and maintained as required throughout the life of

the Project. No condition of the Instrument of Approval removes the obligation for Roads and

Maritime or CPB Contractors to obtain, renew or comply with such necessary licences,

permits or approvals except as provided under Section 115ZG of the EP&A Act.


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3.4 Environmental aspects and impacts

A risk management approach has been used to determine the severity and likelihood of an

activity’s impact on the environment and to prioritise its significance. This process considers

potential regulatory and legal risks as well as taking into consideration the concerns of

community and other key stakeholders.

The objectives of the risk assessment are to:

Identify activities, events or outcomes that have the potential to adversely affect the local

environment and/or human health/property;

Qualitatively evaluate and categorise each risk item;

Assess whether risk issues can be managed by environmental protection measures; and

Qualitatively evaluate residual risk with implementation of measures.

Risk assessments for the Project are based on AS/NZS 4360:1999, the Australian standard

for risk assessments and further details of the process are detailed in Section 3.4.1

Appendix A2 contains a list of overall Project environmental aspects and impacts.

The identification of construction activities and associated impacts that could eventuate

during construction of the Project is central to the selection of appropriate environmental

control measures.

CPB Contractors have prepared an environmental risk register. This register shall be

prepared following an environmental risk workshop with Roads and Maritime. The

identification of risks includes a review of the proposed works and all environmental

assessment documentation.

This risk register will be regularly reviewed and updated if:

New activities and potential impacts are identified;

The likelihood or consequence of potential impacts for existing activities changes; and

Inspection, monitoring or auditing reports identify changes that warrant a review of the

register.

3.4.1 Risk Assessment Process

The following risk assessment process has been implemented, together with a review of

proposed activities and known risks based on past Project experience.


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The following dot points outline the risk assessment process using three steps to identify the

appropriate management measures required.

Table 3-2 Likelihood criteria is used to determine the likelihood that the aspect will have

an impact on the environment.

Table 3-3 Consequence criteria is used to determine the potential consequence rating of

the risk identified.

From these two tables, a risk rating can then be assigned by using Figure 3-1 to

determine how severe the potential impact may be.

Table 3-4 Risk severity is then used to assess what level of management each type of

risk will require.

Table 3-2 Likelihood criteria

ID Occurrence

(likelihood) Description

A Rare/improbable The event may only occur in exceptional circumstances.

B Unlikely/remote The event may occur at some time (about once every five

years).

C Possible The event is likely to occur at some time (about once every

year).

D Likely The event will probably occur in most circumstances (at least

once every six months).

E Almost certain The event is expected to occur in most circumstances (at least

once every month).


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Table 3-3 Consequence criteria

ID Consequence

(impact) Description

1 Insignificant/

negligible

Short-term disturbance with minor environmental release or

damage that is non-reportable.

No impact outside site boundary.

No community complaints or media reports.

2 Minor/low

Minor violation of regulation or guideline with minimal damage to

the environment and small clean-up.

Immediately contained on site.

Local government action, minor community complaints.

Potential or actual breach of legislation.

3 Moderate

Violation of regulation or guideline with moderate damage to the

environment and significant clean-up costs.

Release of pollution off site.

Detrimental media reports, community concerns and complaints.

4 Major

Significant environmental damage – potentially permanent.

Release of pollution off site. Significant loss of environmental

resources.

Detrimental media reports in the national or state media,

organised community concern.

High likelihood of EPA fine or court action.


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ID Consequence

(impact) Description

5 Catastrophic

Long-term environmental harm.

Permanent irreparable damage to the environment.

Sustained detrimental state and national media reports.

Sustained community outrage.

Penalty Infringement Notice/court action.

Figure 3-1 Risk rating

Table 3-4 Risk severity

Risk

severity Management required

Priority Immediate and detailed management action required (e.g. stop or change

activity)

High Priority management action warranted.

Moderate Management action warranted.

A B C D E Risk Severity

1 Priority

2 High

3 Moderate

4 Low

5

Co

ns

eq

ue

nc

e

Likelihood


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Risk

severity Management required

Low Management action should be considered, particularly for low-level impacts

that nevertheless occur on a continual basis.

3.4.2 Significant environmental aspects and impacts

Significant environmental impacts associated with aspects of the Project are detailed in

Appendix A2. Each environmental sub-plan will identify further aspects and impacts

associated with each element of the Project, including a detailed list of mitigation strategies

and procedures to address each identified impact. Each sub-plan provides a range of

measures that will be implemented to:

Control the occurrence of the identified environmental impacts;

Protect the environment from harm;

Safeguard the local community;

Satisfy the environmental requirements of the Project and relevant agencies; and

Provide positive environmental offsets to unavoidable environmental impacts (where

practical and cost effective to do so).

Each sub-plan contains a list of measures to minimise and/or control the environmental

impacts associated with that aspect of the Project. Where required, documented actions to

minimise the risks are addressed in the development of Work Packs and EWMS for each

activity associated with the Project.

The timing of installation of control measures will be critical to ensuring that environmental

obligations are met within the required timeframe and that controls are effective in achieving

their purpose. For example, the installation of controls or crossings in a watercourse must

consider seasonal weather patterns (flooding or scouring) and general disturbance issues.

Specific measures and procedures have been identified to address each of the Project

obligations and are included in the relevant sub-plan.


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3.5 Environmental policy and culture

The environmental policy describes CPB Contractors Pty Ltd commitment to continual

improvement in environmental performance and compliance with applicable legal

requirements (Appendix A3).

CPB Contractors Pty Ltd Environmental Policy complies with ISO 14001:2015.

CPB Contractors Pty Ltd will seek to ensure that this policy, environmental procedures and

construction methods are understood, implemented and maintained by personnel at all

levels involved with the Project. The environmental policy will be displayed at the site office

and communicated to staff and other interested parties via inductions and ongoing

awareness programs.

A positive environmental management culture will be established and fostered throughout

the Project duration. This will be developed and maintained using the following proven

techniques:

Environmental responsibilities will be included in all relevant Position Descriptions. Roles

that carry specific environmental accountabilities (e.g. those that supervise or manage

work with specific environmental risks) will contain more detailed environmental

management content.

The environmental responsibilities contained in Position Descriptions will be

communicated to each person by their immediate supervisor upon commencing in their

role.

All personnel in leadership roles on the Project will participate in environmental

management activities, including task observations, incident reviews and Safety, Health,

Environment and/or Quality (SHEQ) meetings.

The Project management team will:

Regularly review environmental performance against objectives and targets and raise

corrective actions to maintain or improve environmental performance as necessary.

Address pertinent environmental matters at communication forums.

The CPB Contractors Pty Ltd Environmental Policy will be communicated during Project

inductions and prominently displayed at the Project site.

The Project Manager and ESR will assist in development of 'Project Rules' during the start-

up phase to address key environmental management matters. These rules will be


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documented, communicated and prominently displayed at the Project site and will be

reviewed at least every six months. Any person who breaches these rules will be managed

in accordance with CPB Contractors' requirements for counselling, discipline and, if needed,

termination.

Environmental key performance indicators (KPIs) for the Project are identified in Section 3.6.

The associated KPIs include lead and lag indicators. Measurable targets will be set for each

KPI and an applicable time frame nominated. The targets will be in line with CPB

Contractors Group level and Business Unit targets.

Environmental management performance goals will be set and reviewed for individuals with

environmental leadership roles during the performance and development review process.

Early and Project specific communication with regulatory agencies and the community will

be prioritised during the Project start–up phase and will continue throughout construction.

Adoption of environmental regulatory guidelines and advice is standard practice for CPB

Contractors during the development of Project specific documents and construction

techniques.

An initial workshop will be held with key Project staff, regulatory agency representatives and

Client representative at the commencement of the Project to discuss CPB Contractors’

techniques to foster and maintain a positive environmental management culture for the

Project team and promote environmental management best practice and sustainability

initiatives. The risk workshop will also identify high risk activities. Each activity will be

assessed to identify the relevant steps in the activity and the associated environmental

hazards, initial risk levels, mitigation measures and to avoid, manage and/or minimise the

risks and residual risks.

3.6 Objectives and targets

As a means of assessing environmental performance during construction of the Project,

environmental objectives and targets have been established. These objectives and targets

have been developed with consideration of key issues identified through the environmental

assessment and risk assessment process. The objectives and targets are consistent with

CPB’s Environment and Sustainability Policies and will assist in monitoring whether the

commitments of the policies are being met.

Each sub plan also includes a section for aspect specific objectives and targets. These

aspect specific targets reflect compliance with relevant Approvals and Licence conditions.


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The performance of the Project against the following objectives and targets and those listed

in the sub plans will be assessed and documented in the Project monthly performance

reports, bi-annual construction compliance reports and assessed annually as part of the

management review. Refer to Section 8 for all reporting requirements and timeframes.

All environmental management documentation including relevant environmental

management procedures are listed in Appendix A4 Document Register.

Environmental objectives and targets for the Project are provided in Table 3-5.

Table 3-5 Environmental objectives and targets

Objective Target Measurement and

Reporting Tools

Lead Indicators

Ensure environmental

management controls are

planned and implemented

100% of new/revised Work Method

Statements reviewed by Project

Environmental Team

Environmental management plans

include environmental

responsibilities allocated to relevant

site personnel.

Work Pack Procedure /

Monthly Reports

CEMP

Identification and

management of risks to,

and impacts on, the

environmental from the

Project work

Maintain a risk register, including an

environmental risk assessment

Track environmental compliance

against relevant requirements.

Risk Register

Construction

compliance reporting

Ensure regular and

specialist inspections of

work process occurs

100% of scheduled (internal)

inspections occur.

Project Commitment

Matrix

Monthly Reports


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Reporting Tools

Lag Indicators

Construction of the

Project in accordance

with environmental

approvals

Full compliance with statutory

approvals.

Audits, construction

compliance reporting,

management reviews

Compliance with all legal

requirements

No regulatory infringements (penalty

infringement notices or

prosecutions)

No formal regulatory warning.

Audits, construction

compliance reporting,

management review

Implement a rigorous and

comprehensive EMS that

meets the requirements

of AS/NZS ISO 14001

Address non-conformances and

corrective actions within specific

timeframes.

Audits, management

reviews

Engage with the affected

and broader community,

minimise complaints and

respond to any

complaints within a

suitable timeframe

Disseminate regular Project updates

and other information through the

Project website and other tools

identified in the Community

Involvement Plan (CIP)

Record and respond to complaints

within the timeframe specified in the

CIP

Review complaints

register, construction

compliance report and

audits

Continuously improve

environmental

performance

Develop and maintain a program of

ongoing environmental training

Include environmental awareness in

the induction and toolbox talks

Induction records

Toolbox talk records

Construction

compliance report,

management review


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Reporting Tools

Capture lessons learnt from

environmental incidents to minimise

repeat issues

Encourage and reward innovation

and effort throughout the workforce.

Implement sustainability

initiatives on the Project

Adopt sustainability leadership and

continual improvement initiatives

Integrate governance,

environmental, social and economic

considerations into decision-making

processes within the Project

Enhance positive environmental,

social and economic outcomes

wherever possible, while minimising

adverse impacts, resource use and

embodied impacts

Measure, monitor and

report on the

implementation of the

sustainability initiatives

identified in the CPB

Construction

Sustainability

Management Plan

3.7 Project refinements

3.7.1 General changes

Modifications or refinements to the Project may result from detailed design refinement or

changed circumstances during Construction. Roads and Maritime is responsible for formally

seeking approval from the Secretary for any Project modifications and for documenting

refinements that are consistent with the approved Project.

The Roads and Maritime Environment Manager (or delegate) is responsible for the

assessment of Project refinements and management of the consistency assessment

process. The CPB Contractors Environmental Site Representative is responsible for


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incorporating any new environmental impacts and/or new statutory approval requirements

into the appropriate environmental management documentation.

Any design changes or changes in scope of works will be communicated to the CPB

Contractor’s Environmental Site Representative. The CPB Contractors Environmental Site

Representative will undertake an environmental assessment and consistency review for the

proposed changes in consultation with the Roads and Maritime Environment Manager (or

delegate) to determine if a Project modification may be required.

Should the consistency review determine that a Project modification may be required i.e. the

impacts are of a nature and scale that it is not considered consistent with the Project

approval, the Environmental Representative will be informed immediately and a modification

application under Section 115ZI of the EP&A Act will be prepared and submitted to the

Secretary for determination.

The Roads and Maritime Senior Project Manager and Roads and Maritime Environment

Manager (or delegate) and will approve all refinements that are deemed consistent with the

Infrastructure Approval. Endorsement will be sought from the ER.

3.8 Ancillary facilities assessment criteria and management plan

An ancillary facility is defined in the Instrument of Approval as a “temporary facility for

construction including, for example, an office and amenities compound, construction

compound, batch plant (concrete or bitumen), materials storage compound, maintenance

workshop, testing laboratory or material stockpile area.”

In accordance with CoA A15, the location of proposed ancillary facilities are nominated and

detailed in this CEMP, Appendix B8 Ancillary Facility Management Plan (AFMP). In

accordance with CoA A15 the sites for ancillary facilities comply with the below:

The facility is a development of a type that would, if it were not for the purpose of the

CSSI, otherwise be exempt or complying development, or

Is at least 50 metres from any waterway unless an erosion and sediment control plan is

prepared and implemented so as not to adversely affect water quality in the waterway in

accordance with Managing Urban Stormwater series

Within or adjacent to land upon which the CSSI is being carried out

With ready access to a road network


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To prevent heavy vehicles travelling on local streets or through residential areas in order

to access the facility, except as identified in the documents listed in Condition A1

So as to be in accordance with the Interim Construction Noise Guideline (DECC 2009)

or as otherwise agreed in writing with affected landowners and occupiers

So as not to require vegetation clearing beyond the extent of clearing approved under

other terms of this approval except as approved by the ER as minor clearing

So as not to have any impact on heritage items (including areas of archaeological

sensitivity) beyond the impacts identified, assessed and approved under other terms of

this approval

So as not to unreasonably interfere with lawful uses of adjacent properties that are being

carried out at the date upon which construction or establishment of the facility is to

commence

To enable operation of the ancillary facility during flood events and to avoid or minimise,

to the greatest extent practicable, adverse flood impacts on the surrounding environment

and other properties and infrastructure

So as to have sufficient area for the storage of raw materials to minimise, to the greatest

extent practicable, the number of deliveries required outside standard construction

hours.

Where this criterion is unable to be met for any future proposed ancillary facility, an

assessment demonstrating how adverse impacts from construction or operation of the facility

can be mitigated and managed to an acceptable standard will be undertaken and provided to

the Secretary of DP&E for approval.

The CPB AFMP has been prepared in consultation with the EPA and the relevant council(s)

and shall be submitted to the Secretary for approval one month prior to installation of

ancillary facilities. The AFMP details the management of the ancillary facilities and includes:

a description of activities to be undertaken during Construction (including scheduling of

Construction)

a program for ongoing analysis of the key environmental risks arising from these

activities including an initial risk assessment undertaken prior to the commencement of

Construction

details of how the activities will be carried out to:

meet the performance outcomes stated in the EIS and SPIR


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manage the risks identified in the risk analysis.

3.8.1 Minor ancillary facilities

In accordance with CoA A17, minor ancillary facilities that comply with the requirements of

this condition do not require further approval from the Secretary of DP&E. CoA A17 states:

Minor ancillary facilities comprising lunch sheds, office sheds, and portable toilet facilities,

that are not identified in the documents listed in Condition A1 and which do not satisfy the

criteria set out in Condition A15 of this approval must satisfy the following criteria:

a) have no greater environmental and amenity impacts than those that can be

managed through the implementation of environmental measures detailed in the

CEMP required under Condition C1 of this approval; and

b) have been assessed by the ER to have:

a. minimal amenity impacts to surrounding residences and businesses, after

consideration of matters such as compliance with the ICNG, traffic and

access impacts, dust and odour impacts, and visual (including light spill)

impacts;

b. minimal environmental impact with respect to waste management and

flooding; and

c. no impacts on biodiversity, soil and water, and heritage items beyond those

already approved under other terms of this approval.

Refer to CEMP Appendix B8 Construction Ancillary Facility Management Plan for full details

of proposed ancillary facilities.

3.9 Sustainability

The Sustainability Policy describes CPB Contractors’ commitment to continual improvement

in environmental and sustainability performance and compliance with applicable legal

requirements. The Sustainability Policy will be displayed on the Project website, displayed at

the site office, and communicated to staff and other interested parties via inductions and

ongoing awareness programs.

A copy of the Sustainability Policy is provided in Appendix A3.


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In accordance with the G1 specification, a Construction Sustainability Management Plan

(CSMP) including sustainable procurement requirements will be developed for the delivery

phase of the Project to be implemented during construction of the Project.

This plan will embed Project sustainability objectives, commitments and targets into the

Project delivery management systems. The CSMP will incorporate and meet the relevant

Project conditions of approval (CoA E51, E52) and contract requirements in relation to

sustainability of the Project.

3.9.1 Sustainable Procurement

As a member of the CIMIC group of companies, CPB Contractors must through its Project

activities, including its engagement of third parties, meet the performance expectations

outlined in the CIMIC Sustainability Policy (Refer Appendix A3), Group Procurement Policy

(Refer Appendix A8) and Dealing with Third Parties Policy (Refer Appendix A9).

The Sustainability Policy places expectations on its employees and third parties ‘of

environmentally and socially responsible sourcing and governance’ and to ‘seek

opportunities to collaborate with the supply chain to drive innovation and create mutual

value’. It also expects its employees and third parties to promote a culture of accountability

for sustainability outcomes and improve the sustainability knowledge and skills of

employees, enhance resilience to climate change and use resources efficiently. Further to

this, CPB Contractors’ Environmental Policy, which applies to all business entities and

activities, expects the risk assessment process to ‘identify opportunities for improving

efficiency in the use of natural resources, enhancing positive environmental impacts and

driving innovation’.

The Principles of ISO20400 Sustainable Procurement have been integrated into the CIMIC

Group Governance System, by means of the following system management tools described

in Section 4. All tools are used in conjunction with CPB Contractors’ suppliers and

subcontractors.


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Table 3-6 Sustainable Procurement Requirements, Objectives and Targets

Sustainable Procurement Requirements

Potential suppliers to provide environmental and sustainability policy.

Objective Target

Sustainability considered as

part of the procurement

process

100% completion of Tender Submission Questionnaire sustainability

section (including provision of sustainability policy and its

implementation).

Supplier evaluation

incorporates sustainability

100% of supplier evaluations consider environment and sustainability

aspects through use of qualitative criteria Tender Evaluation /

Interview Form.

Monitor procurement

sustainability performance

Supplier sustainability objectives and/or targets monitored and

reported.

3.9.2 Supplier Selection

Initial selection and the retention of Suppliers will be facilitated by a review and assessment

of triple bottom line performance. This process will assess the ability of given suppliers to

satisfy identified safety, environmental, quality and financial performance expectations.

The Sustainability Manager and Commercial Manager will work together to oversee actions

that embed sustainability into the procurement process, including:

Ensuring procurement activities meet the requirements to achieve full points to

contribute to the IS rating scheme Version 1.2 Pro-1 and Pro-2 credits

Issuing targeted statements of our sustainable procurement commitments to suppliers,

including the Project’s sustainability targets

Briefing suppliers on sustainability requirements, including the documentary evidence

required for the IS rating

Requesting suppliers to complete CPB Contractors’ Prequalification Questionnaire to

confirm details of their sustainability and environmental policies


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Evaluating suppliers’ suitability using the Prequalification Questionnaire to collect

qualitative data on environment, quality, safety, industrial relations and people and

capability performance

Helping suppliers strengthen or develop their sustainability policies to ensure they are

effectively contributing to the Project’s sustainability performance

Encourage major suppliers to join the Sustainability Supply Chain School and complete

the self-paced learning program to increase their understanding of applied sustainability,

and ability to contribute to industry-wide sustainability performance

Engaging suppliers early in the procurement process to identify opportunities for

innovation or value engineering, in accordance with CPB Contractors’ Procurement Plan

Using the Request for Quotation to invite suppliers to identify Project-specific

environmental, local content and stakeholder opportunities that contribute to

sustainability performance

Including specific sustainability requirements within supplier scopes of work

Selecting suppliers using CPB Contractors’ supplier evaluation process, which assigns

30% of weighting to an index of non-financial criteria including sustainability,

environment, safety and innovation

Assessing suppliers’ delivery performance in accordance with the CIMIC Group

Procurement Procedure which uses weighted criteria, such as compliance with

sustainability/environmental regulations (15%), compliance with health, safety and

labour standards (15%) and quality (15%)

Providing regular feedback to suppliers, celebrating success and collaboratively

resolving non-conformances.

Title: Construction Environmental Management Plan- The Northern Road Upgrade between Littlefields Road and Glenmore

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4. Implementation and operation

This CEMP is CPB Contractors’ primary management plan for a suite of environmental management

documents. It provides a structured and systematic approach environmental management.

The primary purpose of the system of documentation is to:

Ensure compliance with all applicable environmental laws, obligations and approvals

To minimise environmental impacts

The structure of the CPB’s Environmental Management System relevant to the Project is shown

Figure 4-1.

In addition to the CPB Contractors

Project Management Plan, other Project

plans that interface with the CEMP

include:

Construction Management Plan;

Engineering and Design

Management Plan;

Quality Management Plan;

Safety and Health Management

Plan; and

Completion Management Plan.

This CEMP is based on the requirements of CPB Contractors’ Management System and the Northern

Road Project Overarching CEMP.

The CPB Contractors management system is certified to conform to AS/NZS ISO 14001:2015

Environmental management systems – requirements with guidance for use.

CPB Contractors Management System


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The CPB Contractors Management System has been developed and implemented to ensure a

consistent approach to Project delivery. The management system comprises the following

components:

Policies

A policy is a statement of strategic intent and commitment. It defines the mandatory requirements that

CPB Contractors expects at all levels of the organisation. Refer to Appendix A3 for CPB’s

Environment and Sustainability Policies. Both policies will be displayed on the Project website and at

the Project site offices, and communicated to staff and other interested parties via inductions and

ongoing awareness programs.

Project Management Plan

The Project Management Plan outlines how the Project will be managed and it is supported by a suite

of functional management plans.

Procedures and Work Instruction

Procedures and Work Instruction specify how to undertake and control specific activities. They define

roles and accountabilities, and list the tools or knowledge documents to be used. Where appropriate

and approved by the respective CPB business unit functional manager, Project specific procedures

are produced to reflect specific Project circumstances.

Tools

Tools are pre-formatted documents such as forms and templates that are required to be completed as

part of a Procedure.

Knowledge documents

Knowledge documents are reference material to provide context, additional information or guidance to

a Policy or Procedure.

Business Applications

Business Applications are the software tools used to manage our business and support our

operations.


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Instrument of Approval - CoA Environmental Impact Statement

and Submissions Report Relevant

Legislation

CPB Work Packs

& EWMS

System Procedures And forms

Monitoring and Inspection

Auditing and Reporting

Management

Review

Compliance

Tracking

Program

Corrective action

Overarching CEMP

&

CCEMP


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4.1 Environmental Management Sub Plans and Strategies

A number of environmental management Sub plans support the CEMP. These documents have been

prepared to identify requirements and processes applicable to specific impacts or aspects of the

activities described in Section 2. They address requirements of the CoA, Environment Protection

Licence (EPL) conditions, Roads and Maritime specifications and mitigation measures identified in the

environment assessment documentation.

Environmental strategies will be developed as required throughout the Project. These will also guide

environmental management of potential impacts on-site.

A list of construction Sub plans are provided in Table 4 1.

Table 4-1 Environmental management sub plans

NSW-CoA Document Location Document Title

CoA C4(a) Appendix B1 Construction Traffic and Transport

Management Plan

CoA C4(c) Appendix B2 Construction Flora and Fauna Management Plan

(including Vegetation, Clearing and Grubbing Plan

and Root Ball Management Plan)

CoA C4(b)

CoA C9(b)


CoA C4(d)

CoA C9(c)


(including Site Stabilisation Sub-Plan and Flood

Management Sub-Plan – G38)

CoA C4(e) Appendix B5 Construction Heritage Management Plan

CoA C9(a) Appendix B6 Construction Air Quality Management Plan


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NSW-CoA Document Location Document Title

Appendix B7 Construction Waste, Energy and Resource

Management Plan

CoA A16 Appendix B8 Construction Ancillary Facilities Management Plan

Appendix B9 Construction Community Communication Strategy

(including Community Involvement Plan and Crisis

Communication Sub-Plan)

CoA C4(d)

CoA C9(c)


(including Asbestos Management Plan, and

Remedial Action Plan (as required))

Appendix B11 Construction Pollution Incident Response Plan

(including Emergency Spill Response)


4.2 Environmental Work Method Statements and Work Packs

Environmental Work Method Statements (EWMS) and Work Packs are the main site-based

documents used by CPB to identify and manage environmental risks associated with all construction

activities especially in or adjacent to environmentally sensitive areas.

A series of EWMS’s and Work Packs will be prepared to address the combined impacts of erosion

and sedimentation, water quality control, impacts on fauna, property access, access across creeks,

noise, dust and vegetation removal. All EWMS will be prepared and reviewed by Roads and Maritime

Project Manager, Roads and Maritime Environmental Manager (or delegate) and the ER prior to the

commencement of the Construction activities to which they apply.


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The EWMS’s and Work Packs will utilise specific information from the CEMP as it applies to each

activity and work zone and must include a sequence of work and environmental controls to be

implemented in each work phase. As such, they will include but not be limited to the following:

Description of the works/activities including machinery;

Outline of the sequence of the work/activities;

Identification of potential environmental risks/impacts due to the works/activities;

Evaluation of methods to eliminate/reduce the environmental risk;

Mitigation measures to reduce the environmental risk;

Any safeguards resulting from consultation with public authorities and other stakeholders;

A map indicating the locations of sensitive locations (i.e. threatened species) and likely potential

impacts;

Identification of work area and exclusion areas;

Operation and monitoring measures to eliminate/reduce environmental impacts;

A process for assessing and reporting the performance of the implemented environmental control

measures; and

A process for resolving environmental issues or conflicts and reporting outcomes.

All CPB Contractors personnel and sub-contractors undertaking a task governed by a EWMS and

Work Packs shall have signed on to the documents, which demonstrates that they have participated in

training and awareness of the specific EWMS and Work Pack, and that they have understood their

obligations prior to commencing work.

EWMS shall be prepared for the following activities:

Activities assessed as having high environmental risk

Activities that impact on environmentally sensitive areas and on Aboriginal archaeological sites;

Topsoil stripping including temporary stockpiling and disposal of excavated material and protocols

for the management of materials containing asbestos;

Activities that involve work in waterways or that pose a risk to receiving water quality, for example:


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▪ Construction and operation of sediment basins and/ or buffer swales and connecting

drainage for the associated catchment area;

▪ Construction of culverts, including associated staging, flow diversions, any dewatering,

short and long term stabilisation and removal of existing structures;

▪ Vegetation clearing and grubbing;

▪ Activities where Construction water may be discharged into natural waterways;

▪ Construction and operation of concrete wash out areas;

EWMS shall be forwarded to the appropriate regulatory Authority (for high risk activities), the

Environmental Representative and Roads and Maritime for review at least 21 working days prior to

commencement of the Works and any Temporary Work referred to in the EWMS.

Proposed changes to EWMS shall be advised to the appropriate regulatory Authority, the

Environmental Representative and Roads and Maritime before the changed work method is adopted.

Roads and Maritime shall be consulted to determine which EWMSs require consultation with

regulatory Authorities prior to being approved.

A register of EWMS will be maintained in Appendix A4.

EWMS shall be submitted to Roads and Maritime is accordance with the HOLD POINT requirements

listed in Roads and Maritime Specification G36 Clause 3.2.4.

EWMS shall be submitted progressively to suit the Construction stages.

4.3 Roads and Maritime-nominated hold points

As nominated in Roads and Maritime Specifications approval is required from the Roads and Maritime

Representative prior to commencement, or recommencement, of certain activities. Hold Points will be

incorporated into work procedure documentation (e.g. Construction Area Plans, Work Packs and/or

ITPs). The Roads and Maritime Representative will be provided with reasonable opportunity to

witness any inspections and tests preceding the release of Hold Points. The release of a Hold Point by

the Roads and Maritime Representative will be documented and controlled. Table 4-2 lists Roads and

Maritime hold points relevant to environmental management for the Project.


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Table 4-2 Roads and Maritime hold points

Roads and Maritime

Hold Point References

Roads and Maritime Hold Point Details

Submission details

G36 3.1 Submission of CEMP and

selected EMS documents

At twenty (20) working days prior to the proposed

commencement of the stage of Work under the

contract, submit the CEMP and associated Sub

plans and/or EWMS, as well as the EMS

documents listed in Clause 3.1.

G36 3.2.2 Obtaining of approvals,

licences and permits

At least five (5) working days prior to the activity,

provide to the Roads and Maritime Representative

evidence of receipt of the approval, licence and/or

permit from the relevant authority.

G36 3.2.4 Submission of EWMSs At least twenty one (21) working days prior to the

proposed commencement of each applicable work

activity, submit the EWMS documents, addressing

the issues listed in Clause 3.2.4 for the nominated

work activity.

G36 3.5 Submission of Draft

Environmental Training

Materials

Drafts of all environmental induction and/or online

materials must be provided to Roads and Maritime

at least two weeks before it is planned to be used.

G36 3.10 Any activity that causes or

has the potential to cause

harm to the environment due

to your failure to meet your

environmental obligations

under the deed

Verification that environmental nonconformities has

been rectified.


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Roads and Maritime



Submission details

G36 4.2 Suspected or potentially

contaminated land

At least five (5) working days prior, submit your

Remediation Action Plan to be prepared by you,

and relevant procedures.

G36 4.7 Commencement of pile

driving, excavation by

hammering or ripping,

dynamic compaction or

demolition operations or any

other activities which may

cause damage through

vibration

At least ten (10) working days prior, submit to the

Roads and Maritime Representative a copy of the

Building Condition Inspection Reports or the

combined Noise and Vibration Management sub

plan.

G36 4.9 Engagement of the

archaeological consultant

At least 5 working days prior to your proposed

engagement of the consultant, provide details of

your proposed archaeological consultant and the

proposed salvage excavation methodology.

G36 4.9 Commencement of

Construction in the vicinity of

the partially and totally

impacted sites

Evidence from the archaeological consultant

confirming that the salvage excavation is complete.

G36 4.11 Transport of waste to a place

that is not owned by Roads

and Maritime and is not a

licensed waste facility

Completed and signed original copy of “s.143

Notice” received from the landholder receiving the

waste with evidence that the Waste Site has the

appropriate planning consent.


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Roads and Maritime



Submission details

G36 4.13 Working in or near the

environmentally sensitive

areas

At least five (5) working days prior, provide to the

Roads and Maritime Representative a copy of the

EWMS for working in or near the ESA and written

notice that the ESA are clearly delineated with

locations and boundaries signposted.

G36

4.15.2

Pre-Construction Land

Condition Assessment

Pre-Construction land condition assessment report

is required for each area intended for use for site

facilities, and evidence of any necessary statutory

and environmental approvals.

G38 3.1 Submission of ESCP(s)

where required

Commencement of work requiring the installation of

erosion control and sediment capture measures not

previously addressed by ESCP and authorised by

earlier Hold Point release.

G40 2.4 Clearing and Grubbing Clearing and Grubbing Plan and report on the

presence of weeds and unsound trees together with

written notice that limits of clearing and areas of

weed infestation identified in the ecologist report, at

least seven days before starting any clearing.

4.4 Internal Approvals/Permit Systems

Internal permit systems or processes are tools used by CPB Contractors’ Environmental Site

Representative and other relevant managers such as the Safety or Construction Manager, to assist in

assessment of upcoming works such as dewatering activities or clearing activities.

Prior to approving these permits, assessment considerations include:


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Project obligations including but not limited to CoAs, EPL conditions and Roads and Maritime

specifications

Work techniques or methodologies and associated P0roject procedures

Any need for external approvals (e.g. EPL variations).

The following internal Permit Systems will be implemented during the delivery of the Project:

▪ Dewatering Permit

▪ Land Disturbance Permit

▪ Out of Hours Works Permit

▪ Permit to Enter Protected or No-Go Area

▪ Material Movement Permit.

The Dewater Permit will be used for all dewatering operations, including sediment basins and any

other water to be released from the Construction site. This internal permit will document measures to

avoid pollution, pump location/size and suction heights, release qualities/limits, locations of approved

release points, monitoring of discharge, and Environmental team signoffs before release.

The Land Disturbance Permit (LDP) will be used to identify environmental sensitive areas and utilities

in proximity to Construction activities. It will cover all clearing and earthworks activities as well as

works in new areas, and will document environmental control measures and Environmental Team

signoffs.

An Out of Hours Permit will be implemented for all required out of hours works approved in

accordance with Instrument of Approval and EPL. This permit will include measures to reduce

impacts, location of equipment to minimise impacts, monitoring of out of hours works and

Environmental signoffs on the permit before release.

Entry into Environmentally Sensitive Areas (ESA) will be avoided at all times. However, should entry

be required this will be managed in accordance with an authorised Permit to Enter Protected or No-Go

Area, approved by the Environmental Site Representative. This permit will include details of proposed

works, measures to reduce impacts, consultation with the relevant Authority and Roads and Maritime

Representative as required, and sign-offs on the permit before release.


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The Material Movement Permit will be used to identify all materials to be exported for appropriateness

of receiving facility, material tracking, appropriate stockpiling location and waste classification

purposes.

A log of all internal permits issued shall be held and/or reviewed by the Environmental Site

Representative.

4.5 Erosion and sediment control plans

Appropriate planning is crucial to effective management of erosion and sedimentation on site. Erosion

and sediment control plans (ESCP’s) are planning documents which clearly show the site layout and

the approximate location of erosion and sediment control structures. ESCP’s will be developed for all

work areas prior to commencing activities.

Project Engineers, Superintendents, Foremen, Soil Conservationists, and environmental management

staff will be responsible for the development and implementation of ESCP’s on site. This will ensure

that erosion and sediment management is incorporated into the planning phase of Construction

activities.

ESCP’s will be regularly reviewed as site conditions change and flow paths are altered (e.g. the

reshaping of drainage lines to direct sediment laden runoff). Once approved, all revisions will be

controlled and allocated an appropriate revision number. ESCP’s will be maintained in a site specific

ESCP register and available to site personnel for reference. A process for the preparation, review and

auditing of ESCP’s is detailed in Appendix B4 Construction Soil and Water Management Plan.

4.6 Working hours

4.6.1 Hours of work

In accordance with NSW-CoA E23 and the Project EPL, work will be undertaken during standard

Construction working hours:

7:00 am to 6:00 pm Monday to Friday

8:00 am to 1:00 pm Saturday

at no time on Sunday or public holidays.


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As required by NSW-CoA E24, activities except as permitted by the Project EPL, highly noise

intensive works that result in an exceedance of the applicable noise management level at the relevant

receiver must only be undertaken:

between 8:00 am to 6:00 pm Monday to Friday

between 8:00 am to 1:00 pm Saturday

in continuous blocks not exceeding three hours each with a minimum respite from those activities

and works of not less than one hour between each block.

'Continuous' includes any period during which there is less than a one hour respite between ceasing

and recommencing the work.

All conditions relating to Construction hours outlined in the Project EPL will be complied with.

In accordance with NSW-CoA E25, CPB Contractors will identify and consult with receivers identified

as being subject to levels that exceed the Highly Noise Affected criteria with the objective of

determining appropriate hours of respite unless an agreement is reached with those receivers.

4.6.2 Variation to hours of work

Works associated with the delivery of the Project may be undertaken outside the hours of work

identified in Hours of work Section 4.6.1 in the following circumstances:

for the delivery of materials required by the NSW Police Force or other authority for safety

reasons or

where it is required in an emergency to avoid injury or the loss of life, to avoid damage or loss of

property or to prevent material environmental harm or

where it causes LRAeq(15 minute)R noise levels:

o no more than 5 dB(A) above the day, evening and night rating background level at

any residence in accordance with the Interim Construction Noise Guideline (DECC,

2009) and

o no more than the noise management levels specified in Table 3 of the Interim

Construction Noise Guideline (DECC, 2009) at other sensitive land uses and


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o continuous or impulsive vibration values, measured at the most affected residence are

no more than those for human exposure to vibration, specified in Table 2.2 of

Assessing Vibration: a technical guideline (DEC, 2006) and

o intermittent vibration values measured at the most affected residence are no more

than those for human exposure to vibration, specified in Table 2.4 of Assessing

Vibration: a technical guideline (DEC, 2006) or

o no more than 15 dB(A) above the night time rating background level at any residence

during the night time period, when measured using the LRAeq(1 minute)R noise descriptor or

o where different hours are permitted or required under an EPL in force in respect of the

works, in which case those hours must be complied with.

On becoming aware of the need for emergency works in accordance with the above, CPB Contractors

shall notify the Roads and Maritime Project Manager, the ER and the EPA’s Environment Line of the

need for those works. CPB Contractors will submit a report to the EPA by 2pm on the next business

day after the emergency works commenced that describes:

the cause, time and duration of the emergency

action taken by or on behalf of the licensee in relation to the emergency

details of any measures taken or proposed to be taken by CPB Contractors to prevent or mitigate

against a recurrence of the emergency.

CPB Contractors will use its best endeavours to notify all affected sensitive receivers of the likely

impact and duration of those works.

CPB Contractors will prepare a procedure for out of hours work, prepared in accordance with the

Construction Noise and Vibration Guidelines (Roads and Maritime, 2016). The procedure will be

prepared to address the requirements of NSW-CoA E26 and E27 and the EPL relating to out of hours

works (OOHW). Refer to Appendix B3 Construction Noise and Vibration Management Plan.

Approvals for any changes to the Construction hours outlined in Section 4.6.1 above will be

maintained within the Project’s environmental management systems documentation.


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4.6.3 Community agreements for works outside of standard Construction hours

Works outside of standard Construction hours that do not meet the circumstances listed in Section

4.6.1 above may be undertaken if an agreement between CPB Contractors and a substantial majority

of noise sensitive receivers has been reached, where approved under the EPL, for OOHW not

approved by other EPL conditions. Further details of the requirements, including community

consultation, relating to community agreements are provided in the CCNVMP.

4.7 Environmentally sensitive area plans

The Project traverses a diversity of environmental and socially sensitive areas and sites. To assist

pre-Construction planning and onsite Construction management, these site constraints will be

consolidated by CPB Contractors on a series of map-based sheets that extend the length of the

Project.

Sensitive area plans (SAPs) include information pertaining, but not limited to:

Potential or actual acid sulphate soil areas

Contaminated sites

Monitoring locations for groundwater, surface water and dust

Noise sensitive receivers e.g. residential dwellings, educational institutions

Flora features, including threatened species and endangered ecological communities;

Aboriginal and non-Aboriginal heritage sites, including items, places, objects and sites;

Local waterways

Warragamba Pipelines; and

Recorded threatened fauna sightings.

Environmental sensitive area maps are included in Appendix A6. They are working elements of the

CEMP and will be revised throughout Construction to reflect true ground conditions and the most up-

to-date information available on sensitive sites.

Environmental sensitive area maps will be used in conjunction with EWMS’s to help identify key risk

areas and to promote ongoing communication to Construction personnel during the Project.


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4.8 Resources, roles, responsibilities and authority

The environmental management roles and responsibilities for the Construction phase of the Project

are described as follows. The initial organisational chart is provided in this CEMP Appendix A5.

4.8.1 Roads and Maritime Project Director

The environmental responsibilities of the Roads and Maritime Project Director include (but are not

limited to):

Evaluate and advise on high risk compliance issues relating to CPB and Roads and Maritime

environmental requirements; and

Provide Construction CPB management with environmental advice and/or directions, in

consultation with Roads and Maritime environmental staff.

4.8.2 Roads and Maritime Senior Project Manager

The environmental responsibilities of the Roads and Maritime Senior Project Manager include (but are

not limited to):

Evaluate and advise on high risk compliance issues relating to CPB and Roads and Maritime

environmental requirements;

Review and endorse documentation to be submitted to the Secretary of DP&E and the Federal

Minister of DoEE for approval;

Have oversight of the review and approve any environmental management plans for the Project or

related activities that are not required to be approved by the Secretary of DP&E in consultation

with Roads and Maritime environmental staff and the ER; and

Provide CPB Contractors’ management team with environmental advice and/or directions, in

consultation with Roads and Maritime environmental staff.

4.8.3 Roads and Maritime Project Managers

The environmental responsibilities of the Roads and Maritime Project Managers include (but are not

limited to):

Evaluate and advise on compliance with Roads and Maritime environmental requirements;


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Review and approve any environmental management plans for the Project or related activities that

are not required to be approved by the Secretary of DP&E; and

Provide Construction CPB staff with environmental advice and/or directions, in consultation with

Roads and Maritime environmental staff.

4.8.4 Roads and Maritime Environmental Manager (or delegate)

The environmental responsibilities of the Roads and Maritime Environmental Manager (or delegate)

include (but are not limited to):

Review any environmental management plans and related documents prepared for the Project;

Review and consider minor Project refinements that are consistent with the Project environmental

assessment in accordance with the Roads and Maritime Part 5.1 environmental assessment

procedure;

Monitor the environmental performance of the Project in relation to Roads and Maritime

requirements; and

Provide guidance and where appropriate, monitor compliance with DP&E post approval document

submission requirements.

4.8.5 Independent Environmental Representative (ER)

The environmental responsibilities of the ER are detailed in NSW-CoA A24 and include, for Stages 4,

5 and 6 of the Project:

receive and respond to communication from the Secretary in relation to the environmental


consider and inform the Secretary on matters specified in the terms of the Infrastructure Approval

consider and recommend to Roads and Maritime and CPB Contractors any improvements that

may be made to work practices to avoid or minimise adverse impact to the environment and to the

community


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review documents identified in NSW-CoAs C1, C4 and C9 and any other documents that are

identified by the Secretary, to ensure they are consistent with requirements in or under the

Infrastructure Approval and if so:

make a written statement to this effect before submission of such documents to the Secretary (if

those documents are required to be approved by the Secretary) or

make a written statement to this effect before the implementation of such documents (if those

documents are required to be submitted to the Secretary / Department for information or are not

required to be submitted to the Secretary/Department)

regularly monitor the implementation of the documents listed in NSW-CoAs C1, C4 and C9 to

ensure implementation is being carried out in accordance with the document and terms of the

Infrastructure Approval

as may be requested by the Secretary, help plan, attend or undertake audits of the development

commissioned by the Department including scoping audits, programming audits, briefings and site

visits, but not independent environmental audits required under NSW-CoA A35

as may be requested by the Secretary, assist the Department in the resolution of community

complaints

assess the impacts of minor ancillary facilities comprising lunch sheds, office sheds and portable

toilet facilities as required by NSW-CoA A17, and

prepare and submit to the Secretary and other relevant regulatory agencies, for information, an

Environmental Representative Monthly Report providing the information set out in the

Environmental Representative Protocol (DP&E, 2017) under the heading "Environmental

Representative Monthly Reports." The Environmental Representative Monthly Report must be

submitted within seven calendar days following the end of each month for the duration of the ER's

engagement for the Project, or as otherwise agreed with the Secretary in accordance with NSW-

CoA A26, facilitate and assist the Secretary in any audit of the ER’s exercise of its functions under

NSW-CoA A24.


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4.8.6 Environmental Review Group (ERG)

The ERG comprises the ER and representatives of Roads and Maritime, the Project delivery team,

regulatory authorities (EPA, NRAR, OEH) and local councils (Penrith City Council, Liverpool City

Council).

The purpose of the ERG is to ensure prompt and effective consultation and resolution of

environmental issues raised by or affecting Government agencies, Council, Roads and Maritime, the

Project teams for each Project stage to provide proactive advice on environmental management

issues on the Project and review the environmental performance of the Project.

The ERG will be maintained for the duration of the Project and will meet monthly (or as otherwise

agreed by the regulatory agencies and Roads and Maritime) and undertake environmental

inspections.

CPB Contractors’ relevant personnel including the Project Manager and Environmental Site

Representative will attend the ERG meetings.

4.8.7 CPB Project Manager

The environmental responsibilities of the Project Manager include (but are not limited to):

Ensure all works comply with relevant regulatory and Project requirements, including compliance

with the approvals, EPL, REMMs, Roads and Maritime specifications

Ensure the requirements of this CEMP are fully implemented and are not secondary to other

Construction requirements;

Endorse and support the Project environmental policy;

Liaise with Roads and Maritime and other government authorities as required;

Participate and provide guidance in the regular review of this CEMP and supporting

documentation;

Provide adequate resources (personnel, financial and technological) to ensure effective

development, implementation and maintenance of this CEMP;

Ensure that all personnel receive appropriate induction training, including details of the

environmental and community requirements;


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Ensure that complaints are investigated to ensure effective resolution; and

Stop work immediately if an unacceptable impact on the environment is likely to occur.

4.8.8 CPB Construction Manager

The environmental responsibilities of the CPB Construction Manager include (but are not limited to):

Plan Construction works in a manner that avoids or minimises impact to environment;

Ensure the requirements of the CEMP are fully implemented;

Ensure Construction personnel manage Construction works in accordance with statutory and

approval requirements;

Support CPB Contractors Environmental Site Representatives in achieving the Project

environmental objectives;

Ensure environmental management procedures and protection measures are implemented;

Ensure all Project personnel attend an induction prior to commencing works;

Liaise with Roads and Maritime and government authorities as required; and

Stop work immediately if an unacceptable impact on the environment is likely to occur.

4.8.9 CPB Superintendent and Foreman

The environmental responsibilities of the Superintendent and Foreman include (but are not limited to)

the following:

Undertake, implement and monitor environmental management controls as defined by the Project

environmental management systems including the OACEMP and this CEMP;

Ensure environmental risk assessment of upcoming works are completed prior to commencement

onsite;

Carry out pre-Construction inspections of environmental management controls and resources.

Delay the commencement of works if environmental controls are unsatisfactory;

Ensure site Construction activities comply with relevant EWMS, Work Packs and relevant records

are kept;

Ensure all site workers are site inducted prior to commencement of works;


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Identify resources required for implementation of the OACEMP and this CEMP

Attend to spills or environmental incidents that occur on-site;

Co-ordinate action in emergency situations and allocate required resources

Report activity that has resulted, or has the potential to result, in an environmental incident

immediately to the ESR; and

Stop activities where there is an actual or immediate risk of harm to the environment. Advise the

Project Manager, Construction Manager and ESR as relevant.

4.8.10 CPB Environmental Site Representative

The environmental responsibilities of the Environmental Site Representative include (but are not

limited to) the following:

Advise on environmental matters specified in Roads and Maritime specifications, the

environmental assessment documents, EPL and any other approval/licence/permit;

overall responsibility for the implementation of environmental matters on the Project

implementation of the OACEMP and CEMP

the development, implementation, monitoring and updating of this CEMP and sub-plans in

accordance with ISO14001

report to the CPB Project Manager on the performance and implementation of the OACEMP and

this CEMP

ensure management reviews of this CEMP are undertaken annually, documented and actions

implemented

ensure environmental risks of the Project are identified ongoing and appropriate mitigation

measures implemented

identify where environmental measures are not meeting the targets set and where improvement

can be achieved

ensure environmental protocols are in place and managed

ensure environmental compliance

obtain and update all environmental licences, approvals and permits as required


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liaise with the ER, the Roads and Maritime Environment Manager (or delegate) and approval

authorities

manage environmental document control, reporting, inductions and training

manage environmental reporting within CPB’s Project team and to the Roads and Maritime and

regulatory authorities

prepare reports on a monthly basis outlining the Project works undertaken and the achievements

that have been met, as well as identifying those areas where improvements were made

oversee site monitoring activities, site inspections, audits and site checklists

ensure monitoring records are appropriately maintained, reviewed and any non-compliance issues

addressed

record and provide written reports to the CPB Construction Manager of non-conformances or

corrective actions with the OACEMP and this CEMP. This may include the need to implement

additional, or revise existing, mitigation measures

provide reports to the CPB Project Manager on any major issues resulting from the Project

assist all site staff with issues concerning Project environmental matters

manage all sub-contractors and consultants with regard to environmental matters, including

assessing their environmental capabilities and overseeing the submission of their environmental

documents

develop and facilitate induction, toolbox talks, environment awareness notes and other training

programs regarding environmental requirements for all site personnel

notify Roads and Maritime and relevant authorities in the event of an environmental incident and

manage close-out of these

assist in identifying environmental risks and advise the CPB Construction Manager of any

requirements to avoid or minimise impacts

stop activities where there is an actual or immediate risk of harm to the environment, or to prevent

environmental non-conformities, and advise the CPB Project Manager, CPB Construction

Manager and CPB Superintendent

assist the CPB Community Relations Manager to resolve environment-related complaints


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develop, review and approve ESCPs in consultation with the CPB’s Superintendent, Site

engineers, Foreman and other relevant site personnel, as required; and

manage the day-to-day environmental elements of Construction.

The ESR will consult and co-operate with all relevant government agency representatives and will

assist during agency compliance audits.

The ESR shall notify Roads and Maritime immediately of any visit to the Project site by a government

agency representative. A report would be prepared on each occasion when the site is visited,

documenting the purpose and outcome of the visit (including any actions to be undertaken). This

report will be submitted to Roads and Maritime within one (1) working day of the government agency

visit.

4.8.11 CPB Project/Site Engineers

The environmental responsibilities of the Site / Project engineers include (but are not limited to) the

following:

Provide input into the preparation of environmental planning documents as required;

Ensure that instructions are issued and adequate information provided to employees that relate to

environmental risks on-site;

Ensure that the works are carried out in accordance with the requirements of the OACEMP, this

CEMP and supporting documentation, including the implementation of all environmental controls;

Identify any environmental risks;

Identify resource needs for implementation of CEMP requirements and related documents;

Ensure that complaints are investigated to ensure effective resolution;

Act in the event of an emergency and allocate the required resources to minimise the

environmental impact; and

Report any activity that has resulted, or has the potential to result, in an environmental incident

immediately to the CPB Superintendent and CPB’s ER’s.


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4.8.12 CPB Community Relations Manager

The environmental responsibilities of the Community Relations Manager (CRM) include (but are not

limited to) the following:

Ensure that all community consultation activities are carried out;

Report any environmental issues to the ESR raised by stakeholders or members of the

community;

Communicate general Project progress, performance and issues to stakeholders including the

community; and

Be available for contact by residents and the community at all reasonable times to answer any

questions and to address any concerns in relation to Construction;

Maintain the 24-hour complaints hotline; and

Maintain the complaints register in accordance with the Complaints Management System.

Refer to Community and Stakeholder Consultation Sub-plan for further details.

4.8.13 CPB Wider Project Team (including sub-contractors)

The environmental responsibilities of the wider Project Team (including sub-contractors) include (but

are not limited to) the following:

Comply with the relevant requirements of the CEMP, or other environmental management

guidance as instructed by a member of the Project’s management;

Participate in the mandatory Project/site induction program;

Report any environmental incidents to the CPB foreman immediately or as soon as practicable if

reasonable steps can be adopted to control the incident;

Undertake remedial action as required to ensure environmental controls are maintained in good

working order; and

Stop activities where there is an actual or immediate risk of harm to the environment and advise

the Project Manager, Construction Manager, Superintendent or ESR.


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4.9 Sub-contractor management

The CPB Contractors environmental site representatives will participate in tender assessment and

selection process. CPB Contractors will be responsible for the environmental performance of the sub-

contractor. CPB Contractors will specify environmental requirements and responsibilities to sub-

contractors in the contract documentation.

As a minimum, sub-contractors and their employees will be required to comply with the requirements

of the CEMP. Sub-contractors’ personnel are considered equivalent to CPB personnel in all aspects of

environmental management and responsibilities.

Subcontractors engaged on the Project will be required to undergo a thorough assessment prior to

selection. The ESR will be consulted on environmental requirements for subcontracts, and the

adequacy of proposed conditions.

Subcontractors will be made aware of CPB Contractors’ environmental requirements during the

selection process and start-up meetings.

The scope of work to be performed by each subcontractor will be reviewed to determine whether it

includes works for which Project planning and environmental risk assessments have been completed.

If so, the subcontractor will be formally informed of all relevant risks and existing Project documents,

systems and procedures to be followed prior to commencing works (in addition to having been

informed of these during the selection process). These may include the contents of the Construction

methodology, Construction Area Plans (CAPs), Work Packs (WPs) and environmental management

sub-plans.

For high risk environmental activities, the ESR will review the subcontractor’s scope of works with the

supervising engineer to:

Identify any new issues relevant to the subcontractor’s scope of works;

Identify any additional compliance requirement not captured;

Identify necessary approvals not already in place and obtain those approvals prior to any works

commencing; and

Update the relevant environmental sub-plans.


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Sub-contractors working on the Project shall complete Project inductions before commencing work on

site. The induction will address general and Project-specific environmental issues, including:

CPB Environmental Policy;

How the CEMP will be implemented on site – e.g. via site specific Work Packs;

High-risk environmental activities and associated management controls;

What to do in the event of an environmental incident; and

An assessment conducted upon completion of the induction.

Sub-contractors shall also:

Observe sub-contract and statutory requirements relating to environmental protection and follow

instructions issued by CPB Contractors and Roads and Maritime representatives;

Co-operate fully with site emergency incident procedures and consultative arrangements; and

If requested by CPB, produce documentation detailing their own proposed environmental

management procedures, and where necessary, to prepare their own environmental management

plans and/or environmental procedures to augment the Project’s environmental requirements.

Details within the sub-contractor’s environmental management plans and/or environmental procedures

shall be consistent with this CEMP and the environmental assessment documents. Such

documentation will include (as a minimum):

Responsibilities and authorities;

Training and qualifications in relation to work to be performed;

Environmental procedures in relation to the scope of works; and

Control measures adopted by the sub-contractor.

The sub-contractor will be informed of the requirement to provide all relevant data relating to their

works as per the National Greenhouse and Energy Reporting Act 2007 (Cth). Changes and variations

to sub-contractor scopes of work will be assessed and documentation will be amended accordingly.

Sub-contractors will also participate in communication forums and monitoring activities, including

toolbox talks, pre-start meetings, task observations, inspections and audits, incident investigations (as

required) and the development or review of Work Packs (as required).


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Sub-contractors will undergo all necessary environmental training. The required training will be

determined by reviewing the training matrix relative to the scope of work and roles being filled or

supplied by the subcontractor. CPB Contractors will regularly review and keep a record of:

Sub-contractor’s general work practices

The effectiveness of the sub-contractor’s environmental protection measures – e.g. via Task

Observations (aspect/activity specific inspection).

The sub-contractor’s compliance with the requirements of the OACEMP and this CEMP and,

The maintenance of environmental measures.


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5. Competence, training and awareness

To ensure this CEMP is effectively implemented, each level of management is responsible for

ensuring that all personnel reporting to them are aware of the requirements of this CEMP. The ESR

will coordinate the environmental training in conjunction with other training and development activities

(e.g. safety).

Four main forms of training shall to be provided, including:

Site inductions;

Toolbox talks;

Daily pre-start meetings; and

Role specific environmental awareness training.

5.1 Environmental induction

Prior to working on site all personnel and sub-contractors will undertake a site induction conducted by

CPB Environmental Site Representatives which includes environmental roles, responsibilities, controls

and procedures.

Temporary visitors to site for purposes such as deliveries will be required to be accompanied by

inducted personnel at all times.

Records of induction and training will be kept on a database including the topic of the training carried

out, dates, names and trainer details. Inductees will be required to sign-off that they have completed

the site induction and understand their responsibilities. The ER will review and approve the induction

program prior to the induction being delivered.

The following information shall be included:

relevant details of the OACEMP, this CEMPs, including all sub-plans, procedures and strategies,

their purpose and objectives

requirements of due diligence and duty of care


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relevant legislation, and conditions of environmental licences, permits and approvals

potential environmental emergencies on-site and the emergency response procedures

relevant details of the Pollution Incident Response Management Plan (PIRMP)

reporting and notification requirements for pollution and other environmental incidents

key environmental issues

mitigation measures for the control of environmental issues

complaints response and reporting

high risk activities and associated environmental safeguards and EWMS

site specific environmental management requirements and responsibilities

incident and emergency response and reporting requirements

information relating to the location of environmental constraints

sensitive area plans

environmentally sensitive locations and no-go/exclusion zones

site flagging protocol

erosion and sediment controls, water quality controls and sediment basin management

management of contaminated material (including asbestos impacted material)

location of identified potential contaminated land sites

signs of contaminated soil, including visual asbestos identification protocols

procedure for unexpected finds of contaminated land, asbestos or UXO

groundwater and surface water

mulch and tannin management

stockpile location criteria

working near or in drainage lines and creeks

the location of acid sulfate soils or potential acid sulfate soils

water quality management and protection measures

groundwater issues


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obligation to report and the process for reporting environmental issues on-site including damaged

environmental controls

obligations under the Biosecurity Act 2015 to prevent the spread of weeds during Construction

responsibilities under the National Parks and Wildlife Act 1974, including the need to cease work

immediately and report any object of potential Aboriginal heritage unearthed during clearing,

grubbing and earthworks operations

responsibilities under the Heritage Act 1977 if an object of potential Non-Aboriginal heritage is

uncovered during Construction

location of identified Aboriginal and non-Aboriginal archaeological heritage sites, areas of cultural

sensitivity and areas of archaeological potential and the kinds of historical relics, structures or

deposits which may be encountered during the Construction works

responsibilities under the Contaminated Land Management Act 1997

noise, vibration and air quality management controls

standard Construction hours and the process for seeking approval for out of hours works,

including consultation

noise management measures during night works

location of noise, vibration and air quality sensitive receivers

road safety

road occupancy and other temporary and interim traffic arrangements

response procedure for dealing with traffic incidents

the requirement to maintain surrounding property access for residences, business owners, and

their visitors, and to minimise disruptions to these properties for the duration of Construction

the location of refuse bins, washing, refuelling and maintenance of vehicles, plant and equipment

waste minimisation principles, waste reporting and waste / recycle storage requirements

best practice energy efficiency

equipment start up and shut down procedures

sustainability management measures and initiatives


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boundaries for vegetation clearing, fauna and fauna habitat management, including awareness of

threatened fauna species and fauna rescue

weed control measures

specific species likely to be affected by the Construction works and how these species can be

recognised

specific responsibilities for the protection of flora and fauna.

The ESR may authorise amendments to the induction where required to address Project

modifications, legislative changes or amendments to the OACEMP, this CEMP or related

documentation.

A record of all environment inductions will be maintained in a Project induction and training register

and kept on-site. The training register will identify who is trained, when trained, the trainer and what

they were trained in.

CPB Contractors will provide refresher environmental awareness training as required, but at not less

than six monthly intervals, based on the environmental risk assessment and turnover of Project

personnel. Refresher environmental awareness training will be included on the register of

environmental training.

5.2 Toolbox talks, training and awareness

Toolbox talks will be used to raise awareness and educate personnel on Construction-related

environmental issues. The toolbox talks are used to ensure environmental awareness continues

throughout Construction.

Toolbox talks will be tailored to specific environmental issues relevant to upcoming work, including

(but not limited to):

erosion and sedimentation control

dewatering

hours of work, including noise management strategies to be implemented for out of hours work

emergency and spill response

Aboriginal and non-Aboriginal heritage

threatened species and ecological communities

clearing controls and vegetation protection


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weed management

dust control

noise mitigation

EWMS, for relevant personnel.

Toolbox talk attendance is mandatory and attendees of toolbox talks are required to sign an

attendance form and the records maintained.

Targeted environmental awareness training will be provided to individuals or groups of workers with a

specific authority or responsibility for environmental management or those undertaking an activity with

a high risk of environmental impact. Topics covered may include those detailed above, or others

deemed necessary in the lead up to or during Construction.

Awareness notes, in the form of posters, booklets, or similar will be developed and distributed to the

Superintendent, Project Engineers, Foreman and other personnel with a responsibility for managing

specific work locations or activities. This documentation will be distributed to the broader Project

workforce through daily pre-starts meetings and made available in Project offices / break facilities.

The ER will review and approve the training program and monitor implementation.

5.3 Daily pre-start meetings

Daily pre-start meetings are used to inform the workforce of the day’s activities, safe work practices,

environmental protection practices, work area restrictions, activities that may affect the work,

coordination issues with other trades, hazards and other information that may be relevant to the day’s

work.

The Superintendent and/or Foreman will conduct daily pre-start meetings with the site workforce

before the commencement of work each day (or shift) or where changes occur during a shift.

The environmental component of pre-start meetings will include any environmental issues that could

potentially be impacted by, or impact on, the day’s activities. All attendees will be required to sign on

to the pre-start meeting and acknowledge their understanding of the issues explained.

Pre-start meeting topics, dates delivered and a register of attendees will be recorded and the records

maintained.


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5.4 Task-specific Environmental Training

Targeted environmental awareness training will be provided to individuals or groups of workers with a

specific authority or responsibility for environmental management or those undertaking an activity with

a high risk of environmental impact. Topics covered may include those detailed in previous sections,

or others deemed necessary in the lead up to or during construction.

The CPB Contractors’ Environment and Sustainability Managers will coordinate the environmental

training in conjunction with other training and development activities (e.g. safety). A training schedule

will be developed and will be updated / amended throughout the Project as required. Records of

training will be kept and training gaps for personnel identified throughout the works.

No Construction personnel or sub-contractors will be allowed to work on the Project without the

relevant environmental training requirements being met as per the training program.

The Environmental Representative will review and approve the Project training program and monitor

implementation.

5.4.1 Erosion and Sedimentation Training

Site-specific erosion and sedimentation (ERSED) training will be undertaken upon Project

commencement for key management and supervision staff including:

Area managers

Site Engineers, Project Engineers

Foreman and Leading hands

Labourers and personnel undertaking site activities.

This training will be a one-day BlueBook 2D Main Road Construction training adapted to the Project

works presented by an external provider including, but not limited to:

▪ Best practice implementation and maintenance of area-specific controls

▪ Updating controls in accordance with Project works

▪ Preparation for rain events

▪ Review of ERSED plans for specific areas.

ERSED refresher courses will be undertaken throughout the Project as required.


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5.5 Communications Training

All staff (including plant operators and truck drivers) and subcontractor personnel working on the

delivery of the Project will be required to behave in a courteous and professional manner when in

dialogue with any community member. All personnel will be:

trained on how to respond to community queries

aware of and abide by the requirements for the release of information

advised on the identity of the community within which they are working prior to their involvement in

the Contractor’s Work.

Community involvement obligations will be included in the site induction of all personnel working on

the Project.


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6. Communication

6.1 Internal communication

Clear lines of communication throughout all levels and functions (e.g. management, staff and sub-

contracted service providers) are key to minimising environmental impacts and achieving continual

improvements in environmental performance.

The environmental team will meet regularly to discuss any issues with management on-site, any

amendments to plans that might be required or any new / changes to Construction activities. Regular

meetings will also occur between the ER and Roads and Maritime environment staff to discuss

ongoing environmental performance and identify any issues to be addressed.

In addition, environmental team members will participate in toolbox talks on at least a regular basis.

This forum will provide an opportunity for the environment team members to communicate

environmental performance matters, to advise on any upcoming work in or near sensitive

environmental areas and receive feedback from onsite personnel.

6.2 External and government authority communication

CPB Contractors’ Environmental Site Representative will be the main point of contact regarding

specific environmental issues. The ESR is responsible for reporting on the ongoing environmental

performance of the Project to Roads and Maritime, the ER and the NSW EPA. The ESR will report

regularly to Roads and Maritime on progress and any key environmental matters, and to the EPA

through monthly reports. Other relevant government agencies will continue to be consulted throughout

Construction.

A list of relevant contact names, telephone numbers and fax numbers for Project stakeholders will be

maintained by the ESR onsite.

The name and contact numbers for two site personnel who are available to EPA on a 24-hour basis

and who have authority to take immediate action to shut down any activity or to affect any pollution

control measure as directed by an authorised officer of EPA are:

▪ CPB Environmental Site Representative: Ciaran McAleer 0455 494 163

▪ CPB Project Manager: Nick Fryday 0424 485 763


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Roads and Maritime will be immediately notified on each occasion that the site is visited by EPA and/

or other relevant agencies.

CPB Contractors will prepare a report for each occasion when the Site is visited by the EPA and/ or

other relevant agencies, notifying Roads and Maritime of the purpose and outcome of the EPA and/ or

other relevant agencies visit, and of all actions taken in response to the EPA visit and/ or other

relevant agencies.

The report will be provided to Roads and Maritime within one working day of the visit.

6.3 Community liaison and notification

Roads and Maritime has prepared a Community Communication Strategy (CCS) in accordance with

the requirements of NSW-CoA B1 to document the approach to stakeholder and community

communications for the Project. The CCS identifies opportunities for providing information and

consulting with the community and stakeholders during the Construction of the Project. CPB

Contractors will support the delivery of the CCS.

CPB Contractors has prepared and shall implement a Contractor’s Community Involvement Plan

(CCIP). Refer to Appendix B9 of this CEMP. The CIP has been prepared in accordance with the

CCS.

The CCS and CIP will be implemented for the duration of the Project. The CCS shall be implemented

for 12 months following the completion of all Construction stages of the Northern Road Project.

The CCS and CIP include:

principles to guide the overall approach to community and stakeholder involvement

identification of the stakeholders and groups to be consulted during the Project

procedures and tools for the distribution of information about the Project, such as regular updates

about Construction activities, the program for Construction activities and key milestone dates

opportunities for the community to visit Project Construction sites

methods for involving Construction personnel in engaging with the local community;

methods and tools for engaging with the local community, including community forums to discuss

key environmental management issues of concern for the Project


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procedures and mechanisms:

detailing how the community can discuss or provide feedback in relation to the Project

detailing how the Project team will respond to community enquiries and feedback

describing how issues will be resolved or disputes meditated in relation to environmental

management and Construction of the Project.

procedures to consult with local communities potentially affected by the impacts of multiple

Projects in addition to the Project.

The CCS also provides details on the requirements for coordination and communication between all

Contractors working on the Northern Road Project stages, which will include:

liaison meetings

mailing list for all communications (including Community Updates)

email communication

Project briefings.

Where relevant, the Roads and Maritime Community and Stakeholder Engagement Advisor and the

CPB Contractors’ Community Relation Manager will undertake consultation with proponents of other

nearby developments to increase the overall awareness of Project timeframes and impacts.

Communication tools defined in the CCS & CIP include:

Targeted community open days

Media releases and advertisements in local and metropolitan papers

Public displays

Door-knocks

Letterbox drops

Community update newsletters, information brochures and fact sheets

Community information sessions and community forums

Signage at Construction sites


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Construction updates (including for councils, emergency services and bus operators)

Project Website

Focus meetings

Roads and Maritime 24-hour contact telephone number and email address.

6.3.1 Complaints and enquires procedure

Roads and Maritime have developed a Complaints Management System (CMS) to document overall

approach to complaints management for the Project. The CMS is consistent with AS-ISO 10002-2006

Complaints Handling in accordance with the requirements of NSW-CoA B6 and B7. CPB Contractors

will adopt the requirements of the CMS including relevant reporting requirements.

All community inquiries and complaints related to the Construction activities will be referred to the toll

free 24-hour community information line (1800 703 457), a postal address (Western Sydney

Infrastructure Plan, PO Box 973 Parramatta CBD NSW 2124) and email address

([email protected]) has been provided for receipt of complaints and enquiries. The

telephone number, postal address and email address were published in newspapers circulating in the

local area prior to the commencement of Construction and are provided on the Project website.

Information on all complaints received, including the means by which they were addressed, whether

resolution was reached and whether mediation was required will be included in a complaints register.

The information contained within the register will be made available to the DP&E on request in

accordance with NSW-CoA B8. In accordance with NSW-CoA A25, the Complaints Register will be

provided to the ER on a daily basis.

All complaints will be managed in accordance with the Community Communication Strategy (CCS)

and the CPB Community Involvement Plan (CIP), refer to Appendix B9, including complaints

handling, resolution and recording. Attempts will be made to resolve all complaints in accordance with

the CCS. Refer to Section 9.6 of the CIP for a detailed flowchart outlining the complaints and enquiries

response process.

An initial written response to email complaints will be provided within 24 hours (or during the next

business day if received out-of-hours) and a resolution provided within 7 business days, if the

complaint cannot be resolved in the initial contact. All complaints will be investigated and the source of



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the complaint determined immediately, with a phone call made to the complainant (when received by

phone) within 2 hours.

A further detailed response, including steps taken to resolve the issue(s) that lead to the complaint,

will be provided within 10 days. All complaints should be closed off in the stakeholder database. At all

times the stakeholder will be kept informed of when they will receive a response.

The ESR will apply an adaptive approach to ensure that corrective actions are applied in consultation

with the appropriate Construction staff to allow modifications and improvements in the management of

any environmental issues resulting in community complaints.

CPB Contractors’ ESR will submit a report to the EPA each business day that provides details of all

complaints received in relation to Construction activities as regulated by the EPL. The report will be

prepared in accordance with the requirements of the EPL. A report is not required for any reporting

period where complaints have not been received.


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6.3.2 Project website

A website has been established for the Project (www.rms.nsw.gov.au/thenorthernroad) and will be

regularly maintained during Construction of the Project. The website will be kept up to date with the

latest Project information, environmental assessments, and will include all community updates. It will

also publish methods to communicate feedback, enquiries and complaints related to the Project.

In accordance with NSW-CoA B11, the following information will be maintained on the Project website:

information on the current implementation status of the Project

the EIS, the SPIR and any documentation relating to any modifications made to the Project

a copy of the Infrastructure Approval in its original form, a current consolidated copy of the

Approval (including any approved modifications to its terms), and copies of any approval granted

by the Minister to a modification of the terms of the Approval;

a copy of each statutory approval, licence or permit required and obtained in relation to the Project

and

a current copy of each document required under the terms of the Approval and any

endorsements, approvals or requirements from the ER and Secretary, published prior to the

commencement of any works to which they relate or before their implementation

any community agreement(s) between CPB and noise sensitive receivers under the EPL to

undertake works outside of standard Construction hours (refer Section 4.6.1) (personal details of

residents to be omitted)

information on how the public can make a complaint on the telephone complaints line and how

complaints will be processed.

Relevant Project information will be published on the website throughout the duration of Construction.

Confidential information, which may include the location of threatened species, Aboriginal objects or

places and personnel contact details, will be removed from all documents provided or made available

to the public.

In accordance with EPL Condition A2.5, premises maps will be made available for public viewing on

either the Contractor’s website or Roads and Maritime’s Project website no more than three business

days after the approval of the maps by the EPA.

http://www.rms.nsw.gov.au/thenorthernroad


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Monitoring data required under the EPL will be made available by the EPA on the EPA website and

published monthly by Roads and Maritime in accordance with the EPA Guide for publishing Pollution

Monitoring Data.


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7. Incidents and emergencies

7.1 Incident and emergency management

An incident is defined under the NSW Infrastructure Approval as:

An occurrence or set of circumstances that causes, or threatens to cause, material harm to the

environment, community or any member of the community, being actual or potential harm to the

health or safety of human beings or to threatened species, endangered ecological communities or

ecosystems that is not trivial or

An occurrence which results in non-compliance with the Infrastructure Approval where the meaning

of “material harm” applies for the purpose of the NSW Infrastructure approval only.

The environmental emergency contact personnel for the Project are:

CPB Environmental Site Representative: Ciaran McAleer 0455 494 163

CPB Project Manager: Nick Fryday 0424 485 763

All efforts will be undertaken immediately to avoid and reduce impacts of incidents and suitable

controls put in place.

In the event of an environmental incident, the following procedures and plans shall be implemented:

1. Roads and Maritime Environmental Incident Classification and Reporting Procedure – refer to

Appendix A7

2. CPB Contractors’ Manage and Report SHE Incidents Procedure will also be implemented.

Refer to Appendix A7

3. CPB Pollution Incident Response Management Plan - Refer to Appendix B11

These system documents provide the following details relevant to Construction related incidents and

emergencies:

Types of environmental incidents

Criteria for classifying of environmental incidents


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Processes for systematically responding to and managing emergency situations

Processes, and legal requirements (e.g. Acts, Regulations, EPL), for reporting and notification of

an environmental incident.

The Roads and Maritime procedure covers the management of events including:

Category 1 incidents:

Potential breaches of legislation or failures of process that result in actual off-site environmental

harm or

Residual on-site environmental harm or

Work undertaken outside approved areas, without required approval or without environmental

assessment or

Any Material Harm pollution incidents as defined by Part 5.7 of the POEO Act including:

Pollution incidents

Conservation breaches

Heritage breaches

Planning and compliance breaches

Category 2 incidents:

Failures of process or events that do not result in off-site environmental harm. These incidents may

result in temporary on-site environmental harm that can be rectified to pre-existing conditions.

Reportable events:

An event or unexpected find that occurs outside the scope of reasonable environmental controls

and mitigation measures

Regulatory action:


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Formal regulatory action from an environmental regulator (that has not already been reported in

conjunction with another incident).

These procedures cover the management of events such as, but not limited to:

Spills of fuels, oils, chemicals and other hazardous materials

Unauthorised discharge from sediment basins or other containment devices

Unauthorised clearing or clearing beyond the extent of the Project boundary or premises

Inadequate installation and subsequent failure of temporary erosion and sediment controls

Unauthorised damage or interference to threatened species, endangered ecological communities

or critical habitat

Unauthorised harm or desecration to Aboriginal objects and Aboriginal places

Unauthorised damage or destruction to any State or locally significant relic or Heritage item

Unauthorised damage to marine vegetation and mangroves

Unauthorised dredging or reclamation works within a watercourse

Potential contamination of waterways or land

Accidental starting of a fire or a fire breaking out of containment

Any potential breach of legislation, including a potential breach of a condition of an EPL, CoA, or

any agency permit condition

Works undertaken without appropriate approval or assessment under the EP&A Act

Works undertaken that are not in accordance with a Project EIS or Instrument of Approval

Unauthorised dumping of waste.

Incidents will be closed out as quickly as possible, taking all required action to resolve each

environmental incident.


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7.2 Incident Notifications

7.2.1 Roads and Maritime Notifications

Environmental incidents that are classified as Category 1 under the Roads and Maritime Procedure,

will be notified immediately to the Roads and Maritime Representative and Roads and Maritime

Environment Manager (or delegate).

Incident reports will be provided to Roads and Maritime Project Manager and the ER in accordance

with the Roads and Maritime Procedure, including lessons learnt from each environmental incident

and proposed measures to prevent the occurrence of a similar incident.

7.2.2 EPA Notifications

In accordance with CoA A43 and Part 5.7 of the POEO Act 1997, the EPA will be notified of any

environmental incidents or pollution incidents on or around the site via the EPA Environment Line (ph:

131 555). The circumstances where this will take place include:

a) If the actual or potential harm to the health or safety of human beings or ecosystems is not trivial

b) If actual or potential loss or property damage (including clean-up costs) associated with an

environmental incident exceeds $10,000 (or such other amount as prescribed by the regulations).

When required to notify the EPA, the Environmental Site Representative (or delegated member of the

Project’s Management team) will:

1. Notify of a pollution incident 'immediately' (i.e. reported promptly and without delay)

2. Notify all other relevant authorities, such as:

• EPA (131 555)

• Ministry of Health (via the local Public Health Unit (PHU) 02 9840 3603 / 02 9845 5555)

• WorkCover (13 10 50)

• Penrith Council (02) 4732 7777


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• Fire and Rescue NSW – 1300 729 579 (Note: should any incident involve the actual or potential

harm to human safety or health then NSW Fire and Rescue will be contacted on 000).

Copies of all records relating to environmental incidents shall be forwarded to the Roads and

Maritime’s Representative and the ER.

A record of EPA notification will be provided to the Secretary of DP&E in accordance with CoA A40

and A43.

7.2.3 Other Notification Requirements

Where an incident involves an Aboriginal site, the Office of Environment and Heritage and relevant

Aboriginal stakeholders will be notified and their input sought in addressing and managing the

incident.

• Where an incident involves an impact to a non-Aboriginal heritage item, this will be reported to the

Heritage Council and/or councils (depending on whether a state or local item).

7.2.4 Notification to the Secretary of DP&E and DoEE

In accordance with NSW-CoA A40 or A43 for incidents (other than those relating to the POEO Act

1997), Roads and Maritime will notify the Secretary of DP&E of incidents with actual or potential

significant off-site impacts on people or the biophysical environment within 24 hours of becoming

aware of the incident on weekdays, or the following business day on weekends. Full written details of

the incident will be provided to the Secretary of DP&E within seven days of the date on which the

incident occurred.

If statutory notification is given to the EPA as required under the POEO Act in relation to the CSSI,

such notification will also be provided to the Secretary within 24 hours after the notification was given

to the EPA.

Refer to Appendix B11 for CPB’s Pollution Incident Response Management Plan (including

Emergency Spill Response) for a summary of incident notification requirements.


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7.3 CPB Contractors’ Safety, Health & Environment (SH&E) Incident Management System

All Incidents will also be recorded in the CPB SH&E Incident Management System as soon as

possible following the incident (as outlined within CPB Incident Response Notification and Reporting

Procedure).

All Level 1 and Level 2 incidents will be reported to the CPB Environment Manager – NSW/ACT and

the EPA within the required timeframes.

7.4 Incident investigations

Where required, due to the severity or ongoing nature of the incident, investigations will be conducted

and action plans established in order that the event does not occur again.

An environmental investigation includes the following basic elements:

• Identifying the cause, extent and responsibility of the incident

• Identifying and implementing the necessary corrective action

• Identifying the personnel responsible for carrying out the corrective action

• Implementing or modifying controls necessary to avoid a repeat occurrence of the incident

• Recording any changes in written procedures required

• Advising the relevant government agencies if any substantial pollution has occurred.

In accordance with NSW-CoA A42, CPB Contractors will meet the requirements of the Secretary or

relevant public authority (as determined by the Secretary) to address the cause or impact of any

incident reported in accordance with NSW-CoA A40, within such period as the Secretary may require.

CPB Contractors will provide all records of incidents and regulatory action to the Roads and Maritime

Project team.

Where there are lessons learnt from the investigation or current procedures are identified as being

ineffective, CPB Contractors’ CEMP will be revised by the Environmental Site Representative to

include the improved procedures or requirement.


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8. Inspections, monitoring and auditing

8.1 Environmental inspections

The purpose of the inspections is to identify environmental management risks and avoid

environmental impacts from occurring. A summary of the approach to inspections is provided in the

sections below.

Copies of all environmental inspection reports prepared by CPB Contractors will be kept with the

Project records and closed out within the agreed timeframes.

8.1.1 CPB site inspections

Prior to the commencement of works on each shift, an inspection will be carried out and will include a

check of relevant environmental controls and resources required to ensure effective operation and

maintenance. Works are not to commence unless inspections are found to be satisfactory. The

relevant area Foreman will undertake these inspections. Any necessary actions or key environmental

issues relevant to the works for the day will be documented within either site diaries, and/or Pre-start

documentation.

The ESR (or delegate) will undertake weekly and post rainfall1 inspections of the work sites to

evaluate the effectiveness of environmental controls. The ESR will record inspection findings on an

inspection checklist. Inspections will also be carried out daily during rainfall that causes run-off to

occur and prior to any site closure of greater than 24 hours.

If any maintenance and/or deficiencies in environmental controls or in the standard of environmental

performance are observed, they will be recorded on the checklist form. Records will also include

details of any maintenance required, the nature of the deficiency, any actions required and an

implementation priority. Actions will be closed out in accordance with the identified priority and

evidence of close out will be kept on file.

1 ‘Post rainfall’ would typically relate to rainfall events where 10mm or more has fallen or rainfall

that has caused runoff from the site.


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8.1.2 Environmental Representative and Roads and Maritime

The Environmental Representative, the Roads and Maritime Environment Manager will undertake

regular inspections of works sites, and in particular during critical activities throughout Construction of

the Project.

These inspections would typically occur on a weekly or fortnightly basis depending on the complexity

and anticipated risks associated with the stage of Construction.

Inspections carried out will be in accordance with Roads and Maritime inspection procedure.

8.1.3 Environmental Review Group (ERG) inspections

ERG inspections will typically occur on monthly timeframe or as otherwise required depending on the

staging of the Project.

The role of the ERG is to provide proactive advice on environmental management issues and review

the environmental performance of the Project. Section 8.9 describes the process if the ERG raises

non-conformances or issues requiring corrective/preventative action during site inspections.

The ESR will participate in all ERG inspections to maintain appropriate records, identify required

actions and timeframes for implementation of corrective actions.

8.1.4 Inspections by EPA and other agencies

CPB Contractors will prepare a report on each occasion that the site is visited by the EPA and/ or

other relevant agencies. The report will advise Roads and Maritime of the purpose and outcome of the

EPA and/ or other relevant agencies visit, and of all actions taken by CPB in response to the EPA visit

and/ or other relevant agencies. The report will be provided to Roads and Maritime within one working

day of the visit.

8.2 Environmental monitoring

Monitoring will be undertaken to validate the impacts predicted for the Project, to measure the

effectiveness of environmental controls and implementation of this CEMP, and to address approval

requirements. The monitoring requirements for required aspects are included in the relevant


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environmental management Sub plans and summarised in Table 8-1 Summary of Environmental

Monitoring

Table 8-1 Summary of Environmental Monitoring

CoA Description Relevant Sub plan Reporting Requirements

A27 Compliance Monitoring

including review of CoA

compliance

Compliance Tracking

Program

Bi-annual Compliance

reports to Roads and

Maritime.

Roads and Maritime shall

then submit to EPA and

DP&E

C9 Water Quality Plan and

Monitoring Program

Construction Soil and

Water Quality

Management Plan

Monthly Environmental

Report (G36)



Maritime.



DP&E, DPI and NOW

CoA C9(a) Air quality monitoring of dust

and other emissions

Construction Air Quality

Management Plan



Maritime.



DP&E


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E63 Monitoring for the built

elements, rehabilitated

vegetation and landscaping

(including weed control)

Urban Design and

Landscape Plan.

Not specified within CoA.

Reporting to Roads and

Maritime proposed.

A24 Environmental Representative

to monitor the implementation

of environmental

management plans and

monitoring programs and

advise ROADS AND

MARITIME on the

achievement of the

plans/programs

All sub plans Monthly Report to DP&E

C1 CEMP, specifically:

• Waste generated

• Reducing demand on

water resources

• Hazard and risks

SWCMP, CCSWMP,

CCAFMP and CEMP



Maritime.



DP&E

A16 Environmental monitoring of

ancillary facility compliance

and review/ update of

CCAFMP as necessary

CCAFMP Bi-annual Compliance


Maritime.



DP&E


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CoA

C9(b), E32

and E33

Effectiveness of noise and

vibration mitigation measures

Noise and Vibration

Management Plan



Maritime.



DP&E

C4 (a) Traffic Management and

Access performance, and

implementation of TAMP

Traffic and Transport

Management Plan



Maritime.



DP&E

C9 (c) Surface and groundwater

monitoring

Soil contamination and waste

classification

Soil, Water and

Contamination

Management Plan



Maritime.



DP&E

C4 (e) Avoidance of heritage impact

and implementation of

Heritage Management Plan

Heritage Management

Plan



Maritime.



DP&E


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C4 (e) Pre-clearing monitoring,

ecological monitoring, weed

management

Flora and Fauna

Management Plan



Maritime.



DP&E

C9 (e) Dust emissions Air Quality Management

Plan



Maritime.



DP&E

Monitoring procedures will address how these activities will be undertaken. Monitoring procedures will

include:

Purpose and scope

Minimum acceptable frequency and standards listed in applicable approvals, licences and

regulations

Relevant EPA approved methods, Australian Standards or, in the absence of an Australian

Standard, industry acceptable procedures

Targets and parameters

The location of monitoring

Any consultation to be undertaken in relation to the monitoring

Processes for response to any exceedances of targets/standards

Processes for recording and reporting results.


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CPB Contractors will prepare Construction Monitoring Reports detailing the results of the monitoring

undertaken in accordance with the Construction Monitoring Programs for inclusion in the Six Monthly

Construction Compliance Reporting required under NSW-CoA A32. The reports will be prepared six-

monthly for the duration of Construction of the Project.

Where a non-conformance is detected or monitoring results are exceed the target set in monitoring

programs and are directly attributable to the Project (i.e. are influenced by factors under the direct

control of the Project e.g. noise from Construction equipment), the process described in Section 8.6

will be implemented. Steps in the process will typically include:

An analysis of the results by the Environmental Site Representative in more detail with a view of

determining possible causes for the non-conformance

A site inspection by the Environmental Site Representative (or delegate)

Advising relevant personnel of the problem

Identifying and agreeing on actions to resolve or mitigate the non-conformance

Implementing actions to rectify or mitigate the non-conformance.

A non-conformance Environmental Incident Report and/or Environmental Improvement Notice may be

issued by the Environmental Site Representative in response to the non-conformance problem if it is

found to be Construction related.

The timing for any improvement will be agreed between the relevant Engineer/Superintendent and

Environmental Site Representative based on the level of risk (e.g. a significant risk will require

immediate action).

All environmental monitoring equipment shall be maintained and calibrated according to

manufacturer’s specifications and appropriate records kept.


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8.3 Auditing and reporting

8.3.1 Independent Audits

An overarching Environmental Audit Program for independent environmental auditing against the

Approval has been prepared in accordance with AS/NZS ISO 19011:2014 – Guidelines for Auditing

Management Systems, in accordance with NSW-CoA A35.

The Audit Program has been submitted and approved by the Secretary in accordance with NSW-CoA

A36 and shall be implemented throughout Construction. The Audit Program has also been provided to

the Minister for the DoEE.

The Environmental Audit Program will be implemented for the duration of Construction, in accordance

with NSW-CoA A36.

In accordance with NSW-CoA A37, the independent environmental audits of the Project will be

conducted by a suitably qualified, experienced and independent team of experts in auditing and be

documented in an Environmental Audit Report which:

Assesses the environmental performance of the Project and its effects on the surrounding

environment

Assesses whether the Project is complying with the NSW and Federal CoA, REMMS

Reviews the adequacy of any document required under the Approval

Verifies compliance with the OACEMP, CPB’s CEMP and issue-specific plans

Verifies compliance with any relevant legal and other requirements (e.g. licenses, permits,

regulations, Roads and Maritime contract documentation including specifications) and

Recommends measures or actions to improve the environmental performance of the Project, and

improvements to any document required under the Approval.

The independent auditor must be approved by the Minister of the DoEE prior to the commencement of

the audit. Audit criteria must be agreed to by the Minister and the audit report must address the criteria

to the satisfaction of the Minister.

The first Environmental Audit will be carried out within 12 months of works commencing and annually


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thereafter during the delivery of the Project and within 12 months of the commencement of Operations

and then as required by the Secretary in accordance with NSW-CoA A38.

Roads and Maritime will submit a copy of the Environmental Audit Report to the Secretary with a

response to any recommendations contained in the audit report within six weeks of completing the

audit, or within another timeframe agreed with the Secretary, in accordance with NSW-CoA A39. The

Environmental Audit Reports will also be provided to the Minister for the DoEE.

CPB Contractors will maintain accurate records substantiating all activities associated with or relevant

to the Federal CoA, including measures taken to implement all management plans required by the

Federal CoAs, and make them available upon request to the DoEE. Such records may be subject to

audit by the DoEE or an independent auditor in accordance with section 458 of the EPBC Act, or used

to verify compliance with the Federal CoA. Summaries of audits will be posted on the Department’s

website. The results of audits may also be publicized through the general media.

8.3.2 CPB Internal Audits

Internal auditing will be undertaken generally on a six-monthly basis throughout the Project. The

purpose of auditing is to verify compliance with:

This CEMP and Sub plans

Approval requirements (CoA, EIS and Submissions Report commitments)

Any relevant legal and other requirements (e.g. licenses, permits, regulations, Roads and

Maritime contract documentation).

An audit checklist will be developed and amended as necessary to reflect changes to this CEMP,

subsequent approvals and changes to Acts, regulations or guidelines.

8.3.3 Audit of the ER’s exercise of its functions

The secretary may at any time commission an audit of an ER’s exercise of its functions under NSW-

CoA A24. Roads and Maritime, the Contractor and ER will facilitate and assist the Secretary in any

such audit.


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8.3.4 Independent external audits

External auditing will be undertaken by an independent environment auditor in accordance with ISO

19011:2014 - Guidelines for Quality and/ or Environmental Management Systems Auditing. Table 8-2

Audit Requirements presents auditing requirements that are applicable to the Project.




Page 127 of 177

Table 8-2 Audit Requirements

No. Audit Requirement Timing Responsibility Recipient

1 Internal audit Verify compliance with approval

and legal requirements, Roads and

Maritime specifications and

Construction documentation

The first audit within three months of the

commencement of Construction and then at

six monthly intervals there-after. The final

submitted within five working days of

contract completion date.

Environmental Site

Representative

Project Manager

Roads and

Maritime’s

Representative

2 Independent

audit

(NSW-CoA

A35 & A36))

Program for independent

environmental auditing against the

Approval in accordance with

AS/NZS ISO 19011:2014 –

Guidelines for Auditing

Management Systems

Program to be submitted no later than one

month before the commencement of work

on the first stage of the Project

Program will be implemented for the

duration of Construction

Roads and Maritime’s

Environmental Manager

Project Manager

Roads and

Maritime’s

Representative




Page 128 of 177


3 Independent

audit and

Environment

al Audit

Report NSW

CoA- A37

Federal-

CoA11, 12,

13, 14

• Assess the environmental


• Assess compliance with NSW

and Federal CoA and REMMs

• Review adequacy of documents

required under the Approval

• Verify compliance with

OACEMP, CPB’s CEMP and

sub-plans

• Verify compliance with legal and

other requirements

• Recommend measures to

improve the environmental

performance and

documentation

Annually, commencing within 12 months

from commencement of Construction

Roads and Maritime to

procure suitably qualified,

experienced and

independent team of

auditors

Independent auditor to

undertake audit and

prepare audit report

Secretary, DP&E

(for information)

Minister for DoEE




Page 129 of 177


4 ER NSW-

CoA A26

Audit of the ER’s exercise of its

functions

As required by the Secretary Roads and Maritime and

the ER to facilitate and

assist with the audit

Secretary DP&E


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8.4 Compliance Tracking Program

The Compliance Tracking Program describes the approach to be taken to monitor compliance with the

terms of the Approval, taking into consideration the staging of the Project proposed in the Staging

Report prepared in accordance with NSW-CoA A11 and A12.

An overarching Compliance Tracking Program has been developed for the Project. The requirements

of the Compliance Reporting, as prescribed in CoA A32, include:

The Program shall include, but not necessarily be limited to:

(a) a results summary and analysis of environmental monitoring;

(b) the number of any complaints received, including a summary of main areas of complaint, action

taken, response given and proposed strategies for reducing the recurrence of such complaints;

(c) details of any review of, and minor amendments made to, the CEMP as a result of Construction

carried out during the reporting period;

(d) a register of any consistency assessments undertaken and their status;

(e) results of any environmental audits and details of any actions taken in response to the

recommendations of an audit;

(f) a summary of all incidents notified in accordance with Condition A40 and Condition A43 of this

approval; and

(g) any other matter relating to compliance with the terms of this approval or as requested by the

Secretary.

The Compliance Tracking Program describes how the requirements of CoA A32 will be met and sets

out a program and frequency for compliance reporting and independent auditing. The compliance

reporting requirements as described in the Compliance Tracking Program will record how the CoA

have been addressed.

A summary of the required compliance reporting, as required by CoA A32, is provided in Table 8-2


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Table 8-3 Compliance Reporting

N

o

.

Report Requirement Timing Responsibility Recipient

1 Compliance

Tracking

Program

NSW-CoA

A27

Federal-CoA

13

Describes how

the requirements

of CoA A32 will

be met and sets

out a program

and frequency for

compliance

reporting and

independent

auditing.

Prior to

commencement of

Construction.

Project

Manager

Roads and

Maritime to

submit to

DP&E

2 Pre-

Construction

Compliance

Report

NSW-CoA

A30

Federal-CoA

12, 13

Review of the

compliance status

of the Project

against

requirements of

the Project

approval prior to

Construction of

each Project

stage

1 month prior to

Construction

commencing

CPB/ Roads

and Maritime

to prepare,

Roads and

Maritime to

review and

submit

Secretary,

DP&E (for

information)

Minister for

DoEE

3 Construction

Compliance

Reports

Reporting on

compliance and

performance

against approval

requirements. The

At least five (5)

weeks prior to the

commencement of

Construction and at

6 monthly intervals

Environment

Manager

Roads and

Maritime to

submit to

DP&E


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8.5 Pre-Construction compliance

Pre-Construction, Construction and Pre-Operation Compliance Reporting required under the CTP

provides evidence of compliance with the applicable conditions of approval.

The Pre-Construction Compliance Reporting provides details of how the CoA that must be addressed

before the commencement of Construction have been complied with and identifies the proposed

commencement date for Construction. A separate Pre-Construction Compliance Report will be

prepared for each of the Project stages, prior to the commencement of Construction of that stage.

NSW-CoA

A32

Federal-CoA

13

compliance

reporting required

under the

Compliance

Tracking Program

will record how

the CoA have

been addressed.

during the

Construction

phase. The report

shall be provided to

Roads and

Maritime by the

10th day of the

month following the

reporting period.

At least six (6)

weeks prior to the

commencement of

operation.

4 Pre-Operation

Compliance

Report

NSW-CoA

A33

Federal-CoA

13

Review of

compliance status

of the Project

against the

requirements of

the Project

approval prior to

Operation of each

Project stage

1 month prior to

Operation

commencing

CPB/ Roads

and Maritime

to prepare,

Roads and

Maritime to

review and

submit

Secretary,

DP&E (for

information)

Minister for

DoEE


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8.6 Construction Compliance Report

Construction of the stage will not commence until the Pre-Construction Compliance Report for that

stage has been submitted to the Secretary for information. The Pre-Construction and Construction

Compliance reporting will also be provided to the Minister for the DoEE.

The Construction Compliance Reports will include:

a results summary and analysis of environmental monitoring

the number of any complaints received, including a summary of main areas of complaint, action

taken, response given and proposed strategies for reducing the recurrence of such complaints

details of any review of, and minor amendments made to, the OACEMP or CEMP as a result of

Construction carried out during the reporting period

a register of any consistency assessments undertaken and their status

results of any environmental audits and details of any actions taken in response to the

recommendations of an audit

a summary of all incidents notified in accordance with NSW-CoA A40 and NSW-CoA A43

any other matter relating to compliance with the approval or as requested by the Secretary.

The DoEE requires that the compliance reporting for the preceding 12 months be published on the

Project website. Non-compliance with any of the Federal CoA will be reported to the DoEE at the

same time as the compliance report is published.

8.7 Pre-Operation Compliance Report

The Pre-Operation Compliance reporting details how the CoA that must be addressed before the

commencement of Operation have been complied with and identifies the proposed commencement

date for Operation. A separate Pre-Operation Compliance Report will be prepared for each of the

Project stages, prior to the commencement of Operation of that stage. Operation of the stage will not

commence until the Pre-Operation Compliance Report for that stage has been submitted to the

Secretary for information. The Pre-Operation Compliance reporting will also be provided to the

Minister for the DoEE.


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8.8 Other reporting

Prior to, during and following Construction, various reports will be prepared to fulfil internal Roads and

Maritime specifications, and CPB Contractors’ reporting needs, and commitments under the EIS and

SPIR, and requirements under the Instrument of Approval.

Table 8-4 sets out the reporting requirement applicable to the Project, timing of the reporting, who is

responsible for managing preparation of the reports and the intended recipient(s).

The performance of the Project against the objectives and targets will be documented in the Project

Construction compliance reports and at least on an annual basis as part of the management review.

CPB Contractors will maintain accurate records substantiating all activities associated with the Project

or relevant to the conditions of approval, including measures taken to all management plans. Records

will be made available to the DP&E and DoEE upon request within the timeframe nominated in the

request.




Page 135 of 177

Table 8-4 Summary of Reporting Requirements

No. Report Requirement Timing Responsibility Recipient

1. 1 Monthly environmental

report

For incorporation in Project Monthly Reports

including environmental statistics (i.e. incidents,

regulatory action, complaints on environmental

issues), regulatory and authority considerations,

monitoring program performance and key

environmental issues in accordance with G1 and

G36.

Monthly CPB Environmental Site

Representatives

Roads and

Maritime

Reporting to EPA under the EPL

2. EPL Monthly report Details of all non-compliances with conditions of

EPL, measures taken to prevent recurrence

Within 10 working

days to the end of

each calendar month.

CPB Environmental Site

Representatives

EPA




Page 136 of 177


3. 3 EPL annual returns Report on compliance with EPL including:

• Statement of Compliance

• Monitoring and Complaints suymmary,

• Statement of compliance for: licence

conditions, load based fee, requirement to

prepare PIRMP and publish monitoring

data

Within 60 days of the

anniversary of the

EPL.


Representatives

EPA

Inspection reports (not related to CoA)

4. 4 EPA or any other

Agency inspection

report, other than for

arranged inspections

The report will detail the purpose, outcome and

actions pertaining to the visit and will be submitted

to the Roads and Maritime Project Manager

Within one working

day of the EPA or

any other Authority

visit, other than for

arranged inspections


Representatives

Roads and

Maritime




Page 137 of 177


5. 5 Roads and Maritime

and/or EPA

environmental

inspection reports

Response to matters raised in Roads and Maritime

and/or EPA site inspections

As required. Typically

every two weeks for

Roads and Maritime

inspection reports

and monthly for EPA

inspection reports


Representatives

Roads and

Maritime/EPA

Reporting under the NSW Infrastructure Approval

Part A - Administrative

6. 6 Staging Report NSW-

CoA A11

Details the work and activities to be carried and

their timing for each Project stage

1 month prior to

commencement of

Construction of the

first stage of the

Project

Roads and Maritime Secretary (for

information)




Page 138 of 177


7. 7 Ancillary Facilities

Management Plan

NSW-CoA A16

Refer Section 3.2.1 and Appendix A4 One month prior to

the installation of any

ancillary facilities

Stage specific CCAFMP-

CPB

Secretary (for

approval)

8. 8 ER reports NSW-CoA

A24(I)

Report of site environmental performance following

routine inspections

Refer Section 4.8.5

Monthly, and

submitted within

seven days following

the end of each

month

ER Secretary and

other regulatory

agencies

Roads and

Maritime

9. Compliance Tracking

Program

NSW-CoA A27

Refer Section 8.4 One month prior to

commencement of

Construction

Roads and Maritime ER for

endorsement

Secretary (for

information)

Minister for

DoEE




Page 139 of 177


10. Pre-Construction

Compliance Report

NSW-CoA A30


commencement of

Construction


information)

Minister for

DoEE

11. Construction

Compliance Reports

NSW-CoA A32

Refer Section 8.6 6-monthly from the

date of the

commencement of

Construction

Roads and Maritime/CPB Secretary (for

information)

Minister for

DoEE

12. Pre-Operation

Compliance Report

NSW-CoA A33


commencement of

Operation


information)

Minister for

DoEE




Page 140 of 177


13. Environmental Audit

Program

NSW-CoA A37

Refer Section 8.3.1 Annually, starting

within 12 months of

commencement of

Construction

Audit report to be

submitted within 6

weeks of completing

the audit

Suitably qualified,

experienced, independent

team of auditors

Secretary (for

information)

Minister for

DoEE

14. Notification of incident

NSW-CoA A40, A41

Refer Section 7.1 As early as possible

and within 24 hours

of the incident


information)

Minister for

DoEE




Page 141 of 177


15. Notification of incident

notified to the EPA

under the POEO Act

NSW-CoA A43

Refer Section 6.3 Within 24 hours of

notifying the EPA


Representatives

Secretary (for

information)

Roads and

Maritime

Relevant

authorities

Minister for

DoEE

Part B – Communication Information and Reporting

16. Community

Communication

Strategy

NSW-CoA B1


commencement of

Construction

Roads and Maritime

Community and

Stakeholder Engagement

Advisor

Secretary (for

approval)




Page 142 of 177


17. Construction

complaints

management system

including Complaints

Register

NSW-CoA B6

Refer Section 6 One month prior to

commencement of

Construction

Roads and Maritime

Community and

Stakeholder Engagement

Advisor

Secretary (for

information)

18. Complaints Register

NSW-CoA B7, B8

Refer Section 6 On request during

Construction


Representatives

Secretary (for

information)

Roads and

Maritime

Part C – Construction Environmental Management




Page 143 of 177


19. CEMP NSW-CoA C1 Refer Sections 1.1 and 1.4 One month prior to

commencement of

Construction stage

Roads and Maritime

CPB environmental Site

Representatives

ER (for

endorsement)

Secretary (for

Approval)

Roads and

Maritime

20. CEMP Sub-plans

NSW-CoA C4


commencement of

Construction or within

another timeframe

agreed with the

Secretary


Representatives

Roads and

Maritime




Page 144 of 177


21. Construction

Monitoring Programs

NSW-CoA C9

Refer Section 8,

Appendix B3 CCNVMP,

Appendix B4 CCSWMP,

Appendix B6 CCAQMP

One month prior to

commencement of

Construction or within

another timeframe

agreed with the

Secretary


Representatives

Roads and

Maritime

22. Construction

monitoring report

NSW-CoA C15

Report on monitoring data recorded and potential

exceedances against criteria

As required in CPB’s

CEMP sub-plans


Representatives

Secretary and

relevant

regulatory

agencies (for

information)

Part E – Key Issues

Heritage




Page 145 of 177


23. Historical

Archaeological

Salvage Strategy

NSW-CoA E12

Refer Appendix B5 CCHMP One month prior to

the commencement

of excavation and

salvage works


information)

24. Historical

Archaeological

Excavation Report

NSW-CoA E13

Refer appendix B5 CCHMP 12 months after the

completion of the

work


Representatives

Secretary (for

information)

25. Archaeological

Excavation Report

NSW-CoA E13, E14

Details of any archival recording, historical

research and excavations undertaken

Refer Appendix B5 CCHMP

12 months after the

completion of the

work


Representatives

Secretary

26. Unexpected Heritage

Finds Procedure NSW-

CoA E16


commencement of

Construction


information)




Page 146 of 177


27. Aboriginal Cultural

Salvage Strategy

NSW-CoA E18


the commencement

of excavation and

salvage works


information)

28. Aboriginal Cultural

Heritage Report NSW-

CoA E20

Refer Appendix B5 CCHMP 12 months after the

completion of work


Representatives

Secretary (for

information)

Noise and Vibration

29. Operational noise

mitigation report NSW-

CoA E36

Confirm the operational noise predictions of the

Project, review noise mitigation measures and

investigate alternative measures, if required

Prior to

commencement of

Construction which

would affect identified

receivers


approval)




Page 147 of 177


30. Implementation of

noise mitigation

measures report

NSW-CoA E37

Report justifying why early implementation of noise

mitigation measures is not proposed

Prior to the

commencement of

Construction which

would affect the

identified receivers


approval)

Soils

31. Site contamination

Report NSW-CoA E46

Documents outcomes of contamination

assessments of land on which the Project is

located

Refer Appendix B8 CCCLMP

To be prepared prior

to completion

Suitably qualified and

experienced person

under the CLM Act

Secretary (for

information)

32. Remedial Action Plan

NSW-CoA E45

Documents approach to remediation of specified

contaminated land


As required Suitably qualified and

experienced person

under the CLM Act

Approval by a

NSW EPA

accredited Site

Auditor




Page 148 of 177


33. Site Audit Statement

and Site Audit Report

NSW-CoA E48

Verifies land is suitable for intended land use


1 month prior to

commencement of

Operation

EPA Accredited Site

Auditor

Secretary and

the relevant

local Council(s)

34. Unexpected

Contaminated Land

and Asbestos Finds

Procedure NSW-CoA

E49

Refer Appendix B8 CCCLMP Implement during

Construction

CPB Roads and

Maritime

Sustainability

35. Sustainability Strategy

NSW-CoA E51

Refer to CPB Sustainability Management Plan Prior to the

commencement of

Construction

CPB Roads and

Maritime




Page 149 of 177


36. Road Dilapidation

Report NSW-CoA E55

Road dilapidation report for local roads outside the

Project boundary

Within 3 weeks of

completing the

surveys and no later

than 1 month before

the use of local roads

by Project vehicles

CPB Report to be

prepared by suitably

qualified person

Relevant local

Council(s)

Urban Design

37. Urban Design and

Landscape Plan NSW-

CoA E62

Urban Design and Landscape Plan Prior to the

commencement of

works for which the

UDLP requires

community

consultation under

the Plan

CPB Secretary (for

information)

Measures in the

UDLP relating to

the DEOH Golf

Club must be

consented to by

the Department

of Defence


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8.9 Non-conformity, corrective and preventative actions

Any member of the Project team may raise a non-conformance or improvement opportunity. The

Quality Plan (reference to be provided) describes the process for managing non-conforming work

practices and initiating corrective/preventative actions or system improvements.

The Environmental Representative, The Roads and Maritime’s Representative or public authority may

also raise a non-conformance or improvement opportunity using the same process.

A non-compliance is the failure to comply with the requirements of the Infrastructure Approval or any

applicable licence, permit or legal requirements. Under the Infrastructure Approval, a non-compliance

with a condition of the Approval is classified as an incident and therefore should be managed in

accordance with Section 7. Non-conformances may be identified through the review of compliance,

environmental auditing or incident management.

For each non-conformance identified a corrective/preventative action (or actions) must be

implemented. In addition any environmental management improvement opportunities can be initiated

as a result of incidents or emergencies, monitoring and measurement, audit findings or other reviews.

Improvement opportunities may also result in the implementation of corrective/preventative actions.

Corrective/preventative actions and improvement opportunities will be entered into the CPB’s quality

system database and include detail of the issue, action required and timing and responsibilities. The

record will be updated with date of close out and any necessary notes. The database will be reviewed

regularly to ensure actions are closed out as required.

Non-conforming activities may be stopped, if necessary, by the Environmental Site Representative,

Environmental Coordinators or Project / Site Engineer following consultation with the Construction

Manager or delegate. The works will not commence until a corrective / preventative action has been

closed out. The Environmental Representative may also stop works in these circumstances. In such

circumstances a non-conformance report must be prepared in accordance with the Quality Plan.

Procedures for rectifying any non-compliance identified during environmental auditing, review of

compliance or incident management are also documented in the Compliance Tracking Program.


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9. Review and improvement

Management reviews are undertaken as part of the continual improvement process. The management

review can consist of group reviews, or executive reviews.

A group review is initiated by the Environmental Site Representative and includes relevant Project

team members and stakeholders. The Environment team also meet as least quarterly, or at other pre-

determined periods, to review environmental management issues for the Project. The environment

team meeting can be run in conjunction with a wider group meeting if the Environmental Site

Representative deems it appropriate.

The environment group meetings include:

A review of the aspects and impacts register, legal register and environmental induction

Consideration of monitoring, inspection and audit results

Consideration of incidents and any lessons learnt

Consideration of any new regulatory issues or any proposed CEMP updates

A review of the effectiveness of erosion and sediment controls

Consideration of ERG issues

Consideration of changes in operational needs such as resourcing

Feedback from management reviews.

An executive review will involve the management team. This review will be held every 12 months and

will include a review of:

Effectiveness of environmental management documentation implementation

Management effectiveness

Potential improvements to the environmental management documentation

Adequacy of resources

Findings of audits

Environmental objectives and targets

Environmental performance

Compliance with legal and other requirements


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Critical non-conformance or repeated non-conformances

Organisation changes

Effectiveness of training and inductions.

The outcomes of the group and executive reviews could include amendments to this CEMP and

related documentation, revision to the Project’s Environmental Management System, risk assessment

review, re-evaluation of the Project objectives and targets as well as feeding into other Project

documents.


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10. Documentation

10.1 Environmental records

The Environmental Site Representative is responsible for maintaining all environmental

management documents as current at the point of use. Types of records include:

All monitoring, inspection and compliance reports/records

Correspondence with public authorities

Induction and training records

Reports on environmental incidents, other environmental non-conformances, complaints

and follow-up action

Community engagement information

Minutes of CEMP and Construction Environmental Management System review

meetings and evidence of any action taken.

All environmental management documents are subject to ongoing review and continual

improvement. This includes times of change to scheduled activities or to legislative or

licensing requirements. Systems and documents would also be updated where relevant

following incident investigations and implementation of non-conformance corrective actions.

Only the Environmental Site Representative, or delegate, has the authority to change any of

the environmental management documentation.

10.2 Document control

CPB Contractors or the Roads and Maritime Environment Manager where relevant, will

coordinate the preparation, review and distribution, as appropriate, of the environmental

documents listed above. During the Project, the environmental documents will be stored at

the main site compound.

CPB Contractors will implement a document control procedure to control the flow of

documents within and between the Environmental Representative, Roads and Maritime

Environment Manager, stakeholders and subcontractors.

The procedure will also ensure that documentation is:

Developed, reviewed and approved prior to issue

Issued for use

Controlled and stored for the legally required timeframe


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Removed from use when superseded or obsolete

Archived.

A register and distribution list will identify the current revision of particular documents or

data.


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Appendix A1 Legal and Other Requirements

Page 1 of 15 TNR5 – Legal Register

Act Activity / aspect

Requirement Reference Division 5.2 applicability and

approval/ licence

requirement

General

Environmental Planning and Assessment Act, 1979

All Comply with the terms Minister for Planning’s approval for the project. Obtain the Minister’s approval for any project modifications that are not consistent with the planning approval.

Part 5

S5.14

S5.25

Yes

NSW Minister’s Infrastructure Approval dated 30 May 2018

All To examine and take into account to the fullest extent possible all matters affecting or likely to affect the environment by reason of the activity.

Part 5

S5.5

S5.17

Yes

Protection of the Environment Operations Act 1997

Site licensing Do not carry out or allow an activity listed in Schedule 1, or carry out work to enable such an activity, unless the premises are licensed by the EPA. This applies to

• ‘road construction’ meaning the construction, widening or re-routing of roads if it results in the existence of 4 or more traffic lanes (other than bicycle lanes or lanes used for entry or exit) for 1 km of their length in the metropolitan area, or 5 km in length in any other area, where the road is classified, or proposed to be classified, as a freeway or tollway under the Roads Act 1993

• ‘crushing, grinding and separating’ and ‘extractive activities’ that meet the criteria listed in Schedule 1 (and any other scheduled activity undertaken for the Project).

S47

S48

Yes

An EPL will be required for road construction for all stages of the Project.

Land Acquisition (Just Terms Compensation) Act 1991

Property acquisition

Applies to the acquisition of any land required for the project. Yes

Individual agreements with landowners

Roads Act 1993 Prior to construction, a notice must be placed in the local newspaper allowing for any submissions to be made by any person.

S79 Yes

http://www.enviroessentials.com.au/envirolaw/pagesnsw/legalobs/leg_protenvopact_sched1.php




approval/ licence

requirement

Pollution


Harming the environment

Do not risk harming the environment by wilfully or negligently:

• disposing of waste unlawfully.

• causing any substance to leak, spill or otherwise escape (whether or not from a container); or

• emitting an ozone depleting substance

S115

S116

S117

Yes

Control equipment

Properly and efficiently maintain and operate any installed pollution control equipment (including monitoring devices).

S167 Yes

Notification of pollution incidents

Notify the EPA immediately of pollution incidents where material harm to the environment is caused or threatened.

S148 Yes

Water

Water Management Act 2000

With the exception of controlled activity approvals, the Water Management Act 2000 (WM Act) only applies in relation to those water sources covered by operational water sharing plans – these areas cover most of the State's major regulated river systems.

Water access and use.

Do not take water from a water source (a lake, river or estuary or place where water occurs naturally on or below the surface of the ground, and includes coastal waters) without an access licence.

Do not use of water on land (unless supplied by a water utility, irrigation corporation etc. or in accordance with basic landholder rights) without a water use approval.

S56

S60A

S89

S91A

S91(3)

No




approval/ licence

requirement

Water Management Act 2000

Water management works

Do not construct/use a water supply work, drainage work or flood work without the appropriate approval.

S90

S91B

S91C

S91D

No

Waterfront land. Do not deposit material, excavate, or remove material within a watercourse bank, shore or bed, or on land 40 metres inland, or interfere with the likely flow of water to such a body, without a controlled activity approval.

S91 No

Public authorities are exempt from the need to obtain a controlled activity approval.

Water Management (General) Regulation 2004 (cl.39A)

Water Act 1912

Note that this Act is being progressively repealed by the Water Management Act 2000 (WM Act).

With the exception of controlled activity approvals, the WM Act only applies in relation to those water sources covered by

Surface water Obtain a licence or permit for construction or use of ‘work’ for purposes including the taking and using of water

S21B Yes

Groundwater Obtain a licence where interference with groundwater is likely to occur.

Roads and Maritime being a department of NSW government and as defined within the Water Act 1912 as the Crown is exempt from the prevision of obtaining a licence.

S112

S121A

S112 does not apply to the Crown. Roads and Maritime is therefore not required to obtain a licence under this provision.




approval/ licence

requirement

operational water sharing plans – these areas cover most of the State's major regulated river systems.

Floodplains Obtain an approval for controlled works. These include works which occur on a designated floodplain, which can prevent land from being flooded or which can affect water flow to or from a river or lake.

S180 An exemption in relation to roads potentially applies – see clause 4 of the Water (Part 8-General) Regulation 1995.


Water pollution Do not cause water pollution (other than to a sewer), except in accordance with the conditions of any EPA licence.

S120

S122

Yes

Refer EPL

Noise


Plant maintenance and operation

Do not operate plant if it emits noise caused by poor maintenance or operation.

S139 Yes

Materials management

Do not cause noise by failing to properly and efficiently deal with materials.

S140 Yes

Contaminated material


Land pollution Do not cause or permit land pollution other than under authority of a licence or regulation. (However it is not a land pollution offence to place virgin excavated natural material or lawful pesticides and fertilisers on land, or by placing matter on land that has been notified to the EPA as an unlicensed landfill and which is operated in accordance with the regulations.)

S142A – S142E

Yes

Refer EPL and Resource recovery

Exemption (refer NSW-CoA E69)

http://www.enviroessentials.com.au/envirolaw/pagesnsw/glossary/glossary.php#waterpollution

http://www.enviroessentials.com.au/envirolaw/pagesnsw/glossary/glossary.php#landpollution




approval/ licence

requirement

Contaminated Land Management Act 1997

Reporting contamination

Notify the EPA if:

• Contaminants exceed thresholds contained in guidelines or the regulations where contamination has entered or will foreseeably enter neighbouring land, the atmosphere, groundwater or surface water.

• Contaminants in soil are equal to or exceed guideline levels with respect to the current or approved use of the land.

• Contamination meets other criteria that may be prescribed by the regulations.

S60 Yes

Biodiversity

Biosecurity Act 2015 Weed control In NSW all plants are regulated with a general biosecurity duty under the Biosecurity Act 2015 to prevent, eliminate or minimise any biosecurity risk they may pose. Any person who deals with any plant, who knows (or ought to know) of any biosecurity risk, has a duty to ensure the risk is prevented, eliminated or minimised, so far as is reasonably practicable.

Yes

National Parks and Wildlife Act 1974

Native fauna Do not harm any animal that is of a threatened species population or ecological community, or its habitat except in accordance with a planning approval.

Part 8A Yes

Do not harm critical habitat except as in accordance with a planning approval.

S98 Yes

Do not harm native fauna (other than listed unprotected fauna) except in accordance with a planning approval or licence.

S120

S127

132C

Yes

Biodiversity Conservation Act 2016

Biodiversity Conservation

Do not cause a significant impact to listed threatened species, populations or ecological communities, or their habitats.

Yes

http://www.legislation.nsw.gov.au/fullhtml/inforce/act+80+1974+cd+0+N?





approval/ licence

requirement

Threatened Species Conservation Act 1995 (repealed)

Flora and fauna conservation

Do not cause a significant impact to listed threatened species, populations or ecological communities, or their habitats.

No

Native Vegetation Act 2003 Flora and native vegetation conservation

Only clear native vegetation in accordance with a planning approval or property vegetation plan.

S12 No


Flora and native vegetation conservation

Do not pick protected native plants without a licence S117

S131

No

Fisheries Management Act 1994

Dredging or reclamation

A permit to authorise dredging or reclamation work must be obtained from the Minister

S201 No

Mangroves, seagrasses and marine vegetation

Do not harm any mangroves, seagrasses or other marine vegetation on public water land protected by the regulations without a permit

S205 No

Fish passage Do not block fish passage without a permit S219 No

Environment Protection Biodiversity Conservation Act, 1999 (Commonwealth)


Do not undertake an action that will or is likely to have a significant impact on a listed threatened species or threatened ecological community

Part 3 Yes


Do not undertake an action that will or is likely to have a significant impact on the environment on Commonwealth land

Part 3 Yes

Compliance Do not take any action to contravene any conditions of approval attached to the project approval

Part 9 Yes

Waste

http://www.enviroessentials.com.au/envirolaw/pagesnsw/legalobs/link_planning_approval.php



http://www.enviroessentials.com.au/envirolaw/pagesnsw/glossary/glossary.php#waterland




approval/ licence

requirement


Littering Do not litter in a public place or an open private place. Do not litter from a vehicle.

Only deposit advertising material in receptacles provided for mail or newspapers or under the door of the premises.

Do not deposit advertising material on or in vehicles.

Part 5.6A Yes


Waste and transportation

Do not undertake a scheduled waste activity unless in accordance with an environmental protection licence.

A licence must be obtained when construction and demolition wastes are applied to land under certain circumstances. This includes the reincorporation of crushed road base material back into roads and the placing of excess fill material onto properties. A licence is not required if the material:

• Is VENM.

• Does not exceed 200 tonnes in the Sydney, Newcastle and Wollongong areas, or 20,000 tonnes outside these areas.

• Is covered by a “general exemption”. Current exempted materials are ENM, recycled aggregates and raw mulch. These exemptions are conditional and require some chemical testing of materials before they are placed onto land.

A licence must be obtained if more than 2,500 tonnes (or cubic metres) is stored on a stockpile site at any one time, or more than 30,000 tonnes of waste is received per year from off site.

Part 3.2

Schedule 1

Yes

EPL and Resource Recovery

Exemption (refer NSW-CoA E69)

Only transport waste to a facility that can lawfully accept the waste. S143 Yes

Do not dispose of waste in a manner that harms or is likely to harm the environment.

S115 Yes




approval/ licence

requirement

Protection of the Environment Operations (Waste) Regulation 20014

Waste and transportation

Comply with general requirements for the transport of waste. For example, any vehicle used by the person to transport waste must be kept in a clean condition and be maintained so as to prevent spillage of waste. For some wastes, only licensed transporters can be used.

Regulation

cl.49

Yes

Comply with record keeping requirements in relation to the transport of certain types of waste.

Regulation

Part 3

Yes

Heritage

Environment Protection Biodiversity Conservation Act, 1999 (Commonwealth)

National Heritage

Do not take an action that will or is likely to have a significant impact on the National Heritage values of a National Heritage place

Part 3 Yes

National Heritage

Do not undertake an action that will or is likely to have a significant impact on the environment on Commonwealth land

Part 3 Yes

Compliance Do not take any action to contravene any conditions of approval attached to the project approval

Part 9 Yes

Heritage Act 1977 Heritage Do not undertake an activity that will affect a place, building, work, relic, moveable object or precinct which is subject to an Interim Heritage Order or is listed on the State Heritage Register without approval from the Heritage Council.

S56-57 No

Do not disturb or excavate land with knowledge or reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered, exposed, moved, damaged or destroyed; or Do not disturb or excavate land on where a relic has been discovered or exposed.

S139 No

Notify the heritage Council on discovery of a relic S146 Yes

http://www.legislation.nsw.gov.au/maintop/view/inforce/act+136+1977+FIRST+0+N/




approval/ licence

requirement


Aboriginal places and objects

Do not harm or desecrate an Aboriginal object or Aboriginal place without consent.

S86

S90

No

Notify the NPWS within reasonable time of becoming aware of the location or discovery of certain Aboriginal objects.

S89A Yes

National Parks and Wildlife Regulation 2009

Aboriginal consultation

Consult with Aboriginal parties on the methodology and draft cultural heritage assessment report

80C Yes

Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)

Protection of areas and objects

Report any discovery of Aboriginal remains to the Federal Minister for the Environment and Heritage.

S20 Yes

Comply with the provisions of any declaration in relation to a significant Aboriginal area or object.

S22 Yes

Hazards and risks

Environmentally Hazardous Chemicals Act, 1985

Hazards and risks

Obtain a licence to undertake prescribed activities involving environmentally hazardous chemicals or declared chemical wastes.

S28 Yes

Contractors to obtain as required

Dangerous Goods (Road and Rail Transport) Act 2008

Hazards and risks

Ensure that dangerous goods are transported in a safe manner. S9 Yes



http://www.comlaw.gov.au/comlaw%5Cmanagement.nsf/lookupindexpagesbyid/IP200403275?OpenDocument






approval/ licence

requirement

Pesticides Act 1999 Hazards and risks

Use pesticides in an environmentally sensitive manner.

Do not use an unregistered pesticide without a permit.

Read the label or permit for the pesticide.

Use registered pesticides in accordance with instructions on the label.

Do not use any restricted pesticide unless authorised by a certificate of competency or a pesticide control order under the Act.

Compliance with pesticide codes of practice is required.

S12

S13

S14

S15

S17

Yes

Greenhouse gas emissions

National Greenhouse and Energy Reporting Act, 2007 and Regulations 2008

Greenhouse gas emissions

Accounting and reporting of greenhouse gases produced and energy consumed during construction. Applicability dependent on thresholds.

- Yes

Applicability dependent on

thresholds.


Table 1 Schedule of hold points and witness points

Clause no.

Description

Specification G01 – Job Specific Requirements

11 Concreting work for reinforced concrete structures and concrete pavement construction

15 Commencement of construction

15 Commencement of construction in accordance with the revised Construction Staging Drawings

18 Commencement of construction activities

19 Removal or cold milling of asphalt pavement

20.4 Construction activities in the vicinity of the demolition area

21 Commencement of earthworks

22.2 Commencement of cofferdams and/or shoring construction

22.3 Dewatering activities

24 Installation of regulatory signposting and final pavement marking

Specification G10 – Traffic Management

1.5.4 Submission of traffic control personnel details

2.3.1 Submission of Traffic Management Plan (TMP) and associated documents

2.6.1 Submission of Traffic Control Plan (TCP), where submitted separately from TMP


3.2.2 Opening of temporary roadway or detour to traffic

Specification G36 – Environmental Protection

3.1 Submission of CEMP and selected CEMS documents

3.1 Resubmission of CEMP and selected CEMS documents

3.2.2 Evidence of approvals, licences and permits obtained

3.2.4 Submission of EWMSs

3.5 Submission of Draft Environmental Training Materials

3.10 Verification that environmental nonconformities has been rectified

4.2 Submission of Remediation Action Plan for contaminated land

4.2.7 Submission of Stage 2 Contamination Assessment Report

4.7 Building Condition Inspection Reports and Vibration Management Sub-Plan

4.9 Engagement of the archaeological consultant

4.9 Commencement of construction in the vicinity of the partially and totally impacted sites

4.10 Engagement of the archaeological consultant

4.10 Commencement of construction in the vicinity of the impacted sites

4.11 Copy of “s.143 Notice”

4.13 Working in or near environmentally sensitive areas

4.15.2 Submission of pre-construction land condition assessment report for each area you intend to occupy for your site facilities


Specification G38 – Soil and Water Management

1.2.7 Submission of evidence of appropriate Soil and Water Management Plan and Erosion and Sediment Control personnel

3.1 Submission of an ESCP(s) and, where required, WQMP for a section of the Work Under the Contract

3.1 Submission of written notice that measures set out in the ESCP for a section of the work have been installed

Specification G40 – Clearing and Grubbing

2.4 Written notification of intention to clear any area

6 Submission of Weed Management Sub-Plan prior to clearing in any area

8 Removal and disposal of disused asbestos pipes, conduits and pits

Specification R44 – Earthworks

G71 3.2 Notification of joint survey

2.3.1 Removal of topsoil

2.3.2 Removal of topsoil

2.3.5, G71 3.2

Submission of joint survey results

2.4 Inspection after removal of unsuitable material and prior to backfilling

2.5.2.1 Removal of asbestos contaminated material

2.5.2.1 On Site encapsulation of asbestos contaminated material

3.2 Presentation of each Lot of embankment foundation after removal of topsoil, and submission of CBR and PI test results of material in foundation, if required


3.4 Presentation of each Lot of floor of cutting, and submission of CBR and PI test results of material in floor of cutting, if required

4.2 Presentation of cleaned batter and bench/floor surfaces for geotechnical inspection

6.1.1 Submission of details of location, quantities, type and verification of conformity of Upper Zone Material (including Selected Material). If imported, verification that all possible sources of material within the Site have been exhausted.

6.1.2 Verification of conformity of stockpiled Selected Material

6.1.2 Verification of conformity of each Lot of Selected Material Zone placed, with test and survey reports.

6.2 Submission of details of location, quantities, type and verification of conformity of verge material. If imported, verification that all possible sources of material within the Site have been exhausted.

7.5 Verification of conformity of each trial section of rock fill, including submission of compaction procedure, test results and survey reports

7.5 Construction of each trial section of rock fill

7.6.1 Proof rolling of embankment layers and other surfaces within 1.5 m of the underside of the Selected Material Zone

7.6.2 Submission of deflection test results, finished surface levels and verification of conformity of each Lot of Selected Material Zone placed (or pavement where no Selected Material Zone is specified).

7.6.2 Benkelman Beam testing of Selected Material Zone

Specification R178 – Vegetation

1.5 Engagement of Soil Scientist and Arborist

2.1.1 Topsoil stripping

2.1.1 Use of topsoil from stockpile

2.1.3 Delivery of imported topsoil

2.3 Supply of seed


2.4 Application of fertiliser

2.7 Use of non-potable water

2.13 Use of compost blanket

3.1.2 Preparation of subsoil

3.2 Topsoiling

3.3 Use of off-site pre-treated seed

3.4.1 Sowing

1.4 Training day

1.7.1 Inviting tenders for landscape planting and maintenance until Completion subcontract

1.7.2 Accepting tenders for landscape planting and maintenance until Completion subcontract

2.12 Use of imported organic topsoil

3.4 Advice that the setting out of all planting positions is complete

3.6.2 Advice that planting holes are ready for inspection


Glenmore Parkway



Page 156 of 177

Appendix A2 Environmental Aspects and Impacts

PAGE 2 OF 17

Table 1: Project environmental Risk register

Issue Construction activity/aspect

Potential impact Risk level prior to mitigation

Indicative Mitigation and Management Measures Risk level following mitigation

Management Documents / Training Required

General Environmental Management

All project works

Non-compliance with CEMP, EPL, legislative requirement.

E4 (Priority ▪ Ensure all personnel are inducted and trained in the CEMP and all associated documents.

▪ EC / EM diligence in including requirements from CEMP and procedures into EWMS and training.

▪ Regular review of environmental management documents.

▪ Regular review of compliance with environmental management documents.

▪ Regular environment team meetings.

▪ Environmental Manager to be involved in design and construction meetings.

▪ Training in environmental emergency response (As per CPIRP

▪ Audit and NCR Review Process to be followed

▪ Work Pack in EWMS will provide details, ie: work permit, work activities, other details,

▪ Change Management Plan (design, construction methodology) – any change will have to be done in accordance with CPB Change Management Procedure

A4 (Low) CEMP

EWMS

Induction

Failure to follow requirements of strategies / procedures.

E4 (Priority A4 (Low)

Failure to report environmental issues.


Inconsistent advice to construction personnel.


Inadequate response to environmental incident/ emergency.


Air quality ▪ Bulk earthworks

▪ Vegetation clearing and topsoil stripping

▪ Site access including

Complaints from neighbours, including loss of amenity, dust in living spaces

D4 (High) ▪ Induct personnel on air quality issues and safeguards

▪ For long-term exposed surfaces (e.g. haul roads), area specific treatment to be considered, (e.g. spray seal, use of soil binder)

▪ Use water carts on unsealed surfaces and stockpiles

▪ Utilise safe dust suppressants to reduce dust generation

A4 (Low) AQMP

EWMS

SWMP

Complaints Procedure

Induction Potential adverse health effects.

D1 (Low) A4 (Low)

PAGE 3 OF 17





temporary waterway crossings

▪ Utility realignment works

▪ Spoil handling.

▪ Stockpiling

▪ Vehicular movements on sealed and unsealed roads

▪ Material haulage

▪ Vehicle emissions

▪ Handling of chemicals, waste, hazardous goods and contaminated material

Degradation of water quality and other aspects of the natural environment.

D1 (Low) ▪ Use street sweepers to reduce dust in areas of dust build up

▪ Modify or cease operations during high winds

▪ All trucks on public roads to cover loads

▪ Vehicles, equipment, machinery used and all facilities – designed, operated and maintained to control the emission of smoke, dust, odours and fumes

▪ All disturbed areas stabilised, revegetated and/or landscaped as soon as practicable

▪ Minimise tracked mud/dust on public roads

▪ No burning or incineration of any material at any time

▪ Dust monitoring as per CAQMP

▪ Task specific dust control measures to be included in the EWMS as required

▪ Avoid “hot-work” during total fire bans and obtain any necessary permits/exemptions from the Rural Fire Service

▪ Safework licensing requirements will be complied with for the storage of hazardous substances and dangerous goods

▪ Appropriately stocked spill kits will be readily available at all chemical storage locations and during chemical use

▪ Material Safety Data Sheets (SDSs) will be obtained, complied with and retained on site for all required chemicals

▪ Pesticide use will be in accordance with the Pesticides Act, 1999

▪ Long term stockpiles will be stabilized with a soil binding polymer or sterile cover crop. The community will be

A4 (Low)

Health risks to neighbours and members of the public from release of gases and/or smoke.

D1 (Low) A4 (Low)

Contamination of waterways from dust.

D4 (High) A4 (Low)

PAGE 4 OF 17





notified of the location and contents of stockpiles where relevant

▪ Water Quality monitoring and site inspections when required

Soil & Water

▪ Bulk earthworks


▪ Site access including temporary waterway crossings


▪ Enabling works / demolition

▪ Slope or embankment creation/stabilisation processes

▪ Contamination from stockpiles on the northern road verge

Erosion and movement of soils.

D4 (High) ▪ Site specific Erosion and Sediment Control Plans will be prepared and implemented for each work area.

▪ Appropriately designed erosion control structures will be installed, maintained and cleaned regularly.

▪ Locate spoil stockpiles, plant and equipment storage and refuelling 50m away from drainage lines, watercourses or stormwater drains for Ancillary Facilities

▪ If stockpiles, plant and equipment storage and refuelling 50m are required outside of Ancillary Facilities, task specific control measures are to be included in the EWMS

▪ Install clean water diversions to ensure clean and dirty water are not mixed on site.

▪ Where feasible, storage, compound access and parking areas sealed, as early during works as practicable.

▪ Chemical storage meets Safework and EPA bunding/storage requirements.

▪ Wheel mud reduction/ cleaning measures at exit of all sites where required.

▪ Temporary waterway crossings are established to minimise risk of fines in waterways and designed to address appropriate flow volumes.

▪ Buffer zones of vegetation will be maintained adjacent to waterways for as long as practical.

A4 (Low) SWMP

ESCPs

CLMP

Site training required workforce

Sit training on requirements for stockpile sites

Ancillary Facility Management Plan (AFMP) Site training

Dewatering procedure

SWMP and dewatering procedure

CLMP, hygienist, material tracking, waste register

Captured dirty water discharge from basins

D4 (High) A4 (Low)

Dirty water not captured and leaves site.

D4 (High) A4 (Low)

Contamination of sediment basins and /or waterways from spills.

D4 (High) A4 (Low)

Disturbance to creeks from access road construction.

D4 (High) A4 (Low)

Contamination of watercourses

D4 (High) A4 (Low)

Proximity of compounds and stockpiles to waterways.

D4 (High) A4 (Low)

Discharge from sediment basin.

D4 (High) A4 (Low)

PAGE 5 OF 17





Disposal of prescribed waste (potentially contaminated fill and road deconstruction waste).

D4 (High) ▪ Rehabilitation and landscaping works of disturbed areas undertaken as soon as the works are completed and/or progressively where possible.

▪ Implement concrete washout process within bunded areas.

▪ Provide and maintain spill kits.

▪ All dewatering to be to designated points and have a dewatering permit in place

▪ Undertake regular testing of the Project PIRMP as required by the PIRMP.

▪ Design drainage to maximise dirty water to sediment basins.

▪ Work crews undertaking ERSED works will be employed and trained in ERSED requirements.

▪ Install signage at EPL discharge points to assist workers to understand implications of dirty water release in sensitive areas.

▪ Implement RMS Dewatering guidelines. License of discharge point. EPA – temporary discharge permit, CPB to clarify

▪ Implement Dewatering Permit.

▪ Implement appropriate procedures to identify, contain, handle and manage contaminated material including stockpiling and tracking procedures.

▪ Implement EWMS for piling works for pumping from piles to storage tanks and associated testing and discharge.

▪ Prepare and implement Contaminated Land Management Plan (CCLMP) to manage known and unknown contaminated sites in accordance with the EIS and G36.

A4 (Low)

D4 (High) A4 (Low)

PAGE 6 OF 17





▪ Lock up site as much as practicable and implement security measures such as cameras (real and fake) where needed.

▪ Prioritise the use of captured stormwater over other sources.

▪ Re-use / recycle water where possible.

▪ Spoil Management in Commonwealth Land

▪ Stockpiling of material will not occur within 5m of vegetation protected areas and tree protection zones. Delineation in accordance with

• No waste material generated outside the Defence

Establishment Orchard Hills (DEOH) site may be used as

soil, fill, or a component of soil or fill, within the

boundaries of DEOH nor within 10 metres of the DEOH

boundary, unless:

a) the material is Virgin Excavated Natural Material, and

b) the material is sourced from a location that

appropriate testing demonstrates is free of weed

propagules and/or Phytophthora cinnamomi.

Contaminated Land

▪ Excavations,

▪ Fill areas.

▪ Haulage of spoil and fill.

▪ Stockpiling. Spoil areas.

▪ UXO

Contamination from ACM or coal tar

D4 (High) ▪ Develop Contaminated Land Plan (CCLMP)

▪ Develop Asbestos Management Plan as part of the CEMP

▪ RMS Unexpected Discovery of Contaminated Land Procedure.

A4 (Low) CEMP

EWMS

CSWMP

Cross contamination

D4 (High) A4 (Low)

Inappropriate classification

D4 (High) A4 (Low)

PAGE 7 OF 17





Community Perception

D4 (High) ▪ Induction will include places of potential contaminated material and what to do if unexpected material is discovered

▪ Environmental scientist to undertake preliminary site assessment prior to topsoil stripping

▪ Environmental scientist to be onsite during stripping of topsoil to R44

▪ All known contaminated sites to be included in the site sensitive area plans.

▪ Implement appropriate stockpile management and tracking.

▪ All waste tracking to be recorded.

▪ Licences for waste facilities to be obtained.

▪ All waste to be taken to an appropriately licenced facility

▪ Implemented Military Materials Management Plan

A4 (Low)

Discovery of UXO D4 (High) A4 (Low)

Waste Management

▪ Generation of wastes during all stages of construction

Excessive waste disposed at Landfill

D4 (High) ▪ Apply waste hierarchy principles – avoid-reduce-reuse-recycle.

▪ Waste materials contained in waste bins or other suitable containers, and collected for recycling, reuse or disposal by the licensed waste contractor.

▪ Separate, contain, manage and dispose contaminated waste to prevent migration and further contamination whilst maintaining compliance with EPA requirements.

▪ Label and store all liquid waste containers in a bunded area prior to removal off-site.

▪ Undertake inspections of the worksite and waste storage areas to ensure litter / debris is regularly cleaned up and contained on site.

▪ Establish recycling system early on in Project.

A4 (Low) CEMP

EWMS

Incorrect disposal of contaminated waste

D4 (High) A4 (Low)

Cross-contamination from onsite or illegal dumping

D4 (High) A4 (Low)

PAGE 8 OF 17





▪ Establish good segregation areas for concrete and waste concrete is not to be transported off site for land disposal.

▪ Section 143 Notices Under the PoEO Act and provision of a letter to landholder highlighting the need for a “s.143 Notice”, the Contractor’s role and the respective roles of the RMS and the landholder in ensuring that the waste is appropriately managed.

▪ Consider types of waste, how each waste type will be used as a beneficial use and address in the approvals that no other type of waste will be used.

▪ Establish and maintain a waste register Identify waste management companies, obtain their relevant licenses and keep copies onsite 6-monthly waste avoidance and resource recovery reporting

▪ If waste is to be disposed a place that is not a licenced waste facility, the following must be in place;

o A completed and signed notice under section 143 of the POEO Act

o Letter from the landholder confirming that they are able to accept the waste, and;

o A copy of the Development application /EPL or other approval which authorised the site to receive this material

Energy ▪ Fuel and Energy Use

Excess energy consumption and greenhouse gas generation during construction

C3 (moderate)

▪ Use local material and personnel where possible to reduce transport emissions.

▪ Optimise transport routes to maximise vehicle efficiency

▪ Throttle down or turn off equipment that is not in use

▪ Conduct energy audits during the project to identify and address energy waste.

A3 (Low) CEMP

PAGE 9 OF 17





Traffic and Transport

▪ Haulage of material.

▪ Import of material / plant / equipment.

▪ Travel to / from site.

Increased traffic load on local roads

C3 (moderate)

▪ Develop and update Traffic Management Plans for all stages of work.

▪ Identify and assess roads likely to be affected by Project construction and develop methods to minimise traffic increases.

▪ Identify and consult with receivers likely to be impacted by loss of storage and/or vehicular manoeuvrability.

▪ Undertake before and after dilapidation surveys on local roads

▪ Traffic controllers and / or signage for both egress and ingress off the work sites.

▪ All vehicles carrying materials to be adequately covered to prevent any loss of material, which may cause driver safety issues.

▪ Property access to be maintained throughout the project

▪ Only approved routes on local roads to be used by construction traffic

▪ Clean down draw bars and remove debris lodged between tyres (where double tyres are on vehicle) before exiting site to public roads

▪ Dilapidation survey on identified roads to be undertaken

A3 (Low) CEMP

EWMS

Changes to property access

C3 (moderate)

A3 (Low)

Visual and Landscape

▪ General project works

▪ Vegetation establishment

▪ Evening/Night work

▪ Rehabilitation of disturbed land

General aesthetic impact

C3 (moderate)

▪ Landscape and rehabilitation plan including extensive seeding planting in required areas implemented.

▪ Embankments and cuttings will be stabilised by the use of appropriate landscape treatments.

▪ The use of night-lighting will be minimised where possible during the construction phase and directed away from residential areas and sensitive receivers.

▪ Solar powered day makers will be used where reasonable.

A3 (Low) CEMP

EWMS

Inadequate rehabilitation and reinstatement

C3 (moderate)

A3 (Low)

PAGE 10 OF 17





▪ Establishment of compound

▪ Site compounds and areas surrounding them will be kept tidy and be regularly cleaned and maintained.

▪ Undertake landscaping and revegetation works in accordance with the approved plan.

▪ Monitoring and weed control.

▪ Ensure agreed permanent fence signage is installed in accordance with landholder agreements

Known Heritage

▪ Bulk Earthworks





Identified Aboriginal heritage sites

D4 (High) ▪ Induct personnel on heritage issues and safeguards

▪ Works in knows aboriginal sites to be in accordance with Aboriginal Heritage management plan

▪ Protect identified heritage items to be retained with protective fencing or flagging and signage from being disturbed during construction

▪ No access for site personnel to retained aboriginal sites

▪ Salvage certificates to be obtained prior to undertaking work in areas with known heritage

▪ Salvage boundaries to be confirmed, and fencing installed where required

A4 (Low) HMP

HMP

Identified non-Aboriginal heritage sites

Identified non-Aboriginal heritage sites


▪ Regular inspection of heritage protection fencing. Implement unexpected find procedures as required.

▪ Landholder consultation

▪ EWMS required for works adjacent to or within each non-aboriginal heritage site

▪ Vibration monitoring - Site specific buffer distances to be established and maintained to achieve vibration limits.

▪ Altering construction method if required to meet vibration criteria.

▪ Dilapidation surveys to be conducted.

A4 (Low)

PAGE 11 OF 17





Unknown Heritage

▪ Earthworks





Unidentified Aboriginal heritage sites and coordination of surface clearance.


▪ Pre-Construction Survey with representative Aboriginal Groups. Pre-con surveys to target areas in relation to probable artefact areas and construction program. (Completed by RMS)

▪ Unidentified Finds Procedure.

A4 (Low) HMP, Unexpected finds protocol, induction and site-specific training

Unidentified non-Aboriginal heritage sites.

D4 (High) ▪ Personnel to be trained in Unidentified Finds Procedure.

▪ Pre-construction surveys where applicable. (Completed by RMS)

A4 (Low) HMP, Unexpected finds protocol, induction and site-specific training

Aesthetic curtilage (area and context around the heritage item itself is part of the item) – problem for construction compound sites, stockpiling site.

D4 (High) ▪ Landholder consultation.

▪ Compliance with CoA including Heritage Management Plans.

▪ Access to heritage locations via approved access points only

A4 (Low) HMP

Noise and Vibration

▪ Bulk Earthworks



▪ Culvert and drainage works

Noise impacts on sensitive receivers during construction.

D4 (High) ▪ Program works to avoid/ minimise impact to sensitive receivers as far as reasonably practicable

▪ Liaise (agreements where applicable) with local communities and affected residents

▪ Adherence to working hours in NVMP and EPL unless otherwise approved

▪ Respite periods for particularly noisy/ short duration activities (in accordance with regulatory guidelines and/or NVMP).

A4 (Low) NVMP, noise assessments, out of hours permits

Construction Community Communication Strategy

Vibration impacts on nearby receptors.

D4 (High) A4 (Low)

PAGE 12 OF 17





▪ Site access including temporary waterway crossings

▪ Batch plant operation




▪ Material stockpiles including the treatment of contaminated or acid sulphate soil and rock

▪ Compounds operation including fuel and chemical storage, refuelling and chemical handling

▪ Construction equipment selected, operated and maintained to minimise noise impacts and where necessary fitted with silencers and “smart” reversing alarms.

▪ Reduced use of horns to signal trucks loaded where residences close by.

▪ Place as much distance between construction equipment and sensitive receivers as possible.

▪ Minimise impacts from construction activities through the use of effective shielding or other mitigation measures where reasonable and feasible.

▪ Noise monitoring to monitor predicted verses actual noise levels.

▪ Implementing management measures where regenerated noise is found to be excessive and agreements are not in place.

▪ Managing construction vehicle routes and speed of vehicles.

▪ Modelling noise vibration impacts to inform notification to sensitive receivers.

▪ Establish and maintain complaints management system.

▪ Building condition reports on potentially impacted buildings as required.

▪ Notification of sensitive receivers prior to commencement of works that may have an adverse noise and vibration impact.

▪ Undertake works outside of standard construction hours in accordance with the Out of Hours Protocol and the project EPL Conditions.

▪ Vibration monitoring as required.

PAGE 13 OF 17





▪ Dewatering activities

▪ Paving activities

▪ Construction phase water use / extraction for

▪ Site Establishment

▪ Piling

▪ Review of construction method if there is a potential to exceed noise or vibration levels.

▪ Training for personnel on behaviour – minimising shouting, slamming doors etc.

▪ Mitigate noise at construction site (2.5 m hoardings) to offset necessity of mitigation at receiver end, where applicable.

▪ Batch plant assessment (TBC)

Flora, Fauna and Biodiversity

▪ Bulk Earthworks


▪ Works near and in creeks / temporary crossings.

▪ General earthworks near vegetation.

▪ Vehicular movements.

▪ Open excavation works.

▪ Utility trenching

Unnecessary Removal of Trees

D4 (High) ▪ induct personnel on Biodiversity issues and mitigation measures

▪ Pre-construction Clearing Survey to be undertaken as early works, including identification and flagging of habitat and no-go areas

▪ Ensure pre-clearing procedures are adhered to.

▪ Minimise clearing of all vegetation

▪ Perform ground truthing to ensure tree removal for services and drainage has been adequately captured.

▪ Consult ecologists for fauna relocation procedures

▪ Progressive revegetation and stabilisation to be undertaken.

▪ Ensure a pre-construction weed survey is undertaken and weed spraying is undertaken by qualified operator in accordance with FFMP where deemed appropriate

▪ No clearing without a permit

▪ Notifications to be distributed in accordance with guidelines.

A4 (Low) CEMP

EWMS

FFMP,

Pre-clearing ecologists report,

Internal vegetation removal permit

Refuelling procedure, Induction, site training

Fauna relocation, including Micro bats

D4 (High) A4 (Low)

Ongoing erosion of cleared areas.

D4 (High) A4 (Low)

Contamination to waterways and sensitive species/areas.

D4 (High) A4 (Low)

Fuel and chemical spills in sensitive areas.

D4 (High) A4 (Low)

PAGE 14 OF 17





▪ herbicide spraying

▪ Records to be kept, together with weed spray location maps.

▪ Disturbed areas will be monitored for effective soil stabilisation and restoration / rehabilitation.

▪ Implement a staged clearing process and undertake fauna rescue during clearing as required.

▪ Engage arborist to provide advice on tree health and provide ongoing advice where suspect trees are identified outside the LOC.

▪ Implement washing procedures to prevent the spread of pests and disease where applicable.

▪ Undertake monitoring as required in the Nest Box Plan and CFFMP. Clearing and Grubbing plan to be developed in consultation with the project ecologist.

▪ Develop a clearing and grubbing EWMS Suitably qualified Project Ecologist to undertake pre-clearing assessments and fauna handling/relocation.

▪ Implement best practice methods for working in aquatic habitat where required.

▪ Develop and implement a weed management sub-plan in consultation with the local council weed officer.

▪ All imported soil will be declared weed free. Post clearing reports When working in waterways all temporary crossing or work platforms to meet guidelines on fish passage and PESCP developed.

▪ No haul road design/construction or material storage to occur under the drip line of trees.

▪ Stockpiles will be sized and managed appropriately to help maintain microbiota for revegetation and landscaping (less than 2m high for topsoil).

PAGE 15 OF 17





▪ No refuelling within 50m of a waterway. Without task specific EWMS in place

▪ Refuelling vehicles to have spill kits on standby.

▪ Unexpected finds/ pre-clearing works inspection

Compound operation

▪ Compounds operation including fuel and chemical storage, refuelling and chemical handling

Flooding runoff reaching site areas (compounds, stockpiles, vehicles, sediment basins).

D4 (High) ▪ Fuels and chemicals not to be stored in flood prone areas

▪ Compounds to be managed in accordance with Ancillary facilities management plan

A4 (Low) CEMP

AFMP,

EWMS,

ESCP

Mulch and Tannin Management

▪ Vegetation clearing and storage of mulch

Tannin impacts on waterways.

D4 (High) ▪ Follow the tannin management procedure

▪ Stockpile mulch in designated areas only

▪ Any mulch material applied or stockpiled on land that will be inside the DEOH boundary fence, or on land that will be within 30 m of the DEOH boundary fence, must fulfil the requirements of the Mulch Exemption and the Mulch Order as if the mulch were being applied to an environmentally sensitive area.

A4 (Low) CEMP

SWMP

Flooding ▪ Earthworks

▪ Site access

▪ Culvert works

▪ Works on or near a watercourse

Restriction to flow paths causing localised flooding

D4 (High) ▪ Design drainage structures to cope with design flood events.

▪ Locate compounds / plant / storage above flood level events.

▪ Design and build temporary crossings and work platforms to be stabilised and minimise scour / erosion during flood events.

A4 (Low) CEMP

EWMS

SWMP

Changes to flood levels

D4 (High) A4 (Low)

Stormwater inflow to site

D4 (High) A4 (Low)

PAGE 16 OF 17





Flood damage to plant and equipment

D4 (High) ▪ Install scour protection as early as possible.

▪ Develop Flood Management Sub-Plan Remove plant and equipment from flood zones prior to large rainfall event

A4 (Low)

Erosion of haul roads and partially constructed areas

D4 (High) A4 (Low)

Socioeconomic

▪ All stages of construction

Temporary restricted access to properties due to construction works.

D4 (High) ▪ Maintain access or provide alternative access to individual landholdings at all times.

▪ Ensure that there is constant access to business through the utilisation of service roads.

▪ Rigorous community notification and update procedures

▪ Conduct works to minimise intrusion and disruption to agricultural operations/activities of surrounding properties

▪ Building condition surveys undertaken where required

▪ Where viability of agricultural operations is identified as being impacted, further assessment and mitigation is required

A4 (Low) CEMP

CSIP

PAGE 17 OF 17

Risk Matrix

ID Consequence (impact)

Description

1

Insignificant/ negligible

Short-term disturbance with minor environmental release or damage that is non-reportable.

No impact outside site boundary.

No community complaints or media reports.

2 Minor/low

Minor violation of regulation or guideline with minimal damage to the environment and small clean-up.

Immediately contained on site.

Local government action, minor community complaints.

Potential or actual breach of legislation.

3 Moderate

Violation of regulation or guideline with moderate damage to the environment and significant clean-up costs.

Release of pollution off site.

Detrimental media reports, community concerns and complaints.

4 Major

Significant environmental damage – potentially permanent.

Release of pollution off site. Significant loss of environmental resources.

Detrimental media reports in the national or state media, organised community concern.

High likelihood of EPA fine or court action.

5 Catastrophic

Long-term environmental harm.

Permanent irreparable damage to the environment.

Sustained detrimental state and national media reports. Sustained community outrage.

Penalty Infringement Notice/court action.

Risk severity Management required

Priority Immediate and detailed management action required (e.g. stop or change activity)

High Priority management action warranted.

Moderate Management action warranted.

Low Management action should be considered, particularly for low-level impacts that nevertheless occur on a continual basis.

ID Occurrence (likelihood)

Description

A Rare/improbable The event may only occur in exceptional circumstances.

B Unlikely/remote The event may occur at some time (about once every five years).

C Possible The event is likely to occur at some time (about once every year).

D Likely The event will probably occur in most circumstances (at least once every six months).

E Almost certain The event is expected to occur in most circumstances (at least once every month).

A B C D E Risk Severity

1 Priority

2 High

3 Moderate

4 Low

5

Co

nseq

uen

ce

Likelihood


Glenmore Parkway



Page 157 of 177

Appendix A3 Environment and Sustainability Policies

Title: Environment PolicyID: MSID-7-150 Version: 3.0 Date Published: 04/10/2018Management System - Uncontrolled Document when Printed

Page 1 of 2

Environment Policy

Purpose

This Policy sets out the minimum mandatory requirements for the management of environmental risks and impacts from our construction activities.

Application

This Policy applies to all business entities controlled by the business, including alliances, joint ventures and consortia where the business exerts management control. It applies at all levels of the organisation including Corporate, Business Unit and Project.

Minimum Requirements

Senior leaders must demonstrate a personal visible commitment to our SH&E Cultural Framework and ensure all workers understand the requirements of the Management System as it applies to the work they are undertaking, so that work is undertaken to minimise our environmental impact.

Environment Management Plans (EMP) must be developed and implemented for each Project to outline how the project environmental risk will be managed and controlled.

Environmental objectives, targets and key performance indicators must be established at all levels of the organisation, with performance against these monitored and analysed to provide a baseline for continual improvement.

The Environment Procedures must be used to eliminate or minimise environmental risk from construction activities.

Construction Area Plans and Work Packs must be developed and include an assessment of environmental risk and associated controls.

Site Environment Plans must be developed for Work Packs where environmental risk dictates; these must be used to inform as content of Daily Pre Starts.

As part of the risk management process, personnel and teams at the Project, Business Unit and Corporate level should seek to identify opportunities for improving efficiency in the use of natural resources, enhancing positive environmental impacts and driving innovation.

All environmental incidents must be reported in accordance with the incident notification requirements. They must be thoroughly investigated and appropriate corrective action undertaken with the aim of preventing recurrence of the incident.

Reporting of energy consumption, water use and waste generation, as well as reporting on initiatives and environmental achievements must be completed by projects and business units as requested.

Title: Environment PolicyID: MSID-7-150 Version: 3.0 Date Published: 04/10/2018Management System - Uncontrolled Document when Printed

Page 2 of 2

All levels of the organisation must be prepared to respond to an emergency and in the event of an emergency, plans and capabilities are in place to eliminate or minimise damage to the environment, preserve ongoing operations and our reputation.

Effective communication, cooperation and consultation channels must be in place to consult with workers who may impact upon the environment.

All project personnel responsible for environmental risk shall be appropriately trained and competent and understand their legal obligations with regard to environment management.

Title: Sustainability PolicyID: MSID-7-64 Version: 8.0 Date Published: 28/06/2017Management System - Uncontrolled Document when Printed

Page 1 of 2

SUSTAINABILITY POLICY

This Policy sets out requirements for sustainability across CIMIC Group Limited and entities it controls (the Group). Sustainability is the integration of environmental, social and governance factors into decision making to maximize short and long term shareholder value, seek competitive advantage, and contribute to safe and healthy employees, communities and ecosystems.

This Policy should be read in conjunction with the Group Code of Conduct, the Procurement, Environment, Health and Safety, and Diversity and Inclusion policies, and the NGER Annual Compliance Report template.

This Policy applies to all employees of the Group, and third parties engaged by the Group, including alliances and joint ventures in all jurisdictions.

Any employee of the Group found to have breached this Policy may be subject to disciplinary action.

The objectives of this Sustainability Policy are to:

Focus the Group’s efforts on managing sustainability risks and opportunities, enhancing business performance and supporting the long-term interests of the Group;

Promote a culture of accountability for sustainability outcomes and improve the sustainability knowledge and skills of employees;

Integrate consideration of environmentally and socially responsible sourcing and governance factors into the Group’s operating and procurement processes, and seek opportunities to collaborate with the supply chain to drive innovation and create mutual value;

Drive the efficient use of resources and continual innovation in the delivery of projects; Support the adoption and delivery of appropriate industry rating schemes and standards that drive

sustainability outcomes for clients; Encourage initiatives and successfully deliver projects that meet client expectations, provide value for

money, and leave net positive legacies for the CIMIC Group, our clients, users, the environment and communities; and

Enhance the Group’s resilience to climate change.

1. GovernanceThe Group will abide by the principles of the UN Global Compact and acknowledges its role in contributing to the UN Sustainable Development Goals.

The Ethics Compliance and Sustainability Committee (ECSC) assists the Board in fulfilling its governance and oversight responsibilities in the area of sustainability.

CIMIC will coordinate and support the Operating Companies to develop tailored sustainability strategies and implement initiatives that help to achieve the Group’s commitments and objectives.

CIMIC will facilitate sustainability knowledge sharing across the Group so as to encourage innovation, mitigate risk, drive competitive advantage and create shareholder value.

Operating Companies are responsible for meeting their contractual and compliance obligations regarding the operational aspects of sustainability such as project delivery, health, safety, people development, environment, community relations, procurement, risk, governance and ethical behaviour, within the Group’s governance framework.

2. Reporting

Title: Sustainability PolicyID: MSID-7-64 Version: 8.0 Date Published: 28/06/2017Management System - Uncontrolled Document when Printed

Page 2 of 2

CIMIC will coordinate the annual publication of a Global Reporting Initiative (GRI) based Group Sustainability Report. The ECSC approves the Sustainability Report and any sustainability disclosures in the Annual Report.

CIMIC will participate in recognised sustainability surveys including the Dow Jones Sustainability Index and CDP so as to promote the Group’s reputation as an industry leader in the sustainable delivery of projects.

The Operating Companies are responsible for:

Internal reporting of operational health, safety, environment and community related initiatives and performance information to CIMIC management and the ECSC;

The provision of sustainability data and information to CIMIC to inform corporate sustainability reporting requirements, and to support the submission of sustainability surveys as required by CIMIC; and

Direct external reporting to meet legislative obligations (such as the National Greenhouse and Energy Reporting Act, including the completion of an annual compliance report) where appropriate.

CIMIC will regularly review Operating Company strategies, reporting and performance to ensure they demonstrate compliance with all legislative requirements and support continuous improvement in sustainability and business performance.

Policy InformationOwner: Executive General Manager, Sustainability, CIMICApproved by: Chief Executive Officer, CIMICEffective date: June 2017

Note: CIMIC Group policies may be amended from time to time.

Our management system approach to supporting sustained success

Quality

To achieve our quality objectives we:

Ensure all personnel understand and take ownership for quality and service outcomes

Identify, monitor and respond to client needs and expectations

Develop and implement suitable procedures including effective controls to ensure work is properly planned and delivered

Undertake monitoring, analysis and review to ensure work is undertaken according to plan

Foster a culture of continuous improvement and innovation in all aspects of our work

Review the management system to ensure its continuing suitability, adequacy and effectiveness

Our Management System incorporates CIMIC, Corporate, Client and other Stakeholder requirements

A Policy is a statement of strategic intent, commitment and includes minimum requirements.

A Procedure describes the steps to be undertaken to complete an activity, the accountable roles and the tools and knowledge to be used.

A Work Instruction provides detailed instructions on how to carry out a particular task.

Tools are preformatted documents (forms and templates) used to collect specific data or information for a particular purpose.

Knowledge documents are reference material to provide context, additional information or guidance to a Policy or Procedure.

Business Applications are the software tools used to manage and support our operations.

Safety & Health

To achieve our safety and health objectives we:

Expect personal accountability for Safety & Health, including looking out for others

Foster a positive Safety & Health culture through visible leadership

Provide a safe working environment for all workers and the public

Establish and maintain effective systems to manage Safety & Health risks to workers and the public

Encourage continuous learning through knowledge capture and transfer of lessons learnt

Support effective consultation by encouraging ownership and continuous improvement in Safety & Health

Provide working environments that support mental health and wellbeing

Environment

To achieve our environmental objectives we:

Take personal accountability for environmental performance

Lead by example and engage with industry, clients and regulators to foster innovation and continual improvement

Minimise our environmental impacts to avoid pollution by applying a hierarchy of controls to eliminate, substitute or mitigate such impacts

Set environmental objectives and targets to effect sustainable outcomes and to meet client requirements

Improve our energy efficiency and promote sustainable use of resources

© CPB Contractors Pty Limited | Version 4.0 April 2018

OUR MANAGEMENT SYSTEM

THE WAY WE OPERATE

OUR SHEQ COMMITMENT

Ensures a consistent approach to delivery

Guides the way we manage our business

Underpins our approach to deliver sustainable outcomes

Board Governance

Policies

Procedures & Work Instructions

Tools & Knowledge

Business Applications

The way we operate is an overall process that guides how we manage our business for sustained success

It fosters an integrated approach across all operations and functions to deliver outcomes

It ensures third party certifications in relation to Safety, Health, Environment and Quality are maintained

It is supported by our Code of Conduct and Principles – Integrity, Accountability, Innovation and Delivery, underpinned by a continual focus on Safety

Identify objectives and requirements

Efficiently manage resources

Plan and control work activities

Undertake monitoring and analysis

Improve, innovate and learn

Compliance and performance assurance

Our Mission is to generate sustainable returns for our shareholders by delivering projects for our clients while providing safe, rewarding and fulfilling careers for our people.

Juan Santamaria, Managing Director

CODE OF CONDUCT


Glenmore Parkway



Page 158 of 177

Appendix A4 Document Register

TNR5 – Document Register Page 1 of 9

Environmental

management

document

Purpose Document

Reference

Document title Recipient Reviewed By

Environmental

Policy

Sustainability

Policy

Outlines CPB Contractors Pty

Ltd environmental

management and

sustainability commitments

Sustainability Policy Roads and Maritime / ER CPB Senior

Management

Appendix A3 Environmental Policy Roads and Maritime / ER CPB Senior

Management

Construction

environmental

management plan

Policy

Legal and other requirements

Risk assessment Objectives

and targets

Roles and responsibilities

Communication and training

Monitoring, auditing and

reporting

Corrective action

Management review

Management actions

CEMP Construction Environmental

Management Plan

Roads and Maritime / ER Roads and Maritime /

ER

Environmental

management sub

plans

Objectives and targets

Roles and responsibilities

Legal and other requirements

Training

Monitoring, auditing and

reporting

Management actions

Appendix B1 Construction traffic and access

management plan

Annexure A Roles and

Responsibilities

Annexure B Traffic Staging

Plan

Annexure C Long and Short-

Term Traffic Management

Inspection Checklists

Roads and Maritime / ER

Roads and Maritime /

ER


Environmental

management

document

Purpose Document

Reference


Annexure D Traffic Control

Plan, Traffic Incident Management

Plan, Pedestrian and Cyclist

Movement Plans

Annexure E Vehicle Movement

Plans

Annexure F Traffic control

qualifications for Daniel Tibbetts

Annexure G Special Event

Calendar

Annexure H Site Signage and

VMS locations

Annexure I Traffic Control

Subcontractor Capability Statement

Annexure J Civil Design

Consultants

Annexure K Traffic Controller

tickets and expiries

Annexure L Traffic Switch

Program

Appendix B2

Construction flora and fauna

management plan

Annexure A Permit to Clear

Annexure B Unexpected

Threatened Species Find

Procedure


ER


Environmental

management

document

Purpose Document

Reference


Annexure C Fauna Rescue

and Release Procedure

Annexure D Weed and

Pathogen Management Plan

Annexure E Vegetation

Management Plan (also known as

Clearing and Grubbing Plan)

Annexure F Nestbox

Management Strategy

Annexure G Farm Dam

Dewatering Plan

Annexure H Root Ball Plan

Appendix B3 Construction noise and vibration

management plan

Annexure A Construction

Noise Predictions

Annexure B Construction

Noise and Vibration Monitoring

Program

Annexure C Out of Hours Work

Procedure


ER

Appendix B4 Construction soil and water quality

management plan

Annexure A Environmental

procedures


ER


Environmental

management

document

Purpose Document

Reference


Annexure B Construction

Water, Soil and Contamination

Monitoring Program

Annexure C Sediment basin

Management Plan

Annexure D Stockpile

Management Protocol

Annexure E Management of

Tannins from Vegetation Mulch

Procedure

Annexure F Concept Erosion

and Sediment Control Strategy

Annexure F - Section 9

Stabilisation Sub-Plans

Annexure G Flood

Management Plan

Appendix B5 Construction heritage management

plan

Annexure A Heritage Maps

Annexure B RMS Standard

Management Procedure –

Unexpected Heritage Items

Annexure C Heritage Salvage

Strategy


ER

Appendix B6

Construction air quality

management plan


ER


Environmental

management

document

Purpose Document

Reference


Annexure A Construction Air

Quality Management Program

Appendix B7 Construction Waste, Energy and

Resource Management Plan

Annexure A Location of Waste

Facilities

Annexure B Template Waste

Management Register

Annexure C Spoil Management

Strategy Plan

Annexure D Coal Tar Asphalt

Management Plan

Annexure E Estimation of

Waste Quantities

Annexure F Example Section

143 Notice

Annexure G Waste

Classification Guidelines


ER

Appendix B8 Compound and Ancillary Facilities

Management Plan


ER/ DP&E


ER/ DP&E

Appendix B9

Construction Community

Communication Strategy


ER

Appendix B10

Construction Contaminated Land

Management Plan

Annexure A EPA Guidelines

for Consultants Reporting on

Contaminated Sites


ER


Environmental

management

document

Purpose Document

Reference


Annexure B Unexpected

Discovery of Contaminated Land

Procedure

Annexure C Asbestos

Management Sub-Plan

Annexure D Military Material

Management Plan

Appendix B11 Construction Pollution Incident

Response Plan


ER

Appendix B12 Other Management Measures Roads and Maritime / ER Roads and Maritime /

ER

Appendix B13 Sustainability Management Plan

Annexure A Energy and

Carbon Management Plans

Annexure B Resource Use and

Procurement Plan

Annexure B - Section 11.5

Water Reuse Strategy

Annexure C Workforce Travel

Plan to reduce travel emissions

Annexure D Climate Change

Risk Assessment Review


ER

Compliance

tracking program

Compliance status

Auditing

Recording and reporting

To Be Determined Compliance tracking program

Pre-construction Compliance

Report


ER


Environmental

management

document

Purpose Document

Reference


Environmental

procedures

Operational controls and

instructions

Appendix A7 RMS environmental incident

classification and reporting

procedure


ER

Appendix A6 Sensitive Area plans Roads and Maritime / ER Roads and Maritime /

ER

Refer to Title –

(note some of

these may be

known as Plans or

Programs rather

than Procedures if

developed as part

of the CEMP)

Dewatering Roads and Maritime / ER Roads and Maritime /

ER

Management of Potentially

Contaminated Material


ER

Sediment Basin Management Roads and Maritime / ER Roads and Maritime /

ER

Noise and Vibration Monitoring Roads and Maritime / ER Roads and Maritime /

ER

Flood Warning and Response

Procedure


ER

Water Quality Monitoring


ER

Environmental

Work Method

Statements

To detail environmental

management practices

specified to certain work

activities considered to be

high risk environmental

works.

Appendix A9

Refer to Title

Site Establishment

High Environmental Risk Works

Environmentally Sensitive Areas

Works

Topsoil stripping including

temporary stockpiling and disposal

of excavated material

Asbestos works

Works in waterways


ER


Environmental

management

document

Purpose Document

Reference


Construction and operation of

sediment basins and/ or buffer

swales and connecting drainage for

the associated catchment area

Construction of culverts, including

associated staging, flow diversions,

any dewatering, short and long-

term stabilisation and removal of

existing structures;

Vegetation clearing and grubbing;

Activities where construction water

may be discharged into natural

waterways;

Construction and operation of

concrete wash out areas;

Environmental

forms and

checklists

Monitoring and auditing

Recording and reporting

Refer to Title Non Conformance Report

Environmental incident report

Environmental training attendance

Record

Compliance audit checklist

Weekly inspection checklist

Preventative action form

Template audit report

Work Modification- excessive

wind/weather conditions

Environmental Complaint

Investigation Form - Air quality


ER


Environmental

management

document

Purpose Document

Reference


Registers Appendix A1 Legal Requirements register Roads and Maritime / ER Roads and Maritime /

ER

Appendix A2 Aspects and Impacts Register Roads and Maritime / ER Roads and Maritime /

ER

Appendix A5 Document Register Roads and Maritime / ER Roads and Maritime /

ER

To be advised –

maintained via

Excel

spreadsheet

onsite.

Sediment Basin Discharge Register

Document Register

Surface Water Quality Monitoring

Register

Air Quality Monitoring Register

Erosion and Sedimentation Control

Plans Register

Noise Monitoring Register

Vibration Monitoring Register

Inspections Action Register

Stockpile Register


ER


Glenmore Parkway



Page 159 of 177

Appendix A5 Initial CPB Project Organisational Chart

Roads and Maritime Project Director

John Navamani

Roads and Maritime

Senior Project Manager

Jeff Gilham

Environmental Representative (ER)

Cameron Weller

Environmental Review Group (ERG)

Reps from DP&E, OEH, EPA,

DPI, RMS ER

(all stages)

Roads and Maritime Project Managers

Stage 5: Kandiah Mahendran

Stage 5

Project Director

Nick Fryday

Roads and Maritime Community and

Stakeholder Engagement Advisor

Kamini Parashar

Roads and Maritime

Environmental Manager

Anthony Eland

Owen Clark

Stage 5

Construction Manager

Richard McGloin

Roads and Maritime Sustainability

Coordinator

Mark Gethings

Environmental Site

Representatives

Ciaran McAleer

Site Superintendent

Simon Baldwin

Community Relations Managers

Augusta Goldsmith

*Other roles:

Sustainability Managers

Traffic Managers

Utilities Coordinators

Ecologists

Soil Conservationists

Environmental Scientist/

Engineers

UXO Contractor

Project / Site Engineers

Pablo Alvarez

Ji Zhang

Phong Ngyuen

Foremen / Leading Hands

Charlie Rogers

Legend

Roads and Maritime personnel

Contractor personnel

Independent


Glenmore Parkway



Page 160 of 177

Appendix A6 Environmentally Sensitive Area Plans

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Page 161 of 177

Appendix A7 Environmental Incident Classification and Reporting

Environmental Incident Classification and Reporting Procedure

September 2017

THIS PAGE IS LEFT INTENTIONALLY BLANK


About this release

Title Environmental Incident Classification and Reporting Procedure

Approval

Prepared by Environment Manager Performance Improvement Scott Machar

Reviewed by Director Environment Operations Sally Durham

Approved by Director Environment Michael Crowley

Document Control

Version 5.0 Release date September 2017

Publication Number RMS 17.374 ISBN 978-1-925659-57-3

Page 3


Contents

About this release.........................................................................................................................................3

Acronyms and definitions..............................................................................................................................5

1. Introduction............................................................................................................................................6

1.1 Aim.................................................................................................................................................6

1.2 Objectives ......................................................................................................................................6

1.3 Scope and coverage.......................................................................................................................6

2. Environmental incident classification .....................................................................................................7

3. Environmental incident response.........................................................................................................10

3.1 Considerations and steps for environmental incident response ....................................................10

3.2 Critical incidents ...........................................................................................................................13

4. Environmental incident reporting .........................................................................................................14

4.1 Environmental incident report form ...............................................................................................14

4.2 Completing the incident report form..............................................................................................14

4.3 Submitting the incident report form ...............................................................................................14

4.4 Roads and Maritime contacts .......................................................................................................15

5. Regulatory agency notification.............................................................................................................15

5.1 Notification of Material Harm pollution incidents ...........................................................................15

5.1.1 Definition of Material Harm pollution incidents .......................................................................15

5.1.2 Determining if an incident should be considered Material Harm ............................................15

5.1.3 Relevant authorities to notify .................................................................................................16

5.1.4 The relevant information to provide .......................................................................................17

5.2 Summary of other regulatory agency notification requirements ....................................................17

5.3 Requests for written reports from regulatory authorities (activities delivered internally by Roads and Maritime)..........................................................................................................................................18

Page 4


Acronyms and definitions

Acronym Definition

DE (Roads and Maritime Services) Director Environment

DEO (Roads and Maritime Services) Director Environment Operations

DPE Department of Planning and Environment

Environmental harm Any act that degrades or pollutes the environment

EPA NSW Environment Protection Authority

EP&A Act Environmental Planning and Assessment Act 1997

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

EPL Environment Protection Licence

POEO Act Protection of the Environment Operations Act 1997

REF Review of Environmental Factors

Roads and Maritime NSW Roads and Maritime Services

SEQC (Roads and Maritime Services) Safety Environment and Quality Co-ordinator

SEQO (Roads and Maritime Services) Safety Environment and Quality Officer

Page 5


1. Introduction

1.1 Aim

The Environmental Incident Classification and Reporting Procedure (the Procedure) aims to ensure Roads and Maritime Services workers and contractors understand how to classify, respond to and report environmental incidents that occur as a result of Roads and Maritime managed activities.

1.2 Objectives

The objectives of the Procedure are to:

Ensure all relevant Roads and Maritime workers, managers and contractors are made aware of environmental incidents promptly and can respond accordingly

Ensure site workers understand the immediate environmental incident reporting requirements

Ensure all workers understand reporting timeframes, including statutory requirements

Ensure incidents are reported to enable monitoring, sharing of lessons learnt and response to emerging environmental incident trends

Comply with statutory obligations to report certain environmental incidents to regulators and other relevant government agencies (see section 5.1).

1.3 Scope and coverage

This Procedure is applicable to all Roads and Maritime activities where environmental incidents may occur. This includes (but is not limited to):

Temporary activities, such as preliminary investigations (e.g. geotechnical and environmental surveys) and the construction and maintenance of Roads and Maritime assets

Activities at Roads and Maritime properties and facilities

Vessels operated by Maritime division

Activities undertaken by contractors on behalf of Roads and Maritime.

The requirements of this Procedure must be communicated to all Roads and Maritime workers and contractors (e.g. during inductions) who are undertaking activities where incidents may occur.

The Procedure is for internal reporting processes, except where incidents are identified that need to be notified to regulators, and other relevant authorities (see section 5.1).

The procedure does NOT cover environmental incidents caused by:

Operational road and traffic activities of the general public (e.g. vehicle accidents, fires caused by discarded cigarette butts)

Boating accidents (except those involving Roads and Maritime vessels)

Dumping of materials by members of the public on Roads and Maritime roadsides or land (except where hazardous materials are unexpectedly found during road construction or maintenance activities). Illegal dumping should be reported to the NSW Environment Protection Authority (EPA)

Marine oil and chemical spills covered by the National Plan for Maritime Environmental Emergencies (Australian Maritime Safety Authority, 2014).

Page 6

http://www.epa.nsw.gov.au/illegaldumping/reporting.htm

http://amsa.gov.au/forms-and-publications/Publications/national_plan.pdf


2. Environmental incident classification

There are three categories of environmental incidents, as detailed in Table 2.

Table 2: Environmental incident classification

Category Description Examples

Category 1

Potential breaches of legislation or failures of process that result in actual off-site environmental harm, or residual on-site environmental harm

or

Works undertaken outside approved areas, without required approval or without environmental assessment

or

Any Material Harm pollution incident as

defined by Part 5.7 of the Protection of

the Environment Operations Act 1997 (POEO Act).

Pollution Incidents

Discharge of waters from site not in accordance with any approval requirements (e.g. discharge criteria in an Review of Environmental Factors (REF) safeguard or Environment Protection Licence (EPL) condition)

Pollution, or potential pollution, of waters

Unmanaged vehicle tracking of materials or emissions of dust, offensive odours or noise beyond the site boundary that are not managed in accordance with approval requirements and/or might impact on nearby land users

Pollution incidents that threaten harm to the health or safety of people (e.g. odours)

Unauthorised or illegal disposal or transport of waste

A spill or other incident that causes pollution to land

Conservation Breaches

Unauthorised harm or damage to native flora and fauna (terrestrial or aquatic/marine)

Unauthorised dredging or reclamation works within a watercourse

A fire caused by Roads and Maritime activities that travels beyond the boundary causing or potentially causing harm to the environment or community

Heritage Breaches

Unauthorised harm to Aboriginal objects and Aboriginal places

Unauthorised damage to any State or locally significant relic or Heritage item, or item listed

on the Roads and Maritime Section 170 register

Page 7

http://www.legislation.nsw.gov.au/#/view/act/1997/156/chap5/part5.7

http://www.legislation.nsw.gov.au/#/view/act/1997/156/chap5/part5.7

http://www.rms.nsw.gov.au/about/environment/protecting-heritage/heritage-conserv-reg/index.html




Planning and compliance breaches

Failure to comply with the requirements of:

The Environmental Planning and Assessment Act 1997 (EP&A Act), including exempt activities, Part 5 determinations and Part 5.1 approvals

An Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) approval

An EPL

A CEMP or environmental work method statement

A permit from a regulator (e.g. under the Fisheries Management Act 1994)

Category 2

Failures of process or events that do not result in off-site environmental harm, or residual on-site environmental harm. These incidents may result in temporary on-site environmental harm that can be rectified to pre-existing conditions.

A procedural, administrative or technical breach of environmental requirements, including:

Failure to prepare or submit required documents, reports or other correspondence

Failure to comply with the requirements of:

o The Environmental Planning and Assessment Act 1997 (EP&A Act), including exempt activities, Part 5 determinations and Part 5.1 approvals

o An Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) approval

o An EPL

o A CEMP or environmental work method statement

o A permit from a regulator (e.g. under the Fisheries Management Act 1994).

Spills and discharges that do not leave a site boundary and are cleaned up without residual on-site environmental harm, and the area of temporary impact can be restored to pre-existing conditions

A fire that is contained on site and does not cause or potentially cause adverse impact to the environment or community

Reportable Event

An event or unexpected find that occurs outside the scope of reasonable environmental controls and mitigation measures

Sediment or site water travelling beyond a site boundary, and where it can be demonstrated that:

Erosion and sediment controls were installed and maintained in accordance with an erosion and sediment control plan, and

The cause of the incident was reasonably unforeseen or the weather (rain, wind etc) event exceeded the design capacity of controls.

Note these events are considered to have occurred (and the response should commence in accordance with Section 3) when sediment or site water first travels beyond the site boundary (e.g. when an appropriately sized and maintained sediment basin commences overtopping)

An unexpected archaeological find that is being managed in accordance with the "Roads and Maritime

Page 8




Standard Management Procedure - Unexpected Archaeological Finds”

An unexpected threatened species find that is being managed in accordance with the “Roads and Maritime Biodiversity Guidelines – unexpected threatened species finds procedure”

An unexpected find of contaminated soils, asbestos or other potentially hazardous substances during construction or maintenance works. Note that once a particular contaminant is identified or found for the first time (either during project planning or construction phases) it is then reasonably expected to be found, so additional finds need not be reported in this category.

Regulatory Action

Formal regulatory action from an environmental regulator (that has not already been reported in conjunction with another incident)

Formal regulatory action from an environmental regulator includes, but is not limited to:

Penalty infringement notices (PINs)

Clean up notices

Prevention notices

Official cautions / warnings

EPA show cause notifications.

Note: For any incident where there is associated formal regulatory action from an environmental regulator, copies of this correspondence must be forwarded to [email protected] in addition to the Environmental Incident Report (see section 4).

Page 9



3. Environmental incident response

3.1 Considerations and steps for environmental incident response

The step-by-step response for Category 1 incidents, Category 2 incidents and Reportable Events is detailed in Table 3.1a (activities undertaken by contractors) and Table 3.1b (activities undertaken by Roads and Maritime Regional Maintenance). However, some key points apply throughout all stages of the response to any environmental incident:

If in doubt, treat all incidents as Category 1 to ensure reporting timeframes can be met

Strong consideration should be given to notifying:

o Roads and Maritime Corporate Communications for any incidents that have potential for community or media attention (see section 4.4)

o Roads and Maritime Work Health and Safety Branch for any incidents that involve actual or potential risks to worker health and safety (see section 4.4).

The person responsible for operational management of the site/activity shall assume responsibility for the response to the incident and direct actions as necessary and in accordance with this Procedure

A Roads and Maritime Environment Manager can consult with the Director Environment Operations (DEO) to reclassify the category of an incident where appropriate.

Any Regulatory Action received (that has not already been reported in conjunction with another incident) should be immediately forwarded to the [email protected] mailbox, and followed by an immediate phone call to the relevant Roads and Maritime Environment Manager, who will immediately advise the DEO. Consideration should then be given as to whether an environmental incident has occurred (see section 2) that should be reported in accordance with this section.

Page 10


–


Table 3.1a: Environmental incident response activities undertaken by contractors S

tep

Action

Responsibility for completing action

Timeframe

Category 1 Incidents

Category 2 Incidents /

Reportable Events

1

Stop work in relevant area (if necessary) and take actions to prevent adverse impact to human health or the environment.

Note human health and safety is the primary concern, and no action should be taken if it is not safe to do so.

Person who identifies incident

Immediate Immediate

2 Advise the contractor site management team. Person who identifies incident

Immediate Immediate

3 Advise the Roads and Maritime project management team and the relevant Roads and Maritime Environment Manager.

Contractor Immediate Day of the incident

4

Consider if the incident is a pollution incident that constitutes Material Harm in accordance with Part 5.7 of the POEO Act. For Material Harm pollution incidents, notify relevant agencies (see section 5.2). Sites with an EPL should implement their Pollution Incident Response Management Plan.

Contractor Immediate Immediate

5

Advise DEO by phone. The DEO may request photographs and a brief summary of known information via email. The following Roads and Maritime managers should also be notified by phone as relevant:

Director Environment (Major Projects)

Director Environment (Motorways).

Roads and Maritime Environment Manager

Immediately following advice of the incident

N/A

6 Where relevant, notify incident to appropriate regulatory agency (see section 5.1). Note this does not refer to the requirement to notify Material Harm pollutions incidents (see Step 4).

Contractor As required by legislation

As required by legislation

7 Complete the incident report form (see section 4.2), including sign-off from Roads and Maritime Project Manager, and submit to Roads and Maritime Environment Manager* (see sections 4.3 and 4.4).

Contractor Within 3 business days of the incident

Within 3 business days of the incident

8 Sign and submit incident report form to [email protected]. Roads and Maritime Environment Manager

On the day of receipt of the form


9 For Material Harm pollution incidents, provide a written report to each relevant authority (see section 5.2).

Contractor Within 7 days of the incident

N/A

10

Undertake incident investigation (level of investigation to be appropriate to the severity of the incident) to determine root cause and any necessary corrective actions. Summarise findings in ‘Incident Lessons Learnt’ template and submit to Environment Manager for review.

Contractor Within 1 month of incident

N/A

11 Submit final Incident Lessons Learnt to [email protected]. Roads and Maritime Environment Manager

Within 1 week of receipt

N/A

12 Consider the need for any required corrective actions to be addressed through a management system (e.g. corrective action request).

Roads and Maritime Environment Manager and project team

As appropriate As appropriate

Page 11



–


*Alternate workflow / signatory arrangements may be required for projects where a third party is involved (e.g. a delivery authority). These arrangements can be confirmed with the relevant Roads and Maritime Environment Manager.

Table 3.1b: Environmental incident response activities undertaken by Regional Maintenance (including contractors or RMCC on behalf of Regional Maintenance)

Ste

p

Action

Responsibility for completing action

Timeframe

Category 1 Incidents

Category 2 Incidents /

Reportable Events

1

Stop work in relevant area (if necessary) and take actions to prevent adverse impact to human health or the environment.

Note human health and safety is the primary concern, and no action should be taken if it is not safe to do so.


Immediate Immediate

2 Advise the Roads and Maritime site management team and the relevant Roads and Maritime Environment Manager and Safety Environment Quality Officer (SEQO) / Safety Environment Quality Co-ordinator (SEQC).


Immediate Immediate

3 Advise DEO by phone. The DEO may request photographs and a brief summary of known information via email. The relevant Regional Maintenance Manager must also be notified.

Environment Manager

Immediate N/A

4 Consider if the incident is a pollution incident that constitutes Material Harm in accordance with Part 5.7 of the POEO Act. For Material Harm pollution incidents, notify relevant agencies (see section 5.2). Sites with an EPL should implement their Pollution Incident Response Management Plan.

DEO

Immediately following advice of the incident

N/A

5 Where relevant, notify incident to appropriate regulatory agency (see section 5.1). Note this does not refer to the requirement to notify Material Harm pollutions incidents (see Step 4).

Environment Manager



6 Complete the incident report form (see section 4.2), including sign-off from Roads and Maritime Project Manager, and submit to SEQC (see section 4.3).

Relevant Roads and Maritime site representative



7 SEQC to sign and submit incident report form to relevant Environment Manager (see section 4.4). SEQC On the day of receipt of the form


8 Sign and submit incident report form to [email protected]. Environment Manager



9 For Material Harm pollution incidents, provide a written report to each relevant authority (see section 5.2). DEO Within 7 days of the incident

N/A

10

Undertake incident investigation (level of investigation to be appropriate to the severity of the incident) to determine root cause and any necessary corrective actions. Summarise findings in ‘Incident Lessons Learnt’ template and submit both to Environment Manager for review. Consider the need for any required corrective actions to be addressed through a management system (e.g. corrective action request).

SEQC Within 1 month of incident

N/A

11 Submit final Incident Lessons Learnt to [email protected]. Roads and Maritime Environment Manager

Within 1 week of receipt

N/A

Page 12




Copies of formal regulatory action from an environmental regulator (that has not already been reported in conjunction with another incident) must be forwarded to the relevant Roads and Maritime Environment Manager (and SEQC/SEQO for Regional Maintenance projects) and [email protected] immediately upon receipt.

3.2 Critical incidents

Some Category 1 incidents require escalation so relevant members of the Roads and Maritime Executive are aware of the incident and ready to respond as necessary. Category 1 incidents will be deemed ‘Critical Incidents’ for escalation to the Executive when they have the potential for:

Regulatory action (e.g. EPA Penalty Infringement Notice) and/or

Reputational damage (e.g. media coverage) and/or

Significant environmental harm.

Guiding factors that will be considered when determining whether there has been ‘significant’ environmental harm include:

When there has been actual or potential harm to the health or safety of people or to the environment that is not trivial

Actions required to prevent, mitigate or make good the actual or potential environmental harm are likely to exceed $10,000

When a potential ‘Critical Incident’ is reported, the DEO will immediately brief the Director Environment (DE) who will make a determination on whether it will be considered a ‘Critical Incident’. The DE will then brief the Roads and Maritime Chief Executive and relevant Executive Director, as well as any other members of the Executive as appropriate. When the DE cannot be contacted, the DEO will make the determination and make the relevant Executive briefings.

Page 13



4. Environmental incident reporting

4.1 Environmental incident report form

The Environmental Incident Report Form should be completed for Category 1 incidents, Category 2 incidents and Reportable Events, and is available on the Roads and Maritime website.

4.2 Completing the incident report form

All parts of the Incident Report Form must be completed in accordance with this procedure and following the instructions within the form. The Form (and any subsequent reports) must only include factual information. Speculation about the causes and outcomes of incidents are not to be included.

The Form must be signed by the following:

Signatory Reason

The person making the report

The person witnessed the incident or has the most knowledge of the incident, and can provide sufficient factual information.

The Roads and Maritime Project Manager

To ensure all relevant Roads and Maritime parties can be made aware of the incident, and appropriate resources can be allocated and/or approved to respond to the incident. This also ensures the project management team are aware of any environmental performance trends if multiple incidents occur.

Safety Environment and Quality Co-ordinator (Roads and Maritime Regional Maintenance only)

To ensure Regional Maintenance management system staff are aware of the incident, and any necessary management system changes can be made once corrective actions and lessons learnt are finalised.

The relevant Roads and Maritime Environment Manager

Concurrence that the incident is adequately described, and the immediate actions and corrective actions are appropriate.

As noted in Table 3.1a, alternate signatory arrangements may be required for projects where a third party is involved (e.g. a delivery authority). These arrangements can be confirmed with the relevant Roads and Maritime Environment Manager.

4.3 Submitting the incident report form

All Incident Report Forms must be populated, signed and submitted electronically (never printed / signed / scanned etc.) to enable Roads and Maritime to electronically capture the information entered in the form.

Completed Incident Report Forms should be submitted by the Roads and Maritime Environment Manager to the Environment Operations mailbox:

[email protected]

It is essential that a clear and consistent subject line convention is used to allow tracking of correspondence about each incident. All emails about an incident between all parties should structure the subject line as follows:

Category X - project name / incident location - date

For example, Category 1 – Main Road Upgrade – dd/mm/yy.

Where information cannot be gathered within the timeframes set out in this Procedure, the incident form should be submitted to the mailbox as a ‘draft’, whether or not the information contained is fully completed.

For example, Category 1 – Main Road Upgrade – dd/mm/yy (DRAFT).

The Environment Manager should then request further information from the person making the report, and the final report should be submitted within the next 24 hours.

Page 14

http://www.rms.nsw.gov.au/about/environment/environmental-compliance/index.html



4.4 Roads and Maritime contacts

The relevant Environment Manager for each region and Project Office is the first point of contact for enquiries relating to environmental incidents. Current contacts for all Roads and Maritime Environment Managers can be found on the Roads and Maritime website.

Environment Managers can also provide contact details for other relevant contacts during an incident, such as Communications or Work, Health and Safety.

The DEO oversees the application of this Procedure, and can be contacted in the absence of the relevant Environment Manager for Category 1 incidents:

Phone - (02) 8843 3048

5. Regulatory agency notification

5.1 Notification of Material Harm pollution incidents

5.1.1 Definition of Material Harm pollution incidents

Under Part 5.7 of the POEO Act, there is a duty to immediately notify (i.e. promptly and without delay) each relevant authority (see section 5.1.3) of a pollution incident where material harm to the environment is caused or threatened.

The POEO Act states that a pollution incident should be considered Material Harm 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”

Material Harm only relates to pollution incidents. Other environmental incidents, such as conservation, heritage and planning breaches, are not included in the definition of a pollution incident.

5.1.2 Determining if an incident should be considered Material Harm

As soon as a person becomes aware of a pollution incident that has the potential to cause Material Harm, the Category 1 incident response should be followed (see Table 3.1a and Table 3.1b above). The determination on whether a pollution incident should be considered Material Harm should be made in accordance with Table 5.1.2.

Table 5.1.2: Determination of Material Harm pollution incidents

Project delivery Material Harm determination

Activities undertaken by Regional Maintenance

The DEO should make the determination (and any associated notifications) on whether a pollution incident should be considered Material Harm.

If the DEO is not available, the relevant Environment Manager should seek advice from other Roads and Maritime Environment Branch Directors, or make the material harm determination themselves.

If no assistance can be obtained and it is suspected that a pollution incident should be considered Material Harm, the project should notify the relevant authorities in accordance with Table 5.1.3a or Table 5.1.3b (as relevant).

Activities undertaken by contractors

The contractor project team should make the determination (and any associated notifications) on whether a pollution incident should be considered Material Harm.

The relevant Roads and Maritime Environment Manager or Environment Branch Director may contact the DEO to assist in making an assessment of the incident, to aid the contractor in determining if the pollution incident should be considered Material Harm.

Where Roads and Maritime believes a pollution incident should be considered Material Harm but the contractor disagrees, Roads and Maritime is required by law to notify EPA and other relevant authorities. In this instance the DEO or DE would make a determination on whether the incident should be notified by Roads and Maritime as Material Harm. Roads and Maritime would provide details of any notifications made to the contractor.

Page 15

http://www.rms.nsw.gov.au/about/environment/environmental-compliance/index.html


Even if only limited information is available for a pollution incident being considered Material Harm, each relevant authority must be immediately notified with the information available and updates provided as soon as further relevant information becomes available.

In circumstances where there is doubt about the need to notify a pollution incident as Material Harm, Roads and Maritime and its contractors should always err on the side of notification.

When in doubt, communicate!

Note: Roads and Maritime is not responsible for notifying a Material Harm pollution incident caused by a traffic or vehicle accident where notification has already occurred by someone at the scene. However, if it is believed notification has not been undertaken, Roads and Maritime should undertake notification in accordance with section 5.1.3. Environment Branch can provide advice in this instance (see section 4.4).

5.1.3 Relevant authorities to notify

The relevant authorities that must be notified for a Material Harm pollution incident are listed in tables 5.1.3a and 5.1.3b below. It is important to note the order of notification and phone numbers to use can vary depending on the nature of the pollution incident, as detailed in the two tables.

All of the authorities listed (whether considered relevant or not) must be contacted for each Material Harm pollution incident to satisfy POEO Act requirements. Serious penalties apply to both individuals and corporations for failing to notify Material Harm pollution incidents:

Maximum penalty for individuals - $500,000

Maximum penalty for corporations - $2,000,000.

Table 5.1.3a: Authorities to notify for Material Harm pollution incidents that present an immediate threat to human health or property

Order Authority Contact Number

1 Fire and Rescue NSW 000

2 NSW EPA environment line 131 555

3 Ministry of Health (via the local Public Health Unit)* Contact 1300 066 055 to be directed to the local Public Health Unit, or visit the NSW Health Website

4 SafeWork NSW 131 050

5

The Appropriate Regulatory Authority*, being either:

Local council

Western Lands Commissioner for the Western Division (except any part of the Western Division within the area of a local council).

Local council - contact Office of Local

Government on 4428 4100, or visit the Office of Local Government website

Western Lands Commissioner – phone 6883 5400

Table 5.1.3b: Authorities to notify for Material Harm pollution incidents that do NOT present an immediate threat to human health or property

Order Authority Contact Number

1 NSW EPA environment line 131 555

2

The Appropriate Regulatory Authority*, being either:

Local council

Western Lands Commissioner for the Western Division (except any part of the Western Division within the area of a local council).

Local council - contact Office of Local Government on 4428 4100, or visit the Office of Local Government website

Western Lands Commissioner – phone 6883 5400

3 Ministry of Health (via the local Public Health Unit)* Contact 1300 066 055 to be directed to the local Public Health Unit, or visit the NSW Health Website

Page 16

http://www.health.nsw.gov.au/infectious/pages/phus.aspx


http://www.dlg.nsw.gov.au/

https://www.olg.nsw.gov.au/


http://www.dlg.nsw.gov.au/






4 SafeWork NSW 131 050

5 Fire and Rescue NSW 1300 729 579

* The appropriate contact for the Appropriate Regulatory Authority and Public Health Unit will vary according to the geographic location of the activity. These contact numbers should be found in advance and stored for immediate access (e.g. in a project’s Construction Environmental Management Plan and/or on site notice boards) should a pollution incident need to be notified.

5.1.4 The relevant information to provide

It is important to avoid speculation on origin, causes or outcomes of a pollution incident in discussions with the authorities. Section 150 of the POEO Act provides the information that needs to be notified, being:

a) The time, date, nature, duration and location of the incident

b) The location of the place where pollution is occurring or is likely to occur, the nature, the estimated quantity or volume and the concentration of any pollutants involved, if known

c) The circumstances in which the incident occurred (including the cause of the incident, if known)

d) The action taken or proposed to be taken to deal with the incident and any resulting pollution or threatened pollution, if known

e) Other information prescribed by the regulations.

Only known information should be provided when notifying of a Material Harm pollution incident. If further information becomes known after the initial notification, that information must immediately be notified to all authorities in accordance with Section 150 (see above). The immediate verbal notification is to be followed by written notification to each relevant authority within seven days of the date on which the incident occurred.

Complying with these notification requirements does not remove the need to comply with any other legislative requirements for incident notification (e.g. requirements under EPL conditions or the Work Health and Safety Act 2011).

5.2 Summary of other regulatory agency notification requirements

Specific statutory requirements relating to the notification of environmental incidents to relevant regulatory agencies are summarised in Table 5.2. Additional requirements adopted by Roads and Maritime are indicated in italics. Any notification to regulatory agencies should be indicated in the Environmental Incident Report Form to confirm that any required notifications have been initiated.

Table 5.2: Regulatory agency notification requirements

Legislation / issue Regulating authority

Section / requirement

Commonwealth Aboriginal and Torres Strait Islanders Heritage Protection Act 1984

Department of the Environment and Energy

Section 20 – requirement to notify the Minister of the discovery of Aboriginal remains.

Contaminated Land Management Act 1997

EPA Section 60 – requirement to notify if Roads and Maritime activities have contaminated land or if Roads and Maritime owns land that has been contaminated.

Heritage Act 1977 Office of Environment and Heritage

Section 146 – requirement to notify the Heritage Council of the location of the relic once a relic has been discovered or located.


Office of Environment and Heritage

Section 89A – requirement to notify the location of an Aboriginal object that is the property of the Crown.


EPA and other relevant authorities

Section 148 – requirement to immediately notify pollution incidents that cause or threaten Material Harm to the environment (see Section 5.1)

Page 17

http://www.environment.gov.au/about-us/contact-us



http://www.epa.nsw.gov.au/contact/

http://www.environment.nsw.gov.au/contact/








EPA

Pro-active reporting to the local EPA officer of offsite pollution incidents that occur as a result of Roads and Maritime activities is encouraged as soon as practicable after the pollution incident occurs.

Rural Fires Act 1997 NSW Rural Fire Service

Section 64 – requirement to notify an appropriate fire officer of the inability to extinguish any fire burning during a bush fire danger period applicable to the land.

Breach of Conditions of Approval (projects approved under Part 5.1 of the EP&A Act)

Department of Planning and Environment (DPE)

DPE should be notified by the project proponent when there has been a breach of a Condition of Approval (CoA). There may also be other notification requirements included in the CoA.

Water supply catchment areas

Local water supply authority

If an environmental incident has the potential for unapproved impacts on a drinking water supply, the relevant water supply authority must be advised.

5.3 Requests for written reports from regulatory authorities (activities delivered internally by Roads and Maritime)

Should Roads and Maritime directly receive a request from a regulatory authority for a written report regarding an environmental incident, Environment Branch and Legal Branch must be immediately contacted for advice. No further correspondence (including email) about the incident should be distributed either internally or externally until advice is received. Environment Branch will coordinate with Legal Branch to:

Assist in the investigation of the incident

Provide legal advice to the project

Co-ordinate the preparation of the written response to the regulatory authority.

Page 18


http://www.rfs.nsw.gov.au/about-us/contact-us

http://www.rfs.nsw.gov.au/about-us/contact-us

http://www.planning.nsw.gov.au/Contact-Us



Title: Manage and Report SHE IncidentsID: MSID-2-288 Version: 14.0 Date Published: 04/07/2018Management System - Uncontrolled Document when Printed

Page 1 of 5

Manage and Report SHE Incidents

Purpose

This procedure describes how to respond, classify and report Safety, Health and Environment (SHE) incidents on a project.

Procedure

1 Respond to Incident

Accountability: Worker / Rail Safety Worker

Where safe to do so, take action to prevent further injury.

Give first aid to injured workers.

Notify the Supervisor as soon as possible.

Notify emergency service providers, if required.

Accountability: Supervisor

Ensure the incident area is safe.

Take all actions according to the Project Emergency Response Plan and/or administer any first aid if required

Notify the Project Manager and Project SHE Manager as soon as possible.

Accountability: Project SHE Manager

Confirm the Project Manager has been notified.

If the incident appears to be a Class 1A, Class 1P or Notifiable Incident:

Advise the Supervisor to barricade the area and restrict access.

Contact Employee Assistance Program (EAP).

o Determine if counselling is necessary and arrange if required, advise workers.

Advise the Supervisor to arrange drug and/or alcohol testing.

Obtain statements from witnesses to the incident.

Take measurements, photographs and/or videos.

Initiate medical assessment and treatment of injured workers.

Gather sufficient information to complete entry into Synergy.

2 Classify Incident

Accountability: Project Manager


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Classify the incident, using the tables below, to determine the incident notification requirements.

o Refer to Knowledge: Synergy Event Classification Matrix

o Refer to Knowledge: SHE Incident Notification Criteria

If the incident is likely to be a Safety and Health Class 2A, Class 1P or above or an Environmental Level 1 or 2:

Initial notification must be made to the BU SHEQ Manager within 2 hours; and

A Flash Report must be prepared and sent to the BU SHEQ Manager within 24 hours.

o Refer to Tool: SHE Flash Report

Accountability: BU SHEQ Manager

After being notified of any incident that is likely to be a Safety and Health Class 1P, 2A, 2P or an Environmental Level 1 or 2:

Notify the BU GM and the GM SHEQ immediately; and

As soon as it is received, send a copy of the Flash Report to the BU GM and GM SHEQ.

2.1 Safety & Health Incidents

Class 1PClass 1A

HPI Class 1P

Class 2A Class 2P Class 3A

Class 3P

Death or permanent disability

Most probable outcome would’ve been a Class 1A.

Note: A Class 1P can only be classified as a Class 1 HPI (High Potential Incident) by a Business Unit GM or higher.

See Note 2 in the Synergy Event Classification Matrix

LTI, RWI or an MTI

Most probable outcome would’ve been Class 2A (LTI, RWI, MTI)/ Notifiable Incident/ Breach of the Essentials

First aid injury or a Report Only Incident

Most probable outcome would’ve been a Class 3A First Aid

2.2 Environmental Incidents

Level 1 – High Severity Level 2 – Moderate Severity Level 3 – Low Severity

Pollution or degradation which has high severity impacts on the community and/or environment and may

Pollution or degradation which has moderate severity impacts on the community and/or environment (1 to 3 months duration) but is fully

Pollution or degradation which has low severity impacts on the community and/or environment in the short-term (less than one month duration) and is fully


Page 3 of 5

have irreversible residual impacts

reversible with no residual impacts

reversible with no residual impacts

3 Notify Internal Stakeholders

Accountability: Responsible Manager (as per table)

Notify the relevant stakeholder as per the table below:

Classification Report Type Project Business Unit Corporate

When Immediately Within 1 hour of incident

Within 1 hour of incident

Who Supervisor to PM

PM to Ops Mgr to GM Proj SHEQ to BU SHEQ

GM to EGM to MDBU SHEQ to GM SHEQ

Class 1A

How In person or phone In person, phone or text message

In person, phone or text message

When Immediately Within 2 hours of incident

Within 2 hours of incident


PM to Ops Mgr to GMProject SHEQ to BU SHEQ

GM to EGM to MDBU SHEQ to GM SHEQ

In person / phone / text message

In person / phone / text message

Class 1P HPIClass 1PClass 2A LTI

How In person or PhoneFlash Report within 24 hours

Flash Report within 24 hours

When Immediately 24 hours 24 hours


PM to Ops Mgr to GMProject SHEQ to BU SHEQ

Project SHEQ to Group SHEQ

Class 2P LTI, RWI, MTINotifiable Incidents/ breach of the EssentialsClass 2A RWIClass 2A MTI How In person or Phone Phone & data entry

into Synergy (GM)Data entry into Synergy

When 24 hours 24 Hours 24 HoursClass 3AClass 3P

Who

Supervisor to SuperintendentSuperintendent to PM

PM to Ops Mgr to GM BU SHEQ to Group SHEQ

Project SHEQ to Group SHEQ


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HowVerbally, in person or by phone, data entry into Synergy

Data entry into Synergy

Data entry into Synergy

4 Commence Investigation and deem a Crisis (if required)


Commence incident investigation

o Refer to Knowledge: Synergy Event Classification Matrix

o Refer to Procedure: Investigate SHE Incidents

Note: Where an incident results in the activation of the Emergency Response Plan, a De-Brief must be conducted to evaluate the effectiveness of the emergency response. Records of that Debrief must be documented. Actions from the De-Brief must be tracked.

o Refer to Procedure: Plan for Emergencies

Accountability: Operations Manager

Consult with the BU General Manager to assess the need to deem the event as a crisis.

o Refer to Procedure: Manage a Crisis

5 Determine Legal Professional Privilege Status


Consult the BU General Manager and General Manager SHEQ to determine if legal advice is required, if so:

Contact Legal Counsel, advise them of the incident and request that Legal Professional Privilege (LPP) be applied to the incident.

Note: LPP must be sought and obtained for all Class 1A incidents.

Comply with the advice regarding external notification, recording and investigation requirements.

6 Notify External Organisations

Accountability: Project Manager (or Corporate Management)

Determine if external notification is required upon confirmation of classification.

o Refer to Knowledge: SHE Regulatory Notifications Guide

o Refer to Knowledge: SHE Regulatory Notifications Guide NZ

o Refer to Knowledge: Guidelines for Reporting Safety and Health Incidents

Advise the relevant BU SHEQ Manager, BU GM and the GM SHEQ if external notification is required be made to the relevant Regulator (Work Health and Safety, Office of the Federal Safety Commissioner, Environment Protection Agency or where applicable, the Office of the National Rail Safety Regulator) and follow directions.


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Note: The Office of the National Rail Safety Regulator must be advised of all Category A and B Notifiable Incidents where CPB is the Accredited Rail Infrastructure Manager or Rolling Stock Operator.

o Refer to Tool: OFSC Incident Report

o Refer to Tool: ONRSR Notifiable Occurrences Notification Form

Enter a copy of the external notification into Synergy


Glenmore Parkway



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Appendix A8 Group Procurement Policy

Title: CIMIC Group Procurement PolicyID: MSID-7-51 Version: 8.0 Date Published: 26/04/2017Management System - Uncontrolled Document when Printed

Page 1 of 15

GROUP PROCUREMENT POLICY

This Policy sets out the requirements for the acquisition of goods and services (Procurement) across CIMIC Group Limited and entities it controls (the Group). Procurement is a key element of the Group’s operations that is crucial for project delivery, cost control, sustainability and financial performance – for the Group and for its clients.

This Policy should be read in conjunction with the Group Delegations of Authority (DoA), Group Code of Conduct (the Code), the Accounting Manual (incl. EIS/JDE and EIS/FPM) and the Dealing with Third Parties, Subcontract Management, Expense Reimbursement, Card and Travel policies.

This Policy applies to all employees of the Group, third parties engaged by the Group, including alliances and joint ventures in all jurisdictions.


The objectives of this Policy are to:

Achieve strong procurement value. Support project delivery, cost control, sustainability, safety and financial performance. Support compliance with legal requirements.

1. Procurement PrinciplesThe aim of this Policy is to ensure Group employees procure goods and services in a transparent, competitive, compliant and sustainable manner and to maximise value by encouraging effective competition and employee accountability.

When a need for the acquisition of goods or services is identified, employees must follow this Group Procurement Policy. Key principles of CIMIC procurement activities include:

Requiring an approved Purchase Order and signed contract1 as per the Group Delegations of Authority (DoA) with an approved supplier2 before any goods or services are delivered or work is commenced3 (approval post-delivery or after work commencing is considered as an act of non-compliance and employees may face disciplinary action). Any extension or variation of more than 10% requires the same approval4 as the original contract.5

Ensuring the separation of duties is adhered to with three different persons responsible for approving, receipting and paying.6

Any deviation from the Procurement Policy requires CIMIC CEO approval based on a recommendation from the Operating Company General Counsel and Managing Director (MD). This includes any reasons in any country or joint venture not to comply with this policy.

All procurement activities, including specifications, timing and costs need to be in line with the project procurement plan (or cost centre budget for corporate procurement). Unplanned items require approval, as per the DoA. Select cost types require specific approval as per the DoA.

No supplier commitments are to be made during the Group’s work tendering activities that influence the Group’s procurement in project delivery, unless approved as per the DoA.

1 In some cases procurement can occur without a signed contract as per the DoA.2 Refer to Dealing with Third Parties Policy and sections 6.2. of this Policy for requirements.3 Upfront approval can be set-up in exceptions as per section 6.4. of this Policy for specific procurement activities to ensure

continuous business operations.4 Changes where the cumulative value of the contract including all extensions/variations exceeds the authority of the original contract

approver require approval from the person with the authority for the cumulative value as per the DoA.5 Any deviations from plans as per the contract should be considered indicators for potential cost overruns.6 Expense Reimbursement Policy defines select expenses, which only require two persons, including the approving person.


Page 2 of 15

When entering into Joint Ventures (JVs), the JV shall follow this Policy as a minimum requirement and the Group’s JV representative has to have at least the same authority in the JV as the Project Manager on Group projects. The Group’s JV representative has to participate in the development of the JV procurement standards and the project procurement plan, and can approve procurement decisions up to their authority as per the CIMIC DoA. Exceptions require CIMIC CEO approval.

Strategic procurement partnering, including delivery/procurement partners and frame contracts with suppliers or a panel of suppliers that affect future procurement decisions (i.e. exclusivity agreements, minimum volume uptakes), or are mandated for use anywhere in a Group Company (new agreements or amendments) require approval as per the DoA. Approved mandated agreements must be used where defined and are set out in the Strategic Partnering Agreements.

2. Group Delegations of Authority (DoA)Employees must seek approval for each procurement activity as defined in the DoA and in line with the project procurement plan:

Contract values must not be divided into separate parts for the purpose of avoiding procurement thresholds. Where mandated frame contracts are in place, multiple orders are not considered as dividing into parts and such cases have to be considered in the development of frame contracts.

Organisational reporting structures are to be adhered to from an approval perspective. Where Executives are required to approve as per the DoA, all subordinated approvals between the requesting and approving role must be obtained.7

Delegated authority can be reduced, but limits can’t be increased. Authority can’t be re-allocated permanently to others, and only in case of absences from work can it be delegated up to four weeks, requiring one-up approval (longer periods or extensions require CIMIC CEO or MD approval).

3. Standard Contracts and Contract ConditionsSpecific CIMIC Standard Contracts, including contract conditions are to be used for all goods or services procured (refer to section 8. CIMIC Standard Contracts for details).

All contracts are required in writing and to be signed as per the DoA. Deviations from the standard contracts are not permitted unless approved as per the DoA.

7 Including Business Unit Procurement Manager approval before GM level and above approval.


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4. Group Company Systems and ProcessesGroup Companies are expected to have systems and processes in place, which adhere to this policy:

Procurement category management including definitions, spend data and strategic agreements. An approved supplier list, including supplier details, supplier ratings, background checks and supplier

performance assessment details, which must be actively managed and updated. ICT systems (as approved by CIMIC CIO) to support the procurement process, including Enterprise

Resource Planning, inventory management, financial and document management systems:▪ Records need to be kept to document the procurement process, including details on RFQ, quote

comparisons, signed contract, progress certificate, billing and contract settlement. ▪ Actions outside ICT systems (e.g. changes to contracts or involving petty cash) must be minimised and

added in a timely manner to the relevant system(s) to ensure transparency.▪ Responsibilities and access rights must align with this policy and the DoA. Where timely action is

required to avoid commercial disadvantages, mobile approvals should be implemented in line with the DoA.8

Published procurement procedures, forms and employee communication. Procurement Training: All employees engaged in procurement must be adequately trained to comply

with this policy.

5. Types of Procurement and DefinitionsThe acquisition of goods and services can be differentiated into four types of procurement: project works, service, supply and hire. To accommodate the needs of each procurement type, standard contracts are differentiated (refer to section 8. CIMIC Standard Contracts).

An approved Purchase Order is the digital confirmation in the Group’s ICT System that a specific procurement activity has been approved and is also used as an identifier throughout the process.

Approval for operational and capital expenditure requires different levels of authority as specified in the DoA. The following definitions are used:

Capital Expenditure (capex): a commitment to the long-term use of a depreciating asset, regardless of how the asset is funded, including leases, hiring and rentals of more than twelve months or rentals with material break costs9. The value is calculated as the total cost of the asset, if purchased by the Group or the total rental commitment over the life of the contract.10

Operational Expenditure (opex) – any purchase that does not fall under the capex classification.

Procurement is differentiated into project procurement (project related procurement; spend on projects) and corporate procurement (supports the activities of corporate functions and business units). Requirements for each type of procurement are detailed in following sections.

8 Limited validity of request of up to three work days.9 Material Break Costs applies to rental arrangements whereby the cost of early termination equates to or is greater than three

months rental.10 Multiple short term rentals of the same item that combined exceed 12 months are capex; the extension exceeding 12 months

requires approval as per the capex DoA.


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6. Project Procurement Ensuring compliance and optimising procurement value requires input from several stakeholders. Exhibit 1 provides an overview of key roles relevant to the project procurement process.

Exhibit 1: Overview on key project procurement roles

1. Can be via Functional EGM 2. Can be via EGM

Managing Director

Business UnitGeneral Manager

Ops Manager

Operating Company

Procurement Manager

Project Manager

Project Manager

Operational Executive General

Manager

1

Operating Company

Plant Manager

1

Business UnitProcurement

Manager

2

Project Manager (head of project and responsible to client and business unit for delivery of all project parts on time and on budget): Plan all project expenditure before project start or extension, propose and approve procurement activities, including development of procurement strategies, preparation of specifications, documents and requirements, preparation of request for quotations (RFQs), quote comparison, negotiation and supplier selection, preparation and management of contracts and completion of supplier assessments as per the DoA.

Business Unit Operations Manager: (responsible for multiple projects): Where applicable, endorse project procurement plans and individual procurement proposals from a scope/technical/timing/financial perspective.

Business Unit Procurement Manager11: Ensure compliance with the procurement policy and related procedures, assist the Project Managers (PMs) with procurement plans and selection of suppliers; review and submit quote comparisons, recommendations of award and contracts to the GM and assist in maintaining the approved suppliers list.

Operating Company Procurement Manager: Ensure compliance with procurement policy and related procedures across the Operating Company and provide functional leadership for Business Unit Procurement Managers; manage cross-Operating Company procurement topics, including frame contracts, approved supplier list and supplier reviews, procurement categories and reporting; support business units and projects, with expert sourcing knowledge, including international sourcing and negotiation strategies; endorse project procurement plans and review selective individual procurement proposals from a purchasing perspective.

Operating Company Plant Manager: Manage and optimise current plant and equipment assets held by the Operating Company; support projects in hiring, buying and selling decisions as required; provide plant rate quotes to projects as required.

Business Unit Manager (incl. GMs, EGMs, MD): Sign off project procurement plans and approve individual procurement activities as per the DoA.

11 Reports to the BU General Manager (can be the EGM in exceptions) with functional reporting to the Operating Company Procurement Manager.


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Exhibit 2 lays out the key steps of the project procurement process, which are detailed in the following chapters.

Exhibit 2: Overview of project procurement process

Project procurement

plan

Request for Quotation

(RFQ)

•Requirements/ Specifications

•Selection of Suppliers

Homogenous Quote

Comparison

Supplier Ranking

Negotiation

Recommendation of

Award

Written contract

(execution of contract)

Administration of Contract

•Delivery of goods or services

•Progress certificate

Contract extensions and variations

Operating Company Procurement:Frame contracts, approved supplier list, procurement categories, etc.

Billing(payment of invoice)

Contract Settlement

Assessment of supplier

performance

1 2 3 4 5

6

7 8 9


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6.1. Project Procurement PlanThe Project Manager (PM) will plan all project expenditure before the project start, including any detailing documents. The plan will include the following elements for each procurement package12:

Outcome: Specifications of procurement items, volumes, project/client requirements, testing, documentation, certification, and other key requirements.

Cost: Budget and target cost (consistent with FPM) for each procurement item, including totals for supply cost categories across packages.

Contingencies: Any expected procurement items yet to be finalised should be included as contingency packages with respective budget and target costs (consistent with FPM). No procurement activity can be done using a contingency package as basis for an RFQ.13

Supplier options for the RFQs. Timing: When the process starts and key milestones such as work start, contract signing (including time

limits) and work completion dates. Risks and dependencies: Critical path packages, substantial packages, links between packages, long lead

time items, constrained supply market risks, delivery risks and mitigation plans. Planned CIMIC Standard Contract to be used. Logistics and offsite manufacturing strategy, including inventory requirements. Sourcing responsibility

Minimum requirements for the development of the project procurement plan include:

In projects where the volume of work can change (e.g. mining), the plan should encompass the expected volumes (e.g. annual mine plans) with deviations planned for.

The PM assessing self-performance vs. external procurement for “works”, leveraging the Group’s capabilities and comparing risks for each alternative.

Assessing where commercially advantageous, the purchase of plant/equipment instead of hiring, considering risks, including project changes and post-project plan changes for the asset. Buying can only be considered, if risks appear minimal and benefits clearly outweigh hiring. Full depreciation on the project must be aimed for and approval as per the DoA is required.

The project procurement plan has to be approved as per the DoA before project start and is to be reviewed at least every 3 months.14

Before project procurement plan approval by GM and above, approval from the Business Unit Operations Manager (for scope/ technical aspects/timing/financials of plan; involving EIC as relevant), the Business Unit Procurement Manager and the Operating Company Procurement Manager (for supplier options and pricing) is required.

Cost deviations of more than 5% for procurement packages, supply categories or annual procurement plans for mining contracts, compared to tender estimates, require acknowledgement as per the DoA for the procurement plan.

6.2. Requirements/ Specifications, Selection of Suppliers and Request for Quotation (RFQ)All of the following requirements/specifications are to be defined and signed off as per the DoA for a defined package of the project procurement plan before the request for quotation (RFQ) is sent to suppliers:

12 For repeat order items, each planned contract is to be specified for the entire project. Procurement packages can contain several procurement items.

13 If further information and planning is available at procurement plan reviews, procurement packages can be specified, reducing contingency values and allocating package specific budget and target cost.

14 Additionally the project procurement plan should be reviewed and re-approved, if total procurement costs differ from FPM by more than 1-3%.


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Specifications15

Volumes and possible variations TimingClient requirements, including back-to-back arrangements (contractual requirements, fit for purpose, penalties and warranties) Group standard contract conditions16

Safety requirements, especially Operating Company safety policies and procedures, safety legislation, Australian and international standards as they relate to procurement.

Further requirements, including insurance, warranties, (cross-) guarantees, site requirements and environment.

The approved supplier list is used to assist supplier selection and only approved suppliers are to be sent a RFQ. Suppliers that are currently not on the approved supplier list may be included in the RFQ, if they have completed a pre-qualification form.17 Supplier approval is confirmed together with the RFQ by the approver, ensuring appropriate supplier due diligence is completed prior to RFQ distribution.

Together with the RFQ, quote evaluation criteria and weightings have to be developed for the decision making process. These criteria should include pricing along with other factors, including supplier ability to meet specifications, contract conditions, warranties, total life-cycle cost, indigenous and local community involvement and supplier rating as per the approved supplier list.

Minimum requirements include:

The RFQ has to be distributed to sufficient suppliers18 to ensure three to six comparable and compliant quotes are received.19 Deviations require approval as per the DoA.

The RFQ has to align with the project procurement plan and noted as to what procurement package it relates to in the plan. If unplanned, RFQs require approval as per the DoA and the project procurement plan has to be reviewed. If requested by the approver, the project procurement plan has to be re-approved as per the original DoA.

Suppliers should be provided with the same information at the same time to ensure fairness. Answers to material questions raised by any of the suppliers are to be shared with all suppliers. RFQs requiring GM approval must have the prior approval of the Business Unit Procurement Manager

and are to be sent to the Operating Company Procurement Manager for selective review to ensure that the best sourcing options are considered.

Where capex is required (for purchase or hiring by the project), the project will always consider internal and external sourcing options, requesting a quote from the Operating Company Plant team in addition to the three quotes from external suppliers.

Frame contracts and strategic partnership agreements aim to agree favourable purchasing conditions with large and technically leading suppliers. They can be optional or mandatory and on CIMIC Group or Operating Company level for a specified good or service and geographical scope.20

Mandated frame contracts/strategic partners (refer to Strategic Partnering Agreements) must be used and ‘three quotes’ are not required as a comprehensive assessment will have taken place as part of the frame contract agreement.21 Any decision not to use mandated frame contracts requires approval as per the DoA.

15 Including documentation on technical and particular specifications, drawings, plans, certificates, applicable legislation, trials and testing.

16 The CIMIC Standard Contract is only to be distributed in non-editable formats (e.g. PDF).17 As defined by the Operating Company. With RFQ distribution, pre-qualified suppliers are added to the approved suppliers list.18 Suppliers that have supported in a project tendering phase should also be included in the RFQ distribution.19 Compliance of at least three quotes is confirmed as per the DoA with the ranking of supplier as part of the quote comparison.20 Frame contracts have to follow CIMIC Standard Contracts and Conditions, unless approved by the MD based on a General Counsel

recommendation.21 Further policies might apply and approvals can be required depending on the strategic agreement (e.g. travel policy or IT

equipment purchasing). Please refer to frame contract responsible and/or Group governance guidance.


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Optional frame contracts/strategic partners must be included in respective RFQs and are always subject to negotiations.

In order to use a frame contract on a project, a contract based on the frame contract conditions is to be approved and signed as per the DoA.

Information on frame contract prices or conditions that are inferior to other quotes should be forwarded to the Operating Company Procurement Manager to inform future negotiations.

At the end of this step, the following information is provided to the contract signatory22 (as per the DoA) as well as the BU Procurement Manager: RFQ details and selected suppliers for distribution.

6.3. Quote Comparison and Supplier Ranking Received quotes need to be compared on a homogenous basis to identify the best option for the Group. A quote comparison table as shown in Exhibit 3 is to be used to compare planned pricing as per the project procurement plan with supplier quotes and to identify the lowest cost option for each item and the RFQ overall. Quote evaluation criteria from the RFQ are to be included along with any deviations and supplier ratings from the approved supplier list.

Exhibit 3: Quote Comparison Table

Using the evaluation criteria defined in the RFQ, suppliers are then to be ranked and each quote compared to the minimum quote price received (multiplying item volumes with the lowest quote price received for each item).

Suppliers are to be identified for further negotiations (typically 2-3 suppliers), and negotiation targets (including price, conditions, non-negotiables, minimum outcomes) and a negotiation strategy are to be defined and approved23 as per the DoA before negotiations commence.

At the end of this step, the following information is provided to the contract signatory24 (as per the DoA) as well as the Business Unit Procurement Manager: Quote comparison table, suppliers for negotiation, negotiation targets and strategies.

6.4. Negotiation, Recommendation of Award and Contract with Supplier (execution of contract)

22 If this person is at GM level or above the information is also sent to the Operating Company Procurement Manager.23 If GM approval is needed, prior approval by the Business Unit Procurement Manager must be obtained. 24 If this person is at GM level or above the information is also sent to the Operating Company Procurement Manager.

Project procurement plan (consistent with FPM) Supplier quotes

VolumeBudget price

(per volume unit)Target price

(per volume unit)

Price paid by client (per volume unit)

Lowest price of all

quotes(per volume unit)

Quote 1(per volume unit)

Quote 2(per volume unit)

… Quote 6(per volume unit)

Item 1 [Specification]

Item 2 [Specification]

…

Item n [Specification]

Total Price(price x volume)

Deviations from RFQ (including specifications or timing, client requirements incl. back-to-back arrangements, standard contract deviations)

Other evaluation criteria

Supplier rating (based on approved supplier list)


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Negotiations aim to drive the best procurement outcome for the Group and agree a written contract with a supplier for a defined maximum contract spend. Requirements include:

Avoiding the risk to enter into verbal or otherwise binding contracts prior to contract signing. Considering restarting the whole process or adjusting target outcomes, if no possible outcome can fulfil

the set targets or negotiations result in a major change to the original RFQ.

When negotiation targets are met and no further improvement of the Group’s position is expected, a recommendation of award is to be approved as per the DoA as basis for an approved purchase order that is generated in the ICT system and as basis for the following signing of a written contract.25

A written CIMIC Group standard contract26, signed by the final approver of the recommendation of award and signed by the supplier (execution of contract27), IS REQUIRED BEFORE ANY GOODS OR SERVICES ARE DELIVERED OR WORK IS COMMENCED.

Any decision to use external plant (hire or purchase), where an internal sourcing option is available has to be approved by the Operating Company MD to ensure that the best commercial outcome is selected (in addition to approval for capex or operational expenditure as per the DoA).

A contract can include several draw-downs that are then used to fulfil the contract. The PM can prepare in advance for cases where immediate action outside business hours might be

required to ensure continuous operations:28

▪ The PM can specify when a procurement activity can happen based on a clearly defined trigger/case. A maximum item price and item specifications have to be defined for each specific case and a ranked order of supplier options to be used.

▪ Each case is to be signed off by the EGM or above (‘approval of recommendation of award’ as per the DoA) and the contract has to be signed as per the DoA after the event.

25 Specifying the same elements as defined in the RFQ, including a maximum approved procurement value.26 For purchase of goods under $20k, either a supplier-provided contract or no contract is allowed as per the DoA.27 Two copies of the contract are sent to the supplier in a non-editable format. The supplier has to sign both copies and once

reviewed (by the Business Unit Procurement Manager for all contracts requiring GM signature or above), both copies are signed by the final approver of the recommendation of award (as per the DoA) and one copy is returned to the supplier.

28 Where not defined, procurement activities have to be approved as per the DoA outside business hours.


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6.5. Administration of Contract: delivery of goods and/or services (progress certificate)Once a contract has been signed with the supplier, the delivery of the goods and services commences and the contract is to be administered. All deliveries have to be compliant with the signed contract. The administration of the contract includes the following requirements:

A project manager delegate will review deliveries of goods and services on the project against accruals created for the contract, and issue a signed progress certificate for the compliant delivery, including a calculation of the respective accrual amount. Progress certificates are then to be approved by the PM and the client, if required, and provided to Accounts Payable for forwarding to the supplier as basis for an invoice.

Goods and works are to be physically inspected, tests and analyses conducted and certificates provided to confirm that the correct items/works have been delivered, that there is no damage and all relevant documentation, including guides, supplier manuals and warranties are present. All documentation is to be kept for future use and compliance.

Regular and timely progress and commercial meetings on site with the supplier are to be held to discuss performance according to the contract, including, but not limited to: progress, safety, quality, environment, variations and claims.

Contract notices pursuant to the relevant contract clauses are issued to the supplier. Requests for information, extensions of time, claims, delays, disruption and variation registers are to be

reviewed on a weekly basis by the PM.

6.6. Contract Extensions and VariationsContracts are to be delivered as agreed with the supplier. Potential extensions or variations are early indications of cost overruns - these have to be identified early to provide all sourcing options and require upfront approval as per the DoA.

Changes that increase the contract value by more than 10% require the same approval as the original contract.

Changes where the cumulative value of the contract including all extensions/variations exceeds the authority of the original contract approver require approval from the person with the authority for the cumulative value as per the DoA.

The approver will decide if the extension/variation has to go out to the market.

6.7. Billing (payment of invoice)Invoices shall only be paid, if (a) supplier delivery is compliant with the contract, (b) all elements of the invoice are consistent with the progress certificate approved by the PM, (c) all discussions, negotiations and supplier claims are finalised and (d) the supplier has complied with all contractual requirements (e.g. statutory declarations).29

29 In certain cases limited to purchases where supplier contracts or no contracts are used, payment might be required before receipting is confirmed (an approved purchase order is required before the procurement occurs). In such cases only Finance approved payment methods are accepted.


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6.8. Contract SettlementWhen a contract is nearing completion and before the final payment of the last invoice is performed, the following requirements have to be met for the release of the final payment and for the setting of the commencement date of the warranty period:

Confirmed as per the written contract that the supplier has met all obligations, including submission of documentation (including design certificates, warranty deeds, O&M manuals, authority certificates and licenses), removal of equipment and temporary structures, defects fixed or agreed to be fixed and client approvals as required

All tests required under the contract have been successfully passed and verified. Certificate of compliance is signed by the supplier. Balance is determined and final settlement is drawn up. This will take into account variations, counter

claims, other costs, losses and damages suffered by the parties and payable in accordance with the contract.

Where existing, the ‘Form of Release’ in the contract is to be completed and approved by the PM and issued to the supplier for execution.

The release of any security held in accordance with the terms of the contract will be approved by the EGM subject to satisfactory completion of all obligations under the contract and expiry of any defects liability period.

6.9. Assessment of supplier performance and approved supplier listOnce contract settlement is completed, a supplier assessment as per the following is to take place to inform future supplier selections (supplier assessments for each completed contract are coordinated by the Operating Company Procurement Manager and assisted/reviewed by the Business Unit Procurement Manager):

Suppliers are assessed for the following performance dimensions (proposed weighting):30 compliance with health, safety and labour standards (15%), compliance with sustainability/ environmental regulations (15%), quality (15%), schedule compliance (15%), technical assistance (10%), responsiveness (10%), contract terms and conditions (10%), quality certificates (5%), withholdings and warranties (5%).

Each of the dimensions is to be scored between 0 (low performance) to 10 (high performance). Assessment results are to be incorporated into the approved supplier list as soon as available, which

contains all approved suppliers and their latest rating. A supplier rating consists of a letter indicating the rating level and a figure indicating the maximum

value the supplier has been used for (e.g. A20):▪ Rating: I(initial; pre-qualified), A(Excellent), B(Recommended), C(Acceptable), U(unsatisfactory)31

▪ Maximum level of past contract values with suppliers: 1 (<A$1m), 5 (<A$5m), 20 (<A$20m), 50 (<A$50m), 100 (<A$100m), 100+ (≥A$100m).

30 Supplier assessment criteria and criteria weighting can be adjusted as required by the Operating Company Procurement Manager.31 A score of 0 in any of the following criteria will automatically result in a U (Unsatisfactory) rating (qualitative explanation must be

given): compliance with health and safety regulations, compliance with environmental regulations, quality, or schedule compliance.


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7. Corporate ProcurementCorporate procurement (i.e. non-project related procurement) occurs at a CIMIC and Operating Company level and supports the activities of corporate functions and business units (BU). A similar role to project managers is delivered by BU cost centre owners with delegated authority (cost centre owner). Corporate procurement follows a similar underlying logic as projects, but differs given different requirements and context. Key roles of the corporate procurement process include: Cost Centre Owner (CIMIC and Group Company): Prepare and manage the budget for a defined cost

centre. Operating Company Procurement Manager: Ensure compliance with the procurement policy, manage

mandated frame contracts and manage/coordinate the approved supplier list. Group Company Managing Director: Agree Group Company cost centre budget with CIMIC CEO. Define

corporate function and business unit overheads with Group company cost centre owners. CIMIC CEO: Approve cost centre budgets for CIMIC and Group company budgets.

Each cost centre owner will plan annually for next year’s expected procurement of goods and services, seeking approval by the Group Company MD, who seeks approval for the Group Company cost centre budget from the CIMIC CEO32 as part of the budget planning process. The plan will include the total budget value, based on specifications, volume and pricing of the planned procurement for each cost category (itemising single cost items >A$20k). The plan defines the maximum spend for each cost category and guides cost centre owners in their procurement during the year. It is the cost centre owner’s responsibility that actual costs remain within budget. Any total budget adjustments require approval as per the original budget DoA.

When a need for procurement is identified during the year, employees need to identify procurement options, seek approval and ensure compliance with the separation of duties.

For any professional services or any other procurement ≥A$50k, three to six comparable and compliant quotes are to be obtained and compared using the decision matrix (Exhibit 3). Exceptions require approval as per the DoA.

Procurement approval as per the DoA is to be sought with select procurement activities requiring specific approval, including contracts where spending affects next year’s budget/expenditures, contracts influencing future Group procurement (e.g. exclusivity agreements, minimum uptake) and procurement outside mandated frame contracts.

CIMIC Standard Contracts must be used, unless approved as per the DoA. All deliveries have to be compliant with the agreed contract and be receipted. Any extension or

variation of more than 10% requires the same approval as the original contract. Cash or credit card payments should be avoided, but if not possible then the payer must adhere to the

expense reimbursement policy (select procurement items) and card policy (card payment). Only suppliers from the approved supplier list can be used (or require pre-qualification) and supplier

assessment is to occur post-delivery.

32 The CIMIC CEO also approves all budgets for CIMIC cost centres.


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8. CIMIC Standard ContractsDepending on the procurement activity, the appropriate form of procurement contract must be used for the written contract signed with the counterparty for the supply of goods or services. In case of questions, the advice of the respective Group Company General Counsel is to be sought.

8.1. Payment TermsPayment terms shall be set by the Operating Company Managing Directors for each Group entity. Deviation to these payment terms is only allowed:

a) where a specific project’s head contract or state/national laws mandate other payment terms, or;

b)where the Operating Company Managing Director has appointed a delegate to review and approve specific contracts.

Payment terms negotiated and structured with suppliers must aim to keep the cash flow positive and must only be made in approved currencies33. Payments made in currencies other than the revenue currency under the head contract must be avoided; if the contract requires this, the Operating Company CFO must be consulted to establish, if spot FX payments is required and approval must be given as per the DoA. If hedging is required this must be approved separately as per the DoA.

8.2. Cap on Liability Any cap on liability should be avoided in a procurement contract. However, where a cap on liability is insisted upon:

a) it must be commensurate with the potential impact that a breach of the contract can have on the project’s outcome; this should never be limited to the value of the consultant’s fee or contract sum.

b) where the services include design, Professional Indemnity (PI) insurance must be of a sufficient value. If any cap on liability is agreed to, it must not be less than the amount of PI insurance.

c) the clause wording must be obtained from Operating Company Legal Counsel and included as a special condition.

d) it must be approved by the Operating Company MD.

8.3. Back-to-Back Arrangements: Forwarding of Client Requirements to the SupplierWhere project specific procurement contracts are not applicable, client requirements must, to the maximum extent applicable, be passed down to a subcontractor or supplier on a back-to-back basis, including (but not limited to) legal liabilities, payment securities, time and cost relief etc. Where the head contract imposes fit for purpose obligations, these must be passed down in the subcontract on a back to back basis. In particular, goods and services must always, at a minimum, be fit for their intended purpose.

33 Approved currencies refer to currencies in countries where CIMIC has approved operating companies to work.


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8.4. Standard Forms of Procurement Contracts

Type of procurement

Standard contract Definition

PROJECT WORKS

‘Supply and fix’ or ‘fix only’ works

Works Contract

For works that make up a substantial portion of construction activities and/or will expose CIMIC to financial or other risks (including Design & Construct).Example: Subcontract to design and construct permanent works, “supply and fix” or “construct only”.

Services Contract

For the engagement of all disciplines of general engineering and building consultants, including design consultants, particularly design of permanent works.Example: Design consultants, architectural consultants.

Independent Contractors Agreement

Engagement of non-design related consultancy services for less complex scopes of work.Example: Bid writers.

SERVICES

Pre-bid Agreement

An agreement prior to a tender to establish terms of exclusivity and cooperation during the tender phase.

MINOR WORKS AND SERVICES

Minor Works and Services Contract

For minor works and services that will not expose CIMIC to significant financial or other risks and generally will not form part of the permanent works.Example: day-works, personnel hire, supply and install for low value/low risk items.

Supply Contract (w/o install)

For the supply and delivery without installation, of manufactured-to-order major equipment (including minor equipment if its manufacture, installation or performance could expose CIMIC to financial or other risks).Example: goods to be incorporated into the permanent works such as steel, concrete etc.

SUPPLY

Acquisition of goods

Minor Supply Contract

For the purchase of goods (including manufactured-to-order minor equipment) which will not expose CIMIC to financial, contractual or other risk.Example: Off the shelf items, stationery.

HIREPlant Hire Contract

For the hire of plant or equipment, with or without an operator, (including minor items if their performance could result in CIMIC’s exposure to significant financial or other risks).Example: works under direct supervision and on a time charged basis.

8.5. CIMIC Standard Contracts ManagementCIMIC Standard Contracts are managed by the CIMIC General Counsel. Standard Contracts are controlled documents that must not be distributed in an unlocked or editable format outside the Operating Company Legal Team. Any change to the CIMIC Standard Contracts forms (general changes that apply to all future contracts; not just for one procurement activity) requires CIMIC CEO approval based on a CIMIC General Counsel recommendation.

Policy Information Owner: General Manager Strategy, CIMICApproved by: Chief Executive Officer, CIMIC


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Version Number: 2.0Effective date: 29 September 2016 amended 1 November 2016

Note: CIMIC Group policies may be amended from time to time.


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Appendix A9 Dealing with Third Parties Policy

Title: Dealing with Third Parties PolicyID: MSID-7-74 Version: 4.0 Date Published: 17/05/2017Management System - Uncontrolled Document when Printed

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DEALING WITH THIRD PARTIES POLICY

This Policy sets out the requirements for business relationships with third parties across CIMIC Group Limited and entities it controls (the Group). Third parties are entities and individuals outside of CIMIC Group. They may be clients, joint venture partners, subcontractors, consultants and supplier, agents or intermediaries.

The Group will only do business with third parties for legitimate purposes, in accordance with the Group Code of Conduct (the Code), relevant laws and where that business relationship will benefit the Group. The Group will not do business with a third party that does not share a similar approach to the Group in relation to ethical matters, or where engaging with the third party will harm the reputation of the Group.

This Policy applies to all relationships with third parties and applies to all employees of the Group, third parties engaged by the Group, and all alliances and joint ventures in all jurisdictions.


The objectives of this Policy are to: Ensure risks are appropriately assessed before entering into formal business relationships; and Ensure risks are appropriately managed during the course of those relationships.

1. Third Party Selection process and formal engagements All engagements with third parties must be for a legitimate purpose and in the best interests of the

Group. Selection processes must achieve value for money and avoid conflicts of interest. Appropriate enquiries (due diligence) must be carried out on all third parties prior to formal

engagement. The Group’s procurement and work tendering policies must be followed in accordance with the Group

Delegations of Authority. A written contract must be signed before works, supply or services commence and only entered into with all necessary approvals in accordance with the Group Delegations of Authority.

2. High Risk, Medium Risk and Low Risk Third PartiesA third party is designated as High Risk if any of the following apply: it is a potential/new joint venture partner; it is an agent and/or intermediary (which includes legal, tax, immigration, financial, security and

industrial relations advisers, lobbyists, customs and shipping agents); the remuneration payable to the third party:

▪ is based on success fees for the award of contracts or achievement of a defined outcome;▪ is in cash; or▪ includes a non-refundable up-front payment (other than mobilisation payments for design or

construction services); it is nominated or recommended by a public official or other representative of a government or state-

owned enterprise; it is an individual (rather than a company or partnership) (other than permanent or contract

employees); the engagement relates directly to a project for a government or state-owned enterprise in any country

which has a ranking of 60 or higher in the most recent Corruption Perceptions Index (as published from time to time by Transparency International) (Corruption Perceptions Index); or

due diligence enquiries identify potential issues.

A third party is designated Low Risk if any of the following apply:


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a supplier, government or state-owned enterprise in any country which has a ranking between 1 to 40 on the Corruption Perceptions Index;

a client who has been rated in Band A or Band B of the Defence Companies Anti-Corruption Index published by Transparency International UK (or any subsequent index published by Transparency International relating to companies); or

an existing client who has been approved as Low Risk by the CIMIC CEO and recorded in the register.

All other third parties are designated Medium Risk.

3. Third Party Approval / Engagement In this context the Approving Manager is the person with delegated authority pursuant to the Group Delegations of Authority to approve the transaction under consideration, or as delegated by that person.

Members of the Group are free to engage with Low Risk third parties subject to appropriate procurement/ tendering standards being followed.

High Risk and Medium Risk third parties may only be engaged where: they have completed and executed a Third Party Anti-Bribery and Corruption Declaration:

▪ all High Risk third parties must complete and sign the declaration:o prior to any new engagement; o annually during an engagement; and/or o if there is a significant change in the circumstances of the third party or the engagement;

▪ Medium Risk third parties must have completed and signed a declaration o prior to initial engagement; and o if there is a significant change in the circumstances of the third party (during an engagement or

since the declaration was signed); and basic integrity checks on the third party have been completed (e.g. internet searches on the company

and key individuals) and are acceptable to the Approving Manager (see below).

Where either the Third Party Anti-Bribery and Corruption Declaration or the basic integrity checks are not to the satisfaction of the Approving Manager, further enquires must be made before proceeding. These could include: enquiries of the third party about the specific concerns; and detailed due diligence by an approved specialist due diligence provider (e.g. Thomson Reuters or Control

Risks).

All due diligence information must be presented to the Approving Manager.

The Approving Manager can only approve the proposed business relationship if, based on the information available, the Approving Manager is reasonably confident that: the business relationship is a legitimate one; the business relationship provides value for money; and the third party will comply with the Code1.

1 or, if the third party has a code of similar scope and content to the Code, its own code.


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Approval may be granted conditionally. Conditions may include some or all of the following requirements: the third party’s key representatives undertake training in relation to the Code; periodic updated due diligence; a periodic review of the third party’s payment requests and payments; rights to audit payments made to the third party and payments made by the third party from all sources

of funds; and the right to a full audit of the third party’s accounts.

4. Policy InformationOwner: Group General Counsel, CIMICApproved by: Deputy Chief Executive Officer, CIMICEffective date: 12 August 2015 amended as at 10 March 2017 GGS012

Note: CIMIC Group Policies may be amended from time to time.


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Appendix B1 Construction Traffic and Transport Management Plan


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Appendix B2 Construction Flora and Fauna Management Plan


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Appendix B5 Construction Heritage Management Plan


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Appendix B6 Construction Air Quality Management Plan


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Appendix B7 Construction Waste, Energy and Resource Management Plan


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Appendix B8 Construction Ancillary Facilities Management Plan


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Appendix B9 Construction Community Involvement Plan


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Appendix B11 Pollution Incident Response Management Plan


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Appendix B13 Construction Sustainability Management Plan

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