Pollution Incident Response Management Plan

Pollution Incident
Response Management Plan
for
KELSO WASTE FACILITY
ISSUE NO 2 – JANUARY 2014
Issue
1
2
Reviewed by
Neil Chapman
Sarah Abid
Approved by
Anthony Vangi
Anthony Vangi
Pollution Incident Response Management Plan
Approval date
February 2014
Page 2
Contents
1.0
INTRODUCTION .......................................................................................................................................4
1.1
Objectives ................................................................................................................................................4
1.2
Legislative requirements ........................................................................................................................4
1.3
Definition of ‘pollution incident’ .............................................................................................................5
2.0
SITE OVERVIEW – KELSO WASTE FACILITY...............................................................................................5
2.1
Background..............................................................................................................................................5
2.2
Facility layout...........................................................................................................................................5
2.3
Emergency Incident Response Procedures .............................................................................................6
2.4
Plant and Safety Equipment ....................................................................................................................6
2.5
Inventory of pollutants............................................................................................................................7
2.6
Potential Hazards and Pre-emptive Actions............................................................................................8
3.0
AUTHORITIES TO BE NOTIFIED OF POLLUTION INCIDENT.......................................................................9
3.1
If an incident occurs within standard operating hours ...........................................................................9
3.2
If an incident occurs outside standard operating hours .......................................................................10
4.0
ACTIONS TO BE TAKEN DURING OR IMMEDIATELY AFTER A POLLUTION INCIDENT ............................11
4.1
Initial response phase............................................................................................................................11
4.2
Emergency Services Response Phase ....................................................................................................11
4.3
Containment or Control Phase:.............................................................................................................12
4.4
Recovery Phase......................................................................................................................................12
5.0
COMMUNITY NOTIFICATION & COMMUNICATION ..............................................................................13
6.0
REVIEW & MAINTENANCE OF PIRMP....................................................................................................13
6.1
Staff Training .........................................................................................................................................13
6.2
Testing and review of the PIRMP ..........................................................................................................14
Appendix 1 – Incident Assessment Form ..........................................................................................................15
Appendix 2 – Site Layout ...................................................................................................................................15
Pollution Incident Response Management Plan
Page 3
1.0
INTRODUCTION
This PIMRP has been prepared in response to the requirements of the Protection of the
Environment Legislation Amendment Act 2011 (POELA Act), which requires Bankstown City
Council to report pollution incidents immediately to the EPA and other Agencies, and to have
mechanisms in place to also notify any affected community.
1.1
Objectives
The objectives of this PIMRP are to:
a) Ensure comprehensive and timely communication about a pollution incident to staff at
the Kelso Waste Facility, the Environment Protection Authority (EPA), NSW Ministry of
Health, WorkCover NSW, and Fire and Rescue (NSW) and people outside the facility
who may be affected by the impacts of any pollution incident; and
b) Minimise and control the risk of a pollution incident at the facility by identifying pollution
risks and planning actions to be taken to manage those risks
Ensure the plan is properly implemented by trained staff, identifying the persons
responsible for implementing it and ensuring that the plan is regularly tested for
accuracy, currency and suitability
1.2
Legislative requirements
The specific requirements for Pollution Incident Response Management Plans are set out in
Part 5.7A of the POEO Act and the Protection of the Environment Operations (General)
Regulation 2009 (POEO(G) Regulation). In summary, this provision requires the following:
a) All holders of environment protection licences must prepare a pollution incident
response management plan (section 153A, POEO Act).
b) The plan must include the information detailed in the POEO Act (section 153C) and be
in the form required by the POEO(G) Regulation (clause 98B).
c) Licensees must keep the plan at the premises to which the environment protection
licence relates or, in the case of trackable waste transporters and mobile plant, where
the relevant activity takes place (section 153D, POEO Act).
Licensees must test the plan in accordance with the POEO(G) Regulation (clause 98E).
If a pollution incident occurs in the course of an activity so that material harm to the
environment is caused or threatened, licensees must immediately implement the plan
(section 153F, POEO Act).
Pollution Incident Response Management Plan
Page 4
1.3
Definition of ‘pollution incident’
The definition of a pollution incident is:
Pollution incident means an incident or set of circumstances during or as a consequence of
which there is or is likely to be a leak, spill or other escape or deposit of a substance, as a
result of which pollution has occurred, is occurring or is likely to occur. It includes an incident
or set of circumstances in which a substance has been placed or disposed of on premises,
but it does not include an incident or set of circumstances involving only the emission of any
noise.
A pollution incident is required to be notified if there is a risk of ‘material harm to the
environment’, which is defined in section 147 of the POEO Act as:
a) Harm to the environment is material if:
(i) It involves actual or potential harm to the health or safety of human beings or to
ecosystems that is not trivial, or
(ii) It results in actual or potential loss or property damage of an amount, or amounts
in aggregate, exceeding $10,000 (or such other amount as is prescribed by the
regulations), and
b) Loss includes the reasonable costs and expenses that would be incurred in taking all
reasonable and practicable measures to prevent, mitigate or make good harm to the
environment.
2.0
SITE OVERVIEW – KELSO WASTE FACILITY
2.1
Background
The facility commenced operations in 1952 and the original site now encompasses the Kelso
sporting grounds, Kelso Park. The current landfill area has been in use since 1968. Waste
has been deposited in a series of layers, approximately 2.5 - 3.0 m thick. This approach to
landfilling has now produced a landfill that is some 30 m in fill depth and approximately 18 m
above the prevailing topography.
Currently, the Kelso Landfill is used exclusively by BCC Business Units and Council’s
contractors to dispose of waste that is created by Council activities.
2.2
Facility layout
The Kelso Waste Facility is comprised of the Kelso Landfill site (KLS), Kelso Recycling Area
(KRA) and ancillary weigh-bridge area containing main site office, amenities & plant
compound.
Activities within the KLS include landfilling of wastes, cell construction and stock-piling of
daily & intermediate cover material.
Pollution Incident Response Management Plan
Page 5
Activities within the KLS include stock-piling and campaign crushing of concrete, recycling
aggregates & soils, stock-piling and blending of organic mulches; also the temporary storage
of mattresses and rubber tyres for off-site recycling.
Refer to Appendix 3 attached, for a detailed site layout of the premises.
2.3
Emergency Incident Response Procedures
Council has an adopted Emergency Management Plan for the Kelso Waste Facility.
The objective of this Plan to protect the safety of staff, contractors or visitors present on the
site in the event of Emergency.
The Plan includes evacuation procedures, notification of relevant authorities and provision for
periodic testing and review of the Emergency Management Plan. A copy of the Plan is
maintained at the Kelso site office.
All Kelso personnel carry mobile phones ensuring staff are contactable during operations.
Two way radios are to be installed in all plant providing ready communication between
operators and the site office.
2.4
Plant and Safety Equipment
The following plant & safety equipment is maintained on site:
Type
Potential Use
Location
Personal Protective
Equipment (PPE)
Personal protection against
dust, eye irritations
Site office
Spill Kit
Clean up of liquid spills
Site office
Plant compound
Water cart
Suppress dust, fight small
fire
Plant compound
Track loader & Rubber tyre
loaders
Combat fire, excavate
trenches, divert liquid flows
Plant compound
Portable fire extinguishers
Combat fire
Site office
Plant compound
Pollution Incident Response Management Plan
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2.5
Inventory of pollutants
Very few chemicals and/or potential pollutants are kept in quantity on the site, and these are
stored within the Office & plant compound area. MSDS are held on-site for these
products.
Potential pollutants can be classified generally as:
a) Grease & Oils (maintenance) and Fuels not generally exceeding 100L
b) Small quantities of proprietary herbicide for local weed control around buildings
c) Household grade cleaning products, pest spray degreasers, spray paint
Various items of heavy plant are re-fuelled by a fuel-supply contractor using a mobile tanker.
Type of pollutant
Engine Oil
Trucking Kleen
Spheerol Grease
Premium Engine Oil
Hydraulic Oil
Powerdrive Fluid
Hydraulic Fluid
Food Processing
Degreaser
Transmission Oil
Coolgard Coolant
Castrol Hydraulic Oil
Premixed Heavy Duty
Coolant
Spray Paint
Lubricant
Quantity on site
110 L
25 L
1000 kg
40 L
20 L
20L
20L
40 L
60L
10 L
160 L
120L
1450 g
400g
A Safe Work Method Statement and Standard Operating procedure is in place.
Pollution Incident Response Management Plan
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2.6
Potential Hazards and Pre-emptive Actions
Hazard
Likelihood
Impact
Pre-emptive actions taken
Risk
Dust migrating
from site to M5 or
surrounding
properties
Moderate
Moderate
Low
Smoke from fire
Moderate
Low
Landfill gas
emissions
migrating off-site
Low
High
- Watering of roads, stockpiles when
needed using water cart or sprinklers.
- Maintaining good groundcover
- Intermediate cover/grass applied to
disturbed areas not being filled for
longer than 90 days.
- Management Plan for site vegetation
implemented.
- Minimum 150mm cover material
applied to waste daily. Extensive
buffer around site.
- Sound landfill management practices
used.
- Network of gas monitoring wells.
- Regular emissions monitoring.
Leachate entering
waterways or
groundwater
Moderate
Moderate
Fuel/oil spill
entering
waterways
Low
Moderate
Air pollution
Low
Moderate
Water Pollution
Pollution Incident Response Management Plan
- Minimum 150mm cover material
applied to waste daily.
- Surface water management to limit
ingress of water to waste cells.
Compliance with environmental
guidelines for cell construction.
- Regular water quality monitoring.
 Re-fuelling procedures followed
Spill kits maintained on site.
Moderate
Low
Page 8
3.0
AUTHORITIES TO BE NOTIFIED OF POLLUTION INCIDENT
3.1
If an incident occurs within standard operating hours
Council staff will have the best opportunity to identify and assess the incident promptly. Any
personnel becoming aware of an incident will notify the Team Leader Landfill Operations in
the first instance. The Team leader will notify the Landfill Co-ordinator or if not contactable,
the Director City Assets & Infrastructure, unless there is an immediate threat to human health
or property at which time the Team Leader will first notify 000 (Triple Zero).
The Director (or delegate) will notify the Council General Manager and then assign or will
assume the role of Incident Supervisor.
The Incident Supervisor will:
If there is an immediate threat to human health or property notify the authorities in the
order listed:
1. Relevant Personnel
Anthony Vangi (Director City Assets and Infrastructure)
Tel: 9707 9885
Mob: 0412 019 060
Neil Chapman (Coordinator Landfill Operations)
Tel: 9707 9252
Mob:0409 830 103
Ray Holden (Team Leader Tip Operations)
Tel: 9707 9251
Mob: 0412019060
2. Fire and Rescue NSW
Tel: 000 – triple Zero
3. EPA Environment Line
Tel: 131 555
4. The Ministry of Health via the local Public Health Unit
Western Zone (Camperdown Office)
PO Box 374, Camperdown 2050
Tel: 9515 9420
Fax: 02 9515 9440
Fax: 02 9515 9468 (alternate)
After Hours Contact
Pollution Incident Response Management Plan
Page 9
Tel: 02 9828 3000
(Liverpool Hospital) - ask for Environmental Health - Health Officer on call
5. WorkCover Authority
Tel: 13 10 50
6. Bankstown City Council
Tel: 02 9707 9999 – Customer Service Centre
If there is no immediate threat to human health or property then call
1. Bankstown City Council
Tel: 02 9707-9999 – Customer Service Centre
2. EPA Environment Line
Tel: 131 555
3. The Ministry of Health via the local Public Health Unit
Western Zone (Camperdown Office)
PO Box 374, Camperdown 2050
4. Tel: 9515 9420
Fax: 9515 9440
Fax: 9515 9467 (s)
After Hours Contact
Tel: 9828 3000
(Liverpool Hospital) - ask for Environmental Health Officer on call
5. WorkCover Authority
Tel: 13 10 50
6. Fire and Rescue NSW
Tel: 000 – triple Zero
3.2
If an incident occurs outside standard operating hours
If an incident occurs outside standard operating hours it is most likely to be reported by a
member of the public either direct to Fire & Rescue NSW (000) or via Council’s Emergency
After Hours number (9707-9999)
The Emergency After Hours service will notify the Landfill Co-ordinator or if uncontactable the
Director City Assets & Infrastructure. One of these personnel will be assigned or will assume
the role of Incident Supervisor. The Incident supervisor will inform the General Manager and
follow the relevant notification protocol.
Pollution Incident Response Management Plan
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4.0 ACTIONS TO BE TAKEN DURING OR IMMEDIATELY AFTER A
POLLUTION INCIDENT
4.1
Initial response phase
Council staff or individuals first present at the scene are to report the pollution incident to the
Team Leader – Landfill Operations or otherwise in accordance with Section 3.0 above.
The Incident Supervisor (or delegate) will attend the scene and will ensure any personnel are
safe and put in place any containment actions required to prevent or limit the pollution
incident.
The Incident Supervisor (or delegate) will defer to and follow the instructions of any combat
agency already on-site e.g. Fire & Rescue, that has assumed control and management
responsibilities for the incident.
An initial visual assessment will determine the actions to be implemented which are to be
directed to:
> Protecting life and preventing injury to persons;
> Isolating the location and excluding entry, as appropriate;
> Limiting the potential spread of pollution;
> Identifying additional hazards; and
> Calling for appropriate help, per Section 3.0
An Incident Assessment Checklist is to be used to aid incident assessment and record
information required to be provided to the EPA and other authorities as required by Section
150 of the POEO Act. Information is to be gathered only as safe to do so.
4.2
Emergency Services Response Phase
If the incident presents an immediate threat to human health or property and 000 has been
contacted, staff are to evacuate the site of all persons and enact the Emergency Services
Plan.
Emergency Services personnel will assume responsibility for managing the incident,
including initial command & control responsibilities on arrival. Council staff (and contractors)
will follow and adhere to all directions and instructions issued by the appointed emergency
services Incident Controller.
Council staff (or contractors) will fully co-operate with emergency services and provide:
> An initial briefing of events
> Relevant documentation, plans and the completed Incident Assessment Form
This will assist emergency services to:
> Assess the situation;
> Identify hazards;
> Prepare a Response Plan;
> Identify resources or specialist assistance needed; and
> Contact & co-ordinate additional resources (if any) to respond to the incident
Pollution Incident Response Management Plan
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4.3
Containment or Control Phase:
Having completed the initial assessment of the incident and before emergency services
arrive (if contacted), additional resources and actions should be directed to:
1. Establish mobile phone contact with the Incident Supervisor.
2. Provide first – aid assistance to any injured person
3. If the Emergency Management Plan has been enacted ensure evacuation
procedures are followed.
4. Close the site or the landfill and/or restrict access if appropriate. Exit gates may need
to remain open for passage of emergency services in which case personnel may
need to be assigned security duty on the gate, if safe to do so.
5. Restrict access to the incident area – provide clear communication to any personnel
remaining on site
6. If required and safe to do so, the Incident Supervisor is to initiate actions to prevent
further threat to life, property or the environment.
7. The Incident Supervisor is to collect details of persons involved, keeping time log of
key events.
8. Provide full briefing of incident, actions to date to emergency services
9. Maintain effective communications with relevant authorities and any local affected
community
10. Facilitate or assist with the recovery phase.
4.4
Recovery Phase
The Recovery Phase will focus on:
> Collecting and appropriately managing any spilt materials;
> tabilising any earthworks, diversion drains, containment structures;
> Undertake staff debriefing;
> Restock spill kits; and
> Finalising incident documentation and reporting on outcomes
Pollution Incident Response Management Plan
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5.0
COMMUNITY NOTIFICATION & COMMUNICATION
In the event of a pollution incident, the Incident Supervisor will make an assessment of the
requirement to notify neighbours and/or the surrounding local community. Where possible, an
owners and occupiers of premises who may be affected by a pollution incident will be issued
with an early warning or alert, and if appropriate, regular updates. Once the incident is
controlled or past, a final bulletin will also be issued to provide the “ all clear.”
This decision whether to communicate will be determined on the level of risk, being:
Priority 1: Immediate: indicating high - very high risk of high impact incident.
Pollutants will enter the environment and cause material harm.
The incident is assessed as immediate and threatening to human health, property and/or the
environment. Priority is to contact occupants of likely affected premises as soon as possible.
The Incident Supervisor will call on Council resources for telephone contact, letter box drop
or door-knocks as appropriate. Status reports to be provided to Council’s Customer Service
Centre as appropriate.
Priority 2: Deferred: indicating medium risk incident
Pollutants are likely to enter the environment.
The incident is assessed as being manageable through implementation of containment or
other emergency services measures. Close monitoring of the incident, containment and/or
other site measures are required with notification of occupants of likely affected premises to
occur if measures fail. Incident is regraded to Priority 1. Status reports to be provided to
Council’s Customer Service Centre as appropriate.
Priority 3: No notification
Pollutants may enter the surrounding environment.
The incident is assessed as being managed under normal site incident response and not
likely to have a direct impact or adversely affect the surrounding community.
6.0
REVIEW & MAINTENANCE OF PIRMP
6.1
Staff Training
Staff are inducted and trained in the use of this PIRMP. The PIRMP is promoted at regular
staff meetings to ensure all site personnel understand pollution incident procedures, their
roles & responsibilities and how and when to activate this plan in a pollution incident.
This PIRMP also describes the notification process for Council After Hours services and
contains a list of current contact details in the event of a pollution incident.
Pollution Incident Response Management Plan
Page 13
6.2
Testing and review of the PIRMP
The PIRMP will initially be tested and then tested on an annual basis in conjunction with the
Emergency Management Plan for Kelso Waste facility.
The PIRMP will be reviewed on an annual basis following testing and will also be reviewed
within one month following the occurrence of any pollution incident.
Pollution Incident Response Management Plan
Page 14
Appendices:
Appendix 1 – Incident Assessment Form
Appendix 2 – Site Layout
Pollution Incident Response Management Plan
Page 15
Appendix 1 – Incident Assessment Form
Page 1
INCIDENT ASSESSMENT FORM
To be completed by the Incident Supervisor (Landfill Manager or Site Supervisor)
Date and Time:
Initials
INITIAL RESPONSE PHASE
Provide short description of
Incident - including Nature, and
Location.
Circle relevant incident:
a) Leachate
b) Fire
c) Stormwater
d) Noise
e) Dust
f) Odour
g) Other
Mark Location as best possible on
Figure 1 (attached).
Notes: Location - record of the
place where pollution incident is
occurring or is likely to occur (i.e.
record possible migration path, as
best possible)
Nature - record estimated
quantity or volume and
concentration of any pollutants
involved (if known)
The information recorded here is to allow a initial (or brief)
assessment of the risk to help determine the likely impacts,
implementation of the PIRMP and/or relevant actions to be
undertaken.
Figure 1
Page 2
Date and Time:
Initials
Perform Brief/Initial Risk Assessment
Fill out below sections as best possible. Some
points
not be applicable depending on nature of pollution incident
• Identify spilt material/pollutants
List chemicals/materials/pollutants (if possible)
may
etc. (if possible)
• Determine (i.e. best estimate)
quantity of spilled material
• Evaluate hazards at the location
• Obtain a copy of relevant MSDS
(if chemical spilt)
• Evaluate the RISK and determine
if the pollution incident is a high or CRITICAL/PRIORITY 1
low pollution risk and whether trivial
Implementation of
or not.
PIRMP required;
Circle appropriate risk category:
If incident is
immediate and
threatening for human
health:
Dial 000
MEDIUM/ PRIORITY 2
Implementation of
PIRMP may be
required, monitor
pollution incident.
If containment efforts
fail, implement
PIRMP
LOW/ PRIORITY 3
Unlikely PIRMP is to
be implemented,
Monitor pollution
incident and
containment activities
Page 3
Date and Time:
Initials
ACTIONS
Emergency Services Response
Phase
• Clear affected area of
personnel/individuals
If No, state why. For example,
injured individual may not be able
to be moved or Council staff may
be able to implement containment
activities (if deemed safe to do so)
• Determine if evacuation of
Landfill site is necessary
Yes
Yes
No
No
If Yes, implement Emergency
Evacuation Plan.
If No, record personnel or
individuals remaining on site and for
what purpose
(e.g. assisting in containment
activities)
Check individuals for injuries
including contamination
Purpose remaining on site
Name
•
Note: some individuals may not
be aware of an injury and/or
having been contaminated.
Yes
No
Page 4
Date and Time:
Initials
 If required: Administer First Aid, Details: (include names of individuals andactions
and/or dial 000
Notify EPA and other authorities
of incident - i.e. Implement
Notification Protocol (section 4.1)
taken) (attach pages if necessary)
Name
Contact Details
Record personnel delegated to undertake this task:
Record all information regarding
Ensure above sections are completed as best possible and
incident in preparation for arrival of practicable due to incident situation.
Emergency Services
Page 5
Date and Time:
Containment or Control Phase
Initials
Record actions as best possible including personnel delegated to
tasks
If 000 has been dialed, only proceed if deemed safe to do so.
Cease works if incident worsens and dial 000.
•
Determine appropriate actions
to isolate/contain pollutants (if
safe to do so);
•
Ensure fire protection is
available if risk of fire.
Contact relevant Council staff
for assistance
•
•
•
Contact EPA and other
authorities if incident is not
trivial - i.e. Implement
Notification Protocol
(section 3.1 or 3.2)
Monitor containment works
If Council staff included in response
•
Establish Secure Zone (around
incident area or evacuate and
secure entire site)
•
Assign tasks to personnel
•
Specify equipment and tools for
clean-up including PPE
•
Locate and control spilt material
if appropriate.
Record personnel delegated to undertake this task:
Page 6
Date and Time:
Initials
•
Neutralise and/or absorb
material
•
Prepare residue for removal
•
Verify area clear of
contaminant
•
Decontaminate equipment
•
Debrief personnel involved
Yes
No
•
Complete Incident Reports
Yes
No
Any other information / actions:
Name:
Signature:
(Incident Supervisor; Landfill Manager or Site supervisor)
Date:
Appendix 2 – Site Layout