Midal Cables International Tomago NSW, Australia Pollution Incident Response Management Plan

Transcription

1 MIDAL CABLES INTERNATIONAL PTY LTD TOMAGO, NSW AUSTRALIA POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN 20 June 2014 Prepared for: Midal Cables Tomago, NSW Prepared by: Graham Taylor Ref: N:\800_Environmental\803 - PIRMP 1

2 COPY NO. LOCATION 1. Administration Office 2. ENV Plans (WHS & ENV) AMENDMENTS LIST The Management and Co-ordination of any amendments or changes to this document shall be controlled by the General Manager. Final approval shall be issued by the General Manager Only. Amendment No. Amendment Description Page No. Authority 0 Original document prepared 20 June C Samuels 2

3 Table of Contents 1 PURPOSE AND SCOPE Plan Authority Definitions What if a Pollution Incident Occurs? Site Contact Details Legal Requirements Legislative requirements for the plan What is Pollution Incident? Immediate Notification Site Overview Pollution Incident Notification Protocol When is notification required? Who has a duty to notify? Who do you notify? What information must you provide? Coordination with authorities Community Engagement Protocol Wider Notification Communication Mechanism Information to be provided Site Response Hazards Potential Pollutants Safety Equipment Staff Training Testing the Plan Plan Availability Onsite PIRMP availability Public Availability APPENDIX A APPENDIX B APPENDIX C APPENDIX D

4 1 PURPOSE AND SCOPE This (PIRMP) has been prepared for the Midal Cables International Pty Ltd facility located at Tomago. Midal is required to comply with requirements introduced by the Protection of the Environment Legislation Amendment Act 2011 (POELA Act) to prepare and implement a Pollution Incident Response Management Plan (PIRMP). The POELA Act includes a requirement under Part 5.7A of the Protection of the Environment Operations Act 1997 (POEO Act) to prepare, keep, test and implement a PIRMP. The objectives of PIRMP s are to: Ensure comprehensive and timely communication about a pollution incident to Midal staff, the EPA, PSSC, Ministry of Health, WorkCover NSW and Fire and Rescue NSW and to people external to Midal who may be affected by the impacts of the incident Minimise and control incident risk by identification of risks and development of planned actions to minimise and manage those risks. Ensure that the PIRMP is properly implemented by trained staff, with identified responsibilities and that the plan is regularly tested. Midal has already developed an Emergency Response Plan, a Safety Management System and a number of other plans associated with its Conditions of Consent issued for the project under Environmental Planning and Assessment Act, 1979 and the Environment Protection Licence (EPL No.20254). Midal s PIRMP therefore will reference those documents whilst ensuring that PIRMP content meets the requirements of Section 153C of the POEO Act and the POEO (G) regulation. 1.1 Plan Authority This PIRMP is issued on the authority of the Midal site manager. Contact details are: Street Address Postal Address Midal Cables International Pty Ltd Lot 11, 21D School Drive, Tomago, NSW 2322 Telephone- Business Hours Midal Cables International Pty Ltd PO Box 322 Raymond Terrace, NSW 2324 Telephone After Hours Definitions PIRMP POEO Act Protection of the Environment Operations Act, 1997 POELA Act Protection of the Environment Legislation Amendment Act, 2011 PSSC ERP SMS Port Stephens Shire Council Emergency Response Plan Safety Management System 4

5 3 What if a Pollution Incident Occurs? A Pollution Incident is an incident that cause or threatens material harm to the environment. (See Section 4). The general description of a Pollution Incident potential on the Midal site can be found in Section 4.8 of the ERP. The Emergency Response and Structure to combat a Pollution Incident is detailed in Figure 5.1 and Figure 6.1 of the ERP. The Emergency Response Procedure ERP-08 Pollution Incident included in Section 9 of the ERP, provides specific response details. A summary of relevant information is detailed below. Pollution Incident Identified Take immediate action to ensure the health and safety of people on the site and protection of the environment (if safe to do so) If the pollution incident presents a risk of material harm to the environment the relevant agencies must be immediately notified (See contact list below: Notify the communications office and the site chief warden of the pollution incident with all relevant information) The Communications Officer or the Site Chief Warden must immediately notify the relevant authorities listed below in the order listed NAME PHONE CONTACT EPA Environment Line Hunter New England Local Health District WorkCover PSSC Fire and Rescue NSW( if not already called) 000 Other authorities may need to be contacted depending on the nature of the incident, such as: REASON COMPANY TO CALL PHONE CONTACT The incident involves electricity Energy Australia The incident involves gas Origin Energy The incident involves water supply or ground water contamination Hunter Water Following notification follow the procedures in the ERP and the specific emergency Response Procedure - Pollution Incident Emergency Procedure ERP Site Contact Details 5

6 Midal Personnel with responsibility under this Plan: Table 1: Site Contact Detail Midal Cables International POSITION Site Chief Warden Communication Officer Site Production Engineer 24 HR CONTACT DETAIL Steve Laney Casey Samuels Ben McDonough RESPONSIBLE FOR ACTIVATING THIS PLAN (Y/N) AUTHORISED TO NOTIFY RELEVANT AUTHORITIES OF POLLUTION INCIDENTS (Y/N) RESPONSIBLE FOR MANAGEING THE RESPONSE TO THE POLLUTION INCIDENT Y Y Y Y Y Y Y Y Y 4 Legal Requirements 4.1 Legislative requirements for the plan The Midal facility operates under the Environment Protection Licence (EPL) in accordance with the Protection of the Environment Operations Act 1997 (POEO Act), all EPL holders are required to prepare and implement a PIRMP for each licenced site. Part 5.7A, section 153A of the POEO Act states: Duty of licence holder to prepare pollution incident response management plan The holder of an environment protection licence must prepare a pollution incident response management plan that complies with this Part in relation to the activity to which the licence relates. The PIRMP must include the information detailed in the POEO Act and content specified in the POEO (General) Regulation and the POELA Act. Offences have been introduced under the legislation for not preparing a PIRMP. Offences are also in place for not keeping the PIRMP at the premises to which relates, not testing the PIRMP in accordance with the Regulation, and not implementing the PIRMP when an incident occurs. 4.2 What is Pollution Incident? In accordance with the POEO Act (Section 153F), if a pollution incident occurs in the course of an activity so that material harm to the environment is caused or threatened, the person carrying on the activity must immediately implement the PIRMP. Pollution Incident is defined in the directory of the POEO Act as: A 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 or set of circumstances involving only the emission of any noise. Material Harm is defined in section 147 of the POEO Act. Material harm includes on-site harm, as well as harm to the environment beyond the premises where the pollution incident occurred Meaning of material harm to the environment (1) For the purposes of this Part: (a) Harm to the environment is material if:

7 (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) For the purposes of this part, it does not matter that harm to the environment is caused only in the premises where the pollution incident occurs. 4.3 Immediate Notification EPL licensees, and anyone carrying on an activity or occupying a premises, who become aware of a pollution incident, are required to report the pollution incident immediately (under section 148 of the POEO Act). The Requirement to notify applies to: All holders of EPL s; and Persons that undertake activities resulting in a pollution incident. 5 Site Overview Midal is located on relatively flat land in Tomago, North West of Newcastle (See Appendix A for a Regional Location Plan). The site contains two major buildings; a casting and rolling line building and a drawing and stranding building. There is also a third building currently being constructed for the purpose of a maintenance workshop. A car park is located at the front of the site facing the site access road (which connects to School Road). The main haul road for the transfer of aluminium is located on the North West corner of the site and connects to the Tomago Aluminium Smelter (See Appendix B for a facility layout) Molten aluminium is transferred from the Tomago Aluminium Smelter via a dedicated haul road, using crucibles of about tonne mass. The crucibles are transferred using dedicated vehicles that transport the crucibles to the Northern end of the casting building where they are lifted from the transfer vehicles using a crane, which then assists in pouring the molten aluminium into the holding furnace (X2) located at the northern end of the building. The holding furnaces maintain the molten metal at a temperature of 750C. Once the metal quality is confirmed, by sample and analysis, it is transferred to the tilting furnace via a launder. Two tilt furnaces are installed, with the capability to transfer from either holding furnace. The tilt furnaces are used to feed molten aluminium to the casting machine. The casting wheel on the casting machine is cooled using water. The molten aluminium is cast into a bar which passes into a rolling mill to produce a rod of approximately 9.5mm diameter. The rod is then fed to an automatic coiler. The coiled rod is stored and either sold directly to customers or used in the manufacture of wires and conductors (See Appendix C for a schematic diagram of the manufacturing process). The aluminium rod coils are transferred to the adjoining building for coiled rod storage. The wire drawing machines are set up using different dies to manufacture the particular wire diameter required for the production run. The rod enters the wire drawing machine and is drawn through the various diesets under tension to reduce its diameter to the required size for the particular production run. 7

8 On completion of the wire drawing operation, wire is fed onto bobbins for storage and for later use in the wire stranding operation. Wire bobbins are placed into carriages on the stranding line which rotate in alternate directions so that wires are stranded together in a close helix. Tension is maintained to ensure a circular and uniform conductor profile. On completion of the stranding operation, the conductor is wound onto drums and stored in the warehouse section. 6 Pollution Incident Notification Protocol 6.1 When is notification required? If a pollution incident occurs that causes or threatens material harm (See Section 4.2) to the environment there is a duty to notify (See Section 4.3). More detail can be found in Section 3 of this document and in ERP-08 Pollution Incident Emergency Procedure included in the ERP. 6.2 Who has a duty to notify? Section 3.1 of this document table 6.1 and ERP-08 of the ERP provide the information required. In summary, under the POEO Act the following have a duty to notify of the Pollution Incident: The persons carrying out the activity (including casuals, shift workers or contractors); An employee or agent carrying out the activity; An employer carrying out the activity, and The occupier of the premises where the incident occurs. Notification must be given immediately after the person becomes aware of the incident (See section 4.3). 6.3 Who do you notify? Firstly, call 000 if the incident presents an immediate threat to human health or property. Fire and Rescue NSW, the NSW Police, and the NSW Ambulance Service are the first responders, as they are responsible for controlling and containing incidents. If the incident does not require an initial combat agency, or once the 000 call has been made, you must immediately notify the Site Chief Warden of the incident and all relevant information about it. More details on Emergency Response and Structure can be found in Section 5 of the ERP and in section 9 of the ERP under ERP-08 Pollution Incident Emergency Response. Relevant authorities to be immediately contacted are included in Section 3 of this document and in section 9 of the ERP under ERP-08 Pollution Incident Emergency Response. Whenever an incident notification is made, all five relevant authorities must be contacted. For example: If you initially rang Fire and Rescue on 000 due to an immediate threat to life and property, you must still contact the other four authorities; or If the incident did not require an initial combat agency, you must still notify all of the response authorities (including Fire and Rescue). If, at the time of making the notification, you believe that some of these authorities do not need to attend the incident, you may provide that advice. However, you must still provide all the information 8

9 you have regarding the incident to each authority. It is the responsibility of each authority to decide whether they need to attend the incident. Where authorities decide not to attend, the incident notification enables each authority to respond to enquiries about the incident and provides them with initial information in the event that the incident escalates or their involvement in managing the incident is required at some later stage. 6.4 What information must you provide? Sufficient detail of the incident must be reported to the EPA to enable appropriate follow-up action. The relevant information required includes: The time, date, nature, duration and location of the incident; The location of the place where the pollution is occurring or is likely to occur; The nature, the estimated quantity or volume and the concentration of any pollutants involved, if known; The circumstances in which the incident occurred (including the cause of the incident, if known); The action or proposed to be taken to deal with the incident and any resulting pollution or threatened pollution, if known. Any information that is not known when the incident is notified must be provided immediately once it becomes known. 6.5 Coordination with authorities In the event of an immediate threat to life and property, the incident will be coordinated by emergency services. In such a case, when external emergency services arrive on site their Senior Combat Agency Officer (usually from the Fire Brigade) will take on the role of Emergency Coordinator. The Site Chief Warden will act under instruction from emergency services and take any action as directed to combat pollution caused by the incident. The Site Chief Warden is the person through whom all communications are to be made to coordinate with authorities. (See figure 6.1 of the ERP). 7 Community Engagement Protocol 7.1 Wider Notification The EPA can formally direct Midal to notify others. This direction will require Midal to contact commercial, industrial and residential neighbours to inform them of the circumstances of the incident and what action is being take in response to it. It will be an offence not to comply with such direction. The EPA may advise Midal of the extent of notification required. If not Midal would determine the extent of who to contact based on the nature of the pollution incident and the conditions at the time (for example, the type of pollutant, prevailing winds, magnitude of incident, and possible impacts). 7.2 Communication Mechanism In the event that the pollution incident is being coordinated by emergency services, communications would be under the control of emergency services. Emergency services are able to send out a SMS messages to defined catchment areas to alert and advise the community if required. Midal would work with emergency services to provide communications assistance and support, including direct doorknocks if they were required. 9

10 If communication is not coordinated by emergency services, notification to the owners or occupiers of premises in the vicinity of Midal facility would be coordinated by Midal s Communication Officer (See figure 6.1 of the ERP) A list of neighbours within the vicinity and their telephone numbers is provided in the ERP in Section 8.2 Midal has a variety of mechanisms available for providing early warning and regular updates to neighbours and the community. The mechanisms to be employed would depend on the nature of the incident and include: Telephone calls and SMS messages to immediate neighbours; Media release to the broader community (radio and television); Incident notification on the Midal website; Doorknocking of affected neighbours and community members. The communication response to be used in the event of a pollution incident would depend on the circumstances of the event, and any direction that may be provided by the EPA. 7.3 Information to be provided In the event of a pollution incident, communication to the community would include specific information to minimise the risk of harm. The information to be provided would be dependent on the nature and circumstances of the event. 8 Site Response This section of the PIRMP provides a summary of the actions that would be taken immediately after a pollution Incident has been notified. More detailed response information is included in the ERP and specifically in section 9 ERP-08 of the ERP. The major actions to be undertaken include: Minimise risk to persons on the Midal premises; Reduce or control the Pollution Incident ( only if it is safe to do so); Deal with the Incident in accordance with the ERP and associated procedures (in particular ERP-08) and this PIRMP. 9 Hazards This section of the PIRMP identifies the main potential hazards to human health or environment associated with activities at the Midal facility. Table 2 identified: The main potential hazards; The likelihood of these hazards occurring; The conditions or events that would or would increase the likelihood of hazards occurring; and Pre-emptive actions. The likelihood of hazards occurring has been reduced through implementation of pre-emptive actions. Pre-emptive actions listed in Table 2 are not exhaustive of all pre-emptive measures taken at the site. 10

11 ( A ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Fire Low Spillages of Molten (hot) Metal Metal explosion Fuel/ lubricant leakage from plant or equipment Equipment failure leading to fires Poor housekeeping Poor Maintenance Electrical fires Regional bushfires Vandalism Dross fires from inappropriate management Pre-emptive Actions Fire protection and control equipment installed on site Detailed procedures associated with handling molten aluminium are in use Liquids excluded from molten metal contact areas Liquid usage areas have dedicated sumps Containment and collection of fuel/lubricant leakages undertaken Equipment maintained preventatively to minimise catastrophic failure routine monitoring of key equipment carried out Housekeeping standards established and audited Facility has an established buffer zone to control access by bushfires Fenced site Dross stored undercover and protected from water intrusion 11

12 ( B ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Oil/Fuel Spillages Low Poor maintenance of equipment Vehicle accidents Spillage during transfer to vehicles/equipment Spillage during delivery Dust Emissions Low Transport generation of dust from unsealed areas External storage of dusty materials Failure of abrasive blasting filter bag house Pre-emptive Actions Regular testing and maintenance of site equipment Vehicle access to site controlled Bunding provided for all fuel /lubricant stored on site Access of vehicles restricted to sealed defined routes Unsealed areas stabilised All/potentially dusty materials appropriately contained or stored internally Bag house/filtration media will be routinely inspected to ensure high collection efficiencies 12

13 ( C ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Chemical Spillages Low Spillage of multiple chemicals resulting in surface/groundwater contamination Vehicle accidents resulting in chemical spillage Illegal disposal of chemical wastes Laboratory spillages Pre-emptive Actions All chemicals used on site will be appropriately contained Vehicles site speed restricted Disposal of waste chemicals on site prohibited appropriate containment and disposal by authorised collectors/facilities required Appropriate spillage control practised in laboratory All chemicals used on site have MSDS - spill control advice will be followed 13

14 ( D ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Contamination of surface/groundwater by on-site waste water treatment system Gas (fuel) emissions to the air environment Low Overloading (Biological/hydraulic) of the wastewater system Distribution system failure resulting in hydraulic overloading Disposal of unapproved liquids into the wastewater system Low Failure of delivery system Failure of combustion system Vandalism Pre-emptive Actions Monitoring of wastewater system will establish the effectiveness of performance Visual inspection of disposal area on a regular basis will identify any sub-standard performance No chemical will be disposed of to wastewater - collections and appropriate/approved disposal is required. This will be confirmed by monitoring Delivery system is monitored by gas supplier failure would result in isolation reducing emission Combustion system is carefully designed/ controlled/ managed to prevent loss of operation resulting in gas emissionsemergency stoppage system available to protect people and equipment Site is secure with 24/7 operation to ensure any intruders are easily identified 14

15 ( E ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Emission of Odours Low Odours of wastewater treatment system Odours from combustion of fuel Odours from dross emissions Pre-emptive Actions Wastewater treatment system is carefully managed and monitored to ensure effective performance Gas is used for heating purposes low in sulphur therefore emissions will not be odourous Dross storage will be limited and undercover to protect from interaction with water resulting in odours 15

16 ( F) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Noise Emissions Low Operational noise emissions Equipment noise emissions due to facility maintenance Catastrophic equipment failure Mobile equipment noise Pre-emptive Actions Plant has been approved and evaluated for noise emissions. Noise limits have been imposed to control noise emissions to acceptable levels Routine maintenance and inspection will identify and control potential equipment failure resulting in noise emissions Catastrophic equipment failure will be minimised by effective maintenance Mobile equipment noise (reversing beeping) will be continuously monitored and minimised Complaints systems will assist in identifying noise issues resulting in control. 16

17 ( G ) Main Hazard Likelihood of Hazards Occurring Conditions or events that could increase the likelihood of the hazard occurring Waste Management Low Mixed waste, storage and collection On-site waste accumulation Pre-emptive Actions Waste streams have been identified and will be collected On-site waste accumulation will not be permitted Waste minimisation will be implemented and practised 17

18 Other general pre-emptive measures include- Midal Cables International Site Security: the site has perimeter security fencing to reduce the risk of damage as a result of break-ins etc. The site is also manned and operates 24/7. Unauthorised access will be quickly identified. Training: site inductions and training are undertaken so people understand appropriate work practices and appropriate actions to prevent hazards occurring. Exercises are periodically conducted to test emergency processes and to understand procedures; and Maintenance: effective systems of planned maintenance, inspection, testing and minor modifications are in place at Midal to reduce associated risks to as low as reasonably practicable. Regular plant and equipment maintenance activities ensure that the plant and equipment retain their standards. Safety critical equipment and procedures identified are maintained, inspected and tested rigorously. The regular plant and equipment maintenance activities are carried out according to the Maintenance Safe Operating Procedures. Hard copies of the SDSs for chemicals or fuels used or stored at the Midal facility (Including safety equipment) are located onsite. 10 Potential Pollutants The list of hazardous goods and other potential pollutants likely to be stored or held onsite, the maximum quantity likely to be stored or, held and the storage location is provided in Appendix C The Location of Potential Pollutants is detailed in a Figure held in Appendix D. 11 Safety Equipment Details of Emergency Exits, Extinguishers and Hose Reels, First Aid Kits and Spill equipment are provided in Section 7 of the ERP. More detailed information can be found in the ERP-01 Fire and Explosion A Safety Data Sheet/Listing is included in Appendix B of the ERP. All Emergency equipment is checked periodically to ensure availability, accessibility and operability. 12 Staff Training Training on the PIRMP will be provided to all personnel working at the Midal Facility (employees and contractors). The objective of the training is to inform all workers of the process to be followed in the event of a pollution incident, the notification protocol and actions to be taken. PIRMP training would initially occur as part of the toolbox talk. All new employees and contractors working at the site would be briefed on the PIRMP as part of their induction and briefing on emergency procedures. Ongoing training would be provided annually at formal training sessions. At the annual training sessions, desktop scenarios would be discussed based on the likely risks and potential incidents that could occur on the site. If a change is made to the PIRMP that impacts on the procedures to be followed in the event of a pollution incident, the update would initially be communicated as part of a toolbox talk. Training record will be filed in hard copy or electronically as per normal procedures. 18

19 13 Testing the Plan To check that the PIRMP works effectively the PIRMP will be tested: Routinely at least once every 12 months; and Within one month of any pollution incident occurring The objective of testing is to assess whether the information included in the PIRMP is accurate and up to date and the PIRMP is capable of being implemented in a workable and effective manner. The routine testing will be a desktop assessment. During the desktop assessment the PIRMP will be reviewed and all components of the plan will be checked: Contact details will be checked to ensure they are up-to-date; Procedures in the PIRMP will be checked to ensure they are workable, and Training competency and feedback will be considered to assess the effectiveness of PIRMP training. Annual PIRMP testing is recorded and records are stored, including; The dates on which the plan has been tested; and The name of the person who carried out the test. Following testing, if the PIRMP is updated, the dates on which the plan is updated will be recorded also. 14 Plan Availability 14.1 Onsite PIRMP availability A copy of this PIRMP well be kept at the site and will be readily available to any person who is responsible for implementing the plan. In accordance with the POEO Regulation, a copy of the PIRMP will be made readily available to an authorised EPA officer on request Public Availability The PIRMP is publicly available on the Midal website. 19

20 APPENDIX A REGIONAL LOCATION PLAN Midal Cables Location 20

21 APPENDIX B FACILITY LAYOUT 21

22 APPENDIX C SCHEMATIC DIAGRAM OF CONDUCTOR MANUFACTURING PROCESS 22

23 APPENDIX D LIST AND LOCATION OF POTENTIAL POLLUTANTS POTENTIAL POLLUTANT QUANTITY STORAGE AREA DESCRIPTION OF HAZARD Lubricating oil 5000 litres Shipping containers (outside Building 1) Fire hazard Diesel Fuel 1000 litres Western side of Building 2 Fire hazard, explosive, exhaust fumes, poisonous when spilled or leaked outdoors Paint 250 litres Eastern side Building 2 Fire and explosion hazard Emulsion litres Underneath Building 1 floor Groundwater contamination if there is a leak in the tank Sodium Silicate 1000 litres Building 1 High ph levels in product is harmful to aquatic life if released into surface water. Coolant 205 litres Shipping container Fire hazard Dross Building 1 Highly flammable if it makes contact with water, emission of toxic chemicals and gasses Oxygen 20 Building 2 Fire hazard Acetylene 5 Building 2 Highly explosive Nitrogen 20 Eastern side Building 2, Western side building 1 Explosive if heated, asphyxiant in high concentrations Argon 5 Building 2 Explosive if heated LPG 15 Building 1 Highly flammable, may explode if heated Hydrochloric Acid 2 litre Lab (Building 2) Decomposes on heating emitting toxic fumes, container may also explode when heated Sulphuric Acid 2 litres Lab (Building 2) Decomposes on heating emitting toxic fumes, including those of oxides and sulphur Nitric Acid 2 Litres Lab (Building 2) Fire hazard, toxic to aquatic organisms and flora/ fauna/ soil organisms/ bees Contact adhesive 20 litre Lab (Building 2) Irritant to eyes, skin and respiratory system 23