Construction Air Quality Management Plan

Transcription

1 Construction Air Quality Plan Document Number Project: M4 East Design and Construct Contract Number: Document Number: Revision Date: 6 December 2017 Document Approval Rev Date Prepared by Reviewed by Approved by Remarks A 23/11/2015 CSJ SMC DP&E Submitted to WCXM4 Co. to satisfy SWTC App. C.1 4(d) requirement B 7/12/2015 CSJ Agencies Final draft for agency consultation 0 23/02/2016 CSJ DP&E Submission to DP&E 1 18/03/2016 CSJ DP&E DP&E subject to minor update Revised to address DP&E comments 2 23/03/2016 CSJ Update to address final DP&E comments 3 21/12/2016 CSJ Ryan Franklin ER Minor editorial updates 4 06/12/2017 CSJ Ryan Franklin Don Johnson Minor editorial updates

2 Table of Contents Glossary of terms Introduction Context Environmental management system overview Objectives and targets Training Consultation on this plan Legal and other requirements Legislation Guidelines and relevant documents Conditions of Approval Revised environmental management measures Environment protection licence Roads and Maritime Specification D&C G Sustainability requirements Environmental aspects and impacts Existing environment Meteorology Soil Landscapes Aspects and impacts Construction activities Key construction locations Construction impacts Factors likely to affect construction air quality impacts Sensitive receivers Consolidated environmental safeguards Review and improvement TABLES 5.1 Monitoring and reporting Auditing Non-conformance management, corrective and preventative action Complaints Revision of this plan Table 1: Proposed project targets and Key Performance Indicators (KPIs) associated with the management of air quality... 8 Table 2: Conditions of Approval that address management of air quality Table 3: Revised environmental management measures relevant to the management of air quality Table 4: EPL requirements relevant to the management of air quality Table 5: RMS Specification D&C G36 requirements relevant to the management of air quality Table 6 Soils and geology across the project footprint Project M4 East Design and Construct Page 2 of 35

3 Table 7 Key construction locations Table 8: Project controls associated with management of air quality Table 9: Monitoring requirements relevant to management of air quality FIGURES Figure 1: M4 East CEMP Framework... 7 Figure 2: Annual and seasonal wind roses for Canterbury Racecourse AWS (2014) ANNEXURES Annexure A Air quality management and monitoring procedure Project M4 East Design and Construct Page 3 of 35

4 Glossary of terms Term / acronym Asset Trustee AQMP AWS BoM CEMP CoA Construction Area Construction Area Plan (CAP) CSJ D&C Deed DP&E ECM EIS Definition The Asset Trustee has been engaged by Roads and Maritime Services to deliver the M4 East project that is part of the WestConnex Project that is being delivered by Sydney Motorway Corporation. The Asset Trustee has in turn, engaged the Contractor, CSJ to design and construct the M4 East project Air Quality Plan (this plan) Automatic Weather Station Bureau of Meteorology Construction Environmental Plan Minister s Conditions of Approval A separable portion of work that is identified early in construction planning to help drive early definition of construction methodology and alignment of design activities. Work Areas should be listed in the overall construction methodology. The planning document for a work area is called a Construction Area Plan The main document prepared during the construction planning for that work area. Includes construction methodology, risk assessment, constructability reviews and Work Pack listing CPB Contractors Samsung John Holland joint venture; a consortium comprising CPB Contractors, Samsung C&T Corporation and John Holland CSJ has been engaged by the Asset Trustee to design and construct the M4 East Project. Design and Construct As appropriate to the defined scope of the WestConnex M4 East D&C Deed NSW Department of Planning and Environment Environmental Constraints Map M4 East Environmental Impact Statement EP&A Act Environmental Planning and Assessment Act 1979 EPA EPL ER EWMS Infrastructure Approval NEPC NEPM PM10 NSW Environment Protection Authority Environment protection licence Environmental Representative Environmental Work Method Statements Approval under the Environmental Planning & Assessment Act 1979 for SSI-6307 signed by the Minister for Planning on 11 February National Environment Protection Council National Environment Protection Measure Particulate matter 10 micrometres or less in diameter Project M4 East Design and Construct Page 4 of 35

5 Term / acronym PMP Definition CSJ Project Plan POEO Act Protection of the Environment Operations Act 1997 POEO (Clean Air) Regulation 2010 Project REMM Roads and Maritime, RMS Roads and Maritime Specification D&C G36 Site Environmental Plan (SEP) WCX Work Pack (WP) Protection of the Environment Operations (Clean Air) Regulation 2010 WestConnex M4 East Project, SSI-6307 Revised environmental management measure (from the M4 East Submissions Report) Roads and Maritime Services Roads and Maritime has engaged the Asset Trustee to deliver the M4 East project. Roads and Maritime Services Specification Design & Construct G36 Environmental Protection A3 plans that provide a visual display (on a GIS aerial map) of environmental constraints, physical protection measures and other key management measures to minimise impacts from construction activities on the environment and community. Erosion and sediment controls measures will also be displayed on the SEP. The reverse side of the A3 plan identifies key controls specific to the construction area. WestConnex A pack of relevant construction documents that contains relevant information for Site Engineers and foremen to manage the works. There will be multiple Work Packs contained in a CAP. A Work Pack contains work method statements, risk assessments, ITPs, drawings, site instructions, environmental controls, etc. Project M4 East Design and Construct Page 5 of 35

6 1 Introduction 1.1 Context This Construction Air Quality Plan (AQMP) forms part of the Construction Environmental Plan (CEMP) developed for the construction of the WestConnex M4 East Project (the project). The AQMP describes how the CPB Samsung John Holland Joint Venture (CSJ) will manage air quality and minimise impacts during construction of the project. The project is a component of the WestConnex scheme, a NSW Government initiative to connect Sydney s west and south-west with the Sydney Airport and the Port Botany precinct. The Proponent for the project is Roads and Maritime Services (Roads and Maritime) and the Asset Trustee is delivering the project. Asset Trustee has engaged CSJ (the Contractor) to design and construct the project. The project includes the widening of the existing M4 between Homebush Bay Drive and Underwood Road. Two new three-lane tunnels of approximately 5.5 km will extend from west of Pomeroy Street, Homebush to Alt Street at Haberfield. Interchanges or ramps will be upgraded or installed to allow access to/from the tunnel at the following locations: Homebush Bay Drive, Concord Road, Wattle Street and Parramatta Road at Ashfield/Haberfield. Tunnel ventilation facilities will be installed within the existing M4 road reserve near Underwood Road at Homebush, and at the corner of Parramatta Road and Wattle Street at Haberfield. A fresh air supply facility and operational ancillary facilities will be installed at Cintra Park. Associated road works, particularly at Parramatta Road to the M4 at Powells Creek and modification of the intersection of the existing M4 and Parramatta Road will also be undertaken as part of the works. Thirteen temporary construction compounds along the route will facilitate the construction of the project. A detailed project description is included in Section 2.1 of the CEMP. On 5 December 2014, the project was declared by the Minister for Planning to be State significant infrastructure (SSI) and critical State significant infrastructure (critical SSI), under sections 115U(4) and 115V of the Environmental Planning and Assessment Act 1979 (EP&A Act) and clause 16 of the State Environmental Planning Policy (State and Regional Development) An environmental impact statement (EIS) (AECOM GHD 2015) was prepared and placed on public exhibition from 9 September to 2 November Submissions were received from government, agencies, organisations and the public in repose to the project. A Submissions Report was prepared in response to submissions received during the exhibition period and finalised in December The project was approved on 11 February 2016, subject to the Minister s Conditions of Approval (CoA). This AQMP has been prepared to address applicable legislation, the relevant CoA, particularly CoA D57(e) and the revised environmental management measures (REMMs) listed in the M4 East Submissions Report. 1.2 Environmental management system overview The overall environmental management system (EMS) for the project is described in the Construction Environmental Plan (CEMP). This AQMP is part of the environmental management framework for the project, as described in Section 4 of the CEMP. Figure 1 shows the CEMP framework for the project. Refer to Section 4.1 of the CEMP for an overview of the M4 East project management plan (PMP) framework. measures identified in this plan will be incorporated into the management of environmental impacts through a variety of measures including, but not limited to, site or activity specific environmental work method statements (EWMS), the relevant construction area plan (CAP) or work pack (WP), site environmental plans (SEPs) or training and awareness activities. Where each management measure is best captured is identified in Table 8. Project M4 East Design and Construct Page 6 of 35

7 Key: Main document CEMP sub-plan Sub-plan attachment This plan Indirect relationship Sub-plan associated document Construction Environmental Plan Construction Noise and Vibration Plan Construction Traffic and Access Plan Land Use Survey Out of Hours Works Protocol Blast Strategy Provisional spoil haulage routes Spoil Plan Construction Soil and Water Plan x Construction Heritage Plan Construction Flora and Fauna Plan Construction Air Quality Plan Construction Waste and Resource Plan Water Quality Monitoring Program Contaminated Land Plan Acid Sulfate Soils Plan Flood Mitigation Strategy Heritage management procedure Historical Archaeological Research Design Unexpected heritage items procedure Vegetation clearing procedure Fauna spotter and catcher procedure Unexpected species finds procedure Weed management procedure Air quality management and monitoring procedure Waste and resource management procedure Figure 1: M4 East CEMP Framework 1.3 Objectives and targets The key objectives of the AQMP are to prevent visible emissions of dust from the site and to ensure that impacts to air quality are minimised and within the scope permitted by the Infrastructure Approval. To achieve these objectives, the targets in Table 1 have been proposed by CSJ for the management of air quality impacts during construction. Project M4 East Design and Construct Page 7 of 35

8 Table 1: Proposed project targets and Key Performance Indicators (KPIs) associated with the management of air quality Metric / measure Target Timeframe Accountability Documentation / reporting Visible dust emissions Spillage or tracking on public roads Visible dust responded to immediately Spillage or trackage to be removed within 24 hours At all times Site Supervisor Environmental inspection checklist Site Supervisor s daily diary (or equivalent) At all times Site Supervisor Environmental inspection checklist Site Supervisor s daily diary (or equivalent) Non-compliant monitoring results that can be directly attributed to construction activities. Criteria from the Approved Methods for Modelling and Assessment of Air Pollutants in New South Wales (Department of Environment and Conservation 2005) include: Zero non-compliant monitoring results At all times Construction Project Managers Monitoring results Maximum annual increase in deposited dust level of 2g/m 2 /month Maximum total deposited dust level of 4g/m 2 /month (maximum annual and total levels applies to annual average period). Meet the CoA, REMM and EPL conditions relevant to air quality Compliance with all CoA, REMM and EPL conditions relevant to air quality At all times Site Supervisor Environment and Sustainability Manager Environmental inspection checklist Quarterly Construction Compliance Report 1.4 Training All personnel, including employees, contractors and sub-contractors, are required to complete a project induction containing relevant environmental information before they are authorised to work on the project. Air quality specific information to be covered in the project induction will include: Obligations under the project Conditions of Approval (including the AQMP), including the identification of potential sources of air pollutants of concern and the mitigation measures to be implemented, including measures (e.g. use of water, cover exposed areas) during weather conditions where high levels of dust are probable; Responsibilities pertaining to the management of air quality under the Protection of the Environment Operations Act 1997 and Protection of the Environment Operations (Clean Air) Regulation 2010; Typical construction activities that may impact air quality and associated environmental safeguards; and Incident response procedures. Project M4 East Design and Construct Page 8 of 35

9 Project training is identified, implemented and recorded in accordance with Section 5 of the CEMP. CSJ will provide information (e.g. project inductions, toolbox talks on appropriate environmental risks or management measures) so that project personnel can competently perform their duties and meet environmental obligations. Records of all training activities, including inductions, will be maintained. Records will include the name and role of the attendee, the name of the course and, where applicable, reference to the document controlled version of the material presented, and a copy of the assessment completed. 1.5 Consultation on this plan This AQMP has been provided to relevant stakeholders including NSW Environment Protection Agency (EPA) and relevant councils. Consultation requirements are described in Table 3 of the CEMP. Following closure of the scheduled review period, no comments were received from the EPA or Councils on the AQMP. A separate document Consultation for the M4 East CEMP and sub-plans has been prepared to document the consultation process and was provided to the Department of Planning and Environment as evidence of consultation on the management plans. Project M4 East Design and Construct Page 9 of 35

10 2 Legal and other requirements This section provides the relevant legislation and project requirements that apply to air quality aspects of construction. 2.1 Legislation Legislation relevant to air quality management for the Project includes: Environmental Planning and Assessment Act 1979 (EP&A Act); Protection of the Environment Operations Act, 1997 (POEO Act); and Protection of the Environment Operations (Clean Air) Regulation 2010 (POEO (Clean Air) Regulation 2010). Relevant provisions of the above legislation are explained in the register of legal and other requirements included in Annexure B Environmental obligations register of the CEMP. 2.2 Guidelines and relevant documents The main guidelines, specification and policy documents relevant to this AQMP include: Roads and Maritime Services Specification Design & Construct G36 Environmental Protection (Roads and Maritime Specification D&C G36) (06 August 2014); National Environment Protection Council s (NEPC) National Environment Protection Measure (NEPM) for Ambient Air Quality Guidelines; NSW EPA Local Government Air Quality Toolkit, Visual Guide: Dust from urban construction sites; AS/NZS :2007 Methods for sampling and analysis of ambient air Guide to siting air monitoring equipment OR AS Ambient Air Guide for the siting of sampling equipment; AS/NZS :2003 Methods for sampling and analysis of ambient air Determination of particulate matter deposited matter gravimetric method; Approved methods for the Sampling and Analysis of Air Pollutants in New South Wales (NSW DEC, 2006); Approved Methods for the Modelling and Assessment of Air Pollutants in NSW (NSW DEC, 2005); and Guidance on the assessment of dust from demolition and construction (IAQM 2014). This provides guidance on how to assess the sensitivity of receptors and the risk of impact on those receptors due to the various components of the project construction. 2.3 Conditions of Approval Conditions of Approval (CoA) have been issued by the Department of Planning and Environment (DP&E) for the M4 East project. CoA that relate to air quality management are provided in Table 2. A cross reference is included to indicate where each condition is addressed in this AQMP or other project management documents. Project M4 East Design and Construct Page 10 of 35

11 Table 2: Conditions of Approval that address management of air quality No. Condition of Approval Reference A15 A16 A17 The Proponent must notify the EPA in relation to any pollution incident in carrying out the SSI as required by the Protection of the Environment Operations Act The Proponent must provide the Secretary with a record of any such notification. The Proponent must notify the Secretary (using the contact name and phone number notified by the Department from time to time) of any incident (other than those relating to the Protection of the Environment Operations Act 1997) with actual, or potential, significant off-site impacts on people or the biophysical environment immediately of becoming aware of the incident on weekdays, or the following business day on weekends, public holidays and site shutdown. The Proponent must provide full written details of the incident to the Secretary within seven days of the date on which the incident occurred. The Proponent must meet the requirements of the Secretary or relevant public authority (as determined by the Secretary) to address the cause or impact of any incident, as it relates to this approval. Incident management, including notification of the EPA is summarised in Section 7 of the CEMP Incident management, including notification of the Secretary, is summarised in Section 7 of the CEMP As part of any incident investigations, CSJ will meet the requirements of the Secretary or relevant public authority to address the cause or impact of any incident. This is addressed in Section 7 of the CEMP. C4. Prior to the commencement of construction, or as otherwise agreed by the Secretary, the Proponent must prepare and implement a Construction Complaints System consistent with AS/NZS 10002:2014 Guidelines for Complaint in Organisations and maintain the Construction Complaints System for the duration of construction and up to 12 months following completion of construction of the SSI. Information on all complaints received, including the means by which they were addressed and whether resolution was reached, with or without mediation, must be maintained in a complaints register and included in the construction compliance reports required by this approval. The information contained within the Construction Complaints System must be made available to the Secretary on request. D57. e A Construction Air Quality Plan to detail how construction impacts on local air quality will be minimised and managed. The Construction Air Quality Plan must include, but not be limited to: The Construction Complaints System (described in the Community Communication Strategy) addresses this condition. Section 4 AQL10 This plan, Annexure B i identification of sources (including stockpiles and open work areas) and quantification of airborne pollutants; Section 3.2.1, and ii key performance indicators for local air quality during construction; Section 1.3 iii iv v vi vii details of monitoring methods, including location, frequency and duration of monitoring; mitigation measures to minimise impacts on local air quality; including but not limited to, the relevant revised environmental mitigation measures set out in the documents listed in condition A2(c). procedures for record keeping and reporting against key performance indicators; provisions for implementation of additional mitigation measures in response to issues identified during monitoring and reporting; and mechanisms for the monitoring, review and amendment of the Construction Air Quality Plan. Section 5.1, Table 9 Section 4 Annexure A Section 1.3 Section 5 Section 5.3 Section 5.5 Project M4 East Design and Construct Page 11 of 35

12 2.4 Revised environmental management measures The revised environmental management measures (REMMs) included in the M4 East Submissions Report relating to the management of air quality are included in Table 3. Table 3: Revised environmental management measures relevant to the management of air quality No Revised environmental management measure Reference Communication AQ1 AQ2 AQ3 AQ4 Develop and implement a Construction Air Quality Plan which requires consultation with NSW EPA. Any measures that are required will differ depending on the activities occurring, and so will need to be tailored for each individual site. Carry out regular site inspections to monitor compliance with the Construction Air Quality Plan, record inspection results. Develop and implement a community communication strategy (or equivalent plan) that includes community engagement before work commences on site. Display the name and contact details of person(s) accountable for air quality and dust issues at the boundaries of each construction area. This may be the project hotline, environment manager/engineer or the site manager. This Plan Section 5.1 Community Communication Strategy Section 4 AQL8 Community Communication Strategy Section 4 AQL9 Dust management AQ5 AQ6 AQ7 AQ8 AQ9 AQ10 Plan site layout so that machinery and dust causing activities are located away from receptors, as far as is possible. Ensure where reasonable and feasible appropriate control methods are implemented to minimise dust emissions from the project site. Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site. If they are being re-used on-site cover as soon as practicable. Impose and signpost a maximum-speed-limit of 20 km/h on surfaced and unsurfaced haul roads and in work areas. Where practicable, only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction (e.g. suitable local exhaust ventilation systems). Ensure an adequate water supply on the site for effective dust/particulate matter suppression/mitigation, using non-potable water where possible and appropriate. Section 4 AQL2 Annexure A Section 4 Section 4 AQL12 Section 4 AQL29 Section 4 AQL26 Section 4 AQL13 AQ11 Where possible, use enclosed chutes and conveyors and covered skips. Section 4 AQL27 AQ12 AQ13 Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays on such equipment wherever appropriate. Ensure equipment is readily available on site to clean any dry spillages, and clean up spillages as soon as reasonably practicable after the event using appropriate cleaning methods. Section 4 AQL28 Section 4 AQL14 AQ14 Avoid scabbling (roughening of concrete surfaces) if possible. Section 4 AQL15 Project M4 East Design and Construct Page 12 of 35

13 No Revised environmental management measure Reference Stockpile management AQ15 AQ16 AQ17 AQ18 Stockpiles would be located outside overland flowpaths, and where left exposed and undisturbed for longer than 28 days, would be finished and contoured to minimise loss of material in flood or rainfall events. Materials which require stockpiling and are undisturbed for longer than 28 days would be stabilised by compaction, covering with anchored fabrics, or seeded with sterile grass where appropriate. Where a stockpile, e.g. sand or fine aggregate, has the potential to generate dust, control measures would be implemented. These would include wetting the stockpile, covering the stockpile or contouring the stockpile. Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery. For smaller supplies of fine powder materials ensure bags are sealed after use and stored appropriately to prevent dust. Section 4 AQL17 Section 4 AQL18 Section 4 AQL30 Section 4 AQL31 Tracking of material on roads AQ19 Use water-assisted dust sweeper(s) on the access and local roads, to remove, as necessary, any material tracked out of the site. Section 4 AQL32 AQ20 Avoid dry sweeping of large areas. Section 4 AQL16 AQ21 AQ22 AQ23 AQ24 AQ25 AQ26 Ensure vehicles carrying materials or spoil entering and leaving sites are covered to prevent escape of materials during transport. Inspect on-site haul routes for integrity and instigate necessary repairs to the surface as soon as reasonably practicable. Record all inspections of haul routes and any subsequent action in a site inspection checklist. Where reasonable and feasible, haul roads will be maintained with water carts and graders, and the condition of the roads will be monitored. Implement site exit controls (e.g. wheel washing system and rumble grids) to dislodge accumulated dust and mud prior to leaving the site where reasonably practicable. Ensure there is an adequate area of hard surfaced road between the wheel wash facility and the site exit, wherever site size and layout permits. Section 4 AQL33 Section 5.1 Section 5.1 Section 4 AQL34 Section 4 AQL35 Section 4 AQL36 AQ27 Access gates to be located at least 10 m from receptors where possible. Section 4 AQL36 Emissions management AQ28 Ensure all construction vehicles comply with their relevant emission standards. Section 4 AQL38 AQ29 Ensure that, where practicable engines idling is minimised when stationary. Section 4 AQL39 AQ30 AQ31 Avoid the use of diesel or petrol powered generators and use mains electricity or battery powered equipment where practicable. Promote and encourage sustainable travel (public transport, cycling, walking, and carsharing). Section 4 AQL40 Section 4 AQL41 AQ32 No bonfires and burning of waste materials Section 4 AQL42 Project M4 East Design and Construct Page 13 of 35

14 No Revised environmental management measure Reference Demolition AQ33 AQ34 AQ35 AQ36 Soft strip inside buildings before demolition (retaining walls and windows in the rest of the building where possible, to provide a screen against dust). Ensure effective water suppression is used during demolition operations. Hand held sprays are more effective than hoses attached to equipment as the water can be directed to where it is needed. In addition high volume water suppression systems, manually controlled, can produce fine water droplets that effectively bring the dust particles to the ground and may be more useful for covering larger areas. No explosive blasting during demolition. Appropriate manual or mechanical alternatives will be used. Bag and remove any biological debris or other hazardous materials such as asbestos, damp down such material before demolition. Section 4 AQL22 Section 4 AQL23 Section 4 AQL24 Section 4 AQL25 Earthworks AQ37 AQ38 AQ39 Re-vegetate earthworks and exposed areas/soil stockpiles to stabilise surfaces as soon as practicable. Use hessian, mulches or tackifiers where it is not possible to re-vegetate or cover with topsoil, as soon as practicable. Where possible, only remove any cover for exposed areas in small areas during work and not all at once. Section 4 AQL19 Section 4 AQL20 Section 4 AQL21 Cumulative impacts AQ40 AQ41 Regular communication with other high risk construction ancillary facilities within 500m of the site boundary, to ensure plans are co-ordinated and dust and particulate matter emissions are minimised. It is important to understand the interactions of the off-site transport/deliveries which might be using the same strategic road network routes. Undertake regular on-site and off-site inspection, where receptors are nearby, to monitor dust, record inspection results. Section 4 AQL1 Section 5.1 Complaints management AQ42 Record all dust and air quality complaints, identify cause(s), take appropriate measures to reduce emissions in a timely manner, and record the measures taken. Construction Complaints System (Community Communication Strategy) Section 4 AQL10 AQ43 Make complaints available to the Secretary upon request. Construction Complaints System Section 4 AQL10 AQ44 Record any exceptional incidents that cause dust and/or air emissions, either on- or offsite, and the action taken to resolve the situation. Section 4 AQL7 Project M4 East Design and Construct Page 14 of 35

15 No Revised environmental management measure Reference Monitoring AQ45 Ambient air quality will be monitored continuously for at least twelve months prior to project opening, during construction and for at least two years after project opening. Monitoring results will be made publicly available and will be subject to an independent audit. Section 5.1 The following REMMs will also assist in the management of air quality during construction and will be implemented by way of the management documents referenced. Soil and water management SW6 Measures will be implemented to minimise the risk of erosion and sedimentation. These measures may include: Soil and Water Plan Disturbed areas will be minimised and revegetated or stabilised as soon as practical. Erosion control measures such as sediment fences, check dams, temporary ground stabilising, diversion berm or site regrading will be installed as appropriate. Where practical, clean water will be diverted away from works or disturbed areas. Measures will be employed to control ground stability and limit run-off lengths and velocities within the construction ancillary facilities. Wheel wash or rumble grid systems will be installed, where practical, at compound heavy vehicle exit points to minimise the transfer of soil from construction areas to roadways. Erosion and sedimentation controls will be regularly inspected to maintain performance to the design criteria and design specifications. Controls are to be upgraded or altered if these objectives are found to not be satisfied. SW8 Measures will be implemented to manage stockpiles. These measures may include: Stockpiles will to be located outside of overland flowpaths, riparian corridors and finished and contoured so as to minimise loss of material in flood or rainfall events. Stockpiles left exposed and undisturbed for longer than 28 days will be stabilised by compaction then either: Sprayed with suitable tackifier Covering with anchored fabrics Seeded with sterile grass. Soil and Water Plan SW9 Measures will be implemented to minimise the risk of spills. These measures may include: Spill containment will be included at locations where there is direct discharge of stormwater to receiving waterways. Appropriately bunded areas will be provided for storage of hazardous materials such as oils, chemicals and fuels. Adequate controls around stockpile areas and excavation works will be installed to minimise the risk of contaminants being washed into waterways or stormwater systems. Maintenance of containment/spill infrastructure and clean-up procedures for on-site spills will be undertaken. Spilt materials and/or any contaminated materials will be disposed of appropriately. Soil and Water Plan Contamination management C3. Further site investigations will be undertaken to assess the level and extent of asbestos in publicly accessible areas beside the M4 in Section 1 of the project footprint. Contaminated Land Plan (Annexure B to the Soil and Water Plan) Project M4 East Design and Construct Page 15 of 35

16 No Revised environmental management measure Reference Greenhouse gas management GHG1 Prepare an Energy Efficiency and GHG Emissions Strategy for the project. The Energy Efficiency and GHG Strategy will form Annexure C of the Delivery Phase Sustainability Plan, which are both under development GHG2 GHG3 GHG4 GHG5 GHG6 GHG7 GHG8 GHG9 GHG12 Undertake an updated GHG assessment (Scope 1 and Scope 2) based on detailed design. The emissions intensity of significant construction materials specified in the design of the project will be assessed and, where feasible and in compliance with technical specifications, purchasing power would be used to drive the procurement and use of low emission construction materials. Where feasible, recycled content road construction materials such as recycled aggregates in road pavement and surfacing, or similar, will be used. The fuel efficiency of construction plant and equipment will be assessed before selection and, where feasible and reasonable, equipment with the highest fuel efficiency or equipment that uses lower GHG intensive fuel such as biofuels (eg biodiesel, ethanol) will be used. Project planning will be undertaken to ensure that the site vehicle movements and construction activities are efficient, to avoid double handling of materials and unnecessary fuel use where possible. Locally produced goods and services will be procured where feasible and where cost effective and meeting the project design and specifications, to reduce transport fuel emissions. A minimum of six per cent of the project s estimated electricity consumption will be sourced from a renewable energy source or GreenPower, where reasonable and feasible. Waste will be diverted from landfill, including diversion of spoil, construction and demolition waste, and commercial and industrial waste, where reasonable and feasible. Low carbon energy generation options will be investigated as part of the design process in order to reduce the demand on mains electricity and generate renewable energy onsite, where feasible. Delivery Phase Sustainability Plan Energy Efficiency and GHG Strategy Delivery Phase Sustainability Plan Delivery Phase Sustainability Plan Energy Efficiency and GHG Strategy Traffic and Access Plan Delivery Phase Sustainability Plan Delivery Phase Sustainability Plan Energy Efficiency and GHG Strategy Delivery Phase Sustainability Plan Energy Efficiency and GHG Strategy 2.5 Environment protection licence The M4 East construction activities will be regulated by an environment protection licence (EPL) issued by the EPA. EPL conditions relevant to the management of air quality are provided in Table 4. Project M4 East Design and Construct Page 16 of 35

17 Table 4: EPL requirements relevant to the management of air quality Ref. Relevant Requirement Reference O3 Dust O3.1 The licensee must ensure that construction work is carried on by such practicable means as may be necessary to minimise dust emissions on the premises, and implement all feasible and reasonable mitigation measures to minimise the release of dust from the premises. This plan, in particular: Section 4, Section 5.1, Annexure A O4 Processes and management O4.7 The licensee must endeavour to maximise the reuse of captured stormwater on the premises. Section 4 AQL Roads and Maritime Specification D&C G36 Roads and Maritime Specification D&C G36 identifies environmental safeguards and management measures or conditions of planning consent for the Project that must be satisfied. Requirements specific to the management of air quality are identified in Table 5. Table 5: RMS Specification D&C G36 requirements relevant to the management of air quality G36 No. Relevant requirements Reference 4.4 Prepare and implement an Air Quality Sub-Plan as part of the CEMP, or include mitigation strategies within the CEMP, to minimise the impact of dust, offensive odour, and other air pollutants on the surrounding environment, including adjacent properties and sensitive places. 4.4 Comply with the requirements of the POEO Act and any conditions of licences, notifications, approvals or permits in relation to maximum air pollutant levels. 4.4 Plan and carry out all your construction activities to avoid where practicable, or minimise, the generation of dust and vehicle emissions. Include in the Air Quality Sub-Plan or mitigation strategies the procedures for effective dust control, including dust monitoring and reporting procedures. 4.4 Where air quality monitoring is required, it must comply with the EPA publication Approved Methods for Sampling and Analysis of Air Pollutants in NSW. Monitoring data must include reporting of insoluble solids in accordance with the EPA publication Approved Methods for the Modelling and Assessment of Air Pollutants in NSW. This plan, Section 4 Section 4 Section 3 Section 4 Annexure A Section Sustainability requirements The Sustainability Plan provides the IS credits targeted for the project and the associated sustainability initiatives. The targets and strategies relevant to this plan include: Targets and IS target credits for air quality and the strategies to be implemented to achieve these (Element 6). CSJ will conduct regular monitoring in accordance with Section 5 of this plan, to ensure no recurring exceedance of air quality goals occurs. The project will ensure any exceedances are managed and opportunities for improvement implemented to minimise recurring or major exceedance of air quality goals. Non-conformity, correction and preventative actions are described in Section 5.3 of this AQMP and Section 8.6 of the CEMP. Project M4 East Design and Construct Page 17 of 35

18 3 Environmental aspects and impacts 3.1 Existing environment Meteorology Wind Annual and seasonal wind data from several meteorological stations was used in the EIS to analyse the general wind patterns across the project. The meteorological data for these stations showed very similar wind patterns during the last six years at each individual site, with wind patterns being predominantly from the northwest and southeast directions. Based on the analysis of the available meteorological data from the stations, data from the Bureau of Meteorology (BoM) Canterbury Racecourse Automatic Weather Station (AWS) (Station No ) was chosen as the input for modelling in the EIS. The station was considered to be the most representative of the project s meteorology (refer Figure 2). The assessment methodology used in the EIS was a risk-based approach recommended by the United Kingdom Institute of Air Quality (IAQM, 2014). This methodology takes account of the meteorological conditions (wind speed, direction and rainfall). The air quality assessment noted that many of construction activities at the construction sites would be transitory and the majority of the construction footprint would be underground. However the air quality assessment acknowledged that surface works would be required to support tunnelling activities and to construct surface infrastructure such as interchanges, tunnel portals, ventilation facilities, ancillary operations buildings and facilities, and the eastbound cycleway near the Homebush Bay Drive interchange. In the western and central areas of the project, the nearest sensitive receptors are located along Parramatta Road north and south of the designated construction area. At the eastern end of the project as Parramatta Road turns towards the southeast, receptors are towards the east and west of Parramatta Road as well as along Wattle Street to the northeast. Following a review of the annual and seasonal wind data, the EIS established that winds could be capable of transporting dust emissions towards sensitive receptors in the immediate vicinity of the construction zone, and that these sensitive receptors may experience some occasional dust impacts. In view of the transitional nature of the prevailing winds with respect to the sensitive receptors, this could occur at any time of year. However, the EIS qualifies this statement by asserting that this does not imply that dust impacts are likely, or that if they did occur, that they would be frequent or persistent and that overall construction dust is unlikely to represent a serious ongoing problem. Project M4 East Design and Construct Page 18 of 35

19 Figure 2: Annual and seasonal wind roses for Canterbury Racecourse AWS (2014) Rainfall The EIS concludes that any impacts would be temporary, relatively short-lived and would only arise during dry weather with the wind blowing towards a receptor, at a time when dust is being generated and mitigation measures are not being fully effective. Rainfall data at Sydney Olympic Park indicates that February is the wettest month with an average rainfall of 110 mm over an average of eight rain days. The annual average rainfall at this location is 884mm over an average of 82 rain days per year. Rainfall data from the Canterbury site shows the wettest month on average occurring in April, with 113mm falling over eight rain days. The average annual rainfall at this location is slightly higher at 928mm over an average of 85 rain days per year Temperature The annual average maximum and minimum temperatures recorded at the Sydney Olympic Park station are C and C, respectively. At Canterbury Racecourse these are C and C, respectively. On average January is the hottest month, with average temperatures of C and C at Olympic and Project M4 East Design and Construct Page 19 of 35

20 Canterbury, respectively. July is the coldest month at both stations, with average temperatures of C and C, respectively Soil Landscapes Soil landscapes across the project alignment were described by Chapman and Murphy (1989), and are described in GHD (2015a). Soil landscapes within the project alignment are detailed in Table 6. The majority of the project occurs within the Blacktown Soil Landscape. All soils in the natural environment across the project are considered to be highly erodible and therefore have a significant potential for dust to be blown offsite. Table 6 Soils and geology across the project footprint. Soil landscape name Approximate percentage of the alignment Description Blacktown 85% Gymea 7% Birrong 1% Red and brown duplex soils formed from residual weathering of Wianamatta Group shales. Gently undulating topography, broad relief and slopes generally less than 5%. Soil limitations include reactivity (shrink/swell), plastic subsoils, low fertility, strong acidity, localised sodicity (dispersion), very high erodibility and poor drainage. Localised salinity occurs in western Sydney. Shallow Yellow Earths and Earthy Sands formed from erosional weathering of Hawkesbury Sandstone. Undulating to rolling rises and hills with slopes 10 to 25%. Occasional rock outcrop or shallow bedrock. Soil limitations include high erosion hazard, low fertility, high permeability, low waterholding capacity, strong acidity. Salinity is not recorded on this Soil Landscape. Yellow duplex soils on narrow alluvial infills and plains, overlying Wianamatta Group sediments and often occurring in the lower parts of the Blacktown Soil Landscape. Slopes less than 3%. Soil limitations include high erosion hazard, low fertility, seasonal waterlogging, hardsetting conditions, low waterholding capacity, sodicity (dispersion) and localised salinity. Disturbed Terrain 7% Areas where natural soils have either been completely removed (e.g. quarries) or filled (e.g. reclaimed land). Soil characteristics vary widely. Risk of contamination, depending on past land use. Descriptions derived from Chapman and Murphy (1989). 3.2 Aspects and impacts Construction activities CSJ construction activities have potential to impact on air quality. The construction aspects broadly identified in the EIS that have the potential to impact on air quality are: Dust and Particulate Emissions: Demolition: any activity that involves the removal of existing structures. This may be referred to as deconstruction, specifically when a building is to be removed a small part at a time; Earthworks: the processes of soil stripping, ground levelling, excavation and landscaping. Earthworks will primarily involve excavating material, haulage, tipping and stockpiling; Project M4 East Design and Construct Page 20 of 35

21 Construction: any activity that involves the provision of new structures, modification or refurbishment. A structure will include a residential dwelling, office building, retail outlet, road, etc.; and Track-out: the transport of dust and dirt by heavy vehicles from the construction/demolition site onto the public road network, where it may be deposited and then re-suspended by the vehicles using the network. Gaseous Emissions: Mobile construction plant and equipment: diesel combustion and petrol (gasoline) combustion; Transport of materials, spoil and waste to/from site: diesel combustion; Transport of project vehicles light vehicles (petrol): petrol (gasoline) combustion; Vegetation clearance: removal of planted trees and screening vegetation and removal of parklands and open space; Electricity purchased from the grid: electricity consumption during construction; Odours/gases released during groundwater treatment; Construction materials: concrete, cement, structural steel, reinforcement steel, steel rock bolts, aggregate, asphalt, copper, plastic and mains water; and Waste: construction and demolition waste. The key construction locations and general construction activities that may result in potential air quality impacts are addressed in Section Key construction locations The majority of the construction footprint would be underground. However, surface works would be required to support tunnelling activities and to construct surface infrastructure such as interchanges, tunnel portals, ventilation facilities, ancillary operations buildings and facilities. Table 7 provides a high level summary of construction activities with potential air quality implications, based on key construction sites. Table 7 Key construction locations Location Typical activities with potential to generate air emissions M4 East surface works including Homebush Bay Drive Civil Site, Pomeroy Street Civil Site and Underwood Road Civil, Powells Creek Civil Site Tunnelling facilities including Underwood Road Tunnel Site, Cintra Park Tunnel Site, Northcote Street Tunnel Site Establishment of work areas including building demolition, vegetation clearance, clearing / grubbing Earthworks and exposed areas associated with soil stripping, ground levelling, and excavation Bridge construction and replacement works Construction of the dive structures and cut-and-cover sections of the tunnel Construction of the western vent facility Spoil handling Stockpiling of materials Road foundations and sealing of surfaces Exhaust emissions from the operation of construction plant and vehicles Surface site rehabilitation and restoration. Establishment of work areas including building demolition, vegetation clearance, clearing / grubbing Construction of permanent operational ancillary facilities Spoil removal, storage, handling and transport Stockpiling of materials Project M4 East Design and Construct Page 21 of 35

22 Location Typical activities with potential to generate air emissions Concord Road interchange including Concord Road Civil and Tunnel Sites Western works including Northcote Street Tunnel Site, Parramatta Road Ventilation Facility Site, Parramatta Road Civil Site, Wattle Street and Walker Avenue Civil Site Exhaust emissions from the operation of construction plant and vehicles Surface site rehabilitation and restoration. Establishment of work areas including building demolition, vegetation clearance, clearing / grubbing Earthworks and exposed areas associated with soil stripping, ground levelling, and excavation Construction of the dive structures and cut-and-cover sections of the tunnel, realignment of the M4 and approach roads and ramps Construction of permanent operational infrastructure Spoil removal, storage, handling and transport Stockpiling of materials Exhaust emissions from the operation of construction plant and vehicles Surface site rehabilitation and restoration. Establishment of work areas including building demolition, vegetation clearance, clearing / grubbing Earthworks and exposed areas associated with soil stripping, ground levelling, and excavation Construction of the dive structures and cut-and-cover sections of the tunnel and ramps Construction of permanent operational infrastructure and ancillary facilities Spoil removal, storage, handling and transport Stockpiling of materials Exhaust emissions from the operation of construction plant and vehicles Surface site rehabilitation and restoration Construction impacts The dominant air quality impacts and amenity issues as a consequence of the identified construction aspects are: Dust deposition (soiling of surfaces) and visible dust plumes; Temporary elevation of Particulate Matter (PM10) concentrations due to dust-generating activities; Exhaust emissions from diesel-powered construction equipment; Potential adverse health effects including eye/nose/throat irritation; Impacts on sensitive receivers, including outdoor areas; Impacts on water quality and vegetation; and Dust or odour complaints from public. As discussed in the M4 East EIS, it is difficult to quantify dust emissions from construction activities, since it is not possible to predict the weather conditions that will prevail during specific construction activities. Therefore an emission rate of 2.69 tonnes per hectare per month has been adopted for the project in accordance with AP 42 (USEPA 1995), referenced in Section of the National Pollutant Inventory Emissions estimation technique manual for Fugitive Emissions (Dep. of Sustainability, Environment, Water, Population and Communities, 2012). This is likely to represent a worst-case emissions scenario. Actual rates of dust generation for the project will depend on the total area of land exposed at any one time and the types of activities being conducted. As work areas will generally be opened up and stabilised on a progressive basis, the effects of construction on local dust levels would generally be temporary and relatively short-lived. The mitigation measures provided in Section 4 of this plan for dust minimisation and suppression will assist in further reducing dust levels associated with the project. Project M4 East Design and Construct Page 22 of 35

23 3.2.4 Factors likely to affect construction air quality impacts The risk of dust impacts from a demolition/construction ancillary facility causing loss of amenity and/or health or ecological impacts is related to the following (IAQM 2014): The nature of the activities being undertaken; The duration of the activities; The size of the site; The meteorological conditions (wind speed, direction, rainfall and dew). Adverse impacts are more likely to occur downwind of the site and during drier periods; Soil moisture content and soil type and erodibility; The proximity of receptors to the activities; The sensitivity of the receptors to dust; and The adequacy of the mitigation measures applied to reduce or eliminate dust. In addition, the risk of air quality impacts arising from exhaust emissions are related to the following: The number and type of plant and equipment being used; The duration of use of each item of plant and equipment; Appropriate operation and maintenance of plant and equipment; and Compliance of plant and equipment with relevant emission standards Sensitive receivers Sensitive receivers likely to be impacted by the construction footprint were identified in the EIS and mapped in the Environmental Constraints Map (ECM) documented in the CEMP Annexure A4. They can be broadly classified as: Residential; Commercial; Educational; Medical; Aged care facilities; Places of Worship; Public Buildings; Hotels; Café Bars; Child Care; Outdoor Active Space; Outdoor Passive Space; and Road Users. Project M4 East Design and Construct Page 23 of 35

24 4 Consolidated environmental safeguards Environmental safeguards to manage air quality impacts prior to and during works are identified in Table 8. Elimination of the hazard is the first preference of control, followed by engineering, then administrative controls. These controls include the relevant legal and project requirements identified in the revised environmental management measures (REMM), Conditions of Approval (CoA) and CSJ standard practice measures specific to management of air quality. Table 8: Project controls associated with management of air quality CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. Planning AQL1 AQL2 Communicate regularly with other high risk construction sites within 500m of the site boundary, to ensure plans are co-ordinated and cumulative dust and particulate matter emissions are minimised. Plan site layout so that machinery and dust causing activities are located away from receptors, as far as is possible. REMM AQ40 EM, CM Air Quality and Monitoring REMM AQ5 EM, CM Air Quality and Monitoring CAP / WP Site Environment Plans AQL3 Ensure all air quality risks are considered as part of the development of Construction Area Plans. CSJ standard practice PE CAP AQL4 Ensure Work Packs include relevant environmental control information including a Site Environment Plan where required. CSJ standard practice PE WP Site Environment Plan Project M4 East Design and Construct Page 24 of 35

25 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. Incidents AQL5 All environmental incidents will be managed in accordance with the Roads and Maritime Environmental Incident Classification and Reporting. Where incidents cause or are likely to cause material harm to the environment, the incident will be immediately reported to NSW EPA and other authorities as per the Pollution Incident Response Plan. The Secretary DP&E will be informed of any such notification. Any requirements of the Secretary or other relevant public authority will be met to address the cause or impact of an incident relating to the project. POEO Act CoA A15, A17 EM, EA, SS Roads and Maritime Environmental Incident Classification and Reporting Pollution Incident Response Plan AQL6 AQL7 The Secretary will be notified of any incident (other than those relating to the Protection of the Environment Operations Act 1997) with actual, or potential, significant off-site impacts on people or the biophysical environment immediately of becoming aware of the incident on weekdays, or the following business day on weekends, public holidays and site shutdown. Full written details of the incident will be provided to the Secretary within seven days of the date on which the incident occurred. Record any exceptional incidents that cause dust and/or air emissions, either on- or off-site, and the action taken to resolve the situation. Exceptional incidents include: Wind speeds above 25 km/hr, Dust emissions from non-project related construction projects, and Dust and / or air emissions from other non-project related sources, e.g. bush fires, dust storms. CoA A16 EM Roads and Maritime Environmental Incident Classification and Reporting CEMP Section 7 REMM AQ44 SS Site diaries Project M4 East Design and Construct Page 25 of 35

26 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. Community AQL8 AQL9 Implement the Community Communication Strategy and associated community engagement activities before work commences on site. Notification of nearby residents and businesses may include letters, door knocking residents and/or advertisements (e.g. radio, print). Display the name and contact details of person(s) accountable for air quality and dust issues at the boundaries of each construction area. This may be the project hotline, environment manager/engineer or the site manager. REMM AQ3 CRM Community Communication Strategy REMM AQ4 CRM, CM Community Communication Strategy CAP / WP AQL10 Record all dust and air quality complaints in accordance with the Construction Complaints System and make the complaints log available to the Secretary upon request. Dust - general AQL11 Weather warnings and wind speeds above 25 km/hr to be reported to the Site Supervisor and Construction Teams. CoA C4 REMM AQ42 REMM AQ43 CSJ standard practice CRM, CM Construction Complaints System Air Quality and Monitoring EA Air Quality and Monitoring AQL12 Remove materials that have a potential to produce dust from site as soon as possible, unless being re-used on site. If they are being re-used on-site cover as soon as practicable. REMM AQ7 PE, SS Air Quality and Monitoring AQL13 Ensure an adequate water supply on the site for effective dust/particulate matter suppression/mitigation, using non-potable water where possible and appropriate. REMM AQ10 EPL O4.7 CM, PE, EM CAP / WP Project M4 East Design and Construct Page 26 of 35

27 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. AQL14 Ensure equipment is readily available on site to clean any dry spillages, and clean up spillages as soon as reasonably practicable after the event using appropriate cleaning methods. REMM AQ13 CM, PE, SS CAP / WP Spill (Construction Soil and Water Plan AQL15 Avoid scabbling (roughening of concrete surfaces) if possible. REMM AQ14 CM, PE CAP / WP AQL16 Avoid dry sweeping of large areas. REMM AQ20 SS Air Quality and Monitoring Dust earthworks and stockpiling CAP / WP AQL17 Stockpiles shall be located outside overland flowpaths, and where left exposed and undisturbed for longer than 28 days, would be finished and contoured to minimise loss of material in flood or rainfall events. Materials which require stockpiling and are undisturbed for longer than 28 days would be stabilised by compaction, covering with anchored fabrics, or seeded with sterile grass where appropriate. AQL18 Where a stockpile, e.g. sand or fine aggregate, has the potential to generate dust, control measures would be implemented. These would include wetting the stockpile, covering the stockpile or contouring the stockpile. REMM AQ15 PE, SS, EA Air Quality and Monitoring procedure Site Environment Plans REMM AQ16 PE, SS Air Quality and Monitoring EWMS AQL19 Re-vegetate earthworks and exposed areas/soil stockpiles to stabilise surfaces as soon as practicable. Rehabilitation, seeding or grassing should occur as soon as they become available. REMM AQ37 CSJ standard practice PE, SS, EA EWMS Air Quality and Monitoring Project M4 East Design and Construct Page 27 of 35

28 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. AQL20 Use hessian, mulches or tackifiers where it is not possible to re-vegetate or cover with topsoil, as soon as practicable. AQL21 Where possible, only remove any cover for exposed areas in small areas during work and not all at once. REMM AQ38 PE, SS EWMS REMM AQ39 PE, SS Air Quality and Monitoring CAP / WP Dust demolition AQL22 Soft strip inside buildings before demolition (retaining walls and windows in the rest of the building where possible, to provide a screen against dust). AQL23 Ensure effective water suppression is used during demolition operations. Hand held sprays are more effective than hoses attached to equipment as the water can be directed to where it is needed. In addition high volume water suppression systems, manually controlled, can produce fine water droplets that effectively bring the dust particles to the ground and may be more useful for covering larger areas. AQL24 No explosive blasting during demolition. Appropriate manual or mechanical alternatives will be used. AQL25 Bag and remove any biological debris or other hazardous materials such as asbestos, damp down such material before demolition. REMM AQ33 PE, SS CAP / WP REMM AQ34 PE, SS EWMS Air Quality and Monitoring Air Quality and Monitoring REMM AQ35 PE CAP / WP REMM AQ36 PE, SS CAP / WP EWMS Asbestos Plan Dust plant and equipment AQL26 Where practicable, only use cutting, grinding or sawing equipment fitted or in conjunction with suitable dust suppression techniques such as water sprays or local extraction, e.g. suitable local exhaust ventilation systems. REMM AQ9 PE, SS CAP / WP AQL27 Where possible, use enclosed chutes and conveyors and covered skips. REMM AQ11 PE, SS CAP / WP Project M4 East Design and Construct Page 28 of 35

29 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. AQL28 Minimise drop heights from conveyors, loading shovels, hoppers and other loading or handling equipment and use fine water sprays on such equipment wherever appropriate. REMM AQ12 PE, SS EWMS Dust transport and deliveries AQL29 Impose and signpost a maximum speed limit of 20 km/h on surfaced and unsurfaced haul roads and in work areas. AQL30 Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery. AQL31 For smaller supplies of fine powder materials ensure bags are sealed after use and stored appropriately to prevent dust. AQL32 Use water-assisted dust sweeper(s) on the access and local roads, to remove, as necessary, any material tracked out of the site. AQL33 Ensure vehicles carrying materials or spoil entering and leaving sites are covered to prevent escape of materials during transport. REMM AQ8 CM, PE CAP / WP Air Quality and Monitoring REMM AQ17 PE, EA CAP / WP EWMS REMM AQ18 PE, SS CAP / WP REMM AQ19 PE, SS CAP / WP Air Quality and Monitoring REMM AQ21 PE, SS Air Quality and Monitoring EWMS AQL34 Where reasonable and feasible, haul roads will be maintained with water carts and graders, and the condition of the roads will be monitored especially in high risk areas and/or during high risk days. REMM AQ24 CSJ standard practice PE, SS CAP / WP EWMS Project M4 East Design and Construct Page 29 of 35

30 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. AQL35 Stabilised access, rumble grids, wash bays or similar must be established for site entries and exits to minimise mud on public roads. Sweepers shall be used periodically to clean public roads where mud has been deposited. AQL36 Ensure there is an adequate area of hard surfaced road between the wheel wash facility and the site exit, wherever site size and layout permits. Access gates to be located at least 10 m from receptors where possible. Emissions AQL37 All construction plant and equipment must be maintained and operated to minimise emissions. Visible emissions should not be emitted for any period greater than 10 consecutive seconds. Notify EA of any defective emission controls. AQL38 Ensure all construction vehicles comply with their relevant emission standards: Project would comply with the relevant emissions standards in Australian Design Rules (for heavy duty engines and vehicles); Strategies for minimising air emissions from off road diesel equipment, including graders, bulldozers and loaders; and Confirmation that all off road diesel equipment would meet best available diesel emissions standards or be fitted with an appropriate diesel exhaust treatment device where possible. REMM AQ25 CSJ standard practice REMM AQ26 REMM AQ27 POEO Act CSJ standard practice PE, SS AFMP PE, SS EWMS Site Environment Plans CAP / WP Site Environment Plan PE, SS CAP / WP Air Quality and Monitoring REMM AQ28 PE, SS CAP / WP AQL39 Ensure that, where practicable engine idling is minimised when stationary. REMM AQ29 SS EWMS Air Quality and Monitoring AQL40 Avoid the use of diesel or petrol powered generators and use mains electricity or battery powered equipment where practicable and possible, and to connect to mains power as soon as possible. If generators are to be used, they are to be sited away from receivers. AQL41 Promote and encourage sustainable travel (public transport, cycling, walking, and carsharing). REMM AQ30 PE, SS EWMS REMM AQ31 EM, CM Project Induction Project M4 East Design and Construct Page 30 of 35

31 CSJ No. Control Source Responsibility Training /Induction /Toolbox Monitoring /Inspection /Audit /Check Where addressed EM Environment and Sustainability Manager, EA Environment Advisor, PD - Project Director, FM- Foreman, PE Project Engineers, CM Construction Manager, SS Site Supervisor, CRM Community Relations Manager. CAP Construction Area Plan, WP Work Pack, EWMS Environmental Work Method Statement. AQL42 No bonfires and burning of any materials. REMM AQ32 CSJ standard practice SS EWMS Air Quality and Monitoring Project M4 East Design and Construct Page 31 of 35

32 5 Review and improvement 5.1 Monitoring and reporting Indicative inspections, observations, monitoring and reporting requirements relevant to the management of air quality are identified in Table 9. Table 9: Monitoring requirements relevant to management of air quality Item Frequency Standards Reporting Responsibility Inspections Site inspection Daily No visible dust emissions from site Minimise gaseous emissions Awareness of impending weather Site inspection Daily No mud tracking off-site; check main exit/entry points and material on public roads Dust controls (e.g. watering down of materials, temporary coverage of exposed areas) are being implemented and are working effectively Site inspection Weekly No visible dust emissions No continuous visible vehicle/plant/equipment emissions for longer than 10 seconds (POEO (Clean Air) Regulation 2010) N/A Daily Diary (or equivalent) Environmental Inspection Checklist Site Supervisor, engineers, environmental team Site Supervisor or Environment Advisor Environment Advisor Site inspection Weekly Haul road integrity to be maintained Site log book / Environmental Inspection Checklist Site Supervisor or Environment Advisor Site inspection Fortnightly Regular dust soiling checks of surfaces such as street furniture, cars, and window sills within 100m of site boundary Environmental Inspection Checklist Environment Advisor Plant / equipment inspections including maintenance and emissions Prior to use Plant/equipment in good working order No continuous visible vehicle/plant/equipment emissions for longer than 10 seconds (POEO (Clean Air) Regulation 2010) Plant and vehicle inspection logs Site Supervisor Visual surveillance Continual during activities with high potential to produce dust and during prolonged dry or windy conditions No visible dust emissions Site Supervisor s Daily Diary Site Supervisor Monitoring Prevailing wind conditions and weather forecast from Bureau of Meteorology to be reviewed Daily Extreme weather Winds >25 km/hr Environmental Advisor to report to Site Supervisor Environment Advisor Rainfall monitoring Daily Rainfall gauges will be checked after rainfall events Monitoring results Environment Advisor Project M4 East Design and Construct Page 32 of 35

33 Item Frequency Standards Reporting Responsibility Dust deposition monitoring Dust deposition monitoring throughout construction phase Ambient monitoring 12 months prior to project opening, during construction and for at least two years after project opening Approved Methods for Sampling and Analysis of Air Pollutants in NSW Approved Methods for the Modelling and Assessment of Air Pollutants in NSW Dust deposition gauges will be located in proximity to each of the construction compounds listed below. Precise locations for the gauges will be determined in accordance with the above guidelines and in consultation with the relevant landowner, where necessary: Homebush Bay Drive civil site (C1); As agreed with requesting party / authority Monitoring results to be made publicly available and subject to independent audit. Environment and Sustainability Manager Pomeroy Street civil site (C2); Underwood Road civil and tunnel site (C3); Concord Road civil and tunnel site (C5); Cintra Park tunnel site (C6); Wattle Street and Walker Avenue civil site (C9); and Parramatta Road civil site (C10). Ambient air quality monitoring stations (for the operational project) will be located at: Allen Street Reserve; Powells Creek civil site; Concord Oval; St Luke s Park; Ramsay Street; and Haberfield Public School. Reporting Quarterly Construction Compliance Report Quarterly Compliance Tracking Program Determine the compliance status against CoA and REMM (including those particular to air quality) during construction phase Report on status against KPIs for air quality in accordance with D57(e)(iii) Report submitted to DP&E; Asset Trustee; Environmental Representative Environment and Sustainability Manager Note: Dust deposition gauges are not required by any CoA or REMM. They will be implemented by the project as a due diligence measure. Numerous compounds are in close proximity, and therefore dust deposition gauges are not proposed at each site. 5.2 Auditing Audits (both internal and external) will be undertaken to assess the effectiveness of environmental controls, compliance with this sub-plan, Conditions of Approval and any other relevant approval and licence. Audit requirements and scheduling are described in Section 8.3 of the CEMP. 5.3 Non-conformance management, corrective and preventative action Environmental inspection, observation and monitoring results are interpreted to identify actual and potential non-conformances and events that may result in nuisance, environmental harm and unacceptable loss of Project M4 East Design and Construct Page 33 of 35

34 amenity or community complaints. The Environmental Representative, Asset Trustee Representative and/or a public authority may also raise a non-conformance or improvement notice. Where non-conformances are identified during regular inspections, corrective actions are raised, tracked and closed out through the inspection records Following the identification of a non-conformance, corrective and/or preventative actions will be identified and assigned to the appropriate person with set timeframes. Timeframes will be set to ensure any damage incurred is rectified and any chance of recurrence is eliminated as soon as practicable. Synergy or the Environmental Corrective Actions Register will be used to assign, track and close out corrective actions (except for those actions identified, tracked and closed out within through inspection records). All corrective actions will include reference to the relevant incident record for ease of tracking. Refer to Section 8.6 of the CEMP for further information. 5.4 Complaints Complaints will be recorded in accordance with the Construction Complaints System. Information to be recorded will include location of complaint, time(s) of occurrence of alleged air quality impacts and perceived source. Resident complaints will be responded to in a timely manner and action taken recorded in accordance with the Construction Complaints System. 5.5 Revision of this plan Continual improvement is achieved through constant measurement and evaluation, audit and review of the effectiveness of the plan, and adjustment and improvement of the CEMP, project environmental outcomes and CSJ environmental management system. Monthly reviews undertaken by the Environmental Representative and quarterly management reviews provide specific opportunities to identify improvements in the environmental management system and/or this AQMP. This plan will be updated as required: To take into account changes to the environment or generally accepted environmental management practices, new risks to the environment, any hazardous substances, contamination or changes in law; Where requested or required by the DP&E or any other Authority; or In response to internal or external audits or quarterly management reviews. The updated plan must be endorsed by the Environment and Sustainability Manager and approved internally by the Project Director. Minor changes may be approved by the Environmental Representative. Minor changes would typically include those that: Are editorial in nature (e.g. staff and agency/authority name changes); Do not increase the magnitude of impacts on the environment when considered individually or cumulatively; or Do not compromise the ability of the project to meet approval or legislative requirements. Where the Environmental Representative deems it necessary, the AQMP will be provided to relevant stakeholders for review and comment if required and forwarded to the Secretary of DP&E for approval. Where approval of the Secretary of DP&E is not required, a copy of the updated plan will be provided to the Secretary for information. Project M4 East Design and Construct Page 34 of 35

35 Annexure A Air quality management and monitoring procedure Project M4 East Design and Construct Page 35 of 35

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37 Re-assess the situation Air Quality and Monitoring Assess the Situation Review weather forecast for potential high winds (>25km/hr) [EA]. Consult with SS and other subcontractors for strategies to minimise dust [EA]. The need for and type of dust controls will be assessed prior to works being undertaken [SS]. The implementation of dust and emission controls will be progressive and continual during the various stages of construction of the temporary site facility [SS/EA]. STOP DUST GENERATING WORK if winds exceed 25km/hr and air quality controls are not sufficient to mitigate dust generation. Legend Responsibilities SS Site Supervisor EA Environmental Advisor EM Environment & Sustainability Manager 1. Introduction 1.1 Objectives To describe the minimum mandatory requirements for the management of air quality associated with M4 East construction activities. 1.2 Training All personnel are to undertake Project inductions identifying their environmental and compliance obligations under the Minister s Conditions of Approval for the M4 East Project. Obligations and responsibilities relevant to air quality management will also be included in daily pre-start or activity-specific pre-start briefings, toolbox talks or targeted environmental training as appropriate. 2. Standards / Guidelines Implement Air Quality Controls Construction Air Quality Plan (AQMP); and [SS] The most common dust and emission control mitigation measures to be implemented include: Avoid dry sweeping of large areas. Use water-assisted dust sweeper(s) on the access and local roads to remove tracked out materials. Use a water cart or hoses to wet down access tracks, problematic areas. Ensure effective water suppression to be used during demolition operations. Cover truck loads and sweep tailgates before leaving site. Operate and maintain vehicle wash down facilities. NSW EPA Local Government Air Quality Toolkit, Visual Guide: Dust from urban construction sites. 3. Air quality management Communicate regularly with other high risk construction sites within 500m of the site boundary, to ensure plans are co-ordinated and cumulative dust and particulate matter emissions are minimised; Construction Area Plans and Work Packs to consider air quality controls to be implemented when detailing the construction methodology and planning the works. Air quality controls, in addition to those listed in the process diagram, may be sourced from Section 4 of the AQMP; Temporary stockpiles require regular wetting or are to be covered. Stockpiles or materials to be stored longer than 28 days are to be contoured and seeded to minimise loss of material. Remove materials that have potential to produce dust from site as soon as possible. If feasible and reasonable, erect dust screens around dust generating activities which are in close proximity to the general public. Plan site layout so that machinery and dust generating activities are located away from receptors, as far as is possible; Construction activities which are likely to result in dust generation include: operation of plant and vehicle movements on unsealed roads, demolition, stockpiling, earthworks and material handling. Refer to the Asbestos Plan if dealing with asbestos containing material; Impose and signpost a maximum-speed-limit of 20 km/h on surfaced and unsurfaced haul roads; Observe Effectiveness of Controls [SS] If visible dust observed leaving site, re-assess the situation and potentially implement additional controls. If a dust complaint is received, re-assess the situation and potentially implement additional controls. Bring any significant air quality issues to the attention of the EA (in the first instance) or the EM. Exposed areas to be minimised. Rehabilitation, seeding or grassing to be undertaken as soon as practicable; Ensure operators plant checklist is completed daily and all new plant / equipment being delivered to site has undergone a plant / equipment inspection; Soft strip the inside of buildings before demolition; Notify SS if material is deposited on a public road. SS to make arrangements to have the material cleared as soon as practicable ; Burning of any materials is prohibited; 4. Complaint Monitoring & Recording SS to monitor daily for tracking of mud on public roads, ensuring the integrity of the access/egress points and hail road to ensure loose material not being tracked out. Outcomes of this monitoring are to be recorded in the SS daily diary (or similar). SS to record details of observations regarding visible dust emissions in SS daily diary (or similar). Record all dust and air quality complaints in accordance with the Construction Complaints System. 5. Incident Any exceptional incident which causes dust/emissions, either on-site or in close proximity to the site, is to be recorded in the Foreman s daily diary and immediately reported to the SS. The SS to report the matter to the EM and CM. EA to undertake weekly and fortnightly inspections in accordance with AQMP. EM to regularly review monitoring results from dust deposition gauges. Project M4 East Design and Construct Page 2 of 2 M4E-ES-PRC-PWD Revision Date 14 March 2016