JBS Pollution Incident Response Management Plan

Transcription

1 JBS Pollution Incident Response Management Plan JBS Australia Pty Limited Scone NSW Document Owner Troy White, Group Environment Manager Printed copies of this document are deemed uncontrolled JBS Australia Pty Limited - Scone Page 1 of 23

2 Table of Contents 1. Introduction Background Scope & Purpose Site Description Pollution Incident Response Management Plan Hazard and Pollution Identification Hazard Identification and Assessment Safety Equipment & Maps Incident Response Communication Communicating with Regulatory Authorities Communicating with Local Residents: Training & Document Control Staff Awareness and Training Document Availability Testing of Plan Appendix A: Chemical Storage & Safety Equipment Locations Appendix B: Emergency Evacuation Routes Appendix C: Non-compliance, Incident and Corrective Action Form Appendix D: Environmental Site Inspection Form Appendix E: JBS Environmental Spill Response Procedure Appendix F: Inventory of Potential Pollutants JBS Australia Pty Limited - Scone Page 2 of 23

3 1. Introduction 1.1. Background This Pollution Incident Response Management Plan (PIRMP) has been developed to document the processes required to prepare for and respond to pollution incidents at JBS s facility at Muffett St, Scone NSW The purpose of this plan is to: Outline the procedure for timely communication of an incident to staff, relevant authorities and appropriate stakeholders; Ensure that hazards to the environment, human health and safety are eliminated and where this is not possible minimized to an acceptable level; and Detail the controls and policies in place to ensure that this plan is effectively implemented and regularly reviewed by management and staff. This plan has been prepared in accordance with the requirements introduced by the Protection of the Environment Legislation Amendment Act 2011 and the Protection of the Environment Operations (General) Amendment (Pollution Incident Response Management Plan) Regulation, Scope & Purpose This PIRMP applies to JBS s abattoir at Scone NSW, the license details of which are provided in the table below: Company JBS License Holder P & M Quality Smallgoods Pty Ltd Environmental Protection License (EPL) Number: 7538 Scheduled Activities Livestock Processing Activities - Slaughtering or processing animals Livestock Processing Activities - Rendering or fat extraction Site Name and address Primo Australia Muffett Street, Scone, NSW, 2337 All environmental risks and environmental incidents will be managed through the implementation of this Plan. The PIRMP also details the pre-emptive actions that have been implemented at the site, these include: JBS Australia Pty Limited - Scone Page 3 of 23

4 Specific measures implemented to minimise the risk of an incident occurring due to spillage, storage of hazardous materials or fire; Inventory of potential pollutants on site; Minimum safety equipment requirements; Communication with the community; Minimising harm to persons; Training of personnel; and Testing of the PRIMP Site Description The JBS abattoir at Scone NSW is located at Muffett St and is approximately 0.7 km to the north of the town. It is situated on Lot 31 DP579922, Lot 23 DP622300, Lot 72 DP and Lot 697 DP The site has been used for meat processing for over 60 years and is licensed to slaughter cattle and smallstock. Currently it processes in the order of cattle per week. The site also includes cattle holding yards and irrigation area for disposal of treated wastewater. Within the controlled drainage area of the plant the following functions occur: Cattle unloading, receival and lairage; Beef slaughter; Offal processing; Pre treatment of hides; Pet food and by product collection; Beef carcass chilling; Beef carcass boning to primal cuts; Chilling and freezing of beef cartons; Storage and Load out of beef cartons; Administration offices; Amenities; Canteen; Laboratory; Maintenance and equipment storage; Chemical storage; Effluent screening and treatment; Rendering; and Potable and hot water production. JBS Australia Pty Limited - Scone Page 4 of 23

5 1.4. Pollution Incident Response Management Plan This PIRMP applies to all employees, visitors and contractors within the boundaries of the Scone facility. This document is designed to satisfy the requirements of the EPA s Environmental guidelines: Preparation of pollution incident response management plans (2012). This document will act as a standalone document but will also be incorporated into our Emergency Response Plan that will be drafted in accordance with Australian Standard AS3745. This plan provides comprehensive details of emergency management procedures to be followed during an emergency event. 2. Hazard and Pollution Identification In a list of potentially hazardous goods and pollutants held on the site was developed. Site inspections are regularly carried out by the Environment Officer at Scone in order to identify potential hazards and pollutants. This list is found at Appendix F. The following pollutants may be stored on site at any time: Chlorine Gas, sulphuric acid, liquid carbon dioxide (CO 2), ammonia, diesel, unleaded petrol, lube oil & pesticides as well as flammable liquids (paints, aerosols and thinners), alkalis hypochlorite and other solutions used for cleaning. The master MSDS spreadsheet contains an inventory of potential pollutants that are stored on the premises at the Scone facility. This inventory includes details of potential pollutants at the storages, the maximum quantity that is likely to be stored or held at the facilities, and indicates whether the storages have the potential to be associated with a material pollution incident. Site maps that detail the locations of pollutants and also the location of emergency response equipment are provided in Appendix A of this plan. Environmental Site Inspections are completed every twelve (12) months. An example of this inspection form is contained in Appendix D Hazard Identification and Assessment JBS has developed a comprehensive Risk Register that details environmental and health risks that may occur due to a pollution incident. The figure below illustrates the risk assessment process that was developed to identify the appropriate management measures for environmental risks. 1. The likelihood of the incident having an impact on the environment 2. The potential consequence of the incident occurring 3. A risk rating is assigned based on how severe the potential impact might be 4. A risk priority of action is assigned based on the risk rating JBS Australia Pty Limited - Scone Page 5 of 23

6 When a significant impact to the environment is identified, robust measures will be put in place to reduce the risk to an acceptable level. Figure 1: JBS Risk Assessment Process Consequences (1 to 4) Likelihood (1 to 4) 1 Extreme 2 Major 3 Moderate 4 Minor 1 Very Likely Likely Unlikely Very Unlikely Most Effective Least Effective Eliminate Substitute Engineer Administration Personal Protective Equipment Score 1, 2 or 3 4 or 5 6 or 7 Risk Priotiy Actions Do something about these risks immediately Do something about risks as soon as possible These risks may not need immediate action Table 1 provides an overview of the site specific environmental risks at Scone Abattoir. JBS Australia Pty Limited - Scone Page 6 of 23

7 Table 1: Overview of Environmental Risk at Scone Facility Risk Category Description of Risk/Hazard Mitigation Strategies (Pre-emptive actions) Water Bad disposal of sewage and/or residual water (contamination of local ground / water resources). Depletion of natural resources (water). Possible non-compliance with licence requirements. Waste management training for employees and contractors Regular maintenance of equipment Correct operation of equipment Fuel, chemical and waste storage and handling areas bunded to contain any spillage Establish and maintain MSDS register Emergency response equipment (spill kits) and training for accidental spillages Regular site audits and risk assessments of the site Ensure all equipment is regularly serviced to ensure there are no breakdowns in the process. Ensure that processing facilities are not overloaded leading to a breakdown. Storage of chemical/waste should be away from surface water drains and gullies to avoid any environmental pollution in the event of leakage. Land/Soil Bad disposal of sewage and/or waste (contamination of soil e.g. oil spillage). Depletion of natural resources Possible noncompliance with licence requirements. Regular maintenance to prevent equipment breakdowns Correct operation of equipment and facilities Emergency response equipment (spill kits) and training for accidental spillages Fuel, chemical and waste storage and handling areas bunded to contain any spillage Establish and maintain MSDS register Regular site audits All employees to complete waste management training as part of the environmental training programme. Ensure all equipment is regularly serviced to ensure there are no breakdowns in the process. Storage of chemical/waste should be away from surface water drains and gullies to avoid any environmental pollution in the event of leakage. JBS Australia Pty Limited - Scone Page 7 of 23

8 Risk Category Description of Risk/Hazard Mitigation Strategies (Pre-emptive actions) Hazardous Substances Environmental pollution due to spills or leaks of chemicals resulting in emissions to air, water soil or ground. Breaches of EPA licence and associated legislation. Production of hazardous waste Develop, review & maintain a program for hazardous substances Establish and maintain an MSDS register Provide safe storage for hazardous substances Ensure all hazardous substances are labelled Conduct risk assessments on hazardous substances Chemical Tracking And Risk Assessment Process for all new chemicals Ensure that employees only handle hazardous substances after training and assessment. Storage should be away from surface water drains and gullies to avoid any environmental pollution in the event of leakage. Comply with Emergency Response plan & Dangerous Goods Management Fire & Explosion Flammable and explosive compounds are stored at the site. There is also a fire risk associated with a number of processes e.g. bulk gas storage, other fuel storage and ammonia storage and use. Develop, review & maintain a program for hazardous substances Hazardous materials stored according to MSDS requirements including bunded storage and protective barriers Ensure that employees only handle hazardous substances after training and assessment Chemical Tracking And Risk Assessment Process for all new chemicals Emergency response equipment (spill kits) and training for fire or explosion incidents Urgently advise emergency services and the community if any impact may affect them Provide safe storage for hazardous substances Ensure all hazardous substances are labelled Biological Hazards Production of hazardous biological waste. Environmental pollution due to spills or leaks of chemicals resulting in emissions to air, water soil or ground. Breaches of EPA licence and associated legislation. Production of hazardous waste Adequate controls in place to ensure there is no release of these waste to the environment and community. Develop, review and maintain a program to control the risk of blood borne diseases. Compliance training and audits. JBS Australia Pty Limited - Scone Page 8 of 23

9 Risk Category Description of Risk/Hazard Mitigation Strategies (Pre-emptive actions) Air Emissions to air including chemical emissions, airborne contaminants, dust and smells and fumes. This can lead to compliance issues and complaints from the local community. Possible hazards to staff and local community if hazardous emissions to air arise. Regular maintenance to prevent equipment breakdowns Correct operation of equipment Hazardous materials stored according to MSDS requirements Emergency response equipment and training for accidental discharges Implement effective hazardous waste removal procedures Urgently advise emergency services and the community if any impact may affect them Establish and maintain MSDS register Environmental awareness training is provided to all staff. Notify the community if an incident occurs that may impact them Emergency response equipment should be readily available. Complete regular environmental risk assessments of the site Ensure biofilters re regularly serviced to prevent breakdown Security Risks Unauthorised persons accessing the facility and causing damage to equipment or processes, leading to environmental damage. Secure entire perimeter in the short term. Provide appropriate security to prevent unauthorised persons interfering with the tank or opening valves, etc. That may lead to a spillage of liquids and/or gases and a subsequent fire risk and/or environmental pollution risk. JBS Australia Pty Limited - Scone Page 9 of 23

10 Risk Category Description of Risk/Hazard Mitigation Strategies (Pre-emptive actions) Transport Pollution of environment may arise from vehicle movement in yard associated with the following: Vehicle deliveries Reversing Delivery bays Vehicle loading There may also be noise and dust issues associated with the transportation of these items. Possible ground/soil erosion. Disturbance to neighbours and impacts to the local community. Training of transport operators and contractors Inspection of vehicles entering and leaving Emergency response equipment (spill kits) and training Urgently advise emergency services and the community if any impact may affect them General Carbon emissions. Resource depletion. Previously unidentified and uncontrolled hazards. Complete regular environmental risk assessments of the site Compliance with EPA licence. Environmental awareness training for staff Safety Equipment & Maps Safety equipment is located at a number of locations throughout the site. This equipment is checked regularly in accordance with the OH&S plan. The site maintains a fire engine, trained emergency response team and a warden intercom System throughout the abattoir complex. Site communication is also conducted through internal phones and CB radio (check frequency specs). An equipped first aid facility is located in the abattoir and is maintained by an occupational First Aid-trained worker. The Maps located in Appendix A and B detail the locations of Emergency & Evacuation Response Equipment throughout the site Incident Response JBS s Emergency Response Plan provides comprehensive details of the procedures to be follows in the event of an emergency incident occurring (including environmental emergencies). JBS Australia Pty Limited - Scone Page 10 of 23

11 In addition to this JBS has developed a Hazard, Incident Investigation and Regulatory Contact Reporting Procedure (CORPENV4 22/11/2010). The purpose of this procedure is to outline the processes for investigating and report all potential hazards, incidents and Regulatory Contact. The results of these investigation are then used to improve overall Environmental performance. This plan details the procedure Environmental Incident Protocol in line with their Environmental Management Plan (EMP) which also details corrective actions if an environmental incident should occur. A sample Non Compliance, Incident and Corrective Action form is included in Appendix C. JBS Environmental Spill Response Procedure is provided in Appendix E. The illustration below details the JBS process for responding to environmental incidents at the Scone facility. JBS Australia Pty Limited - Scone Page 11 of 23

12 JBS Australia Pty Limited - Scone Page 12 of 23

13 3. Communication 3.1. Communicating with Regulatory Authorities In the unlikely event that a significant environmental incident occurs (i.e breach of EPA license) a phone call will be made to the appropriate authority by the OHS& Environment Officer. JBS Contacts Gatehouse Security 24 (02) hours Plant Manager-Emergency (02) Incident Manager First Aid/HR Officer/ OHS & (02) Environment Officer Government Contacts Emergency Services 000 EPA (local call cost throughout NSW except from mobile phones) Ministry of Health (02) Fire & Rescue NSW Upper Hunter Shire Council (02) WorkCover Communicating with Local Residents: Community stakeholders that are potentially affected by an environmental incident at the facility event will be notified immediately by one of the following methods: Phone call by OHS & Environment Officer Door knocking by an appropriate site representative Any additional communication will be determined by the nature of the event or as directed by the relevant agency. Regular updates will be provided to the affected community stakeholders throughout the course of the event. In the event of a major pollution incident, residents or businesses may be further contacted by an emergency service representative, such as in a case where evacuation or critical safety actions are necessary. An all-clear telephone call will also be made to residents when the incident is no longer of concern or normality has been restored. JBS Australia Pty Limited - Scone Page 13 of 23

14 Note: In the event of an emergency, the Chief Executive may only make Press Statements on behalf of JBS Australia. Administration staff is to be advised to respond to any queries with: 4. Training & Document Control 4.1. Staff Awareness and Training All staff and contractors are required to complete the one day Introduction to Environment- PRC61 induction training, all site staff are provided with sufficient environmental awareness training. The contents of this training include: Informing employees of their impacts on the environment and how they can prevent or minimise these impacts will lead to sound environmental practices; Providing details on the sensitivity of the site and importance of adhering to environmental procedures; Raising awareness of environmental signage that is displayed on the site; Emergency numbers are to be clearly displayed; and Environmental procedures to be followed. All persons who complete this training will be made aware of the contents of this plan. All persons will be required to complete refresher training on an annual basis Document Availability In accordance with Section 153D of the POEO Act, the plan will be made available to all site personnel via the site document control system. A hard copy of the plan will also be available at the abattoir s administration office. In addition, this plan will be made available to the public via the following methods: Uploading a public version of the plan to the JBS Australia website at Providing copies of the public version of the Plan, without charge, to any member of the public who may request a copy Testing of Plan This plan will be tested at least once every 12 months to ensure that the information contained within the plan is accurate and up to date, and that the plan is capable of being implemented in a workable and effective manner. In addition if a pollution incident occurs at or from the premises it will be tested within 1 month of the date on which the pollution incident commenced. JBS Australia Pty Limited - Scone Page 14 of 23

15 Appendix A: Chemical Storage & Safety Equipment Locations JBS Australia Pty Limited - Scone Page 15 of 23

16 Appendix B: Emergency Evacuation Routes JBS Australia Pty Limited - Scone Page 16 of 23

17 Appendix C: Non-compliance, Incident and Corrective Action Form Company/Department: Project Name: Registered Incident No: Type of Construction Activity: Location of Incident: Date & Time of Incident: Date:. Time:. Type of Incident: Spill or leak of hazardous fluids onto unprotected ground. Fluid Type (Oil, diesel or gasoline):. Spill or leak of other chemicals and/or fluids (please list below): Other (Please describe): Incident Observed by: Name: Position: Short-Term Corrective Action: (Action taken to clean up any resulting contamination and to achieve compliance with regulations) Short-Term Corrective Action carried out by: Name: Position: Long-Term Corrective Action: (Measures to be implemented to prevent repeated non-compliance incident of similar nature.) Long-Term Corrective Action carried out by: Name: JBS Australia Pty Limited - Scone Page 17 of 23

18 Company/Department: Project Name: Registered Incident No: Position: Project Environmental Manager: (Short-term corrective action completed) Project Environmental Manager: (Long-term corrective action completed) Signature: Date: Project Manager: Signature: Date: Project Manager: Signature: Date: Signature: Date: JBS Australia Pty Limited - Scone Page 18 of 23

19 Appendix D: Environmental Site Inspection Form Environmental Measures Observations Comments Compliance Level Waste Management Noise Management Combustion Gases & Dust Management Materials & Dangerous Materials/Substances Management Wastewater Management Other Environmental Measures TOTAL (Use weighted average of results to determine the percentage of compliance) Compliance Level 0 - Low Several deviations observed. 1 - Medium A few small deviations observed 2 - Good No significant deviations observed 3 - Full No deviations observed JBS Australia Pty Limited - Scone Page 19 of 23

20 Appendix E: JBS Environmental Spill Response Procedure Notification All spills need to be considered serious until verified otherwise. The factors which will determine the seriousness of the spill are the nature of the material, the location of the spill and the volume of material released. As a spill can result in WHS, Environmental or Production risk, any spill which is not consistent with NORMAL discharge is to be reported to the area supervisor. 1. Notify the area Supervisor immediately 2. The area supervisor must determine whether or not the Weighbridge is notified and thus the Emergency Response Team. At this point the spill will be treated as an incident. 3. If the spill is determined to be normal, the clean up as per normal operations or consult the MSDS or environmental officer. For the purpose of the environment, the weighbridge should be notified if: Spills escape the Bunded Areas and cannot be controlled When spills are discharged into effluent The material cannot be disposed of to effluent The material must not directly enter the effluent ponds The material may result directly or indirectly in odour Areas outside effluent Catchment The material could contaminate soils or kill plants/trees Could contaminate water courses including storm water Could contaminate ground water The table below is a guide for normal and abnormal discharges to bunded areas, areas discharging to effluent and areas outside effluent Catchment. These items and levels are indicative for typical items at Scone Abattoir. Items not on this list should be reported to the weighbridge for a determination of correct procedures. JBS Australia Pty Limited - Scone Page 20 of 23

21 Material Acceptable Level (Guide Only) Bunded Areas and Areas discharging to effluent Areas outside effluent Catchment Effluent 2ML per day 0ML per day Paunch 10T per day 50kg per day Hot water screenings form save all 3T per day 50kg per day Mineral Oil 0.5L per spill 0.5L per spill Vegetable Oil 3L per day 3L per spill Diesel 3L per spill 3L per spill Petrol 3L per spill 3L per spill Cleaning products 300L per day 25L per spill Acids (concentrated) 207kg per day 1L per spill Oxidising Agents (Chlorite) 129kg per day 10L per spill Blood 7000L per day 200L per spill Tallow 2T per day 0.2T per spill Meat Meal 1T per day 0.1T per day Medical Waste 0T per day 0T per day Molasses 200kg per day 200kg per day Spills should be cleaned up as instructed. However in principle: Contain the spill Control the discharge Determine the disposition of spill and adsorbent material Clean the area The incident is and clean up is performed in consultation with the Environmental Officer and/or Group Environmental Manager. Environmental Spills should be recorded in CORPENV A1 4-1 Environmental Haz or Incident Investigation and Regulatory Contact Reporting and may require reporting to the EPA. JBS Australia Pty Limited - Scone Page 21 of 23

22 Appendix F: Inventory of Potential Pollutants (Feb 2015) Fuels, lubricants and chemicals stored on site include: Storage Location: LPG1 O/S Holding Yard Stored Substance/s: Liquefied Petroleum Gas 85kL vessel Storage Location: LPG2 Maintenance Workshop Stored Substance/s: Liquefied Petroleum Gas 822L cylinders (2 x 411L each) Storage Location: LPG3 Outside Old Piggery Lairage Stored Substance/s: Liquefied Petroleum Gas 6.5kL vessel Storage Location: LNG1 Adjacent to Rendering Plant Stored Substance/s: Liquefied Natural Gas 60kL vessel Storage Location: LNG2 Adjacent to Rendering Plant Stored Substance/s: Liquefied Natural Gas 60kL vessel Storage Location: CS2 O/S Amenities Building Stored Substance/s: LPG 650L in cylinders (6 x 108L each) Storage Location: PV1 Ammonia Plant Stored Substance/s: Anhydrous Ammonia 6kL vessel Storage Location: PV2 O/S Palletising Stored Substance/s: Carbon Dioxide 30kL vessel Storage Location: PV3 Engine Room Stored Substance/s: Anhydrous Ammonia 1,000kg in cylinders (2 x 500kg each) Storage Location: UG1 Maintenance Stored Substance/s: Diesel 8kL underground tank Storage Location: PD6 Engine Room Stored Substance/s: Glycol 1kL tank Storage Location: PS1 Rendering Plant Caged Storage Stored Substance/s: Sodium Hydroxide 1kL IBC + Sulphuric Acid 1kL IBC Storage Location: RS1 Rendering Plant Chemical Dispersal Room Stored Substance/s: Sodium Hydroxide 1kL IBC + Sulphuric Acid 1kL IBC Storage Location: PS2 Oil Store Stored Substance/s: Combustible Liquids (C1/C2) 4.5kL in drums (205L each) + Waste Oil 1.5kL tank + Turpentine 60L in drums (20L each) + Thinners 40L in drums (20L each) Storage Location: PS3 Maintenance Workshop Stored Substance/s: Flammable Liquids (paints, aerosols & thinners) 160L cabinet JBS Australia Pty Limited - Scone Page 22 of 23

23 Storage Location PS4 Hook cleaning Room Stored Substance/s: Corrosive Liquid NOS 820L in drums (4 x 205L each) + Sodium Hydroxide Solution 820L in drums (4 x 205L each) + Caustic Alkali Liquid NOS 410L in drums (2 x 205L each) + Environmentally Hazardous Substance Liquid NOS 100L in containers (5 x 20L each) + Hypochlorite Solution 615L in drums (3 x 205L each) + Corrosive Liquid Acidic Inorganic NOS 615L in drums (3 x 205L each) Storage Location: PS5 Chlorine Dosing Shed Stored Substance/s: Sodium Hypochlorite Solution 1kL IBC Storage Location: PS6 Boiler Room Store Stored Substance/s: Bisulfites Aqueous Solution 410L in drums (2 x 205L each) Storage Location: PS7 Workshop 2 Stored Substance/s: Arcal 50L in cylinders (2 x 23L each) + Acetylene 50L in cylinders (2 x 24L each) + Oxygen 50L in cylinders (2 x 23L each) Storage Location: PS8 Amenities Cleaning Store Stored Substance/s: Sodium Hydroxide Solution 40L containers (2 x 20L each) Storage Location: BATT1 Forklift Recharge Area Stored Substance/s: Sulphuric Acid 10,000kg in batteries (estimated) Storage Location FC1 Cooling Towers Chemical Store Stored Substance/s: Corrosive Liquid Acidic Inorganic NOS 820L in drums (4 x 205L each) + Corrosive Liquid NOS 100L in containers (6 x 15L each) + Toxic Liquid Organic NOS 100L in containers (6 x 15L each) + Hypochlorite Solution 1kL IBC + Corrosive Liquid Acidic Inorganic NOS 820L in drums (4 x 205L each) + Sulphuric Acid 200L in containers (10 x 20L each) Storage Location: PS8 Amenities Cleaning Store Stored Substance/s: Sodium Hydroxide Solution 40L containers (2 x 20L each) Storage Location: PD1 Condenser #1 Dispersal System Stored Substance/s: Toxic Liquid Organic NOS 1kL IBC Storage Location: PD2 Condenser #2 Dispersal System Stored Substance/s: Corrosive Liquid, Acidic, Organic NOS 1kL IBC Storage Location: PD3 Condenser #3 Dispersal System Stored Substance/s: Corrosive Liquid NOS 1kL IBC Storage Location: PD4 Condenser #4 Dispersal System Stored Substance/s: Corrosive Liquid NOS 1kL IBC Storage Location: CS1 Adjacent to Workshop 2 Stored Substance/s: Liquefied Petroleum Gas 972L in cylinders (9 x 108L each) Storage Location: CS3 Adjacent to Workshop 2 Stored Substance/s: Acetylene 192L in cylinders (8 x 24L each) Storage Location: CS4 Adjacent to Workshop 2 Stored Substance/s: Oxygen 184L in cylinders (8 x 23L each) Storage Location: CS5 Adjacent to Workshop 2 Stored Substance/s: Argon 345L in cylinders (15 x 23L each) + Arcal 326L in cylinders (12 x 23L & 5 x 10L each) + Nitrogen 260L in cylinders (10 x 23L & 3 x 10L each) JBS Australia Pty Limited - Scone Page 23 of 23