Annual Environmental Management Report 2016

Transcription

1 Allied Mills Pty Ltd 11-Apr-2017 Annual Environmental Management Report 2016 Allied Mills, Kingsgrove Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

2 AECOM Annual Environmental Management Report 2016 Annual Environmental Management Report 2016 Allied Mills, Kingsgrove Client: Allied Mills Pty Ltd ABN: Prepared by AECOM Australia Pty Ltd 17 Warabrook Boulevard, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T F ABN Apr-2017 Job No.: AECOM in Australia and New Zealand is certified to ISO9001, ISO14001 AS/NZS4801 and OHSAS AECOM Australia Pty Ltd (AECOM). All rights reserved. AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client s description of its requirements and AECOM s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

3 AECOM Annual Environmental Management Report 2016 Quality Information Document Annual Environmental Management Report 2016 Ref Date Prepared by 11-Apr-2017 Adam Plant, Gabriel Wardenburg Reviewed by Ian Richardson Revision History Rev Revision Date Details Name/Position Authorised Signature A 03-Apr-2017 DRAFT Gabriel Wardenburg Principal Environmental Scientist B 07-Apr-2017 DRAFT Gabriel Wardenburg Principal Environmental Scientist Apr-2017 FINAL Gabriel Wardenburg Principal Environmental Scientist Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

4 AECOM Annual Environmental Management Report 2016 Table of Contents 1.0 Introduction Terms of Reference Standards, Performance Measures and Statutory Requirements Environmental Actions Noise Air Quality Stormwater Traffic Landscape Management Waste Management Hazards and Site Safety Analysis of Environmental Monitoring Results Annual Production Monitoring Results Identification of Trends Noise Traffic Monitoring Results Identification of Trends Waste Monitoring Results Identification of Trends Non-Compliance, Incidents and Complaints Non-compliances Recorded during the Current Reporting Period Incidents Recorded During the Current Reporting Period Complaints Received During the Current Reporting Period Recommendations and Action Plan Conclusion References 41 Appendix A Environmental Management Plan A Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

5 AECOM Annual Environmental Management Report 2016 Project Acronyms Acronym AEMR Allied Mills DMS DP&E EMP GRC IEA IHA LGA SEE TMP TSH&E WMP Meaning Annual Environmental Management Report Allied Mills Pty Ltd Deflagration Management Strategy Department of Planning and Environment Environmental Management Plan Georges River Council Independent Environmental Audit Independent Hazard Audit Local Government Area Statement of Environmental Effects Traffic Management Plan Training, Safety, Health and Environment Waste Management Plan Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

6 AECOM Annual Environmental Management Report Introduction This Annual Environmental Management Report (AEMR) has been prepared by AECOM Australia Pty Ltd (AECOM) on behalf of Allied Mills Pty Ltd (Allied Mills). The AEMR provides an overview of environmental activities occurring at the Allied Mills operated Kingsgrove food processing site (the Site), and has been prepared in accordance with Condition 7.1 of the Development Consent DA (as modified) (the Consent). This AEMR covers the period from 1 January 2016 to 31 December The food processing plant was originally expanded in 2001 by Goodman Fielder. The expansion involved the construction of new bulk silos and an additional packing line. In 2002 the Site was purchased by Allied Mills who now manage all site activities undertaken in the manufacture and distribution of a range of grain based baking supplies and food ingredients. The Site is located at Lot 1 DP 20025, 4 The Crescent, Kingsgrove, NSW within the Georges River Council (GRC) Local Government Area (LGA) (refer to Figure 1). This AEMR identifies the environmental standards, performance measures, and statutory requirements which have been established for the site and considers the environmental performance of site activities against these criteria. This report also provides a summary of results recorded in accordance with the Environmental Management Plan (EMP) and other supporting management plans and strategies produced for the site. These include: Noise Management Strategy Air Quality Management Strategy Stormwater Management Strategy Traffic Management Plan Landscape Management Plan Waste Management Plan Finally the AEMR identifies all complaints or incidents of non-compliance recorded during the reporting period and summarises the actions taken to resolve such issues. The information contained within this AEMR has been provided by Allied Mills site management personnel. Figure 1 Site Location Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

7 AECOM Annual Environmental Management Report Terms of Reference Condition 7.1, Schedule 2 of the Consent requires Allied Mills to prepare and submit an AEMR for the approval of the Director-General and Council. Table 1 details the requirements of Condition 7.1 and cross-references the sections of this AEMR containing the requisite information. Table 1 Consent Requirements and Cross-reference to AEMR Section where each requirement is addressed DA Condition Requirement AEMR Cross-reference 7.1 Twelve months after commissioning the food processing plant, and annually thereafter for the duration of the development, the Applicant must submit an Annual Environmental Management Report to the Director-General and the Council. This report must: (a) (b) (c) (d) (e) (f) Identify all the standards, performance measures, and statutory requirements the development is required to comply with. Review the environmental performance of the development to determine whether it is complying with these standards, performance measures, and statutory requirements. Identify all the occasions during the previous year when these standards, performance measures, and statutory requirements have not been complied with. Include a summary of any complaints made about the development, and indicate what actions were taken (or are being taken) to address these complaints. Include the detailed reporting from the Environmental Monitoring Program (see Conditions ), and identify any trends in the monitoring over the life of the project. Where non-compliance is occurring, describe what actions are or will be taken to ensure compliance, who will be responsible for carrying out these actions, and when these actions will be implemented. This AEMR Section 3.0 Section 4.0 and 5.0 Section 6.1 Section 6.3 Section 5.0 Section 7.0 Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

8 AECOM Annual Environmental Management Report Standards, Performance Measures and Statutory Requirements Condition 1.2 of the Consent requires the Applicant to carry out the development in general accordance with the DA and subsequent modifications to the Consent (Notice of Modification dated 17 April 2012), the Statement of Environmental Effects (SEE) prepared for the Site (Benbow Associates, 2001), and the conditions of the Consent issued by the Minister. Under the conditions of the Consent, the Applicant is required to prepare and implement various management plans for the site, as detailed in Table 2. This includes an EMP which specifies relevant statutory requirements and sets standards and performance measures for relevant environmental issues; these are in addition to those identified within the conditions of the Consent. The current EMP has been submitted to the Department of Planning and Environment (DP&E) and includes the following: Noise Management Strategy; Air Quality Management Strategy; Stormwater Management Strategy; Traffic Management Plan; Landscape Management Plan; and Waste Management Plan. The EMP and supporting documents therefore provide the basis for assessing environmental performance of the Site. The EMP also specifically addresses all environmental monitoring requirements and activities in relation to the Site. Table 2 Management Plans Required by Development Consent DA Consent Reference Management Plan Required 3.1 Construction Management Plan 3.3 Construction Safety Study 3.5 Environmental Management Plan Version / Date N/A Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the consent conditions. N/A Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the consent conditions. Final V03.1, 29 March 2017, revised by Allied Mills. Final V03, 17 November 2015, revised by Allied Mills. Final V01, 24 May 2012, prepared by SKM. Approval Status N/A N/A EMP revised (Final V03.1), DP&E will be provided with the document during AEMR submission, as confirmed with DP&E. EMP revised (Final V03), DP&E notified on 25 November Final V01 submitted to DP&E on 25 May Resubmitted to DP&E on 3 June EMP approved by DP&E on 4 August Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

9 AECOM Annual Environmental Management Report Consent Reference Management Plan Required 4.17 Traffic Management Plan 4.26 Waste Management Plan 4.29 Landscape Management Plan Version / Date Appendix E of Environmental Management Plan. Appendix G of Environmental Management Plan. Appendix F of Environmental Management Plan. 5.1 Fire Safety Study Report # 21069FSS, prepared by Environmental Audits of Australia (EAA). 5.2 Deflagration Management Strategy Deflagration Strategy Support, May 2014, prepared by AECOM Australia (AECOM, 2014). 5.3(a) Emergency Plan Revision 1, 17 January 2014, revised by SKM. 5.3(b) Safety Management System 6.1 Environmental Monitoring Program Emergency Plan, 27 August 2012, prepared by SKM. Made up of numerous documents and procedures within the site document database. Section 9.2 of Environmental Management Plan. Approval Status As per Environmental Management Plan. As per Environmental Management Plan. As per Environmental Management Plan. Submitted to NSW DP&E and NSW Fire Brigades on 24 October DP&E Hazard Audit 2015 (DP&E, 2015) noted some recommendations from the DMS report had not yet been closed. Additional evidence was submitted and DP&E confirmed (letter dated 17 December 2015) that outstanding actions had been adequately addressed. Submitted to DP&E on 6 September Resubmitted to DP&E on 29 May Revised and submitted to DP&E on 7 February Approved by DP&E on 8 April Allied Mills submitted a document mapping the contents of its Safety Management System (SMS) against the requirements of Hazardous Industry Planning Advisory Paper (HIPAP) No. 9 (DP&E, 2011a). DP&E approved the SMS mapping document on 28 October As per Environmental Management Plan. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

10 AECOM Annual Environmental Management Report Environmental Actions This section of the report describes the environmental actions that have been carried out during the current annual reporting period (1 January 2016 to 31 December 2016) and what actions are likely to be carried out in the following year. To describe the actions that have been carried out, AECOM has considered the environmental undertakings that the Applicant has committed to fulfil under the EMP and supporting documents, and provided details on the applicant s compliance with these requirements. The tables in the following sections set out the environmental areas of concern and the matters relevant to the implementation of the conditions of consent and or performance measures identified in the EMP and supporting documents. They describe the actions that have been carried out in relation to those matters over the past year, what actions are likely to be carried out in the following year, and illustrate whether the site is currently meeting (or is in progress of meeting) the condition of the Consent, or commitment made in the EMP. The primary method of monitoring for the site is through opportunistic observation and weekly site walk overs which incorporate visual inspection and testing of critical infrastructure. The results of these inspections are summarised in Environmental Inspection Reports which allow for accurate detailing of any major issues or observations made during the walk over. Other monitoring for specific issues (for example, traffic and waste) is undertaken in accordance with the EMP. This detailed monitoring is discussed and analysed in Section 5.0. The overall manufacturing activities on the Site were relatively unchanged from 2015, with no modifications that are considered pertinent to the AEMR. A compliance audit inspection was undertaken by DP&E on 28 May 2015 (DP&E Hazard Audit 2015). The DP&E Hazard Audit 2015 identified a number of hazard related non-compliances and made recommendations in response to these non-compliances. Following this audit, Allied Mills undertook additional actions to address the recommendations as documented in the 2015 AEMR. Items considered to be outstanding from the 2015 AEMR in the 2016 reporting period have been presented in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0. An Independent Environmental Audit (IEA) was undertaken by GHD in 2016 in accordance with the conditions of the Consent which state Within 12 months of commissioning the food processing plant, and every three years thereafter, unless the Director-General directs otherwise, the Applicant must commission and pay the full cost of an Independent Environmental Audit. The previous IEA was prepared in 2013, making the next version due in Any non-compliance reported in the IEA is provided in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0. An Independent Hazard Audit (IHA) was undertaken by GHD in 2016 in accordance with the conditions of the Consent which state Twelve months after the commencement of operations, and every three years thereafter, unless the Director-General directs otherwise, the Applicant must commission and pay the full cost of a comprehensive hazard audit. The previous IHA was prepared in 2013, making the next version due in Any non-compliance reported in the IHA is provided in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

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12 AECOM Annual Environmental Management Report Noise Table 3 reports on environmental actions that have been carried out during the reporting period in relation to noise. It is anticipated that the relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the Noise Management Strategy. Table 3 Summary of Noise Management Actions Undertaken during 2016 Consent Condition / Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition or Commitment? Consent Condition 4.5 Noise emissions from operations at the site must not exceed the following criteria: Three noise complaints were made during the reporting period. A noise audit was undertaken in January 2016 involving attended noise measurement relating to the blower plant room that showed the noise emission contribution from the blower plant room exceeded the acceptable noise criteria at night at a nearby residence. Corrective actions were instigated, specifically the installation of an acoustic louvre on the blower plant, and attended noise monitoring has since been completed and reported that the site was compliant with noise requirements as per the sites conditions of consent. Further details are provided in Section 5.2. The noise audit identified a potential exceedance at nearby residences. Noise attenuation was installed in September 2016 and subsequent noise monitoring confirms compliance with conditions of the Consent. Consent Condition 6.3 Should noise complaints be received, the Director-General may direct the Applicant to commission and pay the full cost of a noise audit. Should any noise audit demonstrate an exceedance of the project specific residential noise limits outlined in Condition 4.5, the Applicant shall employ mitigation measures to reduce noise impacts from the site, to the satisfaction of the Director-General. Three noise complaints were made during the reporting period and a noise audit was commissioned in January The noise audit identified a potential exceedance at nearby residences. Noise attenuation was installed in September 2016 and subsequent noise monitoring confirms compliance with conditions of the Consent. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

13 AECOM Annual Environmental Management Report Consent Condition / Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition or Commitment? EMP Performance Measure (Table 4-1) Noise No nuisance noise will be emitted from the Kingsgrove site. Three noise complaints were made during the reporting period and a noise audit commissioned. Noise attenuation was installed in September 2016 and subsequent noise monitoring confirms compliance with conditions of the Consent. Noise management measures are implemented at the site. The production area and processing equipment are fully enclosed within existing buildings, to minimise noise emissions from site operations. Drivers are instructed to avoid using compression braking and hard acceleration when on the identified heavy vehicle haulage route for the Site. Three noise complaints were made during the reporting period. Noise attenuation was installed in September 2016 and subsequent noise monitoring confirms compliance with conditions of the Consent. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

14 AECOM Annual Environmental Management Report Air Quality Table 4 reports on environmental actions that have been carried out during the current reporting period in relation to air quality. It is anticipated that the relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the Air Quality Management Strategy. Table 4 Summary of Air Quality Management Actions Undertaken during 2016 Consent Condition / Performance Measure Consent Condition 4.12 Consent Condition 4.13 Consent Condition 4.14 Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Alarms and shut off valves shall be installed on silos to prevent overfilling. Dust emissions from equipment must comply with the Clean Air (Plant and Equipment) Regulation Emissions from vehicles associated with the site must comply with the Clean Air (Motor Vehicles and Motor Vehicle Fuel) Regulation Alarms and cut off valves were installed on the silos prior to commissioning. During the reporting period these systems were tested periodically and maintained to ensure correct operation, with two incidents noted. A high level alarm did not activate causing 150+ litres of oil to overflow from the oil silo. There was no spill to drains or external to site. This spill was contained in the oil silo room. A suction blower stopped due to a silo being full, however the full signal did not alert outside, allowing the transfer pipe to block and flour to spill on the driveway. The spill was contained on site however the incident was logged due to the potential to discharge into drains. Vehicles and equipment exhausts were visually monitored (periodically) to ensure that release of black/white smoke did not exceed 10 seconds. Vehicles and equipment exhausts were visually monitored (periodically at entry onto Site) to ensure that release of black/white smoke did not exceed 10 seconds. A preventative maintenance system for all plant and machinery is implemented to ensure vehicles associated with the Site comply with these guidelines. Meeting Condition or Commitment? Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

15 AECOM Annual Environmental Management Report Consent Condition / Performance Measure Consent Condition 4.15 Consent Condition 4.16 EMP Performance Measure (Table 4-1) Dust Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 All activities in or on the premises must be carried out in a manner that will minimise the generation, or emission from the premises, of wind-blown or traffic generated dust using the measures proposed in the SEE. All areas in or on the premises must be maintained in a manner that will minimise the generation, or emission from the premises, of wind-blown or traffic generated dust, using the measures proposed in the SEE. No visible dust or odours noted leaving the Kingsgrove site. The majority of plant / equipment are contained within enclosed buildings to reduce the possibility of dust emissions. Trafficable areas onsite are sealed to reduce exposure to dust and site speed limits are enforced. Landscaping is in place in areas that have not been sealed. No air quality incidents or complaints were recorded during the reporting period. Meeting Condition or Commitment? Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

16 AECOM Annual Environmental Management Report Stormwater Table 5 reports on environmental actions that have been carried out during the current reporting period in relation to stormwater. It is anticipated that the relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the Stormwater Management Strategy. Table 5 Summary of Stormwater Management Actions Undertaken during 2016 Consent Condition / Performance Measure Consent Condition 4.6 Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 A spill tank must be placed beneath coupling points of the edible oil tanker and the above ground edible oil tank. Occasional spot checks confirmed spill trays were used on trucks in accordance with the stormwater management strategy. Consent Condition 4.7 Tankers supplying edible oil must use brake interlocks. Brake interlocks are a condition of entry to the site for edible oil tankers. Consent Condition 4.8 Consent Condition 4.9 EMP Performance Measure (Table 4-1) Stormwater Bunding must be provided around the edible oil tank, with a minimum capacity of 110% the volume of the tank. Stormwater isolation valves must be installed at all stormwater exit points from the site. No pollution of nearby waterways. The bund capacity and condition was checked during weekly visual inspection activities. The correct function of isolation valves was checked regularly. Stormwater pits were checked weekly during routine visual inspections and maintenance undertaken when necessary (e.g. removal of leaves and debris). No water pollution incidents or complaints were recorded during the reporting period. Meeting Condition or Commitment? Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

17 AECOM Annual Environmental Management Report Traffic Table 6 reports on environmental actions that have been carried out during the current reporting period in relation to traffic. It is anticipated that the relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the Traffic Management Plan. Table 6 Summary of Traffic Management Actions Undertaken during 2016 Consent Condition / Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition or Commitment? Consent Condition 4.17 The Applicant must prepare and implement a Traffic Management Plan for the development. The Plan must: a. Describe the routes which will be used by trucks associated with the development; b. Outline the hours during which trucks will operate in the vicinity of the site; c. Indicate the average and maximum number of daily and weekly truck movements which will be associated with the proposed development; d. Describe in detail what measures and procedures will be implemented to: - Minimise the number of trucks which will be used to transport goods; - Minimise noise and vibration associated with truck traffic; - Ensure tucks travel in a safe manner; - Minimise road damage; - Minimise air pollution from exhaust; and - Record and respond to complaints regarding traffic. e. Incorporate monitoring to ensure the requirements of the Traffic Management Plan are being met (refer to Condition 6.4). A Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March The plan was prepared as per requirements of consent condition The Environmental Management Plan Revision 3.1, including the Traffic Management Sub-Plan, is provided in Appendix A. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

18 AECOM Annual Environmental Management Report Consent Condition / Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition or Commitment? Consent Condition 4.19 The Applicant shall review and, where necessary, update the Traffic Management Plan annually as part of the AEMR, and also as directed by the DG. Traffic Management Plan included in Revision 3.1 of the Environmental Management Plan dated 29 March A review of traffic conducted by a Level 3 RMS safety auditor has been undertaken on and around the Kingsgrove site. Allied Mills are waiting on the final document to be provided, however this reviews turning circles, pedestrian access around site and traffic flow. Consent Condition 6.4 The Applicant must monitor compliance with the Traffic Management Plan described in Condition Monitoring must occur within three months of commissioning the mixing plant, and every six months thereafter. All site activities were undertaken in accordance with the Traffic Management Plan during the reporting period. Records are kept of delivery and dispatch vehicles that are on site to inform scheduling activities. Traffic monitoring data is presented in Section 5.3 of the AEMR along with an analysis of the results and comparison to historical data to identify any evident trends. EMP Performance Measure (Table 4-1) Traffic No notable impact to the surrounding community from traffic generated at the Kingsgrove site. No traffic related incidents or complaints occurred in the reporting year. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

19 AECOM Annual Environmental Management Report Landscape Management Table 7 reports on environmental actions that have been carried out during the current reporting period in relation to land management. It is anticipated that the relevant conditions and commitments will continue to be met in the next reporting period and that site actions will continue to be carried out in accordance with the Landscape Management Plan. Table 7 Summary of Landscape Management Actions Undertaken during 2016 Consent Condition / Performance Measure Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Meeting Condition or Commitment? Consent Condition 4.29 The Applicant must prepare and implement a detailed Landscape Management Plan for the development. This plan must: Describe in detail how the site will be landscaped, including the location and species of all planting; and Explain how this landscaping will be managed and maintained over time. Landscaping activities were undertaken in accordance with the Landscape Management Plan. Landscaping was managed and maintained by a contractor on a fortnightly basis. Regular maintenance activities undertaken during the current reporting period included: Slashing / mowing of grassed areas; Trimming /shaping of shrubs; Collection of fallen branches and debris; and General maintenance works as required. Approved by DP&E on 4 August 2014 EMP Performance Measure (Table 4-1) Aesthetic Impacts / Landscaping No aesthetic impact to the surrounding community. No landscaping related complaints were recorded during the reporting period. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

20 AECOM Annual Environmental Management Report Waste Management Table 8 reports on environmental actions that have been carried out during the current reporting period in relation to waste management. Waste generated as a result of site activities is managed in accordance with the Waste Management Plan. Allied Mills will continue to review the waste requirements of the site on an annual basis and update the Waste Management Plan if required. Table 8 Summary of Waste Management Actions Undertaken during 2016 Consent Condition / Performance Measure Consent Condition 4.26 EMP Performance Measure (Table 4-1) Waste Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 The Applicant must prepare and implement a Waste Management Plan for the development in consultation with Council. This plan must describe in detail the waste management system, including: a. The types and quantities of waste which will be generated at the site; and b. How waste will be stored on-site, transported, and disposed of off-site. All waste to be correctly stored on site and disposed of by an appropriately licenced contractor. A Waste Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March The plan was prepared as per requirements of consent condition The Environmental Management Plan Revision 3.1, including the Waste Management Sub-Plan, is provided in Appendix A. No waste related incidents or complaints were recorded during the reporting period. Meeting Condition or Commitment? Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

21 AECOM Annual Environmental Management Report Hazards and Site Safety Table 9 reports on environmental actions that have been carried out during the current reporting period in relation to hazard management. Hazards and site safety are currently managed by the site Deflagration Management Strategy (DMS) and the Emergency Management Plan. The DMS Report covers the management of dusts, control systems, extraction systems and fail-safe systems employed, whilst the Emergency Management Plan details emergency procedures for the site. Table 9 Summary of Hazard Management Actions Undertaken during 2016 Consent Condition / Performance Measure Consent Condition 5.4 Consent Condition 8.3 Relevant Condition, Performance Measure or Safeguard Actions carried out in 2016 Dangerous Goods storage must be in accordance with the Australian Dangerous Goods Code, relevant Australian Standards, and WorkCover requirements. Spill clean-up kits and procedures must be made available and used in the event of a spill. Twelve months after the commencement of operations, and every three years thereafter, unless the Director-General directs otherwise, the Applicant must commission and pay the full cost of a comprehensive hazard audit. A WorkCover Notification of Hazardous Chemicals has been completed for the Site (NDG035076, 13 February 2015). Should any significant changes occur to the quantity, location or manner of storage of the relevant chemicals, WorkCover will be notified of the amendment. Spill kits are stocked and provided at the edible oils station. GHD undertook an Independent Hazard Audit during the reporting period (2016a). The findings of the audit and recommendations made are provided in Section 6.1 and Section 7.0 of this AEMR. Meeting Condition or Commitment? Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

22 AECOM Annual Environmental Management Report Analysis of Environmental Monitoring Results In accordance with Schedule 2, Condition 7.1(e) of the Consent, this section presents an analysis of the detailed environmental monitoring undertaken during the reporting period and identification of any trends in the results compared to previous years. In order to compare current monitoring results against historical results, only environmental aspects with specific, quantified monitoring results are included in this section (noise, transport and waste monitoring). Other environmental aspects included as part of the Environmental Monitoring Program (air quality, stormwater and landscaping) do not have quantifiable results and a review of the Site s performance against these aspects is provided previously in Section Annual Production Monitoring Results Annual production is limited under Schedule 2, Condition 1.3 of the Consent to 150,000 tonnes per annum. Production output remained within the approved limits during the reporting period at 58,912 tonnes and is presented for each month in Table 10. Table 10 Production output during the reporting period Month Monthly production (tonnes) January ,917 February ,198 March ,133 April ,036 May ,918 June ,363 July ,703 August ,453 September ,789 October ,375 November ,693 December ,334 Total 58, Identification of Trends A comparison of annual production for the current reporting period against historical records is provided in Table 11 and shown graphically in Figure 2. Total annual production has decreased marginally compared to 2015 and is approximately 15% less than the 2013 production. Overall production trends however remain relatively consistent and well within the approved limit of 150,000 tonne per annum for the site. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

23 AECOM Annual Environmental Management Report Table 11 Historic Annual Production Volumes Year Total annual production , , , ,912 Figure 2 Historic Annual Production Volumes 5.2 Noise Noise monitoring is required to be undertaken upon receipt of a substantiated community complaint regarding noise. The AEMR captures both any outstanding resolution of noise complaints from the previous reporting year as well as noise complaints that occur in the reporting year. Further details of actions taken are detailed in Section 4.1. With respect to previous reporting year noise complaint resolution, in October 2015 a noise complaint was made regarding an intermittent noise heard by nearby residents over the previous year. Allied Mills commissioned an external noise audit which was undertaken in January 2016, involving attended noise measurement relating to the blower plant room. Attended noise measurements showed that the noise emission contribution from the blower plant room exceeded the acceptable noise criteria at night at nearby residence. Noise control recommendations were made, providing various options. Acoustic louvres were chosen as the control measure and installed on the 29 September During the fabrication of the louvres temporary measures were taken, specifically the temporary covering of the plant vent. Updates of the noise assessment and actions were communicated to DP&E on the 26 August and 21 November Three noise complaints were registered in the reporting year as detailed below. The first was registered on the 5 January 2016 when council advised they had received a complaint from a community member. The complaint was associated with the previous noise issue identified in As previously detailed for the 2015 complaint, a noise impact assessment was prepared and actions taken to resolve the issue, specifically the temporary covering of an identified vent and subsequent installation of an acoustic louvre. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

24 AECOM Annual Environmental Management Report The second was registered on the 23 September 2016 when council advised they had received a complaint from a community member from a noise occurring on the 10 September A review of site operations identified that a vent cover previously installed to minimise noise was temporarily removed at the time of the complaint due to over-heating issues. At the time of the complaint an acoustic louvre was still being fabricated and was subsequently installed on the 29 September The third noise complaint was registered on the 28 November 2016 when council advised they had received a complaint from a community member of a grinding noise especially at night. The noise was similar to that experienced in January and started again in September, around the time of the previous complaint relating to the removal of the vent cover. Since this time an acoustic louvre had been installed. Noise monitoring was undertaken between the 27 and 31 of October at residential receivers. The monitoring reported that the site was compliant with noise requirements as per the sites conditions of the Consent. A further partition was installed in the blower room which alleviated noise issues, as confirmed by the affected resident. 5.3 Traffic Monitoring Results The site records the total number of truck movements each month, from which weekly and daily truck movements can be extrapolated. Total monthly truck movements and average weekly / daily truck movements for the reporting period are presented in Table 12 along with the monthly production data. At the previous request from the DP&E an estimate of potential traffic movements at the full approved production capacity of 150,000 tonnes per annum was undertaken. It is noted that traffic generation is not directly correlated with production, as deliveries of raw materials and final product may differ depending on the product. However an estimate of potential maximum truck movements has been calculated based on the traffic and production data for the 2016 reporting period. This was estimated by calculating the average of the monthly truck/tonne, and multiplying this by the full production volume of 150,000 tonnes. Potential maximum truck movements at full production capacity are included in Table 12 and Table 13. It is noted that traffic projections were presented in the Traffic Impact Statement (Rhodes Thompson Associates, 2001) prepared as part of the SEE for expansion of the Site. The maximum number of trucks per day was projected to be 97 during the day and afternoon shifts and 12 during the night shift, with a total of 109 daily truck movements. This equates to a total of 763 truck movements per week, 3,315 truck movements per month, and 39,785 truck movements per annum. These projections are also shown in Table 12 and Table 13 for comparison with the current year s reporting data. It is also noted that the Consent for the project does not specify a limit on truck movements, however Condition 4.17 requires the Traffic Management Sub-Plan (TMP) to indicate the average and maximum number of daily and weekly truck movements which will be associated with the proposed development. The Traffic Management Sub-Plan included in Revision 3.1 of the Environmental Management Plan dated 29 March 2017, provided in Appendix A, includes the same traffic values reported in the SEE as provided above. For the purposes of this AEMR, truck movements during the reporting period have been compared to the potential maximum truck movements at full production capacity calculated based on the 2016 reporting data. The Traffic Management Sub-Plan has been revised in the current period to incorporate projected maximum traffic volumes. Once the revised TMP is approved (by DP&E), future AEMRs would report against these projected maximum traffic volumes. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

25 AECOM Annual Environmental Management Report Table 12 Truck movements during the reporting period Month Projected maximum predicted in Traffic Impact Statement and Traffic Management Sub-Plan Potential maximum at full production, based on 2016 data Total monthly truck movements Average weekly truck movements Average daily truck movements Monthly production (tonnes) 3, ,000 (Annual) 1, ,000 (Annual) January ,917 February ,198 March ,133 April ,036 May ,918 June ,363 July ,703 August ,453 September ,789 October ,375 November ,693 December ,334 Total 58, Identification of Trends Historically, traffic movements recorded as part of day to day operations have been limited to movements generated as a result of product delivery and dispatch; in accordance with the Traffic Management Plan (TMP). During review of the TMP (undertaken during the current reporting period) the distinction between product loads bound for the warehouse and bulk tanker loads (bound for bulk delivery) has been clarified. Consequently monitoring activities have been expanded beyond product dispatch to reflect all production related traffic movements to and from site. A comparison of traffic monitoring data for the current reporting period against historical traffic monitoring results is provided in Table 13 and is shown graphically in Figure 3. The total number of annual truck movements recorded increased during the current reporting period, however total annual production was lower. Whilst the increase in recorded truck movements relates partially to expanded monitoring efforts, product movements accounted for a high proportion (4,966 of 6,578) of movements identified in Table 13. This highlights the fact that traffic generation does not directly correlate to production levels and may fluctuate depending on market demand and supply chain requirements. Traffic movements remain well below the projected maximum traffic movements estimated for a full production scenario, as shown in Figure 3. The potential average monthly value provided in the figure is calculated from the potential annual value from the below table divided by twelve months. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

26 AECOM Annual Environmental Management Report Table 13 Comparison of historical truck monitoring data Year Projected maximum predicted in Traffic Impact Statement and Traffic Management Sub-Plan Potential maximum at full production, based on 2016 data Annual total truck movements Average weekly truck movements Total annual production 39, ,000 16, , , , , , , , , ,912 Figure 3 Comparison of historical monthly truck monitoring data for most recent three years Note: The Traffic Impact Statement (2001) predicted a maximum of 3,315 trucks per month Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

27 AECOM Annual Environmental Management Report Waste Monitoring Results Allied Mills continues to source recycled options where possible for the removal of waste from the Site. All paper waste and putrescible waste is removed from site and recycled. Waste streams include the following: General Waste (putrescible) is the waste generated from the production process and mainly comprises edible (for animals) material from flush outs through cleaning. This material is recycled by being sold to farmers to feed animals. General Waste (non-putrescible) includes general site waste and paper waste which is recycled. These recyclables and wastes are removed off site by licensed contractors. Hazardous Waste includes small quantities of chemical waste generated from analytical testing in the test baking/laboratory area. These wastes are removed off site by a licensed contractor. Liquid Waste is in the form of oil used in food manufacturing. This is generated in small quantities during overflow from receival or transfer processes. This is collected by an oil recycling company. Special waste generated from plant maintenance and removed from site by a licenced contractor. There continues to be no restricted waste generated at the Site. Monthly waste quantities generated for each waste stream during the current reporting period are provided in Table 14. The proportion of General Waste (non-putrescible) that was recycled or disposed of to landfill for the current reporting period is provided in Table 15. Average weekly quantities provided in the table are from the Waste Management Sub-Plan (WMP) as provided in Revision 3.1 of the Environment Management Plan dated 29 March 2017, provided in Appendix A. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

28 AECOM Annual Environmental Management Report Table 14 Monthly waste quantities generated during the reporting period Month Waste Stream General Waste (putrescible) (tonnes) General Waste (nonputrescible) (tonnes) Hazardous Waste (litres) Liquid Waste (litres) 2 Special Waste Monthly quantities from predictions in WMP 1 January February March April L 3 0 May June July August September October November December Restricted Waste Total Waste Management Sub-Plan as provided in Revision 3.1 of the Environment Management Plan provides indicative weekly quantities, from which these monthly quantities have been calculated. 2 Liquid Waste predictions have been converted from kg to litres using a specific gravity of Old machine oil from the maintenance department during clean-up Table 15 Proportion of General Waste (non-putrescible) recycled or disposed of to landfill during the reporting period Parameter Non-recyclable (disposed of to landfill) General Waste (non-putrescible) Recycled Total (tonnes) Percentage of total 42.9% 57.1% Average weekly (tonnes) Identification of Trends A comparison of annual waste quantities for the current reporting period against historical results is provided in Table 16. The quantity of General Waste (putrescible) generated at the Site has increased each year since 2012, with 2016 having the highest annual quantity to date, however this remains lower than the Waste Management Sub-Plan predictions. There are a number of historic factors which have influenced this trend within previous reporting periods, including: A change to the supply method for some ingredients (from bulk tanker to bags which results in an increase in paper waste for recycling). It is hoped that this supply will revert to bulk tanker in the future but the timing of this is not certain. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

29 AECOM Annual Environmental Management Report Commissioning and production on the Line 3 mixing and packing line (which has involved an increase in the number of bagged ingredients used on site during the commissioning process). Some re-bagging of finished product to assist the business resulted in approximately 36,000 bags being added to recycled waste. Wastage data has been obtained directly from waste collectors allowing for more accurate data to be collected. During the current reporting period a review of operations resulted in diversification of products produced and other process improvements; prompting adaptation of the site inventory. The type and quantity of stock held on site was optimised, with surplus materials contributing to general and liquid waste streams. Allied Mills continues to investigate new recycling initiatives aimed at recycling plastics, pallets and reducing waste generated through the current bagging process. Of the general waste (non-putrescible) generated on site during the reporting period, approximately 43% was disposed of to landfill and 57% was recycled. The quantity of Hazardous Waste generated on Site has continued to decrease since 2013, with 2016 having the lowest annual quantity to date and below the quantity predicted in the Waste Management Sub-Plan. The quantity of Liquid Waste generated at the Site has also varied in the last four years with no apparent trend. The quantities of Liquid Waste removed off site in 2013 and 2014 were higher than the predictions made in the Waste Management Sub-Plan, whilst 2015 and 2016 were below and 2014 levels were a result of 3 isolated incidents, the outcomes of which are addressed in previous AEMR periods. Liquid waste is removed from site by licenced subcontractor and recycled in accordance with industry best practice. Table 16 Comparison of historical waste monitoring data Year Waste Stream General Waste (putrescible) (tonnes) General Waste (nonputrescible) (tonnes) Hazardous Waste (litres) Liquid Waste (litres) 2 Special Waste Annual quantities from predictions in WMP , , Restricted Waste , Waste Management Sub-Plan as provided in Revision 3.1 of the Environment Management Plan provides indicative weekly quantities, from which these annual quantities have been calculated. 2 Liquid Waste predictions have been converted from kg to litres using a specific gravity of Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

30 AECOM Annual Environmental Management Report Non-Compliance, Incidents and Complaints Under Condition 8.1 of the Consent, the proponent is required to notify the DP&E of any accident or potential incident with actual or potential off-site impacts on people or the biophysical environment. A summary of non-compliance is required under Condition 7.1 (f) which states Where non-compliance is occurring, describe what actions are or will be taken to ensure compliance, who will be responsible for carrying out these actions, and when these actions will be implemented. General responsibilities and actions for responding to non-compliances are detailed in the EMP. These include: The Training, Safety, Health and Environment (TSH&E) Coordinator is to be informed immediately; The TSH&E Coordinator must identify an appropriate corrective action; The TSH&E Coordinator must communicate the appropriate corrective action to the Site Manager; The Site Manager must then implement the corrective action or delegate authority over the action to an appropriate person; Any non-compliance and the actions taken are to be recorded and included in the AEMR; and If the non-compliance constitutes a pollution event that may cause material environmental harm, the emergency response procedure will be followed and the appropriate government authorities will be notified immediately. All incidents and complaints are recorded in the Incident Reporting Database: The date and time, of the complaint or incident; The means by which the complaint or incident was made; Any personal details that were provided, or; Any action(s) taken by the Allied Mills Kingsgrove in relation to the complaint or incident, including any follow up contact with complainant/reporter; and If no action was taken by Allied Mills Kingsgrove in relation to the complaint or incident, the reason(s) why no action was taken. 6.1 Non-compliances Recorded during the Current Reporting Period The Independent Hazard Audit 2016 and Independent Environmental Audit 2016 identified noncompliances for the reporting period. These non-compliances are summarised in Table 17, together with any non-compliances reported for the site not listed in such documents. Recommendations made and the actions taken by Allied Mills to rectify these non-compliances are provided in Section 7.0. Table 17 Summary of Non-compliances for the Site Details of Non-Compliance Audit Finding General non-compliances not reported in audits, reports or similar No general non-compliances for 2016 AEMR Independent Hazard Audit 2016 NC5.1, 3.4.5/3, The clearance space around the Fire Indicator Panel does not comply with the requirement of AS Obtain advice from the Fire Brigade, the local Council or an independent fire engineer to determine whether the reduction in spacing compromises access to the FIP panel. Implement recommendations from the advice. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

31 AECOM Annual Environmental Management Report Details of Non-Compliance Audit Finding Independent Environmental Audit 2016 Compliance with the Condition of Approval requirements 3.6 The Applicant must ensure that a copy of the Environmental Management Plan is submitted to Council and is publicly available. The original Environmental Management Plan was sent to the Council via in A revised Environmental Management Plan, Revision 3.1, was sent to Council on 29 March The plan was not publically available on the Allied Mills web-site during the audit period. However, it was loaded onto the Allied Mills website following the IEA in (d). The Applicant must prepare and implement a Traffic Management Plan for the development The Applicant must develop the Traffic Management Plan in consultation with the RTA and Council Trucks servicing the site during construction and operations must not park on The Crescent at any time The Applicant shall implement the recommendations of the Traffic Operations Assessment prepared by Sinclair Knight Merz provided in support of DA MOD 2, and dated 7 November 2011, specifically: (a) parking restriction signage in the vicinity of Gate A on the Crescent; No further action is required to address this noncompliance. The plan does not detail what measures are used to Minimise the number of trucks which will be used to transport goods. A Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March 2017, and provided in Appendix A. Section 5 of the Traffic Management Sub-Plan details the measures to minimise the number of trucks. A Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan. The revised plan was submitted to the RMS on the 29 March Feedback was received from the Roads and Maritime Services (formerly RTA) regarding the Traffic Management Plan indicating that no further input was required as the Crescent and surrounding streets en-route to the site are regulated by Council. Trucks accessing the site were monitored by video camera to monitor and prevent parking on The Crescent. It is noted that Allied Mills received a traffic complaint in the previous reporting year (2 December 2015) when an external utility provider (unrelated to Allied Mills) shutdown part of The Crescent, without notice. Allied Mills spoke to the driver and informed his company that he was no longer welcome to deliver goods to the Site. No further action is required to address this noncompliance Advanced signage has been added to the entrance at Gate A and the angle of the existing traffic light head was modified to improve the sightline for incoming drivers. Allied Mills submitted a request for the carriageway centre-line and No Parking signage to the Georges River Council. However the Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

32 AECOM Annual Environmental Management Report Details of Non-Compliance (b) a carriageway centre-line in the vicinity of Gate A; and (c) advance signage or a secondary traffic light head in the vicinity of Gate A, in consultation with Council, and to the satisfaction of the Director-General, within 6 months of the approval of DA MOD The Applicant must prepare and implement a detailed Environmental Monitoring Program for the development in consultation with the EPA. Compliance with the SEE requirements Audit Finding Council advised on 24 July 2013 that they did not support the application. This requirement was addressed in the Allied Mills Kingsgrove - Environmental Management Plan (SKM, V03, 17 November 2015) It is noted that the Environmental Management Plan was approved by DPE however the EPA was not consulted in the development of the environmental monitoring program It is noted that the site surrendered its Environmental Protection Licence in 2001 hence the EPA no longer regulates this premises. 14. It is further recommended that the site will develop an environmental management system (EMS). The EMS should be developed with the guidance of the ISO series of standards and should include but not be limited to: a) Environmental Management Plan (EMP) b) Emergency Plan c) Fire Manifest d) Training Program Compliance with the request for modifications requirements The site does not have a specific EMS, however the site does have in place the following documents that address each of the items raised in the SEE: Environmental Management Plan (EMP) Emergency Plan Fire Manifest Training Program 6. It is recommended that parking restrictions are put in place in the vicinity of the access to prohibit parking during the delivery hours specified in the Traffic Management Plan, i.e. 6.30am to 8.00pm. Furthermore, centre line markings could be introduced to ensure vehicles travelling northbound on The Crescent do not cross into the opposite carriageway and occupy the space required for vehicles exiting the site. The recommendations of the audit were submitted to Council for consideration but ultimately not endorsed based on Council s consideration of the existing traffic environment. As these recommendations affect a public road Council endorsement is required to support any further action. For site bound traffic, parking restrictions are implemented in accordance with the Traffic Management Plan in the vicinity of the access to prohibit parking during the delivery hours (i.e. 6.30am to 8.00pm). Advanced signage has been erected at the site entrance advising operators not to que in the driveway. 7. Re-align the existing pedestrian route along the northern edge of the site, resulting in one less crossing of the vehicular route and greater visibility for drivers to pedestrians. This recommendation is relative to both one and twoway traffic movements; There is no exit from Gate B in accordance with the TMP. Allied Mills advised that realignment of the pedestrian route was considered however it would result in the loss of parking places and would not necessarily improve pedestrian safety on the site. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

33 AECOM Annual Environmental Management Report Details of Non-Compliance Audit Finding A review of traffic conducted by a Level 3 RMS safety auditor has been undertaken on and around the Kingsgrove site. Allied Mills are waiting on the final document to be provided, which reviews turning circles, pedestrian access around site and traffic flow. 7. Introduce parking restrictions in the vicinity of Gate A which prohibits vehicles parking between 6.30am and 8.00pm, when delivery vehicles enter the site. In addition, consideration should also be given to the introduction of a carriageway centre line at these locations. These measures are relative to both one and two-way traffic movements; Details of a shared pedestrian zone have been included in the TMP based on the preliminary findings of the traffic review. For site bound traffic, parking restrictions are implemented in accordance with the Traffic Management Plan in the vicinity of the access to prohibit parking during the delivery hours (i.e. 6.30am to 8.00pm). Advanced signage has been erected at the site entrance advising operators not to que in the driveway IEA Recommendation Request for Modification - 7. Allied Mills to confirm its finalised approach to pedestrian management with DP&I. ISE Air quality standards and calibration requirements be formally recorded: Ensure calibration method is appropriate; suggest that written advice is sought and presented for the next audit. Ensure that during maintenance calibration is conducted regularly (e.g. at every maintenance instance if this is deemed appropriate) and recorded. This could be done by adding a calibration point to the maintenance sheet that states the date, confirms calibration was conducted and the result. DP&E Audit 2015 N1. Some recommendations from the most recent IHA (September 2013) have not been closed. Open. Allied Mills advised that realignment of the pedestrian route was considered however it would result in the loss of parking places and would not necessarily improve pedestrian safety on the site. A review of traffic conducted by a Level 3 RMS safety auditor has been undertaken on and around the Kingsgrove site. The outcomes of the review have informed the Traffic Management Plan and a shared pedestrian zone has been adopted as a result. Closed Calibration of the particulate monitors was undertaken in December 2013 however a calibration point was not added to the maintenance sheet. It is noted that the Site is taking practicable measures to prevent or minimise air. Clarification was provided to DP&E on 30 September 2016 and endorsed by DP&E representative on 9 th December Maintenance and calibration procedures have been included in the maintenance schedule for the site. The Proponent should implement all outstanding recommendations from the most recent IHA. An action plan should be submitted to the Department to detail how each outstanding Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

34 AECOM Annual Environmental Management Report Details of Non-Compliance Audit Finding recommendations was closed. An IHA was undertaken by GHD in Any non-compliance reported in the IHA is provided in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0. Finding is considered to be closed. N2. The most recent IHA was carried out in September This audit was undertaken by AECOM and included 17 recommendations. At the time of the site inspection in May 2015, the audit report had not been fully accepted by the Department for the following reasons: Insufficient information was provided making it difficult to establish which operations and elements of the SMS had been audited. The report did not include information on changes that had occurred since the 2010 IHA. The report did not include the status of each recommendation from the 2010 IHA. The report did not acknowledge or provide update on the fact that the 2010 IHA was conditionally approved by the DP&E subject to provision of additional information. N3. Some recommendations from the most recent Deflagration Management Strategy Report (December 2013) have not been implemented. Failure to implement the approved DMS is an action carried over from the findings of the DP&E s 2013 compliance audit. N4. The development consent requires that a document setting out a comprehensive SMS be submitted to the DP&E. Following the 2013 compliance campaign, Allied Mills submitted a document that mapped the contents of their SMS against the requirements included in HIPAP No. 9. The SMS map has not been approved by the DP&E. An IHA was undertaken by GHD in Any non-compliance reported in the IHA is provided in Section 6.1 of this AEMR, with the actions undertaken by Allied Mills discussed in Section 7.0. Finding is considered to be closed. The Proponent should implement all outstanding recommendations from the most recent Deflagration Management Strategy Report (Appendix C). An action plan should be submitted to the Department to detail how each outstanding recommendations was implemented. Additional evidence was submitted and DP&E confirmed (letter dated 17 December 2015) that outstanding actions had been adequately addressed. Allied Mills should submit additional information to the DP&E to demonstrate compliance with Condition 5.3(b) of the Consent. Allied Mills submitted a document mapping the contents of its Safety Management System (SMS) against the requirements of Hazardous Industry Planning Advisory Paper (HIPAP) No. 9 (DP&E, 2011a). DP&E approved the SMS mapping document on 28 October Incidents Recorded During the Current Reporting Period A summary of the incidents reported during the current reporting periods is provided below in Table 18. Complaints are not categorised as incidents for the purposes of this report section; complaints are discussed in Section 6.3. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

35 AECOM Annual Environmental Management Report Table 18 Summary of Incidents for the Site Date Details Action Taken February 2016 High level alarm did not activate which caused 150+ litres of oil to overflow from silo. There was no spill to drains or external to site. Contained in oil silo room. July 2016 August 2016 September 2016 November 2016 Minor oil spill contained to site. Manual handling error of a small calibration oil container while exiting room. Flour spill on driveway. Suction blower stopped due to the silo being full, however the full signal did not alert outside, allowing the transfer pipe to block up. When the pipe was disconnected from the truck the residual pressure pushed flour out and onto the driveway. Exhaust vent leaking small amount of dust onto driveway. Fire alarm false alert. Sensor was possibly set off by dust as there was no fire. Fire brigade attended site. Spill contained on site however incident logged as potential to discharge into drains. Overflow alarm maintenance undertaken. Staff involved in incident have been retrained in manual handling procedures. Spill contained on site however incident logged as potential to discharge into drains. Full level alarm maintenance undertaken. Filter bag has been placed on the unit. Fire brigade arrived checked but couldn t find the faulty sensor. Reset zone back to normal and fire brigade chief gave the ok to return to work. 6.3 Complaints Received During the Current Reporting Period Three complaints were recorded for the Site during the current reporting period. One complaint was associated with that registered in October and have been progressed together. A summary of complaints received relevant to the ongoing operation of the site, along with the action taken by Allied Mills staff to address any issues, is shown in Table 19. Table 19 Summary of Historical Complaints Received for the Site Date Complaint Received Action Taken 28 November September 2016 Noise: Complaint lodged with Council regarding grinding noise, especially at night. Noise: Complaint lodged with Council regarding a noise from the site. Site staff identified that the cover placed on the blower vent previously to attenuate noise was temporarily removed due to heating issues. Noise monitoring was undertaken between the 27 and 31 of October at residential receivers. The monitoring reported that the site was compliant to noise requirements as per the sites conditions of the Consent. An additional partition was installed in the blower room which eliminated this issue (based on feedback from the affected resident). An acoustic louvre was installed on the blower vent on 29 September 2016 to attenuate noise from the source. Noise monitoring after installation confirmed acceptable levels and no other mitigation was required. 21 October Noise: Complaint lodged with Council A noise audit was undertaken in January Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

36 AECOM Annual Environmental Management Report Date Complaint Received Action Taken 2015 and 5 January 2016 regarding noise heard at night/early morning on an intermittent basis over the past year. Additional information provided on 5 January 2016 led to the identification of a potential source of noise on the Site (ventilation duct for the blowers on level 5) for the likely noise source, the blower plant. Attended noise measurements showed exceedances at night at nearby residence. Noise control recommendations were made and an acoustic louvre was installed on the 29 September During the louvres fabrication a temporary cover was installed on the vent. Noise monitoring after installation confirmed acceptable levels and no other mitigation was required. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

37 AECOM Annual Environmental Management Report Recommendations and Action Plan Table 20 provides a summary of the recommendations made during audits and similar work undertaken during the reporting period, as well as recommendations identified through the AEMR process (such as resolving complaints) identified as general recommendations. The actions taken or proposed to be undertaken to address each of the recommendations are provided, along with the person responsible for ensuring the actions are carried out and the proposed timing. The table presents outstanding items from the previous reporting year as provided in the 2015 AEMR and as requested in DP&E correspondence dated 4 March General comments are provided upfront, whilst those associated with an audit/report carried out in the previous AEMR reporting year are provided under the audits/reports heading. The table provides outstanding recommendations and plans from the DP&E Hazard Audit 2015 from the 2015 AEMR. Items that were considered to be closed during 2015 AEMR have not been reproduced in this AEMR; only actions outstanding in the current reporting year. The recommendations as an outcome of the Noise Impact Assessment 2016 are presented in Table 20 along with the actions taken to address each of the issues. The non-compliance recommendations as an outcome of the IHA 2016 and IEA 2016 are presented in Table 20 along with the actions taken to address each of the issues. In addition to the audits listed above, the DP&E provided written correspondence dated 4 March 2016 stating that the department is generally satisfied that the 2015 AEMR meets requirements of Condition 7.1 of the Consent, however detailed items that should be addressed in future AEMRs. These items are presented in Table 20 along with the actions taken to address each of the issues. Allied Mills commits to the actions set out in Table 20 in order to ensure compliance with the conditions of the Consent. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

38 AECOM Annual Environmental Management Report Table 20 Recommendations and Action Plan Reference Recommendation Action Required / Undertaken Person Responsible Timing General recommendations and actions not covered within audits, reports or similar as detailed in the following sections Section 5.3 Upon completion and approval of the Traffic Traffic Management Sub-Plan included in Ros Herron March 2017 Management Plan, update the projected Revision 3.1 of the Environmental Completed maximum traffic volumes. Management Plan. The maximum traffic volumes are consistent with previous reported values and hence remain Section AEMR General actions Section 4.1 Table 3 Section 6.3 Table 19 Section 4.4 Section 5.3 Upon completion and approval of the Waste Management Plan, update the projected waste quantities. A noise audit is to be undertaken to investigate the noise source of a complaint registered on 21 October It is recommended that the Plan be updated to include the average and maximum number of daily and weekly truck movements associated with production at full capacity. unchanged in this AEMR. Waste Management Sub-Plan included in Revision 3.1 of the Environmental Management Plan. The maximum waste volumes were updated from previous values and these values have been included in this current AEMR. A noise audit was undertaken in January 2016 for the likely noise source, the blower plant. Attended noise measurements showed exceedances at night at nearby residence. Noise recommendations were made and an acoustic louvre was installed on the 29 September During the louvres fabrication a temporary cover was installed on the vent. Insulation was also installed on the air intake. The average and maximum number of daily and weekly truck movements associated with production at full capacity has been provided in Section 5.3 of this AEMR. Ros Herron March 2017 Completed Ros Herron September 2016 Ros Herron Completed AEMR submission Completed Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

39 AECOM Annual Environmental Management Report Reference Recommendation Action Required / Undertaken Section 5.4 It is therefore recommended that the Waste Management Plan be revised to provide more accurate estimates of the waste quantities generated at the Site AEMR DP&E Hazard Audit 2015 Outstanding actions Section 6.1 The Proponent should implement all N1 outstanding recommendations from the most recent IHA. An action plan should be submitted to the Department to detail how each outstanding recommendations was Section 6.1 N1 R2 (IHA 2013): Section 6.1 N2 Section 6.1 N3 closed. Review cleaning procedure for level 5 for all overhead cleaning. Review level 5 pre-weigh hopper design and determine if changes will reduce dust escaping this area. The next IHA (which is due in 2016) should be undertaken by an independent external audit team or auditor in accordance with the HIPAP No. 5 requirements and Condition 8.3 of the Consent. The Proponent should implement all outstanding recommendations from the most recent Deflagration Management Strategy Report (Appendix C). An action plan should A revision to the Waste Management Plan has been undertaken. Due to the preparation of the Independent Environment Audit in 2016, it was decided to delay the lodgement of the plan to the DP&E so as to include any recommendations or modifications as an outcome of the audit. An extension of time for the submission of the AEMR and the EMP was granted by the DPE on 24 th February It is expected that the revised plan would be lodged in the first quarter of The Action Plan has been submitted to DP&E on various occasions as the proposed actions were updated. An IHA was undertaken by the independent consultancy GHD in Cleaning procedure was updated and sighted by DP&E. The level 5 hopper design was reviewed by DP&E, and the modification completed in An IHA was undertaken by the independent consultancy GHD in 2016 in accordance with the conditions of the Consent and DP&E Hazard Audit DP&E Hazard Audit 2015 (DP&E, 2015) noted some recommendations from the DMS report had not yet been closed. Additional evidence was submitted and Person Timing Responsible Ros Herron March 2017 Ongoing Ros Herron December 2016 Completed Paul Maher November 2016 Completed Ros Herron November 2016 Completed Ros Herron December 2016 Completed Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

40 AECOM Annual Environmental Management Report Reference Recommendation Action Required / Undertaken Section 6.1 N4. be submitted to the Department to detail how each outstanding recommendations was implemented. The development consent requires that a document setting out a comprehensive SMS be submitted to the DP&E. Following the 2013 compliance campaign, Allied Mills submitted a document that mapped the contents of their SMS against the requirements included in HIPAP No. 9. The SMS map has not been approved by the DP&E. Allied Mills should submit additional information to the DP&E to demonstrate compliance with Condition 5.3(b) of the Consent. Noise Impact Assessment 2016 Section 4.1 The roof exhaust outlet be treated with the installation of an internally lined duct. Section 4.2 Plant room intake opening mitigation options 1. Install acoustic louvre 2. Acoustically treated ductwork Independent Hazard Audit 2016 NC5.1, 3.4.5/3 The clearance space around the Fire Indicator Panel does not comply with the requirement of AS DP&E confirmed (letter dated 17 December 2015) that outstanding actions had been adequately addressed. Allied Mills submitted a document mapping the contents of its Safety Management System (SMS) against the requirements of Hazardous Industry Planning Advisory Paper (HIPAP) No. 9 (DP&E, 2011a). DP&E approved the SMS mapping document on 28 October Noise monitoring after installation of the louvres showed acceptance to required criteria and as such no further mitigation was required. An acoustic louvre was installed on the plant intake opening on 29 September 2016 Obtain advice from the Fire Brigade, the local Council or an independent fire engineer to determine whether the reduction in spacing compromises access to the FIP panel. Implement recommendations from the advice. Person Responsible Timing Ros Herron October 2015 Completed Paul Maher September 2016 Action Completed Paul Maher September 2016 Action Completed Ros Herron June 2017 Ongoing Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

41 AECOM Annual Environmental Management Report Reference Recommendation Action Required / Undertaken Person Responsible Timing Independent Environmental Audit 2016 R1 Revise the Traffic Management Plan to document the measures that will be put in place to Minimise the number of trucks which will be used to transport goods. R2 R3 R4 R5 R6 Submit a copy of the revised Traffic Management Plan to Roads and Maritime Services. To prevent ongoing non-compliance of traffic management controls at entrance to the site, submit an application to DP&E to modify this condition to reflect the current agreed status. Submit a copy of the Environmental Monitoring Program to the EPA. Undertake a gap analysis of corporate and environmental policies and procedures and develop a site EMS. To prevent ongoing non-compliance of traffic management controls related to pedestrian routes on-site, submit an application to DP&E to modify this condition. A Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March 2017, and provided in Appendix A. Section 5 of the Traffic Management Sub- Plan details the measures to minimise the number of trucks. A Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March The Plan is currently being sent to RMS. Submit an application to DP&E to modify this condition to reflect the current agreed status. Ros Herron March 2017 Completed Ros Herron March 2017 Completed Ros Herron June 2017 Ongoing Environmental Monitoring Program Sent to Ros Herron January 2016 EPA Action Completed Develop a site EMS. Ros Herron June 2017 Allied Mills advised that realignment of the pedestrian route was considered however it would result in the loss of parking places and would not necessarily improve pedestrian safety on the site. Submit an application to DP&E to modify this condition. Ongoing Ros Herron June 2017 Ongoing R7 Incorporate periodic calibration of air Site to engage contractor to finalise Paul Maher December 2016 Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

42 AECOM Annual Environmental Management Report Reference Recommendation Action Required / Undertaken monitoring equipment into the site s maintenance schedule. DP&E Correspondence dated 4 March 2016 Page 1 All non-compliances against conditions of consent must be reported in addition to reporting non-compliances arising from audits (or similar) undertaken during the reporting period. Page 1 The Department requests that all subsequent AEMRs include a section summarising the status of actions arising from the previous AEMR. Page 1 Submit to the Department for approval any proposed mitigation measures that arise from the noise audit undertaken in Page 1 Update the Traffic Management Plan and Waste Management Plan as recommended in Section 8.0 of the Report. approach to calibration of air monitors and update maintenance procedures as required. Incorporate periodic calibration of air monitoring equipment into the site s maintenance schedule. All non-compliance at the site, not limited to those in audits or similar, are provided in Section 6.1 of this AEMR. The status of actions arising from the previous AEMR are provided in Section 7 of this AEMR. Proposed mitigation were submitted to the Department on 26 August and a subsequent confirming the installation of the mitigation on 21 November An updated Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March An updated Waste Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March Person Responsible Ros Herron Ros Herron Ros Herron Timing Completed AEMR submission Completed AEMR submission Completed At completion of the noise audit Completed Ros Herron March 2017 Completed Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

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44 AECOM Annual Environmental Management Report Conclusion The Allied Mills Kingsgrove site operates a comprehensive environmental management program. The results of the AEMR for the current period demonstrate that the environmental performance of the site is generally meeting expectations, and indicate that site personnel are following site procedures and meeting their environmental responsibilities. A review of current environmental actions indicates that the site is routinely monitored on a weekly basis and this process has been demonstrated to ensure the effective management and maintenance of infrastructure and activities on site. The results of the detailed monitoring undertaken for traffic and waste have been included in this AEMR. Traffic movements at the Site appear to be generally stable and are well below the levels predicted in the SEE for the expansion of the Site. Waste quantities have been variable, with the quantity of General Waste (putrescible) generated at the Site increasing each year since 2012, with 2016 having the highest annual quantity to date, however remains lower than the Waste Management Sub-Plan predictions. An updated Traffic Management Sub-Plan is included in Revision 3.1 of the Environmental Management Plan dated 29 March 2017 provided in Appendix A. An updated Waste Management Sub-Plan is also included in Revision 3.1 of the Environmental Management Plan. Outstanding items from the DP&E Hazard Audit in 2015, as detailed in the 2015 AEMR, have been addressed in this 2016 AEMR, with all items being closed out. During the reporting period both an Independent Environmental Audit and an Independent Hazard Audit were undertaken by GHD in 2016, with non-compliances identified and the recommendations made reported in this AEMR. Non-compliances, incidents and complaints are handled through a site review process managed through the incident reporting database. The database ensures that all identified issues are accurately detailed and appropriately addressed in a timely manner. The improved monitoring and analysis of waste and traffic data has identified further opportunities for improved performance. For example, Allied Mills have started initiatives to review waste management and look at opportunities to recycle plastics and export wooden pallets. This is evidence of the continuous improvement and corrective action process implemented at the site. The results of the current AEMR demonstrate that the environmental actions currently undertaken on site are adequate to effect compliance with the standards, performance measures, and statutory requirements the development is required to comply with. Allied Mills will continue to engage with the local community, Council, the DP&E and other regulatory authorities when required to ensure the efficient operation of the facility and to prevent or minimise harm to the environment. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

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46 AECOM Annual Environmental Management Report References AECOM (2014) AMA Kingsgrove Processing Plant, Risk Management: Deflagration Strategy Support. Newcastle, AECOM Australia. Benbow Associates (2001) Statement of Environmental Effect (SEE) for the Proposed Expansion to Existing Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove. Sydney, Dick Benbow & Associates Pty Ltd. Day Design Pty Ltd (2016) Noise Impact Assessment Blower Room allied Mills, 4 The Crescent, Kingsgrove, NSW, Peakhurst NSW, Day Design Pty Ltd. DP&E (2015) Allied Mills Kingsgrove, 2015 Compliance Audit Campaign, Compliance Audit Report August NSW: Department of Planning & Environment. DP&E (2012) Notice of Modification - DA MOD 2. NSW: Department of Planning & Infrastructure. DP&E (2011a) Hazardous Industry Planning Advisory Paper (HIPAP) No. 9 Safety Management. NSW: Department of Planning. DP&E (2011b) Hazardous Industry Planning Advisory Paper (HIPAP) No. 5 Hazard Audits Guidelines. NSW: Department of Planning. DP&E (2001) Determination of a development application for state significant & integrated development - File No. S01/ NSW: Department of Urban Affairs & Planning. GHD (2015a) Follow-up Verification Audit for 2013 IHA4121. Sydney, NSW, GHD Pty Ltd. GHD (2015b) Kingsgrove Hazardous Area Consultation - Close out Report. Sydney, NSW, GHD Pty Ltd. GHD (2016a) Allied Mills, Kingsgrove Independent Hazard Audit, GHD Pty Ltd. GHD (2016b) Allied Mills, Kingsgrove Independent Environmental Audit, GHD Pty Ltd. Rhodes Thompson Associates (2001) Traffic Impact Statement, Proposed Industrial Expansion Ref: R (3), prepared by Rhodes Thompson Associates on behalf of Goodman Fielder Ltd. SKM (2015c) Allied Mills Kingsgrove Environmental Management Plan. St Leonards NSW: Sinclair Knight Merz. Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

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48 AECOM Annual Environmental Management Report 2016 AAppendix A Environmental Management Plan Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

49 AECOM Annual Environmental Management Report 2016 A-1 Appendix A Environmental Management Plan Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN:

50 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 1 of Overview of Environmental Management Plan (EMP) To ensure that all adverse impacts on the environment resulting from operations at the Kingsgrove site are identified, assessed and, as far as is reasonably practicable, minimised. The site will follow the Allied Mills Environmental Management Policy and the Site Environmental Management Plan (EMP) and work within the Development Application (as modified) for the site and the Conditions of Consent pertained within this DA. 2. Review This document will be reviewed annually and updated if required as part of the review process. 3. Responsibilities Responsibilities, as set out in Section 8 below. Number Document Name Location Kingsgrove Environmental Monitoring Forms. Site Document Kingsgrove Emergency Response Plan Site Document AM Environmental Management Plan Central Document Waste Management Central Document 4. Plans 4.1 Traffic Management Plan The site shall follow the traffic Management plan as set out in this EMP. As a summary, No site employees shall park on The Crescent, and must utilise the staff parking area at the rear of the site. No trucks that are delivering or picking up product from the Kingsgrove site can park on The Crescent prior to entering the site. The Kingsgrove site will control and monitor this by scheduling trucks so they are spread across the day and week to reduce congestion of trucks onto the site. The site has cameras viewing The Crescent that are linked to the despatch department who can monitor the traffic and trucks in the area. The Kingsgrove site utilises a traffic light system, with green indicating trucks can enter the site, while a red light indicates no site access for trucks. Street signage notifies trucks of this entry requirement. The warehouse Manager shall provide truck movement figures for each month and record them in the site shared drive. The site Manager shall review the data on truck movements. The National logistics department shall provide the site with the bulk truck movement figures for each month. The site shall record these in the site shared drive under environmental truck movements. 4.2 Landscape Management Plan The Environmental Management Plan contains details for the site landscaping including a landscape map and outline of the plant species on site. The Kingsgrove site shall maintain the site vegetation with regular maintenance by a gardening contractor. 4.3 Waste Management Plan The site has identified waste streams and removal of waste from the site. Where possible, waste will be recycled to reduce the impact of waste on the environment. This includes putrescible waste (offal product), general waste, recycled waste, liquid waste and hazardous waste. Waste removal contractors provide waste data per month. Monthly wastage will be recorded for the site in the Kingsgrove computer shared drive. 4.5 Environmental Monitoring Requirements: Weekly Monitoring Each week the site will complete a monitoring program for the site. This will cover the monitoring requirements for emissions, traffic, wastage, noise, landscaping, air quality and stormwater. The requirements for this monitoring are documented in the EMP under Section 9, Table 9-2. Monitoring Form Located in this document

51 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 2 of Noise Management The site will operate in a manner to avoid excess noise. As per the site conditions of consent, the site will record any noise complaints in the rapid induct system. Where a substantiated noise complaint is received, the site will implement measures to reduce noise. Refer to Appendix B Noise Management Strategy of this EMP Air Quality Management The site shall control air quality management by: Visually inspecting vehicles for no black or white smoke from exhausts longer than 10 seconds. This will be done periodically as part of the weekly monitoring program. The dust collector monitoring probes will be serviced as per the internal preventative maintenance program. The dust collector monitoring probes will be serviced by an external contractor as per the maintenance schedule. The site dust collector systems and filters will be serviced as per the site preventative maintenance schedule Stormwater Management The site will conduct occasional spot checks of the oil tankers to ensure the drivers are using spill trays under the couplings to prevent spills. Oil tankers must be fitted with interlock brakes as part of entry and operation on the site. Regular inspections of bunding around oil tanks will be undertaken to ensure capacity of the bund is maintained. Inspection of the isolation valves and drains wardens will be part of the weekly monitorin. 4.6 Reporting Requirements: Environmental Impact reporting: In the case of an environmental Spill or issue that causes or has the potential to cause off site environmental harm, the environmental notification script shall be completed as per appendix I of this EMP. Records are provided as an attachment to this document Annual Environmental Management Report The site must complete an Annual Environmental Management Report (AEMR) and submit this to the DP&E each February. This report covers the activities for the site for the previous calendar year against the DA Conditions of Consent for the site. This document is to be prepared by a third party consultant Environmental and Hazard Audits The site must undertake a third party Environmental and Hazard audit every three years. These audits are to be conducted by an approved third party auditor. The DP&E must approve the auditor prior to the audits commencing. This requires the CV s and to be submitted to the DP&E Attorney General for approval. The audits must be completed by July and quotes and approval should start in May to ensure sufficient time to arrange and complete the audits. The audit reports must be submitted to the DP&E as follows: Hazard Report: Within one month of the audit being completed. Environmental Report: Within two months of the audit being completed. If an extension to the submission of reports or the time of the audits it required, a written request shall be submitted to the DP&E.

52 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 3 of Records Data Form or Record Minimum Retention Period Who Holds/Secures the Data Form or Record Retained for Legal or Knowledge Preservation Weekly Monitoring Form 3 Years OHS& Training Coordinator Knowledge Environmental Training / Induction Records 4 Years Rapid Induct / Training & OHS Coordinator Knowledge Environmental Notification script Incident 7 Years Training & OHS Coordinator Legal

53 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 1 of 72 Contents 1. Introduction Environmental Management Plan purpose Environmental Management Plan scope Environmental Management Plan objectives Preparation of this EMP and Sub-Plans 6 2. Overview of site operations Bulk deliveries Truck docks / driveway Offices / kitchens and laboratories Production floor Silos Oil storage 8 3. Legislative and regulatory requirements Conditions of Development Consent (CDCs) Legislation Standards and guidelines Environmental aspects Environmental impacts and controls Overview Environmental management strategies Environmental management sub-plans Site induction and training Communications and reporting Reporting Communications Complaints management Emergency response Incident response Incident reporting Environmental management responsibilities Environmental roles and responsibilities Site Manager National Work Health Safety and Environmental (WHSE) Manager and Coordinator Production Managers Warehouse Manager 21 PAGE i

54 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 2 of Maintenance Manager Employees, Contractors and Delivery Drivers Environmental Contractors Monitoring, inspection & auditing environmental performance Overview Environmental monitoring program Inspections and audits Audit action plan Non-compliances Environmental reporting Management review 27 Appendix A Conditions of Development Consent 29 Appendix B Noise Management Strategy 43 Appendix C Air Quality Management Strategy 44 Appendix D Stormwater Management Strategy 45 Appendix E Traffic Management Sub Plan 46 Appendix F Landscape Management Sub Plan 56 Appendix G Waste Management Sub Plan 63 Appendix H Environmental Inspection Report Template 69 Appendix I Environmental Incident Notification Script 70 Appendix J Emergency Contacts 72 PAGE ii

55 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 3 of 72 Document History and Status Revision Date issued Reviewed by Approved by Date approved Revision type Draft V01 20/04/2012 B Ison G Moylan 27/04/2012 Project manager Draft V02 27/04/2012 J Ball B Ison 24/05/2012 Practise / Project director Version V03 17/11/15 R. Herron CAR Revision H. Lam, O Cetindemir R. Herron CAR s 0502, 0489, 0736, 1029 Printed: 11 April 2017 Last saved: 29 March :44 AM Name of organisation: Allied Mills Kingsgrove Name of document: Document version: Allied Mills Kingsgrove Environmental Management Plan Final Rev 3.1 Notice previous revision 3 was documented outside the SAP system. Dated PAGE iii

56 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 4 of 72 Glossary Term AEMR CBD CDC dba DCP DMS DoP DP&I EMP EPA EPL HCC LAeq LGA LMP POEO Act SEE TSH&E Coordinator TMP WMP Definition Annual Environmental Management Report Central Business District Conditions of Developmental Consent Decibels (A-weighted) Development Control Plan Deflagration Management Strategy Department of Planning Department of Planning and Infrastructure Environmental Management Plan Environmental Protection Agency Environmental Protection License Hurstville City Council Equivalent continuous A-weighted noise level Local Government Area Landscape Management Plan Protection of the Environment (Operations) Act Statement of Environmental Effects Training, Safety, Health and Environment Coordinator Traffic Management Plan Waste Management Plan PAGE iv

57 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 5 of Introduction Allied Mills manufactures and distributes a wide range of food ingredients; in particular grain based baking supplies. The Kingsgrove site receives bulk deliveries of flour, oil and other ingredients and processes these into the products including: flours for items such as bread, pastry, cake, biscuit, noodle and culinary applications pre-mixes for bread, cake, donut and culinary applications other specialty flours, batters, coatings and grain products The Kingsgrove site is located at 4 The Crescent, Kingsgrove NSW, which is within the Georges River Council Local Government Area (LGA), 12 kilometres to the south of the Sydney Central Business District (CBD). The site is adjacent to the M5 East Motorway, Crescent Road, Vanessa Street and existing light industrial facilities. The site occupies an area of 24,490 m 2. The site produces approximately 80,000 tonnes per year of product and employs approximately 100 people Environmental Management Plan purpose This Environmental Management Plan (EMP) has been developed to fulfil the requirements of conditions 3.5(a)-(h) of the development consent (S01/00876). The EMP provides an environmental management framework and strategies to minimise potential environmental impacts arising from site operations. It includes specific management measures to ensure operations at the site have minimal environmental impact and risk, and where possible, enhanced environmental outcomes. This plan: captures environmental issues and mitigation measures already identified and assessed through the environmental documents relating to the operations of the site includes management measures, procedures, monitoring, auditing, reporting and allocates responsibility in relation to the operation s of the facility provides Allied Mills with measures that will be used to manage environmental risks and opportunities 1.2. Environmental Management Plan scope This plan is the lead document dictating environmental performance for Allied Mills operations at Kingsgrove. It covers all areas where physical works will occur, or areas that may be impacted by works, and is applicable over the full duration of operation at the site. It clearly identifies accountabilities for implementation of control measures and actions, monitoring, auditing/inspections and reporting. PAGE 5

58 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 6 of 72 Sub-plans to address specific significant environmental issues associated with the project are shown in Section 5. All Allied Mills staff and sub-contractors are required to operate fully under the auspices of this plan and sub-plans Environmental Management Plan objectives The objectives of this plan are that: all environmental requirements contained in statutory approvals, and other legal controls relevant to Allied Mills operation are clearly defined and mechanisms for implementation specified an environmental management system is established that meets the Conditions of Development Consent (CDC) all roles and responsibilities are set to ensure certainty of delivery all processes for auditing, monitoring and reporting on performance and effectiveness of the EMP are defined other objectives identified within environmental documents are met 1.4. Preparation of this EMP and Sub-Plans All environmental management requirements specified as being the responsibility of Allied Mills in the CDCs have been considered and addressed in preparing this plan. This plan has also been designed to address Allied Mills expectations and requirements, and adequately address risks and stakeholder concerns. Consultation with all stakeholders will be undertaken as per the requirements of the CDCs. PAGE 6

59 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 7 of Overview of site operations The Allied Mills site at Kingsgrove involves the preparation of food ingredients from bulk grain based product. The site is a pre-mix plant utilising ingredients from both external and internal suppliers and blending those ingredients to produce a finished product. Products produced at the site are distributed in a powdered form to be mixed and baked off-site by the retail division or customers. The processes at Kingsgrove involve blending mainly dry products into pre-mixes and cake mixes. Vegetable oil is used as an additive in pre-mixes for the fast food industry, and liquid carbon dioxide is used to cool some products that contain vegetable oil. The processing equipment and storage of ingredients is totally housed within existing buildings. By fully enclosing the production area, opportunities for loss of product to the external environment are significantly reduced with uncontrolled emissions of noise and dust being captured. Activities outside the buildings are limited to solid waste recycling and storage and unloading of bulk deliveries. The main areas of the plant are described further below, and a site map is provided at Figure Bulk deliveries Bulk deliveries of flour products are received adjacent to the storage silos on the southern boundary of the site. Deliveries are typically made by an articulated flour tanker, and piped directly into the onsite flour silos using blower housed inside the Allied Mills building, as such the operation of truck mounted blowers is not required. The onsite road at this point is one direction, as bulk delivery trucks are required to enter through the southern gate (Gate B) and exit through the northern gate (Gate A) Truck docks / driveway The loading / unloading dock has room for two trucks at any time, and an additional waiting bay, located adjacent to the LPG storage tanks in the north of the site. Oil deliveries are made at a point on the northern wall of the building, adjacent to the oil storage area. Trucks are required to enter through the northern access gate (Gate A) and reverse into the docks to load or unload, they then exit through the same northern gate. A forklift operates in this area; however this plant is not equipped with a reversing beeper. PAGE 7

60 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 8 of Offices / kitchens and laboratories The second floor of the building contains the office areas and test kitchen, whilst additional office space and a laboratory are located on the ground floor in the north east of the building Production floor The production area is a large open space located in the eastern wing of the site. This space contains dry mixing machinery, blowers, conveyors and packing equipment, in addition to other machinery. Workers in this area are required to wear hygiene and safety equipment, including hair nets and eye and ear protection Silos The flour silos on the site are approximately 15 m tall and housed internally in the south eastern area of the main building. The area is negatively pressurised and both the silos and building contain vents for the controlled released of potential explosive energy Oil storage This bunded area is housed internally and holds approximately six edible oil tanks, with a total capacity of approximately 92,000 L. Trucks delivering the oil are required to be equipped with brake interlocks, which will only allow oil to leave the truck when the brake is activated, thus helping to prevent accidental spills. PAGE 8

61 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 9 of 72 Figure 2-1 Allied Mills Kingsgrove site layout plan. PAGE 9

62 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 10 of Legislative and regulatory requirements 3.1. Conditions of Development Consent (CDCs) The CDCs were issued as part of the development consent for the Kingsgrove site. These conditions specify a number of measures for implementation during construction and operation of the site. This EMP has been developed specifically to address the requirements of condition 3.5 of the development consent. The requirements of condition 3.5 and the relevant sections of this document where these requirements are met, is identified in Table 3-1. Table 3-1 Condition 3.5 requirements Condition Condition requirements EMP section 3.5 The Applicant must prepare and implement an Environmental Management Plan for all future operations at the site. This plan must: This Document 3.5a) Describe the proposed operations Section 2 3.5b) 3.5c) 3.5d) 3.5e) 3.5f) Identify the relevant statutory requirements that apply to the operation of the development Set standards and performance measures for each of the relevant environmental issues Describe what actions and measures will be implemented to mitigate the potential impacts of the development, and to ensure that the development meets these standards and performance measures Describe what measures and procedures will be implemented to: Register and respond to complaints; Respond to potential emergencies, such as plant failure Describe the role, responsibility, authority, and accountability of all the key personnel involved in the operation of the development Section 3 Section 4 Section 5 Section 6 and Section 7 Section 8 3.5g) Incorporate the detailed Environmental Monitoring Program Section 9 3.5h) Include the following: Management strategies for the control of noise, dust and stormwater A Traffic Management Plan A Landscape Management Plan A Waste Management Plan Appendix B to Appendix G PAGE 10

63 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 11 of 72 Appendix A tabulates all of the CDC requirements and identifies where each requirement is addressed in this plan and/or related documents Legislation Allied Mills has an obligation to comply with the relevant provisions of all legislation and regulations relating to operations of the site. The relevant legislation and the required approvals for the Kingsgrove site are identified in Table 3-2. Table 3-2 Legislative requirements Relevant legislation Environmental Planning & Assessment Act 1979 & Regulation 2000 Protection of the Environment Operations Act (POEO Act) 1997 Occupational Health and Safety Act 2001 Clean Air Regulation 1997 (POEO Act) Overview of legislation Sets out the planning requirements for developments and the factors that must be taken into account concerning the impact of an activity on the environment. Provides a licensing framework for potentially polluting premises or activities. Legal duty to immediately notify the EPA of potential environmental harm Provides a licensing framework for the storage and handling of potentially dangerous goods. Provides emission standards for a variety of different air pollutants. Approvals / requirements The Department of Infrastructure and Planning has provided conditions for the development consent. An EPL (2794) was in place for the site for air emission monitoring, but was surrendered in Incident notification procedures in Section 7.1 to be followed in event of a spill. The Kingsgrove site is licensed to store LP Gas and carbon dioxide in bulk under licence NDG Plant and equipment to be maintained in a proper and efficient manner Standards and guidelines The key standards and guidelines relevant to the management of the site include: Australian Standard AS Car park design Australian Standard AS Commercial parking Australian Standard AS Classification of hazardous areas Part 2 Combustible Dust PAGE 11

64 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 12 of 72 Australian/New Zealand Standards AS Electrical Equipment for Explosive Atmospheres Selection, Installation and Maintenance Part 1 General Requirements Department of Planning and Infrastructure Hazardous Industry Planning paper No 1 Industry Emergency Planning Guidelines Department of Planning and Infrastructure Hazardous Industry Planning paper No 2 Fire Safety Study Guidelines Department of Planning and Infrastructure Hazardous Industry Planning paper No 5 Hazard Audit Guidelines Department of Planning and Infrastructure Hazardous Industry Planning paper No 9 Safety Management EPA Industrial Noise Policy 2000 EPA Environmental Criteria for Road traffic Noise 1999 Department of Housing Managing Urban Stormwater Soils and Construction 1998 Workcover OHS Regulation 2001 Storage and handling of dangerous goods PAGE 12

65 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 13 of Environmental aspects Dick Benbow & Associates prepared the Statement of Environmental Effects (SEE) for the proposed expansion to the existing manufacturing facilities at Goodman Fielder Limited Kingsgrove. The SEE identified the aspects of the Allied Mills Kingsgrove site (formerly the Goodman Fielder site) that may impact upon the surrounding environment. The potential environmental aspects of the Kingsgrove site and the adopted performance measures are detailed in Table 4-1. Table 4-1 Environmental aspects and performance measures Environmental aspect Noise Dust Stormwater Traffic Aesthetic Impacts/ Landscaping Waste Standards / performance measures No nuisance noise will be emitted from the Kingsgrove site. No visible dust or odours noted leaving the Kingsgrove site. No pollution of nearby waterways. No notable impact to the surrounding community from traffic generated at the Kingsgrove site. No aesthetic impact to the surrounding community. All waste to be correctly stored on site and disposed of by an appropriately licenced contractor. PAGE 13

66 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 14 of Environmental impacts and controls 5.1. Overview This plan is the overarching plan for environmental management. Under this plan, individual management strategies and sub plans have been developed to address the environmental aspects that were identified within the SEE, or as required by the CDCs Environmental management strategies The environmental management strategies comprise the environmental safeguards used to achieve the performance measures identified in Table 4-1. For each Environmental Management Strategy, the following approach has been undertaken: Identification of potential risks Assessment of potential risks (using a scale of Negligible, Low, Moderate and High) Identification of Environmental Objectives Identification of major compliance requirements Define monitoring requirements and responsibilities Development of mitigation measures A list of the Environmental Management Strategies developed for the site and where they can be found within this document is shown in Table 5-1. Table 5-1 Environmental management strategies Strategy Environmental Noise Air Quality Stormwater and Wastewater EMP Section Appendix B Appendix C Appendix D 5.3. Environmental management sub-plans The purpose of sub-plans is to guide operational activities in a concise manner, by specifying measures to manage impact on the environment. A register of sub-plans is provided in Table 5-2. PAGE 14

67 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 15 of 72 Table 5-2 Environmental management sub-plans Sub-plan Traffic Management Plan Landscape Management Plan Waste Doc reference Appendix E Appendix F Appendix G 5.4. Site induction and training Allied Mills will ensure that all those who will be working at the Kingsgrove site will undertake site induction training prior to commencing work on site. The objective of the induction training is to ensure all personnel have the appropriate awareness and competence for aspects relevant to their positions/role including environmental management. The site induction and training courses will cover: The content and intent of the EMP The importance of conformance with the EMP, and roles and responsibility in achieving conformance with the EMP Significant onsite and offsite environmental issues Incident Management including location of environmental incident notification script, actions to be undertaken, responsibilities during an incident, communication lines and emergency services to be contacted The potential consequences of departure from specified operating procedures The records will be available in rapid induct and include names of trainees, training provided and date of training. The training records will be kept for 4 years and will be made available for audit. PAGE 15

68 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 16 of Communications and reporting 6.1. Reporting The Site Manager is responsible for managing the environmental reporting program and arranging specialist consultants to prepare reports, as required Communications Weekly operational meetings will be held to discuss environmental issues, such as environmental performance, monitoring results, independent audit findings and will also allow operational personnel to forecast potential issues (eg night works) Complaints management In the event that Allied Mills receives a complaint regarding the works at the Kingsgrove facility, the complainant shall be referred to the Site Manager or National WHSE Manager. Allied Mills shall collect the following details and document them in the Incident Reporting Database: date and time of the complaint; means by which the complaint was made; any personal details of the complainant which were provided, or if no such details were provided, a note to that effect; the nature of the complaint; action taken by Allied Mills in relation to the complaint, including any follow-up contact with the complainant, and if Allied Mills took no action in relation to the complaint, the reasons why no action was taken. The Site Manager will be responsible for coordinating any environmental monitoring required in response to a complaint, and for ensuring that the monitoring results are received in a timely manner. All records collected that relate to a complaint will be saved and available for audit for four years. PAGE 16

69 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 17 of Emergency response 7.1. Incident response In the event of an environmental incident that causes material environmental harm, the Site Manager must be notified; Allied Mills will collect initial basic information on the Environmental Incident Notification Script (included in Appendix I) and then immediately contact the following organisations in accordance with the recent amendments to the POEO Act: Emergency services 000 (whether the incident presents an immediate threat to people or property or not) Georges River Council (02) (Georges River Council is only available 8.30am 5.00pm Mon Fri) EPA Ministry of Health SESI Randwick (02) WorkCover Authority Allied Mills will document the time each of the above organisations were notified and include these details in the incident report Incident reporting All environmental incidents are to be reported immediately to the Site Manager or Production Manager. The Site Manager (or Production Manager) will then be required to follow the above notification procedures. In accordance with Condition 8.1 of the CDC, any incident or potential incident that has actual or potential offsite impacts must have a report supplied to the Director-General, within 24 hours. The immediate report must outline the basic facts of the incident including but not limited to: Description of the incident (including times) Expected receiver (people, environment, waterbodies) Estimated quantities of any spills Immediate actions implemented (including times) Details of any notifications to Government Departments (including times) A further detailed report is also to be compiled in accordance with Condition 8.1 of the CDC, which investigates the cause of the incident (or potential incident) and identifies any PAGE 17

70 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 18 of 72 preventative measures that can be implemented. This report is to be submitted to the Director-General with no later than 14 days after the incident or potential incident. Any records of incident or potential incidents are to be logged and maintained in the Rapid Induct Database as required by Condition 8.2 of the CDC. PAGE 18

71 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 19 of Environmental management responsibilities 8.1. Environmental roles and responsibilities The organisational structure of the Allied Mills Kingsgrove facility is shown in Figure 3-1. Site Manager Production Warehouse Maintenance Managers Manager Manager Pre-Mix Plant Waste Delivery Maintenance employees Contractors Drivers Contractors Figure 3-1 Allied Mills organisational structure PAGE 19

72 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 20 of 72 The responsibilities and authorities of the key management positions are described below: Site Manager directly responsible for management of operations of the site, including environmental aspects, incident response and the day to day implementation of the EMP Production Managers Supervise production activities in accordance with the EMP. Is responsible to notify the Site Manager of any environmental issues Warehouse Manager Records and monitors truck movements through dock area and reports environmental issues to the Site Manager. All employees, contractors and delivery drivers To ensure their own actions are in accordance with this EMP; to ask a supervisor if they are unsure of their environmental responsibilities; to inspect, monitor and report (where relevant) on the environmental impacts of their own work activities or those they observe at the site The contact information for the key responsibilities is included in Site Manager The Site Manager is the Company's designated 'Management Representative', and in exercising this authority is responsible for: ensuring implementation of the Management System for the site ensuring that personnel responsible for inspection, monitoring and other activities are trained and have the necessary skills, resources and authority developing improvements and correcting defects or shortcomings as appropriate review and audit as required of subcontractors' quality, environmental and safety systems Communicating and providing detail to Company Secretary to act as Company s spokesperson in the event of an incident under the Protection of the Environment Operations Act 1997 Ensure all personnel are aware of the environmental incident response procedures and each individual s notification responsibilities facilitate an induction and training program for all persons involved with site activities have the authority to require reasonable steps to be undertaken to avoid or minimise the unintended (or adverse) impacts and failing the effectiveness of such steps to stop work immediately if an unacceptable impact on the environment is likely to occur implement this EMP across the site including the organisation of suitably qualified personnel to fulfil the requirements of the Environmental Monitoring Program PAGE 20

73 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 21 of 72 undertake weekly site inspections to identify and action any corrective/preventative measures as appropriate manage the procedures for receiving and responding to complaints and inquiries in relation to the environmental performance of operations organise the production and submittal the Annual Environmental Management Report to Department of Planning and Environment (DP&E) National Work Health Safety and Environmental (WHSE) Manager and Coordinator The National WHSE Manager and Coordinator will assist the site with reporting and independent environmental and hazard audits Production Managers The Production Managers are required to immediately notify the Site Manager of any spills, any visible dust or odours leaving the Kingsgrove site, or any other potential environmental concerns that may arise. If the Site Manager is unavailable the Production Manager must complete the basic information on the Environmental Incident Notification Script (Appendix I) and contact the relevant regulators Warehouse Manager The Warehouse Manager is required to immediately notify the Site Manager of any spills, any visible dust or odours leaving the Kingsgrove site, or any other potential environmental concerns that may arise. If the Site Manager is unavailable the Warehouse Manager must complete the basic information on the Environmental Incident Notification Script (Appendix IError! Reference source not found.) and contact the relevant regulators. The warehouse manager is also required to coordinate and monitor the movements of delivery vehicles and waste contractors to the Kingsgrove site, to ensure the drivers are not creating a nuisance in the surrounding community in line with the requirements detailed within Appendix E Maintenance Manager The Maintenance Manager is required to immediately notify the Site Manager of any spills, any visible dust or odours leaving site the Kingsgrove site, or any other potential environmental concerns that may arise. If the Site Manager is unavailable the Maintenance Manager must complete the basic information on the Environmental Incident Notification Script (Appendix IError! Reference source not found.) and contact the relevant regulators. PAGE 21

74 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 22 of 72 The Maintenance Manager is also required to ensure that the contractors used for maintenance works are appropriately inducted and working in accordance with the EMP requirements Employees, Contractors and Delivery Drivers Employees, Contractors and Delivery Drivers are required to carry out their work in accordance with site inductions or specific contract instructions and in an environmentally sound manner. All site personnel are to attend the site induction before they commence any work at the Kingsgrove site. Each member of personnel must notify their supervisor or the Site Manager immediately upon noticing any spill or potential environmental hazard. If their supervisor or Site Manager is unavailable, they must complete the basic information on the Environmental Incident Notification Script (Appendix I) and contact the relevant regulators Environmental Contractors Environmental contractors are engaged for specialist environmental support roles. These resources include: landscaping sub-contractor to undertake landscaping works independent environmental and hazard auditors noise specialist for complaint monitoring and reporting GIS, database and other software as required during the course of the project other resources as required during the course of the project A register of specialist environmental personnel is kept by Allied Mills. All environmental contractors are required to complete the site induction and carry out their works in accordance with this EMP. Environmental Contactors must notify their supervisor or the Site Manager immediately upon noticing any spill or potential environmental hazard. PAGE 22

75 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 23 of Monitoring, inspection & auditing environmental performance 9.1. Overview Section 6.1 of the CDC outlines the requirements of the Environmental Monitoring Program. As outlined in Section of this document, the Site Manager is required to coordinate the environmental monitoring program to ensure its effective implementation. The requirements of condition 6.1 and the relevant sections of this document where these requirements are met, is identified in Table 9-1. Table 9-1 Condition 6.1 requirements Condition Condition requirements EMP Section 6.1 The Applicant must prepare and implement a detailed Environmental Monitoring Program for the development in consultation with the EPA. The program must: This document 6.1a) Identify what environmental issues will be monitored; Section 4 6.1b) Set standards and performance measures for these environmental issues; Section 4 6.1c) 6.1d) 6.1e) Describe in detail how these issues will be monitored, who will conduct the monitoring, how often the monitoring will be conducted, and how the results of this monitoring will be recorded and reported to the Director-General and other relevant authorities; Indicate what actions will be taken, or procedures followed, if any non-compliance is detected; Include the following: A Noise Compliance Monitoring Program to determine level of compliance with the noise criteria; and Traffic Monitoring. Table 9-2 Section 9.4 Appendix B Appendix E 9.2. Environmental monitoring program An environmental monitoring program has been developed to address each of the environmental aspects and their performance measures, identified in the SEE and outlined in Section 4 of this plan. A brief summary of the monitoring program and where further information is available has been outlined in Table 9-2. PAGE 23

76 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 24 of 72 Table 9-2 Environmental monitoring program Environmental aspect Performance measure Monitoring method Monitoring frequency Deliverable Responsibility Further information Noise No nuisance noise will be emitted from the Kingsgrove Site. As appropriate Upon receiving a substantiated community complaint Noise Monitoring report, AEMR Site Manager Appendix B Noise Management Strategy Air Quality No visible dust or odours noted leaving the Kingsgrove site. Staff observations of dust and odours Constantly during operating hours Corrective/ Preventative actions All Personnel Appendix C Air Quality Management Strategy Stormwater No pollution of nearby waterways. Site inspection of bunding and isolation valves Weekly Corrective/ Preventative actions Site Manager or Designated person. Appendix D Stormwater Management Strategy Traffic No notable impact to the surrounding community from traffic generated at the Kingsgrove site. Truck movement records Daily Truck Dockets Warehouse Manager Appendix E Traffic Management Plan Aesthetic/ Landscaping No aesthetic impact to the surrounding community. Landscaping to be maintained Fortnightly N/A Site Manager Appendix F Landscape Management Plan Waste All waste to be effectively stored on site. Site inspection of waste receptacles across the site Weekly Corrective/ Preventative actions Site Manager or Designated person. Appendix G Waste Management Plan Note An example of an Environmental Inspection Report Template is attached as Appendix I. PAGE 24

77 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 25 of Inspections and audits The Site Manager is responsible for ensuring effective environmental inspections are carried out. Each week the Site Manager or Designated Person conducts a site safety and environment walk around the site to identify any safety or environmental issues. Any issues identified are to be documented (an example of the Environmental Inspection Report is attached as Appendix H) and actioned appropriately. Weekly site inspection records will be maintained and will be available for audit. Any actions completed to address issues identified in the weekly site inspections, will also be documented and available for audit. Independent environment and hazard audits are to be organised by the Site Manager every three years and must be carried out in accordance with the Condition 7.3 of the development consent Audit action plan Auditees review any adverse findings with appropriate personnel and develop a corrective action plan to address and close out findings. Where necessary, an investigation into the causes of any non-conformance is undertaken. Corrective action plans include actions to be taken, estimated completion date and responsibilities Non-compliances If a Non - compliance is identified during the Environmental monitoring program, weekly site inspection, an independent audit or any other method, the following process is to be followed: The Site Manager is to be informed immediately The Site Manager must identify an appropriate corrective action and then implement the corrective action or delegate authority over the action to an appropriate person. Any non-compliance and the actions taken are to be recorded and included in the Annual Environmental Management Report (AEMR) If the Non-Compliance constituted a pollution event that may cause material environmental harm, the emergency response procedure would be followed and the appropriate government authorities would be notified immediately PAGE 25

78 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 26 of Environmental reporting Allied Mills will compile an Annual Environmental Management Report (AEMR) in compliance with Condition 7.1 of the CDC. This report will: Identify the standards, performance measures, and statutory requirements the Kingsgrove site is required to comply with; Review the environmental performance of the Kingsgrove site to determine whether it is complying with these standards, performance measures and statutory requirements; Identify all the occasions during the previous year when the Kingsgrove site did not comply with these standards, performance measures and statutory requirements; Include a summary of any complaints made about the Kingsgrove site, and indicate what actions were taken (or are being taken) to address these complaints; Include the detailed reporting from the Environmental Monitoring Program, and identify any trends in the monitoring over the life of the project; and Where a non-compliance has occurred, describe what actions are or will be taken to ensure compliance, who is responsible for carrying out these actions, and when these actions will be implemented. The AEMR will be for the period from January to December for each year; and will be submitted to the Director-General and the Georges River Council by the end of February. If the review by the Director-General identifies some additional matters to be addressed, any reasonable requirements will be complied with. PAGE 26

79 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 27 of Management review The CDC s have outlined a number of tasks that require consistent reviews and if necessary updates. The conditions of consent have also detailed a number of deliverables to review the performance of the Allied Mills site and determine the effectiveness of environmental at the site. The tasks outlined within the CDC s have been set out in Table 11-1, along with the frequency of the task and the estimated date of the next revision. The Kingsgrove Safety Audit Schedule will detail the next review period. Table 11-1 Management plan peviews Condition Management plan Task Frequency Next review 3.7 Environmental Management Plan (including Sub Plans) Review Annual (or following a significant incident) February each year 4.19 Traffic Management Plan Review Annual (or following a significant incident) February each year 7.1 Annual Environmental Management Report (AEMR) Issue AEMR Annually February each year 7.3 Independent Environmental Audit Commission Audit Every three years As per EMP KV-REC Incident Register Update register As necessary N/A 8.3 Independent Hazard Audit Commission Audit Every three years As per EMP KV-REC-001 PAGE 27

80 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 28 of 72 References Conditions of Development Consent (dated 2001) issued by the Department of Urban Affairs and Planning. DA No submitted to the Department of Urban Affairs and Planning; SEE, titled Statement of Environmental Effects for the Proposed Expansion to Existing Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove, dated 20 June 2001, and prepared by Dick Benbow and Associates Pty Ltd on behalf of Goodman fielder; Environmental Management Plan, Goodman Fielder, Kingsgrove NSW, October 2002, prepared by ERM. Traffic Impact Statement Proposed Industrial Expansion Lot 1, DP , The Crescent, Kingsgrove. Ref 21-07OR (3), dated August 2001, and prepared by Rhodes Thompson Associates on behalf of Goodman Fielder; Construction Management Plan, prepared by A W Edwards, supplied to Goodman Fielder, 04 October 2002 Traffic Management Plan, prepared by Rhodes Thompson and Associates, Site Incident Logs Dangerous Goods Licence No. 35 / , expiry date 3/5/2012, issued by WorkCover, NSW Fire Safety Study, Goodman Fielder Ltd, 4 The Crescent, Kingsgrove, Doc # 21069FSS.doc, Prepared by Environmental Audits of Australia, Oct 2001 Deflagration ( Explosion) Management Strategy for Goodman Fielder Kingsgrove Plant, Report # 52004, Prepared by Environmental Audits of Australia, June 2002 PAGE 28

81 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 29 of 72 Appendix A Conditions of Development Consent Condition Description of requirements/commitment Implementation EMP Reference 1.1 The applicant must implement all practicable measures to prevent or minimise any harm to the environment that may result from the construction, operation and where relevant, the decommissioning of the development. 1.2 The applicant must carry out the development generally in accordance with the: 1.2 a) DA No submitted to the Department of Urban Affairs and Planning; 1.2 b) SEE, titled Statement of Environmental Effects for the Proposed Expansion to Existing Manufacturing Facilities at Goodman Fielder Limited, Kingsgrove, dated 20 June 2001, and prepared by Dick Benbow and Associates Pty Ltd on behalf of Goodman fielder; 1.2 c) The Traffic Impact Statement Proposed Industrial Expansion Lot 1, DP , The Crescent, Kingsgrove. Ref 21-07OR (3), dated August 2001, and prepared by Rhodes Thompson Associates on behalf of Goodman Fielder; 1.2 d) Additional information supplied to the Department by Dick Benbow and Associates on 16, 24, 27 and 28 August 2001; 1.2 e) Additional information supplied to the Department by Goodman Fielder on 4 September 2001; 1.2 f) Relevant prescribed conditions in clause 78 of the Environmental Planning and Assessment Regulation 1994; and The Kingsgrove site is to remain a well operated and maintained site. This document has been developed to address all of the conditions of consent or direct to appropriate plans - - The DA contains the CDC s. This document has been developed to address all of the conditions of consent or direct to appropriate plans The environmental aspects identified in the SEE are addressed in this plan. The onsite parking provisions have been maintained and the multi-direction internal roadway is to be clearly defined in accordance with the updated Traffic Operations Assessment. Use of articulated trucks in place of B-doubles has been implemented. Minimal sugar grinding is conducted at the site. States that production volumes of 150,000 tonnes/yr, will not increase daily traffic volumes. Traffic numbers comply with traffic statement. Allied Mills have not exceeded 150,000t/yr production. This clause outlines the procedure for public display of the proposed development prior to construction. Given that consent has been granted for this development, it would indicate that Clause 78 has been met 1.2 g) These conditions. The Kingsgrove site is well operated and maintained. This document has been developed to address all of the conditions of consent or direct to appropriate documents This Document This Document Section 4 Traffic Operations Assessment 7 November This Document PAGE 29

82 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 30 of 72 Condition Description of requirements/commitment Implementation EMP Reference 1.3 The production of the entire site will be limited to a total of 150,000 tpa. Noted and conforms Not Used Before any construction work starts, the Applicant must obtain a construction certificate for the proposed development from the Principle Certifying Authority. Certificate number CP , issued by Trevor R Howse and Associates Certificate CP Before any commencement of operations, the Applicant must obtain an occupation certificate for the development from the Principle Certifying Authority. 2.1 Throughout the life of the development, the Applicant must secure, renew, maintain and comply with all the relevant statutory approvals applying to the development. 2.2 The Applicant must ensure that all contractors and sub contractors are aware of, and comply with the conditions of this consent and the approved Construction Management Plan (See conditions 3.1 and 3.2). 2.3 Prior to construction on any aspect of the development commencing, the Applicant must certify in writing to the satisfaction of the Director General, that it has obtained all the necessary statutory approvals for the construction work, and complied with all the relevant conditions of this consent and / or any other statutory requirements for this development pertaining to that aspect of the development to be constructed. The necessary statutory approval includes a permit under Part 3A of the Rivers and Foreshores Improvement Act Prior to commencement of operations of the food processing plant, the Applicant must certify in writing to the satisfaction of the Director General, that it has obtained all the necessary statutory approvals for the operations, and complied with all the relevant conditions of this consent and / or any other statutory requirements for this development. 3.1 The Applicant must prepare and implement a Construction Management Plan for the development. This plan must: Certificate number CP AR issued by Trevor R Howse and Associates Refer Conditions 3.2, 3.4, 4.20, 4.27, 5.2 and A site induction has been prepared that identifies the CDC s requirements including incident response, dust and noise issues. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. 3.1 a) Describe the proposed construction works and associated traffic; N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. 3.1 b) Outline the proposed construction work program; N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Certificate CP AR Section PAGE 30

83 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 31 of 72 Condition Description of requirements/commitment Implementation EMP Reference 3.1 c) Identify all the relevant statutory requirements and conditions of consent that apply to the construction phase of the development; 3.1 d) Set standards and performance measures for each of the relevant environmental matters associated with the construction work; 3.1 e) Describe what actions and measures will be implemented to mitigate the potential impacts of the construction works, and to ensure that these works will comply with the relevant standards and performance measures; Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. 3.1 f) Describe in details what measures and procedures will be implemented to : N/A - Construction activities were carried out by Goodman - Fielder prior to Allied Mills taking possession of the Manage construction traffic; - Kingsgrove site and the CDC s. Manage construction noise, including noise monitoring as indicated in - Condition 6.2; Mitigate any potential dust impacts; - Prevent soil contamination; - Register and respond to complaints during the construction period; - Respond to any emergencies; and - Respond to the discovery of any archaeological relics or sites during the site works. 3.1 g) Explain how the environmental performance of the construction works will be monitored, and what actions will be taken if any non compliance is detected; 3.1 h) Describe the role, responsibility, authority, accountability and reporting of key personnel involved in the construction of the development; 3.1 i) Include a Soil and Erosion Control plan which describes what measures will be used to minimise soil erosion and the discharge of sediment and other pollutants to nearby land, water or drains during the construction activity. This plan must be prepared in accordance with the requirements for plans in the Department of Housing s publication Managing Urban Storm water, Soils and Construction and council requirements; 3.1 j) Include a detailed Storm water Management Plan for the development, to mitigate the impacts of storm water runoff from the development and its N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the PAGE 31

84 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 32 of 72 Condition Description of requirements/commitment Implementation EMP Reference operations; 3.1 k) Include a detailed Landscape Management Plan (See Conditions ) 3.2 No construction work may occur on any aspect of the proposal before the Construction Management Plan for that particular aspect of the development has been approved by the Director General. 3.3 The Applicant must prepare a Construction Safety Study for the proposed development, in accordance with the Department s Hazardous Industry Planning Advisory Paper No 7 Construction Safety Guidelines. 3.4 No construction work may occur before the Construction Safety Study has been approved by the Director General. 3.5 The Applicant must prepare and implement an Environmental Management Plan for all future operations at the site. This plan must: Kingsgrove site and the CDC s. Refer to Conditions N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. N/A - Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. This Document. PAGE This Document 3.5 a) Describe the proposed operations; An overview of site operations has been provided. Section b) Identify all the relevant statutory requirements that apply to the A review of the statutory requirements relating to the Section 3 operation of the development; operations has been completed. 3.5 c) Set standards and performance measures for each of the relevant Standards/performance measures for relevant Section 4 environmental issues; environmental issues have been defined. 3.5 d) Describe what actions and measures will be implemented to mitigate the potential impacts of the development, and to ensure that the development meets these standards and performance measures; Mitigation measures to minimise impacts of the development have been defined. Section e) Describe what measures and procedures will be implemented to: - - Register and respond to complaints A complaint management procedure has been outlined Section 6.3 Respond to potential emergencies, such as plant failure An emergency response procedure has been developed Section 7 Section f) Describe the role, responsibility, authority, and accountability of all the key personnel involved in the operation of the development; 3.5 e) Incorporate the detailed Environmental Monitoring Program (see Conditions ); and Roles, responsibilities, authorities and accountabilities of key personnel have been defined. Refer to Conditions h) Include the following: - - Management strategies for the control of noise, dust and storm water; Management strategies for each of the defined environment aspects have been developed. Appendix B, Appendix C and Appendix D A Traffic Management Plan (see Conditions ); Refer to Conditions Appendix E A Landscape Management Plan (see Conditions ); and Refer to Conditions Appendix F

85 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 33 of 72 Condition Description of requirements/commitment Implementation EMP Reference A Waste Management Plan (see Conditions ). Refer to Conditions Appendix G 3.6 The Applicant must ensure that a copy of the Environmental Management Plan is submitted to Council and is publicly available. Allied Mills will supply a copy of the EMP to Council for public exhibition after it has been approved by the Director- General The Applicant must review and update the Environmental Management Plan regularly, or as directed by Director-General. 3.8 The Environmental Management Plan must be approved by the Director- General before the mixing plant may be commissioned. 4.1 Unless otherwise agreed with the Director-General, construction activities will be restricted to the following times. Monday to Friday 7am to 5pm; Saturday 8am to 5pm; No construction work to take place on Sunday or Public Holidays 4.2 Construction activities may be conducted outside the times specified in Condition 4.1, if: (a) a delivery of material is required, outside the hours specified, by Police or another authority for safety reasons; and/or (b) the operation or personnel or equipment is endangered; and prior notification is provided to the Council within a reasonable time limit. 4.3 The approved hours may be varied with the prior written consent of the Council only where it is satisfied that the amenity of residents in the locality will not be adversely affected. If the approved hours are varied under this condition, the Applicant is to provide the Department with a copy of the Council s written consent. 4.4 Construction noise must not exceed the construction noise levels outlined in the EPA Environmental Noise Control Manual. In applying these noise criteria, the background noise level should be measured and interpreted as specified in the EPA Industrial Noise Policy. 4.5 Noise emissions from the operations at the Goodman Fielder facility must not exceed the following criteria: Project-Specific Residential Noise Limits: Receiver Day (7am-6pm) Noise Limits (L Aeq) db(a) Evening (6pm-10pm) Night (10pm-7am) Residents to the North Annual reviews of this plan are to be completed (or following a significant incident). Allied Mills will submit the EMP to the Director-General for approval. No construction activities are currently taking place - No construction activities are currently taking place - No construction activities are currently taking place - No construction activities are currently taking place - A noise management strategy has been developed to ensure compliance with the residential noise limits defined. PAGE Appendix B

86 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 34 of 72 Condition Description of requirements/commitment Implementation EMP Reference West (Baranbali St and Sth Tallawarra St) Residents to the North (Armitree St) Residents to the West (North Tallawarra St) A spill tank must be placed beneath the coupling points of the edible oil tanker and the above ground edible oil tank. 60L spill trays are carried by each edible oil tanker. 4.7 Tankers supplying edible oil must use brake interlocks. As a condition of entry to the site, all edible oil tankers must have brake interlocks installed 4.8 Bunding must be provided around the edible oil tank, with a minimum capacity of 110% the volume of the tank. 4.9 Storm water isolation valves must be installed at all points where storm water from the site can enter the council storm water mains. These valves must be closed in the event of a fire or spill The above storm water protection features (Condition 4.6 to 4.9) must be operational before the mixing plant is commissioned. Current bunding around the edible oil tankers has the capacity to hold 168% of the volume of the tanks. (Tank capacity 38ML, bund capacity 64ML) Two stormwater isolation valves are currently installed at the site. Weekly inspections are completed by the TSH&E Coordinator to confirm they are functioning appropriately. All measures are currently operational and are regularly maintained Not Used The Applicant shall install alarms and shut-off valves on silos to prevent overfilling Dust emissions from equipment must comply with applicable standards set out in Table B of the Clean Air (Plant and Equipment) Regulation Emissions from vehicles associated with the proposed development must comply with applicable requirements of the Clean Air (Motor Vehicle Fuels) Regulation 1997 under the Protection of the Environment Operations Act All activities in or on the premises must be carried out in a manner that will minimise the generation, or emission from the premises, of wind-blown or traffic generated dust using the measures proposed in the SEE All areas in or on the premises must be maintained in a manner that will minimise the generation, or emission from the premises, of wind-blown or Alarms and shut off valves are installed on silos to prevent overfilling Equipment are enclosed within buildings (all silo vents, bag filters etc). Monitoring conducted for internal areas. The bulk delivery emergency vent is the only external dust source (35mm vent, rarely used and is regularly maintained). The silo rooms are also under negative pressure. Vehicles are visually monitored entering the site to ensure that release of black/white smoke from vehicle does not continue for longer than 10sec. All vehicles associated with the site are to be appropriately maintained and registered. As above, the majority of activities are within enclosed buildings. All trafficable areas of the premises are sealed, the remaining areas are vegetated. Appendix D Appendix D Appendix D Appendix D - Appendix C Appendix C Appendix C Appendix C Appendix C PAGE 34

87 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 35 of 72 Condition Description of requirements/commitment Implementation EMP Reference traffic generated dust, using the measures proposed in the SEE The Applicant must prepare and implement a Traffic Management Plan for the development. This Plan must: 4.17 a) Describe the routes which will be used by trucks associated with the development; A Traffic Management Plan (TMP) has been prepared and implemented. The TMP shows the routes to be used by trucks associated with the development. PAGE 35 Appendix E Appendix E 4.17 b) Outline the hours during which trucks will operate in the vicinity of the site; The TMP outlines the hours of operation. Appendix E 4.17 c) Indicate the average and maximum number of daily and weekly truck movements which will be associated with the proposed development; The TMP provides details of the truck movements associated with the Allied Mills site. Appendix E 4.17 d) Describe in detail what measures and procedures will be implemented to: - Appendix E Minimise the number of trucks which will be used to transport goods; Minimise noise and vibration associated with truck traffic; Ensure trucks travel in a safe manner; Minimise road damage; Minimise air pollution from exhaust; and Record and respond to complaints regarding traffic 4.17 e) Incorporate monitoring to ensure the requirements of the Traffic Management Plan are being met (refer to Condition 6.4) The Applicant must develop the Traffic Management Plan in consultation with the RTA and Council The Applicant shall review and, where necessary, update the Traffic Management Plan annually as part of the AEMR, and also as directed by the Director-General 4.20 The Traffic Management Plan must be approved by the Director-General before the expanded facility is commissioned Before the plant may be commissioned, the Applicant must design and construct a new parking area providing a minimum total of 70 parking spaces on the site. Employees and visitors must not park on The Crescent. The largest size trucks available to use in accordance with Council guidelines are used to minimise the number of trucks. All vehicles used must be fully registered and regularly maintained. Driver behaviour is also covered during the site induction process. Driver behaviour is covered during the site induction process. Driver behaviour is covered during the site induction process. All vehicles used must be fully registered and regularly maintained. Details on the complaint handling process are included within the TMP. The TMP includes details on the monitoring of heavy vehicle traffic associated with the site. The TMP has been developed in accordance with RTA and Council guidelines. Annual reviews (and if necessary updates) of the TMP will be completed by Allied Mills. The TMP will be submitted to the Director-General for approval. There are currently 74 parking spaces at the site. The induction includes instructions that vehicles are not to be parked on the Crescent. Appendix E Appendix E Appendix E Appendix E Appendix E Appendix E Appendix E Figure 2-1

88 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 36 of 72 Condition Description of requirements/commitment Implementation EMP Reference 4.22 Trucks servicing the site during construction and operations must not park on The Crescent at any time The carpark design must conform with AS , and commercial parking must conform with AS The Applicant shall implement the recommendations of the Traffic Operations Assessment dated 7 November 2011 and prepared by Sinclair Knight Merz, specifically a) Parking restriction signage in the vicinity of Gate A on the Crescent; b) A carriageway centre-line in the vicinity of Gate A on the Crescent; and c) Advance signage or a secondary traffic light head in the vicinity of Gate A, In consultation with council, and to the satisfaction of the Department, within 6 months of the approval of DA MOD The Applicant must ensure that any external lighting associated with the development is mounted, screened, and directed in such a manner so as not to create a nuisance to surrounding land uses. The lighting must be the minimum level of illumination necessary The Applicant must prepare and implement a Waste Management Plan for the development in consultation with Council. This plan must describe in detail the waste management system, including - The types and quantities of waste which will be generated at the site; and - How waste will be stored on-site, transported, and disposed of off-site The Waste Management Plan must have been approved by the Director- General before the mixing plant may be commissioned After reviewing the Waste Management Plan, the Director-General may require the Applicant to address certain matters identified in the plan. The Applicant must comply with any reasonable requirements of the Director- General The Applicant must prepare and implement a detailed Landscape Management Plan for the development. This plan must; - Describe in detail how the site will be landscaped, including the location and species of all planting; and Truck arrivals are scheduled to avoid delays and reduce congestion at the site. The induction package instructs that vehicles are not to be parked on the Crescent. The carpark conforms with the relevant standards. - The recommendations of the SKM assessment are to be implemented within 6 months of DP&I acceptance and issuance of MOD2 All adjacent land uses are industrial/commercial and operate normal business hours. Lighting is directed inward and does not create a nuisance to neighbouring properties. A Waste Management Plan has been developed for the Kingsgrove site that details the types and quantities of waste at the site and how the waste is stored, transported and disposed of offsite. The Waste Management Plan is currently being submitted to the Director-General Allied Mills will address any reasonable requirements raised from the Director-General s review of the Waste Management Plan A Landscape Management Plan (LMP) has been developed that outlines the location and species of plants on the site. The LMP also details the landscaping maintenance program at the Allied Mills site. Section Appendix G - - Appendix F PAGE 36

89 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 37 of 72 Condition Description of requirements/commitment Implementation EMP Reference - Explain how this landscaping will be managed and maintained over time The Landscape Management Plan must be developed in consultation with Council. The Plan must have been approved by the Director-General before commissioning the facility After reviewing the Landscape Management Plan, the Director-General may require the Applicant to comply with any reasonable requirements of the Director-General If, in the opinion of a Department of Land and Water Conservation officer, any activity is being carried out in such a manner that it may damage or detrimentally affect a watercourse/foreshore, or damage or interfere in any way with any work, such activity on that section of the watercourse/foreshore shall cease immediately upon oral or written direction of such officer Work as executed survey plans shall be forwarded to the DLWC upon request Operations shall be conducted in such a manner as not to cause environmental damage on or off the site, not increase the erosion of adjacent watercourse/foreshore banks. The Applicant shall carry out any instructions given by the DLWC with a view to preventing damage and to restore the site. The LMP has been developed in accordance with Council guidelines. The LMP will be submitted to the Director-General for approval. Condition noted and any direction will be followed if the situation ever arises. Condition noted and any direction will be followed if the situation ever arises. There is no runoff directly from the site into the nearby stormwater drain (the RTA owned drain is concrete lined), two stormwater drainage lines collect stormwater from the site and direct it the drainage lines Work to be carried out in accordance with the plans presented to DLWC. Works have been carried out generally in accordance with the plans, however no record of these being submitted to DLWC The rehabilitation of any area affected by the proposal is to be in accordance with any approval of direction issued by the DLWC, and is the responsibility of the permit holder and the owner and occupier of the land. 5.1 The Applicant must prepare a detailed Fire Safety Study covering all of the operations at the site to demonstrate BCA compliance. The Study must cover all aspects detailed in the Department s Hazardous industry Planning Advisory Paper No.2 Fire Safety Study Guidelines and the NSW Government Best Practice Guidelines for Contaminated Water Retention and Treatment Systems. The Study must address, but not be limited to fire safety issues associated with dust explosions and storage of vegetable oils. The Fire Safety Study must be submitted to the Director-General for approval, in consultation with the NSW Fire Brigades. Approval must be obtained before the issues of construction certificates. The requirement to rehabilitate any area which has been affected by the development has been noted and will be complied with if necessary. Currently there has been no need to rehabilitate any area of the site. A Fire Safety Study was prepared for Allied Mills (formerly Goodman Fielder Ltd) by Environmental Audits of Australia (EAA), Report # 21069FSS. This report was submitted to NSW DoP and NSW FB on 24 th October, Fire Safety Study Report # 21069FSS 5.2 At least one month prior to the commencement of commissioning, or within A Deflagration Management Strategy (DMS) was prepared Deflagration PAGE 37

90 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 38 of 72 Condition Description of requirements/commitment Implementation EMP Reference such period as otherwise agreed by the Director-General, the Applicant shall prepare and submit for the approval of the Director-General a Deflagration Management Strategy. The Strategy shall be prepared and implemented with the aim of minimising situations conductive to explosions involving fine combustible particulates. The Strategy shall include, but not necessarily be limited to: 5.2 a) Identification of materials stored and/or handled at the development that may be involved in deflagration incidents, including the location, quantity and state(temperature, moisture, agitation etc) of such materials; 5.2 b) A description of the processes used to handle fine particulate combustibles, with specific consideration of components of such processes involving agitation, electricity and heat; 5.2 c) Details of how the development will meet the requirements of relevant Australian Standards including AS Classification of Hazardous Areas Part 2 Combustible Dusts and AS/NZS Electrical Equipment for Explosive Atmospheres Selection, Installation and Maintenance Part 1 General Requirements; 5.2 d) Protocols and procedures for the handling of fine combustible particulates, including consideration of process atmospheric composition, spark avoidance and measures to minimise the formation of suspended particulate clouds; 5.2 e) Protocols and procedures for periods of operation during which a greater potential for deflagration exists, including start-up and shut-down (both controlled in an emergency); 5.2 f) Details of how dust levels in the building will be monitored, and how the dust collection system will be maintained; and 5.2 g) Details of training programs to ensure that all relevant employees are aware of the potential for deflagration and the measures implemented to minimise deflagration incidents. 5.3 No later than one month prior to the commencement of commissioning, or within such period otherwise agreed with the Director-General, the Applicant shall prepare and submit for approval of the Director-General the studies set out under (a) and (b) below. Commissioning shall not commence until approval has been given by the Director-General. for Allied Mills (formerly Goodman Fielder Ltd) by Environmental Audits of Australia (EAA), Report # Comments were received from DP&I on 11/08/2011, and addressed in an update to the 2010 SKM Risk Audit submitted on 10/05/2012. A summary of materials stored at the site and details of the location, quantity and state are included in the DMS Report. The DMS Report covers the management of dusts, control systems, extraction systems and fail safe systems employed. The classification of hazardous areas at the site is covered in Section 4 of the DMS Report. Dust suppression, extraction and filtrations systems provided at the site are covered in the DMS Report. The protocols and procedures for operating at high risk times (such as start-up and shut-down) are covered in the DMS Report. Brief discussion of dust monitoring and collection in the DMS Report, although systems are enclosed and external dust monitoring covered under maintenance and housekeeping procedures in ENABLE SMA database Training programs covered under Allied Mills Internal e- procedures system - ENABLE. An Emergency Response Plan (ERP) has been prepared and documented for the site. Management Strategy (DMS) Report #52004 DMS Report DMS Report DMS Report DMS Report DMS Report DMS Report DMS Report Emergency Response Plan PAGE 38

91 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 39 of 72 Condition Description of requirements/commitment Implementation EMP Reference a) A comprehensive Emergency Plan and detailed emergency procedures for the site, prepared by a duly qualified person or team. This Plan should include details procedures for the safety of all people in the vicinity of the site who may be at risk from operations at the site. The Plan shall be in accordance with the Department s Hazardous Industry Planning Advisory Paper No.1 Industry Emergency Planning Guidelines b) A document setting out a comprehensive Safety Management System, covering all operations onsite and associated transport activities involving hazardous materials. The document shall clearly specify all safety-related procedures, responsibilities and policies, along with details of mechanisms for ensuring adherence to procedures. Records shall be kept onsite and shall be available for inspection by the Director-General upon request. The Safety Management System shall be developed in accordance with the Department s Hazardous Industry Planning Advisory Paper No.9 Safety Management. 5.4 Dangerous Goods storage must be in accordance with the Australian Dangerous Goods Code, relevant Australian Standards, and Work Cover requirements. Spill cleanup kits and procedures must be made available and used in the event of a spill. 6.1 The Applicant must prepare and implement a detailed Environmental Monitoring Program for the development in consultation with the EPA. The program must: Made up of numerous Allied Mills safety documents/ and procedures within the Document Management System. Refer SKM audit findings A WorkCover NSW licence has been received for the site (lic no 35/035076, exp date 3/5/2012). Spill kits are stocked and provided at the edible oils station An Environmental Monitoring Program has been developed in this plan. 6.1 a) Identify what environmental issues will be monitored; The environmental aspects that could pose issues are identified. 6.1 b) Set standards and performance measures for these environmental issues; Standards/performance measures are identified in this plan. 6.1 c) Describe in detail how these issues will be monitored, who will conduct the monitoring, how often the monitoring will be conducted, and how the results of this monitoring will be recorded and reported to the Director-General and other relevant authorities. 6.1 d) Indicate what actions will be taken, or procedures followed, if any noncompliance is detected; and 6.1 e) Include the following: A Noise Compliance Monitoring Program (see below) to determine the level of compliance with the noise criteria in Condition 4.5; and Traffic Monitoring The environmental monitoring program has been broken down into the relevant aspects and is presented in this plan. A noise management strategy has been developed to conform with the noise criteria in Condition 4.5 A noise management strategy has been developed to conform with the noise criteria in Condition 4.5; and A Traffic Management Plan has been developed for the site. SAP Dangerous Goods Licence Section 9.2 Section 4 Section 4 Table 9-2 Section 9.4 Appendix B Appendix E PAGE 39

92 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 40 of 72 Condition Description of requirements/commitment Implementation EMP Reference 6.2 The Applicant must conduct noise monitoring during the construction phase at the site boundaries and the nearest potentially affected residential areas. Monitoring must be conducted in accordance with EPA guidelines. 6.3 If substantiated community noise complaints occur, the Director-General may direct the Applicant to commission and pay the full cost of a noise audit. Should any noise audit demonstrate an exceedance of the project specific noise limits outlined in Condition 4.5 (using distance attenuation calculations), the Applicant shall employ mitigation measures to reduce noise impacts from the site, to the satisfaction of the Director-General. 6.4 The Applicant must monitor compliance with the Traffic Management Plan described in Condition Monitoring must occur within three months of commissioning the mixing plant, and every six months thereafter. 6.5 The Environmental Monitoring Program must have been approved by the Director-General before the plant may be commissioned. 6.6 The Environmental Monitoring Program, the Director-General may require the Applicant to address certain matters identified in the program. The Applicant must comply with any reasonable requirements of the Director- General. 7.1 Twelve months after commissioning the food processing plant and annually thereafter for the duration of the development, the Applicant must submit an Annual Environment Management Report to the Director-General and the Council. This report must: 7.1 a) Identify all standards, performance measures, and statutory requirements the development is required to comply with; 7.1 b) Review the environmental performance of the development to determine whether it is complying with these standards, performance measures and statutory requirements. 7.1 c) Identify all the occasions during the previous year when these standards, performance measures, and statutory requirements have not been complied with; 7.1 d) Include a summary of any complaints made about the development and indicate what actions were taken (or are being taken) to address these complaints; 7.1 e) Include the detailed reporting from the Environmental Monitoring program (see Condition ), and identify any trends in the monitoring over the life of the project; and Construction activities were carried out by Goodman Fielder prior to Allied Mills taking possession of the Kingsgrove site and the CDC s. A noise management strategy has been developed to comply with the limits of Condition 4.5. Monitoring is conducted daily by the site entry system. The Environmental Monitoring Program is being submitted to the Director-General with this plan for approval. Allied Mills will comply with any reasonable requirements of the Director-General. An Annual Environmental Management Report (AEMR) will be compiled and issued to the Director-General and Council. The AEMR will identify all standards and statutory requirements (provided in this plan) The AEMR will review the performance of Allied Mills against the standards and statutory requirements provided in this plan. The AEMR will identify any non-conformances detected during the previous year. The AEMR will include a summary of any complaints recorded during the previous year. The AEMR will include the detailed reporting from the Environmental Monitoring Program - Table 9-2; and Appendix B Appendix E - - Section 10 Sections 3 and 4 Sections 3 and 4 Section 9.4 Section 6.3 Section 9 PAGE 40

93 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 41 of 72 Condition Description of requirements/commitment Implementation EMP Reference 7.1 f) Where non-compliance is occurring, describe what actions are or will be taken to ensure compliance, who will be responsible for carrying out these actions, and when these actions will be implemented. 7.2 After reviewing the Annual Environmental Management Report, the Director- General may require the Applicant to address certain matters identified in the report. The Applicant must comply with any reasonable requirements of the Director-General. 7.3 Within 12 months of commissioning the food processing plant, and every three years thereafter, unless the Director-General directs otherwise, the Applicant must commission and pay the full cost of an Independent Environmental Audit. The Independent Environmental Audit must: 7.3 a) Be conducted by a suitably qualified, experienced, and independent person whose appointment has been endorsed by the Director-General; 7.3 b) Be consistent with ISO Guidelines and General Principles for Environmental Auditing, and ISO Procedures for Environmental Auditing or updated version of these guidelines/manuals; 7.3 c) Assess the environmental performance of the development, and its effects on the surrounding environment; 7.3 d) Assess whether the development is complying with the relevant standards, performance measures, and statutory requirements; 7.3 e) Review the adequacy of the Applicant s Environmental Management Plan, and Environmental Monitoring Program; and if necessary: 7.3 f) Recommend measures or actions to improve the environmental performance of the plant, and/or the environmental management and monitoring systems. 7.4 Within 2 months of commissioning the audit, the Applicant must submit a copy of the audit report to the Director-General. After reviewing the report, the Director-General may require the Applicant to address certain matters identified in the report. The Applicant must comply with any reasonable requirements of the Director-General. The AEMR will include a summary of any actions taken in response to an identified non-compliance in the previous year. Allied Mills will comply with any reasonable requirements issued by the Director General in response to the AEMR. Allied Mills will commission an Independent Environmental Audit of the food processing plant every three years. Allied Mills will ensure that the auditor is suitably qualified, experienced and independent, and approved by the DP&I prior to commissioning.. The audit will be consistent with the requirements of ISO19011:2003 Guidelines for quality and/or environmental management systems auditing (or an updated version of the guidelines). The audit will include an assessment of the environmental performance of the development and its effects on the surrounding environment. The audit will assess if Allied Mills are complying with relevant standards, performance measures and statutory performance. The audit will review the adequacy of Allied Mills EMP and Environmental Monitoring Program. The audit will (if necessary) provide actions to improve the performance of the plant. Allied Mills commissioned SKM to complete an initial environmental audit of its Kingsgrove operations in July Due to the initial audit requiring extensive searching to locate key documents the initial timeframe to submit to the Director-General was unable to be met. PAGE 41 Section An environmental audit was completed by SKM in July SKM environmental audit was submitted on 22 October Within 24 hours of any accident or potential incident with actual or potential An Incident Reporting process has been developed which Section 7.2

94 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 42 of 72 Condition Description of requirements/commitment Implementation EMP Reference off-site impacts on people or the biophysical environment, a report must be supplied to the Department outlining the basic facts. A further detailed report must be prepared and submitted following investigations of the causes and identification of necessary additional preventative measures. This report must be submitted to the Director-General no later than 14 days after the incident or potential incident. 8.2 The Applicant must maintain a register of accidents, incidents and potential incidents. The register must be made available for inspection at any time by the independent hazard auditor (refer to condition 8.3) and the Director- General. 8.3 Twelve months after the commencement of operations, and every three years thereafter, unless the Director-General directs otherwise, the Applicant must commission and pay the full cost of a comprehensive hazard audit. The hazard audit must: 8.3 a) Be conducted by a suitably qualified, experienced, and independent person whose appointment has been endorsed by the Director-General; 8.3 b) Be conducted in accordance with the Department s Hazardous Industry Planning Advisory Paper No.5 Hazard Audit Guidelines ; 8.3 c) Include, but not be limited to, a review of the site safety management system and a review of all entries made in the incident register since the previous audit; 8.4 Within one month of commissioning the audit, the Applicant must submit a copy of the audit report to the Director-General. After reviewing the report, the Director-General may require the Applicant to address certain matters identified in the report. The Applicant must comply with any reasonable requirements of the Director-General. 9.1 If the Applicant Hurstville City Council, and/or any NSW Government agency, other than the Department of Urban Affairs and Planning, cannot agree on any aspect of this consent, other than a General Term of Approval, the matter may be referred by any of these parties to the Director-General or, if necessary, the Minister, whose determination on the dispute shall be binding on all parties. includes the compilation of an immediate (within 24 hours) basic report and a detailed investigation (within 14 days), in this plan. An incident log is maintained on site. Section 7.2 Allied Mills will commission an Independent Hazard Audit of the food processing plant every three years. Allied Mills will ensure that the auditor is suitably qualified, experienced and independent and endorsed by DP&I prior to comissioning. The audit will be consistent with the requirements of the NSW DoP Hazard Audit Guidelines (HIPAP #5), (or an updated version). The audit will as a minimum a review of the site safety management system and all entries in the incident log since the previous audit. Allied Mills commissioned SKM to complete an initial hazard audit of its Kingsgrove operations in July Due to the initial audit requiring extensive searching to locate key documents the initial timeframe to submit to the Director-General was unable to be met. All parties have agreed on the consent conditions. - A hazard audit was completed by SKM in July SKM hazard audit was submitted on 22 October 2011 PAGE 42

95 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 43 of 72 Appendix B Noise Management Strategy Potential Impacts: Risk: Environmental Outcomes Major Compliance Requirements: Noise from operations causes community complaints Community Complaints Low most works are within enclosed buildings and surrounding land use includes other industrial businesses and a major highway. The site will be run in a manner so that environmental noise is not a nuisance to nearby residents by ensuring that appropriate noise management practices are implemented onsite. Conditions 4.5 of Development Consent Noise Criteria Noise emissions from operations at the site must not exceed the following criteria: Receiver Residents to the NW (Baranbai St and Sth Tallawarra St) Resident to the N (Armitree St) Residents to the W (Nth Tallawarra St) Noise Limits (LAeq) dba Day (7am 6pm) Evening (6pm 10pm) Night (10pm 7am) Condition 6.3 of Development Consent Noise Compliance Monitoring Program Monitoring: If substantiated community noise complaints occur, the Director-General may direct the Applicant to commission and pay the full cost of a noise audit. Should any noise audit demonstrate an exceedance of the project specific residential noise limits outlined in Condition 4.5 (using distance attenuation calculations), the Applicant shall employ mitigation measures to reduce noise impacts from the site, to the satisfaction of the Director-General. Noise monitoring will be undertaken by a suitably qualified specialist and results will be provided to Allied Mills. Mitigation Measures Reference Control Measures Action By Timing Sign-off/Date CDC Cond. 4.5 Plant/equipment are to be contained within enclosed Site Manager Before Commissioning Completed buildings as much as possible. CDC Cond. 6.3 If a community complaint/enquiry is received regarding noise from the site, Allied Mills will organise for an appropriate noise monitoring program to be instigated. Site Manager As necessary Within one week of receiving complaint PAGE 43

96 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 44 of 72 Appendix C Potential Impacts: Risk: Environmental Outcomes Major Compliance Requirements: Monitoring: Air Quality Management Strategy Dust from site activities causes community complaints Dust from site activities causes water pollution Community Complaints Low as works are contained within enclosed buildings and all roads/driveways are sealed. Water Pollution Low as dust generation from works is minimal and contained within the site. The site will be operated in a manner that minimises air emissions from the property Condition 4.12 Alarms and shut off valves shall be installed on silos to prevent overfilling; Condition 4.13 Dust emissions from equipment must comply with the Clean Air (Plant and Equipment) Regulation; Condition 4.14 Emissions from vehicles associated with the site must comply with the Clean Air (Motor Vehicles and Motor Vehicle Fuel) Regulation; Condition 4.15 All site activities are to be carried out in a manner to minimise generation (or emission) of wind-blown or traffic generated dust; and Condition 4.16 All areas at the site are to be carried out in a manner to minimise generation (or emission) of wind-blown or traffic generated dust. Visual monitoring of the site for dust generation by Allied Mills staff Mitigation Measures Reference Control Measures Action By Timing Sign-off/Date CDC Cond Alarms and shut-off valves are installed on silos to prevent overfilling. Test and maintain alarms and shut off valves to ensure operations. Site Manager Before Commissioning Completed CDC Cond. 4.13; Clean Air (Motor Vehicles & Motor Vehicle Fuels) Regulation 1997 CDC Cond. 4.14; Clean Air (Motor Vehicles & Motor Vehicle Fuels) Regulation 1997 CDC Cond CDC Cond Visually monitor vehicles equipment exhausts to ensure that release of black/white smoke does not exceed 10sec. Maintain plant. Do not use plant which exceeds limit. Visually monitor vehicles entering the site to ensure that release of black/white smoke from vehicle does not continue for longer than 10sec. All vehicles associated with the site are to be appropriately maintained and registered. The majority of plant/equipment are contained within enclosed buildings to reduce the possibility of dust emissions. Silo rooms are also maintained under negative pressure to minimise dust emission potential. All trafficable areas onsite are sealed to reduce exposure to dust and site speed limits are enforced. Landscaping is in place in areas that have not been sealed. PAGE 44 Site Manager or Designated Person Warehouse Manager Site Manager Site Manager As necessary As necessary Before Commissioning Before Commissioning As necessary As necessary Completed Completed

97 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 45 of 72 Appendix D Stormwater Management Strategy Potential Impacts: Risk: Environmental Outcomes Major Compliance Requirements: Monitoring: Water pollution from spills entering stormwater system Water Pollution Moderate appropriate controls are in place, but procedures must be followed The site activities will not adversely impact the water quality of the council s stormwater mains Condition 4.6 A spill tank must be placed beneath coupling points of the edible oil tanker and the above ground edible oil tank; Condition 4.7 Tankers supplying edible oil must use brake interlocks; Condition 4.8 Bunding around edible oil tank must have a minimum capacity of 110%; Condition 4.9 Stormwater isolation valves must be installed at all stormwater exit points from the site; Maintenance inspection s of isolation valves, use of spill tray s and truck brake interlocks. Mitigation Measures Reference Control Measures Action By Timing Sign-off/Date CDC Cond. 4.6 Each truck carries a spill tray with a capacity of approx 60L. Occasional spot checks to ensure the spill trays are being used. Site Manager or Designated Person As necessary As necessary CDC Cond. 4.7 CDC Cond. 4.8 CDC Cond. 4.9 Brake interlocks are a condition of entry to the site for edible oil tankers. The edible oil storage tanks at the site can hold 38ML of product, the bund capacity around the storage tanks is 64ML. Regular inspections are required to ensure capacity of bunding is maintained Two isolated systems are operational at the site. Regular inspections are completed to ensure the systems are Site Manager or Designated Person Site Manager or Designated Person Site Manager or Designated Person functioning Best Practice Regular cleaning maintenance of stormwater pits Site Manager or Designated Person Annually Weekly Weekly Weekly Trucks Registration Weekly HS&E Inspection Weekly HS&E Inspection Weekly HS&E Inspection PAGE 45

98 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 46 of 72 Appendix E Allied Mills Kingsgrove Traffic Management Sub Plan Revision 3.1 Effective: PAGE 46

99 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 47 of 72 Contents 1. Introduction Environmental Management Plan purpose Environmental Management Plan scope Environmental Management Plan objectives Preparation of this EMP and Sub-Plans 6 2. Overview of site operations Bulk deliveries Truck docks / driveway Offices / kitchens and laboratories Production floor Silos Oil storage 8 3. Legislative and regulatory requirements Conditions of Development Consent (CDCs) Legislation Standards and guidelines Environmental aspects Environmental impacts and controls Overview Environmental management strategies Environmental management sub-plans Site induction and training Communications and reporting Reporting Communications Complaints management Emergency response Incident response Incident reporting Environmental management responsibilities Environmental roles and responsibilities Site Manager National Work Health Safety and Environmental (WHSE) Manager and Coordinator Production Managers Warehouse Manager 21 PAGE 47

100 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 48 of Maintenance Manager Employees, Contractors and Delivery Drivers Environmental Contractors Monitoring, inspection & auditing environmental performance Overview Environmental monitoring program Inspections and audits Audit action plan Non-compliances Environmental reporting Management review 27 Appendix A Conditions of Development Consent 29 Appendix B Noise Management Strategy 43 Appendix C Air Quality Management Strategy 44 Appendix D Stormwater Management Strategy Introduction Heavy Vehicle Route Hours of Operation Daily Deliveries and Dispatch Mitigation Measures Complaint/Incident Management Truck Monitoring Site Entry and Exit Management Review Introduction Site Landscaping Landscape Maintenance Council Landscaping Requirements Management Review Introduction Waste Streams Onsite Storage Waste Disposal Management Review 70 PAGE 48

101 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 49 of 72 Appendix H: Environmental Inspection Report Template 71 Appendix J Emergency Contacts 74 PAGE 49

102 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 50 of Introduction Allied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). The operation of this plant requires the delivery of flour, oil and other ingredients to process these into various products and the dispatch of final product. The delivery of these materials is the subject of conditions 4.17 to 4.20 of the conditions of developmental consent (CDC), which this Traffic Management Plan (TMP) has been developed to address. The CDC s and the sections within this TMP where the conditions are addressed are listed within Table 3-1. Table 1-1 Condition of Consent Requirements Condition Condition Requirements TMP Section 4.17 The Applicant must prepare and implement a Traffic Management Plan for the This Document development. This Plan must: 4.17 a) Describe the routes which will be used by trucks associated with the development; Section b) Outline the hours during which trucks will operate in the vicinity of the site; Section c) Indicate the average and maximum number of daily and weekly truck movements which Section 4 will be associated with the proposed development; 4.17 d) Describe in detail what measures and procedures will be implemented to: - Minimise the number of trucks which will be used to transport goods; Section 5 Minimise noise and vibration associated with truck traffic; Section 5 Ensure trucks travel in a safe manner; Section 5 Minimise road damage; Section 5 Minimise air pollution from exhaust; and Section 5 Record and respond to complaints regarding traffic. Section e) Incorporate monitoring to ensure the requirements of the Traffic Management Plan are being met (refer to Condition 6.4). Section The Applicant must develop the Traffic Management Plan in consultation with the RTA and Council The Applicant shall review and, where necessary, update the Traffic Management Plan annually as part of the AEMR, and also as directed by the Director-General The Traffic Management Plan must be approved by the Director-General before the expanded facility is commissioned. Section 6 Section 7 Section 7 2. Heavy Vehicle Route In accordance with the planning guidelines from the Roads and Maritime Services (RMS) and Georges River Council, access to the site with articulated trucks should refrain from using local roads and remain as much as possible on state and regional roads (based on the HCC road classifications). King Georges Road is a designated state road and Kingsgrove Road, Vanessa Street, Tooronga Terrace and Commercial Road are designated regional roads, the only local road delivery trucks to PAGE 50

103 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 51 of 72 Allied Mills will utilise is The Crescent. There are two alternatives (shown on Figure 2-1) that will minimise the use of local roads for delivery to the site which are: 1) From King Georges Road delivery trucks would turn onto Tooronga Terrace and continue onto Vanessa Street, then turn left into The Crescent to enter the Allied Mills site. 2) From Kingsgrove Road delivery trucks would turn onto Commercial Road and continue onto Vanessa Street, then turn right into The Crescent to enter the Allied Mills site. PAGE 51

104 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 52 of 72 Figure 2-1: Allied Mills, Kingsgrove - Heavy Vehicle Haulage Route PAGE 52

105 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 53 of Hours of Operation The site may utilise despatch and delivery truck accesing the site over a 24 hour period depending on the needs of the site. This will assist with ensuring mitigation measures minimise the impacts of traffic accociated with the site. Employee hours of work are: 6:30 am to 8:00pm Day Shift 2:30 pm to 10:30 pm Afternoon Shift 10:30 pm to 6:30 am Night Shift The plant normally operates 24 hour day, 6 days a week. However, on occasion the plant is required to operate for 24 hours a day, 7 days a week. 4. Daily Deliveries and Dispatch A traffic impact statement (ref: R(3), Rhodes Thompson Associates 2001) was prepared with projection truck movements at full manufacturing capacity. To comply with 4.17 c) of the Conditions of Consent: The traffic management plan has used the above reference to calculate the projected truck movement at full manufacturing capacity of 150,000T per annum. Refer Table 4.1 Table 4.1 Predicted truck movements for Site Truck Movement Total Monthly Truck Average Weekly Average Daily Truck Movements Truck Movements Movements. Projected maximum truck movement as predicted in Traffic Impact Statement 3, PAGE 53

106 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 54 of Mitigation Measures In order to minimise the impacts of traffic associated with the bulk delivery of ingredients and dispatch of product to and from the Allied Mills site, the following procedures are required prior to entry. Allied Mills endevours to dispatch trucks with full loads where possible to minimise the number of trucks accessing the site. All vehicles must be registered; All vehicles must be maintained in an adequate manner; All drivers must be licensed to operate vehicles and must obey all road rules; Drivers are to avoid using compression braking and hard acceleration when on Tooronga Terrace, Vanessa Street, Commercial Road or The Crescent; and Drivers are to avoid using high beam lights when on Tooronga Terrace, Vanessa Street, Commercial Road or The Crescent. The above mitigation measures are included within the site induction and/or subcontractor agreements, which transport companies must complete prior to delivering products to the site Complaint/Incident Management Allied Mills Kingsgrove shall report any complaints or incidents into the Incident Reporting Database. The Incident Reporting Database shall record, but not necessarily be limited to: a) the date and time, of the complaint b) the means by which the complaint/incident was made c) any personal details that were provided, or if no details were provided, a note to that effect d) the nature of the complaint/incident e) any action(s) taken by the Allied Mills Kingsgrove in relation to the complaint/incident, including any follow up contact with complainant/reporter. f) if no action was taken by Allied Mills Kingsgrove in relation to the complaint/incident, the reason(s) why no action was taken The Incident reporting Database shall be made available for inspection by relevant statutory authorities on request. PAGE 54

107 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 55 of Truck Monitoring 6.1. Site Entry and Exit The site has two entry gates located on The Crescent. Gate A is the entry point for delivery / dispatch trucks, couriers and staff/visitor vehicles. Gate B is the entry gate for bulk tankers which unload at the bulk out loading point on the southern side of the site. A site layout plan with traffic direction and pedestrian pathways is provided as Figure 2-1. Gate A is the exit point for all site traffic. The location of the bulk out loading facility does not allow vehicle access to the southern side of the site when a truck is unloading. For this reason, Gate B cannot be used as an exit point for traffic. The site boundary has a security fence and gates which are only operational by access swipe tags or controlled entry via the main office. Only site employees have access swipe cards. All other entry is via an access button at the gate. The site traffic is under constant surveillance using CCTV cameras located around the site. Records are kept of the delivery / dispatch vehicles that are on the site as well as of staff and visitors. The times and volumes of traffic are recorded and used for scheduling purposes to ensure that deliveries to the plant run efficiently and this in turn ensures the traffic volumes on public roads are not too imposing to the surrounding neighbours. 6.2 Pedestrian Access Pedestrian access and walkways are identified around the site using walkways and barriers to identify the route pedestrians are to use. From the carpark located at the rear of the site, pedestrians can access the main buildings using pedestrian walkways and shared zones allowing acess to the production facility and office administration area. A shared zone is identified by a cross hatching on the ground and sign posted areas. PAGE 55

108 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 56 of 72 Figure 6-1 Allied Mills Kingsgrove site layout plan. PAGE 56

109 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 57 of Management Review In accordance with the requirement of Condition 4.19 of the CDC, this TMP will be reviewed annually by Allied Mills. Where necessary the report will be updated to reflect any relevant changes. A management review may also be required in response to a request from the Director-General. In such cases, a review will be completed and any updates will be provided to the Director-General for approval. Prior to the commissioning of the expansion to the sites capacity (beyond those approved within the conditions of consent), the TMP will be reviewed and submitted to the Director-General, in accordance with Condition 4.20 of the CDC. PAGE 57

110 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 58 of 72 Appendix F: Allied Mills Kingsgrove Landscape Management Plan Revision: 3.1 Effective: PAGE 58

111 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 59 of 72 Contents 1. Introduction Site Landscaping Landscape Maintenance Council Landscaping Requirements Management Review 64, Page 59

112 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 60 of Introduction Allied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). The site was inherited from Goodman Fielder and requires compliance with conditions 4.29 to 4.31 of the conditions of developmental consent (CDC s) (S01/00876), which this Landscape Management Plan (LMP) has been developed to address. The conditions of consent and the sections within this LMP where the conditions are addressed are listed within Table 3-1. Table 0-1 Condition of Consent Requirements Condition Condition Requirements EMP Section 4.29 The Applicant must prepare and implement a detailed Landscape Management Plan for the development. This plan must; - Describe in detail how the site will be landscaped, including the location and species of all planting; and - Explain how this landscaping will be managed and maintained over time The Landscape Management Plan must be developed in consultation with Council. The Plan must have been approved by the Director-General before commissioning the facility After reviewing the Landscape Management Plan, the Director-General may require the Applicant to comply with any reasonable requirements of the Director-General. This Document Section 2 Section 3 Section 4 Section 5 2. Site Landscaping Allied Mills acquired the Kingsgrove site from Goodman Fielder in The existing vegetation at the site has been maintained throughout the operations by Allied Mills, but a surveyed landscape plan was not provided. In accordance with the requirements of the Hurstville City Council (HCC) Development Control Plan (DCP), indigenous species have been maintained as much as possible (full requirements of the HCC DCP are included in Table 4-1). A list of species used in landscaping at the site is provided at Table 2-1. The site contains a mix of native and exotic plant species arranged and planted in a natural and maintained garden landscape. Forty-six tree, shrub and groundcover species were identified during site investigations. There were also numerous unidentified grass, herb and bryophyte species within maintained lawn areas. A general layout plan of the landscaping at the Allied Mills site is provided in Figure 2-1. Table 2-1 Landscaping Species Plant Category Species Native Introduced Trees Swamp Oak (Casuarina glauca) x Lemon-scented gum (Corymbia citriodora) Spotted Gum (Corymbia maculata) Eucalyptus sp. (unidentified plant material unavailable) Tallowwood (Eucalyptus microcorys) x x x x, Page 60

113 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 61 of 72 Plant Category Species Native Introduced Swamp Mahogany (Eucalyptus robusta) x Narrow-leaf Red Gum (Eucalyptus sp.) x Forest Red Gum (Eucalyptus tereticornis) x Jacaranda (Jacaranda mimosifolia) x Bracelet Honey-myrtle (Melaleuca armillaris) x Broad-leaved Paperbark (Melaleuca quinquenervia) x Prickly-leaved Tea Tree (Melaleuca styphelioides) x Poplar (Populus sp.) x Shrubs Japanese Boxwood (Buxus microphylla var. japonica) x Cameilla sp. cultivar x Unknown Cactus (Cactaceae) x Callistemon sp. cultivar x Crimson Bottlebrush (Callistemon citrinus) x Rough Lemon (Citrus x taitensis) x Blueberry Ash (Elaeocarpus reticulates) x Cumquat (Fortunella japonica) x Grevillea sp. cultivar x Juniper sp. x Lantana (Lantana camara) x Orange Jessamine (Murraya paniculata) x Pandanus sp. x Sweet Pittosporum (Pittosporum undulatum) x Cocos Palm (Syagrus romanzoffiana) x Lilly Pilly (Syzygium sp.) x Xanthorrhoea sp. x Unidentified (plant material unavailable) x Ground Layer African Lily (Agapanthus praecox subsp. orientalis) x Asparagus Fern (Asparagus scandens) x Wild Aster (Aster subulatus) x Cobbler s Peg (Bidens pilosa) x Couch Grass (Cynodon dactylon) x Blue Flax-lily (Dianella caerulea) x Butterfly Iris (Dietes bicolor) x Grevillea 'Poorinda Royal Mantle' x Mat-rush (Lomandra longifolia) x Japanese Honeysuckle (Lonicera japonica) x Hexham Scent (Melilotus indicus) x Fishbone Fern (Nephrolepis cordifolia) x Mondo Grass (Ophiopogon japonicas) x Star Jasmine (Trachelospermum jasminoides) x, Page 61

114 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 62 of 72 Figure 2-1: Allied Mills, Kingsgrove Landscaping General Layout Map, Page 62

115 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 63 of Landscape Maintenance The existing vegetation at the Allied Mills site is currently maintained fortnightly to ensure the amenity to the surrounding community and site workers are not impacted in accordance with the HCC DCP 1 requirements. A landscaping sub-contractor is commissioned by Allied Mills on a fortnightly basis to maintain the site landscaping. This includes the management of weeds, mowing of grassed areas, trimming/shaping of shrubs, collection of fallen branches and other maintenance works as required. 4. Council Landscaping Requirements HCC has outlined the landscaping requirements for light industry in Section of the DCP 1. The requirements of Section are outlined in Table 4-1. Table 4-1 HCC DCP 1 - Landscaping Requirements Section Section Requirements LMP Section General - a) Development applications are to be accompanied by a landscape plan prepared by a suitably qualified landscape architect or designer. b) A survey plan is to accompany a development application indicating the precise location of existing trees, their condition, species and crown size, and which trees are proposed to be removed. c) Landscaping includes both hard and soft works. Hard works include things such as paving, ramps, terracing, retaining walls etc. Soft works refer to vegetation (grass, shrubs, trees etc) and earthworks. d) Landscaping design is to generally incorporate species indigenous to the area and those which will not cause damage to adjacent buildings and driveways. Plants to avoid are those which have a short life, drop branches, gum or fruit, or which interfere with underground pipes. Section 2 Section 2 Section 2 Section Streetscape (Front Setback Area) - a) Landscaping is to be provided in the front setback area to soften the appearance of buildings and enhance the streetscape. Existing vegetation already in Front Setback Area b) Landscaping is to be provided where the site abuts access streets, service roads, railway lines or residential development. N/A c) Species that will grow to a height consistent with the building are to be included. The existing vegetation is the height of the building Significant Trees - a) Buildings, driveways and service trenches are to have a minimum setback of 4 metres from trees and groups of trees which have been assessed as significant. N/A site acquired with existing vegetation. PAGE 63

116 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 64 of 72 b) Protective measures are required around trees during site works and construction. Such measures are to be submitted with the development application. N/A site acquired with existing vegetation Amenity - a) An outdoor eating and sitting area is to be provided within sites at the rate of 1m2 per employee, with a minimum total area of 10m2. N/A site acquired with existing vegetation. b) Trees planted on site should provide shade in summer and allow sunlight in winter and should be positioned appropriately. N/A site acquired with existing vegetation. 5. Management Review This LMP will be reviewed and updated as necessary by Allied Mills. In accordance with the requirement of Conditions 4.31 of the CDC, if the Director-General has any reasonable requests in relation to this plan, Allied Mills will ensure the request is complied with and this LMP will be updated to reflect any changes. PAGE 64

117 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 65 of 72 Appendix G: Allied Mills Kingsgrove Waste Management Plan Revision: 3.1 Effective: PAGE 65

118 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 66 of 72 Contents 1. Introduction Waste Streams Onsite Storage Waste Disposal Management Review 70 PAGE 66

119 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 67 of Introduction Allied Mills operates a dry foods processing plant at the Crescent, Kingsgrove NSW (the site). The operation of this plant requires the delivery of flour, oil and other ingredients to process these into various products. Following the processing of the wastes various waste streams are produced. The development consent (S01/00876), requires these waste streams to be managed appropriately. This Waste Management Plan (WMP) has been developed to address conditions 4.26 to 4.28 of the development consent. The conditions of consent and the sections within this WMP where the conditions are addressed are listed within Table 3-1. Table 0-1 Condition of Consent Requirements Condition Condition Requirements WMP Section 4.26 The Applicant must prepare and implement a Waste Management Plan for the This Document development in consultation with the Council. This Plan must describe in detail the waste management system, including: 4.26 a) The types and quantities of waste which will be generated at the site; and Section b) How waste will be stored onsite, transported and disposed of offsite. Section 2 to Section The Waste Management Plan must have been approved by the Director-General before the mixing plant may be commissioned After reviewing the Waste Management Plan, the Director-General may require the Applicant to address certain matters identified in the plan. The Applicant must comply with any reasonable requirements of the Director-General. Section 5 Section 5 2. Waste Streams The works at the Allied Mills site generates multiple waste streams. Details of the waste streams and the volumes generated are shown in Table 2-1. NOTE: Special waste is defined as non-hazardous but requires specific waste removal. Ie maintenance oil waste, paint etc. Table 2-1 Allied Mills Waste Streams Waste Stream Average Weekly Quantity Onsite Storage Vessel Special waste 10Lt Sealed Drum Liquid waste 50Lt Sealed Drum Hazardous waste 2.0Lt Plastic storage container Restricted waste Nil Na General waste (putrescible) 7 tonnes Bulka bags General waste (non putrescible) 7.5 tonnes Skip bin / Top loader bin PAGE 67

120 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 68 of Onsite Storage The waste streams identified in Table 2-1 are stored at various locations across the Allied Mills site. The storage locations and the various receptacles used to store the waste streams are identified on Figure 2-1. PAGE 68

121 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 69 of 72 Figure 3-1: Allied Mills, Kingsgrove Onsite Waste Storage Locations PAGE 69

122 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 70 of Waste Disposal The Waste streams identified in Table 2-1 are disposed of by the waste contractors within Table 4-1. The waste contractors are licenced to remove the product and are responsible for ensuring the wastes are removed to an appropriate facility. Allied Mills will endevour to utilise waste contractors who offer recycling options for waste streams generated on the site. Table 4-1 Allied Mills Waste Removal Contractors Waste Stream Waste Removal Contractor Comments General Waste (non Veolia Waste Service putrescible) Grima Waste Service Centacare Industries General waste (putrescible) Michael Mizzi Offal. Recycled Hazardous waste Toxfree EPA Licence (NSW) No Liquid waste Auscol (Graincorp) - oil EPA Licence (NSW) No Management Review In accordance with the requirement of Condition 3.7 of the development consent, this WMP will be reviewed annually (or following a significant incident) by Allied Mills. Where necessary the report will be updated to reflect any relevant changes. A management review of the WMP will be completed prior to any modifications/expansions of the mixing plant. In accordance with Condition 4.27, the revised WMP will be submitted to the Director- General prior to the commissioning of the modified mixing plant. A management review may also be required in response to a request from the Director-General. In such cases a review/update will be completed and provided to the Director-General for approval, in accordance with Condition 4.28 of the development consent. PAGE 70

123 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 71 of 72 Appendix H: Environmental Inspection Report Template WEEKLY ENVIRONMENTAL MONITORING REPORT Inspection Date: Inspector Name(s): Inspection Location(s): MONITORING PROGRAM: (refer to Table 9-2 of the Allied Mills EMP for performance criteria) Area Monitoring Criteria Compliant Noise Any excessive noise noted. Yes / No Any noise complaints in previous week. Yes / No Air Quality Any black/white exhaust smoke from vehicles over 10 sec. Yes / No Any visable dust exiting manufacturing building. Yes / No Are spill trays being used under oil receival couplings on oil tankers. Yes / No / NA Stormwater Is oil bunding around oil tanks in good condition and no oil leaks. Yes / No Are isolation valves blocked or obstructed. Yes / No Are stormwater drain wardens damaged or full of rubbish Yes / No Traffic Are trucks parked on The Crescent waiting to enter Yes / No Aesthetic / Are gardens and landscaping in good condition. Is Landscaping dust blowing on site from unsealed grounds. Yes / No Waste Is waste area tidy and bin capacity acceptable. Yes / No Other Yes / No Actions for any Non Compliance Action Taken - ie Maintenance request raised, CAR Area raised, sent, fixed during walk Comments Comments / Photos / Other PAGE 71

124 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 72 of 72 Appendix I: Environmental Notification Script Environmental Incident Notification Script Collect the following Basic Information: Ref Incident Details Complete this section A Person Reporting: Basic Information B C D E F Position of Person Reporting: Incident Time/Date: Event Type: Estimated Volume: Pollutant Type: Actual/Potential Spill/Leak/Escape/Deposit G Nature and Location of Incident: H Initial Response: Contact the following Regulating Authorities (in order) using the below script and record details on the back of this form: Regulator Phone Number Emergency Services 000 Georges River Council (02) EPA Pollution Line Ministry of Health SESI Randwick (02) WorkCover Authority Hi, my name is (A), and I am the (B) from the Allied Mills Food Processing Plant at 4 The Crescent, Kingsgrov e NSW. I am calling to inform you that at (C) our facility had a (D) of approximately (E) of (F) that occurred at (G). Our initial response has included (H) PAGE 72

125 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 73 of 72 Record details of the conversation with each regulator on the following: Regulator: Emergency Services Time Contacted: Contact madespoke w ith a person or left a message (circle one) Person Contacted: Name: Position: Regulators Recommendations/Directives: Regulator: Georges River Council Time Contacted: Contact madespoke w ith a person or left a message (circle one) Person Contacted: Name: Position: Regulators Recommendations/Directives: Regulator: EPA Pollution Line Time Contacted: Contact madespoke w ith a person or left a message (circle one) Person Contacted: Name: Position: Regulators Recommendations/Directives: Regulator: Ministry of Health SESI Randwick Time Contacted: Contact madespoke w ith a person or left a message (circle one) Person Contacted: Name: Position: Regulators Recommendations/Directives: Regulator: WorkCover Authority Time Contacted: Contact madespoke w ith a person or left a message (circle one) Person Contacted: Name: Position: Regulators Recommendations/Directives: PAGE 73

126 SAP Document Number Effective Date Revision No Print Date 11/04/2017 Page 74 of 72 Appendix J Emergency Contacts Organisation Position Contact Number Notes Emergency Services Police, Fire, Ambulance 000 Georges River Council (02) Only available Monday to Friday 8.30am to 5pm EPA Pollution Line Ministry of Health SESI Randwick (02) WorkCover Authority Allied Mills Kingsgrove Site Manager Allied Mills Kingsgrove Production Manager Allied Mills Kingsgrove Production Manager Allied Mills Kingsgrove Warehouse Manager Allied Mills Kingsgrove Maintenance Manger Allied Mills National National WHSE Manager Allied Mills National National WHSE Coordinator PAGE 74

127 AECOM Annual Environmental Management Report 2016 A-2 AECOM Australia Pty Ltd ABN Revision Apr-2017 Prepared for Allied Mills Pty Ltd ABN: