Port Botany Terminal Operational Environmental Management Plan Environmental Risk Assessment

Transcription

1 Purpose To ensure that potential environmental impacts and risks at the Patrick Terminal Port Botany are identified so that appropriate control measures can be implemented in compliance with applicable Australian Standards and legislation. References AS/NZS ISO 31000:2009 Risk Management Principles and Guidelines Effective Date July 2014 Responsibility Safety, Security and Environment Manager and Supervisors of area where environmental risk assessment is conducted. Ensure all contractors and employees adhere to this procedure Environmental Risk Management A Risk Management process is used to identify and assess environmental risks. This process allows for a prioritising of environmental risks according to their associated risk level. Following this, identified risks are to be eliminated or when this is not possible, control measures are to be implemented to reduce the risk. Ongoing review of risk management is to maintain currency of all documents and processes. The Risk Management process is to be undertaken using the following steps: (1) Identify Risks (2) Assess the Risks (3) Eliminate or Control Risks (4) Review Risks and Control Measures 1) Risk Identification Environmental risks are to be identified for each of the following operational areas: Operations and Administration Straddle Park Dock Workshop Container Storage (non Terminal) General Risks that are specific to each area shall be identified and recorded on the Risk Assessment Form. 2) Assess the Risk Once the environmental risks have been identified, they are to be assessed. A risk is defined as: the chance of something happening that will have an impact upon objectives. It is measured in terms of consequence and likelihood (AS/NZS ISO 31000:2009 Risk Management Principles and Guidelines). A Risk Level is determined by undertaking the following steps: (i) (ii) (iii) Determine Risk Consequence Determine Risk Likelihood Cross-reference Risk Consequence and Likelihood to determine Risk Level (i) Risk Consequence refers to the outcome of an event or situation expressed in terms of loss, injury or disadvantage. Risk consequence is selected from the following categories: Appendix C-1

2 Consequenc e Minor (Mi) Moderate (Mo) Major (Mj) Consequence Description Short term disturbance with minor environmental release. No impact outside the Terminal Release of pollution off-site. Clean up costs incurred. Breach of legal requirements. External complaints. Significant environmental damage potentially permanent. Release of pollution off-site. High likelihood of fines. Sustained complaints. (ii) Risk Likelihood refers to the probability and frequency of the event occurring. Risk Likelihood is selected from the following categories: Rare (R) Occasional (O) Frequent (F) Probability Description Unlikely to happen (>1 in 10 years) Possible (>1 every year) Almost certain to happen (at least every month) (iii) Risk Level is determined by cross-referencing the pre-control measure likelihood and consequence. Risk Level is determined from the Table below: Probability Rare Occasional Frequent Minor L L M Moderate L M H Major M H H L = Low Risk M = Moderate Risk H = High Risk 3) Eliminate or Control the Risk Once the risk has been assessed and a risk level obtained, control measures are to be nominated to eliminate or control each risk. Risk Control is defined as an existing process, policy, device, practice or other action that acts to minimise negative risk or enhance positive opportunities (AS/NZS ISO 31000:2009 Risk Management Principles and Guidelines) 4) Monitoring and Review of Environmental Risk Control Measures The entire risk management process is to be regularly monitored (e.g. via audits, inspections, and review of incidents) and reviewed to ensure that all environmental risks are identified and that appropriate risk control measures are in place. Any further environmental risks that are identified during the weekly Environmental inspection are to be recorded on the Environmental Checklist and the Risk Assessment then updated accordingly. Records An assessment of the risk consequence and measures of likelihood for all identified risks is to be undertaken and recorded on the appropriate Risk Assessment Form. Communication All personnel shall be informed of environmental risks at the site via Site Induction Training and Toolbox Meetings where appropriate. Appendix C-2

3 Date Completed Risk Assessment Form Completed By: Straddle Park 1 Operation of reachstackers / 2 Operation of reachstackers / Land - Spillage of fuel/oils from Straddles / Equipment in yards Spillage of fuel/oils from Cranes Water Spillage of fuel / oils to stormwater drains within main terminal F Mj H Section 142 of the POEO Act it is an offence to pollute land Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Contaminated Land Management Act 1997 requires land owners and persons who carry on contaminating activities to notify the EPA of the contamination of land in certain circumstances. Protection of the Environment Legislation Amendment Act 2011 F Mj H Section 120 of the POEO Act - It is illegal to pollute or cause or permit pollution of waters. Under the Act, 'water pollution' includes introducing litter, sediment, oil, grease, wash water, debris, and flammable liquids such as paint, etc. into waters or placing such material where it is likely to be washed or blown into waters or the stormwater system or percolate into groundwater. Prevent spill from entering stormwater Conduct regular maintenance and servicing according to the Maintenance Schedule Implement change from hydraulic to rubber suspension for Straddles The CLM Act Duty to Report requires Patrick personnel to report contamination to OEH as soon as they become aware of the contamination. Investigation Procedure TO 0802 and complete Incident (Non Injury) Report Form TT0210 Maintenance of straddles and plant Install and maintain DrainSafe Units. Install and maintain pureceptors. Conduct water quality monitoring as per EPL (No. 6962) and CoA Implement change from hydraulic to rubber suspension for Straddles Conduct regular maintenance and servicing according to the Maintenance Schedule O Mi L O Mo M Appendix C-3

4 Straddle Park 3 Operation of reachstackers / 4 Operation of reachstac kers / 5 Operation of reachstackers / Water Spillage of fuel / oils to stormwater drains north of the rail line Water Spillage of fuel / oils to stormwater drains in Knuckle Area Air pollution emissions from trucks/ Straddles / Plant and Equipment F Mj H As above, except Stormwater Quality Improvement Devices (SQIDs) have been installed instead of DrainSafe Units and pureceptors F Mj H As above, except a Gross Pollutant Trap (ECOSOL RSF Treatment Units) has been installed instead of DrainSafe Units and pureceptors. F Mj H POEO Act (Sections ) POEO (Clean Air) Regulation 2010 Air pollution means emitting any impurities into the air, including odours, volatile organic compounds (VOCs), smoke, dust, gases, fumes and solid particles of any kind. National Environment Protection Council (NSW) Act 1985 Ozone Protection Act 1989 Conduct regular maintenance and servicing according to the Maintenance Schedule Automatic turn off when not in use NPI Reporting R Mj M F Mi M 6 Operation of reachstackers / Noise activity of straddles O Mo H POEO Act Sections 139 and 140 Patrick s must not allow noise from the Terminal to be generated as a result of the failure to maintain or operate machinery or deal with materials in a proper and efficient manner. POEO (Noise Control ) Conduct regular maintenance and servicing according to the Maintenance Schedule Turn off when not in use Conduct noise monitoring as by EPA EPL (No. 6962) and CoA Warning lights (visual alarms) are used at night.patrick are committed to installing quacker reversing alarms on new plant and equipment for the Terminal where it is safe and practicable to do so. Appendix C-4

5 Straddle Park Regulation Operation of reachstackers / Land - Spillage/leak from containers O Mo H Section 142 of the POEO Act it is an offence to pollute land Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Protection of the Environment Legislation Amendment Act 2011 Work Health and Safety Regulation 2011, Schedule 18B Savings and transitional provisions, clause 63 Saving of Dangerous Goods Regulation relating to ports. Implement Port Authority of NSW Dangerous Goods Management Guidelines High risk containers are placed directly onto a trailer fitted with a spill tray. Prevent spill from entering stormwater Implement the requirements of Australian Standard The Handling and Transport of Dangerous Cargoes in Port Areas 8 Operation of reachstackers / 9 Truck transport (Truck Grid) 10 Truck transport (Truck Grid) Air - Electricity use increasing GHGe Noise movement of trucks Land - Spillage of fuel/oils or Containers by trucks F Mo H NSW Ports Green Ports Checklist F Mi M POEO Act Sections 139 and 140 Patrick s must not allow noise from the Terminal to be generated as a result of the failure to maintain or operate machinery or deal with materials in a proper and efficient manner. POEO (Noise Control ) Regulation 2008 O Mo H Dangerous Goods (Road and Rail Transport) Act Environmentally Hazardous NPI Reporting Note Automated Straddle Carriers (ASC) have an improved fuel efficiency to the manual straddles. Conduct regular maintenance and servicing Turn off when not in use Conduct noise monitoring as by EPA EPL (No. 6962) Traffic Management Plan One Stop scheduling Ensure truck companies transporting Goods have Systems in place to address legal, maintenance and other requirements. F Mi M O Mi L Appendix C-5

6 Straddle Park Chemicals Act Truck transport (Truck Grid) Water Spillage of fuel / oils to stormwater drains 12 Train transport Land - Spillage of fuel/oils from trains to track ballast Spillage of Containers F Mj H Refer to Item 3 Refer to Item 3 R Mj M O Mo H Dangerous Goods (Road and Rail Transport) Act Environmentally Hazardous Chemicals Act 1985 Maintenance of tracks conducted by Pacific National. 13 Train transport Water Spillage of Fuels / Oils or Dangerous Goods from trains to drains 14 Train transport Noise movement of trains trains operate 24hrs/day 15 Refrigerated and Non-refrigerated Container storage Land Spillage/leak from containers in absence of information on contents R Mj M Section 120 of the POEO Act - It is illegal to pollute or cause or permit pollution of waters. Under the Act, 'water pollution' includes introducing litter, sediment, oil, grease, wash water, debris, and flammable liquids such as paint, etc. into waters or placing such material where it is likely to be washed or blown into waters or the stormwater system or percolate into groundwater. F Mo H POEO Act Sections 139 and 140 Patrick s must not allow noise from the Terminal to be generated as a result of the failure to maintain or operate machinery or deal with materials in a proper and efficient manner. POEO (Noise Control ) Regulation 2008 O Mo H Work Health and Safety Regulation 2011, Schedule 18B Savings and transitional provisions, clause 63 Saving of Dangerous Goods Regulation relating to ports. Refer to Items 2 and 3. Drains on north side of rail line discharge to Penryhn Estuary via SQID devices. Drains on the south side of the line will drain to the straddle park / truck grid area and into pureceptors prior to entering stormwater drains. SICTL and Patrick agreement to provide access for Patrick staff to maintain SQIDs (where ) north of Patrick site. Trains refuelled off-site. Operate alert sirens only during train movements Noise wall constructed by SICTL on northern boundary of rail line (north of Patrick rail line) Ensure attendance at meetings of the Port Botany Expansion CCC as and implement actions if applicable Emergency Procedures Manual Identify, handle and manage containers containing dangerous goods as per Port Authority of NSW Dangerous Goods O Mo M O Mi L Appendix C-6

7 Straddle Park 16 Refrigerated and Non-refrigerated Container storage 17 Refrigerated and Non-refrigerated Container storage Land Spillage/leak from containers of identified Dangerous Substance Land Chemical reaction or explosion caused by incorrect storage of Containers causing land contamination The requirements of Australian Standard The Handling and Transport of Dangerous Cargoes in Port Areas Environmentally Hazardous Chemicals Act 1985 O Mo H Work Health and Safety Regulation 2011, Schedule 18B Savings and transitional provisions, clause 63 Saving of Dangerous Goods Regulation relating to ports. The requirements of Australian Standard The Handling and Transport of Dangerous Cargoes in Port Areas Environmentally Hazardous Chemicals Act 1985 O Ma H Section 142 of the POEO Act it is an offence to pollute land Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Protection of the Environment Legislation Amendment Act 2011 Management Guidelines Ensure all MSDS are available Emergency Procedures Manual Inspect Dangerous Goods container storage areas as part of Weekly Environmental. Inspections to review pumps, sensors, alarms and general condition of area Conduct regular maintenance. Provide fire extinguishers and train people in their use Implement Port Authority of NSW Dangerous Goods Management Guidelines Prevent spill from entering stormwater O Mo M R Mj M 18 Refrigerated and Non-refrigerated Container storage Water - Spillage/leak from containers to Stormwater / Botany Bay O Mj H Section 120 of the POEO Act - It is illegal to pollute or cause or permit pollution of waters. Under the Act, 'water pollution' includes introducing litter, sediment, oil, grease, wash Install and maintain Spillmax Appendix C-7

8 Straddle Park water, debris, and flammable liquids such as paint, etc. into waters or placing such material where it is likely to be washed or blown into waters or the stormwater system or percolate into groundwater. Implement change from hydraulic to rubber suspension for Straddles Conduct regular maintenance and servicing according to the Maintenance Schedule 19 Refrigerated and Non-refrigerated Container storage Air Chemical reaction or explosion caused by incorrect storage of Containers causing air pollution O Mj H POEO Act (Sections ) POEO (Clean Air) Regulation 2010 Air pollution means emitting any impurities into the air, including odours, volatile organic compounds (VOCs), smoke, dust, gases, fumes and solid particles of any kind. National Environment Protection Council (NSW) Act 1985 Ozone Protection Act Refrigerated and Non-refrigerated Container storage Air - Gaseous / odorous leak from containers to air O Mo M Section 129 of the Protection of the Environment Operations Act Odourous air is not to be emitted beyond the boundary of the site O Mo L 21 Refrigerated and Non-refrigerated Container storage Waste solid waste and liquid waste air filter waste oils, sludge, chemical containers F Mo H Protection of the Environment Operations Act 1997 The owners of waste (as well as the transporters and receivers) have a responsibility to ensure their waste is managed, transported and disposed of appropriately. Waste Avoidance and Dispose of used containers such as oil drums to a licenced waste facility or recycling contractor Dispose of scrap metal to a licenced scrap metal merchant Ensure all waste generated is appropriately segregated and disposed off site by a licenced waste contractor. Ensure hazardous wastes are not disposed Appendix C-8

9 Straddle Park 22 Berthing Ships Water spillage of substances from ships into Botany Bay Resource Recovery Act 2001 O Mo M The Navigation Act 1912 Protection of the Sea (Prevention of Pollution from Ships) Act 1983 (Cth) The following pollution activity should be reported: Any quantity of oil. If oil can be seen then it is likely to be an illegal discharge. Oil includes waste oil, fuel oil, sludge, lube oil and additives etc Any discharge from a ship involving washings of chemical or dry cargoes Any plastic material Garbage disposed of in the sea within 12nm of land (garbage includes food, paper, bottles etc) of with general waste Separate waste and implement waste hierarchy of reuse, recycle, dispose. Record waste types, quantities and disposal location in Waste Register Classify waste according to EPAs Waste Classification Guidelines Part 1 Classifying Waste (1999) Cover waste skips to reduce wind blown rubbish and feral animals Quarantine waste is disposed of in accordance with the requirements of Port Authority of NSW, EPA and AQIS. Any spills are managed by NSW Ports and reported to the Harbourmaster. Incident reporting managed by NSW Ports. O Mo M 23 Straddle Park - General Biosecurity O Mj H Quarantine Act 1908 (Cth) DAFF manages quarantine controls at Australian borders, including Port Botany, to minimise the risk of Provide assistance when DAFF conduct regular inspections and as. R Mj M Appendix C-9

10 Straddle Park exotic pests and diseases entering the country. 24 Straddle Park - General Sydney Airport aviation hazards (Pooling water, rubbish on site) O Mj H Airports Act 1996 Minimise ship board lighting while berthed Orientate ships in a specific direction Provide temporary shielding on the ship mounted floodlights while docked. Remove ponded water from site as soon as practicable and reasonable. Remove all rubbish (putresibles and nonputrescibles) from site. R Mj M 24 Caltex Fuel Line (beneath Patricks Terminal) Land - Spillage of fuel from Caltex Fuel Line R Mj M Dangerous Goods (Road and Rail Transport) Act Environmentally Hazardous Chemicals Act 1985 Caltex fuel line labelled as easement on drawings. Easement prevents work in close proximity to fuel line. Caltex line has been surveyed with plaques and labels placed on pipe. R Mj M 25 Transformers / Substation Land Leaks from transformers or substation R Mi L Section 142 of the POEO Act it is an offence to pollute land Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Contaminated Land Management Act 1997 requires land owners and persons who carry on contaminating activities to notify the EPA of the contamination of land in certain circumstances. Protection of the Environment Legislation Amendment Act 2011 Transformers and substations self bunded and covered. Implement maintenance regime R Mi L Appendix C-10

11 Workshop 26 Maintenance and Servicing Water Spillage of fuel / oils to stormwater drains F Mo H Section 120 of the POEO Act - It is illegal to pollute or cause or permit pollution of waters. Under the Act, 'water pollution' includes introducing litter, sediment, oil, grease, wash water, debris, and flammable liquids such as paint, etc. into waters or placing such material where it is likely to be washed or blown into waters or the stormwater system or percolate into groundwater. Maintain first flush system and drains and ensure requirements of EPA EPL (No. 6962), Consent to Discharge Industrial Trade Wastewater and CoA are addressed including water quality monitoring. Turn off taps and hoses when not in use Conduct regular maintenance and servicing according to the Maintenance Schedule O Mi L 27 Maintenance and Servicing Waste solid waste and liquid waste air filter waste oils, sludge, chemical containers F Mo H Protection of the Environment Operations Act 1997 Waste Avoidance and Resource Recovery Act 2001 The owners of waste (as well as the transporters and receivers) have a responsibility to ensure their waste is managed, transported and disposed of appropriately. Dispose of used containers such as oil drums to a licenced waste facility or recycling contractor Dispose of scrap metal to a licenced scrap metal merchant Ensure all waste generated is appropriately segregated and disposed off site by a licenced waste contractor. Ensure hazardous wastes are not disposed of with general waste Separate waste and implement waste hierarchy of reuse, recycle, dispose. Record waste types, quantities and disposal location in Waste Register Classify waste according to EPAs Waste Classification Guidelines Part 1 Classifying Waste (1999) Cover waste skips to reduce wind blown rubbish and feral animals O Mo M 28 Oil Storage Room Land - Storage of hazardous F Mo H Environmentally Hazardous Chemicals Act 1985 Store minimum quantities of paints, oils, solvents, batteries etc on site in bunded or Appendix C-11

12 Workshop substances and dangerous goods causing pollution to land. 29 Wash Bay Waste - Equipment malfunction causing pollution to trade waste system and / or stormwater 30 Storage of Fuel in above ground storage tanks O Mo M Section 120 of the POEO Act - It is illegal to pollute or cause or permit pollution of waters. Under the Act, 'water pollution' includes introducing litter, sediment, oil, grease, wash water, debris, and flammable liquids such as paint, etc. into waters or placing such material where it is likely to be washed or blown into waters or the stormwater system or percolate into groundwater. Land spills of fuel Section 142 of the POEO Act it is an offence to pollute land contained designated areas Identify and manage storage and handling of dangerous goods according to the Port Authority of NSW Dangerous Goods Management Guidelines. Provide safety signage and bunding in all storage areas containing any hazardous / dangerous goods.. Investigation Procedure (OEMP Appendix I). Maintain MSDS in Hazardous Substances Register. Service and maintain wastewater treatment plant in accordance with Sydney Water Trade Waste Agreement Conduct water quality testing as by EPA EPL (No. 6962) Dispose of sludge waste at a licenced facility and enter quantity and disposal location details in Waste Register Install and maintain Spillmax Conduct water quality monitoring as per EPL Storage tanks are double skinned tanks with internal bunding. Appendix C-12

13 Workshop 31 Storage of Fuel in above ground storage tanks 32 Fuel Storage Area Old infrastructure Water discharge of spilt fuel from fuel storage area Land Contamination from old infrastructure (pipes, storage tanks etc) Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Contaminated Land Management Act 1997 requires land owners and persons who carry on contaminating activities to notify the EPA of the contamination of land in certain circumstances. Protection of the Environment Legislation Amendment Act 2011 Australian Institute of Petroleum Guideline 12 - Safe above ground fuel storage on farms and industrial sites Maintain tanks in accordance with mantainenance schedule. Maintain bund within tank storage area. Maintain pureceptor beneath tank bund. Implement Port Authority of NSW Dangerous Goods Management Guidelines (January 2012) Hazardous Containers Procedure Summary (SO0405-1) Storage and Handling of Hazardous Substances and Dangerous Good (SO0308) Hazardous Procedures (SO0405) F Mj H Storage tanks are double skinned tanks with internal bunding. Storage tanks are placed within a bund. Bund is connected to a pureceptor to manage any spills O Mi L Section 142 of the POEO Act it is an offence to pollute land Section 116 of the POEO Act- It is an offence to wilfully or negligently cause any substance to leak, spill or otherwise escape in a manner that harms or is likely to harm the environment. Contaminated Land Management Act 1997 requires land owners and persons who carry on contaminating activities to notify the EPA of the contamination of land in certain circumstances. Protection of the Environment Legislation Amendment Act Removal of redundant infrastructure as. Inspections of old infrastructure in accordance with maintenance schedule. R Mj M O Mi L Appendix C-13

14 Workshop 2011 Australian Institute of Petroleum Guideline 12 - Safe above ground fuel storage on farms and industrial sites Administration and General 33 Terminal - General Feral animals O Mo M Threatened Species Conservation Ensure that food scraps are not deposited Act 1995 on the ground and that bin lids are closed to prevent feral animals from accessing food sources at the site. If any predation of shorebirds in the Penryhn Estuary is reported, the perimeter fence is to be inspected for damage or evidence of burrowing. Damaged fencing is to be repaired as soon as practicable. 34 Terminal General Pesticide use O Mo M Pesticides Act 1999 Ensure compliance with pesticide use requirements and Port Authority of NSW Pesticide use Notification Plan 35 Terminal General Air use of electricity for operating Cranes, refrigerated storage, workshop and Administration Buildings increasing GHGe 36 Office administration 37 Office administration 38 Office administration F Mo H National Greenhouse and Energy Reporting Act 2007 Clean Energy Act 2011 NSW Ports Green Ports Checklist Potable water use F Mo H NSW Ports Green Ports Checklist Energy use increasing GHGe Use of chemical refrigerants for F Mo H NSW Ports Green Ports Checklist NGER Reporting NPI Reporting Turn off taps when not in use and ensure leaking taps are repaired promptly Investigate water reuse schemes Turn off lights and equipment when not in use Commission and implement energy audit F Mi M F Mi M F Mi M F Mo H POEO Act (Sections ) Regularly service air conditioning units F Mi M using licenced contractors Appendix C-14

15 Administration and General cooling contributing to Climate Change 39 Office administration POEO (Clean Air) Regulation 2010 National Environment Protection Council (NSW) Act 1985 Ozone Protection Act 1989 Generation of Waste F Mo H Protection of the Environment Operations Act 1997 Waste Avoidance and Resource Recovery Act 2001 Review alternative methods of cooling Separate waste and implement waste hierarchy of reuse, recycle, dispose. Record waste types, quantities and disposal location in Waste Register Classify waste according to EPAs Waste Classification Guidelines Part 1 Classifying Waste (1999) Cover waste skips to reduce wind blown rubbish and feral animals Ensure waste is segregated and disposed of at an appropriately licenced facility F Mi M Appendix C-15