Kurnell Terminal Demolition Project

Transcription

1 Kurnell Terminal Demlitin Prject Air Quality Management Plan CALTEX AUSTRALIA PETROLEUM PTY LTD January 2018 Page 1

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3 1 INTRODUCTION Legislative and Other Requirements OBJECTIVES PROJECT OVERVIEW Ptential Surces f Air Emissins Wrks Prgram AIR QUALITY MANAGEMENT PROCEDURES Air Quality and Odur Management & Mitigatin Measures Mnitring External Cmmunicatin IMPLEMENTATION Rles and Respnsibilities Inductin Training Incident Management Cmplaints Management Perfrmance Indicatrs Reprting Crrective Actins Revisin Histry Revisin N. Date f Revisin Descriptin f Revisin Sectin / Page N. A July 2015 Draft fr cnsultatin - B September 2015 Final fr Apprval - C September 2015 Apprved - D January 2018 Updated t include SSD 5544 MOD2 and SSD 5544 MOD3. Sent t Department f Planning and Envirnment fr apprval. Whle dcument Page 3

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5 1 INTRODUCTION Caltex is in the prcess f cnverting the petrleum refinery in Kurnell (the Site ) t a finished fuel terminal facility (the Prject). The Prject is divided int three phases: Cnverting infrastructure t allw the Site t perate as a terminal and shut dwn the refinery (the cnversin wrks). Demlitin and remval f redundant infrastructure, including Tank 101 (the demlitin wrks). Cnstructin, filling and clsure f the asbests cntainment cell (the ACS Management wrks). This Air Quality Management Plan (AQMP) has been prepared in relatin t the demlitin wrks and ACS Management wrks.. The bjective f the Prject is t ensure that Caltex s peratins within Australia remain viable and can prvide a safe, reliable and sustainable supply f petrleum fuels t NSW and the ACT. As such the Prject will allw the Site t cntinue t be utilised as a terminal where finished prducts can be received by ship, stred in tanks befre leaving the Site by pipeline t ther terminals. The demlitin wrks and ACS Management wrks are being undertaken in accrdance with Develpment Cnsent frm the Department f Envirnment and Planning, Apprval Number: SSD 5544 MOD1, SSD 5544 MOD2, SSD 5544 MOD3 and the cnslidated Management and Mitigatin Measures (MMM) (refer t Apprval: SSD 5544 MOD3). This AQMP has been prepared in respnse t Develpment Cnsent cnditin C28 and C28A utlined in Table 1. Table 1 Develpment Cnsent cnditins addressed in this Management Plan Cnditin Requirement C28. The Applicant shall prepare and implement an Air Quality Management Plan fr the prpsed cnstructin wrks. The plan shall: Reference Sectin - (a) (b) be prepared and implemented by a suitably qualified and experienced expert in cnsultatin with the EPA and NSW Health; be apprved by the Directr-General prir (refer t Cnditin D1 fr timing); Sectin 1 Sectin 1 Page 5

6 Cnditin Requirement Reference Sectin (c) (d) describe the measures that wuld be implemented n site t ensure: i. the cntrl f air quality and dur impacts f the Develpment; ii. that these cntrls remain effective ver time; iii. that all reasnable and feasible air quality management practice is emplyed; iv. the air quality impacts are minimised during adverse meterlgical cnditins and extrardinary events; and v. cmpliance with the relevant cnditins f this cnsent. describes the air quality & dur management system; Sectin 1, Sectin 4, Sectin 5.6 Sectin 4.1, Sectin 4.2 (e) includes an air quality mnitring prgram that: i. is capable f evaluating the perfrmance f the prpsal; ii. includes a prtcl fr determining any exceedances f the relevant cnditins f cnsent and respnding t cmplaints; iii. adequately supprts the air quality management system; and iv. evaluates and reprts n the effectiveness f the air quality management system. C28A The Applicant shall update and implement the Air Quality Management Plan fr the demlitin wrks t the satisfactin f the Secretary. This plan is t update the plan apprved under cnditin C28 and shall als: (a) be apprved by the Secretary (refer t cnditins D1a and D2 fr timing); (b) utline prcedures fr VOC, dur and dust depsitin mnitring and suspressin methds during excavatin wrks and where ptential hydrcarbn cntaminatin is present; and (c) include dust suppressin measures and prcedures fr dust mnitring during peratin f the cncrete crusher. Sectin 4.2 This Plan Sectin 1 Sectin 4.2 Sectin 4.1 and 4.2 This AQMP has als been prepared in accrdance with the fllwing: SSD 5544 cnditins C24, C25, C26, C27 MMM - H1 H16, H18, H19, H21, H22, H24 H26 The Cntainment Cell Management Plan includes a number f air quality cntrl measures specific t the ACS Management wrks. The cntrls included in this AQMP must be implemented in additin t thse included in the Cntainment Cell Management Plan. 1.1 Legislative and Other Requirements Envirnment Prtectin Licence The Terminal currently perates in accrdance with an Envirnment Prtectin Licence (EPL) 837 issued by the NSW Envirnment Prtectin Authrity (EPA). This EPL cntains numerus peratinal cnditins and Pllutin Reductin Prgrams (PRPs). All wrk undertaken during demlitin wrks will cmply with the cnditins within this EPL. Page 6

7 Cnditin L2 f the EPL specifies Lad Limits fr the Site. The actual lad f an assessable pllutant discharged frm the Site must nt exceed the lad limit specified fr the assessable pllutant in Table 2. Table 2 Lad Limits Assessable Pllutant Lad Limit (kg) Benzene (Air) Vlatile rganic cmpunds Summer (Air) - Vlatile rganic cmpunds (Air) Cnditin L6.1 f the EPL ntes that n cnditin f the EPL identifies a ptentially ffensive dur fr the purpses f Sectin 129 f the Prtectin f the Envirnment Operatins Act 1997 (POEO Act). Cnditin O3.1 f the EPL stipulates that the Site must be maintained in a cnditin which minimises r prevents the emissin f dust frm the Site. Cnditin M4 f the EPL ntes that Divisin 3 f the Prtectin f the Envirnment Operatins (General) Regulatin 2009 requires that mnitring f actual lads f assessable pllutants listed in Cnditin L2.2 must be carried ut in accrdance with the relevant lad calculatin prtcl set ut fr the fee-based activity classificatin listed in the Administrative Cnditins f the EPL. Cnditin U1 PRP U16: VOC Emissins frm Petrleum Strages will be implemented in three parts. Part ne and tw will be carried ut during the cnversin Prject. Part three will be carried ut as part f the nging tank maintenance prgram at the Kurnell Terminal. Part 1 - Pre-transitin t Terminal - 4 EFRTs will be upgraded - Cmpletin Date: 31 Octber 2014 Part 2 - Pst-transitin t Terminal - 6 EFRTs will be upgraded - Cmpletin Date: 31 December 2017 Part 3 - Terminal Turnarund and Inspectin - 2 EFRTs will be upgraded - Cmpletin Date: 31 December 2020 Page 7

8 2 OBJECTIVES The bjective f the AQMP is t ensure that the demlitin wrks and ACS Management wrks d nt result in decreased air quality r impacts t the surrunding envirnment as detailed in the SEEs. As an envirnmental utcme fr the Site, Caltex shall nt cause r permit the emissin f ffensive durs frm the Site, as defined under Sectin 129 f the POEO Act. Further, the cnditins f cnsent fr SSD 5544 MOD 1 specify that Caltex shall: Implement all reasnable and feasible dust and dur mitigatin measures t prevent and minimise dur and dust emissins frm peratins; Prevent and minimise the air quality impacts f the develpment during adverse meterlgical cnditins and extrardinary events; Minimise any visible ff-site air pllutin; Minimise surface disturbance f the Site, ther than as permitted under this cnsent; Minimise energy use; and Minimise greenhuse gas emissins. T address these bjectives, the Management Plan dcuments: The management measures, actins and assciated perfrmance indicatrs, that will be implemented thrughut the demlitin wrks; The prpsed mnitring prgram that will be implemented; and Key prject management rles and respnsibilities and reprting requirements. Page 8

9 3 PROJECT OVERVIEW The Site has an ISO accredited Envirnmental Management System (EMS). This system includes cmprehensive management plans and is used Site wide. The EMS shuld be used in cnjunctin with the DEMP and this sub-management plan. The demlitin wrks cmprise f fllwing ptential VOCs/dur and dust generating activities: Demlitin, dismantling r remval f redundant refinery prcess units, tanks, n-site pipes (in pipeways, abve and undergrund pipes), buildings and services; Remval f redundant ff-site pipelines (Cntinental Carbn Pipeline, redundant pipelines that run thrugh the western and eastern Right f Ways (ROWs) and the cling water intake pipelines; Returning the wrk areas t grund level; and A range f ancillary wrks (civil wrks, waste management including cncrete crushing etc.). The ACS Management wrks cmprise f fllwing ptential VOCs/dur and dust generating activities: Pipeway excavatins; Excavatin f ACS frm ther parts f the Site; and Cntainment cell cnstructin, filling and clsure wrks. 3.1 Ptential Surces f Air Emissins The ptential surces f impact t air quality during the demlitin wrks are limited t: Dust generated frm excavatin, emplacement, backfilling, handling, transfer and stckpiling f sil; Dust frm cncrete/fundatin cutting, breaking and crushing, handling and stckpiling; Vehicle generated dust especially when traversing in ff-rad areas; Wind-blwn dust generated frm temprary stckpiles; VOCs and/r durs frm the peratin f vehicles, mvement/excavatin f ptentially cntaminated sil and stckpiles, and hydrcarbn spills; Wastewater treatment plant peratin including sludge handling; Fumes and fine particulates frm cutting and grinding and cncrete crushing; and Odur generated frm the presence f bilgical matter in the cling water inlet pipeline. The ptential surces f impact t air quality during the ACS Management wrks are limited t: Particulate matter and sil cntaminant emissins (including asbests) frm the excavatin, handling, transprt f cntaminated sils. Page 9

10 Particulate matter emissins frm the cnstructin f the cntainment cell. Particulate matter frm transprt f ACS n internal radways. Cmbustin emissins frm mbile plant (e.g. trucks, excavatrs, dzers). 3.2 Wrks Prgram Caltex cmmenced the demlitin wrks during the secnd half f The ACS Management wrks will cmmence in early A schedule fr demlitin wrks and the ACS Management wrks is shwn in Table 3 belw. Table 3 Prpsed Wrks Schedule Task Indicative Date Demlitin wrks Demlitin f Refinery Prcess Units Mid 2015 Mid 2017 Demlitin f Tanks Mid 2016 Mid 2018 Pipeline Remval Start 2016 Mid 2018 Demlitin f Buildings Mid 2016 End 2017 Cncrete Crushing Q ACS Management wrks Cntainment Cell Cnstructin Late 2017 Q Excavatin f ACS frm Pipeways and Filling f Cntainment Cell Q Q Clsure f Cntainment Cell Q Demlitin wrks assciated with the Prject will nt extend beynd three years frm the date f cnsent f SSD 5544 MOD 1 (i.e. 10 August 2018). The ACS Management wrks will be cmplete by 30 April 2019 in accrdance with SSD 5544 MOD 2 cnditin B7B. Page 10

11 4 AIR QUALITY MANAGEMENT PROCEDURES Specific cntrl measures required t undertake the demlitin wrks and ACS Management wrks including the Perfrmance Objectives, Management Actins, Perfrmance Indicatrs, Mnitring, Reprting and Crrective Actins set ut in the fllwing sectins. Suitable equipment, facilities, training, wrk practices and ther necessary precautins will be taken t minimise impacts t the envirnment and the risk f pllutin. All Caltex and Cntractrs persnnel will implement reasnable and practicable measures t avid r minimise impacts t the envirnment that may arise frm the demlitin wrks. 4.1 Air Quality and Odur Management & Mitigatin Measures The systems fr management f ptential air quality and dur impacts include: Truck and Equipment Mvements Vehicles will nly travel n designated rads t the maximum extent pssible. The speed will be limited t 10 km/hr in ff-rad areas 25 km/hr in all ther areas. All sil lads entering r leaving the Site will be cvered and all tailgates will be securely fastened. Vehicles will nt be laded higher than the sides and tailbard. Trucks assciated with the demlitin wrks d nt track dirt nt the public rad netwrk. Dirt n public rads as a result f the develpment will be prmptly remved. All plant will be maintained and perated in line with the manufacturer s specificatins in rder t minimise the emissin f air pllutants and ffensive durs. Plant and cnstructin vehicles will be turned ff when nt in use. Excavatin/Demlitin Activities Ptentially dust generating demlitin activities will be minimised during high wind events (i.e. > 8 m/s (r 28.8km/hr) hurly average r in severe wind gust cnditins). In unfavurable weather cnditins (e.g. > 8 m/s hurly average r in severe wind gust cnditins) r where dust surces are present near sensitive receivers and wrk is required t prceed, water sprays will be used t dampen dwn sils prir t excavatin, handling and/r lading/unlading materials. All expsed surfaces (frm recent excavatins) and stckpiles (f excavated material) will als be watered, sprayed r cvered where required, t minimise nuisance dust and durs. Excavatin will be staged t manage ptential VOC and dur emissins. Excavatins f cntaminated sils will nt cmmence prir t 8am nr after 4pm as weather cnditins at these times are generally cnducive t adverse dur air quality situatins frm fugitive emissins. Odurus stckpiles wil be cvered, wetted dwn and/r dur suppressant applied where required. Page 11

12 During unfavurable weather cnditins (e.g. > 8 m/s hurly average) and extrardinary weather events (as defined by the Bureau f Meterlgy weather warnings) such where elevated backgrund dust is present, additinal mitigatin measures will be emplyed and will include, but nt be limited t, implementing the fllwing: Reducing wrking surface area; Cmmencing excavatin during favurable wind cnditins; Increase wetting agents fr expsed surfaces; and Increase cvering f expsed surface areas. Where visible dust emissins are bserved management actins will be implemented t prevent impact including: reducing wrking surface area; halting excavatin until there are favurable wind cnditins (i.e. when winds drp belw 8m/s (hurly average) and/r when severe wind gusts have ceased and/r when visual mnitring has cnfirmed that there are n mre visible dust emissins); increasing wetting agents fr expsed surfaces; and cvering f expsed surface areas. Sils r cncrete with significant hydrcarbn staining r bvius hydrcarbn durs will be transprted t designated area f the Site and stred and managed in line with the Blue Bk (refer t the Sil and Water Management Plan). Stckpiles f cntaminated sil stred n-site will be cvered t prevent drus VOC emissins and windblwn particulate emissins. Surface disturbance will be minimised. Expsed grund will be rehabilitated as sn as practicable (refer t Sil and Water Management Plan) All cncrete cutting and cring will be undertaken using wet tls. During cncrete crushing, dust suppressin measures will be implemented, which may include watering f stckpiles, dust curtains and ther measures as required. In the event f an dur cmplaint, investigatins will be undertaken t cnfirm if the demlitin wrks are the surce f the durs. If the demlitin wrks are cnfirmed as a ptential nging dur surce additinal mitigatin measures will be investigated and implemented which culd include the use f water sprays t suppress durs and, if necessary, the use f dur suppressants. Off-site lfactry bservatins and VOC mnitring using equipment will als be undertaken if necessary. In the event f nging dur issues, excavatin activities will be reviewed and if necessary the excavatin stpped, cvered r backfilled (refer als t the Sil and Water Management Plan). Further, if mitigatin measures d nt wrk, wrks will be stpped until suitable measures can be emplyed t manage this issue. In line with Caltex s existing prcedure, fllwing a cmplaint and its subsequent investigatin, feedback regarding the surce and nature f the cmplaint will be prvided t the affected cmmunity members (refer als t Sectin 4.3). Page 12

13 Cling Water Inlet Pipewrk Prir t demlitin/remval f three cling water lines, Caltex will assess t determine the presence f bilgical matter. Where bilgical matter is present, the pipewrk will be demlished/remved as quickly as pssible t help minimise the ptential fr dur issues assciated with the degradatin and then expsure f the bilgical matter. ACS Management wrks The fllwing specific cntrl measures are prpsed fr the cntainment cell wrks area: Sil misture cntent will be managed in rder t minimise ptential particulate matter and asbests emissins t the maximum extent practicable. Directed water sprays will be used when required thrughut ACS handling peratins. ACS will be cvered with a bidegradable spray after it is placed in the cntainment cell. Stckpiles will be maintained in a mist cnditin, and cvered if nt in use r left vernight. Cmpleted areas f the wrks area will be revegetated with native grasses as sn as is practicable The Remedial Actin Plan fr the ACS Management wrks will be implemented during excavatin f the pipeways and filling f the cntainment cell. The Cntainment Cell Management Plan will be implemented during the cnstructin, filling and clsure f the cntainment cell. ACS will be managed by a licensed asbests cntractr as per the Asbests Remval Cntrl Plan. 4.2 Mnitring A number f mnitring menthds will be used during the demlitin wrks including: Weather/dust/asbests mnitring; and Odur and VOC mnitring. Mnitring during the ACS Management wrks is discussed in the Cntainment Cell Management Plan and Remedial Actin Plan. Dust Dust emissins will be mnitred via the fllwing methds: The n-site real time ambient air quality mnitring statin will perate thrughut the wrks fr PM2.5, PM10, wind directin and speed, temperature and humidity and rainfall (refer t Figure 1 fr lcatin). Data frm this air quality mnitring statin is analysed n a mnthly basis t demnstate cmpliance with the Australian Standards. During activities that have the ptential t generate dust and/r during adverse weather cnditins visual bservatins f dwnwind dust emissins t the cmmunity r lcal residents will be undertaken. Further, an anemmeter may be used, at 2 m abve grund level, t verify Page 13

14 when adverse weather cnditins are ccurring (i.e where there are severe wind gusts r an hurly average wind f ver 8 m/s). A temprary halt t dust generating activities will ccur during adverse weather cnditins and/r where visual dust emissins are sighted and/r when sensitive receptrs are likely t be affected by dust emissins. Apprpriate measures will be taken t mitigate/manage the ptential fr adverse air quality impacts (refer t Sectin 4.1). During wrks with significant ptential t generate dust beynd the site bundary and/r during adverse weather cnditins, dust depsitin mnitring (e.g. a dust depsitin gauge as per the AS/NZS 3580) will be undertaken. Depending n prevailing cnditins, lcatins may include: 1 x dust depsitin gauge in the Western ROW (as a representative lcatin in the Kurnell Cmmunity); 1 x dust depsitin gauge in an upwind lcatin t prvide a representative backgrund dust level; and Up t 3 x dust depsitin gauges nearfield and dwnwind f the excavatin wrks. These dust depsitin gauges will be analysed n a weekly r mnthly basis. Weekly checking will ccur where a there has been significant (cntinuus) excavatin wrks ver a week lng perid. Mnthly analysis will ccur where these activities have been less intensive. 2 g/m 2 /mnth criteria will be used when baseline data n depsited dust levels exists, while the 4 g/m 2 /mnth criteria is used when n baseline data exists 1. The results frm this mnitring will result in additinal/different management and mitigatin measures being implemented as per Sectin 4.1 and Sectin 5.8. Stckpiled material will be assessed fr the ptential t cause dust emissins. If air pllutants are likely, measures utlined in Sectin 4.1 will be implemented. Air mnitring will ccur in accrdance with the requirements detailed within Sectin 8.8 f the Mdel Wrk Health and Safety Regulatins 2011 fr asbests during excavatins and stckpiling. The disturbance area will be mnitred cntinuusly fr asbests using fur mnitrs (ne upwind and three dwnwind). The results f the air mnitring will be prvided t the relevant internal stakehlders. Refer als t the Sil and Water Management Plan and the Asbests Management Plan. Odur and VOCs Odur and VOC emissins will be mnitred via the fllwing methds: VOC and dur mnitring will be undertaken by demlitin wrkers r ACS Management wrkers (i.e. visual and lfactry mnitring) and where required, using prtable mnitring equipment (PID r similar) during excavatin activities where ptential hydrcarbn cntaminated sil is present. If any significant durs f VOCs (bservable durs at the site bundary) are identified during demlitin, measures utlined in Sectin 4.1 will be implemented. Further, if mitigatin measures d nt wrk, wrks will be stpped until suitable measures can be emplyed t manage this issue. 1 DEC (2005) Apprved Methds & Guidance fr the Mdelling and Assessment f Air Pllutants in NSW Page 14

15 Stckpiled material will be assessed fr the ptential fr causing durs f VOCs using visual, lfactry r PID mnitring. If air pllutants and ffensive durs are likely, measures utlined in Sectin 4.1 will be implemented. Cncrete Crushing Real-time dust mnitring (e.g. DustTrak mnitring) will be undertaking during the peratin f the cncrete crusher. An alarm r message will be generated if an hurly average f 80 ug/m 3 f dust particles is triggered 2. This will be altered based n the upwind mnitring results. Where ptential dust impacts are identified during crushing, measures utlined in Sectin 4.1 will be implemented. 4.3 External Cmmunicatin One r mre f the fllwing cmmunicatin methds, where apprpriate, will be used t ntify ptentially affected persns, the EPA and the NSW Public Health Unit during the demlitin wrks: Site meetings with the Cmmunity Representative(s); The Caltex website ( Cmmunity leaflets/newsletters; Meetings and crrespndence with interested parties including the SSC and EPA; Discussins with adjining land wners / neighburs and the cmmunity; and A summary f the air quality mnitring data fr the demlitin wrks will be prvided t the cmmunity during Caltex s quarterly cmmunity meeting. Where air mnitring results shw that respirable asbests fibre exceeds the level f 0.01 fibres/ml r mre than 0.01 fibres/ml the fllwing will be undertaken: The cmpetent persn will review review cntrl measures, investigate the cause and implement cntrl mechanisms t ensure dust desn't leave the site t neighburing prperties; and A cpy f the air mnitring results t be sent t the Public Health Unit. 2 Page 15

16 Figure 1 Caltex Air Quality Mnitring Statin Page 16

17 5 IMPLEMENTATION 5.1 Rles and Respnsibilities Overall respnsibility fr the implementatin f this Air Quality Management Plan rests with Caltex. All emplyees and the Cntractr will meet the requirements f this Management Plan and assciated prcedures. Management actins set ut in this Management Plan may be delegated in writing by Caltex t the specific Cntractr. Key wrks persnnel including the Demlitin Prject Lead (and their delegate), Caltex ER, Cntractr Prject Manager and each Cntractr s Envirnment / HSE Representative, will ensure that all management actins are undertaken t a satisfactry standard and that all persnnel are aware f their respnsibilities with respect t envirnmental matters. There will be dedicated staff t manage envirnmental issues (r integrated HSE matters) during the implementatin and peratinal phase f the wrks. A general utline f respnsibilities in relatin t envirnmental management is prvided belw: Demlitin Prject Lead / Demlitin Executin Superintendent / Demlitin Supprt Services Superintendent Overall accuntability fr the envirnmental management f the demlitin wrks and ACS Management wrks. Implementatin f the Caltex Envirnmental Plicy with respect t the demlitin wrks and ACS Management wrks. Overall respnsibility fr develpment, implementatin, maintenance and cmpliance with this Management Plan. Caltex Envirnmental Representative (ER) Accuntable fr envirnmental matters n the demlitin wrks and ACS Management wrks. Prvide supprt t Caltex persnnel and the Cntractr as required t ensure this Management Plan is implemented and cmplied with. Review effectiveness and implementatin f this Management Plan and update if required. Mnitr the implementatin f all required envirnmental management actins and cmpliance with legislatin. Undertake envirnmental auditing as required. Implement Prtectin f the Envirnment Operatins Act 1997 (POEO Act) ntificatin requirements in the event f a pllutin incident (these requirements can be delegated t apprpriate persnnel by the ER). Page 17

18 All Persnnel (Caltex and the Cntractr) Cmply with the requirements f this Management Plan. Reprt all envirnmental incidents as they ccur. Attend envirnmental inductins r any ther training as required. 5.2 Inductin Caltex has a site inductin prgram that all cntractrs and emplyees are required t cmplete prir t undertaking any wrk. All Caltex emplyees and the Cntractr are required t undertake the Caltex Prject Inductin befre they can cmmence wrk n the demlitin wrks and ACS Management wrks. 5.3 Training All Prject persnnel will have the experience and necessary training t carry ut their required tasks, including in the use f equipment and the implementatin f this Management Plan. Caltex and the Cntractr will each maintain a Training Register that recrds all envirnmental training cmpleted by its persnnel, including recrds f attendance at awareness training and tlbx talks, as well as cmpetency assessments. 5.4 Incident Management Caltex will cntinue t implement its existing incident management prcedures, including fr respnse t, investigatin and reprting f incidents. A cmprehensive Emergency Management System is currently implemented at the Kurnell Terminal, with assciated respnse and safety equipment held n-site. Key persnnel are trained t supprt the implementatin f the system. Regular training exercises are carried ut by Caltex. Further, the Prtectin f the Envirnment and Operatins Act 1997 (POEO Act) requires that the hlder f an EPL prepare a Pllutin Incident Respnse Management Plan (PIRMP). Accrdingly, Caltex has develped and implements a PIRMP fr the Kurnell Terminal. In the event f an incident causing envirnmental harm ccurs as a result f demlitin wrks, the Kurnell Pllutin Incident Respnse Management Plan (PIRMP) will be implemented. 5.5 Cmplaints Management Caltex has a cmplaints management prcedures fr the investigatin, respnse and reprting f cmplaints. Caltex manages all cmmunity cmplaints in accrdance with the requirements f EPL 837, including: Reprting cmplaints in the Annual Return fr EPL 837 Keeping a legible recrd f all cmplaints made t Caltex and its Cntractrs, including: The date and time f the cmplaint Page 18

19 The methd by which the cmplaint was made Any persnal details f the cmplainant which were prvided by the cmplainant r, if n such details were prvided, a nte t that effect The nature f the cmplaint The actin taken by Caltex in relatin t the cmplaint, including any fllw-up cntact with the cmplainant If n actin was taken by Caltex, the reasns why n actin was taken Caltex will cntinue t perate its 24-hur htline number ( tll free) t receive feedback and cmplaints assciated with the Prject. All feedback and cmplaints will be relayed t the ER and relayed t the Terminal Manager, Demlitin Prject Lead (r delegate), Cmmunity Relatins Manager and the Envirnmental Prtectin Superintendent, as relevant depending n their nature. Any feedback and cmplaint recrds will be lgged in the Cmplaints Register, tracked and where relevant, respnded t. Respnses t cmplaints will be made, where reasnably pssible, within 48 hurs f receiving the cmplaint. 5.6 Perfrmance Indicatrs The fllwing perfrmance indicatrs will be implemented during the demlitin wrks and ACS Management wrks: N unacceptable air quality cmplaints (dur, dust) received in relatin t the demlitin wrks and ACS Management wrks; and N visible emissins f dust beynd the Terminal bundary in relatin t the demlitin wrks and ACS Management wrks. N exceedance f expsure r cntrl limits fr asbests. 5.7 Reprting The reprting requirements include: Ntificatin f Caltex ER f any dur screening results where excessive dur is bserved. The dates and utcmes f visual emissins mnitring will be reprted by the Cntractr t the Caltex ER frtnightly. Ntificatin f Caltex ER f any cmmunity cmplaints; Ntificatin f Caltex ER f any stp-wrk requirements triggered by meterlgical cnditins. Page 19

20 5.8 Crrective Actins Where exceedances f the perfrmance criteria ccur, ne r mre f the fllwing crrective actins will be implemented: Land based dur screening is undertaken dwn-wind and twards nearest residential receptrs; Cntractrs, in cllabratin with Caltex, will develp and implement apprpriate management measures where anmalus durs are identified r significant dust generatin is ccurring (as utlined in Sectin 4.1). Further, if mitigatin measures d nt wrk, wrks will be stpped until suitable measures can be emplyed t manage this issue. Surces f dust emissins will be cvered, r wet dwn; and Equipment bserved t be creating excessive emissins will be replaced r serviced within 48 hurs. Page 20