M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush

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1 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan April 2017 Sydney Motorway Corporation (ACN ) and its controlled entities Sydney Motorway Corporation M4 Widening Motorway: Operational Environmental Management Plan Page 1 of 62 Commercial in Confidence

2 Definitions Term Definition Asset Describes the WestConnex M4 Motorway between Pitt Street at Parramatta and Homebush Bay Drive Asset footprint Describes the area covered by the asset Approved project Refers to the WestConnex M4 Widening project (SSI- 6148) Compliance audit Compliance audit Conditions of approval (MCoA) CTP DP&E DPI Ecologically sustainable development Verification of how implementation is proceeding with respect to an operation environmental management plan (OEMP, which incorporates the relevant approval conditions). Verification of how implementation is proceeding with respect to an operation environmental management plan (OEMP, which incorporates the relevant approval conditions). Conditions of approval for the M4 Widening Project Compliance Tracking Program Department of Planning and Environment The NSW Department of Primary Industries now part of NSW Department of Trade and Investment, Regional Infrastructure and Services (DTIRIS) Using, conserving and enhancing the community s resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future, can be increased (Council of Australian Governments, 1992). EIS EMS Environmental aspect Environmental impact Environmental Impact Statement Environmental Management System Defined by AS/NZS ISO 14001:2004 as an element of an organisation s activities, products or services that can interact with the environment Defined by AS/NZS ISO 14001:2004 as any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation s environmental aspects Environmental incident An unexpected event that has, or has the potential to, cause harm to the environment and requires some action to minimise the impact or restore the environment Environmental objective Defined by AS/NZS ISO 14001:2004 as an overall environmental goal, consistent with the environmental policy, that an organisation sets itself to achieve Environmental policy Statement by an organisation of its intention and principles for environmental performance Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 1 of 59

3 Term Definition Environmental target Defined by AS/NZS ISO 14001:2004 as a detailed performance requirement, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives EP&A Act Environmental Planning and Assessment Act 1979 EPA ESWMS NSW Environment Protection Authority Environmental safe work method statement Feasible and reasonable Consideration of best practice taking into account the benefit of proposed measures and their technological and associated operational application in the NSW and Australian context. Feasible relates to engineering considerations and what is practical to build. Reasonable relates to the application of judgement in arriving at a decision, taking into account mitigation benefits and cost of mitigation versus benefits provided, community expectations and nature and extent of potential improvements. Where requested by the Secretary, the SMC will provide evidence as to how feasible and reasonable measures were considered and taken into account. Heritage Encompasses both Aboriginal and non-aboriginal heritage including sites that predate European settlement, and a shared history since European settlement such as shared associations in pastoral landscapes as well as associations linked with the mission period. IMS KPI OEMPSP Minister, the Non-compliance Non-conformance O&M O&M activities Integrated management system Key performance indicator OEMP sub-plan Minister for Planning Failure to comply with the requirements of the project approval or any applicable license, permit or legal requirements. Failure to conform to the requirements of system documentation including this OEMP or supporting documentation. Operation and maintenance All activities required to undertake the operation and maintenance of the M4 Motorway personnel SMC IMS Undertakes the operation and maintenance of the asset under the O&M deed All people employed by the to undertake operation and maintenance work Contains the policy, practices, and procedures for operating, maintaining and repairing WestConnex, which includes relevant environmental management information including this OEMP and the OEMPSPs Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 2 of 59

4 Term O&M services O&M stakeholders OEH OEMP Operation Project approval, the Project deed Relevant councils RMS RNP Secretary, the Sensitive receiver SWTC SMC Definition Operation and maintenance of the M4 Motorway All entities undertaking operational and maintenance activities on the asset. Typically including SMC and and other sub-contracted parties. Office of Environment and Heritage Operation Environmental Management Plan Means the operation, maintenance and/or repair of the Asset The written approval from the Minister for Planning and Environment for the Project The agreement between SMC and RMS that sets out the fundamental obligations to operating, maintaining and repairing the asset. City of Parramatta City Council and Cumberland Council Roads and Maritime Services Road Noise Policy Secretary of the Department of Planning and Environment Residence, education institution (e.g. school, university, TAFE college), health care facility (e.g. nursing home, hospital), religious facility (e.g. church) and children s day care facility. Scope of work and technical criteria forming part of the project deed relating to the specific scope and performance requirements and specifications associated with operating, maintaining and repairing the asset. Sydney Motorway Corporation Pty Limited (SMC) (ABN ) is a special purpose entity that has been created by the NSW Government to manage the delivery of WestConnex. For the purposes this M4 Widening Motorway Operational Environmental Management Plan (OEMP), WCX M4 PT Pty Ltd will act on behalf of Sydney Motorway Corporation Pty Limited (SMC) SOP SOPA SPG SSI WCX M4 AT Pty Ltd WCX M4 PT Pty Ltd Standard operating procedure Sydney Olympic Park Authority Senior project group State significant infrastructure WCX M4 AT Pty Ltd (ABN ) in its capacity as trustee of the WCX M4 Asset Trust (ABN ) is a related body corporate of the Sydney Motorway Corporation Pty Limited (ABN ) group of companies. WCX M4 PT Pty Ltd (ABN ) in its capacity as trustee of the WCX M4 Project Trust (ABN ) is a related body corporate of the Sydney Motorway Corporation Pty Limited (ABN ) group of companies. For the purposes this M4 Widening Motorway Operational Environmental Management Plan (OEMP), all Sydney Motorway Corporation Pty Limited (SMC) responsibilities will be undertaken by WCX M4 PT Pty Ltd Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 3 of 59

5 Table of Contents 1 Introduction Purpose Objectives Management, update, certification and approval Consultation OEMP structure OEMP Sub-plans Key stakeholders Asset description Asset Location Operational activities Operation and maintenance of the asset O&M facilities: maintenance depot O&M equipment Timing of operation and maintenance Details of employment numbers Environmental obligations Statutory obligations Conditions of approval Mitigation and management commitments Legislation Permits, licences and approvals Environmental policies, guidelines and principles Implementation Roles and responsibilities Responsibilities Compliance, training and awareness Environmental induction Toolbox talks Environmental awareness training Emergency response training Communication Internal communication External and Government consultation Community information and reporting Community engagement strategy Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 4 of 59

6 7.3.2 Advertising routine operations and maintenance activities Media protocol Contact information Complaints and enquires procedure Directing and stopping work Risks, incidents and emergencies Environmental risk analysis Continual improvement Risk identification Incident and emergency management Managing and monitoring performance Environmental monitoring and inspections Subcontractor environmental management Operational performance monitoring Operational audits Independent environmental audit Non-compliances Corrective actions Other non-compliances and non-conformances Compliance tracking Reporting to DP&E Non-conformance reporting and notification Corrective actions OEMP review and records management OEMP review Records management Document control Appendix A: SMC environmental and sustainability policy Appendix B: OEMP Consultation feedback Appendix C: Environmental risk analysis Appendix D: Environmental incident procedure Appendix E: Environmental Monitoring Checklist OEMPSP1: Noise and Vibration OEMPSP2: Traffic and transport OEMPSP3: Visual amenity and landscaping OEMPSP4: Surface water quality and hydrology Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 5 of 59

7 1 Introduction This document forms the operational environmental management plan (OEMP) for the M4 Widening Motorway between Pitt Street at Parramatta and Homebush Bay Drive at Homebush (SSI-6148, the asset ). It has been prepared in accordance with: Environmental Management System Guidelines 3 rd Edition (EMS Guidelines, NSW Government, 2013), which helps prepare and implement systematic practices to manage environmental performance and conformance Roads and Maritime s quality assurance specifications that include provisions for managing the environmental impacts of road related infrastructure and development ISO 14001:2015 environmental management standards (Standards International, 2015), which provide a defined system to manage operations to minimise their environmental impacts, ensure legal compliance, and allow for continual improvement over time Relevant Ministerial conditions of approval (MCoAs) relating to the operation of the WestConnex M4 Widening project ( the approved project ), refer to section The OEMP will be published on the WestConnex M4 Widening project resources website ( and provided to the public upon request. 1.1 Purpose The OEMP identifies risks and legal obligations associated with the asset s day-to-day operations by: Identifying best environmental management practices for operating the asset in the future Setting-out relevant operational environmental management commitments, safeguards and management measures Describing relevant legal and regulatory provisions Managing environmental risk. The OEMP also: Satisfies and executes relevant operational environmental obligations and MCoA (refer to Table 4.1) Allows environmental performance to be easily reported, audited and monitored Allows standard operating procedures (SOPs) and environmental safe work method statements (ESWMSs) to be developed and implemented. 1.2 Objectives The OEMP s objectives are aligned with SMC s corporate environment and sustainability policy (refer to Appendix A). They are to: Provide a reference document that defines and interprets operational environmental commitments Satisfy the operational MCoA covering the approved project (as detailed in section 4.1) relating to: Operational noise management and compliance Urban design and landscape management and maintenance Operational environmental management Independent environmental auditing Compliance tracking Water quality planning and monitoring Community consultation and involvement. Provide environmental protection during the asset s operation, extending to ensuring the obligations on all personnel (management, workforce and subcontractors) are achieved and the asset performs to a standard consistent with the requirements of Roads and Maritime s quality assurance specification G36: Environmental Protection (Roads and Maritime, 2016) Ensure all personnel are trained and undertake activities in an environmentally responsible manner Identify and appropriately manage risks in order to prevent, or minimise, environmental harm Ensure asset operations minimise road user disturbance and local community impacts Monitor the asset s operational environmental impacts in accordance with this document Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 6 of 58

8 Document the environmental monitoring requirements needed to maintain the environment Develop, implement, and maintain effective management systems and plans to control and manage activities that may have an environmental impact Ensure legislative and regulatory environmental compliance, while meeting social expectations, statutory and legal provisions, and other planning policy requirements Demonstrate environmental protection, pollution prevention control, and continual improvement Ensure consistency with ISO14001 environmental management standards. 1.3 Management, update, certification and approval The OEMP must remain a flexible document that provides continual feedback and improvement over the course of its life. It must therefore be updated to reflect: Improvements, observations and non-conformances Improvements in mitigation, management and monitoring measures. Changes in: Project implementation and operation Maintenance methods Organisational structure, roles and responsibilities Legislation, regulation, policy and guidance. 1.4 Consultation The OEMP must also be updated to respond to feedback and consultation. The following stakeholders were consulted in developing the OEMP: NSW Department of Planning and Environment (DP&E) Roads and Maritime Department of Primary Industries: Fisheries and Water WaterNSW Heritage Council of NSW NSW Office of Environment and Heritage NSW Environment Protection Authority City of Parramatta Council Cumberland Council Deerubbin Local Aboriginal Land Council Metropolitan Local Aboriginal Land Council Sydney Olympic Park Authority Sydney Water Appendix B summarises the consultation feedback provided to date. It describes how and where the feedback has been covered or addressed in this OEMP. SMC will continue consulting with the above stakeholders and other relevant parties as the OEMP is implemented. Subsequent feedback will be documented and used to inform revisions and updates of this OEMP (refer to section 10.1). Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 7 of 59

9 2 OEMP structure 2.1 OEMP The OEMP comprises: This document (including appendices) Four OEMP sub-plans (OEMPSPs) as appended to this document that focus on key performance issues. The OEMP also requires the O&M Contractor to develop and work under its own: Standard operating procedures (SOPs) Environmental safe work method statements (ESWMS). 2.2 Sub-plans OEMP sub-plan and relevant MCoA OEMPSP1: noise and vibration MCoA E5 and E8i OEMPSP2: traffic and transport MCoA E8ii OEMPSP3: visual amenity and landscaping MCoA E8iii OEMPSP4: surface water quality and hydrology MCoA E8iv Details Maintenance of noise mitigation infrastructure Manage operational road traffic noise Equipment maintenance Noise management during maintenance and repair Vibration management during maintenance and repair Operational noise compliance and assessment Community communications Complaints management Toll and ITS management, maintenance and repair Bridge, structures and intersection maintenance and repair Line marking, road surface (pavement) repairs Weed control Litter management Graffiti clean-up Landscape management Tree and vegetation management Contamination management Spills and clean-up materials Stormwater management and maintenance Water quality monitoring Sediment and erosion control Responsibility O&M Contractor SMC SMC/O&M Contractor O&M Contractor O&M Contractor SMC SMC SMC/O&M Contractor O&M Contractor O&M Contractor O&M Contractor O&M Contractor O&M Contractor O&M Contractor O&M Contractor O&M Contractor SMC/O&M Contractor SMC/O&M Contractor SMC/O&M Contractor SMC/O&M Contractor SMC/O&M Contractor 2.3 Key stakeholders The key O&M stakeholders are: Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 8 of 59

10 Road and Maritime Services (RMS) Sydney Motorway Corporation (SMC): asset delivery and operation Table 2.1 summarises the roles and functions of the key O&M stakeholders. Table 2.1: Key O&M stakeholder roles and functions Organisation Roles and function Roads and Maritime: proponent SMC: delivery and operation : operational maintenance Act on behalf of the Government as the client and commissioning agency Manage concession arrangements on behalf of the NSW Government Carry-out project development work for future WestConnex projects Act as proponent for planning approvals Acquire the property needed to build and operate WestConnex Maintain responsibility for tolling policy (with Transport for NSW) Provide advice and leadership on environmental policy and regulation Overall customer care Commission future planned major maintenance, repair and upgrade activities Holding SMC to account under contract. Project manage delivery of WestConnex Procure and manage contracts for the operation and maintenance of WestConnex and any impacts that could result from this Finance WestConnex, including securing limited-recourse debt Deliver communication and stakeholder engagement activities and services including Ministerial liaison during operation Prepare planning approval documents Undertake certain operational start-up verification and monitoring Contractor management, performance monitoring and auditing. Operation Services Traffic management including monitoring the operation of traffic signalling devices from the Motorway Control Centre (MCC) Equipment and systems management including monitoring the operation of tolling systems Incident management, including attending and clearing all breakdowns and other vehicle incidents (including spills) on the M4 Motorway. Maintenance Services Routine and non-routine preventative maintenance activities required to maintain the safe and continuous operation of the Motorway Landscape maintenance Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 9 of 59

11 3 Asset description 3.1 Asset The Asset comprises the M4 Motorway between Pitt Street at Parramatta and Homebush Bay Drive. Table 3.1: Key asset components Asset Location Interchanges Interchanges James Ruse Drive Westbound on-ramp and off-ramp Eastbound on-ramp and off-ramp Silverwater Road Westbound on-ramp and off-ramp Eastbound on-ramp and off-ramp Hill Road Westbound on-ramp Eastbound on-ramp and off-ramp Homebush Bay Drive Westbound on-ramp and off-ramp Eastbound on-ramp and off-ramp Other features Off-road shared use path Between Fox Street and Wigram Street including three underpasses connecting into Bridge Street Junction Street and Wigram Street to the north of the motorway Watercourse bridges A Becketts Creek Duck River Haslams Creek Intelligent transport systems Environmental and amenity controls Tolling equipment Gantries Equipment shelters Substations Cameras Cabling and conduits Noise barriers Planting and landscape treatments Water quality basins Stormwater drainage Longitudinal drains (pits and pipes) Cross drains (culverts) Detention (storage) basins Road furniture Lighting Signage Utilities Power Communications Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 10 of 59

12 Asset Location Cables and conduits 3.2 Location Figure 3.1 shows the location and key features of the Asset. etmc Motorway Control Centre Maintenance Depot Operations and Maintenance Project Boundary Figure 3.1: Key features of the asset as upgraded under the approved project 3.3 Operational activities This section describes the operational activities associated with the asset including O&M services O&M facilities O&M equipment O&M timing Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 11 of 59

13 3.3.1 Operation and maintenance of the asset Table 3.2 lists the operational and maintenance activities the O&M is responsible for. Table 3.2: Operational and maintenance services Services Operations services Maintenance and repair services Activities All things necessary for the use, operation and control of the motorway including: Managing traffic including monitoring the operation of traffic signalling devices from the motorway control centre (MCC) Managing equipment and systems including monitoring the operation of tolling systems Managing incidents including attending and clearing all breakdowns and other vehicle incidents (including spills) on the M4 Motorway. Routine preventative maintenance activities required to maintain the safe and continuous operation of the Motorway including: Maintaining landscaped areas including vegetation trimming, grass mowing and replanting using equipment such as tractor slashers, ride on mowers, hand mowers, brush cutters, blower/vacs, small skids steer, augers, water carts, etc. Removing material deposited by motorists, such as non-biodegradable litter and food wastes from the Motorway verges using road sweeping equipment and maintenance crew members Cleaning up any spills from motor vehicles using spill kits containing kitty litter material to absorb spills, then shovelled/swept up and material disposed at approved waste facilities Removing graffiti from road furnishings, retaining walls, bridges, etc. using non-hazardous materials and a pressure cleaner after application of removal agent Cleaning out drains (including detention and sedimentation basins) Repairing the road surface (pavement) Maintaining road furnishings (including noise barriers) Maintaining roadside and medians (including fences, retaining walls and landscaping) including removal of graffiti Maintaining bridges including repairs after collisions and removal of graffiti Maintaining the MCC and maintenance facility Maintaining mechanical and electrical systems (lighting, hydraulics, instrumentation) including replacement of light globes Maintaining roadside tolling equipment Maintaining and repairing intelligent transport systems (traffic lights, traffic signs, safety cameras) Undertaking line markings. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 12 of 59

14 3.3.2 O&M facilities: maintenance depot Location The maintenance depot is located on Adderley Street at Auburn immediately adjacent to Newton Street South. The will operate and maintain the depot. [] Depot Boundary [] Parking Area [] Site Building [] Storage Area Maintenance Yard Access point Figure 3.2: Maintenance depot Table 3.3 lists the operational features of the maintenance depot. Table 3.3: Maintenance depot infrastructure and equipment Aspect Infrastructure/equipment Buildings Site office facilities and restroom facilities: mobile site buildings Spares and equipment storage: freight containers Access Low volume: 24 hours per day for O&M Contractor vehicles Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 13 of 59

15 Aspect Chemical and liquid storage Large spares and consumable storage Sediment fencing Infrastructure/equipment Liquids Small quantities of diesel and petrol fuel (< 100 litres) Small quantities of paint (<2 x 20 litres) Small quantities of pesticides (<2 x 50 litres) Cleaning chemicals (<2 x 50 litres) Gases Oxy acetylene Solids Cold mix asphalt Notes: all liquids and dangerous goods will be stored in bundled flame proof storage. A material safety data sheet (MSDS) register will be kept onsite of all chemicals held. Appropriately-sized spill kits will be held onsite. Within the hardstand, area pallets will be used to store: Sand Mulch (from landscape maintenance for reuse) Motorway spares (e.g. guard rails) Sediment fencing will be placed around the premier of the maintenance depot O&M equipment The following equipment will be used to operate and maintain the asset: Tow trucks 15 tonne truck mounted attenuator Four wheeled drive utility vehicles Two wheeled drive utility vehicles Canter tipper truck with Hiab crane Tractor/slasher/mower Trailers Scissor lift and knuckle boom Road sweepers AS series arrow boards Other equipment/workshop tools, including items such as whipper snippers, knapsacks, secateurs, and handsaws Timing of operation and maintenance The commencement date for the operation of the road is the 22 June The completion time is 40 years from that date. The asset will be continuously operated and maintained 24-hours per day. Programmed maintenance works will be undertaken, where possible, during daylight hours. However due to the strategic importance of the motorway, certain scheduled activities will be timed to take place between 11pm and 5pm to minimise road user disruption. The will notify the public and other stakeholders before working at night or out of hours, using the methods described in section Urgent unplanned maintenance will be undertaken in accordance with the s community engagement strategy (refer to section 7.3.1) Details of employment numbers Management Positions Employment numbers are as per the organisational structure charts 1 person per box (refer to Figure 5.1 below) with the exception being the Quality Safety and Environment (QSE) professional. The community & Stakeholder manager will be 1 person in the interim period (i.e. prior to the opening of the Stage 2 M4 East motorway). Total Full Time Equivalent (FTE) or 1 person on a 38hr week for management positions: 10. Labour Positions Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 14 of 59

16 O&M Operations team will consist of: 5 FTE controller positions O&M Maintenance team will consist of: 6 FTE positions Total Labour: FTE Positions 11 Total Positions for M4 Widening: 21 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 15 of 59

17 4 Environmental obligations This section summarises the legal, environmental, and contractual obligations covered by this OEMP. 4.1 Statutory obligations This sections describes the statutory and other obligations covering the operational asset Conditions of approval Table 4.1 summarises the MCoA that SMC is responsible for that relate to the operation of the asset. Table 4.1: Relevant operational Ministerial conditions of approval MCoA Details Responsibility Reference B1 E1 Soil, water quality and hydrology Operate the asset in compliance with Part 5.3 Section 120 of the Protection of the Environment Operations Act Operational noise SMC/O&M Contractor Section 4.1 Operate the asset in accordance with the requirements and objectives of the NSW Road Noise Policy (NSW DECCW, 2011). SMC/O&M Contractor OEMPSP1 E2 Operational noise review Unless otherwise agreed by the Secretary, within six months of commencing construction, the Proponent shall, in consultation with the EPA, submit for the approval of the Secretary, a review of the operational noise mitigation measures proposed to be implemented for the SSI. The review shall: a) Confirm the operational noise predictions of the SSI based on detailed design, including maximum night time noise events (utilising an appropriately calibrated noise model which has incorporated additional noise monitoring where necessary for calibration purposes); b) Review the suitability of the operational noise mitigation measures identified in the documents listed under condition A2 to achieve the criteria outlined in the NSW Road Noise Policy (Department of Environment, Climate Change and Water, 2011), based on the operational noise performance of the SSI predicted under condition E1 c) Where necessary, investigate and identify additional feasible and reasonable noise mitigation measures to achieve the criteria outlined in the NSW Road Noise Policy (Department of Environment, Climate Change and Water, 2011). d) Identify all sensitive receiver locations eligible for architectural treatments. The review shall be undertaken by a suitably qualified and experienced acoustic specialist. Indirect operational noise impacts associated with the SSI on the adjoining road network, including for sensitive receivers along Parramatta Road between Woodville Road, Parramatta and the intersection of Parramatta Road/M4, Concord, shall be considered and addressed where feasible and reasonable under the Roads and Maritime Services Noise Abatement Not applicable during operations Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 16 of 59

18 MCoA Details Responsibility Reference Program ( ng-noise/noise-abatementprogram.html). The Proponent shall provide the Secretary and the EPA with a copy of the Operational Noise Report within 60 days of completing the operational noise monitoring referred to in (a) above or as otherwise agreed by the Secretary. Note: this is consistent with mitigation commitment NV-4 as described in the approved project submissions report, E7 Urban design and landscaping The ongoing maintenance of urban design and landscaping items and works implemented as part of this infrastructure approval shall remain the Proponent s responsibility unless satisfactory arrangements have been put in place for the transfer of ownership of the item or work to another authority. The Proponent will maintain items and works to the standards established in the Urban Design and Landscape Plan required under condition B26, unless and until landscaping items have been transferred. SMC/O&M Contractor OEMPSP3 E8 Operational environmental management plan Prior to the commencement of operation, or as otherwise agreed by the Secretary, the Proponent shall prepare and implement (following approval) an Operation Environmental Management Plan for the SSI. The OEMP shall outline the environmental management practices and procedures that are to be followed during operation, and shall be prepared in consultation with relevant agencies and in accordance with the Guideline for the Preparation of Environmental Management Plans (Department of Infrastructure, Planning and Natural Resources, 2004). The OEMP shall include, but not necessarily be limited to: SMC This OEMP e) A description of activities to be undertaken during operation of the infrastructure activity (including staging and scheduling) f) Statutory and other obligations that the Proponent is required to fulfil during operation, including approvals, consultations and agreements required from authorities and other stakeholders under key legislation and policies g) Overall environmental policies, guidelines and principles to be applied to the operation of the infrastructure activity h) A description of the roles and responsibilities for relevant employees involved in the operation of the infrastructure activity, including relevant training and induction provisions for ensuring that employees are aware of their environmental and compliance obligations under these conditions of approval SMC/O&M Contractor Section 3.3 SMC Section 4.1 SMC Section 4.3 SMC Section 5.1 i) An environmental risk analysis to identify the key environmental performance issues associated with the operation phase SMC Section 8.1 Appendix C Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 17 of 59

19 MCoA Details Responsibility Reference j) Details of how environmental performance would be managed and monitored to meet acceptable outcomes, including what actions will be taken to address identified potential adverse environmental impacts, including those safeguards and mitigation measures detailed in section 8 of the PIR (and any impacts arising from the staging of the construction of the infrastructure activity). In particular, the following environmental performance issues shall be addressed in the OEMP: SMC Chapter 9 (i) noise and vibration SMC/O&M Contractor OEMPSP1 (ii) traffic and transport SMC/O&M Contractor OEMPSP2 (iii) visual amenity and landscaping; and SMC/O&M Contractor OEMPSP3 (iv) surface water quality and hydrology SMC/O&M Contractor OEMPSP4 The Plan shall be submitted for the approval of the Secretary no later than one month prior to the commencement of operation, or as otherwise agreed by the Secretary. Operation shall not commence until written approval has been received from the Secretary. Note: the approval of an OEMP does not relieve the Proponent of any requirement associated with this infrastructure activity approval. If there is an inconsistency with an approved OEMP and the conditions of this infrastructure activity approval, the requirements of this infrastructure activity approval prevail. Note: this is consistent with mitigation commitment SWW-3 as described in the approved project submissions report, E9 Independent environmental audit Within 18 months of the commencement of operation, the proponent shall commission and pay the full cost of an Independent Environmental Audit of the SSI. This audit shall: a) Be conducted by a suitably qualified, experienced and independent team of experts whose appointment has been endorsed by the Secretary b) Include consultation with the relevant agencies and local councils c) Assess the environmental performance of the SSI and assess whether it is complying with the requirements in this approval, and any other relevant environmental approvals (including any assessment, plan or program required under these approvals) d) Review the accuracy of predicted environmental outcomes discussed in the documents listed in MCoA A2 e) Review the accuracy of any approved strategy, plan or program required under the abovementioned approvals f) Recommend measures or actions to improve the environmental performance of the SSI and or any strategy plan or program required under these approvals. Within 90 days of commissioning this audit, or as otherwise agreed by the Secretary, the Proponent shall submit a copy of the audit report to the Secretary and relevant public authorities, together with its response to any recommendations contained in the audit report. SMC Section 9.5 Should the audit identify unsatisfactory compliance with the SSI approval, the Secretary may require an additional audit to be undertaken at a later date(s). Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 18 of 59

20 MCoA Details Responsibility Reference Notes: this audit team shall be led by a suitably qualified and experienced auditor, and include relevant experts. The audit may be staged to suit the staged operation of the SSI. A12 Compliance tracking program The Proponent shall develop and implement a Compliance Tracking Program to track compliance with the requirements of this approval. The Program shall be submitted to the Secretary for approval prior to the commencement of construction and will operate for a minimum of 18 months following commencement of operation, subject to the Secretary s review of the outcomes of the Independent Environmental Audit Report referred to in MCoA E9. The operation of the program may be extended if the Secretary determines that there has been unsatisfactory compliance. The Program shall include, but not necessarily be limited to: SMC a) Provisions for the notification of the Secretary prior to the commencement of construction and prior to the commencement of operation of the SSI (including prior to each stage, where works are being staged) SMC b) Provisions for periodic review of the compliance status of the SSI against the requirements of this approval SMC c) Provisions for periodic reporting of compliance status to the Secretary, including but not limited to: (i) (ii) A Pre-Construction Compliance Report prior to the commencement of construction Quarterly Construction Compliance Reports, for the duration of construction Not applicable during operations Section 9.5 (iii) A Pre-Operation Compliance Report prior to the commencement of operation d) A program for independent environmental auditing in accordance with AS/NZS ISO 19011: Guidelines for Auditing Management Systems SMC e) Mechanisms for recording environmental incidents during construction and actions taken in response to those incidents SMC f) Provisions for reporting environmental incidents to the Secretary during construction, in accordance with MCoA A13 and A14 Not applicable during Operations g) Procedures for rectifying any non-compliance identified during environmental auditing, review of compliance or incident management SMC h) Provisions for ensuring all employees, contractors and sub-contractors are aware of, and comply with, the conditions of this approval relevant to their respective activities. SMC B7 Water Quality Plan and Monitoring Plan A Water Quality Plan and Monitoring Program shall be prepared and implemented to ensure that the project is designed and constructed to meet MCoA B1 and to monitor SMC Section 9.3 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 19 of 59

21 MCoA Details Responsibility Reference C2 impacts on surface and groundwater quality and resources and wetlands, during construction and operation. The Plan and Program shall be developed in consultation with the EPA, DPI (Fishing and Aquaculture and WaterNSW), the Sydney Olympic Park Authority (SOPA), and Councils and shall include but not necessarily be limited to: a) Identification of surface and groundwater quality monitoring locations (including watercourses, waterbodies and wetlands) which are representative of the potential extent of impacts from the SSI, including the relevant analytes and frequency of modelling b) Identification of work and activities during construction and operation of the SSI, including emergencies and spill events, that have the potential to impact on surface water quality of potentially affected waterways c) The presentation of water quality standards and parameters having regard to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000 (Australian and New Zealand Environment Conservation Council, 2000) d) Identification of environmental management measures relating to surface and groundwater during construction and operation, including sediment and stormwater management measures consistent with Water Sensitive Urban Design measures, where relevant e) Representative background monitoring of surface and groundwater quality parameters prior to the commencement of construction, to establish baseline water conditions, unless otherwise agreed by the Secretary f) A minimum monitoring period of one year following the completion of construction. If impacts are identified after one year of monitoring, continue monitoring for a further two years or until the affected waterways and/ or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales) g) Contingency and ameliorative measures in the event that adverse impacts to water quality are identified, including trigger values for action and associated actions or mitigation measures if trigger values are exceeded h) Reporting of the monitoring results to the Secretary, EPA, DPI and WaterNSW i) The Plan and Program shall be submitted to the Secretary for approval prior to the commencement of construction of the SSI, or as otherwise agreed by the Secretary. A copy of the Plan and Program shall be submitted to the EPA, DPI (Fishing and Aquaculture), WaterNSW and councils prior to its implementation. Community information, consultation and involvement Not applicable Completed during Construction (see CEMP) Not applicable Completed during Construction (see CEMP) SMC Not applicable Completed during Construction (see CEMP) Not applicable Completed during Construction (see CEMP) SMC/O&M Contractor SMC SMC SMC Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 20 of 59

22 MCoA Details Responsibility Reference Prior to the commencement of construction, or as otherwise agreed by the Secretary, the Proponent shall ensure that the following are available for community enquiries and complaints for the duration of construction: a) A 24 hour telephone number(s) on which complaints and enquiries about the SSI may be registered b) A postal address to which written complaints and enquires may be sent c) An address to which electronic complaints and enquiries may be transmitted d) A mediation system to assist in considering complaints that are unable to be resolved through initial contact. SMC Section The telephone number, the postal address and the address shall be published in newspaper(s) circulating in the local area prior to the commencement of construction and prior to the commencement of operation. This information shall also be provided on the website (or dedicated pages) required by this approval Mitigation and management commitments Table 4.2 summarises the mitigation commitments included in the EIS and submissions report that relate to the asset s operation. Table 4.2: Operational environmental mitigation and management measure commitments Mitigation and management measure Responsibility and OEMP reference TT-9 (associated with MCoA E6): undertake an operational traffic review to confirm the operational traffic impacts of the project on surrounding arterial roads and major intersections/ interchanges. Associated with MCoA E6. OEMPSP2 SWW-3: implement measures to minimise the risk of operational erosion and sedimentation, including monitoring the establishment of landscaping and vegetation cover, and introduce additional remedial planting where the landscaping and vegetation cover has not established. OEMPSP4 GHG-7: assess opportunities to use renewable energy sources to power control systems, lighting and signage. O&M Contractor s EMP Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 21 of 59

23 4.1.3 Legislation The following legislation is relevant to the OEMP and its implementation. Table 4.3: Relevant key environmental legislation Legislation General Relevance Environment Planning and Assessment Act 1979 Planning and development control Local Government Act 1993 Pollution control, protection of Aboriginal heritage, and watercourse management Protection of the Environment Operations Act 1997 Pollution and waste management Work Health and Safety Act 2011 Worker safety Noise and vibration Protection of the Environment Operations Act 1997 Protection of the Environment (Noise Control) Regulation 2008 (as amended) Noise and vibration management Traffic and transport Roads Act 1993 Traffic management and working on public roads Surface water quality and hydrology Soil Conservation Act 1938 Erosion and sediment control Contaminated Land Management Act 1997 National Environmental Protection (Assessment of Site Contamination) Measure 1999 Water Management Act 2000 Water Management Amendment Act 2014 Contaminated land management Stockpile management Spill management Watercourse protection Water access and use Water use approval Water management work approval Activity approval (other than aquifer interference) Sydney Water Act 1994 Requirement to obtain consent to discharge waste water to a sewer Pesticide Act 1999 Safe use and application of pesticides Public notification requirements before applying pesticides Road and Rail (Transport) Dangerous Goods Act 1997 Safe and licenced transportation of dangerous goods Other environmental aspects Biodiversity Noxious Weed Act 1993 Fisheries Management Act 1994 Threatened Species Conservation Act 1995 Weed management and control Safe fish passage Protection of threatened (fish) species, populations and communities Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 22 of 59

24 Legislation Relevance Aboriginal heritage National Parks and Wildlife Act 1974 Aboriginal heritage protection Management of unexpected finds Non-Aboriginal heritage Heritage Act 1977 Non-Aboriginal heritage protection Management of unexpected finds Air quality Protection of the Environment Operations Act 1997 Protection of the Environment (Clean Air) Regulation 2002 (as amended) Pollution management Prohibition of burning Greenhouse gas National Greenhouse and Energy Reporting Act 2007 Minimisation of greenhouse gas generation Waste and resource management Protection of the Environment Operations (Waste) Regulation 2005 Protection of the Environment Operations Act 1997 Waste classification, management, storage, transportation, and disposal Waste hierarchy: reduction, in preference to reuse and recycling Littering Reduction of resource consumption Minimisation of transport impacts Permits, licences and approvals The asset does not routinely operate under any additional permits, licences and/or approvals. However, certain permissions and licences may be needed for maintenance activities as described in Table 4.6. The need for any permission or licence would need determining by the O&M Manager (refer to Table 4.6) on a case-by-case basis depending on the nature of the proposed work. Table 4.4: Permits and licences Requirement/potential Licences Section 138: NSW Roads Act 1993: road occupancy Required when operation or maintenance activities require the occupation of the road carriageway. Section 220ZW: NSW Fisheries Management Act 1994: harm to threatened species, population or ecological community or damage habitat. As a result of undertaking bridge inspection and repair work over A becketts Creek, Duck River and Haslams Creek which may affect fish populations. Section 91: NSW Threatened Species Conservation Act licence to harm or pick threatened species, populations or ecological communities As a result of undertaking vegetation management work within the road margins. Requirement to confirm licence requirement before starting such work. Section 28: NSW Environmentally Hazardous Chemicals Act 1985: licence to carry on any prescribed activity with respect to an environmentally hazardous chemical or a declared chemical waste from NSW EPA. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 23 of 59

25 Requirement/potential As a result of undertaking ground excavation or maintenance work in a location with known contaminants and the risk of encountering asbestos containing materials. Permits Section 199: NSW Fisheries Management Act permission to undertake dredging or reclamation work As any inspection, maintenance and repair work over A becketts Creek, Duck River and Haslams Creek would not involve dredging or reclamation work. Only required if these activities take place in the future. Clause 71: NSW Fisheries Management (General) Regulation permission to use explosives or electrical devices in waterways Any inspection, maintenance and repair work over A becketts Creek, Duck River and Haslams Creek which may affect fish populations would not require the use of explosives or electrical devices. Only required if these activities take place in the future. 4.2 Environmental policies, guidelines and principles The policies, guidelines and principles are also relevant to the OEMP and its implementation. Table 4.5: Environmental policies, guidelines and principles Legislation Relevance General G36 Environmental Protection (Roads and Maritime, 2016) EIA-PO5-01 Environmental Assessment Procedure for Routine and Minor Works (Roads and Maritime, 2015). Interim Community Consultation Requirements for Applicants (DEC, 2005) International Association for Public Participation: Spectrum of Public Participation (IAP2, 2007) Community Engagement Policy Statement (Roads and Maritime, 2012). Environmental protection Management of routine and minor work Community consultation Noise Interim Construction Noise Guidelines (DECC, 2009) Construction Noise and Vibration Guidelines (Roads and Maritime, 2016) Environmental Noise Management Manual (Roads and Maritime, 2001) Noise Mitigation Guidelines (Roads and Maritime, 2015) Road Noise Policy (RNP, Roads and Maritime, 2011). Industry Noise Policy (EPA, 2000) Australian Standard: AS 1055 Acoustics (Standards Australia, 2011) Maintenance and repair noise management Operational road traffic noise Operational equipment noise Description and measurement of environmental noise Traffic and transport Guide to Traffic Management (Austroads, 2014) Guide to Traffic Generating Developments (Roads and Traffic Authority, 2002, as amended) Traffic Control at Work Sites (Version 4, 2010, Roads and Maritime) Traffic management and working on public roads Landscape and visual Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 24 of 59

26 Legislation Australian Standard (AS) Control of the Obtrusive Effects of Outdoor Lighting (Australian Standards, 1997) Draft WestConnex Urban Design Framework (Roads and Maritime, 2013) RMS QA Specification M3 (under M321 Landscape Maintenance) Bridge Aesthetic Guidelines (Roads and Maritime, 2012) Noise Wall Design Guidelines (Roads and Maritime, 2012) The Guidelines for Landscape Character and Visual Impact Assessment (EIA-N04, Roads and Maritime, 2013) Landscape Guidelines (Roads and Maritime, 2012) Beyond the Pavement (Roads and Maritime, 2014) G36: Environmental Protection (Roads and Maritime, 2016) G40: Clearing and Grubbing (Roads and Maritime, 2016) Relevance Light spill Landscape, urban design and vegetation management Surface water quality and hydrology Best Practice Guidelines for Contaminated Water Retention and Treatment Systems (NSW Government, 1994) Code of Practice for Water Management: Roads and Development Management (Roads and Maritime, 1999) Guidelines for Treatment of Stormwater Runoff from the Road Infrastructure (AP- R232, Austroads, 2003) Technical Guideline: Temporary Stormwater Drainage for Road Construction (Roads and Maritime, 2011) Managing Urban Stormwater Soils and Construction: Volume 2D Main Road Construction (DECC, 2008) The Blue Book: Managing Urban Stormwater: Soils and Construction, Volume 1 (Landcom, 2004) Floodplain Risk Management Guideline: Practical Consideration of Climate Change (NSW DECC, 2007) Guidelines for Controlled Activities: Watercourse Crossings (NSW DEC, 2008) G38: Soil and Water Management (Roads and Maritime, 2016) Stockpile Site Management Guidelines (Roads and Maritime, 2008) Code of Practice for Water Management: Roads and Development Management (Roads and Maritime, 1999) Guidelines for Bunding and Spill Management (NSW EPA, 2011) Australian Standard AS 1940B:1993: The Storage and Handling of Flammables and Combustibles (Standards Australia, 1993) Australian Standard AS 4452B:1997: The Storage and Handling of Toxic Substances (Standards Australia, 1997) Storage and Handling Liquids: Environmental Protection: Participants Manual (NSW EPA, 2007) Guidelines for Construction Water Monitoring (Roads and Maritime, undated) AS/NZS :1998 Water Quality, Sampling, Guidelines on the Design of Sampling Programs, Sampling Techniques and the Preservation and Handling of Samples (Standards Australia, 1998) Australian and New Zealand Guidelines for Fresh and Marine Water Quality: Volume 1 The Guidelines ( the ANZECC guidelines, ANZECC, 2000) Guidelines for Construction Water Quality Monitoring (Roads and Maritime, 2003) The Blue Book: Managing Urban Stormwater (MUS): Soils and Construction, Volume 1 and Volume 2 (Landcom, 2004) Guidelines for Assessment and Management of Contaminated Groundwater (DEC, 2007) Storage and treatment of firefighting water Stormwater runoff management Working in flood plains and over/close to watercourses Soil and water management Water quality sampling Contaminated waters and leachate management Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 25 of 59

27 Legislation Environmental Direction: Management of Tannins from Vegetation Mulch (Roads and Maritime, 2012) Guideline for the Management of Contaminated Land (Roads and Maritime, 2013) Incident classification and reporting procedure (Road and Maritime, 2013) Relevance Other environmental aspects Biodiversity Biodiversity Guidelines Protecting and Managing Biodiversity (Roads and Maritime, 2011) Environmental Impact Assessment Practice Note: Biodiversity Assessment (EIA-N06, Roads and Maritime, 2016) Discussion Paper- Compensating for Edge Effect (Roads and Maritime, 2000 and 2005) Matters of National Environmental Significance: Significant Impact Guidelines 1.1 Environment Protection and Biodiversity Conservation Act 1999 (DEWHA, 2009) Threatened Biodiversity Survey and Assessment: Guidelines for developments and activities (working draft, NSW DEC, 2004) G40: Clearing and Grubbing (Roads and Maritime, 2016) Why do Fish Need to Cross the Road? Fish Passage Requirements for Waterway Crossings (NSW DPI - Fisheries, 2005) Threatened species management Safe fish passage Soils and geology Stockpile Site Management Guidelines (Roads and Maritime, 2008) Waste Classification Guidelines Part 4: Acid Sulfate Soils (NSW EPA. 2014) G38: Soil and Water Management: Soil and Water Management Plan (Roads and Maritime, 2016) Acid Sulfate Soils Assessment Guidelines (Acid Sulfate Soil Management Advisory Committee, 1998) Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee, 1998) Guidelines for the Management of Acid Sulphate materials: Acid Sulphate Soils, Acid Sulphate Rock and Monosulphidic Black Ooze (Roads and Maritime, 2005) Waste Classification Guidelines Part 4: Acid Sulfate Soils (EPA. 2014) Soil and water management Acid sulphate soils Aboriginal heritage Guide to Investigating, Assessing and Reporting on Aboriginal Cultural Heritage in NSW (NSW OEH, 2011) Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW, 2010 (NSW OEH, 2010) Code of Practice for Archaeological Investigation of Aboriginal Objects in NSW (NSW DECCW, 2010) Procedure for Aboriginal Heritage Consultation and Investigation (PACHCI, Roads and Maritime, 2011) Standard Management Procedure, Unexpected Archaeological Finds (Roads and Maritime, 2012) Investigating and managing Aboriginal heritage Management of unexpected finds Non-Aboriginal heritage NSW Heritage Manual (Heritage Office and Department of Urban Affairs and Planning, 1996) Investigating and managing non- Aboriginal heritage Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 26 of 59

28 Legislation Assessing Heritage Significance (Heritage Office, 2001) Statements of Heritage Impact (Heritage Office and Department of Urban Affairs and Planning, 2002) How to Prepare Archival Records of Heritage Items, (Heritage Office, 1998) Standard Management Procedure, Unexpected Archaeological Finds (Roads and Maritime, 2012) Relevance Management of unexpected finds Socioeconomics Environmental Impact Assessment Practice Note: Socioeconomic assessment (EIA- N05, Roads and Maritime, 2014)) Managing socioeconomic impacts Air quality Air Quality Management Guideline (9TP-SD-107/2, Transport for NSW, 2016) Guidelines for Controlling Dust from Construction Sites (NSW EPA, 2003) Dust management Greenhouse gas The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, revised edition (World Council for Sustainable Business Development and World Resources Institute, 2004) Greenhouse Gas Assessment Workbook for Road Projects (Transport Authorities Greenhouse Group 2011, TAGG Workbook) National Greenhouse Accounts Factors (DCCEE, 2014) Minimisation of greenhouse gas generation Climate change Australian Standard AS/NZS AS 5334: 2013 Climate Change Adaptation for Settlements and Infrastructure (Standards Australia, 2013) Climate Change Impacts and Risk Management: A Guide for Business and Government (Department of the Environment and Heritage, Australian Greenhouse Office, 2006) Roads and Maritime Climate Change Plan (Roads and Maritime, undated). Climate change adaptation Waste and resource management Environmental Compliance Report: Liquid Chemical Storage, Handling and Spill Management - Part B Review of Best Practice and Regulation (NSW DEC, 2005) Storing and Handling Liquids, Environmental Protection: Participants Manual (NSW DECC, 2007) Excavated Natural Material Exemption 2014 (NSW EPA, 2014) Excavated Public Road Material Exemption 2014 (NSW EPA, 2014) Raw Mulch Exemption 2014 (NSW EPA, 2014) Reclaimed Asphalt Pavement Exemption 2014 (NSW EPA, 2014) Stormwater Exemption 2014 (NSW EPA, 2014) Waste Classification Guidelines (NSW EPA, 2014) Management of Wastes on Roads and Maritime Land (Roads and Maritime, 2014) Fact Sheet 1: Virgin Excavated Natural Material (Roads and Maritime, 2015) Fact Sheet 2: Excavated Natural Material (Roads and Maritime, 2015) Fact Sheet 3: Excavated Public Road Materials (Roads and Maritime, 2015) Fact Sheet 4: Reclaimed Asphalt Pavements (Roads and Maritime, 2015) Fact Sheet 5: Asbestos Waste (Roads and Maritime, 2015) Fact Sheet 6: Waste Sampling (Roads and Maritime, 2015). Materials handling and storage, and waste management Roads and Maritime waste factsheets Waste Avoidance and Resource Recovery Strategy (NSW EPA, 2014) Waste hierarchy Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 27 of 59

29 Legislation Sustainability Policy: Waste Reduction and Purchasing Policy (WRAPP, NSW OEH, 2011) Waste Reduction and Purchasing Plan (Roads and Maritime, 2010 Relevance Reduction of resource consumption The Environmental Impact Statement (EIS) and Urban Design and Landscape Plan (UD&LP) are available at the link below: Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 28 of 59

30 5 Implementation This section describes how the OEMP will be implemented. 5.1 Roles and responsibilities This section describes the key environmental management roles and responsibilities that will operate for the asset s lifetime. Figure 5.1 shows the organisational structure. SMC O&M Contractor Project Director Stage 1 Community Engagement Manager O&M Manager Environmental Manager O&M Manager O&M Contract Manager Maintenance Manager QSE Manager Maintenance Manager Operations Manager Community & Stakeholder Manager Indirect Reporting line Reporting lines Lines of communciation Figure 5.1 : OEMP management structure Responsibilities Table 5.1 lists the main environmental responsibilities of each of the above principal roles. For reference: SMC stakeholders refers to everyone in the table; and personnel refers to everyone under the corresponding heading. Table 5.1: Management responsibilities Organisation Names and Responsibilities SMC Project Director Stage 1 SMC O&M manager SMC Project Director Stage 1 Terry Chapman Ensure environmental impacts obligations met Ensure prescribed environmental outcomes are achieved Ensure legal and regulatory compliance Ensure implementation of the OEMP across the asset Ensure environmental requirements are fully integrated across all asset activities Endorse and support SMCs environmental policy included in this OEMP Liaise with Roads and Maritime and other Government agencies Ensure complaints are investigated and resolved Direct work to stop immediately if there is likely to be an unacceptable environmental impact. SMC O&M Manager Gunhan Guven Provide adequate resources (personnel, financial and technological) to ensure effective development, implementation and maintenance of this OEMP Participate and provide guidance in the regular review of this OEMP Ensure the requirements of this OEMP are fully implemented Ensure O&M Contractor manage their work in accordance with statutory approvals Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 29 of 59

31 Organisation SMC environmental manager SMC Community Engagement Manager Names and Responsibilities Direct work to stop immediately if there is likely to be an unacceptable environmental impact Oversee the implementation of environmental monitoring activities Obtain/maintain environmental approvals/licences Ensure all O&M stakeholders are familiar with the OEMP and that activities are planned and conducted such that they comply with environmental requirements, legislation and contractual obligations Establish and communicate environmental requirements for the planning, selection and management of subcontractors Monitor and audit against contractual requirements Periodically review the OEMP to assess its effectiveness and practicality Collate, review and report on maintenance and monitoring outcomes SMC Environmental Manager David Kelly Maintain and update the OEMP content and its execution Ensure s compliance with the MCoA and O&M deed across all operational aspects Ensure statutory, legal and regulatory compliance across all aspects of the asset s operation and maintenance Undertake site inspections and audits, internal environmental management system audits and provide performance feedback across all aspects of the Asset s operation and maintenance Ensure the requirements of the OEMP are implemented and fulfilled across the Asset Ensure the assessment, management, monitoring and reporting requirements of the OEMP are implemented across the asset Develop, implement, monitor and update the OEMP Provide reporting feedback to the SMC Project Director on the OEMP s performance and implementation Audit the s performance and compliance against their obligations under the O&M deed, MCoA, mitigation measures and other controls. Ensure management reviews of the OEMP and OEMPSPs are undertaken annually, documented and actions implemented Ensure environmental risks are identified and appropriate mitigation is implemented and effective across the Asset Identify where environmental measures are not meeting the objectives and targets and where improvement can be achieved across the asset Manage SMC environmental reporting Oversee O&M Contractor Development of asset inductions, toolbox talks and other training programs regarding environmental requirements for all site personnel across the asset Notify the SMC Project Director and relevant authorities in the event of an environmental incident with regards to affairs directly relating to the O&M stakeholders Direct work to stop immediately if there is likely to be an unacceptable environmental impact Prevent environmental non-conformities with regards to affairs directly relating to O&M stakeholders Assist the SMC Community Engagement Manager to resolve environment-related complaints with regards to affairs directly relating to the asset Ensure all O&M stakeholders are familiar with the OEMP and that activities are planned and conducted such that they comply with environmental requirements, legislation and contractual obligations. SMC Community Engagement Manager- Michael Johnson Lead community and agency engagement Prepare community and agency responses to queries and questions Respond to community complaints Support the SMC environmental manager in updating the OEMP to account for any community and agency feedback, compliments or complaints. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 30 of 59

32 Organisation SMC O&M Contract Manager SMC Maintenance Manager Names and Responsibilities SMC O&M Contract Manager Ian Anderson Direct work to stop immediately if there is likely to be a health and safety issue Ensure that all O&M stakeholders are trained and inducted Communicate with all O&M stakeholders regarding compliance with the OEMP and assetspecific environmental issues Immediately report any activity to the SMC environmental manager that has resulted, or has the potential to result, in an environmental incident Coordinate action in emergency situations and allocate required resources Close-out actions as a result of workplace inspections Supervise and audit and other O&M stakeholders in accordance with their responsibilities under this OEMP Coordinate environmental awareness training where required for all O&M stakeholders. SMC Maintenance Manager Peter Walters Direct work to stop immediately if there is likely to be an unacceptable environmental impact Ensure environmental requirements are fully integrated with asset activities Plan work activities to avoid or minimises the risk of environmental impacts Ensure the requirements of this OEMP are fully implemented Monitor and audit O&M stakeholder performance against contractual requirements Participate and provide guidance in the regular review of this OEMP. Specialist advisers to SMC - To be employed Independent accredited auditor Undertake the required independent audit one year into operation (MCoA A12, refer to section 9.4.1) Report findings to DP&E Recommend corrective actions and reinforce positive behaviours Close-out observations and non-conformances. personnel O&M manager O&M operations manager O&M Manager Aedan Hewitt Ensure all O&M activities comply with relevant regulatory, Roads and Maritime and SMC requirements Ensure the requirements of the OEMP are fully implemented, and in particular, that environmental requirements are not secondary to other O&M requirements Implement the s environmental policy Liaise with SMC and other Government authorities as required Provide adequate resources (personnel, financial and technological) to ensure effective development, implementation and maintenance of the s EMP Ensure that all maintenance personnel receive appropriate induction training, including details of the environmental and community requirements Ensure that complaints are investigated and issues raised resolved in accordance with the community engagement strategy (which is termed the community relations plan, CRP) Direct work to stop immediately if there is likely to be an unacceptable environmental impact Report back to the SMC Project Director Confirm the need for any specific permissions and licences before work starts. Operations Manager Shane Couch Plan operations and incident response services to avoids or minimises environmental impacts Ensure the requirements of the OEMP are fully implemented Ensure personnel manage operations in accordance with statutory approval requirements Ensure environmental management procedures and protection measures are implemented Ensure all personnel attend an induction before starting work Liaise with SMC and other Government authorities as required Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 31 of 59

33 Organisation O&M maintenance Manager O&M QSE manager O&M QSE training coordinator O&M operations team Names and Responsibilities Direct work to stop immediately if there is likely to be an unacceptable environmental impact Report, as required to the SMC O&M manager and SMC operations and safety manager Maintenance Manager To be employed Plan maintenance services in a manner that avoids or minimises impact to environment Ensure the requirements of this OEMP are fully implemented Ensure personnel manage maintenance works in accordance with statutory and approval requirements Ensure environmental management procedures and protection measures are implemented Ensure all personnel attend an induction prior to commencing works Liaise with SMC and other government authorities as required Direct work to stop immediately if there is likely to be an unacceptable environmental impact Report, as required to the SMC O&M manager and SMC asset manager. QSE Manager To be employed Manage environmental aspects of the O&M services Report to O&M manager and SMC on the performance and implementation of the s EMP and other environmental documentation Ensure environmental risks are identified and appropriate mitigation is implemented Identify where environmental measures are not meeting the set targets and where improvement can be achieved Ensure environmental protocol are in place and managed Ensure environmental compliance Liaise with SMC and approval authorities Direct work to stop immediately if there is likely to be an unacceptable environmental impact or to prevent an environmental non-conformance and advise the O&M manager, O&M operations manager and O&M maintenance manager Assist the SMC Community Engagement Manager resolve environment-related complaints Report to the SMC environment manager as required. QSE Training coordinator To be employed In conjunction with the O&M QSE manager and external providers, develop the environmental component of the site induction program In conjunction with the O&M QSE manager and external providers develop targeted environmental awareness training for individuals or groups of workers undertaking an activity with a high risk of environmental impact Conduct the environmental component of the site induction (as required) Conduct toolbox talks Recommend environmental training as required Ensure all personnel attend the induction program and scheduled training Maintain induction and training records. Operations Team To be employed O&M operations team will consist Five (5) Full time personal positions Implement activities in accordance with the OEMP Work under the requirements of the OEMP, SOPs, and ESWMSs Minimise the potential for environmental impacts Assist during unforeseen environmental incidents Feedback to the O&M operations manager and O&M QSE manager on the effectiveness and practicality of maintenance methods and environmental controls Immediately report any environmental impact or risks Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 32 of 59

34 Organisation O&M maintenance team Names and Responsibilities Maintenance Team To be employed O&M maintenance team will consist of six (6) full time personal positions Implement work in accordance with the OEMP and the s EMP Work under the requirements of the OEMP, SOPs and ESWMSs, and SOPs Proactively minimise the potential for environmental impacts Provide assistance during unforeseen environmental incidents Feedback to the O&M maintenance manager and O&M QSE manager on the effectiveness and practicality of maintenance methods and environmental controls Provide feedback to the s maintenance manager and the O&M QSE manager on the effectiveness and practicality of maintenance methods and environmental controls Immediately report any environmental impact or risk Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 33 of 59

35 6 Compliance, training and awareness This section describes the process to ensure this OEMP is effectively implemented by ensuring all O&M stakeholders are trained in undertaking their roles and responsibilities as discussed in section 5.1. It describes environmental: Induction requirements Toolbox talks Awareness training Emergency response training. The training requirements would be reviewed every three months. It will form part of staff performance reviews, compliance tracking, and ISO14001 audits. 6.1 Environmental induction The will implement a compulsory site induction that includes an environmental component for all O&M stakeholders attending the site. This will be done to ensure all O&M stakeholders are aware of the requirements of the OEMP and are familiar with implementing all associated management measures. Note: visitors will be required to be accompanied by inducted personnel at all times. The s QSE Manager will conduct the environmental component of the site inductions. This will include, but not be limited to, an overview of: Relevant details of the OEMP Key environmental issues Conditions of environmental licences, permits and approvals Specific environmental management requirements and responsibilities Mitigation measures for the control of environmental issues Incident response and reporting requirements, including near misses Spills, leaks, emissions, and contamination treatment Emergency response procedures, communications and equipment Localised health, safety and environment meetings Site and job-specific environmental impacts and aspects Environmental management system obligations Information relating to the location of environmental constraints. The SMC environmental manager will review and approve the induction program and monitor its implementation. 6.2 Toolbox talks Toolbox talks will be one method of raising awareness and educating O&M stakeholders on issues related to all operational aspects including environmental issues. The toolbox talks will be used to ensure environmental awareness continues throughout the asset s lifetime. They will also be tailored to specific issues relevant to upcoming work such as: Environmental hazards and risks SOPs, ESWMSs and incident response procedures (IRPs) Legislation changes Inspection findings Audit results Incident or near-miss investigations personnel and community suggestions for improvements Community feedback and actions. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 34 of 59

36 6.3 Environmental awareness training Targeted environmental awareness training will be provided to O&M stakeholders with a specific authority or responsibility for environmental management or those undertaking an activity with a high risk of environmental impact. Awareness notes will also be developed and distributed to inform personnel. These will typically take the form of a poster, booklet, or similar and will be distributed to those responsible for managing specific work locations or activities. Training will include: ISO awareness, obligations and requirements SMC and environmental policies, procedures, standards and guidelines SOPs and ESWMSs Auditing (including spot and formal auditing) and workplace inspections Incident reporting and investigation Continuous improvement policies Environment protection and sustainability Spill, leaks, emissions and contamination management The waste hierarchy. Awareness training will be delivered through: Distance and online training in the form of memoranda and instructions Training sessions prepared and delivered by the s QSE Manager The SMC environmental manager will review and approve the environmental training program and monitor its implementation. 6.4 Emergency response training All personnel involved in the O&M activities are required to participate in an incident and/or emergency response will be trained under a program that focuses on implementing effective environmental management controls. The training will cover: Stop work procedures and follow-on actions Oil, fuel, chemical spill response Containment Clean up Waste management including removal, classification, storage, transport and disposal Liaison with the Fire Brigade, NSW EPA and other emergency response services Environmental management controls (e.g. the water quality basins). The, as operator of the MCC, will be suitably trained in emergency response procedures. This will ensure the correct and most-appropriate response is initiated, and that incidents are reported to the correct authority as required. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 35 of 59

37 7 Communication This section covers the requirements to implement internal and external communication procedures in operating, maintaining and repairing the asset. It covers: Internal communications External and Government consultation Stakeholder and community communication. 7.1 Internal communication Table 7.1 provides a list of the internal communication methods that will be used across the operational asset. Table 7.1: Internal communication Method Description Responsibility Frequency Management operational meetings Meeting to discuss all operational issues SMC asset manager Monthly Management review meetings Review OEMP and supporting documents SMC environmental Manager At least annually Training and awareness sessions Improve awareness of all employees SMC environmental Manager At least quarterly Issues, updates and schedules SMC environmental manager As required Intranet Corporate information SMC O&M manager SMC environmental manager Ready access Quarterly environmental forums Forum discussion, information and new initiatives development SMC environmental manager Quarterly 7.2 External and Government consultation The SMC environmental manager will be the main point of contact regarding specific environmental issues. They would report ongoing environmental performance to SMC, the NSW EPA and other Government agencies. Relevant Government agencies will be consulted routinely or following an incident and/or emergency. Routine meetings will be used to discuss environmental performance, upcoming work, and high-risk activities. The meetings will include inspections of the asset as needed. Section 1.4 describes the agencies consulted on this OEMP and its preparation, and Appendix B outlines the feedback received to date. Consultation with these agencies will be maintained throughout the asset s operational life. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 36 of 59

38 7.3 Community information and reporting Community engagement strategy SMC has developed a community engagement strategy to provide an approach to stakeholder and community engagement: The community engagement strategy identifies opportunities for providing information and consulting with the community and stakeholders throughout the asset s life. The plan defines: Engagement groups Key messages Tools that will be used to interact with community and stakeholders. Communication tools defined in the strategy include: Advertisements Doorknocking Letterbox drops Signage Website updates Meetings 24-hour contact telephone number and address Advertising routine operations and maintenance activities Expected traffic delays and restrictions due to planned major operation and maintenance work will be publicly advertised through various media streams. The consultation is to describe: The nature of the work Areas where the work is proposed Hours of working Contact information Changes to traffic and transport arrangements How to register complaints Details of how to obtain further information. The must comply with the format of all written information and standard formats provided by the SMC Community Engagement Manager where appropriate. Motorists will be informed of upcoming work and disruptions through: Variable message signs (VMS) WestConnex website Livetraffic.com Advertisements in newspapers and online Radio advertisements Media protocol All personnel will adhere to the following media communication protocol: Media enquiries will be directed to the SMC Project Director and SMC Community Engagement Manager No O&M stakeholders will be authorised to make a public statement without consulting with the SMC Community Engagement Manager Enquires made to SMC or the will be directed to the SMC Project Director and SMC Community Engagement Manager Media will not be permitted onsite without SMC approval All personnel will be made aware of this the media protocol in their induction training Contact information Table 7.2 lists the relevant contact information for community enquiries. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 37 of 59

39 Table 7.2: Community contact information Method Information 24 hour telephone number A permanent 24-hour contact number ( ) will be maintained, publicised and advertised on the WestConnex website, mail outs and in all publications. Postal address Locked Bag 3905 GPO Sydney NSW address Website info@westconnex.com.au SMC manages the asset website ( The website will be routinely and regularly updated to include: The latest OEMP and OEMPSPs Tolling queries Scheduled operations and maintenance activities Complaints handling details Contact details Traffic management and patronage Other relevant community information Complaints and enquires procedure A complaints management system, consistent with Australian Standard: AS 4269: Complaints Handling (Standards Australia, 1995) has been developed by SMC for the asset. The work under this system. Information on all complaints received, including the means by which they were addressed, whether resolution was reached, and whether mediation was required, will be included in a complaints register. The information contained on the register will be made available to DP&E on request. Attempts will be made to resolve all complaints in accordance with the CRP. An initial response to complaints will be provided within 24 hours of a complaint being received A further detailed response, including steps taken to resolve the issue(s) that lead to the complaint, will be provided within 10 days. All complaints should be closed off in the complaints register. Stakeholder will also be kept informed of when they will receive a response. The SMC environmental manager and SMC Community Engagement Manager will apply an adaptive approach to ensure that corrective actions are applied in consultation with the appropriate O&M stakeholders to allow modifications and improvements in the management of any environmental issues resulting in community complaints Directing and stopping work All management roles in the Organisation charts provided have the ability to stop works. The SMC and the O&M Contractor roles are the key contacts with full authority over the works. The direct contact role that will be available 24 hours a day, 7 days a week who has the authority to stop or direct works is the O&M Contractor Operation Manager. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 38 of 59

40 8 Risks, incidents and emergencies This section covers the processes used to identify, monitor and manage risks, incidents and emergencies. 8.1 Environmental risk analysis Appendix C analyses the typical inherent environmental risks associated with the asset s operational key environmental performance issues. The environmental risk analysis adopts the methods included in Australian Standard AS ISO 31000: 2009 Risk Management, Principles and Guidelines (Standards Australia, 2009). It includes: Routine operational risks Non-routine operational risks. The analysis then describes the measures that serve to manage these risks and consequently the residual outcome. The OEMP and supporting OEMPSPs serve to introduce risk mitigation controls to reduce: Likelihood, such as training and awareness, as well the assignment of roles and responsibilities Magnitude, such as water quality detention basin maintenance. The risk assessment would be reviewed and updated once every three months. It would also be reviewed ahead of undertaking and non-routine operational maintenance and repair activities Continual improvement Due to the complexity of asset management and maintenance, Appendix C does not include all feasible and reasonable risks. Also, until the asset is operational it is not possible to identify or qualify all risks. As such, the environmental risk analysis process is dynamic and iterative. The environmental risk analysis will be reviewed, and upgraded if required following an incident, emergency, change in legislation, operating and maintenance procedures/activities, audit findings, non-compliance, continual improvement measures or otherwise annually. New, atypical, non-routine or major environmental risks will be included and assessed under environmental risk analysis. They will be included proactively and not reactively to ensure hazards are identified, controlled, and ideally, eliminated before they occur. Where additional key environmental impacts are identified through this process, an appropriately detailed assessment of key environmental impact will be undertaken. The SMC environmental manager will be responsible for maintaining and reviewing the environmental risk analysis process, within input from the. The SMC environmental manager will also be responsible for its update to respond to the above outcomes. Risks and residual risks will be reviewed, regraded and/or rerated to reflect changing operational and maintenance processes Risk identification O&M stakeholders will identify environmental risks through: Site audits Reporting checks and audits On-the-job observations Site meetings Toolbox talks. O&M stakeholders will be trained in their responsibility to report any breaches of the MCoAs and OEMP that present an environmental risk. Any breach shall be directed to the relevant Government agency in accordance with the OEMP and OEMPSPs as led by the SMC environmental manager. Subsequent, investigations, audit findings, learnings, corrective actions, and continuous improvement measures will be fed back into the risk analysis. 8.2 Incident and emergency management SMC operates under an incident management procedure that will apply to the operational asset. Appendix D includes this procedure that captures the elements of the emergency awareness and response training described in section 6.3 and section 6.4. The must include elements of this plan into its EMP. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 39 of 59

41 9 Managing and monitoring performance This section addresses ongoing monitoring and inspection audit requirements, reporting obligations, nonconformance reporting, subcontractor requirement, and operational audits of the OEMP. SMC will remain responsible for managing and monitoring performance, with the undertaking the relevant inspections and feeding back to SMC. The section covers environmental: Monitoring, inspections and test plans Subcontractor environmental management Operational audits Compliance tracking DP&E reporting Non-conformance reporting and notification. 9.1 Environmental monitoring and inspections Environmental monitoring will be completed annually or more regularly if there is a significant change in operations, maintenance, personnel, organisation structure, reporting lines, or legislation. SMC Asset Manager will be responsible to monitor environmental management activities and controls and also implement measurements of its effectiveness. The environmental management monitoring and control activities checklist was developed for the operation phase. The environmental monitoring checklist and sign-off to verify that the control actions were undertaken and are working effectively is presented in Appendix E. Monitoring will be undertaken to validate and confirm the operational impact. This monitoring will extend to the effectiveness of the installed environmental mitigation controls, such as the water quality basins. Table 9.1 summarises the infrastructure monitoring that will take place on the operational asset. Table 9.1: Environmental monitoring and inspections Inspections, compliance and evaluation Inspections, compliance and evaluation Owner: inspections, compliance and evaluation Stormwater system, drains and water quality basins Bi-annually: inspection SMC asset manager Noise wall integrity Water management, storage, handling, disposal and tracking Maintenance work and performance Incident and emergency clean-up and control Preservation of environmentally sensitive areas including watercourses and riparian habitat Successful establishment and consequential maintenance of site vegetation Erosion and sediment control (including scour protection) Annually: inspection Monthly: inspection For all major activities and non-routine activities: inspection Upon incident notification: Inspection Quarterly: inspection Quarterly: inspection Quarterly: inspection SMC operations and safety manager SMC environmental manager SMC operations and safety manager SMC environmental manager Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 40 of 59

42 Inspections, compliance and evaluation Weed suppression and management Pathogen suppression and management Surface water quality of A becketts Creek, Duck River and Haslams Creek and wider groundwater monitoring Inspections, compliance and evaluation Quarterly: inspection Monthly: inspection Quarterly: inspection Owner: inspections, compliance and evaluation Energy consumption reduction and performance Quarterly: inspection SMC operations and Safety manager 9.2 Subcontractor environmental management Subcontractors performing high-risk environmental activities will be required to work under this OEMP and OEMPSPs. The O&M Contractor is required to provide their own EMP relating to the activities they are contracted to perform. 9.3 Operational performance monitoring Table 9.2 describes the monitoring that needs to take place Table 9.2: Operational performance monitoring Monitoring Operational noise compliance report: MCoA E5: Water quality plan and monitoring program MCoA B7 Landscaping maintenance program MCoA B26(i) Implementation Within 12 months of operation including consultation with NSW EPA and DP&E. To support this, the will provide SMC with: Monthly noise monitoring results Recorded average daily traffic volumes on the widened M4 Motorway Details of any received operational noise complaints and enquiries. Within 12 months of operation. The water quality plan and monitoring program (WQPMP) prepared for the design and construction of the M4 Widening Major Civil Works was approved by DP&E on 27 April It describes how the requirements of MCoA B7 were met during construction and identifies the frequency for the compliance reporting and independent auditing. SMC will continue the monitoring for at least one year following the completion of construction. If impacts are identified after one year of monitoring, monitoring will continue for a further two years or until the affected waterways and/or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring will also confirm the establishment of operational water control measures, such as vegetation swales. The previously approved construction WQPMP has been amended to focus on surface and ground water quality during the asset s operation. SMC will continue to consult with NSW EPA, DPI (Fishing and Aquaculture and Water), WaterNSW, and Sydney Olympic Park Authority, and relevant Councils on the implementation of the WAQPMP. SMC will provide the collected data and interpretative report to DPI Water (if required). Within 12 months of operation: SMC will carry on with the landscaping maintenance procedures and will comply with the landscaping maintenance program detailed in the RMS Specification: M3 Routine Services and all maintenance intervention requirements specified in RMS QA Specification M3 (under M321 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 41 of 59

43 Monitoring Implementation Landscape Maintenance). and current best industry practice. 9.4 Operational audits SMC will undertake bi-annual internal audits and commission an annual independent operational audit of the asset. The following sections provide information regarding the audit scope, methods and responsibilities for conducting the audit and reporting results. The purpose of the operational phase audit process is to review and ensure that all the control mechanisms are overseen and (as needed) corrective actions and lessons learnt are in place. The internal audit will be undertaken by an independent person(s) engaged to audit the asset. The scope of the audit will include the operations, and the effectiveness of this OEMP and its management sub plans. The independent audit(s) are to be undertaken and a copy of the audit be provided to the Secretary and relevant public authorities in accordance with MCoA E Independent environmental audit An independent environmental audit will be undertaken 18 months after the asset is operational. The audit scope will include: agency and council consultation performance compliance with the MCoA and other relevant approvals an accuracy review of the predicted outcomes of the documents listed under MCoA A2 an accuracy review of any approved strategy, plan or program required under the abovementioned approvals recommendation to any corrective actions or improvements The report will be provided to DP&E within 90 days of it being undertaken Non-compliances The independent audit may produce non-conformances with the OEMP or work practices. Environmental non-conformances are defined as: Any potential or actual non-compliance with the MCoA that specifically relate to environmental performance. Any other error, misadventure or incident resulting in actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, is costly (>$10 000), and/or is harmful to WCX M4 reputation. The SMC asset manager is to be responsible for approving all corrective and remedial actions and the closing out of non-conformance items Corrective actions The independent audit findings, corrective actions and updates will be reported to the Secretary within three months of each audit, or as otherwise agreed by the Secretary. The audit findings report will be submitted to the Secretary and relevant public authorities, together with its response to any recommendations contained in the audit report Other non-compliances and non-conformances Following a review of the incident and compliance tracking register, corrective action is to be identified and determined by the asset manager for an identified non-conformance. This is to reflect the nature and scale of the matter and whether it presents a material risk to human health, the environment or risk damaging property. Corrective actions are to be preventative-based and summarised as follows: Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 42 of 59

44 The asset manager notifies the SMC Manager and SMC Operation logistics team. The asset manager is to assign corrective actions and responsibility to a specific member of SMC Operation logistics team including timeframes, follow-up dates and close-out expectations. The action is closed out on the compliance tracking register following observation by the asset manager that the non-conformance and associated risk has been ideally removed, or is being appropriately managed to limit the potential for material harm as far as is reasonably feasible and practical. 9.5 Compliance tracking The CTP prepared to support design and construction was approved by DP&E on 11 May It described how the requirements of MCoA A12 will be met. It also identifies the frequency for the compliance reporting and independent auditing. SMC will use this CTP to during this asset s operation. The CTP contains: Provisions for: Notifying the DP&E before the asset is operational Periodic compliance reviews against the MCoA Periodic reporting to the DP&E including a pre-operation compliance report. All employees, contractors and sub-contractor to be aware and comply with the relevant MCoA relating to their respective roles and responsibilities Reviewing compliance and incident management An independent environmental auditing program Procedures for rectifying any non-compliance identified during environmental auditing. The CTP will operate for at least 18 months. It will independently reviewed and audited as described in section Reporting to DP&E Table 9.3 lists the reporting DP&E reporting requirements under this OEMP. Table 9.3: Reporting to DP&E Document OEMP Operational noise monitoring Water quality plan and monitoring program Compliance tracking program Independent environmental audit Water quality plan and monitoring program Operational Traffic Performance Review Timing One month before operation 12 months after operation starts 12 months after operation starts 18 months after operation starts 18 months after operation starts 3 years after operation if impacts are identified 5 years after operation starts* *Also reported to the local councils 9.7 Non-conformance reporting and notification Environmental incident reports will be used to record non-conformances. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 43 of 59

45 9.7.1 Corrective actions Corrective actions will be identified and determined by the relevant manager and will reflect the nature and scale of the incident and whether it presents a material risk to human health, the environment or property. Corrective actions will be preventative-based. They will be implemented, monitored, checked and reviewed. The corrective action process is summarised as: O&M stakeholders notifying the SMC environmental manager of the non-conformance The SMC environmental manger either preparing an environmental incident report and/or environmental improvement notice The SMC environmental manager assigning corrective actions and responsibility to a specific (or group) of O&M stakeholders including timeframes, follow-up dates, and close-out expectations Closing-out the action following monitoring, and follow-up observation that the non-conformance and associated risks have been ideally removed or are being appropriately managed to limit the potential for material harm as far as is reasonably feasible and reasonable. The SMC environmental manager will review all plans and notices every month for summary reporting so as to provide feedback to senior management. Corrective action statistics will be reviewed annually to set key performance indicators. The actions will also be entered into the compliance tracking program described in section 9.5. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 44 of 59

46 10 OEMP review and records management This section describes how, why and when the OEMP will be reviewed and updated. It covers: OEMP review Records management Document control OEMP review The OEMP and OEMPSPs will be checked, reviewed and updated annually or as required if there is a significant change in operations, maintenance, personnel, organisational structure, reporting lines, or legislation. The review will ensure that SMC s contractual obligations are being executed in accordance with the requirements of this OEMP and that identified issues and corrective actions are being appropriately managed and reported. The review will be conducted by the: SMC Project Director SMC O&M Manager SMC Environmental Manager SMC Community Engagement Manager SMC O&M Contract Manager SMC Maintenance Manager. As a minimum, the review will look at: Feedback, comments, actions and communications provided by Government agencies, regulators, and independent specialists Audit findings Environmental monitoring outcomes Incidents and non-conformances Environmental risks Community feedback, including trends and persistent issues Organisational structure change Role and responsibility changes Operations and maintenance responsibility changes Legislative and regulatory changes. Between reviews, the SMC environmental manager will have the delegated authority to change or modify the systems and processes of the OEMP by way of preparing addenda. The SMC environmental manager will also be responsible for recording any decisions including the reason for making the decision. Any changes to the OEMP will be communicated by the SMC environmental manager using either the monthly management operational meetings (refer to Table 7.1) for non-critical updates or through an release using the read-receipt function (refer to Table 7.1) for critical and essential updates Records management The SMC environmental manager will be responsible for all environmental records and information relating to this OEMP, including the resources and training needed to maintain: The OEMP and OEMPSPs Monitoring data, inspections and corrective actions Audit reports and corrective actions Environmental incident reports and notifications Internal and external communications Training and induction records Operations and maintenance activities Complaints Compliance tracking Subcontractor monitoring and performance Waste management records Greenhouse gas emissions Meeting minutes Monitoring environmental planning obligations Agency, regulatory, Governmental and Roads and Maritime correspondence. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 45 of 59

47 All environmental management documents will be subject to ongoing review, revision and continual improvement. This includes changes to scheduled activities and legislative and licencing requirements. Records will be held for 10 years. Roads and Maritime, the DP&E and key Government agencies will have access to all records upon request. Records will be managed in accordance with SMC s ISO: 9001 accredited quality management system Document control OEMP and OEMPSP preparation, distribution, and review will be led by the SMC environmental manager. During the asset s operation, the environmental documentation will be stored in the SMC integrated management system. O&M stakeholders will implement a document control procedure to manage the flow of information between all internal and external parties in line with the communication requirements in Chapter 7. This procedure will ensure that all documents are: Developed, reviewed and approved before being issued Issued for use Controlled and stored for 10 years, or the prevailing legal requirements at the time Removed when superseded or updated Achieved. A distribution list will identify the current version of each document, report and/or data. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 46 of 59

48 10 OEMP review and records management This section describes how, why and when the OEMP will be reviewed and updated. It covers: OEMP review Records management Document control OEMP review The OEMP and OEMPSPs will be checked, reviewed and updated annually or as required if there is a significant change in operations, maintenance, personnel, organisational structure, reporting lines, or legislation. The review will ensure that SMC s contractual obligations are being executed in accordance with the requirements of this OEMP and that identified issues and corrective actions are being appropriately managed and reported. The review will be conducted by the: SMC general manager SMC O&M manager SMC environmental manager SMC communications manager SMC operations and safety manager SMC asset manager. As a minimum, the review will look at: Feedback, comments, actions and communications provided by Government agencies, regulators, and independent specialists Audit findings Environmental monitoring outcomes Incidents and non-conformances Environmental risks Community feedback, including trends and persistent issues Organisational structure change Role and responsibility changes Operations and maintenance responsibility changes Legislative and regulatory changes. Between reviews, the SMC environmental manager will have the delegated authority to change or modify the systems and processes of the OEMP by way of preparing addenda. The SMC environmental manager will also be responsible for recording any decisions including the reason for making the decision. Any changes to the OEMP will be communicated by the SMC environmental manager using either the monthly management operational meetings (refer to Table 7.1) for non-critical updates or through an release using the read-receipt function (refer to Table 7.1) for critical and essential updates Records management The SMC environmental manager will be responsible for all environmental records and information relating to this OEMP, including the resources and training needed to maintain: The OEMP and OEMPSPs Monitoring data, inspections and corrective actions Audit reports and corrective actions Environmental incident reports and notifications Internal and external communications Training and induction records Operations and maintenance activities Complaints Compliance tracking Subcontractor monitoring and performance Waste management records Greenhouse gas emissions Meeting minutes Monitoring environmental planning obligations Agency, regulatory, Governmental and Roads and Maritime correspondence. Sydney Motorway Corporation M4 Widening Motorway: Operational Environmental Management Plan Page 47 of 62

49 All environmental management documents will be subject to ongoing review, revision and continual improvement. This includes changes to scheduled activities and legislative and licencing requirements. Records will be held for 10 years. Roads and Maritime, the DP&E and key Government agencies will have access to all records upon request. Records will be managed in accordance with SMC s ISO: 9001 accredited quality management system Document control OEMP and OEMPSP preparation, distribution, and review will be led by the SMC environmental manager. During the asset s operation, the environmental documentation will be stored in the SMC integrated management system. O&M stakeholders will implement a document control procedure to manage the flow of information between all internal and external parties in line with the communication requirements in Chapter 7. This procedure will ensure that all documents are: Developed, reviewed and approved before being issued Issued for use Controlled and stored for 10 years, or the prevailing legal requirements at the time Removed when superseded or updated Achieved. A distribution list will identify the current version of each document, report and/or data. Sydney Motorway Corporation M4 Widening Motorway: Operational Environmental Management Plan Page 48 of 62

50 Appendix A: SMC environmental and sustainability policy Sydney Motorway Corporation M4 Widening Motorway: Operational Environmental Management Plan Page 48 of 61

51 Environment Policy Sydney Motorway Corporation Pty Limited and its subsidiaries (SMC) are committed to undertaking our business activities in a safe and environmentally responsible manner while effectively managing any risks that may lead to an impact on the environment. Our benchmark is best practice, cost effective environmental performance as we deliver project outcomes. This policy applies to all people employed or engaged by SMC to provide services on a permanent, temporary or casual basis to or on behalf of SMC. Each SMC business area is required to comply with all environmental laws, regulations and standards and ensure that projects are delivered under the SMC environmental management system. Our commitments To deliver responsible environmental solutions, SMC is committed to: meeting our obligations under relevant legislation and environmental standards encouraging and delivering environmental best practice outcomes across all our projects environmental planning to ensure enhanced environmental outcomes for our projects and the community delivering ecologically sustainable development, in line with the SMC Sustainability Policy regularly monitoring our environmental performance to ensure continual improvement, including regular reports to the SMC Executive and SMC Board. Our objectives We are accountable We take personal and collective accountability for addressing and minimising the environmental impacts of our activities and deliver our projects to satisfy the expectations and legislative requirements of our shareholders, client and the NSW community. We provide solutions We actively oversee the management of environmental risks and encourage innovative solutions to ensure that all our activities are undertaken to minimise our environmental footprint and achieve environmental compliance. We plan and collaborate We deliver our projects by integrating environmental considerations into planning stages and working in collaboration with our industry partners and regulatory stakeholders to achieve enhanced environmental outcomes and encourage a culture of environmental responsibility. We listen and respond We communicate openly, responsively and empathetically with the community, our industry partners and our stakeholders on environmental matters. We improve We deliver continual improvement in environmental performance in all our activities. Dennis Cliche Chief Executive Officer Environment Policy April 2017 Page 1 of 2

52 Policy evaluation and review Overall responsibility for implementation and application of this policy lies with the Chief Executive Officer under delegation from the Board. The Principal Manager, Health and Safety has primary responsibility for the interpretation, application, ongoing management and monitoring of this policy and consults with the Environment Manager, Sustainability Manager and Project Directors as appropriate on practical and operational issues of policy implementation, monitoring and compliance. This policy will be evaluated and reviewed every two years by the Chief Executive Officer and Principal Manager, Health and Safety, in consultation with the Environment Manager, Sustainability Manager and Project Directors as appropriate, as part of the Audit & Risk Assurance Program. Related Documents This policy should be read in conjunction with the following related SMC policies: 1. Sustainability Policy 2. Communications and Stakeholder Management Policy 3. Quality Management Policy 4. Work Health and Safety Policy 5. Procurement Policy 6. Risk Management Policy 7. Business Continuity Management Policy 8. Code of Conduct Responsible Officer: Michael Polito Principal HSES Manager Contact Officer: Environment Manager Laurenne Coetzee Phone: (02) Effective date: 22 March 2017 Date of publication: 22 March 2017 Review Date: 22 March 2019 Environment Policy April 2017 Page 2 of 2

53 Sustainability Policy Sydney Motorway Corporation Pty Limited and its subsidiaries (SMC) are committed to embedding sustainable practices into our business activities. We are committed to conducting operations in a sustainable manner by balancing economic, environmental and social issues. This policy applies to all people employed or engaged by SMC to provide services on a permanent, temporary or casual basis to or on behalf of SMC. Our Commitments To deliver sustainable solutions, SMC is committed to: Creating lasting value Caring for our community, the environment and our people Being efficient We will achieve this by: Leadership and continual improvement Ensuring that all people employed or engaged by SMC to provide services are made aware that they have a shared responsibility to actively contribute towards the achievement of this policy Establishing sustainability objectives and targets and providing adequate resources Embedding sustainability requirements within planning, design, contracts and procurement criteria Together with our delivery partners taking joint responsibility for leading and integrating sustainability Continual improvement in: Monitoring and assessing performance against sustainability objectives and targets Implementing corrective actions where appropriate Publicly reporting on progress, sharing knowledge and building on lessons learnt Creating lasting value Providing safe and accessible motorways to connect communities Contributing to and enhancing the liveability of communities Ensuring balanced consideration and proactive management of the whole-of-life environmental, social and economic costs and benefits during decision-making (including those related to future proofing for climate change and long term growth) Encouraging innovation and setting high standards Caring for our community, the environment and our people Proactively minimising adverse environmental and social impacts, in line with the SMC Environment Policy Establishing positive relationships with the community through ongoing and open engagement Providing training, education, apprenticeships and employment opportunities Protecting and promoting the environment, cultural heritage, staff and community health and wellbeing Valuing diversity and providing equal employment opportunities, in line with the SMC Diversity Policy Develop and implement the SMC Reconciliation Action Plan, acknowledging that Reconciliation is a shared responsibility Ensuring SMC is a socially responsible employer, investing in its people and its communities Being efficient Using resources (energy, water, materials) efficiently, avoiding and reducing waste and pollution Reducing SMC s corporate operational footprint. Dennis Cliche Chief Executive Officer Sustainability Policy 26 May 2017 Page 1 of 2

54 Policy Evaluation and Review Overall responsibility for implementation and application of this policy lies with the Chief Executive Officer under delegation from the Board. The Principal Manager, Health and Safety has primary responsibility for the interpretation, application, ongoing management and monitoring of this policy and consults with the Sustainability Manager and Project Directors as appropriate on practical and operational issues of policy implementation, monitoring and compliance. This policy will be evaluated and reviewed every two years by the Chief Executive Officer and Principal Manager, Health and Safety, in consultation with the Sustainability Manager and Project Directors as appropriate, as part of the Audit & Risk Assurance Program. Related Documents This policy should be read in conjunction with the following related SMC policies: 1. Environment Policy 2. Diversity Policy 3. Quality Management Policy 4. Work Health and Safety Policy 5. Procurement Policy 6. Risk Management Policy 7. Business Continuity Management Policy 8. Code of Conduct Responsible Officer: Principal Manager, Health and Safety Michael Polito Phone: (02) Effective date: 16 May 2017 Date of publication: 26 May 2017 Review Date: 16 May 2019 Sustainability Policy 26 May 2017 Page 2 of 2

55 Sustainability Policy Sydney Motorway Corporation Pty Limited and its subsidiaries (SMC) are committed to embedding sustainable practices into our business activities. We are committed to conducting operations in a sustainable manner by balancing economic, environmental and social issues. This policy applies to all people employed or engaged by SMC to provide services on a permanent, temporary or casual basis to or on behalf of SMC. Our Commitments To deliver sustainable solutions, SMC is committed to: Creating lasting value Caring for our community, the environment and our people Being efficient We will achieve this by: Leadership and continual improvement Ensuring that all people employed or engaged by SMC to provide services are made aware that they have a shared responsibility to actively contribute towards the achievement of this policy Establishing sustainability objectives and targets and providing adequate resources Embedding sustainability requirements within planning, design, contracts and procurement criteria Together with our delivery partners taking joint responsibility for leading and integrating sustainability Continual improvement in: Monitoring and assessing performance against sustainability objectives and targets Implementing corrective actions where appropriate Publicly reporting on progress, sharing knowledge and building on lessons learnt Creating lasting value Providing safe and accessible motorways to connect communities Contributing to and enhancing the liveability of communities Ensuring balanced consideration and proactive management of the whole-of-life environmental, social and economic costs and benefits during decision-making (including those related to future proofing for climate change and long term growth) Encouraging innovation and setting high standards Caring for our community, the environment and our people Proactively minimising adverse environmental and social impacts, in line with the SMC Environment Policy Establishing positive relationships with the community through ongoing and open engagement Providing training, education, apprenticeships and employment opportunities Protecting and promoting the environment, cultural heritage, staff and community health and wellbeing Valuing diversity and providing equal employment opportunities, in line with the SMC Diversity Policy Develop and implement the SMC Reconciliation Action Plan, acknowledging that Reconciliation is a shared responsibility Ensuring SMC is a socially responsible employer, investing in its people and its communities Being efficient Using resources (energy, water, materials) efficiently, avoiding and reducing waste and pollution Reducing SMC s corporate operational footprint. Dennis Cliche Chief Executive Officer Sustainability Policy 26 May 2017 Page 1 of 2

56 Policy Evaluation and Review Overall responsibility for implementation and application of this policy lies with the Chief Executive Officer under delegation from the Board. The Principal Manager, Health and Safety has primary responsibility for the interpretation, application, ongoing management and monitoring of this policy and consults with the Sustainability Manager and Project Directors as appropriate on practical and operational issues of policy implementation, monitoring and compliance. This policy will be evaluated and reviewed every two years by the Chief Executive Officer and Principal Manager, Health and Safety, in consultation with the Sustainability Manager and Project Directors as appropriate, as part of the Audit & Risk Assurance Program. Related Documents This policy should be read in conjunction with the following related SMC policies: 1. Environment Policy 2. Diversity Policy 3. Quality Management Policy 4. Work Health and Safety Policy 5. Procurement Policy 6. Risk Management Policy 7. Business Continuity Management Policy 8. Code of Conduct Responsible Officer: Principal Manager, Health and Safety Michael Polito Phone: (02) Effective date: 16 May 2017 Date of publication: 26 May 2017 Review Date: 16 May 2019 Sustainability Policy 26 May 2017 Page 2 of 2

57 Appendix B: OEMP Consultation feedback To be completed as consultation feedback is provided. Stakeholder Contact details Documents issued for consultation feedback Date documents issued for comment Initial phone calls & details Follow-up phone call(s)/ (s) & details Response provided? Comments from stakeholder How comments raised have been addressed (in the OEMP or otherwise) NSW Environment Protection Authority (EPA) Robbert Mels Operations Officer Metropolitan Infrastructure Metropolitan Branch, NSW Environment Protection Authority OEMP and SPs 15 February 2017 NA NA Yes Noted that EPA s position is to encourage the development of such plans to ensure they meet their statutory obligations and designated environmental objectives. However, as the Agency does not approve or endorse the plans it does not provide specific comments No action required. Chapter 4 of the OEMP and Chapter 3 of each OEMPSP refers to the statutory obligations and objectives relevant to the asset s operations. Roads and Maritime Department of Primary Industries: Fisheries Carla Ganassin Fisheries Manager Aquatic Ecosystems Unit OEMP and SPs 9 January 2017 NA NA Yes Supports the plan and suggests that no changes be made No action required Department of Primary Industries: Water Irene Zinger A/Regional Coordinator: Metro OEMP and SPs 9 January 2017 NA NA Yes Provides a number of suggested editorial changes and clarifications in the main OEMP relating to S1, S1.1, S1.4, S9.1 and S9.4 of the proposal. Makes the following comments/recommendations: DPI Water did not review OEMPSP2 or OEMPSP3 Inclusion of the detail of the post rehabilitation monitoring of the riparian land in OEMPSP3 that shows: Monitoring locations Performance indicators The various editorial changes and clarifications to the noted sections of the main OEMP have been made where relevant. Additional clarifications have been made to the controls in OEMPSP4 to respond to the Department s comments on the rehabilitation monitoring. Responsibilities, timings and duration Contingencies where the revegetation fails Ongoing maintenance and weed control Reporting monitoring results Confirmation if groundwater monitoring is included in OEMPSP4 Clarification on the specifics of the application and that the relevant provisions of the NSW Water Management Act 2000 have been included in the OEMP. WaterNSW Heritage Council of NSW Katrina Stankowski Senior Team Leader Archaeology Heritage Division Office of Environment & Heritage OEMP and SPs 20 February 2017 NA NA Yes Recommends that the following safeguard is included in the s EMP operation and management services proposed in the vicinity of heritage items will be appropriately designed and managed avoid any direct heritage impacts. Comments taken forward and actioned in the O&M contractor s EMP. NSW Office of Environment and Heritage

58 Stakeholder Contact details Documents issued for consultation feedback Date documents issued for comment Initial phone calls & details Follow-up phone call(s)/ (s) & details Response provided? Comments from stakeholder How comments raised have been addressed (in the OEMP or otherwise) City of Parramatta Council Bianca Lewis Senior Project Officer Land Use City of Parramatta PO Box 32, Parramatta NSW 2124 OEMP and SPs 20 February 2017 NA NA Yes Makes a request to receive a copy of the s EMP. Makes three recommendations for OEMPSP4. S3.3: Stormwater Management: should include reference to the NSW Floodplain Development Manual: the Management of Flood Liable Land (NSW DIPNR, 2005) and the Urban Stormwater Drainage Design Guidelines in Australia: Rainfall and Runoff (the ARR Guidelines, Australian Government, Geoscience Australia, 2016) The s EMP will be provided to Council once finalised. The other recommendations have been adopted in OEMPSP4. C4: Existing Environment: provide information on the flood events that caused the inundation levels quoted along with the design flood capacity of the road Annex A, C8: Reporting: submission of the monthly water quality reports to Council [along with NSW EPA]. Also involve Council in any water issues affecting surface waters in the Local Government Area, including atypical results and/or incidents that could substantially reduce water quality or affect the natural riparian environment. Cumberland Council Deerubbin Local Aboriginal Land Council Metropolitan Local Aboriginal Land Council Sydney Olympic Park Authority Sydney Water Willy Ramlie, Development Project Officer Development Partnerships DIPS Liveable City Solutions Sydney Water, Level 7, 1 Smith Street, Parramatta NSW 2150 OEMP and SPs 20 February 2017 NA NA Yes No concerns overall about the document. Its only minor comment is that any discharge of liquid waste discharged to a Sydney Water sewer system will need a (trade waste) agreement/approval from Sydney Water. Included under Control 6.8 of OEMPSP4 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 50 of 61

59 Appendix C: Environmental risk analysis Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 51 of 61

60 WestConnex M4 Widening Operation and Maintenance Operational Environmental Management Plan - Risk Assessment Version: 1 Revised: 3/02/2017 Noise generally Description of Activity/ Environmental Risk Consequence (best/worst case) Pre Control Risk (Before treatment) Likelihood (best/worst case) Risk Rating Proposed Control Measures, Treatment Responsibility Consequence (best case, treated) Target Control Risk (After treatment) Likelihood (best case, treated) Risk Rating Residual Risk $ Noise and vibration from the regular maintenance activities such as: Grass mowing Vegetation trimming Street sweeping generates community complaints Significant Possible Med 13 Inform residents in accordance with the Community Relations Plan about the planned works via the M4 website and/or other forms of communication. Such notification will be in advance of the significant maintenance works Inform the community before any programmed out of daylight hours work is undertaken by providing the following information - programmed times and locations of work, noise and vibration impact predictions, and noise and vibration mitigation measures being implemented. Stakeholder and Communications Manager Stakeholder and Communications Manager Minor Possible Med 8 Implement a hot line and complaints handling procedure for noise -related complaints to ensure all complaints are responded to. Stakeholder and Communications Manager Undertake regular maintenance of plant and equipment, to ensure that noise emissions do not increase over time. Maintenance Supervisor Safe Work Method Statements to address specific noise issues related to tasks Maintenance Supervisor Use of noisy equipment during O&M Activities Significant Possible Med 13 Minor Possible Med 8 Residential areas near project to be identified and communicated to all stafff Operations Manager Regular maintenance activities Noise from reversing alarms and horns during general operations and maintenance activities affects sensitive receivers and generates community complaints Sound walls have been extended by D&C Stakeholder and Communications Manager Plan and conduct works in a manner to minimise the reversing of vehicles with audible reversing alarms. Maintenance Supervisor (Civil) Vehicle warning devices, such as horns, are not to be used as signalling devices. Safe Work Method Statements and training to highlight noise issues to incident response and Maintenance Supervisor (Civil) Significant Possible Med 13 maintenance personnel Minor Possible Med 8 Towed vehicle drop-off locations to be established in non-residential areas Operations Manager Maintenance depot to be established in industrial area Switch off equipment during maintenance works if not used for extensive periods of time Where possible, the occurrence of consecutive works within the same locality, and coincidence of noisy plant/equipment working close together (and adjacent to sensitive receivers) will be avoided or otherwise minimised O&M Manager Maintenance Work Crews Maintenance Planner Noise and vibration from equipment used in regular maintenance activities such as: Grass mowing Vegetation trimming Sweet sweeping Cleaning of drainage and sedimentation basins generates community complaints Significant Possible Med 13 Schedule maintenance works during daytime hours (if possible). Where works must occur outside of daytime hours, notify community in accordance with Community Relations Plan Plan and conduct works in a manner to minimise the reversing of vehicles with audible reversing alarms. Use two way radios at the minimum effective volume. Maintenance Planner Stakeholder & Community Manager Maintenance Supervisor Maintenance Work Crews Minor Possible Med 8 Plant and equipment shall be task specific and if necessary fitted with less tonal alarms or warning devices. If noisy works will occur, and it is reasonably predicable that an exceedance may be possible the operator will conduct noise monitoring on that site. Maintenance Superintendent Unless required for technical reasons, undertake high noise generating work during the day, or early in the evening. If required to be undertaken at night; avoid short sharp sounds from impacts during night work to minimise sleep disturbance to neighbouring residents. Maintenance Planner Avoid metal-to-metal contact on equipment where feasible. Avoid dropping material from a height into unlined metal trays (line trays with soil or similar to reduce noise). Maintenance Supervisor Significant Possible Med 13 Loading of maintenance vehicles with waste affects sensitive receivers and generates community complaints Significant Possible Med 13 Loading and unloading to be carried out as far as practical away from sensitive receivers Maintenance Supervisor Significant Possible Med 13 Locate plant and equipment to take advantage of barriers provided by existing site features and structures Maintenance Supervisor Significant Possible Med 13 Major maintenance/repair activities Unless required for urgent maintenance activities, undertake high noise generating work during the day, or early in the evening. If required to be undertaken at night; avoid short sharp sounds from impacts during night work to minimise sleep disturbance to neighbouring residents. Maintenance Superintendent Noise generated from: Replacement of signage damaged by vehicle incidents Repairs to structures (ie, bridges) damaged by vehicle incidents Paving affects sensitive receivers and generates community complaints Significant Likely High 17 Where possible, undertake works in continuous blocks not exceeding three hours each with a minimum respite from those activities and works of not less than one hour between each block. Safe Work Method Statements and training to highlight noise issues to incident response and maintenance personnel Maintenance Superintendent Maintenance Superintendent Significant Possible Med 13 Undertake programmed high noise impact activities (ie, paving, repair to structures such as guardrails, etc) only after community notifications Maintenance Superintendent Content ID: WCX-M4W-EMP AppA6 Page 1 of 5

61 Description of Activity/ Environmental Risk Consequence (best/worst case) Pre Control Risk (Before treatment) Likelihood (best/worst case) Risk Rating Proposed Control Measures, Treatment Responsibility Consequence (best case, treated) Target Control Risk (After treatment) Likelihood (best case, treated) Risk Rating Residual Risk $ Noise generated from maintenance works undertaken out of daylight hours affects sensitive receivers and generates community complaints Significant Likely High 17 Inform the community before any out of daylight hours work is undertaken by providing the following Stakeholder and Communications information: programmed times and locations of work, noise and vibration impact predictions and noise Manager and vibration mitigation measures being implemented. Significant Possible Med 13 Incident response Noise generated from queueing traffic and incident response vehicles Operations Manager affects sensitive receivers and generates community complaints Significant Possible Med 13 SWMS and Training to address noise issues. Maintenance Superindentant Minor Possible Med 8 Towed vehicle drop-off locations to be established in non-residential areas Operational traffic noise Noise generated from vehicles using the Motorway affects sensitive receivers and generates community complaints Significant Possible Med 13 Undertake noise monitoring and report results to Project Company with recommendations (if feasible) to minimise impact, i.e. pavement surface refurbishment Analyse complaints from sensitive receivers and report to Project Company with recommendations (if feasible) to minimise impact, i.e. recommend construction of additional noise barriers in response to regular complaints QSE Manager Project Company QSE Manager Project Company Significant Surface Water quality management Excess rainfall causes deposits build up on road surfaces and pavement areas during dry weather to be washed off and transported to local waterways Major Likely High 21 Monitor weather conditions and forecasts (including rainfall prediction maps) daily and pass on relevant information to the Maintenance Superintendent/Supervisor to allow for adequate planning for significant QSE & Training Coordinator rain events. Prior to forecast rainfall, temporary ground covers such as fabrics, mats or polymer sprays will be deployed in high risk areas. Maintenance Supervisor Major Unlikely Med 14 Excess rainfall causes erosion Significant Possible Med 13 Divert formation runoff into pits and the stormwater drainage system as soon as practical to reduce surface flow lengths. Program regular landscape maintenance activities in accordance with the UDLP to maintain surface vegetation coverage Maintenance Supervisor Significant Unlikely Med 9 Maintenance Planner Significant Rare Low 6 Mulching of vegetation trimmings causes: Contamination of surface water by tannins Negative impact on local waterways Reduced water quality in local waterways due to increased turbidity and sediment loading from unstabilised mulch stockpiles Significant Possible Med 13 Manage vegetation stockpiles to minimise the impact of tannins leaching into the surrounding environment in accordance with RMS Environmental Direction Management of Tannins from Vegetation Mulch (RMS, 2012) appended to OEMP. Maintenance Manager Significant Rare Low 6 Spills of hydrocarbons that occur during maintenance activities or vehicle incidents on Motorway Significant Possible Med 13 All maintenance and incident response vehicles to contain a spill kit Maintenance Manager Operations Manager Significant Rare Low 6 Water quality risks associated with the runoff of pollutants from the road surface including: Sediments from the paved surface from pavement wear and atmospheric deposition Heavy metals such as lead, zinc, copper, cadmium, chromium and nickel attached to particles washed off the motorway pavement Oil and grease and other hydrocarbon products Rubber particles from wearing of tyres on the road pavement Brake pad dust which could potentially include asbestos from older brake pads Nutrients (N, P). Significant Almost Certain High 20 Planned maintenance activities including: Suction cleaning of drains, culverts and sedimentation basins Planned road sweeping INFO NEEDED FROM WARREN DO WE DISPOSE OF THE WATER FROM THE SUCTION CLEANING Maintenance Manager Significant Possible Med 13 Material deposited by motorists, such as non-biodegradable litter and food wastes impacts water quality, amenity and aquatic ecosystems if transported into receiving waterways. Litter from pedestrians on bridges over Motorway such as non-biodegradable litter and food wastes impacts water quality, amenity and aquatic ecosystems if transported into receiving waterways. Culverts and drainage including sedimentation basins causes reduced water quality in local waterways due to increased turbidity and sediment loading through sediment-laden runoff Significant Likely High 17 Significant Likely High 17 Significant Likely High 17 Scheduled street sweeping, drainage cleaning (drains, culverts and sedimentation basins) and litter collection Daily inspections of motorway to identify litter requiring collection Provision of 24/7 hotline for motorists to advise FHEOM of any major dumping of litter on Motorway corridor Regular programmed cleaning out of culverts and drains including sedimentation basins Reactive cleaning out of culverts and drains including sedimentation basins after heavy rainfall Maintenance Planner Maintenance Manager Stakeholder and Community Manager Maintenance Planner Maintenance Manager Significant Unlikely Med 9 Significant Rare Low 6 Sediment-laden water from cleaning of drainage and sedimentation basins discharged into waterways Significant Possible Med 13 When necessary, sediment will be settled out of any water to be discharged using a flocculant (gypsum unless approved otherwise by SMC). Apply flocculant to settle sediments within 24 hours of the conclusion of the last rainfall event. Maintenance Superintendent Maintenance Supervisor Significant Unlikely Med 9 Fuel spills during repair of pavements causes contamination of surface water by hydrocarbons Fuel spills during refueling of O&M vehicles causes contamination of surface water by hydrocarbons Significant Possible Med 13 Maintain all equipment according to manufacturers instructions Maintenance Manager Significant Unlikely Med 9 Significant Possible Med 13 All refueling of O&M vehicles to be undertaken out of the Maintenance Site Mantenance Manager Significant Unlikely Med 9 Accidental spillage of fuel, chemicals or other hazardous liquids as a result of vehicle leakage or road accidents on the motorway causes reduced water quality in local waterways Significant Possible Med 13 Maintain spill kits and fire extinguishers at all times in all incident response and maintenance vehicles. In the event of a spill, take corrective or remedial actions to render the area safe and avoid or minimise environmental harm. Maintenance Superintendent Incident Response Manager Maintenance crews Incident Response team members Significant Rare Low 6 Stabilisation of disturbed areas Promptly report all spills to the QSE Manager. Maintenance Superintendent Program regular landscape maintenance activities in accordance with the UDLP Maintenance Planner O& 3 Content ID: WCX-M4W-EMP AppA6 Page 2 of 5

62 Description of Activity/ Environmental Risk Consequence (best/worst case) Pre Control Risk (Before treatment) Likelihood (best/worst case) Risk Rating Proposed Control Measures, Treatment Responsibility Consequence (best case, treated) Target Control Risk (After treatment) Likelihood (best case, treated) Excessive clearing during O&M Activities cause erosion Minor Unlikely Low 5 Minor Rare Low 3 Commence stabilisation of waterways, including their beds and banks, immediately after the completion of any O&M Activities within these areas Maintenance Superintendent Maintenance Supervisor Erosion and sediment controls Undertake post-construction monitoring to ensure successful establishment of landscaping and vegetation cover to minimise risk of erosion and sedimentation Vegetation cover dies causing erosion and sedimentation Significant Possible Med 13 Undertake (or, during Defects Liability Period, arrange for D&C Contractor to undertake) remedial Mantenance Manager Significant Unlikely Med 9 planting in locations where vegetation cover has not established or has only partially established to minimise risk of erosion and sedimentation Undertake landscape maintenance in accordance with the UDLP Risk Rating Residual Risk $ O&M Activities alongside waterways cause disturbance Significant Possible Med 13 Immediately commence stabilisation of waterways, including their beds and banks, after the completion of any O&M Activities within these areas. All stabilised areas to mimic a naturalised creek system and the disturbed areas planted with native species. Maintenance Supervisor Significant Unlikely Med 9 Excessive clearing during O&M Activities cause erosion Significant Possible Med 13 Management of contaminated materials Use mulch bunds or straw bales as alternatives to sediment fencing where appropriate. Do not use mulch in concentrated flow areas or where it has the potential to result in tannin leachate into waterways.see RMS Environmental Direction No.25 Management of Tannins from Vegetation Mulch appended to OEMP. QSE Manager Maintenance Superintendent Maintenance Supervisor Significant Rare Low 6 In the event that contamination is identified, the contingency is to implement the Unexpected Discovery QSE Manager of Contaminated Material Procedure appended to the OEMP. Contamination is identified during landscape maintenance Major Unlikely Med 14 Major Rare Med 10 Develop a remedial action plan if contamination is found to pose unacceptable risks to the environment QSE Manager or human health. Undertake remediation works in consultation with the EPA. Acid Sulphate Soils are identified during landscape maintenance Major Unlikely Med 14 Should the presence of ASS be confirmed, follow ASS Management Procedure appended to the OEMP. Prepare an ASSMP if required, to identify strategies to remove or reduce the risks associated with ASS. QSE Manager Major Rare Med 10 QSE Manager Management of other activities with potential water quality impacts Do not locate storage areas within 50 metres of natural surface drainage areas, storm drainage systems or poorly drained or flood prone areas or any area with a slope steeper than 10%. Maintenance Superintendent Major Rare Med 10 Undertake storage and transport of liquid and dry chemicals (including pesticides, fuels and oils) in bunded areas and according to relevant Australian standards Maintenance Supervisor Major Rare Med 10 Maintain the Safety Data Sheet (SDS) and Hazardous Products Register and copies of all SDS documents in the site office within a special SDS folder. QSE Manager QSE & Training Coordinator Major Rare Med 10 Clearly label, use and handle liquid and dry chemicals (including pesticides, oils and fuels) in accordance with the instructions provided in its SDS document. Maintenance Supervisor Major Rare Med 10 Incorrect storage and handling of fuels and chemicals Major Possible High 18 Keep liquid chemicals (including pesticides) and fuels in bunded storage areas or sheds that have the capacity to contain spills from leaky containers or from an incident involving a decanting activity. Ensure the bunded capacity is at least 120% of the total capacity of all containers stored inside the bunded area or shed. Maintenance Superintendent Major Rare Med 10 Loss of native vegetation/ fauna habitat Maintenance of vegetation on Motorway verges Grass cutting Foliage trimming Maintenance around watercourses and aquatic environments Excessive foliage trimming destabilises banks Identification of EEC/threatened species Minor Possible Med 8 Minor Possible Med 8 Maintenance on Motorway Site generally Significant Unlikely Med 9 Terrestial fauna injury/mortality Maintenance vehicles Vehicles on M4 Motorway Invasion of weeds During O&M Activities there is potential for weed seeds and plant material to be dispersed into adjoining areas where weed species do not currently occur associated with the movement of soil and attachment of seed to maintenance vehicles and equipment. Significant Possible Med 13 Minor Possible Med 8 During site induction, advise all personnel of the following: The location of bunded storage areas, liquid absorbent materials and other spill containment materials and kits. Storage of large quantities of fuel for O&M vehicles and plant is not permitted. Licensed fuel trucks QSE Manager carrying emergency fuel spill kits must be used to service plant and equipment. QSE & Training Coordinator All drums and decanted containers must be labelled and stored within bunded areas whenever they are not in use. Whenever practical, all unattended drums/containers must be returned to the bunded storage area. Maintain landscaping in accordance with the UDLP to ensure that local native species are used to stabilise the soil and enhance the area. In the event that an EEC/threatened species is identified during operations, incorporate any specific procedures to deal with that species (e.g. re-location, translocation and/or management and protection measures) is incorporated into OEMP Where fauna is encountered that requires handling or rescue, follow the Fauna Handling and Rescue Procedure appended to the OEMP Weed management and control will be undertaken in accordance with the Biodiversity Guidelines (RTA 2011) Maintenance Superintendent Major Rare Med 10 QSE Manager Significant Rare Low 6 Maintenance Manager QSE Manager Mantenance Supervisor (Civil) Cleaning of maintenance vehicles and equipment regularly Mantenance Supervisor (Civil) Minor Unlikely Low 5 Significant Unlikely Med 9 Minor Unlikely Low 5 Use of pesticides Pesticide use will be undertaken in accordance with the Pesticide Use Procedure appended to the OEMP Content ID: WCX-M4W-EMP AppA6 Page 3 of 5

63 Description of Activity/ Environmental Risk Consequence (best/worst case) Pre Control Risk (Before treatment) Likelihood (best/worst case) Risk Rating Proposed Control Measures, Treatment Responsibility Consequence (best case, treated) Target Control Risk (After treatment) Likelihood (best case, treated) Risk Rating Residual Risk $ Pesticides not used correctly causing loss of native vegetation and runoff into waterways Significant Possible Med 13 Maintain the Safety Data Sheet (SDS) and Hazardous Products Register and copies of all SDS documents in the MCC within a special SDS folder. Clearly label, use and handle pesticides in accordance with the instructions provided in its SDS document. Maintenance Manager QSE Manager Significant Unlikely Med 9 Development of EWMS and training of all maintenance personnel Incorrect storage of pesticides leads to spills Significant Possible Med 13 Keep pesticides in bunded storage areas that have the capacity to contain spills from leaky containers or from an incident involving a decanting activity. Ensure the bunded capacity is at least 120% of the total capacity of all containers stored inside the bunded area or shed. Do not locate storage areas within 50 meters of natural surface drainage areas, storm drainage systems or poorly drained or flood prone areas or any area with a slope steeper than 10%. Maintenance Manager QSE Manager Significant Rare Low 6 Aquatic impacts Pesticide use will be undertaken in accordance with the Pesticide Use Procedure iappended to OEMP Contamination of local waterways as a result of any pesticide spills or pesticides not being used correctly Significant Possible Med 13 Maintain the Safety Data Sheet (SDS) and Hazardous Products Register and copies of all SDS documents in the MCC within a special SDS folder. Clearly label, use and handle pesticides in accordance with the instructions provided in its SDS document. Development of EWMS and training of all maintenance personnel Maintenance Manager QSE Manager Significant Rare Low 6 Increase in sediment and pollution loads in stormwater due to the removal of buffer vegetation, increase in road surface and increase in vehicular traffic impacting on water quality through road runoff containing suspended solids, nutrients from atmospheric fallout and other pollutants from vehicle, tyre and pavement wear Significant Possible Med 13 Maintain landscaping in accordance with the UDLP to ensure that local native species are used to stabilise the soil and enhance the area. Maintenance Manager Significant Unlikely Med 9 Dust Wind erosion of stockpiled mulch has an amenity impact to sensitive receivers where dust is deposited on surfaces resulting in community complaints Wind erosion of stockpiled mulch causes reduced water qualtiy in local waterways where dust is deposited Significant Possible Med 13 Significant Possible Med 13 Cover any mulch stockpiles Maintenance Superintendent Significant Rare Low 6 Maintain vegetation to eliminate bare land Dust generated during grass mowing and street sweeping affects sensitive receivers and generates community complaints Significant Possible Med 13 Only use equipment with appropriate filters Modify or stop dust-creating maintenance activities during periods of strong wind (in excess of 40km/h) and in response to strong wind weather forecasts. Record this in the Strong Wind Work Modification Record Maintenance Superintendent Significant Rare Low 6 Dust generated during repair of structures damaged by traffic incidents, ie. Dry saw cutting of concrete affects sensitive receivers and generates community complaints Significant Possible Med 13 EWMS to be developed to mitigate impact of dust and noise Inform community as per Community Relations Plan QSE Manager Stakeholder & Community Manager Significant Unlikely Med 9 Mud is tracked onto Motorway from maintenance vehicles engaged in motorway verge maintenance, e.g. grass cutting, vegetation trimming Significant Possible Med 13 Remove mud spilt by O&M traffic from public roads as soon as it is identified/reported and at the end of each working day Maintenance Supervisor (Civil) Significant Rare Low 6 Dust from waste leaving the maintenance site affects sensitive receivers and generates community complaints Significant Possible Med 13 Cover all loads that enter or leave the Maintenance Site. Maintenance Crews Significant Rare Low 6 Use temporary ground covers such as soil stabilisers or hydromulch as much as possible to stabilise batters, stockpiles and large surface areas. Maintenance Superintendent Dust from bare earth affects sensitive receivers and generates community complaints Significant Possible Med 13 Significant Rare Low 6 Maintain vegetation according to UDLP Maintenance Manager Emissions Emissions from vehicular traffic on Motorway Significant Likely High 17 Clear all traffic incidents as quickly as possible to enable free flowing traffic to resume Operations Manager Significant Possible Med 13 Turn machinery and vehicles off when not in use. Maintenance Crew Emissions from O&M vehicles Significant Possible Med 13 Heritage Maintain all vehicles and construction equipment in good working order to prevent excessive exhaust emissions in accordance with the manufacturer s specification to comply with all relevant legislation. Where possible, off road diesel equipment used must be compliant with Australian Design Rules 80 Emission Control for Heavy Vehicles. Maintenance Manager Significant Rare Low 6 Unexpected cultural Aboriginal and non-aboriginal heritage finds are encountered within the Maintenance Area Potential archeological objects identified within the Maintenance Area during O&M Activities Major Possible High 18 Major Possible High 18 Adopt and follow the RMS Standard Management Procedure Unexpected Heritage Items (Roads and Maritime Services, 2013) Before the start of O&M Services, all personnel will be trained regarding the procedure for unexpected finds of Aboriginal objects and about their responsibilities in accordance with the National Parks and Wildlife Act 1974 and the Heritage Act Works should cease in the immediate area and the RMS Unexpected Archaeological Finds Procedure 2012 followed. Maintenance Supervisor QSE Manager Maintenance Supervisor Major Unlikely Med 14 Human skeletal remains found within the Maintenance Area during O&M Activities Major Unlikely Med 14 Waste Procedures will be developed for management of any possible human skeletal remains. In the event that possible human skeletal remains are revealed, work would cease in the affected area and the reported to the NSW Police and the Office of Environment and Heritage. QSE Manager Major Rare Med 10 Content ID: WCX-M4W-EMP AppA6 Page 4 of 5

64 Description of Activity/ Environmental Risk Consequence (best/worst case) Pre Control Risk (Before treatment) Likelihood (best/worst case) Risk Rating Proposed Control Measures, Treatment Responsibility Consequence (best case, treated) Target Control Risk (After treatment) Likelihood (best case, treated) Risk Rating Residual Risk $ Ongoing operation of MCC and maintenance facility leads to excessive packaging of products and supplies delivered Calculate precise estimates prior to placing orders Maintenance Manager Minor Possible Med 8 Minor Unlikely Low 5 Implement, where possible, agreements with suppliers to return excess packaging for future reuse. Procurement Manager Setup of MCC and maintenance facility leads to over-ordering of materials resulting in waste General office waste generated by personnel such as paper, cardboard, beverage containers and food waste at Motorway Control Centre and maintenance facility Excessive paper use and toner use at MCC and maintenance facility High energy use in MCC due to 24/7 operation Minor Calculate precise estimates prior to placing orders Procurement Manager Minor Unlikely Low 5 Possible Med 8 Minor Encourage all staff to separate paper waste. O&M Manager Minor Unlikely Low 5 Provide paper recycling bins/boxes in MCC and maintenance facility offices. All paper waste to be sent to recycling facility. Set printers at the site office to default to double sided and black and white printing. Office Manager Encourage all staff to minimise paper use through use of electronic media, re-use of paper etc. Minor Possible Med 8 Minor Unlikely Low 5 Refill or return printer cartridges for recycling Purchase low-energy equipment that has standby mode Use low energy lighting Procurement Manager Litter from motorists using Motorway enters stormwater system through drains leading to reduced water qualtiy in local waterways where litter is deposited Litter from pedestrians on bridges over Motorway enters stormwater system through drains leading to reduced water qualtiy in local waterways where litter is deposited Significant Possible Med 13 Significant Possible Med 13 Scheduled street sweeping, drainage cleaning (drains, culverts and sedimentation basins) and litter collection Daily inspections of motorway to identify litter requiring collection 24/7 hotline for motorists to advise FHEOM immediately of excessive litter on motorway Maintenance Supervisor (Civil) Significant Unlikely Med 9 Vehicle and plant maintenance leads to waste fuel, oil and chemical containers Minor Possible Med 8 Vehicle and plant maintenance leads to cross contamination of waste Waste fuel, oil and chemical containers Minor Possible Med 8 Maintenance of O&M vehicles to be undertaken outside Maintenance Site Collect and store waste oil in suitable containers and store in a bunded area until collected for recycling. All permanent bunded storage areas must be covered. Maintenance Manager Minor Rare Low 3 Maintenance Superintendent Minor Unlikely Low 5 Use of hazardous materials during maintenance activities Minor Likely Med 12 Where possible and practicable, give priority to non-hazardous products when ordering materials Procurement Manager Minor Unlikely Low 5 Adopt and promote the waste hierarchy (reduce or avoid waste, reuse waste, recycle waste, recover energy, treat waste, dispose of waste). Encourage everyone working on the delivery of the O&M Services to avoid and reduce waste, wherever possible, by for example, training staff on the identification, classification and appropriate waste handling as well as disposal practices as part of the site induction Establish a list of preferred suppliers for waste management services (e.g. waste oil recyclers, metal recyclers, etc.). QSE Manager Procurement Manager QSE Manager Procurement Manager Include in waste contractor subcontract agreements requirements to comply with statutory requirements, report quantities, types, dates and destination of material removed from site. Procurement Manager Incorrect recycling/re-use of waste Significant Likely High 17 Classify all wastes generated on the Maintenance Site during O&M Activities in accordance with the 2009 Waste Classification Guidelines prior to transporting waste off site. QSE & Training Coordinator Significant Rare Low 6 Obtain and provide receipts/dockets for waste removed from site QSE & Training Coordinator Record all waste removed from Maintenance Site in the Waste Register. QSE & Training Coordinator When transporting waste to the premises other than EPA-licenced waste management facilities, ensure these premises can lawfully accept this waste; obtain a copy of the completed and signed Notice under Section 143 form to confirm this prior to transporting material to the premises. Waste received on Maintenance Site Significant Unlikely Med 9 Excessive fuel used during O&M Activities Minor Possible Med 8 No waste generated outside the site to be received at the Maintenance Site for storage, treatment, processing, reprocessing, or disposal on the Maintenance Site, except as expressly permitted by a licence under the Protection of the Environment Operations Act 1997, if such a licence is required in relation to that waste (CoA B10) Monitor fuel use consumption and investigate and implement minimisation practices where reasonable and practicable QSE Manager Significant Rare Low 6 Maintenance Manager Minor Unlikely Low 5 Excessive trimming of plants on motorway verges leads to waste Minor Possible Med 8 Reuse waste material generated onsite where possible, particularly mulch. Maintenance Manager Minor Rare Low 3 Ordering of products required for maintenance activities Significant Likely High 17 Use recycled products in O&M Activities to reduce demand on resources, where the use of the material is cost and performance competitive and RMS specifications allow it. Maintenance Manager Significant Possible Med 13 Content ID: WCX-M4W-EMP AppA6 Page 5 of 5

65 Appendix D: Environmental incident procedure Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 52 of 61

66 ENVIRONMENTAL INCIDENT CLASSIFICATION AND REPORTING PROCEDURE February 2016

67 Title About this release R Environmental Incident Classification and Reporting Procedure Approval and authorisation Name Prepared By Environment Manager Environment Performance Sean Hardiman Improvement Approved By Principal Manager Environment Operations David Featherston Document Status Date Version March 2015 Version Date Revision Description Classification and Management of Environmental Incidents and Hazards. Environmental incidents classified under two categories Additional definitions included Clarified definition of Senior Environmental Officer Title change. New incident category (Cat 3) included Appendix 1 Environmental Incident Report Form & instructions included Environmental Incident Report Form & instructions included in Guidance material Minor changes to category 1 incident types; discharge of waters, critical habitat and failure to comply with a REF determination. Sections from Guidance document included in Procedure. Requirement to notify Chief Executive and relevant Directors of significant category 1 incidents. Appendices included Significant changes to formatting Title change to Environmental Incident Classification And Reporting Procedure. Update to include Maritime Division. Unexpected threatened species find to be managed in accordance with Biodiversity Guidelines included in reportable events. Significant changes to notification of material harm. Reportable event category included. Changes to reportable events, including unexpected contamination finds. Update to notification of material harm. Legal Branch revision and update following recommendations in The External Review of Roads and Maritime Services Handling of Contaminated Material on the Pacific Highway Herons Creek to Stills Road Section by Brian Gilligan dated February Update Maritime Division contact and inclusion of document history Update contact positions, edit references to RMS Update contact positions, update incident form Update Contacts page Clarify that unexpected find of asbestos is a reportable event. Update to meet Web Content Accessibility Guidelines version 2.0 (WCAG 2.0) Clarification on reportable event notification address Update on report sign off process to ensure Environment Manager signoff and acknowledgement. Reference to RMD incident fact sheet. Priority reference to Part 5.7 incidents. General formatting and editorial amendments Update of the incident form work flow to ensure Project Manager approval and Regional Environment Manager concurrence. Clarification of a Category 2 procedural / administrative/ documentation incident Editorial corrections, amendments to report form, update contact list Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 1 of 17

68 CONTENTS 1 BACKGROUND Purpose Scope and Coverage Responsibilities 3 2 CLASSIFICATION, NOTIFICATION AND REPORTING PROCESS Environmental Incident Classification Environmental Incident Response Environmental Incident Reporting The Environment Incident Report Form Environmental Incident Report Form Completion Environment Operations mailbox Subject Line Submitting the Form Regulatory Agency Notification POEO Act Notification of Material Harm 8 APPENDIX 1 ENVIRONMENTAL INCIDENT REPORT FORM 13 APPENDIX 2 ROADS AND MARITIME CONTACTS 15 APPENDIX 3 CONTACT DETAILS FOR PUBLIC HEALTH UNITS 16 Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 2 of 17

69 1 BACKGROUND 1.1 Purpose To ensure that Roads and Maritime Services has processes to classify and report environmental incidents that may occur during Roads and Maritime managed activities and to comply with its statutory obligations to report certain incidents. 1.2 Scope and Coverage This Procedure is for the use of all Roads and Maritime staff in all regions and divisions where environmental incidents may occur, including where incidents occur during the course of Roads and Maritime s contractors or alliance members undertaking works. The procedure is to clearly define the requirements of Roads and Maritime staff and contractors to report environmental incidents. The procedure does NOT cover environmental incidents caused by traffic accidents or boating accidents nor marine oil and chemical spills covered by the National Plan 1. The Roads and Maritime Environmental Incident Classification and Reporting Procedure relates to incidents involving Roads and Maritime or its contractor/alliance partners and is for internal reporting processes as outlined in this procedure Responsibilities All Roads and Maritime staff and contractors are responsible for reporting an environmental incident in accordance with this procedure when they become aware of the incident. Regional Maintenance Delivery (RMD) shall manage environmental incidents in accordance with the RMD Environmental Incident Fact Sheet at this link. 2 CLASSIFICATION, NOTIFICATION AND REPORTING PROCESS 2.1 Environmental Incident Classification There are three categories of environmental incidents / events that are to be identified and managed as shown in shown in Table 1. Category 1 Incidents -- potentially the most serious incidents. They generally reflect breaches of environmental legislation. Category 2 Incidents - are generally less environmentally serious and generally have lower maximum penalties. Nevertheless, there are sound policy reasons why these incidents need to be identified and reported, including in order to track potential trends that may lead to Category 1 incidents if not addressed Reportable Events - This category captures events that occur outside the scope of reasonable controls and mitigation. 1 The National Plan to Combat Pollution of the Sea by Oil and Other Noxious and Hazardous Substances Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 3 of 17

70 Table I Environmental Incident Classification Categories Incident Category Category 1 Pollution Incidents Breaches of the Protection of the Environment Operations Act POEO Act (1977) particularly s.148 (notification requirements). Pollution incidents which cause, or threaten to cause, material harm to the environment, that is, actual or potential harm to the health or safety of humans or ecosystems that is not trivial or that results in actual or potential loss or damage over $10K must be NOTIFIED to the EPA and other relevant authorities. Conservation Breaches Breaches of the National Parks & Wildlife Act (1974) NPW Act Fisheries Management Act (1999) FMA Act and the Environment Protection and Biodiversity Conservation Act (1999). EPBC Act Primary Legislative Requirements and offence provisions Discharge of waters from site not in accordance with any applicable Minor Works memo or safeguard / Part 5 determination / approval / licence condition (EP&A Act particularly s.115w, s.76a, s.115w: POEO Act particularly s.64) Pollution, or potential pollution, of waters with sediment or chemicals/fuels/oils that travel beyond the site boundary causing or potentially causing adverse impact to the environment, including discharges or spills to waters from the Rozelle Maritime marina or Maritime operated vessels (s.120 POEO Act water pollution, sediment laden water, chemical/oil spill and sewage/septic overflow) Emission of excessive levels of dust, or an offensive odour or noise that travel beyond the site boundary and might impact on nearby land users (s.126 POEO Act - dust exceeding reasonable levels without active management measures in place, s offensive odour;.s offensive noise) Unauthorised disposal or transport of waste s.143 POEO Act Unlawful transporting or depositing of waste A spill or other incident that causes pollution to land or residual environmental impact. (s.116 POEO Act spills and leaks generally, s.142 pollution of land) Unauthorised harm or damage to native vegetation, threatened species, endangered populations, endangered ecological communities or critical habitat. NPW Act particularly s.118a, s.118c and s.118d Unauthorised harm to threatened aquatic species and protected marine vegetation or unauthorised dredging or reclamation works within a watercourse. FMA Act (1994) particularly s. 199 and 204A.NPW Act particularly s.118a, s.118c and s.118d. A fire that travels beyond the boundary causing or potentially causing adverse impact on the environment or community. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 4 of 17

71 Heritage Breaches Breaches of the Heritage Act (1977) and NPW Act (1974), EPBC Act (1999) Planning Breaches Breaches of the Environmental Planning & Assessment Act (1979) EP&A Act, Protection of the Environment Operations Act (1977) POEO Act. (also refer Category 2 exception) Unauthorised harm to Aboriginal objects and Aboriginal places. NPW Act particularly s.86 and s.87. EPBC Act 1999 s.15a, B &C Unauthorised damage to any State or locally significant relic or Heritage item Heritage Act 1977 particularly s. 57, s.119, s.139 and s.156. EPBC Act 1999 s.15a, B &C Works undertaken outside approved areas, without required approval, without environmental assessment. EP&A Act particularly s.115w, and s.111 POEO Act particularly s.64 Failure to comply with a Minor Works memo or safeguard / Part 5 determination / approval or permit/ environment protection licence condition. EP&A Act particularly s.75d, s.76a, s.115 ; POEO Act s. 64 A procedural, administrative or technical breach that relates to the preparation or submission of documents, reports or other correspondence. Category 2 Failure to implement component of Environment Management Plan or work method statement that does not result in a Category 1 incident. Spills that do not leave a site boundary and are cleaned up without environmental harm or residual environmental impact A fire that is contained on site and does not cause or potentially cause adverse impact to the environment or community Reportable Events Material travelling beyond a site boundary, and where it can be demonstrated that the erosion and sediment controls have been installed and maintained well, and the weather (rain, wind etc) event exceeds the design capacity of controls. An unexpected archaeological and is being managed in accordance with the " Roads and Maritime Standard Management Procedure - Unexpected Archaeological Finds An unexpected threatened species find that has been discovered and not previously identified during previous environmental assessments and is being managed in accordance with the Roads and Maritime Biodiversity Guidelines unexpected threatened species finds procedure An unexpected find of contaminated soils, asbestos or other potentially hazardous substances. A formal complaint or warning from a regulatory agency Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 5 of 17

72 2.2 Environmental Incident Response Table 2 details the response to each incident category and Appendix 2 gives information in relation to who is responsible for the various management actions described below. The table provides information of the type of response and whether it is required to be undertaken by Roads and Maritime and/or the Roads and Maritime contractor. Regional Maintenance Delivery (RMD) shall manage environmental incidents in accordance with the RMD Environmental Incident Fact Sheet at this link. If in doubt, treat all incidents as Category 1 and in consultation with the PMEO, a decision can be made to reclassify the category. Table 2: Environmental Incident Response Category 1 Incident Response Stop work in relevant area (if necessary) and take immediate actions to prevent adverse impact to the environment or community. Note that the health and safety of workers is the primary concern, and no action should be taken if it is not safe to do so. For NOTIFIABLE POLLUTION INCIDENTS refer to section 2.4 below. For all other Category 1 incidents immediately advise RMS Project Site Management and relevant RMS Regional Environment Manager who must immediately advise Principal Manager Environment Operations (PMEO) by phone. Complete the environmental incident report form 624 and submit to Regional Environment Manager and the Environment Operations mailbox within 3 days of the date of the incident. The RMS Project Manager must approve the incident report and submit to the RMS Regional Environment Manager who will signoff as concurrence of receipt and submit to PMEO and the Environment Operations mailbox by on the same day of receipt. Category 2 Incident Response 1 2 Stop work in relevant area (if necessary) and take immediate actions to prevent adverse impact to the environment or community. Note that the health and safety of workers is the primary concern, and no action should be taken if it is not safe to do so. Advise relevant RMS Regional Environment Manager (Roads and Maritime contractors to advise Roads and Maritime Project Site Management). 3 Complete the environmental incident report form 624 (and submit to RMS Regional Environment Manager and the Environment Operations mailbox within 3 days of the date of the incident. The Regional Environment Manager will signoff and submit to PMEO and the Environment Operations mailbox by on the same day of receipt. Reportable Event Response 1 RMS Regional Environment Manager to advise Principal Manager Environment Operations by with copy to the Environment Operations mailbox. Roads and Maritime contractors to advise Roads and Maritime Project Site Management Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 6 of 17

73 2.3 Environmental Incident Reporting It is important that there is consistency in the way that an environmental incident is reported. The incident report form and any subsequent reports must only include factual information. Speculation about the causes and outcomes are not to be included. The completed reports must be forwarded through regional Environment Managers or relevant Project Manager to the Principal Manager Environment Operations. The following conventions must be used when ing and reporting on environmental incidents: The Environment Incident Report Form All environmental incidents must be reported by project staff and project managers through the Environmental Incident Report Form (refer Appendix 1, Form 624 available here or Form 400 for Regional Maintenance Delivery projects available here) Environmental Incident Report Form Completion All parts of the form must be completed o The form must be signed off by: o o o the person making the report; and the RMS Regional Environment Manager. It is the responsibility of the RMS Regional Environment Manager to complete the section regarding the notification of the incident to the EPA and other relevant authorities Environment Operations mailbox The Environment Operations mailbox is envops@rms.nsw.gov.au Subject Line When ing an Environmental Incident Report to the Environment Operations mailbox, the subject line must include the incident category level (1 or 2), the project name and date. This will ensure that any subsequent s relating to the incident may be adequately captured and tracked by Environment Branch. For example, the subject line convention would be written as Category 1 Raleigh Road Upgrade 1/10/ Submitting the Form All environmental incident report forms must follow the following signoff workflow: 1. preparation and signoff by the person preparing the report (RMS or contractor staff) 2. approval by the RMS Project Manager, 3. signoff concurrence by the relevant RMS Regional Environment Manager and forwarding to the Environment Operations mailbox. The Regional Environment Manager may also request further information regarding the incident. The Regional Environment Manager should submit the form within timeframes and include DRAFT in the subject line while waiting for the information which must be provided and resubmitted within the timeframes requested. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 7 of 17

74 2.4 Regulatory Agency Notification There are specific statutory requirements relating to the notification of pollution or environmental incidents to relevant regulatory agencies. These are summarised in table 3 below Table 3: Environmental Incident Notification Requirements Legislation POEO Act 1997 (see Section 2.5) Regulating Authority EPA and relevant authorities Section Section 148 requirement to immediately notify pollution incidents occurring during an activity that cause or threaten material harm to the environment. Heritage Act 1977 EPA Section 146 requirement to notify the Heritage Council of the location of the relic once a relic has been discovered or located. National Parks and Wildlife Act 1974 Commonwealth Aboriginal and Torres Strait Islanders Heritage Protection Act, 1984 Contaminated Land Management Act 1997 Rural Fires Act 1997 EPA Department of Environment EPA NSW Fire Brigades Section 89A requirement to notify the location of an Aboriginal object that is the property of the Crown. Section 20 requirement to notify the Minister of the discovery of Aboriginal remains. Section 60 requirement to notify if Roads and Maritime activities have contaminated land or if Roads and Maritime owns land that has been contaminated. Section 64 requirement to notify an appropriate fire officer of the inability to extinguish any fire burning during a bush fire danger. Should an environmental incident have the potential to impact on a drinking water supply, the relevant water supply authority must also be advised. It is the responsibility of Environment Managers to liaise with Environment Operations Section prior to notifying regulatory agencies of relevant environmental incidents. 2.5 POEO Act Notification of Material Harm Under Part 5.7 of the POEO Act, there is a duty to notify each relevant authority (identified below) of a pollution incident, where material harm to the environment is caused or threatened. Material harm includes actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or that results in actual or potential loss (refer definitions in s147 of POEO Act) or property damage of an amount over $10,000. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 8 of 17

75 The following notification procedure only relates to pollution incidents. Conservation, heritage and planning breaches described in Section 2.1 are not included in the definition of a pollution incident with respect to Part 5.7 of the POEO Act. Roads and Maritime is not responsible for notifying a pollution incident caused by a traffic or vehicle accident where notification has already occurred. Notification is required by the person carrying on the activity immediately upon becoming aware of the incident. IMPORTANT NOTE The following procedure is to be followed by all Roads and Maritime staff and contractors. Any actual or potential material harm to a person s health or well being or the environment as a result of a pollution incident must be reported immediately to Principal Manager Environment Operations on (02) Contractors who hold an environment protection licence for their activities are responsible for implementing their compliant Pollution Incident Response Management Plan including notifying EPA and the other relevant authorities in accordance Part 5.7 of the POEO Act and any relevant Conditions of their EPL Contractors undertaking works without an EPL are responsible for notifying Roads and Maritime, EPA and the relevant authorities in accordance Part 5.7 of the POEO Act. As soon as a Roads and Maritime employee becomes aware of a Category 1 pollution incident, all Roads and Maritime environment officers and project managers are to immediately notify Principal Manager Environment Operations on (02) of all Category 1 pollution incidents. RMD staff are to notify according to RMD Environmental Incident Fact Sheet. PMEO will assist in making an assessment of the incident and determine whether or not to formally notify the incident to the EPA and other relevant authorities. If for any reason that PMEO is not contactable, staff should contact their regional Roads and Maritime Environment Managers (or Regional Maintenance Delivery Environmental Manager for Regional Maintenance Delivery projects) to assist in assessing whether an incident triggers the notification requirement. If no assistance can be obtained within a reasonable time, you are required to notify the relevant authorities in the order of notification outlined in the table below and provide each agency with the information required in section 2.5 of this procedure. Even if you do not have all the information, you must notify each agency with the information you have at hand and ensure that they are updated as soon as further relevant information becomes available. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 9 of 17

76 In circumstances where there is doubt about the need to notify or the relevance of a particular agency, Roads and Maritime should always err on the side of notification. When in doubt, communicate! Relevant Authorities to Notify Table 4 provides the contact details for the authorities that need to be notified in the event of a material harm pollution incident. Table 4: Appropriate Authorities for Part 5.7 Incident Notification Relevant Authority Contact Number Fire and Rescue NSW 000 (for pollution incidents that present an immediate threat to human health or property) (for pollution incidents that do not present an immediate threat to human health or property) EPA environment line The Ministry of Health Via the local Public Health Unit see Appendix 3 WorkCover Authority The appropriate regulatory authority Your Local Council or Western Lands Commissioner for the Western Division (except any part of the Western Division within the area of a local council) Local Council Please call Division of Local Government on to find relevant local council contacts or visit their website on The appropriate contact for the relevant local council and Public Health Unit will vary. All necessary contact numbers should be found in advance and stored for immediate access should a pollution incident need to be notified. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 10 of 17

77 Relevant authorities notification order If the incident presents an immediate threat to human health or property, Fire and Rescue NSW, the NSW Police and the NSW Ambulance Service should be contacted first for emergency assistance o call Fire and Rescue NSW on 000 first then o EPA environment line o The Ministry of Health o WorkCover Authority o Local Authority (Council) If there is not an immediate threat to human health or property: o call EPA environment line first then o Local Authority (Council) o The Ministry of Health o WorkCover Authority o Fire and Rescue NSW on All of the above authorities (whether considered relevant or not) must be contacted for each material harm pollution incident to satisfy notification obligations The relevant information to provide Section 150 of the POEO Act provides the information that needs to be notified. It is important to avoid speculation on origin, causes or outcomes of a pollution incident in discussions with the authorities. While it is important not to speculate on the causes of an incident, s150 (1) (d) of the POEO Act requires notification of the circumstances in which the incident occurred (including the cause of the incident, if known) and there is an ongoing duty ensure that relevant information be notified after it becomes known. Section 150 POEO Act - Relevant information to given 1. The relevant information about a pollution incident required under section 148 consists of the following: a. the time, date, nature, duration and location of the incident, b. the location of the place where pollution is occurring or is likely to occur, the nature, the estimated quantity or volume and the concentration of any pollutants involved, if known, c. the circumstances in which the incident occurred (including the cause of the incident, if known), d. the action taken or proposed to be taken to deal with the incident and any resulting pollution or threatened pollution, if known, e. other information prescribed by the regulations. 2. The information required by this section is the information known to the person notifying the incident when the notification is required to be given. If the information required to be included in a notice of a pollution incident by subsection (1) (c), (d) or (e) is not known to that person when the initial notification is made but becomes known afterwards, that information must be notified in accordance with section 148 immediately after it becomes known. Note: if a pollution incident occurs, the above information is to be initially communicated verbally to each relevant authority and is to be followed by written notification within 7 days of the date on which the incident occurred (Clause 101 POEO (Gen) Regs). Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 11 of 17

78 Complying with these notification requirements does not remove the need to comply with any other obligations for incident notification, for example, those that apply under other environment protection legislation such as an EPL condition or legislation administered by WorkCover. Should Roads and Maritime receive a request from a regulatory authority for a written report regarding an environmental incident, the relevant Project Manager must immediately contact Environment Branch and Legal Branch for advice. Communications with Legal Branch, for the purpose of obtaining legal advice in relation to incidents, may be subject to legal professional privilege. Documents that may be the subject to legal privilege should be clearly identified and sent to Legal Branch prior to producing them to a regulatory agency. Such documents may not be required to be produced to the agencies under written notices to provide information. Environment Branch will provide advice and will co-ordinate a response with Legal Branch. Environment Branch and Legal Branch will assist in the investigation of incidents, prepare legal advice and assist with the preparation of reports to EPA, OEH and DP&I. Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 12 of 17

79 Appendix 1 Environmental Incident Report Form Form 624 available here or Form 400 for Regional Maintenance Delivery projects available here Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 13 of 17

80 Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 14 of 17

81 APPENDIX 2 ROADS AND MARITIME CONTACTS Position Location Phone Mobile General Manager Environment North Sydney Principal Manager Environment Operations Principal Manager Environment (IDD) Principal Manager Environment Policy, Planning and Assessment Maritime Division Emergency Planner Officer Senior Environment Specialist Biodiversity Senior Environment Specialist - Heritage North Sydney North Sydney North Sydney Rozelle office North Sydney North Sydney Environment Manager Motorways North Sydney Environment Manager Sydney Parramatta Environment Manager Western Parkes Environment Manager Southern Wollongong Environment Manager Northern Grafton Environment Manager South- West Wagga Wagga Environment Manager Hunter Newcastle Environment Manager Pacific Highway Environment Manager Easing Sydney Congestion Environment Manager Freight and Regional Environment Manager Western Sydney Environment Manager Greater Sydney A/Environmental Manager Regional Maintenance Delivery Grafton Parramatta Newcastle Parramatta Parramatta Grafton Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 15 of 17

82 APPENDIX 3 CONTACT DETAILS FOR PUBLIC HEALTH UNITS Public Health Unit Contact Details After Hours Contact Goulburn Office Locked Bag 11, Goulburn, 2580 Ph: Fax: / (s) Ph: (diverts to Albury Base Hospital) - ask for Public Health Officer on call, Albury Office PO Box 3095, Albury, 2640 Ph: Fax: Ph: (diverts to Albury Base Hospital) - ask for Public Health Officer on call, Broken Hill Office PO Box 457, Broken Hill, 2880 Ph: Fax: / 1196 (s) Ph: (Broken Hill Base Hospital) - ask for Public Health Officer on call, if no answer: Mob: Dubbo Office PO Box 739, Dubbo, 2830 Ph: Fax: (s) Ph: (Dubbo Base Hospital) - ask for Public Health Officer on call, if no answer: Mob: ask for Public Health Officer on call Bathurst Office PO Box 143, Bathurst, 2795 Ph: Fax: (s) Mob: ask for Public Health Officer on call Newcastle Office Locked Bag 10, Wallsend, 2287 Ph: Fax: / (s) Ph: (diverts to John Hunter Hospital) - ask for Public Health Officer on call Tamworth Office Locked Mail Bag 9783, NEMSC 2348 Ph: Fax: (s) Ph: (diverts to Public Health Officer on call) Matraville Office PO Box 150, Matraville 2036 Ph: Fax: (s) Ph: Port Macquarie Office PO Box 126, Port Macquarie 2444 Ph: Fax: Pager Service: Communicable Disease: Environmental Health: If no answer phone: Mob or Mob Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 16 of 17

83 Public Health Unit Contact Details After Hours Contact Lismore Office PO Box 498, Lismore 2480 Ph: Fax: / (s) Pager Service: Communicable Disease: Environmental Health: If no answer phone: Mob or Mob Hornsby Office Hornsby Hospital, Palmerston Rd, Hornsby 2077 Ph: Fax: / 1358 (s) Ph: (Hornsby Hospital) - ask for Public Health Officer on call Gosford Office PO Box 361, Gosford, 2250 Ph: Fax: (s) Ph: (Gosford Hospital) - ask for Public Health Nurse on call Randwick Office Locked Bag 88, Randwick 2031 Ph: Fax: / 8314 (s) Ph: (Prince of Wales Hospital) - ask for Public Health Nurse on call Wollongong Office Locked Bag 9, Wollongong 2500 Ph: Fax: (s) Ph: (Wollongong Hospital) - ask for Public Health Officer on call Eastern Zone(Camperdown Office) For Liverpool Area, please dial the Camperdown office. PO Box 374, Camperdown 2050 Ph: Fax: Fax: (s) Ph: (Royal Prince Alfred Hospital) - ask Public Health Officer on call Penrith Office PO Box 63, Penrith 2751 Ph: Fax: / 3444 (s) Ph: (Westmead Hospital) - ask for Public Health Officer on call Parramatta Office Locked Bag 7118, Parramatta BC 2150 Ph: Fax: / 3591 (s) Ph: (Westmead Hospital) - ask for Public Health Officer on call Version 4.12 February 2016 Printed copies of this document are uncontrolled Page 17 of 17

84 Appendix E: Environmental Monitoring Checklist Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 53 of 61

85 Monitoring element and reference Commitment Responsibility OEMP checklist action required Timing Last review date Follow up date Control actions undertaken Signoff Environmental obligations Section Implement, review and manage the conditions of approval SMC Environmental Manager Audit and track compliance and implementation of the full requirements listed in Table 4.1 Biannually Legal and regulatory requirements Sections 4.1.3, and 4.2 Requirement to work under provisions of Commonwealth and NSW statute and legislation even if this falls outside of the conditions of approval, the Deed or the Scope of Works and Technical Criteria SMC Asset Manager Review Section 4 to ensure it is up to date and identify any upcoming approval requirements Live document that must be reviewed in lieu of any legislative updates Monthly reporting Environmental risk analysis Section 8 Appendix C Review and understand the asset s operations and maintenance risks and management controls SMC Environmental Manager Review the environmental risk analysis Ensure ratings reflect the current state of the asset s operation and maintenance Review nonconformances and closeout. All actions biannually Induction and training Section 6 All asset stakeholders are to be inducted and trained SMC Asset Manager Review induction and training records Annually Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 54 of 61

86 Monitoring element and reference Commitment Responsibility OEMP checklist action required Timing Last review date Follow up date Control actions undertaken Signoff Communication, consultation and complaints Section 7 Maintain complaint register and action response Maintain Community Consultation Committee, and report, issue and release monitoring data and environmental performance SMC Asset Manager Review complaints register and close out actions Review document control records, undertake quality assurance check and the quality control of data Review community consultation committee communications, responses and implemented actions Biannually Annual reporting Emergency response and preparedness Section 6.3 and 6.4 Section 9 Implement emergency and incident response and preparedness records SMC Asset Manager Inspect storage areas and implement housekeeping and best-practice measures Update the materials safety data sheet register Check emergency procedure stocks All actions biannually Appendix D Update emergency contact list and circulate as required Review incident register and Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 55 of 61

87 Monitoring element and reference Commitment Responsibility OEMP checklist action required Timing Last review date Follow up date Control actions undertaken Signoff compliance tracking register and close out any outstanding items Complete this checklist and follow up any outstanding items OEMP compliance and update Section 6.1 Review the implementation and success of the OEMP. SMC Asset Manager Review compliance register and close out any outstanding items Monitor the implementation of relevant standard operating procedures to check compliance All actions biannually Review nonconformances and closeout. Review and improvement Section Review and update the OEMP SMC Environmental Manager Fully review the OEMP and sub-plans Annually unless there are substantial changes Record management Section 10.2 Maintain records of environmental maintenance and monitoring activities SMC Environmental Manager Fully review the OEMP, management sub-plans and standard operating procedures Annually unless there are substantial changes Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 56 of 61

88 OEMPSP1: Noise and Vibration Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 57 of 61

89 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan OEMPSP1: Noise and Vibration Management Sub-Plan April 2017 Sydney Motorway comprises Sydney Motorway Corporation (ACN ) and its controlled entities

90 Definitions Term Ambient Noise Asset Audible Range Background Noise dba: A-weighted decibels MCoA DP&E EMP ENMM EPA EIS Impulsiveness L1 L10 L90 LAeq (period of time) Loudness Noise management levels (NMLs) Definition The all-encompassing noise associated within a given environment at a given time, usually composed of sound from all sources near and far. M4 Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush The limits of frequency which are audible or heard as sound. The normal ear in young adults detects sound having frequencies in the region 20 Hz to 20 khz, although it is possible for some people to detect frequencies outside these limits. Background noise is the term used to describe the underlying level of noise present in the ambient noise, measured in the absence of the noise under investigation, when extraneous noise is removed. It is described as the average of the minimum noise levels measured on a sound level meter and is measured statistically as the A-weighted noise level exceeded for ninety percent of a sample period. This is represented as the L90 noise level The ear is not as effective in hearing low frequency sounds as it is hearing middle frequency sounds. That is, low or very high frequency sounds of the same db level are not heard as loud as middle frequency sounds. The sound level meter approximates the human response of the ear by using an electronic filter which is called the A filter. A sound level measured with this filter switched in is denoted as dba. Minister for Planning Condition of Approval Department of Planning and Environment O&M Contractor s Environmental Management Plan Environmental Noise Management Manual NSW Environment Protection Authority Environmental Impact Statement An impulsive noise is characterised by one or more short sharp peaks in the time domain, such as occurs during hammering. The noise level exceeded for 1 per cent of the time for which the given sound is measured. The sound pressure level that is exceeded for 10 per cent of the time for which the given sound is measured. The sound pressure level that is exceeded for 90 per cent of the time for which the given sound is measured. The LAeq is the A-weighted equivalent continuous sound level, sometimes referred to as the average noise level. It represents a sound level with the same energy content as the actual varying noise level measured. The period of time for which the Leq is calculated over is defined by the type of noise being measured, the time of day and the regulatory requirements. A 3dB increase represents a doubling of the sound pressure, however an increase of about 10dB is required before the sound will subjectively appear to be twice as loud. That is, a sound of 85dB is twice as loud as a sound of 75dB which is twice as loud as a sound of 65dB and so on. That is, the sound of 85dB is four times as loud as a sound of 65dB. Typically smallest change which can be readily heard by the average person is approximately 3dB. An increase beyond 5dB is considered to represent the level at which a change in loudness begins to be clearly perceived. The noise management levels are described in the Interim Construction Noise Guidelines (ICNG, 2009). They are typically used to assess the impacts of construction and maintenance noise, however they can be to inform the management of general operational noise. Noise management levels are calculated by using the rating background level. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 1 of 30

91 Term O&M personnel O&M stakeholders OEMP OEMPSP1 OOHW PPV Rating background level (RBL) SMC SMC IMS Sensitive receiver SOP Sound Sound level meter Sound power level Sound pressure level Tonality Definition Operation and Maintenance Undertakes the operation and maintenance of the asset under the O&M deed All people employed by the to undertake operation and maintenance work All entities undertaking operational and maintenance activities on the asset. Typically including SMC and O&M Contractor and other sub-contracted parties. Operation Environmental Management Plan Noise and Vibration Management Sub-plan Out of hours work Peak particle velocity measured in mm/s The Rating Background Level as defined in the INP (NSW EPA, 2000) is the median of the assessment background levels (ABL). The ABL is the lowest tenth percentile noise level measured in each day, evening and night period. It is used to develop construction noise management levels. Sydney Motorway Company, a special purpose entity that has been created by the NSW Government to manage the delivery of WestConnex. Contains the policy, practices, and procedures for operating, maintaining and repairing WestConnex, which includes relevant environmental management information including the OEMP and this OEMPSPs Residence, education institution (e.g. school, university, TAFE college), health care facility (e.g. nursing home, hospital), religious facility (e.g. church) and children s day care facility. Standard operating procedure Any pressure variation that the human ear can detect. An instrument designed to measure sound pressure levels. Typically sound level meters consist of a microphone, signal amplifier and processing and storage facilities. Sound Level Meters can be rated to perform to a specific standard, defined by International Standards. Ten times the logarithm to the base 10 of the ratio of the sound power of the source to the reference sound power. It represents the inherent acoustic energy of a noise source and therefore does not change with distance or environment. Ten times the logarithm to the base 10 of the ratio of the sound pressure of the source to the reference sound pressure. It is the most common way of measuring the magnitude of sound at a distance from a noise source. Tonal noise contains one or more prominent tones (i.e. distinct frequency components), and is normally regarded as more offensive than broad band" noise. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 2 of 30

92 Table of Contents 1 Introduction Purpose and application Objectives Content Monitoring and auditing the plan Environmental obligations Statutory obligations Conditions of approval Legislation Permits, licences and approvals Other obligations Roads and Maritime specification G36: environmental protection Environmental policies, guidelines and principles Existing environment Noise sensitive receivers Vibration sensitive receivers Noise mitigation infrastructure Changes introduced under the operational noise compliance review Operational noise review Unexpected findings Operational noise monitoring Noise and vibration control measures Overview Operation and maintenance activities Management controls Operational noise compliance review Non-routine operational noise and vibration monitoring Controls Community communications and complaints management Training and awareness Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 3 of 30

93 1 Introduction 1.1 Purpose and application This document comprises the Noise and Vibration Management Sub-plan (OEMPSP1). It applies to all activities with the potential to: Generate noise that may affect adjacent sensitive receivers Generate vibration that may cause cosmetic or structural building damage or result in amenity impacts Result in a change in operational road traffic noise. OEMPSP1 also considers the: Maintenance and the ongoing effectiveness of noise mitigation infrastructure (e.g. noise walls) Equipment maintenance to ensure its noise and vibration performance is in line with manufacturer specifications and tolerances. The OEMPSP1 forms part of the asset Operational Environmental Management Plan (OEMP). 1.2 Objectives The plan s objectives are: Manage all activities to ensure they do not harm or impact on noise and vibration sensitive receivers or affect building integrity Ensure activity-based noise and vibration does not exceed guidance limits Work under a target of not receiving any noise or vibration complaints Ensure all noise and vibration mitigation infrastructure is maintained and effective. 1.3 Content The plan provides for the following provisions: Noise control during maintenance and repair work Vibration control during maintenance and repair work Equipment maintenance Maintenance of noise mitigation infrastructure Management of operational road traffic noise Operational noise compliance and assessment. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 4 of 30 Commercial in Confidence

94 2 Monitoring and auditing the plan OEMPSP1 will be assessed and reviewed in accordance with section 1.3 and section 10.1 of the OEMP. Specifically, it will be reviewed: In preparing for a change in: Legislation or regulation Licencing or approval conditions Operations or staff. Following: Routine inspections, monitoring and audits where there is an associated observation, corrective action, and/or environmental improvement notice issued (refer to section 9.7 of the OEMP) An incident or emergency (refer to section 8.2 of the OEMP) A recorded noise/vibration exceedance Persistent noise/vibration complaints Continuous non-conformance. Otherwise the plan will be audited, reviewed and modified annually. Periodic site inspections, as described in Chapter 9 of the OEMP, will also be used to review environmental performance. Where there is inconsistency between the plan s intention and the inspection/audit findings, the management procedures and protocol will be reviewed and amended as necessary to ensure continuous improvement. Reviews will comprise: documentation Observing procedure and protocol onsite Issuing corrective actions or environmental improvement notices Re-auditing performance once the corrective actions/improvement notices have been implemented. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 5 of 30

95 3 Environmental obligations This section summarises the legal, environmental, and contractual obligations covered by this OEMP. 3.1 Statutory obligations This sections describes the statutory and other obligations covering the operational asset Conditions of approval The requirement to operate under a noise and vibration management sub-plan is in response to Minister for Planning Condition of Approval MCoA E8-Fi, which states that: Details of how environmental performance would be managed and monitored to meet acceptable outcomes, including what actions will be taken to address identified potential adverse environmental impacts, including those safeguards and mitigation measures. In particular, the following environmental performance issues shall be addressed in the OEMP: noise and vibration. Table 3.1 summarises the relevant conditions relating to noise and vibration management. Table 3.1: Relevant operational Ministerial conditions of approval MCoA Details Responsibility Reference E1 Operational noise E5 Operate the asset in accordance with the requirements and objectives of the NSW Road Noise Policy (NSW DECCW, 2011). Operational noise compliance Within 12 months of the commencement of operation of the SSI, or as otherwise agreed by the Secretary, the Proponent shall undertake operational noise monitoring to compare actual noise performance of the SSI against noise performance predicted in the review of noise mitigation measures required by MCoA E2, and prepare an operational noise compliance report to document this monitoring. The Report shall include, but not necessarily be limited to: a) Noise monitoring to assess compliance with the operational noise levels predicted in the review of operational noise mitigation measures required under MCoA E2 and documents specified under MCoA A2 of this approval b) A review of the operational noise levels in terms of criteria established in the NSW Road Policy (Department of Environment, Climate Change and Water, 2011) c) Methodology, location and frequency of noise monitoring undertaken, including monitoring sites at which SSI noise levels are ascertained, with specific reference to locations indicative of impacts on sensitive receivers d) Details on average daily traffic volumes on the widened M4 and impacted length of Parramatta Road during the daytime and night-time periods based on recorded observations e) Details of any complaints and enquiries received in relation to operational noise generated by the SSI between the date of commencement of operation and the date the report was prepared f) Any required recalibrations of the noise model taking into consideration factors such as actual traffic numbers and proportions SMC/O&M Contractor SMC/O&M Contractor OEMPSP1 Section 9.3 of the OEMP Control 5 in Table 6.2 Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 6 of 30

96 MCoA Details Responsibility Reference g) An assessment of the performance and effectiveness of applied noise mitigation measures together with a review and if necessary, reassessment of feasible and reasonable mitigation measures h) Identification of additional feasible and reasonable measures to those identified in the review of noise mitigation measures required by MCoA E2, if required, that would be implemented with the objective of meeting the criteria outlined in the NSW Road Policy (Department of Environment, Climate Change and Water, 2011), when these measures would be implemented and how their effectiveness would be measured and reported to the Secretary and the EPA. The Proponent shall provide the Secretary and the EPA with a copy of the operational noise report within 60 days of completing the operational noise monitoring referred to in (a) above or as otherwise agreed by the Secretary. Note: this is consistent with mitigation commitment NV-4 as described in the approved project submissions report, Legislation The following legislation is relevant to OEMPSP1. Table 3.2: Legal obligations Legislation Relevance General Environment Planning and Assessment Act 1979 Application of penalty notices where MCoA are breached including noise exceedances and complaints Local Government Act 1993 Prevention of public nuisance from noise pollution Noise and vibration Protection of the Environment Operations Act 1997 Protection of the Environment (Noise Control) Regulation 2008 (as amended) Defines and controls noise pollution Noise and vibration management Regulates vehicle emissions including exhaust noise and car alarms Permits, licences and approvals The asset does not routinely operate under any additional permits, licences and/or approvals. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 7 of 30

97 3.2 Other obligations Roads and Maritime specification G36: environmental protection Under the O&M deed, the is required to develop and environmental management plan (EMP) that meets the requirements of Roads and Maritime s quality assurance specification G36: Environmental Protection (Roads and Maritime, 2016) Environmental policies, guidelines and principles Roads and Maritime and other Government agencies have developed guidance and policy for managing noise and vibration. The O&M stakeholders will work under this guidance and policy: Table 3.3: Environmental policies, guidelines and principles Legislation Relevance General operations and maintenance Interim Construction Noise Guidelines (ICNG, NSW DECC, 2009) Construction Noise Strategy (CNS, Transport for NSW, 2013) Construction Noise and Vibration Guideline (CNVG, Roads and Maritime, 2016). British Standard BS :1993 Evaluation and Measurement for Vibration in Buildings. Guide to Damage Levels from Groundborne Vibration (British Standards Institution, 1993, adopted in the absence of equivalent local criteria) German Standard DIN Structural vibration - Effects of vibration on structures (adopted in the absence of equivalent local criteria). Assessing Vibration: A Technical Guideline (NSW DECC, 2006) Noise management when undertaking site work Vibration management when undertaking site work Fixed equipment Industrial Noise Policy (INP, NSW EPA, 2000). Maintenance of fixed equipment Road traffic noise Environmental Noise Management Manual (ENMM), Practice Note II and III (ENMM, Roads and Maritime, 2001) Road Noise Policy (RNP, NSW DECCW, 2011) Noise Criteria Guidelines (NCG, Roads and Maritime, 2015) Noise Mitigation Guidelines (NMG, Roads and Maritime, 2015). Management and monitoring on ongoing rod traffic noise Note: the NCG (Roads and Maritime, 2015) are Roads and Maritime s interpretation of the RNP (NSW DECCW, 2011). The NCG (Roads and Maritime, 2015), NMG (Roads and Maritime, 2015) and CNVG (Roads and Maritime, 2016) replace the ENMM (Roads and Maritime, 2001) except for Practice Note II and III. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 8 of 30

98 4 Existing environment 4.1 Noise sensitive receivers The following noise-sensitive receivers are close to the asset footprint. Table 4.1: Sensitive receiver types Sensitive receiver type Considered sensitive to construction noise (i.e. maintenance and repair work) Commercial premises Industrial facilities Other (such as cinemas, theatres). Considered sensitive to construction and operational noise (i.e. maintenance, repair and road traffic noise): Residents Educational institutions Child-care centres Hospitals and other medical facilities Places of worship Recreational areas Given the high number of sensitive receivers adjacent to the asset footprint they were grouped into noise catchment areas (NCAs) in the approved project EIS. Each NCA contained a representative number of similar receivers (i.e. commercial properties or residential properties). Rather than assessing the potential impact at each receiver, the impact was assessed at the closest receiver in the NCA. As shown in Figure 4.1, 19 NCAs were developed in the EIS. Table 4.2 summarises their characteristics. Table 4.2: Sensitive receivers NCA Minimum distance (metres) Characteristics Noise catchment areas NCA.A01_02N 20 Commercial receivers and open space north of the M4 Motorway between Bellona Avenue, Sydney Olympic Park and Birnie Avenue, Sydney Olympic Park. NCA.A01_02S 45 Commercial receivers south of the M4 Motorway between Kanoona Avenue, Homebush West and Bachell Avenue, Lidcombe. NCA.A01_04 95 Residential receivers and isolated commercial receivers south of Parramatta Road between Centenary Drive, Homebush West and the railway lines to the west and south. NCA.A02_01 90 Residential receivers south of the M4 Motorway between Bachell Avenue, Lidcombe and the canal to the west of Bombay Street, Lidcombe. NCA.A02_02N 10 Commercial receivers north of the M4 Motorway between Birnie Avenue, Lidcombe and Haslams Creek, Lidcombe NCA.A02_02S 12 Commercial receivers south of the M4 Motorway between Bachell Avenue, Lidcombe and Haslams Creek, Lidcombe. NCA.A02_03N 9 Residential receivers and isolated commercial receivers north of the M4 Motorway between Haslams Creek, Newington and Stubbs Street, Silverwater. NCA.A02_03S 18 Commercial receivers south of the M4 Motorway between Haslams Creek, Lidcombe and Stubbs Street, Auburn. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 9 of 30

99 NCA Minimum distance (metres) Characteristics NCA.A02_04 52 Residential receivers and isolated commercial receivers south of the M4 Motorway, north of Parramatta Road, either side of Melton Street South, Auburn. NCA.A02_05N 3 Commercial receivers north of the M4 Motorway between Skarratt Street, Silverwater and James Ruse Drive, Rosehill. NCA.A02_05S 5 Commercial receivers south of the M4 Motorway between Stubbs Street, Auburn and James Ruse Drive, Clyde. NCA.A02_06 40 Residential and commercial receivers north of the M4 Motorway between Stubbs Street, Silverwater and Newton Street North, Silverwater. NCA.A02_07N 6 Residential receivers and isolated commercial receivers north of the M4 Motorway between James Ruse Drive, Rosehill and Church Street, Granville. NCA.A02_07S 7 Residential receivers and isolated commercial receivers south of the M4 Motorway between James Ruse Drive, Clyde and the railway lines adjacent to Victoria Street, Granville. NCA.A03_01N 21 Commercial receivers north of the M4 Motorway either side of Church Street, Granville. NCA.A03_01S 3 Commercial receivers south of the M4 Motorway between Gough Street, Holroyd and the railway lines adjacent to Victoria Street, Granville. NCA.A03_02N 21 Residential receivers north of the M4 Motorway between Church Street, Granville and Pitt Street, Granville. NCA.A03_02S 46 Residential receivers south of the M4 Motorway between Fox Street, Holroyd and Pitt Street, Holroyd NCA.A03_ Residential receivers and isolated commercial receivers either side of Woodville Road, Holroyd south of the railway lines. Other individual receivers NCA.A01_02N 50 Open space (passive) Wentworth Reserve, Wentworth Road South, Homebush 60 Open space (active) Sydney Olympic Park Tennis Centre, Rod Laver Drive, Sydney Olympic Park 100 Open space (active) Sydney Olympic Park Hockey Centre, Shirley Strickland Drive, Sydney Olympic Park NCA.A02_03N 20 Open space (passive) Deakin Park, Beaconsfield Street, Silverwater 245 Place of worship the Korean Martyrs and St. Stanislaus Catholic Church, 26 Carnarvon Street, Silverwater. NCA.A02_03S 60 School Auburn North Public School, 100 Adderley Street West, Auburn NCA.A02_03S 500 School Auburn Girls High School, Hunter Street, Auburn 300 Place of worship Roger Page Church, 85 Macquarie Road, Auburn NCA.A02_07N 240 School St. Oliver s Primary School, 33 Wigram Street, Harris Park NCA.A02_07S 220 Place of worship church buildings, 66 Good Street, Granville NCA.A03_01S 10 Open space (active) Holroyd sports ground, Robert Street, Holroyd Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 10 of 30

100 Figure 4.1 Noise sensitive receivers 4.2 Vibration sensitive receivers The guidelines referred to in Table 3.4 describe recommended safe working distances to avoid vibration impacts from typical construction plant. They are: 75 metres to prevent cosmetic building damage (excluding heritage-listed structures) 100 metres to prevent amenity-related (human comfort) impacts. As such, the majority of the NCAs and receivers described above are also considered vibration sensitive in terms of any site work as per Assessing Vibration: A Technical Guideline (NSW DEC, 2006) and the CNVG (Roads and Maritime, 2016). 4.3 Noise mitigation infrastructure Section of the approved project EIS predicted that in upgrading the M4 Motorway about 740 residential properties and 50 non-residential receivers would be eligible for noise treatment by The approved project EIS also described the mitigation controls that needed installing within and adjacent to the asset footprint to reduce noise levels at the receivers described in the previous section. Specifically, the RNP (NSW DECCW, 2011) and NMG (Roads and Maritime, 2015) define four types of mitigation that can be applied to reduce operational noise impacts as being: Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 11 of 30

101 Road design and traffic management Low noise pavement surfaces In-corridor noise barriers and mounds At-property treatments or local barriers and mounds. Under the approved project, the following noise treatment measures were included: Low noise pavement surfaces within the extent of the asset footprint A composition of new and upgraded noise barriers in the locations shown on Figure 4.2 At-property treatments. The barriers locations on Figure 4.2 show where: Existing barriers have been retained Existing barriers have been supplemented New barriers were built. The noise barriers were built to heights of up to six metres. This provided sufficient noise reduction to comply with the RNP (NSW DECCW, 2011). There were 325 receivers that were classified as eligible for acoustic treatment work, including one school and one day care centre. The rest were residential housing (units and houses). Figure 4.2 shows the property treatment maps presented in Appendix I of Appendix E of the approved project EIS and the barrier locations. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 12 of 30

102 Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 13 of 30

103 Figure 4.2 Noise treatment maps and barrier locations 4.4 Changes introduced under the operational noise compliance review Operational noise review The controls described in section 4.3 were identified mitigate for the above predicted impacts. However, the assessment was clear in identifying the inherent limitations and inaccuracies in noise modelling. For that reason, Roads and Maritime committed to undertake an operational noise review (mitigation measure NV-4, refer to Table 3.1 above and section 9.3 of the OEMP) within 12 months of the upgraded road operating. The review will: Monitor noise in a number of agreed locations to confirm the baseline Compare actual noise performance against predicted noise performance (i.e. assess compliance with the operational noise levels) Assess the performance and effectiveness of the noise treatment measures and confirm if they need adjusting or supplementing Identify the need for any additional feasible and reasonable noise mitigation measures consistent with the NMG (Roads and Maritime, 2015). This monitoring and reporting will be completed by the end of Q providing the asset is operational by Q Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 14 of 30

104 4.4.2 Unexpected findings If the operational noise review verifies the noise to be less than predicted, SMC will consult NSW EPA and the DP&E to identify and agree if any mitigation controls or management measures can be relaxed over time. Conversely, if the operational noise review results verify there to be more receivers subject to noise levels that are higher than predicted then SMC will undertake additional monitoring and: The noise monitoring data will be reviewed The prediction methods will be reviewed The existing controls will be reviewed and revised Corrective action will be implemented. As the asset continues to operate the surrounding environment and land uses will change. As such new receivers may be introduced. However, there will be no legal responsibility on SMC to provide noise treatment for future development or land use changes. However, there will be an obligation on all O&M stakeholders to manage and control noise and vibration when undertaking site work, as allowed for in Chapter 5. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 15 of 30

105 5 Operational noise monitoring The will undertake operational noise monitoring, provisioned under its EMP. Table 5.1 lists the locations selected for monthly monitoring. Table 5.1: Noise monitoring locations Address 6 Welfare Street, Homebush 3 Courallie Avenue, Homebush West 135 Delhi Road, Lidcombe 8 Spritz Avenue, Newington 21 Barker Avenue, Silverwater 7080 Adderley Street West, Auburn 87 Deakin Street, Silverwater 25A Arthur Street, Granville 9 A Beckett Street, Granville 55 Railway Street, Granville 8 Gough Street, Holroyd Table 5.2 describes the type, frequency and duration to the noise and vibration monitoring that the undertakes onsite. Table 5.2: Monitoring and inspection Monitoring details Record Frequency Test procedures Inspections Inspection of works to ensure that noise & vibration mitigation measures are being implemented on site. Noise monitoring Noise monitoring at monitoring locations identified in Table 5.1. Where complaint is received and monitoring is considered an appropriate response to determine if noise levels exceed predicted operational noise levels Environmental inspection checklist Noise Monitoring Record Noise monitoring record Weekly Monthly As required Nil If monitoring cannot be undertaken at the nearest relevant sensitive receiver, a suitable representative location will be selected. The testing method includes: Sound level meter configured for Fast time weighting and A frequency weighting Test environment free from reflecting objects where possible. Where noise monitoring is conducted within 3.5 metres of large walls or a building facade, then a reflection correction of up to -2.5 db(a) will be applied to remove of increased noise due to sound reflections Tests will not be carried out during rain or when wind speed exceeds 5 m/s Conditions such as wind velocity and direction, temperature, relative humidity and cloud cover will be recorded from the nearest Bureau of Meteorology station or on-site weather station/observations Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 16 of 30

106 Monitoring details Record Frequency Test procedures Spot checks of noise intensive plant where it is required to check noise emission against manufacturer s specifications. Spot checks for worstcase noise impact scenarios or when new predicted high noise impact activities commence Where required for the purposes of refining methods or techniques to reduce noise levels. Vibration monitoring At start of vibratory compaction work within 50m of residential buildings. Where complaint is received and monitoring is considered an appropriate response. Where an activity may occur within safe working distances for cosmetic damage for no more than one day continuously. Where an activity may occur within safe working distances for cosmetic damage for a period of more than one day continuously. Noise monitoring record Noise monitoring record Noise monitoring record Vibration monitoring record Vibration Monitoring Record During normal servicing schedule As required As required As required As required The monitoring period should be sufficient such that measured noise levels are representative of noise over a 15-minute period At a minimum Leq, Lmax, L10 and L90 levels will be measured and reported. The observations of the person undertaking the measurements will be reported including audibility of construction noise, other noise in the environment and any discernible construction activities contributing to the noise at the receiver. Stationary test procedures according to AS Acoustics: Measurement of airborne noise emitted by earth-moving machinery and agricultural tractors Stationary test condition. The testing method includes: Sound level meter configured for Fast time weighting and A frequency weighting. The test environment will be free from reflecting object Tests will not be carried out during rain or when wind speed exceeds 5 m/s In accordance with AS , a minimum of three measurement points will be defined at locations on the hemispherical surface around the plant with the radius determined by the basic length of the machine The A-weighted Leq background noise at the measurement locations will be at least 6 db and preferably 10 db below the level with the plant operating Both Leq and L10 levels will be measured and reported. Attended vibration monitoring will be undertaken when checking the safe working distances from construction plant (e.g. compaction plant) or in response to a complaint. The testing method includes: Monitoring to be conducted for at least three distances from the plant, including a representative distance for the nearest sensitive structures and/or receivers The testing will be conducted at each location to obtain a suitable representation of the range of vibration levels that would occur from the tested plant The plant will be tested in the settings in which it is expected to operate. For vibratory rollers this may include both High and Low settings Peak partial velocity (PPV) vibration levels and the dominant frequency of the vibration will be recorded for assessment against the structural and cosmetic damage criteria. In situations in which human comfort is also of concern then the root mean square vibration level should also be recorded. Continuous vibration monitoring will be undertaken where vibration from a construction activity may exceed cosmetic damage criteria at a sensitive structure, where activities may occur within safe working distances for cosmetic damage. The testing method includes: Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 17 of 30

107 Monitoring details Record Frequency Test procedures Vibration logger to continuously measure vibration while relevant works are occurring within the safe working distance for cosmetic damage Measurement to be conducted as close as possible to the sensitive structure A warning system will be implemented including one or both of an audible and/or visual warning alarm, and/or SMS and/or alerts to O&M contractor personnel. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 18 of 30

108 6 Noise and vibration control measures 6.1 Overview The O&M Contractor will implement controls to ensure: Noise and vibration is managed for all planned activities All noise and vibration generating equipment is on an active maintenance schedule All noise mitigation infrastructure is on an active maintenance schedule Operational road traffic noise is managed Noise and vibration is managed during an incident and emergency. SMC will have overall responsibility for maintaining the asset to ensure it remains effective in managing operational noise and vibration. As such, the above will be supplemented by: Ensuring the asset and its associated equipment and infrastructure operates to its environmental performance specifications to control and abate noise and vibration Allowing for noise and vibration monitoring in instances where there is a substantiated complaint or there is evidence of any equipment and/or infrastructure fault or failure Allowing for revision in the mitigation controls following persistent issues and complaints Determining the need to maintain, replace or upgrade the noise mitigation infrastructure/controls if they are found to be unsatisfactory. The requirement to maintain, replace or upgrade any road or noise mitigation infrastructure may need approval either under Part 5 of the NSW Environmental Planning and Assessment Act 1979 or as a modification approval under Part 5.1 of the same Act. The must consult the SMC environmental manager to discuss the proposal to maintain, retain or upgrade any of this equipment and confirm what approvals will be required before its implementation. 6.2 Operation and maintenance activities Each O&M stakeholder is to annually prepare and update a schedule of activities that require the use of noise and vibration-generating equipment revising and/or supplementing the information in Table 6.1. For reference the O&M stakeholders comprise: Sydney Motorway Corporation (SMC): asset delivery and operation : asset maintenance and repair. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 19 of 30

109 Table 6.1: Noise and vibration generating activities Activity Routine maintenance/repair work Vegetation clearing and grubbing Pavement renewal and resurfacing Maintenance earthworks Drainage works Renewals General maintenance and repair work Responsibility Routine equipment maintenance Tolling equipment Mechanical and electrical equipment Road plant and machinery Maintenance vehicle fleet Routine noise mitigation infrastructure maintenance Noise wall, fencing and retaining walls Low noise pavement Note: O&M stakeholders are not responsible for maintaining off-site at-property treatments. Operational noise compliance MCoA E5 (refer to Table 3.1) Operational road traffic noise management Non-routine (incident/emergency) work SMC/ SMC SMC/O&M Contractor The above activities will be managed under the relevant guidelines presented in section and in accordance with the relevant legal provisions in section Management controls This section sets out the controls (and monitoring) that will be implemented to manage noise and vibration impacts form the above activities. These controls satisfy MCoA E5, MCoA E8 and G36: environmental protection, specification 4.6 (refer to Chapter 4 of the OEMP) Operational noise compliance review As described in section 4.4.1, SMC will prepare an operational noise review with support and input from the, to confirm the actual noise impacts of the operational road against the predictions of the approved project EIS (refer to Control 5 in Table 6.2) Non-routine operational noise and vibration monitoring The will undertake noise and vibration monitoring at, or at a location representative of, the complainant where there has been a legitimate grievance to ensure the asset is operating to satisfy the operational requirements of the RNP (NSW DECCW, 2011). Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 20 of 30

110 6.3.3 Controls Table 6.2 lists the management control steps that will be implemented to plan, manage, monitor and review environmental performance. Table 6.2: Environmental controls Step Requirement Responsibility Control 1: Noise generated during planned site work Notes: the following procedure would be used for all routine planned site work. This includes activities that are undertaken frequently (e.g. more than once per quarter, such as vegetation management) and activities that are undertaken infrequently (e.g. once every five years, such as pavement and water quality basin renewal). The s EMP will be used to manage noise during planned routine activities. The EMP will be reviewed and updated annually. Regardless of the above differences, the same steps will be followed. 1.1 Map noise sensitive receivers relative to the work locations. O&M stakeholders Note: the location and type of receivers may have changed due to development in the area. Therefore, there is the requirement to confirm the location and validity of all noise sensitive receivers. 1.2 Obtain baseline noise monitoring data where there are none available, or the data needs updating in light of changes in the local noise environment since 2013 (the date of the last monitoring). 1.3 Establish ambient conditions and associated noise management levels for each catchment area/receiver as per the CNVG (Roads and Maritime, 2016) 1.4 Prepare a schedule of all noise-generating activities associated with the planned routine site work (i.e. clearing, cutting, grinding). Determine the duration and location where the noise-generating activities are planned to take place. 1.5 Predict the noise levels that are expected during the planned routine site work and identify any activities/locations where there are expected to be noise management level exceedances and the potential to cause sleep disturbance if out of hours work is planned. 1.6 Either update the s EMP as part of the annual review, otherwise prepare an activity specific SOP to describe the relevant controls that will be implemented to manage predicted noise exceedance for the planned routine site work. O&M stakeholders O&M stakeholders SMC operations and safety manager O&M stakeholders Note: The level of assessment required by the CNVG (Roads and Maritime, 2016) varies according to the number of receivers affected and the duration of the works. 1.7 Undertake additional monitoring in locations where routine work requires the prolonged removal of noise walls and barriers to determine the impact on adjacent receivers; as per the CNVG (Roads and Maritime, 2016), and the RNP (NSW DECCW, 2011) for road traffic noise. Introduce additional controls such as restricted working hours and/or the use of temporary shields or walls where the assessment predicts likely impacts on the above receivers. 1.8 Include noise management measures in the s EMP or activity specific SOP as required. These measures need to respond to the work schedule and the requirements for out of hours work. Generally, the provisions of the procedure to avoid vibration impacts will involve some of all of the following controls: Provide onsite training through inductions and toolbox talks as per Chapter 6 of the OEMP. Position the work (or equipment) away from noise-sensitive receivers. Maintain entry and exit points to any work sites away from noise sensitive receivers. O&M stakeholders SMC/ Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 21 of 30

111 Step Requirement Responsibility Include additional temporary noise barriers and protection for the duration of the work. Substitute or revise the equipment schedule to favour using lower noisegenerating alternatives. Prevent equipment from idling and warming up. Minimise working in the same location or using the same plant on consecutive days/nights. Where feasible, undertake high noise-generating activities during the day. Limit or restrict the use of certain equipment at night. Prevent the use of reversing alarms at night unless there is a mandatory safety requirement. Ensure all equipment is fitted with suppression equipment, maintained in an efficient condition, and operated in an efficient manner. Include additional control devices where there are predicted noise exceedances despite the use of suppression equipment. Include additional measures where the work will involve the removal of noise barriers, walls or other treatment measures that would impact on adjacent receivers as per Control 1.7. Prevent loading and unloading away from sensitive receivers. Limit the use of noisy equipment operating simultaneously. Prevent the use of compression braking. When using tonal or impulsive equipment, allow three hours of operation followed by at least one hours respite. 1.9 Allow for ongoing noise monitoring during the work to ensure the activities achieve the predicted noise levels Revise the safeguards and management measures if the noise monitoring undertaken during the activity shows there to be an exceedance of the noise management levels Ensure that any out of hours work complies with G36: Environmental Protection (Version 3.0, Roads and Maritime, 2016), the CNVG (Roads and Maritime, 2016), or the relevant standards at the time. SMC environmental manager SMC environmental manager SMC environmental manager Control 2: Vibration generated during planned routine site work Notes: the following procedure would be used for all routine planned site work. This includes activities that are undertaken frequently (e.g. more than once per quarter, such as vegetation management) and activities that are undertaken infrequently (e.g. once every five years, pavement and water quality basin renewal). The O&M Contractor s EMP will be used to manage planned routine activities. The EMP will be reviewed and updated annually. Regardless of the above differences, the same steps will be followed. 2.1 Map vibration sensitive receivers relative to the work locations. O&M stakeholders Note: the location and type of receivers may have changed due to development in the area. Therefore, there is the requirement to confirm the location and validity of all noise sensitive receivers. 2.2 Prepare a schedule of all vibration-generating activities associated with the planned routine maintenance and repair work (i.e. jackhammering, piling, vibratory rolling). Determine the duration and location where the vibration-generating activities are planned to take place. 2.3 Establish safe working distances as described in the CNVG (Roads and Maritime, 2016) and the vibration limits within Assessing Vibration: A Technical Guidelines, BS 7385 and DIN Confirm if any planned routine work would take place closer than the safe working limits or would exceed vibration limits for heritage items stated in the above guidance. SMC operations and safety manager O&M stakeholders Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 22 of 30

112 Step Requirement Responsibility 2.4 Either update the s EMP as part of the annual review, otherwise prepare an activity specific SOP to describe the relevant controls that will be implemented to manage predicted noise exceedance for the planned routine site work. 2.5 Include vibration management measures in the s EMP or activity specific SOP as required. These measures need to respond to the work schedule and the requirements for out of hours work. Generally, the provisions of the procedure to avoid vibration impacts will involve some of all of the following controls: In the first instance, review the equipment schedule. Identify equipment alternatives (where possible) to remove the risk of cosmetic damage, human amenity impacts or the potential to cause sleep disturbance if the work is planned to take place at night. This will be achieved by selecting smaller equipment that generates less vibration. If the impact cannot be avoided, undertake a location-specific vibration assessment before starting work. Confirm locations where there is a regarded potential for vibration impacts. Consider building condition surveys for receivers that are located within the safe working distances before starting work. Consider the requirement for vibration monitoring during the work activity. Limit or restrict the use of certain equipment at night. Allow respite periods when using tonal or impulsive equipment. 2.6 Allow for ongoing vibration monitoring during the work to ensure the activities achieve the safe working distances. SMC environmental manager Note: Building condition surveys maybe needed before and after vibration intensive work to determine any damage or in response to community concerns. 2.7 Revise the safeguards and management measures if the vibration monitoring undertaken during the activity shows there to be an exceedance of the limits. Review the impacts caused by the exceedance should be undertaken to determine if damage has occurred to sensitive receivers. 2.8 Ensure that any out of hours work complies with the quality assurance requirements specified in the Roads and Maritime specification G36: Environmental Protection (Roads and Maritime, 2016) and the CNVG (Roads and Maritime, 2016), or the relevant standards at the time. SMC environmental manager SMC environmental manager Control 3: Routine equipment maintenance Notes: this control will apply to all noise-generating equipment onsite. This includes mobile equipment, plant and machinery that will be used to undertake routine site work, which is the responsibility of the O&M Contractor. The noise monitoring results will be compared against the performance rating limits (sound power levels), and previous monitoring data, to ensure the equipment is functioning properly and within manufacturer specifications. The monitoring will take place during a typical operating cycle. 3.1 Prepare a schedule of all noise generating plant and equipment associated with the asset and determine the sound power levels of each item. Update the schedule annually or following a change in operations, equipment, or legislation. 3.2 Fixed equipment: either annually, following a complaint, or a change in operations, monitor the noise generated at the nearest sensitive receiver, the complainant s property or a representative location to ensure that the sound pressure levels meet the criteria of the INP (NSW EPA, 2000). 3.3 Mobile equipment: either once per quarter, following a complaint, or change in maintenance or repair activities, monitor the noise generated within specified set distances from the equipment or otherwise at the complainant s property or a representative noise sensitive location to ensure that the corresponding sound pressure level meets the criteria of the INP (NSW EPA, 2000). SMC asset manager SMC asset manager Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 23 of 30

113 Step Requirement Responsibility Non-compliance 3.4 Where the monitoring shows non-compliance with the INP (NSW EPA, 2000) criteria, prepare a letter, report or describing the current noise emissions compared with the initially measured sound power levels obtained under Control 3.1 and the reason for the non-compliance. The letter/report/ will also detail the conditions when the monitoring was undertaken, including operating configuration and meteorological conditions and confirm the reason(s) for any departure between the monitoring results, the sound power levels determined in Control 3.1 and the resultant sound pressure levels measured at the compliance point, allowing for natural fluctuations and expected real world variations. Identify any non-conformances or failures to meet the fixed plant specification limits. 3.5 Prepare an equipment noise SOP describing what is required to improve the noise performance of the equipment ranging from (a) maintenance, (b) equipment replacement, and/or (c) the introduction of additional noise controls. SMC asset manager SMC asset manager 3.6 In preparing the procedure, review the OEMP and this sub-plan. SMC environmental manager and SMC asset manager 3.7 Submit the procedure outlining the relevant issues. Given that the procedure is a summary of the requirements, and the urgency of the situation, it should take no longer than two working days to prepare and submit. SMC Asset Manager Regulatory notification 3.8 Review the procedure to ensure all requirements can be reasonably implemented. Additional advice will be sought if required. SMC asset manager 3.9 Review the procedure to confirm if regulatory notification is required. SMC general manager 3.10 If regulatory notification is required, complete a standard notification letter. SMC environmental manager 3.11 Forward the draft notification letter, procedure and preliminary report for review, and consider any amendments. SMC environmental manager 3.12 Forward the signed notification letter to the relevant regulator SMC general manager 3.13 Keep the notification letter, procedure and preliminary assessment in the SMC IMS SMC environmental manager Implementing the equipment noise standard operating procedure 3.14 Modify the procedure to take into account any additional regulatory advice and comments. SMC environmental manager 3.15 Implement the procedure. SMC general manager 3.16 Undertake short-term noise monitoring during a typical operational cycle at the source and at adjacent noise-sensitive receivers (if required) to monitor the effectiveness of the procedure. SMC environmental manager Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 24 of 30

114 Step Requirement Responsibility 3.17 If the monitoring shows the procedure to be effective seek clarification in writing that its provisions are effective and should be adopted under the OEMP and this management sub-plan If the monitoring shows the procedure to be ineffective, the above steps must be followed again from Control 3.4b and the provisions of the procedure must be revised or supplemented Maintain monitoring after the provisions of the procedure are implemented to determine compliance with the INP (NSW EPA, 2000) criteria. If there is any change in the monitoring levels, consider revising or relaxing the management plan controls. Conversely, if the noise management levels are not met at any time then the above steps must be followed again from Control 3.4b. SMC environmental manager SMC environmental manager SMC environmental manager Control 4: Routine noise mitigation infrastructure maintenance Notes: this control will apply to the noise walls, barriers and mounds. While the asset includes low-noise surface pavement its maintenance will form part of the asset s overall maintenance schedule and the requirement for regrading, resurfacing and/or patching the road. The requirement to maintain, replace or upgrade any road or noise mitigation infrastructure may need development consent or approval. The relevant O&M stakeholders must consult the SMC environmental manager to discuss the proposal to maintain, retain or upgrade any of this equipment and confirm what approvals will be required before they are introduced. 4.1 List all noise management infrastructure on a maintenance schedule. Update the schedule annually or following a change in operations, equipment or legislation. 4.2 Either annually, following a complaint or infrastructure failure, monitor the noise at representative receivers that are/were treated by the noise infrastructure to determine compliance. 4.3a If the monitoring shows compliance, prepare a letter or memo confirming this. SMC asset manager Non-compliance 4.3b Where the monitoring shows non-compliance, prepare a letter, report or describing the current noise exceedances and the reason for the non-compliance. The letter/report/ will also detail the conditions when the monitoring was undertaken and confirm the reason(s) for any departure, allowing for natural fluctuations and expected real world variations. 4.4 Prepare a noise mitigation infrastructure repair SOP describing what is required to improve the noise performance of the infrastructure ranging from (a) maintenance/repair, (b) replacement, and/or (c) the introduction of additional infrastructure controls. SMC asset manager SMC environmental manager 4.5 Review the procedure to confirm if regulator notification is required. SMC general manager 4.6 If regulator notification is required, complete a standard notification letter. SMC environmental manager 4.7 Forward the draft notification letter, procedure and preliminary report for review, and consider any amendments. SMC environmental manager 4.8 Forward the signed notification letter to the relevant regulator. SMC general manager 4.9 Keep the notification letter, procedure and preliminary assessment in the SMC IMS. SMC environmental manager Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 25 of 30

115 Step Requirement Responsibility Implementing the noise mitigation infrastructure repair SOP 4.10 Modify the procedure to take into account any additional regulatory advice and comments. SMC environmental manager 4.11 Implement the procedure. SMC operations and safety manager 4.12 Undertake noise monitoring during typical operational conditions at representative locations to monitor the effectiveness of infrastructure repairs/additional controls If the monitoring shows the procedure to be effective seek clarification in writing that the management plan provisions are effective If the monitoring shows the procedure to be ineffective, this procedure must begin at Control 4.3b, and the management controls revised or supplemented Maintain monitoring after the provisions of the procedure are implemented to ensure they remain effective. If there is any change in the monitoring levels, consider additional (a) maintenance, (b) replacement, or (c) additional infrastructure controls. Conversely, if the noise criteria are not met at any time, then this procedure should be repeated from Control 4.3b. SMC environmental manager SMC environmental manager SMC environmental manager SMC environmental manager and O&M contractor Control 5: Operational noise compliance Notes: there will be a requirement to undertake noise monitoring within 12 months of operation in accordance with CoA E5 (refer to Table 3.1) 5.1 Within 12 months of operation (unless requested by DP&E) undertake operational noise monitoring at agreed locations. This will be supplemented with count data on the M4 Motorway and Parramatta Road to validate the noise levels. 5.2 Prepare an operational noise compliance report to document the noise monitoring. The report will at least include: The context, conditions, locations and frequency where the monitoring was undertaken and the likely reason(s) for any departure from the predicted values A statement of compliance or consistency with the predicted operational noise levels as described in Appendix E of the approved project EIS A discussion if and where the WestConnex strategic traffic model needs revising or recalibrating to account for variations in regional and local growth from the inputs to the existing model Where there is a non-compliance, review the effectiveness and performance of the introduced noise mitigation measures and infrastructure in accordance with operational noise review undertaken to be consistent with MCoA E2 (refer to Table 3.1), and the controls and assessment included in the EIS and submissions report consistent with MCoA A2 Complaints and enquiries received from the date of operation to the date the report is finalised, including the nature of the complaint, the action taken and any residual outcome (refer to section of the OEMP) Proposed additional feasible and reasonable measures to supplement the mitigation controls and infrastructure where the operational noise monitoring is inconsistent/shows an unexpected exceedance. This will include where the measures will be implemented, and how their effectiveness will be measured The report will be issued to DP&E and the NSW EPA 60 days of undertaking the monitoring. 5.3 Contact Roads and Maritime (Environment Branch) and discuss the need to revise or update the WestConnex strategic traffic model and noise model to respond to revised or higher-than-expected growth in the area than modelled originally. SMC environmental manager SMC environmental manager Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 26 of 30

116 Step Requirement Responsibility 5.4 Review the need for supplementary or additional noise mitigation controls consistent with the NMG (Roads and Maritime, 2015) in the event that the noise monitoring confirms an exceedance of the predicted modelling prepared for the EIS and/or during the detailed design (refer to MCoA E5). Prepare (if needed) and submit a supplementary noise mitigation strategy to NSW EPA and NSW DP&E. SMC environmental manager 5.5 Implement the confirmed and agreed supplementary noise mitigation strategy. SMC environmental manager 5.6 Undertake noise monitoring during typical operational conditions at representative locations to monitor the effectiveness of any additional noise mitigation. 5.7 If the monitoring shows the controls to be effective, seek clarification in writing from an acoustician (and the regulator if required). 5.8 If the monitoring shows the plan to be ineffective, this procedure must begin at Control 5.4 to revise and/or supplement the management controls. 5.9 Maintain monitoring after the provisions of the supplementary noise mitigation strategy are implemented to ensure it remains effect. If there is any change in the monitoring levels, consider additional controls. Conversely, if the noise management levels are not met at any time then this procedure should be repeated from Control 5.4. SMC environmental manager SMC environmental manager SMC environmental manager Control 6: Non-routine (incident/emergency) work Notes: this control will be followed as part of the incident and emergency response process described in Chapter 8 of the OEMP. The following control steps will only be introduced where it is safe to do so. They will also only be introduced where there is time to respond to the incident or emergency. In an event where the response is immediate to avoid any risk to human life, property and the environment, then it may not be feasible or reasonable to undertake the following control steps. Control 6 will be supported by Control 3 to ensure that the equipment used during an incident or emergency is well-maintained within manufacturer specifications. Training and prevention 6.1 Undertaken incident management training as part of the compliance, training and awareness measures described in Chapter 6 of the OEMP. This will include measures to: Identify potential incidents and emergencies that would involve the use of noisegenerating equipment Assess the likelihood of the incident or emergency occurring to determine the potential need to use noise and vibration generating equipment Eliminate any risk for noise and vibration complaints during an incident and emergency by maintaining fixed and mobile equipment as per Control 3 Train staff in the correct use of noise and vibration generating equipment in an incident and emergency situation. Management 6.2 Where it is safe to do so, set up mobile acoustic screens or equipment shields around equipment used in an incident and emergency. 6.3 Where there is time, and noise and vibration generating equipment is used for more than 24-hours, update the mobile road signage and website to notify the community of the expected higher levels of noise and vibration and the length of time it is likely to last. 6.4 Brief the person/people manning the 24-hour telephone number and address of the incident and emergency so that they can respond to any complaints quickly. Consider using automated messaging or providing a mail shot to the community to communicate the incident and emergency where the use of noise-generating response equipment is expected to last longer than 72-hours. SMC communications manager Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 27 of 30

117 Step Requirement Responsibility Continual improvement 6.5 Review the effectiveness of Control 6.1 to Control 6.4 as part of the incident and emergency response process review. This will include a review of the: Deployment of noise and vibration controls Nature and extent of noise and vibration queries and complaints Effectiveness of the communication and consultation responsiveness during the incident and emergency. 6.6 Update this management sub-plan, the OEMP, community communications strategy (community relations plan, refer to section of the OEMP) and s EMP based on the review undertaken in Control 6.1. SMC environmental manager SMC environmental manager and O&M contractor Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 28 of 30

118 7 Community communications and complaints management In accordance with section of the OEMP, this management sub-plan will operate under a community communications strategy (community relationship plan) that includes: A 24-hour community hotline for complaints and queries Liaison with the community ahead of undertaking any work that is likely to cause impact by giving them at least two weeks prior notice, unless it is an incident or emergency situation Carrying out the community notification requirements as per Chapter 7 of the OEMP Controlling and managing the outcome of complaints through the procedure discussed in section of the OEMP. 8 Training and awareness All O&M stakeholders will be trained and made aware of management requirements before (planning for), during (undertaking) and after (reporting) any activity. The training will form part of induction requirements, toolbox talks, meetings and subcontractor requirements, as discussed in Chapter 6 of the OEMP. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP1: noise and vibration management sub-plan Page 29 of 30

119 OEMPSP2: Traffic and transport Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 58 of 61

120 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan OEMPSP2: Traffic and Transport Management Sub-plan April 2017 Sydney Motorway comprises Sydney Motorway Corporation (ACN ) and its controlled entities

121 Table of Contents Definitions Introduction Purpose and application Objectives Content Monitoring and auditing the plan Environmental obligations Statutory obligations Conditions of approval Legislation Permits, licences and approvals Other obligations Environmental policies, guidelines and principles Existing environment General characteristics Freight and commercial vehicles Commuters, public transport and active transport Network conditions Traffic and transport control measures Overview Operation and maintenance activities Management controls Other stakeholders/external agencies Community communications and complaints management Training and awareness Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 1 of 13

122 Definitions Term DP&E EMP EPA EIS IRP IRProc MCoA O&M O&M Activities O&M stakeholders OEMP OEMPSP2 OEMPSP4 SMC SMC IMS TMP IRP Definition Department of Planning and Environment O&M Contractor s Environmental Management Plan NSW Environment Protection Authority Environmental Impact Statement Incident Response Plan Incident Response procedure Minister for Planning Condition of Approval Operation and Maintenance All activities required to undertake the operation and maintenance of the M4 West Motorway All entities undertaking operational and maintenance activities on the asset. Typically including SMC and the and other sub-contracted parties. Operation Environmental Management Plan Traffic and Transport Management Sub-plan Surface Water Quality and Hydrology Management Sub-plan Sydney Motorway Company, a special purpose entity that has been created by the NSW Government to manage the delivery of WestConnex. Contains the policy, practices, and procedures for operating, maintaining and repairing WestConnex, which includes relevant environmental management information including the OEMP and this OEMPSPs Traffic Management Plan Incident Response Plan Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 2 of 13 Commercial in Confidence

123 1 Introduction 1.1 Purpose and application This document comprises the Traffic and Transport Management Sub-plan (OEMPSP2). It applies to all activities with the potential to: Cause traffic delays on the M4 Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush (the asset) and surrounding roads Affect operation of the tolling and intelligent transport systems Involve work on the operational asset. The OEMPSP2 therefore includes: Operation: the control and management of: Motorised and non-motorised traffic on the M4 Motorway Toll infrastructure Intelligent Transport Systems. Maintenance and repair: the control and management of: Pavement work Bridges, structures, interchanges and intersections Toll infrastructure Intelligent Transport Systems. Incident management: following a road traffic accident. The OEMPSP2 forms part of the Operational Environmental Management Plan (OEMP). 1.2 Objectives The plan s objectives are: Manage activities to ensure they do not harm or impact on the operational network performance and journey reliability of the M4 Motorway Ensure traffic and transport activities associated with the operational asset do not harm or impact on sensitive receivers Ensure maintenance and site vehicles are operated to reduce their amenity impacts on adjacent residents, road users, and other sensitive receivers Implement effective traffic management controls to: restrict sensitive turning movements; provide for directional traffic flows onsite and offsite; and prevent and restrict access when working onsite Work to a target of not receiving any traffic complaints Provide adequate provisions for laydowns, parking, loading and unloading when maintaining the asset Provide logistics management to ensure there is no undue delays or congestion when maintaining the asset Ensure all traffic management control infrastructure is maintained and effective. 1.3 Content The plan provides for the following provisions: Traffic, transport and access management during: Routine and non-routine operations Maintenance and repair work. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 3 of 13

124 2 Monitoring and auditing the plan OEMPSP2 will be assessed and reviewed in accordance with section 1.3 and section 10.1 of the OEMP. Specifically, it will be reviewed: In preparing for a change in: Legislation or regulation Licencing or approval conditions Operations or staff. Following: Routine inspections, monitoring and audits where there is an associated observation, corrective action, and/or environmental improvement notice issued (refer to section 9.7 of the OEMP) An incident or emergency (refer to section 8.2 of the OEMP) Continuous non-conformance. Otherwise the plan will be audited, reviewed and modified annually. Periodic site inspections, as described in Chapter 9 of the OEMP, will also be used to review environmental performance. Where there is inconsistency between the plan s intention and the inspection/audit findings, the management procedures and protocol will be reviewed and amended as necessary to ensure continuous improvement. Reviews will comprise: documentation Observing procedure and protocol onsite Issuing corrective actions or environmental improvement notices Re-auditing performance once the corrective actions/improvement notices have been implemented. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 4 of 13

125 3 Environmental obligations This section summarises the legal, environmental, and contractual obligations covered by this OEMP. 3.1 Statutory obligations This sections describes the statutory and other obligations covering the operational asset Conditions of approval The requirement to operate under a traffic and transport management sub-plan is in response to Minister for Planning condition of approval (MCoA) E8-Fii, which states that: Details of how environmental performance would be managed and monitored to meet acceptable outcomes, including what actions will be taken to address identified potential adverse environmental impacts, including those safeguards and mitigation measures. In particular, the following environmental performance issues shall be addressed in the OEMP traffic and transport. There are no conditions that are directly applicable to this sub-plan. Table 3.1 therefore summarises the conditions that indirectly refer to traffic and transport related inputs and outputs. Table 3.1: Relevant operational Ministerial conditions of approval MCoA Details Responsibility Reference B15 B17 E5 Transport and access Within 12 months of SSI approval prepare a road network performance mitigation plan in consultation with relevant Councils Transport and access Within 12 months of operation prepare a Hill Road options review for a westbound off-ramp and associated works at the Hill Road interchange. Operational noise compliance Completed - Not relevant to operational phase Roads and Maritime Services NA NA E6 Within 12 months of operation prepare an operational noise compliance report to compare the modelled predictions against the real world. As per Table 9.2 of the OEMP, the O&M contractor is required to provide recorded average daily traffic volumes on the widened M4 Motorway to support the compliance review. Transport and access SMC/ Section 9.3 OEMPSP1: noise and vibration The Proponent shall prepare an Operational Traffic Performance Review. The review shall be undertaken at 12 months and 5 years after the commencement of operation of the SSI, or as otherwise agreed by the Secretary. Note: this is consistent with mitigation commitment TT-9 as described in the approved project submissions report, Roads and Maritime Services NA Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 5 of 13

126 3.1.2 Legislation The following legislation is relevant to OEMPSP2. Table 3.2: Legal obligations Legislation Relevance Traffic and transport Roads Act 1993 Traffic management and working on public roads NSW Road Regulation 2008 Measures to protect traffic and provide public safety Permits, licences and approvals The asset does not routinely operate under any additional permits, licences and/or approvals. However, any O&M stakeholder would need to obtain a Road Occupancy Licence from the Transport Management Centre or relevant Council under section 138 of the NSW Roads Act 1993 if it intends to do the following planned work onsite: Erect a structure or carry out a work in, on or over a public road Dig up or disturb the surface of a public road Remove or interfere with a structure, work or tree on a public road Pump water into a public road from any land adjoining the road Connect a road (whether public or private) to a classified road. Such a licence is not needed if responding to an incident or emergency. Also, licences are typically not granted: Between 6am and 10am and 3pm and 7pm on weekdays During special events At times of other known peak traffic demand. The O&M stakeholders will obtain approval from Roads and Maritime and the relevant Authority before occupying, modifying or affecting any roads, footpaths or cycleway which are open to the public. 3.2 Other obligations Environmental policies, guidelines and principles Roads and Maritime and other Government agencies have developed guidance and policy for managing noise and vibration. The O&M stakeholders will work under this guidance and policy: Table 3.3: Environmental policies, guidelines and principles Legislation Relevance General operations and maintenance Guide to Traffic Management (Austroads, 2014) Guide to Traffic Generating Developments (Roads and Traffic Authority, 2002, as amended) Traffic Control at Work Sites (Version 4, 2010, Roads and Maritime) Traffic management and working on public roads Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 6 of 13

127 4 Existing environment Appendix D of the approved project EIS describes the traffic and transport conditions before the asset was upgraded and predicts how these would change following its upgrade. 4.1 General characteristics The M4 Motorway is about 40 kilometres long connecting the Blue Mountains in the west with Parramatta Road in the east. The main roads adjacent to the M4 Motorway include: The Great Western Highway Parramatta Road. The main roads that cross the M4 Motorway are: Silverwater Road Hill Road Homebush Bay Drive/Centenary Drive. Additional roads as a result of the upgrade include: James Ruse Drive 4.2 Freight and commercial vehicles The M4 Motorway remains important and essential for freight (heavy) and commercial (light) vehicles. About 37 per cent of all traffic travelling along the M4 Motorway are freight vehicles and the average number of weekday freight trips is expected to increase by 40 per cent between 2011 and 2031 The M4 Motorway carries more than double the proportion of work-related business trips compared to other parts of Sydney s road network. 4.3 Commuters, public transport and active transport The number of people commuting to and from work along the M4 Motorway during the peak periods is excessive, which has caused congestion and was one of the major factors contributing to the upgrade of the M4 Motorway. The Motorway also supports over 50 daytime bus routes. Cyclists are permitted to use the M4 Motorway and are also provided with a separated cycleway around the Homebush Bay Drive interchange and a shared use paths around Parramatta. While people are not permitted to walk along the M4 Motorway, there are footpaths along the roads that run adjacent and over/under the motorway. There are also a number of specific pedestrian-only crossings over the M4 Motorway. 4.4 Network conditions In 2012, collected survey data confirmed that it took about 15 minutes to travel between Church Street and Homebush Bay Drive in the morning peak period, however this could increase to 25 minutes during heavily congested periods. In the afternoon peak period this journey westbound would take about 23 minutes typically. This compares to the journey taking about eight minutes in either direction in the inter-peak (middle of the day). Also as of 2012, it was considered that the queuing and congestion on the M4 Motorway was significant, this being another driver for upgrading the road as part of the WestConnex scheme. Now that the M4 Motorway is upgraded and operational it is predicted that motorists would typically save up to nine minutes on their journey times between Church Street and Homebush Bay Drive. This is set to increase to 14 minutes eastbound and 10 minutes westbound once the whole WestConnex scheme becomes operational in The other expected change is a traffic reduction on the M4 Motorway as people avoid incurring the tolls. It predicts that there would be: About 3,350 vehicles per hour using the M4 Motorway in the morning peak period increasing to about 3,630 vehicles per hour once the whole WestConnex scheme is operational About 3,510 vehicles per hour using the M4 Motorway in the afternoon peak period increasing to about 3,820 vehicles per hour once the whole WestConnex scheme is operational. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 7 of 13

128 5 Traffic and transport control measures Overview The O&M stakeholders will implement controls to: Monitor operational traffic on the M4 Motorway Manage general road traffic during routine activities Manage general road traffic during incidents and emergencies Manage site traffic during routine activities. 5.2 Operation and maintenance activities Each O&M stakeholder is to annually prepare and update a schedule of activities that could potentially impact on traffic, transport and access, revising and/or supplementing the information in Table 5.1. For reference the O&M stakeholders comprise: Sydney Motorway Corporation (SMC): asset delivery and operation : asset operation, maintenance and repair. Table 5.1: Activities potentially impacting on traffic, transport and access Activity Routine operation Traffic operations and monitoring Toll equipment monitoring Intelligent Transport System monitoring Responsibility Routine maintenance/repair work Vegetation clearing and landscape management Litter and graffiti removal Stormwater system maintenance and repair Road infrastructure maintenance and repair Pavement renewal and resurfacing General maintenance and repair work Routine equipment maintenance Tolling equipment Intelligent Transport Systems SMC/ Non-routine operation Road traffic accidents and incidents Flooding SMC/ Non-routine maintenance and repair Asset damage (i.e. vehicle strike) Major spill including clean-up SMC/ The above activities will be managed under the relevant guidelines presented in section and in accordance with the relevant provisions of the legislation in section Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 8 of 13

129 5.3 Management controls This section sets out the controls (and monitoring) that will be implemented to manage traffic, transport and access impacts form the above activities. These controls satisfy MCoA E8 Fii. Table 5.2 lists the management control steps that will be implemented to plan, manage, monitor and review environmental performance. Table 5.1: Environmental controls Step Requirement Responsibility Control 1: Traffic monitoring The is responsible for continuously monitoring traffic conditions on the M4 Motorway. The inclusion of intelligent transport systems allows for the partial adjustment of traffic conditions on the motorway such as variable speed limits, ramp metering controls and use of the hard shoulder; all measures that help promote and maintain the operational traffic performance. Control 2: Traffic management during routine O&M activities O&M vehicles 2.1 Ensure that all O&M vehicles enter and leave any work areas and the maintenance depot (at Adderley Street, Auburn, immediately adjacent to Newton Street South) via designated routes that are restricted to main arterial roads including: M4 Motorway Church Street/Woodville Road James Ruse Drive Silverwater Road Hill Road Homebush Bay Drive. 2.2 Seek the approval of the SMC environmental manager to use additional roads. 2.3 Where feasible, do not permit site traffic movements through residential streets. Where this is not possible avoid movements during out-of-hours periods or peak times. Traffic management provisions 2.4 Seek road occupancy before undertaking any work requiring the need to excavate, disturb, remove, interfere, pump water into, or form a connection with a road. 2.5 Develop a specific Traffic Management Plan (TMP) covering controls relevant to the location and O&M activity taking place. The TMP will be prepared in accordance with the Traffic Control and Work Site Manual (Roads and Maritime, 2010) and quality assurance specification G10: Control of Traffic (Road and Maritime, 2010) and will include: Layout of plant, any required exclusion zones, loading areas and circulation requirements. Site arrival and pre-notification plans. Traffic volume estimates including vehicle type, frequency and timing of arrival to and departure from site. Traffic control plans showing access arrangements and the details of signs and devices. Vehicle management and movement plans showing entry and exit points. Controls to prevent traffic queuing on public roads. Pedestrian and cyclist management plans including diversions and temporary provisions to guide people through work areas. Measures to manage other road users including lane closures, diversions, and temporary speed restrictions. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 9 of 13

130 Step Requirement Responsibility Specified work hours, including restrictions on queuing on the motorway and/or in the local area. Response plans to any incident or emergency. Communication and notification plans. Any localised changes to existing traffic management arrangements. 2.6 Confirm site access points before starting work unless it is in response to an incident or emergency on the M4 Motorway. 2.7 Provide road users and the local community with two weeks notice before implementing any traffic management controls. 2.8 Ensure safe sight and stopping distances are provided to any work site to allow traffic to safely leave and join the road network. 2.9 Ensure all surfaces are properly maintained and in good condition Where work takes place on open or cleared ground, ensure vehicles are fitted with brushes, or are washed down to prevent the spread of mud onto the local road network Determine any placards or warning devices to be installed on heavy vehicles Brief drivers working onsite about: the above traffic management controls; TMP requirements; site entry, exit and circulation; and other safety measures. Control 3: Road traffic environmental incidents A road traffic environmental incident includes any unplanned and/or undesired event that results in, or has the potential to result in, environmental impairment, such as fuel spills, toxic chemical spills, problems with air quality or incidents involving water contamination. 3.1 Develop an Incident Response Plan (IRP) and Incident Response Procedures (IRProc) to deal with road traffic incidents. Ensure the IRP/IRProc includes: First response measures to ensure motorist and road user safety including road and lane closures, use of variable message warning signs and contacting the emergency services. Development of a Pollution Incident Response Management Plan to address the environmental risks associated with incidents. Training for personnel in dealing with potential environmental impacts (refer to Chapter 6 of the OEMP). Regular exercises on the implementation of the procedure and plans. Traffic management control procedures for a minor, moderate and major road traffic accident, including ongoing traffic management controls, safety provisions, environmental controls and notification requirements. Sets out other reporting and escalation processes. Protocol and authorisations to reinstating normal traffic operations on the motorway. Protocol for delivering environmental protection, including site clean-up, pollution control and abatement, with appropriate links to the controls in OEMPSP4: Surface Water Quality and Hydrology Management Subplan. Subsequent reporting processes, including lessons learnt, corrective actions and revisions to the IRP and associated procedures Provision for an annual drill in emergency and incident response. Control 4: Site traffic management during routine O&M activities Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 10 of 13

131 Step Requirement Responsibility 4.1 Ensure all site traffic operates within the defined speed limit of 10 km/h while operating on a maintenance site. 4.2 Ensure reversing alarms, or lights or spotters (if the work takes place in a noise sensitive area) are used, however the reversing alarms should not be used at night unless there is a mandatory safety requirement. 4.3 Implement a one-way traffic flow all work sites to guide traffic. 5.4 Other stakeholders/external agencies A number of external agencies have roles relating to road traffic environmental incident response and management. After identifying a major (significant) incident or emergency the is responsible for contacting the relevant agency as soon as practicable. Table 5.9: Roles of other stakeholders Organisation Role and responsibility Transport for NSW Transport Management Centre (TMC) Where appropriate, making adjustments to network traffic arrangements to facilitate prompt access by emergency services when required to respond to environmental incidents. Provision of relevant outer cordon traffic and traveller information. Providing reports to the media including details on the incident situations and response arrangements. Fire and Rescue NSW NSW Police NSW Ambulance NSW Environment Protection Authority (NSW EPA) Other agencies Fire and Rescue NSW is the responsible agency for managing environmental incidents involving: A major smoke, fire or explosion event Major flammable liquids Major natural disasters A major fuel, chemical or toxic spill event. NSW Police is the responsible agency for managing all other incidents/emergencies including on site, control and coordination of traffic and pedestrians during major environmental incidents NSW Ambulance will attend the incident site when requested, and provide emergency response to injured persons, including initial patient care and specialised transport services. NSW EPA personnel will become involved when incidents impact on environmental matters, such as fuel spills, toxic chemical spills, problems with air quality or incidents involving water contamination. Other agencies that may be involved in an environmental incident include: State Emergency Services (SES) Department of Planning and Environment (DP&E) Major Hazards Branch Local Emergency Management Committee (LMEC). Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 11 of 13

132 6 Community communications and complaints management In accordance with section of the OEMP, this management sub-plan will operate under a community communications strategy (community relationship plan) that includes: A 24-hour community hotline for complaints and queries Liaison with the community ahead of undertaking any work that is likely to cause impact by giving them at least two weeks prior notice, unless it is an incident or emergency situation Carrying out the community notification requirements as per Chapter 7 of the OEMP Controlling and managing the outcome of complaints through the procedure in section of the OEMP. 7 Training and awareness All O&M stakeholders will be trained and made aware of management requirements before (planning for), during (undertaking) and after (reporting) any activity. The training will form part of induction requirements, toolbox talks, meetings and subcontractor requirements, as discussed in Chapter 6 of the OEMP. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP2: traffic and transport management sub-plan Page 12 of 13

133 OEMPSP3: Visual amenity and landscaping Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 59 of 61

134 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan OEMPSP3: Visual Amenity and Landscaping Management Sub-plan April 2017 Sydney Motorway comprises Sydney Motorway Corporation (ACN ) and its controlled entities

135 Table of Contents Definitions Introduction Purpose and application Objectives Content Monitoring and auditing the plan Environmental obligations Statutory obligations Conditions of approval Legislation Permits, licences and approvals Other obligations Roads and Maritime specification G36: environmental protection Environmental policies, guidelines and principles Existing environment General characteristics Urban design Landscaping and planting Changes to the existing environment Visual amenity and landscaping control measures Overview Operation and maintenance activities Management controls Community communications and complaints management Training and awareness Annex A: Urban Design and Landscape Plan and Maintenance Plan Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 2 of 15 Commercial in Confidence

136 Definitions Term Asset DP&E EMP EPA EIS ESWMS MCoA O&M O&M Activities O&M stakeholders OEMP OEMPSP1 OEMPSP3 OEMPSP4 SMC SMC IMS SOP Definition M4 Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Department of Planning and Environment O&M Contractor s Environmental Management Plan NSW Environment Protection Authority Environmental Impact Statement Environmental Safe Work Method Statements Minister for Planning Condition of Approval Operation and Maintenance All activities required to undertake the operation and maintenance of the M4 Motorway All entities undertaking operational and maintenance activities on the Asset. Typically including SMC and the and other sub-contracted parties. Operation Environmental Management Plan Noise and Vibration Management Sub-plan Visual Amenity and Landscaping Management Sub-plan Surface Water Quality and Hydrology Management Sub-plan Sydney Motorway Company, a special purpose entity that has been created by the NSW Government to manage the delivery of WestConnex. Contains the policy, practices, and procedures for operating, maintaining and repairing WestConnex, which includes relevant environmental management information including the OEMP and this OEMPSP Standard Operating Procedure Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 3 of 15 Commercial in Confidence

137 1 Introduction 1.1 Purpose and application This document comprises the Visual Amenity and Landscaping Management Sub-plan (OEMPSP3). It applies to all activities with the potential to affect the general appearance, tidiness, condition and urban design of the M4 Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush (the asset). OEMPSP3 covers activities relating to vegetation planting and other remedial landscaping treatments. OEMPSP3 forms part of the Operational Environmental Management Plan (OEMP). 1.2 Objectives The plan s objectives are: Manage the general appearance, tidiness, condition and urban design of the asset to be consistent with its objectives as described in the WestConnex M4 Widening project EIS Monitor remedial vegetated areas post upgrade to ensure that they provide the intended screening, aesthetic, ecological, and amenity function Introduce further remedial measures to support struggling vegetation Ensure O&M stakeholders are trained in vegetation protection and the protection remnant vegetation, native vegetation, and other urban design and amenity features associated with the asset Ensure the SMC IMS contains relevant activities that contribute to maintaining and enhancing the landscape planting and urban amenity of the asset Ensure there are no light spill complaints Undertake routine site inspections to ensure weeds are identified, managed and removed. 1.3 Content The plan provides for the following provisions: Maintenance and repair of the asset to be consistent with its urban design Vegetation management and establishment to provide amenity, screening and buffering Light spill and management Protection of native and remnant vegetation Weed management The is to develop provisions under its EMP or otherwise prepare standard operating procedures (SOPs) to cover: Management of tannins from vegetated mulch Pesticide use Pesticide application record Grass and weed control Mowing operations Garden bed maintenance Litter control Noxious weed management Tree and shrub management Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 4 of 15 Commercial in Confidence

138 2 Monitoring and auditing the plan OEMPSP3 will be assessed and reviewed in accordance with section 1.3 and section 10.1 of the OEMP. Specifically, it will be reviewed: In preparing for a change in: Legislation or regulation Licencing or approval conditions The Asset Following: Routine inspections, monitoring and audits where there is an associated observation, corrective action, and/or environmental improvement notice issued (refer to section 9.7 of the OEMP) An incident or emergency (refer to section 8.2 of the OEMP) Continuous non-conformance. Otherwise the plan will be audited, reviewed and modified annually. Periodic site inspections, as described in Chapter 9 of the OEMP, will also be used to review environmental performance as will periodic inspections in the event that there is a concern about implementation or performance. Where there is inconsistency between the plan s intention and the inspection/audit findings, the management procedures and protocol will be reviewed and amended as necessary to ensure continuous improvement. Reviews will comprise: documentation Observing procedure and protocol onsite Issuing corrective actions or environmental improvement notices Re-auditing performance once the corrective actions/improvement notices have been implemented. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 5 of 15 Commercial in Confidence

139 3 Environmental obligations This section summarises the legal, environmental, and contractual obligations covered by this OEMP. 3.1 Statutory obligations This sections describes the statutory and other obligations covering the operational asset Conditions of approval The requirement to operate under a visual amenity and landscape management sub-plan is in response to Minister for Planning s conditions of approval (MCoA) E8-Fiii, which states that: Details of how environmental performance would be managed and monitored to meet acceptable outcomes, including what actions will be taken to address identified potential adverse environmental impacts, including those safeguards and mitigation measures. In particular, the following environmental performance issues shall be addressed in the OEMP: visual amenity and landscaping. Table 3.1 summarises the relevant conditions relating to noise and vibration management. Table 3.1: Relevant operational Ministerial conditions of approval MCoA Details Responsibility Reference E7 Urban Design and Landscape Plan The ongoing maintenance of urban design and landscaping items and works implemented as part of this infrastructure approval shall remain the Proponent s responsibility unless satisfactory arrangements have been put in place for the transfer of ownership of the item or work to another authority. The Proponent will maintain items and works to the standards established in the Urban Design and Landscape Plan required under condition B26, unless and until landscaping items have been transferred. O&M Contractor OEMPSP3 Under condition of approval B26 SMC prepared and implemented an urban design and landscape plan before construction work started to upgrade the road. Annex A includes the approved plan and the supporting landscape maintenance plan Legislation The following legislation is relevant to OEMPSP3. Table 3.2: Legal obligations Legislation Relevance Australian Standard (AS) Control of the Light spill Obtrusive Effects of Outdoor Lighting (Australian Standards, 1997) Noxious Weed Act 1993 Weed management and control Permits, licences and approvals The asset does not routinely operate under any additional permits, licences and/or approvals. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 6 of 15 Commercial in Confidence

140 3.2 Other obligations Roads and Maritime specification G36: environmental protection Under the O&M deed, the is required to develop and environmental management plan (EMP) that meets the requirements of Roads and Maritime s quality assurance specification G36: Environmental Protection (Roads and Maritime, 2016) Environmental policies, guidelines and principles Roads and Maritime and other Government agencies have developed guidance and policy for managing noise and vibration. The O&M stakeholders will work under this guidance and policy: Table 3.3: Environmental policies, guidelines and principles Legislation Relevance General operations and maintenance Draft WestConnex Urban Design Framework (Roads and Maritime, 2013) RMS QA Specification M3 (under M321 Landscape Maintenance) Bridge Aesthetic Guidelines (Roads and Maritime, 2012) Noise Wall Design Guidelines (Roads and Maritime, 2012) The Guidelines for Landscape Character and Visual Impact Assessment (EIA-N04, Roads and Maritime, 2013) Landscape Guidelines (Roads and Maritime, 2012) Beyond the Pavement (Roads and Maritime, 2014) G36: Environmental Protection (Roads and Maritime, 2016) G40: Clearing and Grubbing (Roads and Maritime, 2016) Landscape, urban design and vegetation management Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 7 of 15 Commercial in Confidence

141 4 Existing environment Appendix F of the approved project EIS describes the urban design for the upgraded M4 Motorway. 4.1 General characteristics The asset footprint is located within the urban environment of western Sydney. The landscape character of the area surrounding the M4 Motorway corridor can be characterised into seven zones as shown on Figure 4.1. The zones comprise a mixture of residential, commercial and industrial values. The zones in the east around Homebush are typically more commercial and industrial in character and therefore typically less sensitive to change and visual impact. Conversely, the western zones comprise more residential values and features that make them more sensitive to change and visual impact. 4.2 Urban design The WestConnex Urban Design Framework (Roads and Maritime, 2013) defined the built form objectives and provisions for the concepts of upgrading the M4 Motorway under the WestConnex scheme. As a result, the motorway has been upgraded to: Integrate sustainable principles into the planning and design while ensuring that a natural systems approach was adopted Create a strong, simple, legible and inspiring integrated engineering, urban design and environmental solution Minimise impacts on the local community while responding to their concerns and issue through developing a responsive design outcome Transform spaces into places and encourage improved lifestyle opportunities Create a bold language that provides identity to the motorway with a high-quality design. 4.3 Landscaping and planting Section 7 of Appendix F of the approved project EIS details the urban concept design and associated planting and landscaping strategy and principles, which include: Woodland/Cumberland Plain woodland: planted on new batter slopes and areas beyond floodplains/ creeks Riparian/river flat forest: used to reinforce creek and river lines Figs: new plantings at key locations to reinforce the existing planting and maintain local identity Indigenous shrubs: on batters, in narrow planting beds, and areas where trees cannot be planted close to the motorway Native grasses and tussocks: used as mass planting in key locations and as part of the median enhancements to improve overall setting and amenity Median enhancement: including streetscape improvements and enhancing median treatments to include eucalypts with an understorey of native shrubs, groundcover and/or tussocks. Also, the remnant native vegetation within the corridor has been retained and enhanced where feasible. Section 7.6 of Appendix F of the approved project EIS provides additional detail on the planting species mix. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 8 of 15 Commercial in Confidence

142 Figure 4.1: Landscape character zones 4.4 Changes to the existing environment As the asset continues to operate the surrounding environment and land uses will change. As such, the landscape character will change and new visually-sensitive receivers may be introduced. However, there will be no legal responsibility on SMC to provide screening and visual treatments for future development or land use changes. However, there will be an obligation on all O&M stakeholders to manage and control their activities when undertaking routine planned site work to reduce visual amenity impacts, as allowed for in Chapter 5. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 9 of 15 Commercial in Confidence

143 5 Visual amenity and landscaping control measures 5.1 Overview The O&M stakeholders will implement controls: To protect amenity and landscape values when undertaking routine planned activities relating to vegetation and landscape management Undertake additional vegetation and landscape remediation Ensure the protection of native and remnant vegetation Manage light spill Manage and control weeds. 5.2 Operation and maintenance activities Each O&M stakeholder is to annually prepare and update a schedule of activities that could potentially impact on visual amenity and landscape values, revising and/or supplementing the information in Table 5.1. For reference the O&M stakeholders comprise: Sydney Motorway Corporation (SMC): asset delivery and operation : asset operation, maintenance and repair. Table 5.1: Activities potentially impacting on visual amenity and landscape values Activity Routine maintenance/repair work Vegetation and landscape management Litter and graffiti removal Weed management General maintenance and repair work Batter slope and embankment management. Responsibility The above activities will be managed under the relevant guidelines presented in section and in accordance with the relevant provisions of the legislation in section Management controls This section sets out the controls (and monitoring) that will be implemented to preserve visual amenity and protect the landscape form the above activities. These controls satisfy CoA E8 (Fiii) and G40: Clearing and Grubbing (refer to section 4 of the OEMP). Table 5.2 lists the management control steps that will be implemented to plan, manage, monitor and review environmental performance. Table 5.2: Environmental controls Step Requirement Responsibility Control 1: General maintenance and repair work 1.1 Ensure the asset boundary and security fencing are inspected once every quarter to deter illegal dumping and trespass. 1.2 Undertake any boundary and security repairs within 24-hours of being notified of a breach or following an inspection. 1.3 Maintain the general tidiness and appearance of the asset on a routine proactive schedule. This is to ensure: Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 10 of 15 Commercial in Confidence

144 Step Requirement Responsibility Litter and waste is removed as part of the inspection process Orphan waste (i.e. illegally dumped materials or litter) is be classified in accordance with the NSW Waste Classification Guidelines (NSW EPA, 2014) to ensure it is managed, handled, stored, treated and disposed of in accordance with OEMPSP4 Should the waste or litter have potentially caused environmental harm this will be reported to NSW EPA in accordance with OEMPSP4 Should the waste or litter potentially contain pollutants and/or contaminants then OEMPSP4 will be used to ensure environmental and human health protection. 1.4 Inspect the amenity (general appearance) of the built asset once every quarter or in conjunction with wider scheduled maintenance and repair programs. 1.5 Ensure repairs and improvements to the general amenity (i.e. painting, welding, vegetation management, signage visibility) are undertaken within contracted timeframes following an inspection. 1.6 Use the complaints handling procedure described in section of the OEMP to respond to comments about the appearance and amenity of the asset within 24-hours. Ensure any remedial actions are implemented within one week, where feasible and reasonable, otherwise scheduled for maintenance and/or repair in as reasonable timeframe as possible. Report back on the outcome of the complaint once the remedial action is complete. 1.7 Ensure any graffiti removal and wash down is undertaken in accordance with the relevant provisions of OEMPSP4. SMC/O&M contractor SMC/O&M contractor Control 2: vegetation and landscape management 2.1 Develop relevant SOPs and ESWMSs for vegetation and landscape management including the provisions and actions of the urban design and landscape plan and landscape maintenance plan in Annex A. These documents will include: Training provisions developed in accordance with Chapter 6 of the OEMP that focus on: Dust and noise management when undertaking work. The location and management of acid sulphate soils as per OEMPSP4 Environmentally sensitive areas. Known and recorded threatened flora, fauna and habitat, with records maintained in the SMC IMS and supported by SOPs. Soil conservation issues as per OEMPSP4. Erosion and sediment control as per OEMPSP4. Spill management and response as per OEMPSP4. The location of heritage values, with records maintained in the SMC ICMS and supported by SOPs. Issues of potential contamination as per OEMPSP4. Waste management and reuse as per OEMPSP4. Water and energy conservation as per OEMPSP4. Work plans including schedules, timings (including timing restrictions), and notification and advertisement requirements. Exclusion provisions including site set-up, demarcation and provision of no-go areas, including entry and exit points and any vehicular access limitations. Note: this includes exclusion provisions covering weed-infested areas. Marking out provisions and clearing limits consistent with G40: Clearing and Grubbing (Roads and Maritime, 2016). Pre-clearance ecological surveys and checks of sensitive areas or written approval from the SMC environmental manager before clearing and management starts. SMC/O&M contractor Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 11 of 15 Commercial in Confidence

145 Step Requirement Responsibility Incident management in accordance with the provisions in section 8.2 of the OEMP. Complaints handling and management in accordance with the provisions in section of the OEMP. General site management working practices relating to: Tracking mud onto public roads. Dust management and air quality management. Noise and vibration management as per OEMPSP1. Materials management and handling as per OEMPSP4. Waste management and handling as per OEMPSP4. Grass slashing: Risks to public safety. Erosion and sedimentation issues for soil exposure. Unnecessary vegetation removal. Inappropriate material management. Exposure and management of acid sulphate soils as per OEMPSP4. Potential environmental harm to vegetation, threatened species, flora and fauna, and heritage items. Dealing with and managing potential contamination as per OEMPSP4. Vegetation and tree management (including removal, branch trimming and pruning). Protection of endangered communities and habitat. Potential risk of damage to other flora and fauna. Note: The Urban Design and Landscape Plan (UD&LP) confirms the need for SMC to undertake landscape maintenance for 12 months once the asset is operational. The maintenance actions in Appendix C of the UD&LP will then apply for a following two years. For the rest of the asset operation life SMC will comply with the landscaping maintenance program detailed in the RMS Specification: M3 Routine Services and all maintenance intervention requirements specified in RMS QA SPECIFICATION M3 (under M321 Landscape Maintenance and current best industry practice. Control 3: Further vegetation and landscape remediation 3.1 Inspect the areas of remedial landscaping and vegetation cover introduced in upgrading the M4 Motorway to provide screening and amenity and to prevent erosion once every month for the first year of operation. If there is evidence of poor establishment consider the need for additional remedial planting. Continue inspections after one-year in locations where there is evidence of poor establishment in the first year until a point in time where the area is established. Ensure that any planting or other remedial action is approved by the SMC environmental manager before it is introduced 3.2 Adopt Control 3.1 where land will be cleared in the future when operating, maintaining and repairing the asset. This will ensure the effectiveness of any associated landscaping and vegetation cover introduced to remediate the cleared area. SMC/O&M contractor Control 4: Training in native and remnant vegetation protection 4.1 Consistent with the provisions of section 6 of the OEMP, ensure that all O&M stakeholders are trained in native and remnant vegetation protection and dealing with unexpected finds. SMC/O&M contractor Control 5: Management of light spill Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 12 of 15 Commercial in Confidence

146 Step Requirement Responsibility 5.1 Ensure the asset lighting is on an active maintenance schedule. 5.2 Ensure the maintenance schedule covers light spill, flare, up lighting (light pollution), backscatter, driver safety, and light levels to adjacent receivers. 5.3 Review the provision of light control in maintaining, repairing and upgrading the asset to cover: Improvements in directional lighting Use of back plates and flat lamps Use of LED lights Application of energy efficient lighting. 5.4 Ensure that the asset is managed, and site work is undertaken, to prevent light spill in accordance with the limits set out in Australian Standard AS 4282: 1997 Control of Obtrusive Effects of Outdoor Lighting (Australian Standards, 1997). 5.5 Use the complaints handling procedure described in section of the OEMP to respond to comments about light spill and light pollution within 24-hours. Ensure any remedial actions are implemented within one week, where feasible, otherwise scheduled for maintenance and/or repair in as reasonable timeframe as possible. Report back on the outcome of the complaint once the remedial action is complete. SMC/O&M contractor SMC/O&M contractor SMC/O&M contractor Control 6: weed management 6.1 Develop SOPs for weed management accounting for the provisions of the NSW Noxious Weed Act These documents will include: Weed removal practices that include: Incorrect weed treatment Exposure and management of acid sulphate soils Weed spread Potential environmental harm to vegetation, threatened species, flora and fauna, and heritage items Incorrect weed disposal Notification requirements for Class 1 weeds Weed control (spraying) practices that cover Incorrect weed treatment Seed stock and weed removal from topsoil Poor spraying outcomes Impacts to water quality from pesticide weed killer application Incorrect weed management Ongoing weed management practices that cover: Prevention of weed spread and propagation. SMC/O&M contractor Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 13 of 15 Commercial in Confidence

147 6 Community communications and complaints management In accordance with section of the OEMP, this management sub-plan will operate under a community communications strategy (community relationship plan) that includes: A 24-hour community hotline for complaints and queries Liaison with the community ahead of undertaking any work that is likely to cause impact by giving them at least two weeks prior notice, unless it is an incident or emergency situation Carrying out the community notification requirements as per section 7 of the OEMP Controlling and managing the outcome of complaints through the procedure discussed in section of the OEMP. 7 Training and awareness All O&M stakeholders will be trained and made aware of management requirements before (planning for), during (undertaking) and after (reporting) any activity. The training will form part of induction requirements, toolbox talks, meetings and subcontractor requirements, as discussed in Chapter 6 of the OEMP. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 14 of 15 Commercial in Confidence

148 Annex A: Urban Design and Landscape Plan and Maintenance Plan The Urban Design and Landscape Plan (UD&LP) is available at the link below: Sydney Motorway Corporation M4 Widening Motorway: OEMPSP3: visual amenity & landscaping management sub-plan Page 15 of 15 Commercial in Confidence

149 OEMPSP4: Surface water quality and hydrology Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan Page 61 of 62

150 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan OEMPSP4: Surface Water Quality and Hydrology Management Subplan April 2017 Sydney Motorway comprises Sydney Motorway Corporation (ACN ) and its controlled entities

151 Table of Contents 1 Introduction Purpose and application Objectives Content Monitoring and auditing the plan Environmental obligations Statutory obligations Conditions of approval Legislation Permits, licences and approvals Other obligations Roads and Maritime specification G36: environmental protection Environmental policies, guidelines and principles Water quality standards Water quality objectives Existing environment General characteristics Flood risk Water quality Groundwater Acid sulphate soils Contaminated land Wetlands Changes introduce under water quality plan and monitoring program Changes to the existing environment Surface water and hydrology control measures Overview Operation and maintenance activities Management controls Water quality planning and monitoring Controls Community communications and complaints management Training and awareness Annex A: water quality plan and monitoring program Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 1 of 31

152 Definitions Term DP&E EMP EPA EIS MCoA O&M O&M Activities O&M stakeholders OEMP OEMPSP3 SMC SMC IMS Definition Department of Planning and Environment O&M Contractor s Environmental Management Plan NSW Environment Protection Authority Environmental Impact Statement Minister for Planning Condition of Approval Operation and Maintenance All activities required to undertake the operation and maintenance of the M4 Motorway All entities undertaking operational and maintenance activities on the asset. Typically including SMC and the O&M Contractor and other sub-contracted parties. Operation Environmental Management Plan Visual Amenity and Landscaping Management Sub-plan Sydney Motorway Company, a special purpose entity that has been created by the NSW Government to manage the delivery of WestConnex. Contains the policy, practices, and procedures for operating, maintaining and repairing WestConnex, which includes relevant environmental management information including the OEMP and this OEMPSPs Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Commercial in Confidence Page 2 of 31

153 1 Introduction 1.1 Purpose and application This document comprises the Surface Water Quality and Hydrology Management Sub-plan (OEMPSP4). It applies to all activities with the potential to: Cause Pollution or contamination (e.g. fuel and chemical spills, seepage spills, washings, contaminated water release, water discharge, firefighting activities) Sediment-laden runoff Flooding or runoff Unplanned water releases Affect the performance of the asset s pollutant control infrastructure. OEMPSP4 therefore includes: Operation: the control and management of: Traffic Incidents, accidents and emergencies Heavy rain and adverse weather. Maintenance and repair: the control and management of: Road drainage infrastructure Debris removal Water detention features Pesticide application Chemical and fuel storage, use, application, transport and disposal Pavement repairs, re-sheeting and resurfacing. Incident management: relating to incidents, emergencies and/or exceedances Reporting: monitoring and reporting of water quality metrics and parameters. OEMPSP4 forms part of the asset Operational Environmental Management Plan (OEMP). 1.2 Objectives The plan s objectives are: Manage all activities to ensure they do not harm or impact surface or groundwater quality Ensure the quality of water discharged to the receiving environment meets statutory requirements and relevant objectives Ensure that the asset s water quality and management systems and its pollution prevention infrastructure (e.g. basins) is maintained and effective Train O&M stakeholders in: Erosion and sediment control Pesticide use and application Spill management Heavy rainfall events Stockpile management Work over, and the installation of Acid sulphate soil management temporary and permanent structures Incident response in or over, A Becketts Creek, Duck Dewatering River and Haslams Creek Promote sustainable water use and the use of recycled and grey water where feasible and reasonable Maintain the asset so as not to cause a flood risk. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 3 of 31

154 1.3 Content The plan provides for the following provisions: Incident and emergency response Spill prevent and clean-up Erosion and sediment control Acid sulphate soil management Contaminant management Surface and groundwater quality management Stormwater and drainage inspection, maintenance and repair Flood protection Materials handling Water conservation. The plan also requires the following SOPs to be developed by the as part of its EMP: Unexpected discovery of contaminated material Acid sulphate soil management Stockpile management Heavy rainfall event Pesticide use Pesticide application record Culvert and pit cleaning Litter control Maintenance of surface drains Maintenance of sub-surface drains ESWMSs are to be developed as required for O&M activities such as work over A Becketts Creek, Duck River and Haslams Creek. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 4 of 31

155 2 Monitoring and auditing the plan OEMPSP4 will be assessed and reviewed in accordance with section 1.3 and section 10.1 of the OEMP. Specifically, it will be reviewed: In preparing for a change in: Legislation or regulation Licencing or approval conditions Operations Following: Routine inspections, monitoring and audits where there is an associated observation, corrective action, and/or environmental improvement notice issued (refer to section 9.7 of the OEMP) An incident or emergency (refer to section 8.2 of the OEMP) Continuous non-conformance. Otherwise the plan will be audited, reviewed and modified annually. Periodic site inspections, as described in Chapter 9 of the OEMP, will also be used to review environmental performance. Where there is inconsistency between the plan s intention and the inspection/audit findings, the management procedures and protocol will be reviewed and amended as necessary to ensure continuous improvement. Reviews will comprise: documentation Observing procedure and protocol onsite Issuing corrective actions or environmental improvement notices Re-auditing performance once the corrective actions/improvement notices have been implemented. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 5 of 31

156 3 Environmental obligations This section summarises the legal, environmental, and contractual obligations covered by this OEMP. 3.1 Statutory obligations This sections describes the statutory and other obligations covering the operational asset Conditions of approval The requirement to operate under a surface water quality and hydrology management sub-plan is in response to Minister for Planning condition of approval MCoA E8-Fiv, which states that: Details of how environmental performance would be managed and monitored to meet acceptable outcomes, including what actions will be taken to address identified potential adverse environmental impacts, including those safeguards and mitigation measures. In particular, the following environmental performance issues shall be addressed in the OEMP: surface water quality and hydrology. Table 3.1 summarises the relevant conditions relating to surface water and hydrology management. Table 3.1: Relevant operational Ministerial conditions of approval MCoA Details Responsibility Reference B7 Water Quality Plan and Monitoring Plan A Water Quality Plan and Monitoring Program shall be prepared and implemented to ensure that the project is designed and constructed to meet MCoA B1 and to monitor impacts on surface and groundwater quality and resources and wetlands, during construction and operation. The Plan and Program shall be developed in consultation with the EPA, DPI (Fishing and Aquaculture and WaterNSW), the Sydney Olympic Park Authority (SOPA), and Councils and shall include but not necessarily be limited to: a) Identification of surface and groundwater quality monitoring locations (including watercourses, waterbodies and wetlands) which are representative of the potential extent of impacts from the SSI, including the relevant analytes and frequency of modelling b) Identification of work and activities during construction and operation of the SSI, including emergencies and spill events, that have the potential to impact on surface water quality of potentially affected waterways c) The presentation of water quality standards and parameters having regard to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000 (Australian and New Zealand Environment Conservation Council, 2000) d) Identification of environmental management measures relating to surface and groundwater during construction and operation, including sediment and stormwater management measures consistent with Water Sensitive Urban Design measures, where relevant SMC Not applicable Completed during Construction (see CEMP) Not applicable Completed during Construction (see CEMP) SMC SMC Section 9.3 of the OEMP Annex A Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 6 of 31

157 MCoA Details Responsibility Reference e) Representative background monitoring of surface and groundwater quality parameters prior to the commencement of construction, to establish baseline water conditions, unless otherwise agreed by the Secretary f) A minimum monitoring period of one year following the completion of construction. If impacts are identified after one year of monitoring, continue monitoring for a further two years or until the affected waterways and/ or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales) g) Contingency and ameliorative measures in the event that adverse impacts to water quality are identified, including trigger values for action and associated actions or mitigation measures if trigger values are exceeded h) Reporting of the monitoring results to the Secretary, EPA, DPI and WaterNSW i) The Plan and Program shall be submitted to the Secretary for approval prior to the commencement of construction of the SSI, or as otherwise agreed by the Secretary. A copy of the Plan and Program shall be submitted to the EPA, DPI (Fishing and Aquaculture), WaterNSW and councils prior to its implementation. Not applicable Completed during Construction (see CEMP) SMC/O&M Contractor SMC SMC SMC Legislation The following legislation is relevant to OEMPSP4. Table 3.2: Legal obligations Legislation Relevance General Protection of the Environment Operations Act 1997 Pollution and waste management Surface water quality and hydrology Soil Conservation Act 1938 Erosion and sediment control Contaminated Land Management Act 1997 National Environmental Protection (Assessment of Site Contamination) Measure 1999 Water Management Act 2000 Water Management Amendment Act 2014 Contaminated land management Stockpile management Spill management Watercourse protection Water access and use Sydney Water Act 1994 Requirement to obtain (trade waste) consent to discharge waste water to a sewer Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 7 of 31

158 Legislation Relevance Pesticide Act 1999 Safe use and application of pesticides Public notification requirements before applying pesticides Road and Rail (Transport) Dangerous Goods Act 1997 Safe and licenced transportation of dangerous goods Biodiversity Fisheries Management Act 1994 Requirement to remove sediment discharge to watercourses and notify NSW EPA Permits, licences and approvals The asset does not routinely operate under any additional permits, licences and/or approvals. 3.2 Other obligations Roads and Maritime specification G36: environmental protection Under the O&M deed, the is required to develop and environmental management plan (EMP) that meets the requirements of Roads and Maritime s quality assurance specification G36: Environmental Protection (Roads and Maritime, 2016). A list of the assurance specification requirements is provided in Table 3.3 which must be included in the s EMP. Table 3.3: Quality assurance specification G36: Environmental Protection Details Soil and water quality management Contaminated land management plan Remediation action plan Spill prevention and response Fire safety and burning-off Waste management and resource recovery Use of pesticides Work in environmentally sensitive areas Environmental incident notification and reporting Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 8 of 31

159 3.2.2 Environmental policies, guidelines and principles Roads and Maritime and other Government agencies have developed guidance and policy for managing noise and vibration. The O&M stakeholders will work under this guidance and policy: Table 3.4: Environmental policies, guidelines and principles Legislation Relevance General G36 Environmental Protection (Roads and Maritime, 2016) Environmental protection Surface water quality and hydrology Best Practice Guidelines for Contaminated Water Retention and Treatment Systems (NSW Government, 1994) Code of Practice for Water Management: Roads and Development Management (Roads and Maritime, 1999) Guidelines for Treatment of Stormwater Runoff from the Road Infrastructure (AP- R232, Austroads, 2003) Technical Guideline: Temporary Stormwater Drainage for Road Construction (Roads and Maritime, 2011) Managing Urban Stormwater Soils and Construction: Volume 2D Main Road Construction (DECC, 2008) The Blue Book: Managing Urban Stormwater: Soils and Construction, Volume 1 (Landcom, 2004) NSW Floodplain Development Manual: the Management of Flood Liable Land (NSW DIPNR, 2005) Urban Stormwater Drainage Design Guidelines in Australia: Rainfall and Runoff (the ARR Guidelines, Australian Government, Geoscience Australia, 2016). G38: Soil and Water Management (Roads and Maritime, 2016) Stockpile Site Management Guidelines (Roads and Maritime, 2008) Code of Practice for Water Management: Roads and Development Management (Roads and Maritime, 1999) Guidelines for Bunding and Spill Management (NSW EPA, 2011) Australian Standard AS 1940B:1993: The Storage and Handling of Flammables and Combustibles (Standards Australia, 1993) Australian Standard AS 4452B:1997: The Storage and Handling of Toxic Substances (Standards Australia, 1997) Storage and Handling Liquids: Environmental Protection: Participants Manual (NSW EPA, 2007) Floodplain Risk Management Guideline: Practical Consideration of Climate Change (NSW DECC, 2007) Guidelines for Controlled Activities: Watercourse Crossings (NSW DEC, 2008) Guidelines for Construction Water Monitoring (Roads and Maritime, undated) AS/NZS :1998 Water Quality, Sampling, Guidelines on the Design of Sampling Programs, Sampling Techniques and the Preservation and Handling of Samples (Standards Australia, 1998) Australian and New Zealand Guidelines for Fresh and Marine Water Quality: Volume 1 The Guidelines ( the ANZECC guidelines, ANZECC, 2000) Guidelines for Construction Water Quality Monitoring (Roads and Maritime, 2003) The Blue Book: Managing Urban Stormwater (MUS): Soils and Construction, Volume 1 and Volume 2 (Landcom, 2004) Storage and treatment of firefighting water Stormwater runoff management Soil and water management Working in flood plains and over/close to watercourses Water quality sampling Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 9 of 31

160 Legislation Relevance Guidelines for Assessment and Management of Contaminated Groundwater (DEC, 2007) Environmental Direction: Management of Tannins from Vegetation Mulch (Roads and Maritime, 2012) Guideline for the Management of Contaminated Land (Roads and Maritime, 2013) Incident classification and reporting procedure (Road and Maritime, 2013) Contaminated waters and leachate management Biodiversity Why do Fish Need to Cross the Road? Fish Passage Requirements for Waterway Crossings (NSW DPI - Fisheries, 2005) Safe fish passage Soils and geology Stockpile Site Management Guidelines (Roads and Maritime, 2008) Waste Classification Guidelines Part 4: Acid Sulfate Soils (NSW EPA. 2014) G38: Soil and Water Management: Soil and Water Management Plan (Roads and Maritime, 2016) Acid Sulfate Soils Assessment Guidelines (Acid Sulfate Soil Management Advisory Committee, 1998) Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee, 1998) Guidelines for the Management of Acid Sulphate materials: Acid Sulphate Soils, Acid Sulphate Rock and Monosulphidic Black Ooze (Roads and Maritime, 2005) Waste Classification Guidelines Part 4: Acid Sulfate Soils (EPA. 2014) Soil and water management Acid sulphate soils Waste and resource management Environmental Compliance Report: Liquid Chemical Storage, Handling and Spill Management - Part B Review of Best Practice and Regulation (NSW DEC, 2005) Storing and Handling Liquids, Environmental Protection: Participants Manual (NSW DECC, 2007) Excavated Natural Material Exemption 2014 (NSW EPA, 2014) Excavated Public Road Material Exemption 2014 (NSW EPA, 2014) Raw Mulch Exemption 2014 (NSW EPA, 2014) Reclaimed Asphalt Pavement Exemption 2014 (NSW EPA, 2014) Stormwater Exemption 2014 (NSW EPA, 2014) Waste Classification Guidelines (NSW EPA, 2014) Management of Wastes on Roads and Maritime Land (Roads and Maritime, 2014) Fact Sheet 1: Virgin Excavated Natural Material (Roads and Maritime, 2015) Fact Sheet 2: Excavated Natural Material (Roads and Maritime, 2015) Fact Sheet 3: Excavated Public Road Materials (Roads and Maritime, 2015) Fact Sheet 4: Reclaimed Asphalt Pavements (Roads and Maritime, 2015) Fact Sheet 5: Asbestos Waste (Roads and Maritime, 2015) Fact Sheet 6: Waste Sampling (Roads and Maritime, 2015). Waste Avoidance and Resource Recovery Strategy (NSW EPA, 2014) Sustainability Policy: Waste Reduction and Purchasing Policy (WRAPP, NSW OEH, 2011) Waste Reduction and Purchasing Plan (Roads and Maritime, 2010 Materials handling and storage, and waste management Roads and Maritime waste factsheets Waste hierarchy Reduction of resource consumption Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 10 of 31

161 3.2.3 Water quality standards There is a requirement to ensure any discharged stormwater, runoff or other pollutant discharge does not impact on the surface or groundwater quality of the receiving environment as described in section 4. The ANZEEC guidelines provide trigger values for the introduction of additional management controls. The following water quality standards and parameters were adopted in the approved project EIS (refer to section of Appendix G of the approved project EIS). They will continue to be relevant to OEMPSP4 and the water quality plan and monitoring program in Annex A as they provide trigger values for corrective actions and/or the revision or introduction of mitigation controls. Water quality objectives The NSW Water Quality Objectives (WQOs) for upper estuaries (reflecting the characteristics of the catchments and sub catchments covered by the asset footprint) focus on the protection of: Aquatic ecosystems Visual amenity Primary (i.e. swimming) and secondary (i.e. kayaking) contact recreation Aquaculture and fishing (consumption). Table 3.5 presents the benchmark triggers for the above WQOs, as taken from Table and Table of the ANZECC guidelines. Table 3.5: Water quality objectives under the ANZECC guidelines Parameter/analayte ANZECC WQO trigger value Total phosphorous (μg/l microgram per litre) 30 Total nitrogen (μg/l) 300 Chlorophyll α (μg/l) 4 Turbidity (nephelometric turbidity units, NTU) Dissolved oxygen (% saturation) ph Primary contact recreation The ANZECC guidelines state that for primary contact recreation the water should be free from: Faecal coliforms Pathogenic organisms Other hazards. Secondary contact recreation The ANZECC guidelines state that for secondary contact recreation the water should be free from: Floating debris, grease, and other objectionable matter Substances that produce undesirable colour, odour, taste or foaming Undesirable aquatic life, such as algal blooms, or dense growths of attached plants or insets. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 11 of 31

162 Physicochemical characteristics Table 3.6 lists the ANZECC guideline trigger values for microbiological, physical and chemical characteristics. Table 3.6: Microbiological and physicochemical trigger levels under the ANZECC guidelines Parameter ANZECC WQO trigger value Microbiological Primary Secondary The median bacterial content in samples of fresh or marine waters taken over the bathing season should not exceed: 150 faecal coliform organisms/100 ml (minimum of five samples taken at regular intervals not exceeding one month, with four out of five samples containing less than 600 organisms/100 ml) 35 enterococci organisms/100 ml (maximum number in any one sample: organisms/100 ml) Pathogenic free-living protozoans should be absent from bodies of fresh water. The median bacterial content in fresh and marine waters should not exceed: 1,000 faecal coliform organisms/100 ml (minimum of five samples taken at regular intervals not exceeding one month, with four out of five samples containing less than 4,000 organisms/100 ml) 230 enterococci organisms/100 ml (maximum number in any one sample: organisms/100 ml). Physical and chemical Visual clarify and colour Acidity/alkalinity (ph) Temperature Toxic chemicals Surface films To protect the aesthetic quality of a waterbody: The natural visual clarity should not be reduced by more than 20 per cent The natural hue of the water should not be changed by more than 10 points on the Munsell Scale The natural reflectance of the water should not be changed by more than 50 per cent. To protect the visual clarity of waters used for swimming, the horizontal sighting of a 200 mm diameter black disc (Secchi disc) should exceed 1.6 metres. The ph of the water should be within the range , assuming that the buffering capacity of the water is low near the extremes of the ph limits. No specific recommendation given variability of individual human response but general range of ºC identified. Waters containing chemicals that are either toxic or irritating to the skin or mucous membranes are unsuitable for recreation. In general, toxic substances should not exceed the concentrations provided in Table and Table of the ANZECC guidelines. Oil and petrochemicals should not be noticeable as a visible film on the water nor should they be detectable by odour. Aquaculture and fishing Section of the ANZECC guidelines list the water quality guideline trigger values for the protection of human consumers of aquatic food. The guidelines are used in conjunction with Food Standards Codes to protect human health. Guidelines are also provided on biological contaminants. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 12 of 31

163 4 Existing environment Appendix G of the approved project EIS describes the surface waters and hydrology local to the asset. 4.1 General characteristics The asset is located on the southern side of the Parramatta River estuary crossing the A Becketts Creek, Duck Creek, Duck River, Haslams Creek, and Powells Creek sub-catchments, all of which drain to the Parramatta River, which in turn drains into Sydney Harbour. Figure 4.1 shows the location of the 12 watercourse (and reaches) crossed by the asset. 4.2 Flood risk The asset footprint is located on flood prone land. The largest flood event that could occur across the asset footprint (known as the probable maximum flood level) could be up to about 18 metres deep where the asset crosses Reach E. However, the probability of such an event occurring is remote. A more realistic potential is for each of the 12 water courses to flood to a depth of between four and 16 metres (refer to Table 8.28 in the project EIS). This is the modelled flooding that would occur from a storm that typically occurs once every five years, known as the 5% annual exceedance probability (AEP). The asset would have no measurable impact on flood risk in the area as a result of: Widening and augmenting A Becketts Creek between Good Street and Woodville Road Enlarging the Good Street bridge waterway area Carefully positioning and streamlining the viaduct piers Providing the following flood immunity protection in the design: Five years for the open drains. 10 years for pipes and pits. 50 years for culverts and surcharge structures. 100 years for culverts and non-surcharge structures. 10 years for the pavement. One year for the gross pollutant traps. 100 years to the outfall channels. One year for the cycleways. 4.3 Water quality The water quality of the estuary and the associated sub catchments is generally poor due to the commerce and industry in the area. It is characterised by low dissolved oxygen (DO), low ph, high turbidity, nutrient loading (nitrogen and phosphorous), high algal concentrations and blooms, and the presence of pathogens such as faecal coliforms. The recorded water chemistry also exceeds the aquatic health ecosystem guideline limits for south-east estuaries in Australia as developed under the Australian and New Zealand Water Quality Guidelines for Fresh and Marine Water 2000: Volume 1 the Guidelines (ANZEEC, 2000). The poor quality has limited the recreational use of the estuary. It has also led to the Government advising on people limiting their consumption of fish and prawns from the area s recreational sports fishing ground, while placing restrictions on aquaculture in the area. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 13 of 31

164 4.4 Groundwater Water was recorded at depths of between 0.1 metre and 14 metres below Australian height datum (AHD) in The groundwater across the asset footprint was assessed as being broadly consistent, characterised as: Being fresh to brackish, typical of the Ashfield shale in which it is located Having an oxidation-reduction potential. Non-potable groundwater is likely to be present in the alluvium, shale, and sandstones that underlay the asset footprint. Figure 4.1: Watercourse locations Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 14 of 31

165 Figure 4.2: Acid sulphate soils 4.5 Acid sulphate soils Acid sulphate soils are potentially present along the entire asset corridor, particularly along existing drainage and creek lines. If these soils are exposed to the air the oxidation process forms sulphuric acid that can wash out and impact on the receiving environment affecting groundwater, surface water, soils and the built environment. Figure 4.2 (above) shows the location of the potential acid sulphate soils in relation to the asset. 4.6 Contaminated land The asset passes through a developed urban environment that comprises a mixture of land uses. Over the past 150 years industrial and commercial land uses have given rise to the potential risk of encountering contaminants. Table 4.1 lists the key land uses and the associated contaminants of potential concern that may have impacted the Asset footprint. Table 4.1: Areas presenting a high or high-to-moderate contamination risk Location Land use and contaminants of potential concern Pitt Street to Church Street Battery recycling depot: potential for heavy metal contaminants and low ph. Church Street to Deniehy Street Cement bound asbestos fragments were observed beneath the M4 Motorway to the northern of A Beckett Street and the corner of Alfred Street. On the eastern side of the James Ruse Drive Junction in a landscaped area beneath the M4 Motorway a grassed over stockpile (about 60 metres by 20 metres by two metres) was observed in weathered portions of the stockpile to contain cement bound asbestos containing materials and potentially acid sulphate soils. Additionally the fill in these areas may contain other contaminants including hydrocarbons, Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 15 of 31

166 Location Land use and contaminants of potential concern pesticides and heavy metals, and possible acid sulphate soils (in the stockpile at James Ruse Drive). A section of Duck Creek beneath the M4 Motorway and James Ruse Drive junction was observed to be heavily contaminated by rubbish as well as potential sewage/leachate. The source of this was not identified. There is potential for a range of contaminants including hydrocarbons, heavy metals, asbestos, polycyclic aromatic hydrocarbons (PAHs) and nutrient contaminants. Junction Street to Silverwater Road On the northern side of the M4 Motorway between Junction Street and Newton Street North is a soil and brick recycling facility; this was historically used as a landfill site. To the east of Stubbs Street there is evidence of fill materials (earth mounds, concrete rubble) along the vegetation strip. Waste odours were also noted in the eastern most portion of this area. Landfill and fill materials have the potential for a variety of contaminants including hydrocarbons, pesticides, heavy metals and asbestos, as well as explosive and toxic landfill and volatile organic fugitive gases. Silverwater Road to Homebush Bay Drive On the vegetation strip between Wetherill Street and Day Street South many of the mature trees are either distressed or have died. On the southern side of the M4 Motorway, to the east of Hill Road, between the M4 Motorway and Parramatta Road an area of open space has about 10 partially vegetated stockpiles over an area of about 50 metres by 20 metres. Fill materials included soils, brick, concrete and timber. On the southern side of the M4 Motorway between Birnie Street and Homebush Bay Drive, fill materials were observed in the vegetated strip between Parramatta Road and the M4 Motorway. To the east of Homebush Bay drive a portion of the open space area is used as a recycling centre (fill soils and trees). Fill materials have potential for a variety of contaminants including hydrocarbons, pesticides, heavy metals and asbestos. 4.7 Wetlands The 12 watercourses crossed by the asset classify as low-value highly disturbed coastal freshwater wetlands of the Sydney Basin. Ducks Creek is the only crossing where there is some potential for wetland birds to occur along the riparian (river) corridor, despite the habitat being highly modified in the local area. The only other aspect that is not highlighted in the EIS is the important wetland areas to the north of the M4 Motorway associated with the Sydney Olympic Park west of Hill Road. This area contains groundwater dependent ecosystems, and supports various threatened flora and fauna including a notable population of green and golden bell frog and golden orb spider, which are endangered at the State level and vulnerable at the Commonwealth level. This wetland is supported and supplied by Haslams Creek. 4.8 Changes introduce under water quality plan and monitoring program Under MCoA B7, SMC was required to prepare and implement a water quality plan and monitoring program to support construction of the upgrade of the M4 Motorway. This is to remain in place for a minimum of one year after the upgraded asset is operational. The purpose of the plan and program is to ensure the surface, groundwater and wetland values of the area are protected (refer to section 3.1 above). If impacts are identified after one year of monitoring, the will continue monitoring for a further two years or until the affected waterways and/or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales). Annex A contains a copy of the water quality plan and monitoring program for operations. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 16 of 31

167 4.9 Changes to the existing environment Over time the surface and groundwater quality of the local area will change. As such, different water quality objectives and parameters may apply. There will also be an obligation on all O&M stakeholders to manage and control routine and non-routine operational activities in line with any change to the existing environment, as allowed for in section 5. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 17 of 31

168 5 Surface water and hydrology control measures 5.1 Overview The O&M stakeholders will implement controls to: Plan for and execute an incident and emergency response, spill prevention and clean-up controls Prevent erosion and sedimentation, including monitoring vegetation establishment and the introduction of remedial planting where required Manage acid sulphate soils Manage potential contaminated land and unexpected contaminated finds Manage known and potential asbestos Protect groundwater quality and manage dewatering activities Maintain the stormwater drainage system, including the water quality infrastructure, water sensitive urban design measures and outfall points Ensure the asset operates to provide the required flood immunity Ensure solid and liquid materials and waste, including wastewater is managed, stored, classified, handled, transported, treated and disposed of in accordance with its classification under guidance, including any exemption provisions Work over A becketts Creek, Duck River and Haslams Creek Conserve water. 5.2 Operation and maintenance activities Each O&M stakeholder is to annually prepare and update a schedule of activities that could potentially impact on surface and groundwater quality, revising and/or supplementing the information in Table 5.1. For reference the O&M stakeholders comprise: Sydney Motorway Corporation (SMC): asset delivery and operation : asset operation, maintenance and repair. Table 5.1: Activities potentially impacting on surface and groundwater Activity Routine maintenance/repair work Vegetation clearing and landscape management Stormwater and water sensitive urban design clean out Road infrastructure maintenance Pavement renewal and resurfacing Graffiti removal and cleaning General maintenance and repair work Routine equipment maintenance Tolling equipment Electrical equipment Vehicle washing Road maintenance plant and machinery O&M vehicles Non-routine operation Road traffic incidents Stormwater and water quality equipment failure Responsibility SMC/ Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 18 of 31

169 Activity Non-routine maintenance and repair Asset damage (i.e. vehicle strike) Major spill including clean-up Equipment failure leading to damage, spill or an uncontrolled outcome Responsibility SMC/ The above activities will be managed under the relevant guidelines presented in section and in accordance with the relevant provisions of the legislation in section Management controls This section sets out the controls (and monitoring) that will be implemented to manage surface water and hydrology impacts form the above activities. These controls satisfy MCoA E8-Fiv, MCoA B7, G36: environmental protection, and G38: soil and water management (refer to Chapter 4 of the OEMP) Water quality planning and monitoring As described in section 4.8, SMC is required to continue to implement a water quality plan and monitoring program for at least one year. Elements of the plan and program in Annex A form part of OEMPSP4 including: Emergency response and spill management Adoption of water quality standards, including trigger levels Sediment management controls Stormwater management measures, including water sensitive urban design Controls Table 5.4 lists the management control steps that will be implemented to plan, manage, monitor and review environmental performance. Table 5.2: Environmental controls Step Requirement Responsibility Control 1: incident and emergency response, spill prevention and clean-up Incident and emergency response: road traffic incidents 1.1 Follow the incident and emergency procedure as described in Chapter 8 and provided in Appendix D of the OEMP. 1.2 Shut down the stormwater system and stop discharging offsite as soon as it is safe and feasible to do so. 1.3 Ensure that O&M stakeholders work with emergency authorities to clean-up spills and prevent them migrating to the stormwater drainage or reaching surface or groundwater. The key steps will include: The use of spill kit material once the area is made safe. Contain the spill within the pavement area if possible. Install containment measures comprising sandbags and booms to prevent migration to the stormwater drainage. Cap outfall points to prevent offsite discharge of polluted water if required and feasible. Potentially drain ponds following heavy rainfall and collect the water for testing and offsite disposal where feasible. Remove any polluted water using a licenced company. Skim oil sheens from the surface of the water quality pond if required. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 19 of 31

170 Step Requirement Responsibility 1.4 Notify NSW EPA and the Councils of the incident and work in collaboration during the clean-up. 1.5 Post event, test the water quality collected in the stormwater management system under the specifications of the ANZECC guidelines (refer to section 3.2.3). Where there are trigger exceedances, collect and pump water offsite for treatment and disposal to a licenced facility. Only start discharge once the testing confirms that the above guideline values have been met and approval has been sought from the NSW EPA. SMC/ SMC/ Note: direct seepage, spills, contaminated water, firefighting water or other water that contains pollutant concentrations above the background concentrations will be directed into separate sumps with pump-out facilities. It will not be discharged to the stormwater system without the approval of NSW EPA and WaterNSW. Spill prevention: material and chemical storage 1.6 Store materials more than 50 metres from a surface watercourse and away from any location where stormwater will be diverted offsite with a direct access to surface or groundwater. Retain material safety data sheets (MSDS) onsite. Also ensure they are available via a 24-hour contact number. 1.7 Maintain access to spill prevention kits onsite ensuring they are included in all operations and maintenance vehicles and within the maintenance depot. 1.8 Protect all stormwater and surface drains before starting any site activities requiring the use of chemicals or fuels, or involving ground clearance or excavation work. 1.9 Ensure that spills are contained and cleaned up as soon as practical notwithstanding the associated health and safety requirement in handling and managing chemicals and fuels Ensure that all chemicals, fuels, dangerous goods and other potentially polluting materials are stored within the maintenance depot. This extends to storing all such materials on hardstand within an area that is bunded to 110 per cent of the capacity of the stored materials and 120 per cent of the volume of the largest contained for smaller packaged storage. Ensure that all drainage within chemical and fuel storage areas is self-contained to prevent any offsite migration. Spill prevention: refuelling 1.11 Ensure that all chemical and fuel transfer, maintenance, loading and unloading, and application activities, or any activity that could result in a spillage, takes place within a bunded and contained area. The bund needs to be capable of capturing 110 per cent of the contained chemical or fuel volumes and 120 per cent of the volume of the largest contained for smaller packaged storage Ensure that a person will be in attendance when vehicle refuelling takes place and that spill kit provisions are on hand and kept on all machinery and vehicles that require refuelling. Spill prevention: pesticide management 1.13 Notify the public ahead of using pesticides Check licencing controls governing pesticide management to ensure that pesticides are not used without licencing authorisation Ensure pesticides are not applied within 50 metres of a surface watercourse or in a location that would allow them to transfer to a watercourse. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 20 of 31

171 Step Requirement Responsibility 1.16 Ensure that pesticide management training forms part of the induction and toolbox talk provisions (refer to Chapter 6 of the OEMP). SMC/ Spill prevention: vehicle and equipment servicing 1.17 Undertake all vehicle servicing outside of the asset footprint or in a workshop on hardstand Use spill containment controls when vehicles are serviced Inspect vehicles, plant and equipment on a fortnightly basis for leaks. Spill prevention: vehicle washing 1.20 Ensure that vehicle washing only takes place outside of the asset footprint at the maintenance depot Ensure that no vehicles will be washed to allow runoff to the stormwater system. Spill prevention: graffiti removal and washing structures 1.22 Ensure that all water used to remove graffiti or wash structures (including signs and noise walls) is managed to prevent its migration to the stormwater system. This will include the protection of stormwater inlets and pits. Spill management 1.23 Following a minor or major spill: Ensure all O&M stakeholders are trained in spill management, including the use of materials and their deployment. Immediately identify the type and volumes of spilled material. Refer to MSDS for personal protective equipment (PPE) requirements Retain all needed PPE onsite. Stocktake and check the use-by date of all spill containment kit and PPE once every quarter. Assess containment needs. If containment is required use earth mounds and/or absorbent socks/spill kit Use the relevant clean-up procedure in MSDS. Dispose of material using a licensed contractor, and keep records of disposal onsite. Complete an incident reporting form and forward it to the SMC environmental manager Manage minor spills in-situ by removing the spoil and securing the area. Apply an appropriate absorbent product in accordance with manufacturer specifications. Remove the absorbent materials for disposal (generally as hazardous waste) Alternatively, classify the waste and dispose of it accordingly to a licenced facility Remove, store, test and dispose of any removed (potentially) contaminated spoil accordingly to a licenced facility Manage major fuel or chemical spills through the incident response procedure (refer to Chapter 8 and Appendix D of the OEMP). Clean-up all spillages immediately, providing there is not risk to human health or the environment so as to prevent is spread offsite or into the stormwater system, surface waters or groundwater sources. Collect all waste material (and spoil) and send it to a licenced facility for testing and disposal. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 21 of 31

172 Step Requirement Responsibility 1.26 Contract qualified and licenced personnel to manage any classify (or suspected) hazardous or special wastes in accordance with the requirements of the NSW Environmentally Hazardous Chemicals Act 1985 and the EPA Waste Classification Guidelines (NSW EPA, 2014). SMC/ Control 2: Erosion and sedimentation controls, including post-construction monitoring of vegetation General provisions: all relevant activities 2.1 Erect and maintain effective sediment control barriers down gradient of all areas where soil disturbance will be undertaken. 2.2 Construct diversion banks upslope of activities where sediment loss may occur to manage surface water runoff away from the exposed areas, where appropriate. 2.3 Test and classify generated spoil and sediment in accordance with the NSW Assessment, Classification and Management of Liquid and Non-Liquid Waste Guidelines (NSW DEC, 2004) and/or the NSW Waste Classification Guidelines (NSW EPA, 2014) before its disposal offsite. 2.4 Excavate and transport soil offsite for treatment and disposal at a licenced facility that is (suspected to be) contaminated as a result of fuel, oil, or chemical spills. 2.5 Sweep road surfaces at least once a fortnight to prevent the build-up of sediment Undertake additional sweeping following adverse weather Transfer the collected sediment offsite for disposal the NSW Assessment, Classification and Management of Liquid and Non-Liquid Waste Guidelines (NSW DEC, 2004) and/or the NSW Waste Classification Guidelines (NSW EPA, 2014) before its disposal offsite. SMC/ SMC/ 2.6 Stabilise exposed areas and earthworks during the maintenance period. 2.7 Protect all stormwater drainage to prevent the discharge of sediment by using gravel bags, sand filters or other geotextile fabrics. Routinely inspect all spent and used spill materials (i.e. sediment and gravel socks) during site activities. Replace spill materials on an active management schedule when undertaking routine operation and maintenance activities. Routinely replace sediment control devices and remove the old devices offsite for storage, waste classification and disposal. 2.8 Undertake daily observations of the water quality pond/sediment basin for visible signs of fine sediments during routine site activities. Only discharge from the water quality pond/sediment basin once the water is tested (where required) and/or the sediment is settled. Batter slopes and embankment management 2.9 Undertake visual inspections of the batter slopes and embankments and implement management actions if there is evidence of loose or unstable rock. Land clearance 2.10 Implement soil protection controls to prevent erosion including but not limited to: Staged clearance and progressive rehabilitation of exposed areas. Soil protection using geotextiles or plastics where it is not possible to rehabilitate the area immediately. Retain vegetation within drainage lines and medians. Minimise exposed areas to the required amount needed for the operation or maintenance activity. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 22 of 31

173 Step Requirement Responsibility Protect exposed soil, batters and other erosion-sensitive areas from the wind through using velocity reduction measures, covering, seeding and grassing, and/or water diversion. Erosion and sediment control devices maintenance and management 2.11 Remove sediment from control devices following a major rainfall event and/or when required Ensure that the collected water contained in control devices and excavations is only discharged after testing. Where required, contain, test and subsequently treat the water to confirm its suitability for discharge in accordance with the ANZECC guidelines (refer to section 3.2.3). Road sweeping and cleaning 2.13 Ensure the motorway and road margins are dry swept regularly and kept clear of debris including; vehicle waste, solid waste, sediment, sand, soil, clay or stones Monitor and clean all sediment traps and pits when they are 60 per cent full. Stockpile management 2.15 Install erosion and sediment control measures at stockpile areas based on the provisions included the Management of Urban Stormwater: Soils and Construction (Landcom, 2004, refer to Control 2.1 to Control 2.8). Ensure all stockpiles are: Maintained on hardstand Fenced Surrounded by drainage diversions No greater than 2.5 metres in height Stored as far as is reasonably practical from the stormwater drainage and surface watercourses and at least 50 metres from surface water features Covered as appropriate, and vegetated/stabilised if they are to be retained for more than three months. Vegetation establishment 2.16 Inspect the areas of landscaping and vegetation cover, introduced in upgrading the M4 Motorway to prevent soil erosion, once every month for the first year of operation. If there is evidence of erosion, consider additional remedial actions. Preference will be given in the first instance to natural controls (i.e. additional remedial planting), followed by manmade controls such as geotextile fabrics. Continue inspections after one-year in locations where there is evidence of erosion in the first year until a point in time where the area is established Adopt Control 2.16 where land will be cleared in the future. This will ensure the effectiveness of any associated landscaping and vegetation cover introduced to remediate the cleared area. Control 3: Acid sulphate soils 3.1 Manage acid sulphate soils in accordance with: Guidelines for the Management of Acid Sulphate materials: Acid Sulphate Soils, Acid Sulphate Rock and Monosulphidic Black Ooze (Roads and Maritime, 2005). Acid Sulfate Soils Assessment Guidelines (Acid Sulfate Soil Management Advisory Committee, 1998). Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee, 1998). Waste Classification Guidelines Part 4: Acid Sulfate Soils (EPA. 2014). Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 23 of 31

174 Step Requirement Responsibility 3.2 Develop a SOP for acid sulphate soil management that will: Describe the acid sulphate material aspects and impacts. Map all areas where the above activities are taking place in suspected or confirmed acid sulphate soil risk areas (refer to Figure 4.2). Define activities that are deemed of high risk in terms of acid sulphate soils. Describe and justify the acid sulphate material handling and management controls. Describe the acid sulphate material treatment methods controls and management strategies that will be employed as per section 7.4 of the Guidelines for the Management of Acid Sulphate Soils (Roads and Maritime, 2011). Describe the contingency measures that will be implemented in the event of a failure or non-conformance. Describe the sampling and testing regime to validate acid sulphate material before (and if required) during the work activity. Describe the proposed monitoring and supervision regime. Describe the delegation process for approving the removal, storage, management and disposal of acid sulphate materials. Describe how the delegated person will be trained and experienced in executing his/her duties. Describe the consultation program that will be implemented during any work. Describe the process for providing inductions and training for all O&M stakeholders to ensure unauthorised discharges are eliminated with reference to Chapter 6 of the OEMP. Ensure the SOP contains an acid sulphate soils contingency plan that will include procedures for investigating, handling, treating and managing the unexpected discovery of potential or actual acid sulphate soils. This contingency plan will be prepared in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee, 1998). Include maps in the SOP and contingency plan to identify all locations where: Minor ground disturbance will take place, considered less than 1,000 metric tonnes of soil in a confined area where there will be no effect on groundwater. Major ground disturbance will take place, considered more than 1,000 metric tonnes of soil in an unconfined area where there will be an effect on groundwater. 3.3 Ensure the SOP provides a clear description of supervision and monitoring requirements for all minor and major ground disturbance work in identified risk areas or involving identified risk activities. SMC/ Engage a qualified soil conservationist to monitor and inspect all minor and major ground disturbance work in risk areas before, during and after the work. Implement the mitigation controls identified in the SOP in instances where there is a (perceived) risk. This will include: Activities and actions at risk of causing the oxidation of acid sulphate soils via exposure to the air or dewatering. Controls to prevent the leaching, dispersion or migration of sulphuric acid the soil, groundwater, or surface water. Controls to protect and remove the risk of worker exposure. Controls to protect any immediately adjacent ecological and human receivers. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 24 of 31

175 Step Requirement Responsibility Control 4: Encountering and handling contaminants General provisions 4.1 Prepare a SOP for managing and handling contaminated materials that accords with the Guideline for The Management of Contamination (Roads and Maritime, 2013). The SOP will: Define management objectives in accordance with the above guideline. Confirm if the management objectives can be met by relying on existing data, or if this is not the case, then engage a specialist consultant to undertake further investigative work on potentially contaminated land. Include an environmental risk analysis to identify the key issues associated with undertaking work activities and the requirements of how environmental performance and human health risks would be managed and monitored especially with regards to the handling, treatment, and management of contaminated soil. Encountering unexpected contamination finds 4.2 Ensure the SOP includes controls for dealing with unexpected contaminated materials. This will include a stop-work procedure and the need to notify the SMC environmental manager within 24-hours of encountering any suspected or potential contamination. Ensure the SOP allows the SMC environmental manager to take over the investigation and management of an unexpected contamination find, and directly appoint an NSW EPA accredited contaminated site auditor if needed. Control 5: Groundwater management and dewatering Groundwater quality monitoring and auditing 5.1 Following the implementation of Control 1, undertake additional groundwater monitoring after a major spill or accident where chemicals are discharged overland. 5.2 Ensure that all monitoring complies with the provisions of the ANZECC guidelines relating to physical and chemical stressors, the trigger levels for toxicants, the interim sediment quality guidelines, the limits to ensure ecological protection, and the limits for recreational purposes (refer to section 3.2.3). 5.3 Record any exceedances of the water quality parameters as a non-conformance and report this directly to the SMC environmental manager who in turn will notify the NSW EPA and WaterNSW. 5.4 Develop a remediation action plan where required, submit the plan to NSW EPA via the SMC environmental manager and implement its provisions. Where required, resample the groundwater periodically to confirm the effectiveness of the action plan. Control 6: Stormwater drainage system maintenance and repair, including water quality infrastructure, water sensitive urban design measures and outfall points General provisions: all relevant activities 6.1 Keep and maintain an asset drawing of the stormwater system, its respective catchments, collection points, and discharge points. 6.2 Prepare, maintain, update and review a schedule of all operation and maintenance activities that involve work that could impact on stormwater drainage. This will principally include sediment-generating activities and activities involving the use of chemicals, fuels and other potentially polluting materials. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 25 of 31

176 Step Requirement Responsibility 6.3 Prepare, maintain, update and review a schedule of all atypical, incident and accident scenarios that could impact on stormwater drainage. Routine and regular maintenance of the stormwater system including water quality features and water sensitive urban design 6.4 Ensure that the stormwater system is placed on an active management schedule. 6.5 Visually inspect the system at least once a month for signs of debris, poor maintenance, chemical and oil sheens, notable odours, or other signs of pollution. 6.6 Ensure that additional daily inspections take place for a week immediately following an incident, spill or adverse heavy rainfall. 6.7 Remove sediment from control devices following a major rainfall event and/or when the device is 60 per cent full. Collect, test, classify and dispose of the sediment in accordance with the NSW Waste Classification Guidelines (NSW EPA, 2014). 6.8 If required, obtain consent from Sydney Water to discharge the collected water to the trunk sewer main. Control 7: Flood immunity protection 7.1 Ensure the road drainage infrastructure is inspected every month and maintained every six months, or more frequently if there is a period of prolonged heavy rainfall or accidental discharge, to ensure it operates within its design specifications to achieve the required flood immunity protection, namely an average return interval of: Five years for the open drains. 10 years for pipes and pits. 50 years for culverts and surcharge structures. 100 years for culverts and non-surcharge structures. 10 years for the pavement. One year for the gross pollutant traps. 100 years to the outfall channels. One year for the cycleways. Control 8: Material and waste management, storage, classification, handling, transportation, treatment and disposal Waste classification 8.1 Classify all waste in accordance with the Waste Classification Guidelines (EPA, 2014). Waste storage: general provisions 8.2 Store stockpile-collected spoil, topsoil or mulch onsite in allocated areas, and where required, implement dust control and stockpile management measures. 8.3 Store liquid waste in appropriate containers in bunded areas in the maintenance depot until they can be transported offsite. Ensure the bunded areas have the capacity to carry 110 per cent of the bulk storage or 120 per cent of the volume of the largest contained for smaller packaged storage. 8.4 Remove all orphan waste (e.g. illegally dumped materials) encountered in the asset footprint to a licenced contractor. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 26 of 31

177 Step Requirement Responsibility 8.5 Store other recyclable or non-recyclable materials in appropriately covered bins and skips. Store these materials in appropriate locations onsite. Commission a licenced contractor to regularly empty the bins and skips to an approved disposal or recycling facility. Waste transportation 8.6 Ensure all trucks transport waste to appropriately licensed waste facilities. 8.7 Ensure all waste truck loads are covered and tailgates secured before leaving site. 8.8 Ensure all controlled wastes are transported under a consignment number and waste data forms are completed. Waste disposal 8.9 Ensure (suspected) contaminated spoil is classified in accordance with the approach described above. Once classified, dispose of the waste to the nearest appropriately licenced landfill or preferentially, allow for its reuse or recycling Ensure general site waste is collected by a licenced contractor and transported to the nearest waste transfer station or landfill for disposal Record the types, volumes and destinations of all waste on a waste register Undertake monthly inspections and audits to ensure all waste documentation is being completed and is correct, and that all waste is being appropriately classified, stored, transported and disposed of. Control 9: Working over and installing temporary structures in/crossings over A becketts Creek, Duck River and Haslams Creek 9.1 Prepare ESWMS before undertaking work over A Becketts Creek, Duck River and Haslams Creek. Prepare specific ESWMS for instances where temporary structures or crossings are installed in or over the above creeks. Each ESWMS will include: A map showing all work locations and environmental sensitivities. A detailed description and justification of all work, need for structure installation and crossings. A description of onsite erosion, sedimentation, and scour protection controls. Equipment limitations and restrictions associated with working within 50 metres of a watercourse consistent with the spill management provisions set out under Control 1. A map showing proposed offsite discharge locations. Design requirements for offsite discharge locations to prevent bed or channel erosion. Provisions to ensure the safe passage of fish consistent with Why Do Fish Cross the Road? (Fairfull and Witheridge, 2003). Water quality objectives as per section Description of the water quality treatment techniques to be used. The water sampling and testing regime to validate water quality prior to and (if required) during the work. 9.2 Select methods to provide the highest level of environmental protection. This will focus on alternatives to the installation of structures in waterways. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 27 of 31

178 Step Requirement Responsibility 9.3 Ensure the ESWMSs provide a clear description of all supervision and monitoring requirements for the work activity. This extends to ensuring all activities will be inspected and monitored by inducted, experienced and competent personnel, as per Chapter 6 of the OEMP. Before any work takes place, ensure any pre-inspection checks are undertaken by qualified personnel (i.e. ecological inspections). Control 10: Water conservation 10.1 Develop and implement water efficient practices including water reuse, and recycling for roadside irrigation and site work Adopt the following conservation management hierarchy for all water collected onsite, following its testing: Reuse (e.g. dust suppression, grey water recycling in toilet facilities). Irrigation (e.g. diffuse application within the asset footprint). Direct discharge Audit water reuse annually with the objective of increasing the volume of asset-generated water that is reused during routine operations, maintenance, and repair activities. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 28 of 31

179 6 Community communications and complaints management In accordance with section of the OEMP, this management sub-plan will operate under a community communications strategy (community relationship plan) that includes: A 24-hour community hotline for complaints and queries Liaison with the community ahead of undertaking any work that is likely to cause impact by giving them at least two weeks prior notice, unless it is an incident or emergency situation Carrying out the community notification requirements as per Chapter 7 of the OEMP Controlling and managing the outcome of complaints through the procedure discussed in section of the OEMP. 7 Training and awareness All O&M stakeholders will be trained and made aware of management requirements before (planning for), during (undertaking) and after (reporting) any activity. The training will form part of induction requirements, toolbox talks, meetings and subcontractor requirements, as discussed in Chapter 6 of the OEMP. Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 29 of 31

180 Annex A: water quality plan and monitoring program Sydney Motorway Corporation M4 Widening Motorway: OEMPSP4: surface water quality & hydrology management sub-plan Page 30 of 31

181 M4 Widening Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush Operational Environmental Management Plan Annex A to OEMPSP4: Water Quality Plan and Monitoring Program April 2017 Sydney Motorway comprises Sydney Motorway Corporation (ACN ) and its controlled entities

182 Table of Contents 1 Introduction Purpose and application Legislative and regulatory requirements Conditions of Approval Objectives Potential operation impacts and management measures Operation impacts Operation Maintenance Management measures Sampling sites Baseline water conditions Water quality standards and parameters ANZECC and pre-construction monitoring Surface water Groundwater Monitoring Surface water Groundwater Contingency and ameliorative measures Reporting... 8 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 1 of 29 Commercial in Confidence

183 1 Introduction 1.1 Purpose and application This Water Quality Plan and Monitoring Program (WQPMP) describes how the impacts from the M4 Motorway: Pitt Street at Parramatta and Homebush Bay Drive at Homebush on surface and groundwater quality will be monitored. It describes how the requirements of CoA B7 will be met and identifies the frequency for the compliance reporting and independent auditing. SMC, through the O&M Contractor, will continue the monitoring for at least one year following the completion of construction. If impacts are identified after one year of monitoring, the O&M Contractor will continue monitoring for a further two years or until the affected waterways and/ or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales). This WQPMP has been developed from the Water Quality Plan and Monitoring Program prepared by Rizzani de Eccher Australia Pty Ltd/Leighton Contractors Pty Ltd Joint Venture for SMC prior to the design and construction of the M4 Widening Major Civil Works and approved by DP&E on 27 April The approved construction WQPMP has been amended to focus on water quality during the operation of the M4 Motorway. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 2 of 29 Commercial in Confidence

184 2 Legislative and regulatory requirements 2.2 Conditions of Approval Table 2-1: Conditions of Approval CoA B7 B7a) B7b) B7c) B7d) B7e) B7f) B7g) Requirement A Water Quality Plan and Monitoring Program shall be prepared and implemented to ensure that the project is designed and constructed to meet condition B1 and to monitor impacts on surface and groundwater quality and resources and wetlands, during construction and operation. The Plan and Program shall be developed in consultation with the EPA, DPI (Fishing and Aquaculture and Office of Water), SOPA, and councils Identification of surface and groundwater quality monitoring locations (including watercourses, waterbodies and wetlands) which are representative of the potential extent of impacts from the SSI, including the relevant analyses and frequency of modelling Identification of works and activities during construction and operation of the SSI, including emergencies and spill events, that have the potential to impact on surface water quality of potentially affected waterways; The presentation of water quality standards and parameters having regard to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000 (Australian and New Zealand Environment Conservation Council, 2000); Identification of environmental management measures relating to surface and groundwater during construction and operation, including sediment and stormwater management measures consistent with Water Sensitive Urban Design measures, where relevant; Representative background monitoring of surface and groundwater quality parameters prior to the commencement of construction, to establish baseline water conditions, unless otherwise agreed by the Secretary; A minimum monitoring period of one year following the completion of construction. If impacts are identified after one year of monitoring, continue monitoring for a further two years or until the affected waterways and/ or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales); Contingency and ameliorative measures in the event that adverse impacts to water quality are identified, including trigger values for action and associated actions or mitigation measures if trigger values are exceeded; and Document reference This WQPMP Section 4 Section 5 in OEMP Section in OEMP Section 6 in OEMP Section 4.1 and 5 Section 6 Section 7 B7h) Reporting of the monitoring results to the Secretary, EPA, DPI and NoW. Section 8 The Plan and Program shall be submitted to the Secretary for approval prior to the commencement of construction of the SSI, or as otherwise agreed by the Secretary. A copy of the Plan and Program shall be submitted to the EPA, DPI (Fishing and Aquaculture), NOW and councils prior to its implementation. Sections 8 Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 3 of 29 Commercial in Confidence

185 2.3 Objectives The objectives of the Water Quality Plan and Monitoring Program are: To comply with Condition of Approval (CoA) B7 - Water Quality Plan and Monitoring Program and Project Deed requirements as applicable to the M4 Widening project To provide a methodology for the measurement and assessment of water quality parameters. 3 Potential operation impacts and management measures 3.1 Operation impacts Operation Water quality risks during operation of the M4 Motorway are largely associated with the runoff of pollutants from the road surface. Typically, pollutants associated with road runoff are: Sediments from the paved surface from pavement wear and atmospheric deposition. Heavy metals such as lead, zinc, copper, cadmium, chromium and nickel attached to particles washed off the motorway pavement. Oil and grease and other hydrocarbon products. Rubber particles from wearing off tyres on the road pavement. Brake pad dust which could potentially include asbestos from older brake pads. Nutrients (N, P). These deposits build up on road surfaces and pavement areas during dry weather and can be washed off and transported to waterways during rainfall periods. Material deposited by motorists, such as non-biodegradable litter and food wastes, could also impact water quality, amenity and aquatic ecosystems if transported into receiving waterways. During operation there is also a risk of accidental spillage of fuel, chemicals or other hazardous liquids as a result of vehicle leakage or road incident on the M4 Motorway. While the likelihood of such potential spills would be low, the impact on the receiving environment could be considerable as spills of this nature would pollute receiving waterways if not adequately managed or mitigated Maintenance Water quality risks during maintenance are likely to be minimal and include: Excess rainfall causes erosion Spills of hydrocarbons that occur during maintenance activities Sediment-laden water from cleaning of drainage and sedimentation basins discharged into waterways Fuel spills during refueling of O&M vehicles causes contamination of surface water by hydrocarbons Incorrect storage and handling of fuels and chemicals 3.2 Management measures A series of measures to manage the above impacts to water quality have been included in OEMPSP4: Surface Water Quality and Hydrology Management Sub-plan appended to the OEMP. Provided that those measures are implemented during operation, short term impacts are expected to be manageable and similarly have no material impact on receiving water quality. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 4 of 29 Commercial in Confidence

186 4 Sampling sites Surface and groundwater sites were determined in the EIS as representative locations to monitor potential impacts from Operations (refer to EIS Appendix 1). These locations will be sampled and analysed for water quality parameters (see section 4) on a monthly basis. Where potential impact occurs following a storm event (i.e. >10mm), water sampling will be undertaken for comparison against baseline data. Refer to Table 4-1 and Table 4-2 for water quality monitoring sample location details. Table 4-1: Surface water monitoring locations Monitoring reference Waterway name Approx. chainage AB1 A Becketts Creek CH910 AB2 A Becketts Creek CH1400 AB3 A Becketts Creek CH1600 AB4 A Becketts Creek CH1690 DC1 Duck Creek CH2500 DC2 Duck Creek CH2580 DC3 Duck Creek CH3440 DR1 Duck River CH3410 DR2 Duck River CH3490 HC1 Haslems Creek CH5780 HC2 Haslems Creek CH5810 Table 4-2: Groundwater monitoring locations Monitoring reference Waterway name Approx. Chainage MW201 Near Robert Street CH300 MW N of A00 N of A Ck CH700 MW212 AW212 of A Creek CH910 MW232 Duck Creek CH2490 MW226 End of Section 2 CH3050 MW231 Near Duck River CH3310 MW235 Start of Section 4 CH3800 MW244 Opposite Melton St CH4800 MW252 Near Adderley St CH5300 MW259 Near Parramatta Rd CH6400 MW269 N of Parramatta Rd CH Baseline water conditions For further information on groundwater baseline data refer to Phase II Contamination and Acid Sulphate Investigation and Assessment (GHD, 2014). Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 5 of 29 Commercial in Confidence

187 5 Water quality standards and parameters 5.1 ANZECC and pre-construction monitoring Surface water Existing water quality in the Parramatta River estuary is degraded with average concentrations of water quality management parameters being above the ANZECC (2000) aquatic ecosystem health guidelines for south-east Australian estuaries. ANZECC provides a framework for the assessment of water quality in fresh water environments that identifies guidelines that can be used as a yardstick to determine possible risk to the environment. The ANZECC criteria can be used to initiate further investigations into surface water quality impacts from a specific site. In the absence of site specific data the ANZECC default values can be used as a guide until sufficient data is available. ANZECC assumes a steady state condition of creek lines which is problematic when applied to ephemeral creek lines due to the high variability of water flows and conditions which can lead to changes in the physical and chemical properties of the water compared to perennial streams. Water quality was measured as part of the EIS biodiversity assessment (SKM 2014) and the Project s Phase II Contamination and Acid Sulphate Investigation and Assessment (GHD, 2014). Table 8-1 provides the results from the EIS biodiversity assessment which compares 2014 water quality results against the ANZECC water quality guidelines. Table 5-1: Water quality sampling results Parameter ANZECC WQ Duck River Duck Creek Haslams Creek Guideline 2000 (Kay St) Turbidity (NTU) Dissolved Oxygen (mg/l) Dissolved Oxygen (%) Conductivity (ms/cm) Salinity (ppt) ph Groundwater Groundwater monitoring results (see Table 8-1) were observed to be reasonably consistent across the M4 West alignment, and within each of the strata: DO: results range from low to moderate oxygen levels typical of fresh/brackish groundwater. EC: results suggest that the groundwater is generally brackish to saline, which is expected for groundwater in the Ashfield Shale as this unit was formed in a marine environment. ph: readings were generally circum neutral which is typical for fresh/brackish groundwater. Oxidation-reduction potential indicated reducing conditions in many of the monitoring wells while some indicted potential oxidising conditions. During the purging and sampling of the groundwater wells, no obvious visual or olfactory evidence of contamination was recorded, with the exception of BH101 where a slight hydrocarbon odour was noted during the purging and sampling. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 6 of 29 Commercial in Confidence

188 6 Monitoring 6.1 Surface water The key surface water quality parameters that shall be monitored include: Conductivity (EC us/cm) Dissolved Oxygen (mg/l) Oil and Grease (any visible sheen) Turbidity (NTU) ph (units) Quarterly monitoring of hydrocarbons and heavy metals will be undertaken in addition to the physical parameters listed above. Surface water quality monitoring would be undertaken at the locations identified in Appendix 1 each month using a water quality monitoring probe during operations for the initial 12 months post Construction Completion. Note, in accordance with CoA B7 (f) - if impacts are identified after one year of monitoring, monitoring shall be continued for a further two years or until the affected waterways and/ or groundwater resources are certified by an independent expert as being rehabilitated to an acceptable condition. The monitoring shall also confirm the establishment of operational water control measures (such as vegetation swales); Monitoring will be undertaken for wet events (rainfall events where 10mm or more has fallen or rainfall that has caused runoff from the Maintenance Site) and monthly routine dry weather sampling for upstream and downstream readings. Where there is a difference greater than 20% between upstream and downstream further analysis and investigation will be performed to determine if the changes in water quality relate to operation activities. 6.2 Groundwater Groundwater will be monitored on a monthly basis for the following parameters: Conductivity (EC us/cm) Dissolved Oxygen (mg/l) Turbidity (NTU) ph (units) water level Groundwater will be monitored post rainfall would typically relate to rainfall events where 10mm or more has fallen or rainfall that has caused runoff from the site. Quarterly monitoring of hydrocarbons and heavy metals will be undertaken in addition to the physical parameters listed above. The monthly data will be reviewed to determine any trends. This would include reviewing the data for a variance of 20% from the results identified in Appendix 1 and implementing remedial measures if required. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 7 of 29 Commercial in Confidence

189 7 Contingency and ameliorative measures In the event that adverse impacts to water quality are identified as a result of M4 West O&M Activities, the QSE Manager will implement mitigation and/or remediation strategies to prevent future impacts. These may include: Implement stop works process in accordance with the OEMP Review and amendment of maintenance methodologies Use of alternative maintenance equipment Focus on stabilising disturbed areas with a cover crop, hydro-mulch, hydro- seeding, topsoil and/or mulch Increased monitoring and surveillance of O&M Activities Remediation of disturbed areas Recommence work once the corrective actions have been implemented and preventative actions determined and agreed 8 Reporting All surface water and groundwater sampling will be recorded on the Water Quality Monitoring Record Form (see Appendix 3) A summary of the water quality monitoring results will be reported as part of the O&M Contractor s monthly Environment Report to SMC. The quarterly compliance reports will also include all water quality monitoring results and will be submitted to the Secretary of DP&E, EPA, WaterNSW and City of Parramatta Council. Also involve Council in any water issues affecting surface waters in the Local Government Area, including atypical results and/or incidents that could substantially reduce water quality or affect the natural riparian environment. Incident reporting will be done in accordance with the OEMP. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 8 of 29 Commercial in Confidence

190 Appendix 1 Water quality sample locations Surface and groundwater Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 9 of 29 Commercial in Confidence

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202 Groundwater was purged and sampled from each monitoring well on 5 to 7 March 2014 (GHD boreholes) and 2 and 8 April 2014 (RMS geotechnical boreholes). Table 8-1: Groundwater monitoring boreholes Borehole D.O. (mg/l) E.C. (µs/cm) ph Eh (mv) Temp ( o C) Volume purged before sampling GHD groundwater monitoring boreholes MW MW MW206A* MW MW MW MW MW235 n/a n/a n/a n/a n/a n/a MW_RMS_COMP MW MW MW MW259 n/a n/a n/a n/a n/a n/a MW MW RMS Geotechnical boreholes BH BH BH BH BH BH BH BH BH Notes n/a Well was considered dry and no sampling or purging was able to be undertaken. Therefore, no sample or field parameters were obtained. * unstabilised field parameters. Grab sample only. Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 21 of 29 Commercial in Confidence

203 Appendix 2 Baseline water quality monitoring data Table 0-1: Baseline water quality data for surface water General Field Measurements Hydrological Data Sample ID Section Number Location description Sample Date Sampling Officers Sampling Method Environmental Observations (⁰C) Electrical Conductivity (us/cm) ph Dissolved Oxygen (ppm) Oxygen Reduction Potential (mv) Flow measurement x-section width (m) Depth (m) SW1 3 A'becketts Creek, adjacent to car wash, bike path 20/03/14 Alexander Spaller & George Iliopoulos Bomb sampler Fine weather, heavily vegetated w ith lantana present, gentle slope, little/ no erosion, some general rubbish stagnant SW2 4 Duck River, underneath footbridge, near M4 Motorway overpass, opposite High Tech (Industry) 20/03/14 Alexander Spaller & George Iliopoulos Disposable bailer Fine weather, mangroves and scattered vegetation, gentle slope, little/ no erosion, general rubbish, asbestos, concrete, scrap metal on bank, surface film and slight sheen on water moderate SW3 4 Duck River, underneath M4 Motorway, opposite High Tech (Industry) 20/03/14 Alexander Spaller & George Iliopoulos Disposable bailer Fine weather, mangroves and scattered vegetation, gentle slope, little/ no erosion, general rubbish, asbestos, concrete, scrap metal on bank moderate 25 4 SW4 4 Duck Creek and Duck River intersection 20/03/14 Alexander Spaller & George Iliopoulos Disposable bailer Fine weather, mangroves, gentle slope, no erosion moderate 15 2 SW5 3 A'becketts Creek nearby Good Street, M4 overpass, cementlined stormwater drain 20/03/14 Alexander Spaller & George Iliopoulos Fine weather, scattered vegetation - large trees with Disposable bailer lantana, steep slope, moderate erosion slow SW6 6 Haslam's Creek, 10 m eastof Western Motorw ay overpass, industrial surroundings 21/03/14 Alexander Spaller & George Iliopoulos Dedicated unpreserved plastic bottle Overcast weather, concrete lined channel, grass and weeds, steep embankment, little erosion, absorbment booms in creek, general rubbish in water slow 20 2 SW7 6 Haslam's Creek, east of M4 Motorw ay 21/03/14 Alexander Spaller & George Iliopoulos Disposable bailer Overcast weather, concrete lined but some vegetation on eastern embankment, steep slope, no erosion stagnant 20 >2 SW8 3 Duck Creek nearby James Ruse Drive overpass, M4 Motorway, factory surrounds 21/03/14 Alexander Spaller & George Iliopoulos Bomb sampler Fine weather, trees with lantana, steep slope, minimal erosion, general rubbish in water slow SW9 3 A'becketts Creek, adjacent to Western Motorw ay, underneath footbridge, residential surrounds 21/03/14 Alexander Spaller & George Iliopoulos Disposable bailer Fine weather, no vegetation, moderate slope, cement-lined stormwater drain slow Sydney Motorway Corporation M4 Motorway: Operational Environmental Management Plan: OEMPSP4 Page 22 of 29 Commercial in Confidence

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