POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN EPA LICENCE NO.5411 – ALBURY WATER FILTRATION PLANT AW - 114

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SITUATION

The Protection of the Environment Legislation Amendment Act (POELA Act) 2011 requires

Environmental Protection Licence holders to prepare, keep, test and implement a Pollution

Incident Response Management Plan. This regulation became effective as at 1st September

2012.

APPLICATION

This document sets out Council’s response to pollution incidents under POELA Act, POEO

Regulation and EPA Licence 5411.

IMPLEMENTATION

The flow chart on page two sets out the procedure to be implemented.

ADMINISTRATION

The remainder of the document details the requirements under the POEO regulations as

summarised in the table of contents.

The PIRIMP testing and update register can be found at Appendix E.

COMMUNICATION

Enquiries shall be directed to the Team Leader Water and Wastewater Operations on 02 6023

8167 or Group Leader Water and Wastewater on 02 6023 8170

Colin Johnson Group Leader Water & Wastewater

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Albury City Council – EPA LICENCE No.5411

Pollution Incident Response Management Plan

Flow Chart

Police Fire Ambulance Workcover NSW Health EPA ACC RMO ACC OH&S ACC TLO NSW Fire & Rescue

000 (112) 000 (112) 000 (112) 13 10 50 6080 8999 131 555 0429 444 904 0408 400 219 0417 663 276 1300 729 579

Incident Notification

Did an injury occur?

Did a fire occur?

Are persons in danger?

Yes No

Yes

Phone – 000 (Ask for Fire Brigade, Ambulance, Police as required)

Phone – Workcover on 13 10 50

Phone – Team Leader Water & Wastewater

Operations on 0417 663 276

Phone - ACC Risk Manager on 0429 444 904

- ACC OH&S Officer on 0408 400 219

Is the substance which leaked or spilled raw sewage or Waste Water Treatment Plant effluent?

Does the spill involve potential harm to;

No Yes

Clean up – Ref MSDS & SOP

Is assistance required?

Phone - NSW Fire Brigade on 000

Manage the incident response as directed by response

authority in control of the incident scene. Also consult council

policy for OH&S, Risk Management and Operating

Procedures of the facility where applicable.

Go directly to the Sewage Overflow

Notification flow chart AW-016. Health and safety of human beings Ecosystems / Environment

No No Yes Yes

Phone - EPA on 131 555 &

- NSW Health on 6080 8900

No

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Table of Contents

1. Introduction ................................................................................................................................. 4

2. Definition of Premises ................................................................................................................ 4

3. Definition of Pollution Incident .................................................................................................. 5

4. Incident Risk Analysis ................................................................................................................ 5

5. Risk Minimisation actions and resultant risk level acceptable ................................................ 5

6. Inventory of Potential Pollutants ............................................................................................... 6

7. Safety equipment and infrastructure used to contain or control impact of incident ............. 6

8. Personnel .................................................................................................................................... 8

9. Names & Contact details of owners & occupiers of premises in the vicinity ......................... 8

10. Mechanism for early warning system to premises in the vicinity............................................ 8

11. Procedures for notification of pollution incidents .................................................................... 8

12. Follow up actions following pollution incidents ....................................................................... 8

13. Arrangements for minimising risk of harm to people on the premises................................... 8

14. Detailed Map ................................................................................................................................ 9

15. Description how risk will be limited ........................................................................................... 9

16. Training Provided to Staff .......................................................................................................... 9

17. How will the plan be tested ........................................................................................................ 9

18. Record of testing exercises ....................................................................................................... 9

19. Appendix A – Risk Analysis ..................................................................................................... 10

20. Appendix B – Map of Premises ................................................................................................ 11

21. Appendix C – Material Safety Data Sheets .............................................................................. 13

22. Appendix D – Pollution Incident Reporting Form ................................................................... 14

23. Appendix E – PIRMP Testing and Update Register ................................................................ 16

24. Appendix F – PIRIMP Staff Training Register ......................................................................... 17

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1. Introduction

Council was notified by the EPA by letter dated 16 January 2012 of the following (as set

out in Part 5.7A of the POEO Act and the Protection of the Environment Operations (General)

Regulation 2009 (POEO(G) Regulation)).

All holders of environment protection licences must prepare a pollution incident response

management plan (section 153A, POEO Act).

The plan must include the information detailed in the POEO Act (section 153C) and be in the

form required by the POEO(G) Regulation (clause 98B).

Licensees must keep the plan at the premises to which the environment protection licence

relates or, in the case of trackable waste transporters and mobile plant, where the relevant

activity takes place (section 153D, POEO Act).

Licensees must test the plan in accordance with the POEO(G) Regulation (clause 98E).

If a pollution incident occurs in the course of an activity so that material harm to the

environment is caused or threatened, licensees must immediately implement the plan (section

153F, POEO Act).

This document sets out Council’s response to pollution incidents for EPA Licence 5411,

2. Definition of Premises

Definition of Premises is detailed in Licence 5411 in SectionA2 as follows

A2 Premises to which this licence applies

A2.1 The licence applies to the following premises: Premises Details ALBURY WATER FILTRATION PLANT WATER WORKS ROAD ALBURY, NSW, 2640 LOT 1 DP 840823

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3. Definition of Pollution Incident

The definition of a pollution incident is,

“pollution incident means an incident or set of circumstances during or as a

consequence of which there is or is likely to be a leak, spill or other escape or

deposit of a substance, as a result of which pollution has occurred, is occurring or

is likely to occur. It includes an incident or set of circumstances in which a

substance has been placed or disposed of on premises, but it does not include an

incident or set of circumstances involving only the emission of any noise.

A pollution incident is required to be notified if there is a risk of ‘material harm to the

environment’, which is defined in section 147 of the POEO Act as:

(a) harm to the environment is material if:

(i) it involves actual or potential harm to the health or safety of human

beings or to ecosystems that is not trivial, or

(ii) it results in actual or potential loss or property damage of an amount,

or amounts in aggregate, exceeding $10,000 (or such other amount

as is prescribed by the regulations), and

(b) loss includes the reasonable costs and expenses that would be incurred in

taking all reasonable and practicable measures to prevent, mitigate or

make good harm to the environment.

Industry is now required to report pollution incidents immediately to the EPA, NSW

Health, Fire and Rescue NSW, Work Cover NSW and the local council. ‘Immediately’ has

its ordinary dictionary meaning of promptly and without delay. “

4. Incident Risk Analysis

Pollution incident classification and risk assessment can be found at Appendix A.

5. Risk Minimisation actions and resultant risk level acceptable

Risk minimisation actions and resultant acceptable risk can be found at Appendix A.

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6. Inventory of Potential Pollutants

Pollutants found on the premises with their location scheduled below and on the map at

Appendix B.

7. Safety equipment and infrastructure used to contain or control impact of incident

Water Filtration Plant

All chemicals at the Water Filtration Plant are detailed in the Emergency Information

folder located adjacent to the main entrance to the premises. This folder details the

location of chemicals, a chemical risk assessment and MSDS sheets as required by,

Dangerous Goods Legislation and Work Cover regulations.

Chlorine Gas is contained in 1000 kg cylinders in two locations. Plant A Chlorine

room contains up to two cylinders and Plant B chlorine room up to three cylinders.

Serial Chemical / Pollutant Location Quantity

1 Alum (liquid) Water Filtration Plant

Waterworks Rd

60000 litres

2 Chlorine Gas Water Filtration Plant

Waterworks Rd

4000 kg

3 Polyelectrolyte (Powder) Water Filtration Plant

Waterworks Rd

500 kg

4 Sodium Silica Fluoride (Powder) Water Filtration Plant

Waterworks Rd

6000 kg

5 Raw Sewerage Main Clear Water Pump

Waterworks Rd

NA

6 Hydrated Lime (Powder) Water Filtration Plant

Waterworks Rd

20000 kg

7 Powdered Activated Carbon

(Powder)

Water Filtration Plant

Waterworks Rd

6000 kg

8 Sodium Hypo Chlorite Riverina Hwy – East – PS

Table top Rd – Pump Station

Table top – Chlorine Booster

Bandalong - Chlorine Booster

Bonnidoon – Chlorine Booster

100 litres

100 litres

1 kl

1 kl

100 litres

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All operators are trained in the handling of chlorine gas. Entry into the rooms is

governed by AW-097 Chlorine Plant Inspection Checklist.

Sodium Fluorosilicate Powder is contained in 20 Kg bags in two locations. Plant

A fluoride room and Plant B fluoride room with each room containing up to 3000

kg. All operators are trained in the handling of fluoride. Entry into the rooms is

governed by AW-100 Fluoride Plant Inspection Checklist and AW-39 Fluoride

Management Plan.

Alum Liquid is contained in two bulk storage tanks servicing both plants. The

tanks are bunded and spillage can be recovered or drained to sludge lagoons on

the premises.

Polyelectrolyte powder is contained in 25kg bags in the Plant B chemical room.

No specialised training is required to handle this material.

Hydrated Lime Powder is contained in a bulk storage bin common to both plants.

No specialised training is required to handle this chemical.

Powdered Activated Carbon Powder is contained in 1000 kg bags and loaded

into the dosing system as required. No specialised training is required to handle

this chemical.

Sodium Hypochlorite is held at five locations. Two 1000kL sites at Bandalong Rd

and Table Top. Three 100 litre sites at Bonnie Doon pump Station, Riverina

Hwy.(East) pump station and Table Top Rd pump station. Calibration and dose

adjustment at each of these sites is regulated by AW-106 and AW-107

respectively.

Raw Sewage – A sewage pump station is located on these premises at the main clear

water pump station. Management of this material is subject to Council’s Sewage

Overflow notification procedure AW-016.

The response to incidents involving this material is dependent on the site and scale of

the incident.

Typical response will include clean up and disinfection of the contaminated site

including removal of contaminated material if necessary.

General Clean up

Chemical spill cleanup kit – 240 litre wheelie bin containing booms, sheets of

absorbent material, centrally located at Jelbart Rd. Also additional bags of absorbent

material carried on the Calcium Nitrate trailer.

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8. Personnel

Council’s Team Leader Water and Wastewater Operations is

Responsible for and authorised to activate the plan

Authorised to Liaise with relevant authority

Responsible for managing councils response

9. Names & Contact details of owners & occupiers of premises in the vicinity

Details of premises in the vicinity can be sourced directly from Council’s intranet / GIS

system. The following houses are immediately adjacent to the Water Filtration Plant,

names and phone numbers are not published here as they are confidential (to be hand

written in the onsite document).

Assessment - 11263 – Skillen La – Occupant – Phone See operator copy

Assessment - 25743 – Riverina Hwy – Occupant – Phone See operator copy

Assessment - 345805 – Skillen La – Occupant – Phone - Vacant

10. Mechanism for early warning system to premises in the vicinity

In terms of advising residents this will be accomplished by a door knock action at the

discretion of the combat authority or the Team Leader Operations as required.

11. Procedures for notification of pollution incidents

See Pollution Incident Response Management flowchart on page two.

12. Follow up actions following pollution incidents

Report to EPA as directed

Comply with directions of EPA as required

Implement Council’s internal incident reporting procedure

Review of plan and update

Retrain staff if required

13. Arrangements for minimising risk of harm to people on the premises

Employees are required to comply with Albury City OH&S policies applicable to the work site including;

Personal Protective Equipment including self contained breathing apparatus,

Trained First Aid Officer,

Council OH&S procedure,

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Contractor registration,

SOP’s for onsite handling of chemicals,

Officers trained in chemical handling

Notification of dangerous goods on premises and licence as required,

Emergency information folder readily accessible to incident response authorities at the entrance to the premises or adjacent to emergency assembly areas.

Copy of PIRMP and EPA licence on site with emergency information folder.

Visitors to the sites are required to sign in and be accompanied by an operator at all times unless specifically inducted and registered to work independently.

14. Detailed Map

A map of the Albury Filtration Plant detailing chemical location, neighbours and

surrounding property boundaries can be found at Appendix B.

15. Description how risk will be limited

Early Warnings; This can be accomplished by

o Placing alarms on storages to indicate sudden change in levels via Council’s

SCADA system which is networked throughout the organisation.

o Daily inspections of high risk chemical storages

o Implementation of a comprehensive maintenance management programme for

mechanical and electrical assets

Review of actions taken after or during and incident

Maintenance of bunding and on site operation procedures for each site as detailed in

item 7 above.

16. Training Provided to Staff

See Appendix F

17. How will the plan be tested

See Appendix E

Council intends to conduct table exercises based on scenarios applicable to the sites in question.

18. Record of testing exercises

See Appendix E

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19. Appendix A – Risk Analysis

PENDING

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20. Appendix B – Map of Premises

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21. Appendix C – Material Safety Data Sheets

MSDS information not included here.

MSDS can be found on the premises in the

emergency management information folder

located adjacent to the main entrance of the

plant.

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22. Appendix D – Pollution Incident Reporting Form

DATE

TIME

LOCATION

DESCRIPTION OF THE INCIDENT

WEATHER CONDITIONS

NATURE, ESTIMATED QUANTITY, VOLUME AND CONCENTRATION OF POLLUTANT IF KNOWN

CIRCUMSTANCES OF THE INCIDENT INCLUDING THE CAUSE IF KNOWN

CORRECTIVE ACTION TAKEN TO MANAGE OR PROPOSED TO BE TAKEN TO MANAGE THE

INCIDENT

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HAS THE TEAM LEADER OPERATIONS BEEN NOTIFIED? YES NO

HAS THE DIRECTOR OF ENGINEERING BEEN NOTIFIED? YES NO

WAS 000 (EMERGENCY SERVICES) CONTACTED? YES NO

WAS NSW HEALTH NOTIFIED? YES NO

WAS WORKCOVER NOTIFIED? YES NO

WAS FIRE AND RESCUE NOTIFIED? YES NO

WAS THE EPA NOTIFIED? YES NO

WERE NEIGHBOURS NOTIFIED? YES NO

YES NO

TITLE SIGNATURE DATE

TEAM LEADER WATER & WASTWATER

OPERATIONS

GROUP LEADER WATER &

WASTEWATER

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23. Appendix E – PIRMP Testing and Update Register

SERIAL DATE TEST OR

UPDATE

LAST

INCIDENT

DATE

SUPERVISORS

ADVISED DATE

DETAILS

1 BELOW

2 BELOW

3 BELOW

4 BELOW

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24. Appendix F – PIRIMP Staff Training Register

I CERTIFY THAT I HAVE BEEN INSTRUCTED IN THE PROCEDURES REQUIRED FOR ALBURY CITY

COUNCILS RESPONSE TO POLLUTION INCIDENTS AS REQUIRED UNDER THE POLLUTION OF THE

ENVIRONMENT LEGISLATION AMENDMENT ACT 2011.

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