POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN (PRIMPS) Bituminous Products PTY LTD

Transcription

1 POLLUTION INCIDENT REPONSE MANAGEMENT PLAN POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN (PRIMPS) Bituminous Products PTY LTD 33 & 35 Violet Street Revesby NSW Industry is now required to report pollution incidents immediately to ALL regulatory bodies. Call 000 if the incident presents an immediate threat to human health or property. If the incident does not require an initial combat agency, or once the 000 call has been made, notify the Managing Director to contact the remaining authorities in the following order: NSW Environment Protection Authority The Ministry of Health (Ask Public Health Officer on call) Safework NSW Canterbury Bankstown Council (02) (office hours) Fire and Rescue NSW Also call Transpacific (Cleanaway) Spill response 1800 SPILLS ( ), if required. Revision Status Date Issue By Checked Approved 10/07/ Mel Fazeli Ken Telfer Greg McRae 25/10/ Mel Fazeli Ken Telfer Greg McRae 27/09/ Greg McRae Janette Fowler Neil Morcombe 28/09/ Greg McRae Janette Fowler Neil Morcombe 11/11/ Glenn Brayley Tuan Luu Neil Morcombe 15/09/ Glenn Brayley John Arvanitidis Neil Morcombe BP COR PL REV 6 Page 1 of 1

2 POLLUTION INCIDENT REPONSE MANAGEMENT PLAN 01/09/ Glenn Brayley John Arvanitidis Neil Morcombe BP COR PL REV 6 Page 2 of 2

3 3.3.5 Contact details [clause 98C (1) (g) and (h)] Position Name Work Number After Hours Managing Director Neil Morcombe WHSE Coordinator Glenn Brayley DEFINITION OF POLLUTION INCIDENT Under NSW Regulations: 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. Notification Protocol Appendix A contains the Protocol for Industry Notification of Pollution Incidents, to be updated for each site and posted on the sites noticeboards. If the incident clearly requires notification, (e.g. tank collapse with bund breached and liquid entering canal), the most senior person on site shall commence notification (Emergency Numbers) if the Managing Director is not present. This person shall also then immediately contact the Managing Director of who will notify all remaining authorities immediately including the EPA. In the event of any pollution incident, notify the Managing Director immediately to determine if it meets the definition of the attached protocol. The Managing Director will be the primary contact point for the authorities. BP COR PL REV 6 Page 3 of 3

4 POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN (PRIMPS) Description and likelihood of hazards & associated risks [Regulation clause 98C (1) (a) and (b)] Pre-emptive actions (controls) to be taken [Regulation clause 98C (1) (c)] Table as per Business Unit Risk Register (incorporated as an extract of Business Unit Annual Plan) Aspect / Hazard Impact / Risk Potential Business Unit Risk Current Business Unit Controls Business Unit Annual Plan (BURR). IMS, SOP- Fire Prevention, Hazardous Zones, LPG Filling, Training - Training Matrix/TNA, Monthly Reporting KPI, Hazard Observation Program, Workplace design and layout, JSEA. Site Induction - Uniform policy and procedure. Current Business Unit Risk Risk Assessments Hazop CAP. Hazardous Zone Classification & risk assessment. Fire risk assessment completed. Designated smoking areas on site - risk assessment completed. Fire & Explosion Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate. 22 Procedures - Work Instructions Work Permits (for solvent transfers/hot work on site). Hose register (tested by BAT). Equipment registers (Test & Inspection Program-preventative maintenance). CO2 cylinders Suppression system on U-Mixers. Administrative controls in place Induction, Contractor Management Procedures, Signage, Emergency Management Plan. Evacuation maps completed at emergency exits. 12 Training DG training completed for operators. Risk Management, Emergency awareness, emergency control and fire fighting training. Safework NSW DG notification & license. Forklifts used in hazardous zones (spark arrest system -wet scrubber/ no electricals). BP COR PL REV 6 Page 4 of 4

5 Annual Fire Statement Certificate completed & displayed. Emergency manifest completed & stored within manifest cabinets. Evacuation rehearsals completed as per Business Unit Annual Plan. Fire service provider - Extinguisher Services PTY LTD (Harley). SOPs and WI contain SEQ prompts and hold points, Training Plan/matrix, Workplace design and layout, JSEA. Site Induction - Uniform policy and procedure. Physical Hot/Cold (burns) Exhaustion, dehydration, illness, physical harm, burns, fatality, corporate prosecution 17 PPE management of inventory by supervisor/s. PPE to be worn on bitumen transfers & sampling as per Work Instructions and JSEAs for transfer of liquids at elevated temperatures and hot surfaces. Hazard signage for hot surfaces displayed on site 33 (including laboratory). Emergency Management. Trained first aiders. Provision for burns (heat & bitumen) incorporated in FAK for both sites. Bitumen burns cards. Heat tracing installed on vessel outlet valves and pouring arms. Emergency showers (green light). Platform ladder utilised for safe completion of bitumen sampling. Specialised bitumen container for bitumen samples. Working Safely with Bitumen Course. 13 Rest breaks, provision of amenities and climate control devices. Allegro neck ties used in summer (mitigate heat stress). Investigate climatic cooling aids ice vests. Heat stress to be addressed in all JSEAs. Air conditioners added to test and inspection program. WI & JSEAs for gas cylinders. Training for gas decanting. Signage and instructions displayed for gas cylinders -chained. Toolbox talk meeting presentation (Safetycare DVD on Heat illness) completed annually. Chemical risk assessments for hazardous substances completed. Chemical - exposure Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate 13 Chemical/hazardous substances management training conducted. MSDS (SDS) register completed and available in crib room on site 35 & office in buildings 29 & 35 for all workers (location signposted). Workers have received DG awareness information on chemicals handled & stored on site. Face fit training for respirators (by 3M). PPE provided for all tasks 7 BP COR PL REV 6 Page 5 of 5

6 involving chemicals used on site - supervisor/s manage PPE inventory (safe handling code & matrix). Site management have completed DG course in DG Class 3 to ensure storage of DG on site is as per AS 1940 and AS Uniform laundry service. Atmospheric contamination monitoring completed on paint manufacturing plant. Emissions to water (anything that changes the biological, chemical or physical nature of the receiving water, including water pollution, sediment, heat, salinity, etc) Emissions to Air (including climate change gases, ozone depleting gases, dust, smogs, heat, vapour, etc). Unburn't hydrocarbon causing odour emissions. Water pollution, aquatic ecosystem degradation, chronic and acute human, fauna & flora impact, contaminated potable water and food supply, corporate reputation, corporate prosecution, individual prosecution, inability to operate, license conditions, share price, general environmental and social impacts, human health, community aesthetics Air Pollution; ozone depletion, climate change, smog, acute and chronic impact on humans and natural fauna & flora, nuisance complaints, corporate reputation, corporate prosecution, individual prosecution, inability to operate, license conditions, share price, general environmental and social impacts Vapour recovery system to reduce VOC emissions (wet scrubber). Dust extraction system/s-both plants. Mechanical ventilation for paint plant. Stack Testing Monitoring as per license conditions. Oil/ water separator - closed system on Site 33. No trade waste agreement in place Worth Recycling dispose of waste in tanks. Site is fully bunded. Bunding regularly inspected/ maintained (operator s checklist & workplace inspection). Spill kits located around site. Hydrocarbon traps installed on site 35. Bunding installed for dosing chemicals for both cooling towers. Stainless steel fittings installed on cooling tower. Bunding installed on tanks & processing vessels. Emergency management procedures in place - spill kits (extra spillsorb). TPI (Cleanaway) assistance for spills. Stormwater management plan documented. License/ Consent Conditions, SOP, BUAP - Site Environmental Management Plan (BUAP), monitoring programme, planned maintenance, NPI reporting, auditing. Augers installed on main U-Shaped mixer vessels. Augers are specialist equipment (closed system) which reduce the air emissions during manufacture. Vapour recovery system when tanker loading via wet scrubber. OEH Licence requires annual emission testing of furnace stack and wet scrubber (monitoring report by Stephenson's). Furnace interlocked with blower plant to operate only at temperature exceeding 760'c. 7 7 BP COR PL REV 6 Page 6 of 6

7 Hazardous substance leak/spill Mechanical fixed plant Land, air and/or water contamination, local ecosystem destruction, corporate reputation, corporate prosecution, individual prosecution, share price, capital cost for remediation, human health, fire & explosion, general environmental and social impacts Physical harm, property damage, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate Potential - body falls, slips, trips Physical harm 13 Contractors & Visitors Pedestrian & Vehicle Interaction Physical harm, fatality, corporate reputation, corporate prosecution, individual prosecution Injury, fatality, corporate reputation, corporate prosecution, individual prosecution Injury, fatality, corporate reputation, corporate prosecution, individual prosecution Spill Response Training (Spill Station), SOP, waste tracking system (TPI - Cleanaway) Spill kits in place. Site bunded. TPI (Cleanaway) for timely emergency response for external spill. Spill Response training. High level alarms fitted to storage tanks. Maintenance completed as per manufacturers recommendations (schedules). Equipment register - Test & Inspection Program. Mechanical tradesperson contractors employed on site in maintenance role. Long term electrical contractor employed to maintain electrical equipment. WIs revised to include operations pre-start checklists. Plant commissioned as per SOP. Guarding audit completed. Work permit/ Isolation training and SOP. Housekeeping SOP. Safety Interactions (observations), WI and JSEAs completed on sites. Periodic inspection of ladders. Workplace inspections. Information on preventing slips, trips and falls displayed on SEQ noticeboard. Uneven areas (including nosing) highlighted on platforms & stairs (lab & plant). SOP - Contractors/Visitors. Planned maintenance, Insurance policies and audits. Site Inductions (Powerpoint Presentation/ questionnaire) completed for preferred contractors utilised by the site. Sign in book. Work permit system utilised for contractors completing high risk activities on site SWMS/ JSEAs. Restricted access to site- site induction for operational areas. Speed limit signage in place (10km). Tankers reverse as per AS 1940/ ADG Code 7. Speed humps and signage in place on site 35. Signage audit completed. Visitors book on site. All visitors escorted while on site. Contractors complete site induction. Designated walkways marked. Formal traffic management risk assessment/ plan. RTA traffic control courses completed by relevant staff for directing tankers/trucks onto/from site. Forklift pre-start checklists completed. Forklifts maintained by trade qualified contractor according to manufacturer s recommendations BP COR PL REV 6 Page 7 of 7

8 Manual Handling Work at heights (fall from one level to another) Physical harm Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate Basic manual handling training. JSEAs include manual handling risks where relevant. Forklifts/lifting aids used for most manual handling tasks on site. Scissor lift table for paint plant. Scaffolds/man-lift cage for maintenance tasks. Manual handling risk assessment. Ergonomics - valves at waist height. Fall arrest systems in place on client tanker trailers. Work Safely at Heights training completed for relevant staff. Scaffold refurbished by Oldfield s. Zippy scaffold (small) utilised for maintenance tasks. Man-lift cage utilised for maintenance tasks- Training. Work platforms comply with AS Fixed ladders on plant main platform only used for emergency exit. Periodic inspection of ladders template. Lifting gear register (harnesses/rescue kit) - inspected by LB Wires BP COR PL REV 6 Page 8 of 8

9 3.3.3 Inventory of pollutants [Regulation clause 98C (1) (d) and (e)] Site Chemical Manifest: Form B - Site Chemical Substances List BUSINESS: Bituminous Products PTY LTD Bitumen Manufacturing Plant DATE: 01/09/2017 ADDRESS: 33 Violet St Revesby CONTACT: Site 24 hour contact Neil Morcombe Location of Substance Proper UN DG PG Hazardous MSDS Volume EPG Tank / Shipping Cla (Yes/No) Typical No. Vessel Size Name ss (litres) Depot No. Bulk Tank No. Depot 1 Tank 14 Base Oil (C2) NA NA NA N Y NA Y Tank 15 Diesel Fuel NA C1 CAT 4 Y Y NA Y Risk Assessment conducted (Yes/No) Depot 2 Tank M DIA Tank M DIA Tank M DIA Tank M DIA U-Shaped Mixer N0: M5 Packaged Products Turpentine III Y Y Y Substitute Xylenes III Y Y Y Kerosene III Y Y Y Tars, Liquid II Y Y Y Elevated Temperature Liquid III N Y Y Tars, Liquid II Y Y NA Y BP COR PL REV 6 Page 9 of 9

10 Depot 3 IBC/ 205 litre drums Depot 4 Tank 25 U-Shaped Mixer N0: M6 U-Shaped Mixer N0:22 U-Shaped Mixer N0: M1 U-Shaped Mixer N0: M2 U-Shaped Mixer N0: M3 U-Shaped Mixer N0: M4 Tank 5 2.8M DIA Tank 6 Amines, Liquid, Corrosive, NOS Amines, Liquid, Corrosive, NOS Elevated Temperature Liquid, NOS Elevated Temperature Liquid, NOS Elevated Temperature Liquid, NOS Elevated Temperature Liquid, NOS Elevated Temperature Liquid Elevated Temperature Liquid, NOS Elevated Temperature Liquid, NOS Pre-coat (C2) II & III Y Y NA Y III Y Y Y III N Y Y III N Y Y III N Y Y III N Y Y III N Y Y III N Y Y III N Y 20, Y N Y Y BP COR PL REV 6 Page 10 of 10

11 Depot 4 continued Tank 7 Dry Fuel Oil (C2) Y Y Y Tank 8 2.8M DIA Tank 9 2.8M DIA Tank 10 Tank 11 Pre-coat (C2) Elevated Temperature Liquid, NOS Dry Fuel Oil (C2) Dry Fuel Oil (C2) N Y Y III N Y Y Y Y Y Y Y Y Tank 12 Diesel Fuel NA C1 CAT 4 Y Y Y Tank 20 Diesel Fuel NA C1 CAT 4 Y Y Y Tank 28 Dry Fuel Oil (C2) NA Y Y Y Notes. Site #33 tanks 23, 33 & 36 along creek contain waste water. Site #33 surface water is fully contained with all rain water collected into 3 x Storm Water Tanks (18KL each). Location of Substance Depot No. Bulk Tank No. Gas Bottle Storage LPG Oxygen Acetylene Proper Shipping Name Petroleum Gases, Liquefied Oxygen, compressed Acetylene, dissolved UN DG Cla ss PG Hazardous MSDS (Yes/No) Volume Typical EPG No. Tank / Vessel Size (litres) NA Y Y 2 x Y / NA Y Y 2 x Y NA Y Y 2 x Y Risk Assessment conducted (Yes/No) BP COR PL REV 6 Page 11 of 11

12 Gas Bottle Storage cont Argon Ammonia Argon, compressed Ammonia, anhydrous NA Y Y 2 x Y / 8 NA Y Y 1 x Y Form B - Site Chemical Substances List Site: Bituminous Products PTY LTD - Paint Plant DATE: 09/03/2016 ADDRESS: 35 Violet St Revesby Location of Substance Depot No. Bulk Tank No. Depot 5 Packaged Product Proper Shipping Name PAINT or PAINT RELATED MATERIAL UN DG Cla ss PG II & III Note: Site #35 storm water goes to drains via hydrocarbon traps. Hazardous (Yes/No) MSDS (Yes/No) Volume Typical CONTACT: Site 24 contact Neil Morcombe EPG No. Tank / Vessel Size Y Y Y Risk Assessment conducted (Yes/No) BP COR PL REV 6 Page 12 of 12

13 3.3.6 Communicating with neighbours and the local community [clause 98C (1) (i)] Bituminous Products PTY LTD comprises an office, storage buildings and two manufacturing plants. The site is located in an industrial area with no schools or hospitals in the immediate area. Therefore, the only incident which would impact on the local neighbours, would be a fire/explosion in the operations area on either site 33 or site 35. As all tanks are located in bunded areas and the stormwater drains are fitted with emergency shut off valves, the likelihood of a significant spill to stormwater is minimal. Tanks are also fitted with high level alarms. In the event of an uncontrollable spill due to leak or fire water, the liquid would enter the stormwater canal where it would not affect human health. The liquid would be contained in the area of the canal between both sites by spill kits located at either end of site 33. In the event of a fire the decision to notify to the neighbours would be made in conjunction with the fire Brigade based on risk, severity and wind direction. The local fire brigade is located in River road (less than 5 km). Immediate neighbours to be notified are as follows and there location is shown in map. Contact numbers for the neighbours are: Neighbours Business name Contact Number Quality Castings Intasys Er Curtain Bingo Recycling Minimising harm to persons on the premises [clause 98C (1) (j)] The site has established Emergency Response Plans, adequate fire protection in the form of fire extinguishers & hose reels (tested six monthly).there is also provision for foam on site #33 which would be used in the event of a large spill event from hydrocarbons from a tank. There is an audible alarm system activated by manual call points tested weekly and evacuations drills carried out at least annually. BP COR PL REV 6 Page 13 of 13

14 All staff are trained in fire fighting extinguisher (C02 & Dry Chemical powder) & the plant operators with hose drill by our fire service provider (Extinguisher Services Pty Ltd). Evacuation The fire Alarm is also the evacuation alarm. Regardless of the situation if the fire alarm is activated via manual call point, evacuation must take place and the most senior person on site takes responsibility. If a clear danger exists, emergency services will be called by the emergency coordinator (Chief Warden). The Chief Warden or Area Warden may reassess the situation for immediate actions to take place. If the designated evacuation point becomes endangered, or the evacuees need to remain outside the premises for an extended period, all personnel will be relocated to a suitable point at the direction of the emergency coordinator. Head Count After evacuation, all persons on site including visitors and contractors shall assemble at the evacuation point. The evacuation or assembly point is located at the gate of the front car park. Emergency response staff will conduct a roll call to ensure all persons are accounted for including visitors and contractors. Missing persons shall be advised to the emergency coordinator, who will then advise the emergency services. No personnel shall undertake search and rescue for missing persons in endangered areas. Adjacent Areas The occupants of adjacent premises are to be advised if endangered by the emergency. Evacuation of adjacent premises is the responsibility of the individual companies and the emergency services. Re-Entry Re-entry to the site will not take place until advised by the emergency services to do so. This will be relayed to all personnel by the emergency coordinator. Review The evacuation plan shall be reviewed: a. Following any emergency or training exercise that exposes any short comings. b. Following any significant changes to the layout or operations. c. At least once annually BP COR PL REV 6 Page 14 of 14

15 3.3.9 Actions to be taken during or immediately after a pollution incident [clause 98C (1) (l)] Spills When safe to do so: Isolation and containment of spill Raise alarm, ensuring this closes stormwater valves Stop the source of the spill; In all situations the priority is to isolate the spill using the appropriate spill containment equipment from appropriate spill kits; Refer to the Section for the Hazchem code for Emergency Procedures During the isolation and containment, appropriate personal protective equipment is to be worn to handle the substance; Ensure the scene has been secured especially if the spill is located close to sensitive receiving environments. Off-site spill recovery procedure In the event the liquid leaves the site and enters stormwater see Map 2 for location of offsite containment areas. Clean up and disposal of spills All spills will be cleaned up using the appropriate material such as a spill kit, absorbent rags, or sand. Absorbent products are placed in an empty drum and processed with other drums of absorbent waste awaiting disposal. The hosing down of spill areas shall be avoided to prevent run-off to the soil, stormwater, or sewerage systems. Air pollution (Fire or Explosion) Notify relevant management immediately and emergency services if required. In the event of an evacuation due to fire or explosion, emergency evacuation procedures are to be followed and immediate neighbours notified by direct contact or phone. If safe to do so the plant will be shut down according to procedures set in Appendix A Staff training [clause 98C (1) (m, n, o, p)] Staff training is maintained according to the site training register (TNA/matrix). Bituminous Products Pty Ltd requires all sites to undergo an Emergency Evacuation Exercise at least every 12 months. Training in emergency awareness is to be conducted annually. Emergency control training is to be completed for wardens and BP COR PL REV 6 Page 15 of 15

16 also refreshed every 12 months. Training in fire fighting equipment is scheduled at least every two years. This plan is incorporated into that exercise; records of attendance are kept on the sites training records. Spill response training is also completed at least annually with a scenario incorporated to test emergency preparedness in the event of a spill. Training Training Organisation(RTO) Last Completed Emergency Awareness Internal As per training matrix Emergency Control Internal As per training matrix Fire Fighting Evacuation Rehearsal Spill Response PRIMP Plan Extinguisher Services Pty Ltd Internal (meeting debrief of ERT) Internal (spill station training package) Internal (scenario-table top exercise)* Due in 4Q /09/17 As per training matrix 29/09/17 First Aid Reviva As per training matrix * To be carried out by 1 senior manager, 1 other staff member and 1 worker, prior to the annual revision of this plan. BP COR PL REV 6 Page 16 of 16

17 POLLUTION INCIDENT REPONSE MANAGEMENT PLAN Safety equipment [Regulation clause 98C (1) (f)] Fire fighting equipment on site includes hose reels & extinguishers (CO2 & Dry Chemical Powder). There is a hose reel on site 33 with provision for foam. Spill kits are located around the site with provision to clean up spills entering the canal (booms) which runs between site #33 & site #35. Hydrocarbon traps are installed on the stormwater drains on site #35. All site areas are bunded Maps [clause 98C (1) (k)] Maps - General, Neighbours & Site (showing tank location) 33 Violet Street, Revesby N BP COR PL REV 6 Page 17 of 17

18 POLLUTION INCIDENT REPONSE MANAGEMENT PLAN ER Curtain Intasys Bituminous Products Site 29 Bituminous Products Site 33 Bituminous Products Site 35 Vulkan Advanced Engineering Billabong Water BP COR PL REV 6 Page 18 of 18

19 POLLUTION INCIDENT REPONSE MANAGEMENT PLAN #35 Violet Paint Office Paint Manufacturing Unit 1 M Unit 2 Depot 5 Vulkan Advanced Engineering (VAE) Unit 3 Billabong Water NORTH Car Park S T O R M W A T E R C H A N N E L Pit Pit Car Park Site office Lab (upstairs) Rollover bund Rollover bund #33 GATE Violet 1 street #29 Violet st Bitumen Blend (awning) Main Office Drum Store BP COR PL REV 6 Page 19 of 19 M2 M1 M M & G A S D e p o t 4 20 Car Park Depot M Legend M6 U22 Exits Safety Showers Bunds Stormwater System Traffic Routes Site Manifest Cabinet Depot 2 Depot 3 2 5

20 Appendix A Notification Protocol 33, Violet Street, Revesby EPA Site Licence Number: 5267 PROTOCOL FOR INDUSTRY NOTIFICATION OF POLLUTION INCIDENTS Effective 6 February 2012 all NSW sites licensed with the EPA are required to immediately notify each of the relevant authorities when material harm to the environment is caused or threatened. All the below authorities must be notified not just the appropriate regulatory authority 1 Call 000 if the incident presents an immediate threat to human health or property. Fire and Rescue, the NSW Police and the NSW Ambulance are the first responders responsible for controlling and containing incidents. 2 If the incident does not require an initial combat agency, or once the 000 call has been made, notify the relevant authorities in the following order: NSW Environment Protection Authority (EPA) : The Ministry of Health: (ask Public Health Officer on call) Safework NSW Local Council (Canterbury Bankstown): Fire and Rescue: Transpacific Spill response (if required) 1800 SPILLS ( ) Neighbours Business Name Contact Number Quality Castings Intasys Er Curtain Bingo Recycling BP COR PL REV 6 Page 20 of 20