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POLLUTION INCIDENT REPONSE MANAGEMENT PLAN INTEGRATED MANAGEMENT SYSTEM

BP COR PL 0023 1 REV 6 Page 1 of 1 Uncontrolled document when printed

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

131 555

The Ministry of Health 9515 6111

(Ask Public Health Officer on call)

NSW Workcover 13 10 50

Bankstown Council (02) 9707 9999 (office hours)

Fire and Rescue NSW 1300 729 579

Also call Transpacific (Cleanaway) Spill response 1800 SPILLS (1800 774 557), if required.

Revision Status

Date Issue By Checked Approved

10/07/2012 0 Mel Fazeli Ken Telfer Greg McRae

25/10/2012 1 Mel Fazeli Ken Telfer Greg McRae

27/09/2013 2 Greg McRae Janette Fowler Neil Morcombe

28/09/2014 3 Greg McRae Janette Fowler Neil Morcombe

11/11/2015 4 Glenn Brayley Tuan Luu Neil Morcombe

15/09/2016 5 Glenn Brayley John Arvanitidis Neil Morcombe

POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN INTEGRATED MANAGEMENT SYSTEM


3.3.5 Contact details [clause 98C (1) (g) and (h)]

Position Name Work Number After Hours

Managing Director Neil Morcombe 02 9772 4433 0414 499 402

WHSE Coordinator Glenn Brayley 02 9772 4433 0435 958 529

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.



POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN (PRIMPS)

3.3.1 Description and likelihood of hazards & associated risks [Regulation clause 98C (1) (a) and (b)]

3.3.2 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 Current Business Unit Risk

Fire & Explosion

Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate.

22

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. Risk Assessments – Hazop 2009 - CAP. Hazardous Zone Classification & risk assessment. Fire risk assessment completed. Designated smoking areas on site - risk assessment completed. 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. Training – DG training completed for operators. Risk Management, Emergency awareness, emergency control and fire fighting training.

NSW Workcover DG notification & license. Forklifts used in hazardous zones (spark arrest system -wet scrubber/ no electricals).

12



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).

Physical – Hot/Cold (burns)

Exhaustion, dehydration, illness, physical harm, burns, fatality, corporate prosecution

17

SOPs and WI contain SEQ prompts and hold points, Training Plan/matrix, Workplace design and layout, JSEA. Site Induction - Uniform policy and procedure. 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. 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.

13

Chemical - exposure

Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate

13

Chemical risk assessments for hazardous substances completed. 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



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 3833. Uniform laundry service. Atmospheric contamination monitoring completed on paint manufacturing plant. 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.

Emissions to water (anything that changes the biological, chemical or physical nature of the receiving water, including water pollution,

sediment, heat, salinity, etc)

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

12

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.

7

Emissions to Air (including climate change gases, ozone depleting gases, dust, smogs, heat, vapour, etc). Unburn't hydrocarbon causing odour emissions.

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

12

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



Hazardous substance leak/spill

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

12

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.

7

Mechanical – fixed plant

Physical harm, property damage, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate

17

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.

12

Potential - body falls, slips, trips

Physical harm 13

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).

7

Contractors & Visitors

Physical harm, fatality, corporate reputation, corporate prosecution, individual prosecution

17

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.

7

Pedestrian & Vehicle Interaction

Injury, fatality, corporate reputation, corporate prosecution, individual prosecution Injury, fatality, corporate reputation, corporate prosecution, individual prosecution

13

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

7



Manual Handling Physical harm

13

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.

7

Work at heights (fall from one level to another)

Illness, injury, fatality, corporate reputation, corporate prosecution, individual prosecution, ability to operate

22

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 1657. 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.

12



3.3.3 Inventory of pollutants [Regulation clause 98C (1) (d) and (e)]

Dangerous Goods Manifest

Location Proper Shipping Name UN DG

Clas

s

Hazardous

(Yes/No)

Volume

Typical

Max.

M3

(maximum)

HAZCHEM

code

Tank 14 C2 – Base Oil NA NA N 55 000 NA

Tank 15 C2 - Base Oil (TPR 150) NA NA N 55 000 NA

Tank 16 Turpentine Substitute 1300 3 Y 55 000 3Y

Tank 17 Xylenes 1307 3 Y 55 000 3Y

Tank 18 Kerosene 1223 3 Y 55 000 3Y

Tank 19 Tars, Liquid (Cutback)

1999 3 Y 35 000 2W

Mixer 5 (Mixer)

Elevated temperature liquid NOS. 3257 9 N 29 000 2Y

Depot 2 Packaged Products

Tars, Liquid (Cutback)

1999 3 Y 50 000

2W

Depot 3 Packaged Products

Amines 2735 8 Y 30 000

2X

Mixer 6 Elevated temperature liquid NOS. 3257 9 N 29 000 2Y

Mixer 22 Elevated temperature liquid NOS. 3257 9 N 800 2Y

Tank 25 Amines 2735 8 Y 15 000 2X





Tank 5 Elevated temperature liquid NOS. 3257 9 N 29 000 2Y

Tank 6 C2 - Precoat NA NA N 55 000 NA

Tank 7 C2 – Dry Oil

NA NA N 55 000 NA

Tank 8 C2 - Precoat NA NA N 60 000 NA

Tank 9 Elevated temperature liquid NOS. 3257 9 N 25 000 2Y

Tank 10 C2 - Dry Oil NA NA N 28 000 NA


Tank 12 C1 - Diesel NA Cat 4 N 55 000 NA

Tank 28 C2 – Dry Oil NA NA N 60 000 NA

Tank 20 C2 - Dry Oil

NA NA N 60 000 NA


Depot 5 - Packaged Products Paint or paint related material 1263 3 Y

20 000

•3YE

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 9774 2933

Intasys 9772 1300

Er Curtain 9773 0539

3.3.7 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.

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



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 3.3.3 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

3.3.10 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 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 Extinguisher Services

Pty Ltd

Due in 2016

Evacuation Rehearsal Internal (meeting debrief of ERT)

28/09/16

Spill Response Internal (spill station training package)

As per training matrix

PRIMP Plan Internal (scenario-table top exercise)*

13/09/2016

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.



3.3.4 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.

3.3.8 Maps [clause 98C (1) (k)]

Maps - General, Neighbours & Site (showing tank location)

33 Violet Street, Revesby

N



Bituminous Products – Site 29

Intasys



ER Curtain



Main Office

Drum Store

17

16

15

18

S T O R M W A T E R C H A N N E L

Paint Office

Paint Manufacturing – Unit 1

Maint

Unit 2

Unit 3

Car Park

Site office

Lab (upstairs)

45

43

44 4

33

34

35

36

31 30

M2

M1

M4

9

5

6

8

10

7

11 12

M3

28

37 & 38

20

32

Pit

Pit

19

Rollover bund

Rollover bund

U22

Car Park

Legend

Exits Safety Showers Bunds

Stormwater System Traffic Routes Site Manifest Cabinet

M6U21

29

Bitumen Blend (awning)

GATE 1

25

Depot 2

Depot 3

Depot 5

Depot 1

Depot

4

M5

33 Violet street

MS

29 Violet st

14

35 Violet

NORTH



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) : 131 555

The Ministry of Health: 95156111 (ask Public Health Officer on call)

NSW Workcover: 13 10 50

Local Council (Bankstown): 9725 0222

Fire and Rescue: 1300 729 579

Transpacific Spill response (if required) 1800 SPILLS (1800 774 557)

Neighbours Business Name

Contact Number

Quality Castings 9774 2933

Intasys 9772 1300

Er Curtain 9773 0539

Documents

POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN … · Hazardous Zones, LPG Filling, ... – SWMS/ JSEAs. 7 Pedestrian & ... POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN