LOCKHART SEWERAGE SCHEME POLLUTION … Lockhart Sewerage Scheme Pollution Incident ... a pollution...

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LOCKHART SEWERAGE SCHEME POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN

October 2012

LOCKHART SHIRE COUNCIL

NSW Public Works PIRMP

Document Control

Approved for Issue Version Author Reviewer

Name Date

Draft v1 B. Douglas L Greentree L. Greentree 5/9/2012

Draft v2 B. Douglas Lockhart Shire Council David Webb 16/10/2012

Final B. Douglas L Greentree L.Greentree 25/10/2012

O:\2012-13\Engineering\S15-005\DOC 0910 LockPIRMP Rev2.docx

NSW Public Works PIRMP 3

Foreword The Lockhart Sewerage Scheme Pollution Incident Response Management Plan (PIRMP) is a document that has been developed to be used by Lockhart Shire Council in the operation and management of incidents at the Lockhart Sewage Treatment Plant (STP) and the sewerage collection system. The purpose of this plan is to ensure that, where possible, pollution incidents are avoided but if they do occur they are managed appropriately to minimise the effects on the environment and to human health.

This PIRMP addresses the requirements under the POELA Act 2011.

The objectives of the plan are to:

• communicate in a timely manner and with sufficient detail about a pollution incident to relevant authorities and people outside the facilities who may be affected by the impacts of the pollution incident

• minimise and control the risk of any pollution incident occurring at the facility by requiring identification of risks and the development of planned actions to minimise and manage those risks; and

• ensure that the plan is properly implemented by trained staff, identifying persons responsible for implementing it, and ensuring that the plan is regularly tested for accuracy, currency and suitability.

This management plan is to be continually updated and reviewed by Council’s Director of Engineering, Lockhart Shire Council, and Council’s Work Health and Safety (WHS) Committee.


Contents

Foreword 3

Contents 4

1 Introduction 7

1.1 Sewage Treatment Plant and Collection System 7

1.2 Scope of the PIRMP 7

2 Context of the Assessment 9

2.1 Background 9

2.2 Council Commitment 10

2.3 Regulatory and Formal Requirements 11

3 Assessment of the Risks 12

3.1 Risk Assessment – Lockhart STP and Collection System 12

4 Preventative Actions to be Undertaken 20

4.1 Collection System 20

4.1.1 Gravity Sewer System 20

4.2 Pumping Stations 21

4.2.1 Adequate Pumping Capacity 21

4.2.2 Reliable Power Supply 21

4.2.3 Provision of Emergency Storage 21

4.2.4 Response Times to Abnormal Operating Conditions 21

4.2.5 Standby Pumps 21

4.3 Sewage Treatment Plant Overflows 24

4.3.1 Dry Weather 24

4.3.2 Wet Weather 24

4.4 Sewerage System Spills 24

4.5 Further Preventative Measures to Lower The Risks 27

5 Inventory of Pollutants and MDS 28

5.1 Inventory of Chemicals 28

5.2 Chemical Usage 28

5.3 Other Pollutants – Sewage and Effluent 28

6 Safety Equipment 30

6.1 List of PPE Equipment Onsite 30

6.2 List of Monitoring Devices 30

7 Roles, Responsibilities and Contact Details 33

7.1 Stakeholder Responsibilities and Engagement 33

7.2 List of Contact Details 34

7.3 Council Procedures for Contacting Staff to Respond to a Possible Incident 34


8 Communicating with Neighbours and the Community 35

8.1 Incident Classification 35

8.2 Notification Process 36

8.3 Workplace Incidents 36

8.4 Investigation of Incidents and Emergencies 38

9 Minimising Harm to Persons on the Premises 39

9.1 Attendance Register 39

9.2 Site Induction 39

9.3 Evacuation Procedure 39

9.4 Emergency Assembly Points 39

9.5 Signage 39

10 Maps 42

11 Actions to be Undertaken During or Immediately After a Pollution Incident 44

11.1 Minor Incident Action Plan 44

11.2 Significant Incident Action Plan 45

11.3 Major Incident Action Plans 46

12 Evaluation, Audit and Review for Continuous Development 48

12.1 Evaluation and Review 48

12.2 Auditing 48

13 References 49

14 Appendices 50

Appendix A – MSDS 50

Appendix B – Plans 51

Appendix C - Training/ Education Register 53

Appendix D – Incident Reporting Form 54

Appendix E – Audit Log Form 57

Appendix F – Safe Work Method Statements 58

Appendix G – Accident and Emergency Procedure 59


Figures

Figure 1.1: Lockhart STP - Location of STP................................................................................... 8

Figure 4.1 SPS 1........................................................................................................................... 22

Figure 4.2 SPS 2........................................................................................................................... 22

Figure 4.3 SPS 3........................................................................................................................... 23

Figure 4.4 STP – Chlorine Storage Area....................................................................................... 25

Figure 4.5 STP – Chlorine Cylinders ............................................................................................. 25

Figure 4.5 STP – Spill Clean Up Procedure .................................................................................. 26

Figure 8.1 Incident Communication Protocols ............................................................................... 37

Figure 9.1 Chlorination Building Signage ...................................................................................... 40

Figure 9.2 Emergency Assembly Point Diagram ........................................................................... 41

Figure 10.1 Aerial Photo Of Lockhart STP .................................................................................... 42

Figure 10.3 Aerial Photo Of STP, SPS 1, 2 and 3 ......................................................................... 43

Figure 11.1 Minor Incident Action Plan.......................................................................................... 44

Figure 11.2 Moderate Incident Action Plan.................................................................................... 45

Figure 11.3 Major Incident Action Plan.......................................................................................... 46

Figure 11.4 Major Incident Action Plan Chlorine Gas .................................................................... 47

Tables

Table 2.1: Formal and Regulatory Requirements 11

Table 3.1: Definitions of Likelihood 12

Table 3.2: Definitions of Impact 13

Table 3.3: Risk Analysis Criteria 14

Table 3.4: Risk Register 15

Table 4.1: Preventative Measures at each Site 27

Table 5.1: Pollutant List – Chemicals 29

Table 5.2: Pollutant List – Sewage And Effluent 29

Table 6.1: List of PPE 30

Table 6.2: List of Monitoring Devices 30

Table 7.1: Stakeholder Responsibilities and Engagement 33

Table 7.2: Stakeholder Contact Details 34


1 Introduction The township of Lockhart is located 580km southwest of Sydney. Lockhart currently has a population of approximately 850 people.

Lockhart Shire Council owns and operates the Lockhart Sewerage Scheme that includes a sewage treatment plant (STP) and the collection system servicing the town.

1.1 Sewage Treatment Plant and Collection System The Lockhart STP comprises the following treatment/process units:

� Inlet screening

� Sedimentation tank

� Trickling filter

� Humus tank

� Maturation ponds

� Sludge digestor

� Drying beds

� Chlorination system for effluent reuse

The Lockhart sewerage collection system comprises the following:

� Gravity mains

� Main SPS (SPS 1)

� Other SPS – 2,3,4

� Rising mains (from each SPS)

The STP and the collection system operates under an Environmental Protection Licence (EPL) 1705 granted by the NSW Environment Protection Authority (EPA) that is renewed annually.

1.2 Scope of the PIRMP The scope of the plan is as follows:

• Description and likelihood of hazards

• Pre-emptive actions to be taken

• Inventory of pollutants

• Safety equipment

• Contact details

• Communicating with neighbours and the local community

• Minimising harm to persons on the premises

• Maps shown location of scheme components

• Actions to be taken during or immediately after a pollution incident

• Staff training


Figure 1.1: Lockhart STP - Location of STP

Lockhart STP

Brookong Creek


2 Context of the Assessment

2.1 Background A new provision under the Protection of the Environment Legislation Amendment Act (POELA) 2011 is the requirement to prepare, keep, test and implement a pollution incident response management plan for each environmental protection licence that Council holds.

The objectives of these plans are to:

• communicate in a timely manner and with sufficient detail about a pollution incident to relevant authorities and people outside the facilities who may be affected by the impacts of the pollution incident;

• minimise and control the risk of any pollution incident occurring at the facilities by requiring identification of risks and the development of planned actions to minimise and manage those risks; and

• ensure that the plan is properly implemented by trained staff, identifying persons responsible for implementing it, and ensuring that the plan is regularly tested for accuracy, currency and suitability.

The NSW EPA defines a ‘pollution incident’ as follows:

“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, WorkCover NSW and the local council. ‘Immediately’ has its ordinary dictionary meaning of promptly and without delay. These strengthened provisions will ensure that pollution incidents are reported directly to the relevant response agencies so they will have direct access to the information they need to manage and deal with the incident in as fast a time as is practical.

The NSW EPA requires a plan to be implemented for all existing licenses by the 1st of September 2012. Council holds EPL No. 1705 for the Lockhart STP and collection system.


2.2 Council Commitment Lockhart Shire Council is committed to protecting the health of the public, the environment and its workers. This commitment has been formalised and is contained in Council’s Annual Report and Budget 2011/12. Council’s charter is shown below.

Local Government Act - Council’s Charter

The Local Government Act contains a Charter for Local Government which describes the approach to supplying services and activities. It charges local government with a number of responsibilities:

• to provide directly or on behalf of other levels of government, after due consultation, adequate, equitable and appropriate services and facilities for the community and to ensure that those services and facilities are managed efficiently and effectively

• to exercise community leadership

• to exercise its functions in a manner that is consistent with and actively promotes the principles of multiculturalism

• to promote and to provide and plan for the needs of children

• to properly manage, develop, protect, restore, enhance and conserve the environment of the area for which it is responsible, in a manner that is consistent with and promotes the principles of ecologically sustainable development

• to have regard to the long term and cumulative effects of its decisions

• to bear in mind that it is the custodian and trustee of public assets and to effectively account for and manage the assets for which it is responsible

• to engage in long-term strategic planning on behalf of the local community

• to exercise its functions in a manner that is consistent with and promotes social justice principles of equity, access, participation and rights

• to facilitate the involvement of councillors, members of the public, users of facilities and services and council staff in the development, improvement and co-ordination of local government

• to raise funds for local purposes by the fair imposition of rates, charges and fees, by income earned from investments and, when appropriate, by borrowings and grants

• to keep the local community and the State government (and through it, the wider community) informed about its activities

• to ensure that, in the exercise of its regulatory functions, it acts consistently and without bias, particularly where an activity of the council is affected

• to be a responsible employer.


2.3 Regulatory and Formal Requirements The regulatory and formal requirements applicable to the Lockhart Sewerage Scheme are shown in Table 2.1 . These legislative and licensing requirements and guidelines are to be met to ensure the protection of the environment public health and to satisfy work health and safety (WHS). This management plan addresses how these requirements are to be met.

Table 2.1: Formal and Regulatory Requirements

Parameter Instrument Administered by

Water Management Act 2000 NSW EPA Overall Scheme Operation

Local Government Act 1993 NSW Office of Water

Public Health

Section 55 Protection of the Environment Operations Act 2011 Environment Protection

Licence 1705

NSW EPA, NSW Health

Environmental Health

Section 55 Protection of the Environment Operations Act 2011 Environment Protection

Licence 1706

NSW EPA

WHS Work Health and Safety Act 2011

(WHS Act) and the WHS Regulations.

WorkCover Authority of NSW

Plumbing

All pipe work associated with recycled water schemes is to be

installed in accordance with AS/NZS 3500 (Plumbing and Drainage Code: Standards

Australia 1996-2003)

Lockhart Shire Council

The Director of Engineering at Lockhart Shire Council is responsible for the review and evaluation of this plan and for meeting the regulatory and other requirements.


3 Assessment of the Risks

3.1 Risk Assessment – Lockhart STP and Collection S ystem An inspection was undertaken at Lockhart on the 28th of August 2012 by NSW Public Works and Lockhart Shire Council and a risk assessment was undertaken based on this inspection. The objective of the assessment was to:

• identify the hazards

• identify hazardous events

• assessment of the likelihood of the event and other factors that may increase the likelihood

• assess the impacts

• assess the overall risk.

Shown in Table 3.1 , Table 3.2 and Table 3.3 are the likelihood, impact and risk criteria used in the assessment.

As can be seen in Table 3.4 , the identified hazard events relating to the STP risks are all low. The identified SPS hazard events are all rated as low risk except SPS 1 which is rated a moderate risk.

Table 3.1: Definitions of Likelihood

Level Likelihood Description

A Almost certain - The event is expected to occur often ( several times per year)

B Likely - The event will probably occur often (once every 1-3 years)

C Possible - The event might occur at some time (once every 3 to 10 years)

D Unlikely - The event could occur at some time (once every 20 years)

E Rare - The event may occur only in exceptional circumstances (once every 100 years)


Table 3.2: Definitions of Impact Level Classification Description 1 Insignificant The overflow is extremely unlikely to drain to a local sensitive

environment* and: - Where the overflow reaches waters, the volume of sewage

likely to enter the waterways is insignificant with regard to the volume and flow of receiving waters, or

- Where the overflow reaches land, it is likely to be contained in an area with little chance of public exposure within the maximum response time**

2 Minor The overflow is unlikely to drain to a local sensitive environment* and: - Where the overflow reaches waters, the volume of sewage

likely to enter the waterways may be significant with regard to the volume and flow of receiving waters, or

- Where the overflow reaches land, it is likely to be contained in an area where the public exposure is minimal given the maximum response time**

3 Moderate The overflow is likely to drain to a local sensitive environment* and: - Where the overflow reaches waters, the volume of sewage

likely to enter the waterways is significant with regard to the volume and flow of receiving waters, or

- Where the overflow reaches land, it may travel to an area where public exposure is low within the maximum response time**

4 Major The overflow is likely to drain to a local sensitive environment* and: - Where the overflow reaches waters, the volume of sewage

likely to enter the waterway is high with regard to the volume and flow of receiving waters, or

- Where the overflow reaches land, the public exposure risk is likely given the maximum response time**

5 Catastrophic The overflow is likely to drain to a local sensitive environment* and: - Where the overflow reaches waters, the volume of sewage

likely to enter the waterways is high with regard to the volume and flow of receiving waters, or

- Where the overflow discharges to land, the public exposure risk is high given the maximum response time**

*A sensitive environment includes: a drinking water catchment or domestic groundwater source, or shellfish growing area, or protected water bodies, ecological communities or conservation areas defined by legal an non-legal instruments, such as local environment plans (LEPs), State Environmental planning policies (SEPPs), national parks, and class P or class S waters, or waterways used for primary contact recreation, or a recreational area or other area with high public exposure o associated health risk. **Maximum response time should be based on the length of time taken for the licensee to detect the overflow, or for the overflow to be reported, and the time taken for the licensee to attend the site and secure against public contact


Table 3.3: Risk Analysis Criteria

Impacts

Likelihood Insignificant

1 Minor

2 Moderate

3 Major

4 Catastrophic

5

Almost Certain – A Low Moderate High Very High Very High

Likely – B Low Moderate High Very High Very High

Possible – C Low Moderate Moderate High Very High

Unlikely – D Low Low Moderate High Very High

Rare – E Low Low Low Moderate High


Table 3.4: Risk Register

Con

tam

inan

t

Des

crip

tion

of th

e H

azar

dous

Eve

nt

Hum

an H

ealth

(P

ublic

Hea

lth)

Env

ironm

enta

l Ris

ks

Like

lihoo

d A

lmos

t cer

tain

- s

ever

al ti

mes

per

yea

r Li

kely

- o

nce

ever

y 1

- 3

year

s P

ossi

ble

- o

nce

ever

y 3

- 10

yea

rs

Unl

ikel

y -

once

eve

ry 2

0 ye

ars

Rar

e -

once

eve

ry 1

00 y

ears

Eve

nts

or C

ircum

stan

ces

that

w

ould

ace

rbat

e or

incr

ease

lik

elih

ood

Impa

ct

Insi

gnifi

cant

M

inor

M

oder

ate

M

ajor

C

atas

trop

hic

Ass

esse

d R

isk

Low

M

oder

ate

Hig

h V

ery

Hig

h

Pre

-em

ptiv

e A

ctio

ns (

Exi

stin

g C

ontr

ols)

In

add

ition

to O

pera

tor

trai

ning

, SW

MS

STP

1 Chlorine Cylinder leak �� Unlikely Moderate Moderate Stored outside Operator site attendance 7 days

2 Chlorine System Leak �� Unlikely Moderate Moderate Stored outside Operator site attendance 7 days

3 Effluent Toxic wastes upsets/kills

process �� Rare

Trade waste

discharges

Moderate Low No local trade waste. Routine plant monitoring.

4 Effluent

Stormwater inflow to STP

causing overflows

�� Unlikely Minor Low Plant designed to handle PWWF All inflows pumped.

5 Effluent Poor quality - sabotage of plant

�� Rare Minor Low Locked gates and manproof fencing (in process of

being installed Aug 2012). Locked building.


6 Effluent Poor quality -

extended power failure

�� Unlikely Minor Low Reliable power system. Long outages would be

planned. Ponds will provide some treatment

7 Effluent Poor quality - equipment failure �� Unlikely Minor Low

Standby capacity. SPS storage if required.

Telemetry system. Operator attendance in less than 1 hour.

8 Effluent Failure of humus

tank pump station

�� Likely Wet weather

Minor Moderate

9 Effluent Failure of

sedimentation tank pumps

�� Unlikely Wet weather

Minor Low Duty and standby pumps

10 Effluent Flooding of STP �� Unlikely Moderate Low Electrical items above flood level

11 Effluent Flooding of STP ponds leading to

overflow �� Rare Minor Low Ponds above flood level

12 Screening and grit

Washed off site - currently buried

�� Unlikely Minor Low Buried in trench

13 Sludge Overflows from drying beds �� Unlikely Minor Low Small volumes

14 Biosolids Washing from site or leachate �� Unlikely Minor Low Drying beds have sides

Small volumes

15 Biosolids

Drying beds flooded – release

of biosolids to flood waters

�� Unlikely Minor Low Drying beds have sides Small volumes


Table 3.4: Risk Register (continued – SPS, gravity mains)

Con

tam

inan

t

Des

crip

tion

of th

e H

azar

dous

Eve

nt

Hum

an H

ealth

(P

ublic

Hea

lth)

Env

ironm

enta

l Ris

ks

Like

lihoo

d A

lmos

t cer

tain

- s

ever

al ti

mes

per

yea

r Li

kely

- o

nce

ever

y 1

- 3

year

s P

ossi

ble

- o

nce

ever

y 3

- 10

yea

rs

Unl

ikel

y -

once

eve

ry 2

0 ye

ars

Rar

e -

once

eve

ry 1

00 y

ears

Eve

nts

or C

ircum

stan

ces

that

w

ould

ace

rbat

e or

incr

ease

lik

elih

ood

Impa

ct

Insi

gnifi

cant

M

inor

- S

hort

term

low

leve

l M

oder

ate

- S

hort

term

low

leve

l lar

ge p

opul

atio

n M

ajor

- S

ever

e ill

ness

or

deat

h sm

all p

opul

atio

n C

atas

trop

hic

- S

ever

e ill

ness

or

deat

h la

rge

popu

latio

n

Ass

esse

d R

isk

Low

M

oder

ate

Hig

h V

ery

Hig

h

Pre

-em

ptiv

e A

ctio

ns (

Exi

stin

g C

ontr

ols)

In

add

ition

to o

pera

tor

trai

ning

, SW

MS

SPS 1

16 Sewage

Overflow to creek or public area - extended power

failure

�� Possible

Wet weather

event Restricted access to

SPS

Minor Moderate

Reliable power system. Long outages would be planned.

Emergency storage Operator response less than 1 hour after

notification

17 Sewage Overflow to creek - extended power failure unplanned

�� Possible

Wet weather


SPS

Minor Moderate


Emergency storage (gravity system only) Operator response less than 1 hour after

notification


18 Sewage Overflow to creek

or public area - pump failure

�� Rare

Wet weather


SPS

Minor Low


Emergency storage (gravity system only) Operator response less than 1 hour after

notification


or public area - electrical failure

�� Possible

Wet weather


SPS

Minor Moderate


Operator response less than 1 hour after notification


or public area - flooding of SPS

�� Possible

Wet weather


SPS

Minor Moderate





�� Possible

Wet weather


SPS

Minor Moderate



SPS 2,3

22 Sewage


failure

�� Unlikely Insignificant Low


8 hours ADWF emergency storage Operator response less than 1 hour after

notification

23 Sewage


failure unplanned


Reliable power system. 8 hours ADWF emergency storage



or public area - pump failure


Duty and standby Pumps

8 hours ADWF emergency storage Operator response less than 1 hour after

notification



or public area - electrical failure

�� Unlikely Wet

weather event

Insignificant Low Operator response less than 1 hour.

8 hours ADWF emergency storage after notification



�� Unlikely Insignificant Low Operator response less than 1 hour.

8 hours ADWF emergency storage after notification

Gravity System

27 Sewage Overflow due to blockage �� Moderate Minor Low

Operator to call in tanker Operator response less than 1 hour after

notification Small volumes

28 Sewage

Discharge due to pipe break –

ground movement/ earthquake

�� Rare Wet

weather event

Minor Low

Operator to call in tanker Operator response less than 1 hour after

notification Small volumes

29 Sewage Discharge due to

pipe break – excavation works

�� Unlikely Wet

weather event

Minor Low Dial before dig. Maintain up-to-date plan records.

Rising Mains

30 Sewage

Discharge due to pipe break – poor pipe condition or

high pressure

�� Unlikely Wet

weather event

Moderate Low Flow/pump monitoring.

31 Sewage

Discharge due to pipe break –

ground movement/ earthquake

�� Rare Wet

weather event

Major Low Flow/pump monitoring.

32 Sewage Discharge due to

pipe break – excavation works

�� Unlikely Wet

weather event

Moderate Low

Flow/pump monitoring.

Dial before dig.

Maintain up-to-date plan records.


4 Preventative Actions to be Undertaken The preventative actions or measures to manage and minimise the risk to human health and the environment involve a multiple barrier approach. The multiple barriers, in order of preference, are as follows:

• Elimination

• Substitution

• Isolation

• Engineering means

• Administrative

• Personal Protection Equipment (PPE)

These are readily broken down to the following classification of management strategies:

• Appropriate design of the facilities

• Appropriate operation and monitoring and

• Appropriate education and training

The identified current preventative actions are shown in this section. Photos of the existing SPS are shown in Figures 4.1 through to Figure 4.11.

4.1 Collection System Collection system overflows can principally occur from five main causes. They are:

• Power/mechanical failure at pumping stations

• Reticulation system blockage/leakage

• Rising main breakage (leaks or major failure)

• Breakdown of pump units and

• Excessive inflows

4.1.1 Gravity Sewer System Overall, the Lockhart reticulation system is in good condition has sufficient capacity, and the number of overflows or incidents per kilometre of pipeline per year would be considered low by industry standards. Council uses water jetting equipment to clear blockages. Blockages in reticulation mains occur infrequently. The main cause is tree root intrusions but can also occur due to foreign objects lodging in the pipelines.

As per the past records kept by Council, apart from minor seepages due to blockages in pipelines, no major overflow events have occurred in the reticulation system in the recent past

Unusual excessive inflows, greater than the design peak wet weather flow (PWWF), may occur during extreme flood events if reticulation manholes become inundated and the inflow is greater than the pumping station capacity. Other possibilities for sewer overflows include illegal connection of stormwater pipes and low lying gullies or boundary traps.

The past records kept by Council do not indicate to any overflows due to wet weather in the recent past.


4.2 Pumping Stations The likelihood of overflows from SPSs can be minimised by the provision of the following:

• Adequate pumping capacity

• Reliable power supply

• Service response time to address abnormal operating conditions such as power failure, pump failure etc. less than the detention time provided within the pumping station before overflow occurs

• Availability of standby pumps (pump failure), and/or portable generators (power supply/electrical failure), access to pumper trucks

• Implementation of effective emergency plan/operational procedures for attending to failure and breakdown within the system effectively.

4.2.1 Adequate Pumping Capacity All of the SPSs within the Lockhart Sewerage Scheme have sufficient pumping capacity for present and future requirements.

4.2.2 Reliable Power Supply Council has reported that Lockhart has a relatively reliable power supply. Generally power outages in the Lockhart area have been less than 4 hours in duration. While not common, power failures of extended duration are possible but are usually planned outages.

4.2.3 Provision of Emergency Storage A sewerage system must have sufficient capacity to store sewage, which continues to flow from the catchment during extended mechanical breakdowns or electrical failures. Each of the Lockhart SPS and collection system has 8 hours of ADWF emergency storage.

4.2.4 Response Times to Abnormal Operating Conditio ns Council has advised that the response time for Operator attendance to any abnormal operating condition would generally be less than one hour at all times once it is notified.

4.2.5 Standby Pumps All SPSs have duty and standby pumps installed (100% capacity).


Figure 4.1 SPS 1

Figure 4.2 SPS 2


Figure 4.3 SPS 3


4.3 Sewage Treatment Plant Overflows The Lockhart STP is a basic STP that is providing adequate treatment. It is currently underloaded, based on the design capacity of the STP (1500 EP) and the connected population (850 EP).

At present all flows are pumped via SPS1 to the inlet works. Flows expected in the future are less than the capacity of the STP units. Overflows are unlikely through excessive inflows causing a bypass to occur. All inflows can be fully treated as the design capacity of the STP is in excess of the SPS pump rate.

Equipment failure may occur at the plant, and lead to overflows, the most likely being the effluent pump after the humus tank which conveys effluent from the humus tank to the maturation ponds. This is a single pump.

The collection system does have sufficient storage capacity to isolate the STP if a failure occurs. This storage can be used to store sewage for short terms in which the STP failure may be resolved.

The STP is monitored 7 days, business hours, by the plant Operator. The Operator lives locally to the STP which provides ready response to any treatment problem events.

4.3.1 Dry Weather Generally, unless exceptional circumstances such as malfunction of systems due to mechanical/ electrical failure or blockages occur, overflows at the STP in dry weather flow conditions are extremely unlikely.

Some small dry weather overflow events have occurred from the humus tank due to pump failure. No dry weather overflow events (or even near events) have been recorded in the recent past from other elements of the plant.

4.3.2 Wet Weather The STP is designed to treat all inflows. Generally, unless exceptional circumstances such as malfunction of system due to mechanical/electrical failure or blockages occur, overflows at STP are unlikely.

No overflows due to wet weather have been recorded.

4.4 Sewerage System Spills Spills are managed as per the attached diagram in Figure 4.6.


Figure 4.4 STP – Chlorine Storage Area

Figure 4.5 STP – Chlorine Cylinders


Figure 4.5 STP – Spill Clean Up Procedure


4.5 Further Preventative Measures to Lower The Risk s The following list of required works has been formulated to further lower the risks of a pollution event. These are shown in Table 4.1.

Table 4.1: Preventative Measures at each Site

Site Potential Hazards Existing ‘Preventative’ Acti ons Proposed New Measures

SPS 1 Overflow Storage

Duty and Standby pumps

1. Daily inspection

2. Telemetry system

Chlorination System

4x 70kg

Release of gas - Major Valve outlet caps

Valve protection covers

Fire extinguisher

PPE

Operator training

Backup personnel

MSDS

Staff check daily

Alternative assembly area to allow for wind direction changes

1. Gas detectors to be provided in and connected to the telemetry system

2. Auto shut off valves

3. Light and alarm activated is chlorine release detected

4. Fire alarm system for the chlorination room

5. Wind sock for the chlorination room

6. Weigh scales

7. Telemetry system

Release of gas – Minor As above 1. As above

Effluent Overflow from effluent pump failure

None 1. Install a standby pump or at least have an uninstalled standby

2. Telemetry system


5 Inventory of Pollutants and MDS

5.1 Inventory of Chemicals The only chemical stored and used on-site for treatment is chlorine for disinfection. The chlorine details are as listed in Table 5.1 .

A material safety data sheet (MSDS) representative of the alum chemical used at the STP is included in Appendix A .

5.2 Chemical Usage Chlorine is the only chemical used onsite.

5.3 Other Pollutants – Sewage and Effluent The other potential pollutants are:

• Sewage – within the collection system and at head of the STP

• Effluent – produced at the STP

• Sludge (including WAS and stabilised and/or dewatered bio solids) produced at the STP

• Supernatant – produced at the STP

• Screenings – produced at the STP inlet works

• Grit – produced at the STP inlet works

• Stormwater


Table 5.1: Pollutant List – Chemicals

Chemical Location Chemical Name and

Formula Typical Analysis Use

Amount Stored

Chlorine Outside Lockhart

STP – chlorination room

cH Disinfection 4x70 kg

Table 5.2: Pollutant List – Sewage And Effluent

Parameter Typical Raw Sewage

Effluent (90 percentile)

Biochemical oxygen demand (BOD5) 270 mg/L <20 mg/L

Suspended solids (SS) 270 mg/L <30 mg/L

Total nitrogen (TN) 53 mg/L <20 mg/L

Total phosphorus (TP) 11 mg/L <11

Oil and grease (O&G) <10 mg/L <2 mg/L

Faecal coliforms, FC 1,000,000 cfu/100 mL <1,000 cfu/100 mL

pH 6.5 - 8.5 6.5 - 8.5


6 Safety Equipment Safety equipment and other devices that are provided on-site will minimise the risks to human health or the environment and contain or control a pollution incident. These will include any PPE, MSDS, monitoring devices and spill containment facilities/equipment.

6.1 List of PPE Equipment Onsite The following PPE safety equipment is provided onsite:

Table 6.1: List of PPE

Personal Protective Equipment Location Location

Hearing protection STP Operator’s Truck

Protective gloves STP Operator’s Truck

Dust mask STP Operator’s Truck

Safety glasses STP Operator’s Truck

Safety apron STP Operator’s Truck

6.2 List of Monitoring Devices The following monitoring devices are present onsite:

Table 6.2: List of Monitoring Devices

System Monitoring Devices Devices Alert

STP Inflow monitor,

Pump (effluent) Operator on inspection

SPS High Level alarm light Operator on inspection or

general public

Power failure As above

Pump Mechanical Failure As above

Intrusion As above


Figure 6.1 STP – Switchboard

Figure 6.2 STP – Inflow Monitoring


7 Roles, Responsibilities and Contact Details

7.1 Stakeholder Responsibilities and Engagement Council has committed to operating its STP and collection system in a responsible manner. Effective stakeholder engagement is necessary to fulfil this commitment. Table 7.1 presents the stakeholders involved in the operation of the STP and collection system, sets out their roles, the communication expected to occur to achieve safe operation of the plant and collection system. Further information on the operation of the system and communication protocols is addressed later in this plan.

Table 7.1: Stakeholder Responsibilities and Engage ment Stakeholder Responsibility Communicates with Reason

Overall scheme operation/ responsibility

Facilities Officer Management of operations

staff

NSW Health Health advice, reporting

incidents

NSW EPA Reporting on Licence compliance, reporting

incidents


Director of Engineering

Community of Lockhart Advice where required

during incidents

WorkCover Reporting of injuries and accidents where required.

Facilities Officer Management of scheme

operation and maintenance, emergency

response

Council operators and Director of Engineering

Management of operations staff, reporting issues regarding operation,

maintenance and compliance to Council, resolving site issues,

Council Operators and

W&S crews

Day to day operation of STP and collection

system, response to emergencies

Sewer Operator

Communicates issues regarding operation,

maintenance and compliance

Police/ Fire Brigade/

HAZMAT/ Ambulance/ SES

Response to emergencies

Lockhart Shire Council Director of Engineering/ Environmental Services

Facilities Officer

Response to spills, injuries, accidents


7.2 List of Contact Details The contact details of the stakeholders are listed below in Table 7.2.

Table 7.2: Stakeholder Contact Details

Name Position and Organisation Phone


The after-hours, emergency contact number for sewerage

6920 5305

Council during business hours 6920 5305

Director of Engineering – David Webb 6920 5305

Facilities Officer – Julie Hush 0427 957 584

Works Officer 0429 931 342

Lockhart Depot 6920 5516

EPA EPA Pollution Line 131 555

Wagga 02 6932 9100

NSW Health Greater Southern Area Queanbeyan

NSW Office Phone: (02) 6128 9777

Fax: (02) 6299 6363

24 Hour After Hours Contact: (02) 6080 8900

Hospital 69205 206

Doctor 69205 249

NSW Office of Water NSW Office of Water Wagga 02 6932 9100

Bernie Barnes 0429 604 409

Utilities Great Southern Energy 6913 2356

AGL 131 909

Telstra 132 203

RMS 6938 1111

Emergency Services Police, Fire Brigade, Ambulance,

Hazmat 000

HAZMAT 000

Poisons Information Line

13 11 26

NSW Rural Fire Service

000

7.3 Council Procedures for Contacting Staff to Resp ond to a Possible Incident

All notifications to Council regarding SPS and sewerage system are transmitted by phone message to the `On Call ` Operator as well as the Sewer Operator.

The Operator will attend to an alarm and report to the Facilities Officer.

Any blockages reported within the sewage collection system are attended to by the Operators and cleared. All works are undertaken to comply with the relevant Safe Work Method Statement(s) (Appendix F) and appropriate action report forms (Appendix D) are completed.


8 Communicating with Neighbours and the Community

To determine the appropriate communication strategy for an incident the incident needs to be categorised. Once categorised the prescribed communication strategy can be deployed.

8.1 Incident Classification • Minor Risk Incident : managed by routine procedures/work practices.

o Incident affects small area only AND

o Incident is easy to clean up without additional assistance AND

o There is no risk of material harm to humans or the environment

• Moderate Risk Incident: further investigation may be required and assessment of management options; in the short term, operations and maintenance adjusted to reduce the consequences, likelihood and exposure.

o Incident affects more than one property OR

o There is a risk of pollution or material harm to the environment BUT

o Clean up can be completed without assistance AND

o There is no danger to humans

• Major Risk Incident: further detailed investigation and assessment of management options is required; immediate review and adjust operations and maintenance to reduce the consequences, likelihood and exposure; clean-up and notification procedures become high priority.

o Potential or actual harm to humans and the environment AND/OR

o Assistance is required with clean-up from other agencies

The following examples are shown:

• Minor Risk Incidents – incidents with a low risk to health and the environment such as:

o Reticulation system blockages

o Short term power failure or electrical failure

o Minor spills to the ground

• Moderate Risk Incident - an incident with a medium risk to health and the environment such as:

o Major spills to the ground and/or to an sensitive environment

o Sewage spills to a waterway

o Extended power failure

• Major Risk Incident - an incident with a high risk to health and the environment such as:

o Major sewage spill to a waterway

o Extended power failure wet weather

o Earthquake or structural collapse causing significant damage


8.2 Notification Process The following incident notification process will be undertaken for the identified incident levels:

• Low Risk Incident

o The operator will report MINOR incidents to the Facilities Officer ASAP

o The Facilities Officer to report to the Director of Engineering weekly

• Moderate Risk Incident – Notifiable

o The Operator will report MODERATE RISK incidents to the Facilities Officer IMMEDIATELY

o The Facilities Officer will report MODERATE RISK incidents to the Director of Engineering IMMEDIATELY

o The Facilities Officer will alert the Director of Engineering IMMEDIATELY

� If overflows occur - The Director of Engineering will report SIGNIFICANT OR HIGH RISK incidences IMMEDIATELY to EPA

� If public affected call NSW Health

� Notify neighbours

• Major Risk Incident - Notifiable

o The Operator will report SIGNIFICANT OR HIGH RISK incidents to the Water and Sewer Manager IMMEDIATELY

o The Water and Sewer Supervisor will report SIGNIFICANT OR HIGH RISK incidents to the Director of Engineering IMMEDIATELY

o The Water and Sewer Manager will alert the Director of Engineering IMMEDIATELY

� If overflows occur - The Director of Works will report SIGNIFICANT OR HIGH RISK incidences IMMEDIATELY to EPA

� If public affected call 000 emergency services

� Notify neighbours

This is shown schematically in Figure 8.1.

This procedure will form part of the operator training and awareness.

Incident reporting includes communicating the incident and also documenting the incident.

8.3 Workplace Incidents The following incidents and injuries must be reported to WorkCover:

• Notifiable incidents involving a fatality or a serious injury or illness

• Notifiable incidents involving a fatality or serious injury or illness to other people at your workplace

• Notifiable incidents that present a serious risk to health and safety at your workplace (dangerous incidents)

• Other incidents involving an injury or illness where workers compensation is payable.


Figure 8.1 Incident Communication Protocols

General Manager


Operator

Facilities Officer

Agency Stakeholders

Council Employees NSW Health

EPA

WorkCover

Low Risk Incident Reporting

Moderate Incident Reporting

General Manager


Operator

Facilities Officer

NSW Health

EPA

WorkCover

General Manager


Operator

Facilities Officer

Major Incident Reporting

Quarterly reporting

As soon as practicable

Immediate ly

IMMEDIATELY

IMMEDIATELY

IMMEDIATELY As soon as practicable Immediately

IMMEDIATELY

Councillors, Media and others as necessary

Contact Emergency

Services

Neighbours

Immediately

Immediately


8.4 Investigation of Incidents and Emergencies Following any incident or emergency situation, including any “near misses”, an investigation will be undertaken and all involved staff debriefed, to discuss performance and address any issues or concerns.

The investigation will consider factors such as:

• What was the initial cause of the problem?

• How was the problem first identified or recognised?

• What were the most critical actions required?

• What communication problems arose and how were they addressed?

• What were the immediate and longer term consequences?

• How well did the protocol function?


9 Minimising Harm to Persons on the Premises

9.1 Attendance Register An attendance register is in place at the STP. All visitors are signed in and out of the site.

9.2 Site Induction Visitors are instructed to report to the site office where they are inducted to the site by the STP Operator prior to access to treatment areas of the site.

9.3 Evacuation Procedure

The evacuation procedure is located in the amenities building and is shown in Figure 9.2

9.4 Emergency Assembly Points

The emergency assembly points are at the front gates of the STP as shown in Figure 9.2.

9.5 Signage

Warning signage has been provided for the chlorination system as shown in Figure 9.1.


Figure 9.1 Chlorination Building Signage


Figure 9.2 Emergency Assembly Point Diagram


10 Maps Figure 10.1 Aerial Photo Of Lockhart STP

Lockhart STP

Brookong Creek


Figure 10.3 Aerial Photo Of STP, SPS 1, 2 and 3

Lockhart STP SPS 1

SPS 2 Hayes Street

SPS 3 Green St West


11 Actions to be Undertaken During or Immediately After a Pollution Incident

11.1 Minor Incident Action Plan The action plan for the following minor incidents is shown in Figure 11.1:

Figure 11.1 Minor Incident Action Plan

Facilities Officer

.

Sewer Operator

As soon as practicable

Record all details

Assess if the spill, overflow, power failure is likely to be detrimental to health, safety or welfare of anyone.

Contain spill.

Call in additional resources as required.

Notify Facilities Officer.

Clean up affected areas.

Confirm actions with Facilities Officer.

Monitors the situation as appropriate.

Record incident.

MINOR INCIDENT MANAGEMENT


11.2 Significant Incident Action Plan The action plan for the following significant incidents is shown in Figure 11.2:

Figure 11.2 Moderate Incident Action Plan

Facilities Officer

IMMEDIATELY

Notify the EPA, NSW Health, WorkCover

Notify General Manager as appropriate

Sewer Operator

Environmental Health Officer

MODERATE INCIDENT MANAGEMENT

Immediately Notify Facilities Officer

General Manager



Assess if the spill, overflow, fire potential is likely to be detrimental to health, safety or welfare of anyone.


Arrange for waste tankers or bypass pumps. Contain spill by bund, sandbagging etc.

Notify neighbors by door knock if overflow likely to impact the health, safety or welfare of anyone.


Immediately Notify Director of Engineering

Attend the site.

Co-ordinate actions with the Operator and others


11.3 Major Incident Action Plans The action plan for the following significant incidents is shown in Figure 11.3:

Figure 11.3 Major Incident Action Plan

Facilities Officer

IMMEDIATELY

Notify the EPA

IMMEDIATELY (As appropriate) NSW Health

WorkCover

Notify General Manager

NSW Office of Water

Emergency Services


MAJOR INCIDENT MANAGEMENT

MAJOR SEWAGE SPILL

Immediately Notify Facilities Officer

General Manager



Assess if the spill, overflow, fire potential is likely to be detrimental to health, safety or welfare of anyone.


Arrange for waste tankers or bypass pumps

Contain spill by bund, sandbagging etc

Notify neighbors by door knock if overflow likely to impact the health, safety or welfare of anyone.


Immediately Notify Director of Engineering

Attend the muster point.

Co-ordinate actions with Sewer Operator and and emergency services.

Assess situation

Liaise with Council

Sewer Operator


Figure 11.4 Major Incident Action Plan Chlorine Gas

Facilities Officer

IMMEDIATELY

Notify the EPA, NSW Health,

WorkCover

Notify General Manager

Sewer Operator


MAJOR INCIDENT MANAGEMENT CHLORINE GAS LEAK OR FIRE IN CHLORINATION ROOM

Immediately Notify Facilities Officer Immediately Notify the STP Neighbour

General Manager



Close valves/isolate cylinders/TRY TO STOP LEAK

Call 000

Assess WIND DIRECTION if toward house immediately notify residents.

Go to muster point


Immediately Notify Director of Engineering Attend the muster point.

Co-ordinate actions with Sewer Operator and emergency services.

Assess situation

Liaise with HAZMAT


12 Evaluation, Audit and Review for Continuous Development

12.1 Evaluation and Review A systematic review of the plan will be undertaken by the Facilities Officer annually or within one month of an incident occurring at the plant. The evaluation will:

• Assess the relevance of the risk assessment against the current state of the plant

• Identify any emerging problems and trends

• Assess the communication between Council, Council’s operational staff and regulators

• Assist in determining priorities for improving procedures

• Assessment of incidents and responses determined

• Determine when and what is to be audited in the next six months

Evaluation of results described above will be documented and the plan updated.

Evaluation will be reported to the Council and stakeholders.

12.2 Auditing Auditing of the pollutant inventory is to be done annually.

An audit may also be triggered by a significant incident or if the process chemical is changed.


13 References 1. POELA Act 2011

2. POEO Act 1997

3. EPL – 1733 Section 55 Protection of the Environment Operations Act 1997

4. O&M Manual – Lockhart Operation and Maintenance Manual 2012


14 Appendices

Appendix A – MSDS


Appendix B – Plans


Appendix C - Training/ Education Register

Family Name Given Name Qualification Description Issued Date Expiry Date James Laurie Wastewater Treatment Part 1 March 2012 PIRMP Manual Handling Confined Spaces Chemcert Apply First Aid Apply Traffic Control Plans (Yellow) NSW Driver's Licence Relief Operator Wastewater Treatment Part 1 PIRMP Manual Handling Confined Spaces Chemcert Apply First Aid Apply Traffic Control Plans (Yellow) NSW Driver's Licence


Appendix D – Incident Reporting Form



65 Green Street Lockhart NSW 2656

Telephone (02) 6920 5305 Fax (02) 6920 5247

Email: [email protected]

Lockhart Collection System Environmental Protection Licence (EPL)

RECORD OF SEWER OVERFLOW (SPS, manhole or pipeline)

Date Start Time Duration

Estimated Volume

Location of spill

Description of the Receiving Environment

Was there a public Health Risk Go to notifications

Classification of the spill Dry weather Wet Weather

Cause of the spill

Actions taken to minimise or contain the spill

Actions taken to clean up after the spill

Actions required to prevent the spill occurring again

Notifications Director of Engineering

Director of Environmental Services

NSW Health

EPA



65 Green Street Lockhart NSW 2656

Telephone (02) 6920 5305 Fax (02) 6920 5247

Email : [email protected]

Lockhart STP Environmental Protection Licence (EPL)

RECORD OF OVERFLOW STP

Date Start Time Duration

Material Spilled

Estimated Volume

Location of spill

Did it leave the site?

Description of the Receiving Environment

Was there a public Health Risk Go to notifications

Classification of the spill Dry weather Wet Weather

Cause of the spill

Actions taken to minimise or contain the spill

Actions taken to clean up after the spill

Actions required to prevent the spill occurring again

Notifications Director of Engineering

Director of Environmental Services

NSW Health

EPA


Appendix E – Audit Log Form

Auditor/ reviewer comment (System deficiency and non-compliances)

Scheme response

Corrective actions to prevent reoccurrence

Timetable for corrective/preventive action

Person(s) responsible

Completion Date

The report must be signed by the Director of Engineering.


Appendix F – Safe Work Method Statements


Appendix G – Accident and Emergency Procedure

LOCKHART SHIRE COUNCIL Project Safety Management Plan

Accident / Emergency Procedures

Form OHS-03 Rev1/July 2002


Level 14 McKell Building

2-24 Rawson Place

Sydney NSW 2000

www.publicworks.nsw.gov.au

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