Pollution Incident Response Management Plan

Water and wastewater services

June 2018

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1 Area of Operations

1.1 Water

Sydney Water supplies over 1.5 billion litres of drinking water to homes and businesses throughout

Sydney, the Blue Mountains and the Illawarra every day. Water is treated at one of nine water

filtration plants. It is then supplied through a network of pipes, reservoirs and pumping stations:

• 21,951 km of water pipes

• 243 reservoirs

• 151 water pumping stations

1.2 Wastewater

Wastewater is treated at any of 16 wastewater treatment plants or 14 water recycling plants. The

wastewater network to get to those plants consists of:

• 25,597 km of pipes

• 684 wastewater pumping stations

• the Northside storage tunnel.

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Sydney Water has 24 separate systems that are licenced by the NSW Environment Protection

Authority (EPA)

1.3 Stormwater

Sydney Water’s stormwater network provides services to around 570,000 properties through 73

catchments and consists of:

• 447 km of channels and pipes

• over 60 stormwater quality improvement devices

• flood-prone land and trunk drainage in the Rouse Hill area.

1.4 How do pollution events happen?

Sydney Water has implemented Corporate Environmental and Quality Management Systems

compliant with ISO14001: Environmental Management Systems and ISO9001: Quality

Management Systems.

Despite having high standards of product quality and asset management, there are many natural

and operational factors that can result in pollution events. The most common pollution incidents

affecting Sydney Water are in relation to wastewater overflows.

Wastewater overflows occur when pipes become blocked and cause wastewater to back up and

overflow from a designed relief point. In dry weather, these blockages are most commonly caused

by tree roots, material such as wet wipes, silt, oil and grease or a combination of these. In wet

weather, stormwater can enter the wastewater system from illegal connections or ingress through

cracked pipes, and cause diluted wastewater to overflow to the environment.

Occasionally an asset failure or adverse weather conditions can cause a bypass of some

treatment process units. Extended power failures from the electricity networks can also result in

pollution events.

Sydney Water reports all incidents according to the conditions set out in their environment

protection licences.

1.5 Contact details

Although the water supply is available at least 99.7% of the time, customers can have their service

affected. Customers can see if there is a problem or planned maintenance work in their area by

going to Water supply and service updates on the Sydney Water website.

The Sydney Water Contact Centre is the primary mechanism for identification of pipe failures,

including leaks, breaks, odours or sewage overflows. To report an incident, customers can call the

24-hour emergency services line on 13 20 90.

Sydney Water also has a general enquiries line, 13 20 92, which is monitored during business

hours.

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2 Pollution incident response management

Incident Management is the process of limiting the actual and potential disruption caused by an

event. Sydney Water has adopted the comprehensive approach to Incident Management

commonly referred to as PPRR, which includes:

• Prevention

• Preparedness

• Response

• Recovery

To effectively manage incidents, all areas of Sydney Water, including our suppliers and business

partners, take an integrated perspective in preventing, preparing, responding to and recovering

from events.

To do this effectively we have aligned our Business Resilience Framework with international

standards ISO 22301: Societal security – Business Continuity and ISO 22320: Societal security –

Emergency Management. Our framework also implements the Australasian Interservice Incident

Management System (AIIMS) which is a cornerstone of the NSW State Government Emergency

Management arrangements.

2.1 Risk management

Before a disruptive event there are opportunities to implement proactive contingencies and

controls that can reduce the frequency and impact of disruptive events. Effective risk management

relies on a thorough understanding of criticalities, vulnerabilities, dependencies, and threats.

Suitable controls and contingencies can only then be developed to reduce risk to an acceptable

level.

Sydney Water has implemented a Risk Management Framework compliant with ISO 31000: Risk

Management, Principles and Guidelines. All criticalities are assessed to ensure an appropriate

level of risk management is applied and effective mitigation is in place.

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LeadershipEngagementCommitment

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2.2 Incident plans

Sydney Water develops incident plans to help manage the disruption caused by an event; it does

not prevent or eliminate the threat. In doing so Sydney Water takes an ‘All Hazards’ approach to

managing those impacts. These plans detail the actions to be taken to minimize or prevent any risk

of harm to human health or the environment.

Plans are developed for all identified criticalities to ensure continuity of supply to customers and

generally fall into one of the following categories as described below:

Testing of plans is done on a risk basis, the higher the risk the more frequent the testing and

assurance. Plans may also be tested during planned maintenance activities such as shutdowns and

when significant change occurs. The Water and Wastewater Services PIRMP is tested annually.

2.3 Incident notifications

Sydney Water has developed mechanisms to communicate both internally and externally with all

stakeholders who could be potentially impacted by an event. As each event is different, the

Incident Controller ensures that communication mechanisms, protocols and messaging are

established to effectively notify and communicate with staff, customers and key stakeholders.

External agencies will make decisions and initiate notifications and communications to their

stakeholders based on the information that we provide.

Social media has become an essential part of our communications strategy, particularly during an

event. Sydney Water currently has a presence on the following platforms.

• Twitter twitter.com/SydneyWaterNews

• Facebook facebook.com.au/SydneyWater

• LinkedIn linkedin.com/company/sydney-water

• YouTube youtube.com/SydneyWaterTV

• Instagram instagram.com/sydneywater

Assets

• Asset and Facility Contingency Plans

• System manuals

• Continuity of Operations Plans (COOPs)

• Pressure Management Plans

• Hazard Supplements

Customers

• High Consequence Customer Plans

Processes

• Drinking water quality event management plan

• Recycled water event management plan

• Standard Incident Plans

• Business Continuity Plans

• Alternate Site Plans

People

• Site Incident Response Plans/ Evacuation Plans

Suppliers

• Supplier's incident plans

Technology

• IT systems - IT Disaster Recovery Plans

• IICATS & SCADA telemetry plans

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The diagram below illustrates the external notifications required by our licences and agreed

Memoranda of Understanding.

OTHER AGREEMENTS

NOTIFICATION OBLIGATIONS

MEMORANDA of UNDERSTANDING

INSTRUMENTS

LEGISLATION

NSW State Legislation

Essential Services Act 1988

State Emergency & Rescue Mgt Act

1989

State EM arrangements

EUSFAC concept of operations plan

Sydney Water Act 1994

Operating Licence

RMS & RailCorp NSW Health F&R NSWNP&WSOffice of Water& Water NSW

DPI & the NSW Food Authority

Workplace Health & Safety Act

SafeWorkNSW

POEO Act 1997

Environmental Protection Licences

NSW EPA

Local Councils

Beachwatch

Mandated in Operating Licence

‘5 authorities’ notifications as per EPLs

Interagency agreement to notify

2.4 Incident response

The Sydney Water emergency response process is illustrated below and described overleaf.

Assess & declare incident

Establish controlNotify Manage Record

REVIEW

For every incident, a Controller is appointed who is accountable for all activities necessary for the

resolution of the event, including:

• establishing an Incident Management Team

• identification and application of tasks required to resolve the event

• acquisition, provision and management of resources, services, materials etc

• collection and analysis of information, including forecasts

• provision of warnings, notifications and information to staff, customers and stakeholders

• escalation and de-escalation of resourcing.

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Step Key tasks

Assess and declare incident

Actions to determine initial incident level

Assess and declare the incident based on the potential for it to escalate

Initial assessment looks at impact on:

▪ customers ▪ community ▪ environment ▪ public health ▪ safety ▪ reputation and media interest ▪ other Sydney Water businesses

Notify

Actions to notify affected stakeholders following predefined business rules and other direction

Notify key external stakeholders as required

▪ NSW EPA - Pollution Line, 13 15 55 ▪ NSW Health – 9391 9049 (Water Unit) ▪ SafeWork NSW, 13 10 50 ▪ Local Councils ▪ Fire & Rescue NSW, 1300 729 529 ▪ Roads & Maritime Services ▪ Sydney Trains (RailCorp) ▪ Beachwatch ▪ Food Authority/Dept. Primary Industries ▪ National Parks & Wildlife Services ▪ State Emergency Operations Centre ▪ Energy & Utilities Services Functional Area Coordinator (EUSFAC) ▪ Regional Emergency Management Officers

Notify additional stakeholders as directed by NSW EPA

Establish control

Actions to determine incident leadership and to exercise control over the event

Appoint Incident &/or Emergency Controller and nominate Incident Control Point as defined in plans/ procedures or by the direction of a Duty Manager

Establish the Incident &/or Emergency Management Team, including Liaison Officers where required

Review initial situation analysis

Commence Incident Log

Issue initial Situation Report (SITREP) to Duty Managers and stakeholders

Manage the incident

Actions to contain the event and restore services

Identify objectives, strategies and key tasks

Gather information and perform ongoing situational awareness, including feedback from deployed Liaison Officers

Conduct regular briefings for the Emergency Management Team and key stakeholders

Implement relevant plans and procedures

Implement communications protocols

Issue regular Situation Reports to Duty Managers and external stakeholders

Review and monitor effectiveness of response

Determine whether a Recovery Coordinator is required based on impacts. Early appointment

Maintain event records

Conduct Incident/Emergency Management Team handover briefings at shift changeover

Implement demobilisation

Agree on recovery objectives

Record the incident

Actions to record event details, investigations and debrief reports

Collate all event records

Record the event in SWIRL

Debrief incident in accordance with business rules

Commence incident investigation

Update risk registers

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2.5 Incident Management Team (IMT) structure

The structure of Sydney Water’s Incident Management Teams (IMTs) are based on AIIMS. The

structure can be adapted to the circumstances being dealt with and are flexible enough to change

as the event unfolds. A typical IMT is illustrated below.

For larger and more complex events, groups of tasks are delegated to functional teams within an

Emergency Management Team. Each functional team is led by a Team Coordinator to allow for a

manageable span of control. A typical EMT is illustrated below.

Emergency ControllerEmergency Controller

Personal Assistant

Personal Assistant

BR Advisor

BR Advisor

Deputy Controller

Deputy Controller

Managing Director & Executive

Managing Director & Executive

Minister & Board

Minister & Board

NSW EPANSW Health

NSW EPANSW Health

EUSFACSEOC

EUSFACSEOC

Planning Coordinator

Planning Coordinator

Operations Coordinator

Operations Coordinator

Communications Coordinator

Communications Coordinator

Logistics Coordinator

Logistics Coordinator

Situation Analysis

Situation Analysis

Customer Support

Customer Support

Social Media

Social Media

Rostering

Rostering

Mapping

Mapping

Liaison Officers

Liaison Officers

Media

Media

Risk Assessment

Risk Assessment

Monitoring & Testing

Monitoring & Testing

>24hr Planning & Forecasting

>24hr Planning & Forecasting

Board & Executive Briefings

Board & Executive Briefings

Staff Information

Staff Information

Customers & Stakeholder

management

Customers & Stakeholder

management

Insurance

Insurance

Legal

Legal

Safety

Safety

Plant & Equipment

Plant & Equipment

Technical Repairs/Planning

Technical Repairs/Planning

Civil

Civil

Mec/Elec

Mec/Elec

Treatment

Treatment

Asset monitoring

Asset monitoring

<24hr planning

<24hr planning

Incident Control

(incl. Planning)

Operations & Logistics

Logistics/ Warehouse

Site Coordination

Crew

Communications

Media

Document number: D0000825

SW238 06/18 © Sydney Water. All rights reserved.