Environmental Management Plan - Department of Defence...This Environmental Management Plan (EMP) has been prepared for the environmental field investigations required to be carried

Department of Defence

05-Nov-2015

Environmental Management Plan RAAF Williamtown Stage 2B Environmental Investigation

AECOM Environmental Management Plan – RAAF Williamtown Stage 2B Environmental Investigation

\\ausyd1fp001\Projects\_Proposals\2015\Environment\OPP-422708_RAAFWilliamtownAssessment\Project Work\EMP and ECC\EMP\EMP_Stage 2B Investigation.docx Revision 0 – 05-Nov-2015 Prepared for – Department of Defence – ABN: 68706 814 312

Environmental Management Plan RAAF Williamtown Stage 2B Environmental Investigation

Client: Department of Defence

ABN: 68706 814 312

Prepared by

AECOM Services Pty Ltd Level 21, 420 George Street, Sydney NSW 2000, PO Box Q410, QVB Post Office NSW 1230, Australia T +61 2 8934 0000 F +61 2 8934 0001 www.aecom.com ABN 46 000 691 690

In association with

AECOM Australia Pty Ltd

05-Nov-2015

Job No.: 43218467/0/0

AECOM in Australia and New Zealand is certified to the latest version of ISO9001, ISO14001, AS/NZS4801 and OHSAS18001.

© AECOM Services Pty Limited. All rights reserved.

No use of he contents, concepts, designs, drawings, specifications, plans etc. included in this report is permitted unless and until they are the subject of a written contract between AECOM Services Pty Limited (AECOM) and the addressee of this report. AECOM accepts no liability of any kind for any unauthorised use of the contents of this report and AECOM reserves the right to seek compensation for any such unauthorised use.

Document Delivery

AECOM Services Pty Limited (AECOM) provides this document in either printed format, electronic format or both. AECOM considers the printed version to be binding. The electronic format is provided for the client’s convenience and AECOM requests that the client ensures the integrity of this electronic information is maintained. Storage of this electronic information should at a minimum comply with the requirements of the Electronic Transactions Act 2002.



Table of Contents 1.0 Introduction 1

1.1 Site Operations 1 1.2 EMP Objectives 1 1.3 Compliance with Legislative Articles 2 1.4 Compliance with Existing Environmental Management Systems 3 1.5 Roles and Responsibilities 3

1.5.1 Site Supervisor 3 1.5.2 Subcontractors 3 1.5.3 Community and Environment Personnel 4

1.6 Benefits of Complying with EMP Procedures 4 1.7 Potential Consequences of Departure from Specified EMP Procedures 4 1.8 Compliance Control 4 1.9 Environmental Training 4

2.0 Site Works and Emergency Arrangements 5 2.1 Description of Site Activities 5 2.2 Site Contact and Emergency Numbers 5 2.3 Incident and Emergency Response 6 2.4 Onsite and Offsite Work Areas 6

3.0 Site Environmental Aspects, Impacts and Controls 0 4.0 Limitations 1



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1.0 Introduction The Defence Environmental Remediation Programs (DERP) engaged AECOM Services (AECOM) to undertake and deliver the Stage 2B Environmental Investigation (Stage 2B EI) at RAAF Base Williamtown, Port Stephens NSW. The purpose of the investigation is to further assess the nature and extent of soil, groundwater, surface water and sediment impacts due to historical releases of aqueous film forming foam (AFFF) as identified in the Stage 2A Environmental Investigation conducted by URS Australia Pty Ltd in 2014.

This Environmental Management Plan (EMP) has been prepared for the environmental field investigations required to be carried out as part of the Stage 2B EI.

1.1 Background

RAAF Base Williamtown is an active airbase of the Royal Australian Air Force and is the headquarters of the RAAF Air Combat Group. The Base is the home of several squadrons operating the F/A-18 Hornet, Wedgetail AEWC, PC-9 and Hawk Lead-In Fighter aircraft. Newcastle Airport also operates from a leased area on the southern side of the airfield and utilises the runway under an operating agreement with the Department of Defence.

The site is located in a semi-rural setting with agricultural land, water catchment reserve and State Conservation Areas surrounding the site. The site is within the Port Stephens Local Government Area and is approximately 15 km north of the city of Newcastle. Adjacent areas are Medowie to the north and Raymond Terrace to the west.

1.2 Site Operations

The site is an operational establishment from which several aviation squadrons and support organisations conduct training and operational activities. These activities include:

- Aircraft take off, landing and air operations

- Aircraft refuelling

- Aircraft wash down

- Aircraft maintenance

- Ground support operations and maintenance

- Through life support of capability and equipment

- Air traffic control operations

- Fire training and emergency response

- Administrative activities.

- Infrastructure maintenance

Fire training activities, emergency response, spills of AFFF concentrate, failing water treatment and retention infrastructure and testing of deluge systems has resulted in contamination of soil and groundwater with AFFF compounds.

1.3 EMP Objectives

The EMP has been prepared in accordance with the required scope of work set out in the Stage 2B Sampling, Analysis and Quality Plan (SAQP), October 2015.

The objective of the EMP is to document the managerial procedures and onsite environmental safeguard controls associated with the fieldwork to be conducted at the site and at specified offsite areas.



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1.4 Compliance with Legislative Articles

Environmental Protection and Biodiversity Conservation Act (Commonwealth, 1999)

The primary Commonwealth environmental law is the Environmental Protection and Biodiversity Conservation Act (EPBC Act, 1999). A person planning an activity involving a matter regulated by the EPBC Act may need to obtain approval from the Environment Minister under the EPBC Act and these matters are known as Matters of National Environmental significance (MNES). Projects, activities, developments or other undertakings which are likely to have a significant impact on MNES (as determined by the Significant Impact Guidelines) require the approval of the Commonwealth Minister for the Environment.

The Australian Government Department of the Environment Protected Matters Search Tool (PMST) was accessed and the following Protected Matters were identified along with proposed risk mitigation approaches:

- Protected bush area north of facility 394 (former land fill) offsite: No intrusive work is proposed in this area.

- Base building and structures are of Commonwealth heritage significance onsite: No intrusive work is proposed within buildings, external structures or hardstand ground coverings.

Protection of the Environment Operations Act (NSW 1997)

The Protection of the Environment Operations Act 1997 (POEO Act) is the principal legislation by which the New South Wales Government regulates activities which have the potential to adversely impact the environment. It provides the NSW Environmental Protection Authority (EPA) with the power to regulate scheduled activities, grant licences, issue environmental protection notices and prosecute environmental offences. The POEO Act contains a duty to notify “relevant authorities” of pollution incidents where material harm to the environment is caused or threatened to be caused. This includes actual or potential harm to the health, safety and wellbeing of humans or to ecosystems that results in actual or potential loss or property damage of an amount exceeding $10,000.

During the onsite and offsite intrusive works, AECOM will implement environmental controls to ensure that, so far as is reasonably practicable, pollution of the environment is prevented and existing areas of environmental pollution are not made worse.

Contaminated Land Management Act (NSW 2008)

The Contaminated Land Management Act 2008 establishes a process for investigating and remediating land which the NSW EPA considers to be contaminated significantly enough to require regulation. The act sets out accountabilities for managing contamination, the role of the EPA in the assessment of contamination, the supervision of the investigation and management of contaminated sites and to ensure that contaminated land is managed with due regard to the principles of ecologically sustainable development.

The principle concept of the act is the “polluter pays” principle, effectively meaning that the party which is responsible for the contamination also has the responsibility for managing and remediating it. This act is of importance to site works at RAAF Williamtown as there are several areas where additional areas may become contaminated due to site works. As stated previously, AECOM will implement site pollution control measures to ensure that, so far as is practicable, pollution of the environment is prevented and existing areas of pollution are not made worse.

Development Control Plan 2014

The Development Control Plan (2014) administered by the local authority (Port Stephens Council) is applied under the Port Stephens Local Environmental Plan (LEP) 2013 as made under the provisions within 74C of the Environmental Planning and Assessment Act 1979, and Part 3 of the Environmental Planning and Assessment Regulation 2000

The DCP provides guidance on environmental safeguard measures for development activities, including earthworks that should be undertaken to protect the local environment. Such measures include mitigation of erosion and runoff, protection of water quality, drainage, natural resources and heritage, and adequate waste management practices.



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1.5 Compliance with Existing Environmental Management Systems

AECOM have complied with the specified protocol under the RAAF Base Williamtown Environmental Management System (EMS) by preparing this EMP to establish works that may have adverse environmental impacts, and document the risk mitigation approaches to such activity.

1.6 Roles and Responsibilities

1.6.1 Site Supervisor

Role

The role of the Site Supervisor is to manage sub-contractors, sampling activities and intrusive works to ensure time, quality, and financial, community and environmental targets of the site are met.

The Site Supervisor is accountable to the Project Manager for all site issues.

Responsibilities

The responsibilities of the Site Supervisor are:

- Report directly to the Project Manager on all environmental and community matters;

- The onsite and offsite implementation of this EMP;

- Ensure that all sub-contractors comply with environmental protection procedures appropriate to their activities;

- Ensure that all sub-contractors comply with community relations procedures;

- Conduct regular site inspections of the work area, surrounding areas and sub-contractors activities;

- Record and action System Defects (i.e. spills, incidents and complaints) when required; and

- Enforce compliance with requirements or risk mitigation measures identified in the works-specific Environmental Clearance Certificate (ECC), to be issued by the REO/SEM.

1.6.2 Subcontractors

Role

The role of the subcontractor is to complete their assigned scope of works in a diligent and professional manner. The subcontractors are accountable to the Site Supervisor for all site issues and to the Project Manager (AECOM) with respect to all Contract issues.

AECOM will engage specialist subcontractors to assist with field investigations, including:

- Location of underground services in areas proposed for bore drilling;

- Drilling of soil bores at nominated locations to access soil for sampling and testing needs;

- Installation of single and nested monitoring wells as per the SAQP; and

- Transport of waste to the Base.

Responsibilities

The responsibilities of the Subcontractors will be to:

- Comply with all Commonwealth and State Legislation and Regulations in relation to the work they are undertaking;

- Demonstrate understanding of environmental issues and environmentally sensitive areas;

- Implement environmental protection measures in accordance with the proposal and this EMP;

- Train all workers in relation to environmental measures;

- Report all incidents, System Defects and complaints to the Site Supervisor; and

Ensure all workers and others (e.g. sub-contractors and suppliers) comply with community relations, protocols and procedures.



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1.6.3 Community and Environment Personnel

Site Supervisors and all AECOM Sub-Contractors are to ensure that the community and environmental objectives in the EMP are achieved.

The site supervisor will be responsible for reporting directly to the Project Manager on all environmental and community issues and risks identified (e.g. complaints made by neighbouring residents), these will be entered into the Issues Risk Register for follow up and close out. The Project Manager will address any unresolved environmental and community issues in consultation with the REO/SEM.

1.7 Benefits of Complying with EMP Procedures

The AECOM site induction process is designed to improve AECOM site personnel awareness relating to the impact of site works on the internal Defence stakeholders, immediate users of adjacent facilities, the local community and the receiving environment. The induction process will also identify what AECOM site personnel and subcontractors can do to control and minimise these impacts. The benefit of AECOM site personnel and subcontractors adhering to the EMP requirements is that site works will have minimal impact on the Base Stakeholders, the local community and all environmental and ecosystem values.

1.8 Potential Consequences of Departure from Specified EMP Procedures

Consequences of departure from specified operating procedures could have the potential to impact on the Program in the following ways:

- Detrimental impacts on the environment;

- Liability under the EPBC Act and State environment protection legislation;

- Personal fines for AECOM senior managers;

- Loss of company reputation;

- Poor stakeholders perceptions of AECOM operations;

- Lack of Project Due diligence; and

- Impact to base operations.

1.9 Compliance Control

The procedural framework to manage compliance with environmental legislation, and assess and manage potential environmental impacts, as per the requirements of this EMP, is identified below:

- Identify potential environmental risks and opportunities prior to carrying out certain tasks and mitigate these through forward planning;

- Report and learn from environmental incidents or near-misses;

- Follow Environmental Operating Procedures to avoid or mitigate environmental impacts associated with works; and

- Regularly audit field procedures against the requirements of this EMP.

1.10 Environmental Training

AECOM site personnel working on the site will have received the appropriate internal and external training and possess the required skills to fulfil their role in a competent manner. Only AECOM approved subcontractors will be used on this project. Environmental training requirements will include as a minimum:

- Site induction which will detail the following:

The scope of works and the requirements of this EMP;

Types of hazards likely to be encountered which may impact on the environmental values at the base;

Expected best practice requirements with regards to minimising run-off from the work area, emissions to air, noise and dust;



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3.0 Site Environmental Aspects, Impacts and Controls The potential environmental aspects and impacts associated with the proposed field works are documented in the following table, along with a description of the measures to mitigate and/or reduce the risks associated with these activities.



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4.0 Limitations

AECOM Services Australia Pty Ltd (AECOM) has prepared this report in accordance with the usual care and thoroughness of the consulting profession for the use of Department of Defence and only

those third parties who have been authorised in writing by AECOM to rely on the report.

The Report is based on generally accepted practices and standards at the time it was prepared. No other warranty, expressed or implied, is made as to the professional advice included in this report.

The Report is prepared in accordance with the scope of work and for the purpose outlined in the Proposal dated 26 October 2015.

This report should be read in full. No responsibility is accepted for use of any part of this report in any

other context or for any other purpose or by third parties.

The methodology adopted and sources of information used by AECOM are outlined in the Report.

Where this report indicates that information has been provided to URS by third parties, AECOM has made no independent verification of this information unless required as part of the agreed scope of work. AECOM assumes no liability for any inaccuracies in or omissions to that information.

This Report was prepared between 22 October 2015 and 27 October 2015.The information in this

Report is considered to be accurate at the date of issue and is in accordance with conditions at the site at the dates sampled. Opinions and recommendations presented herein apply to the site existing at the time of our investigation and cannot necessarily apply to site changes of which AECOM is not

aware and has not had the opportunity to evaluate. This document and the information contained herein should only be regarded as validly representing the site conditions at the time of the investigation unless otherwise explicitly stated in a preceding section of this Report. AECOM

disclaims responsibility for any changes that may have occurred after this time.

Except as required by law, no third party may use or rely on, this Report unless otherwise agreed by AECOM in writing. Where such agreement is provided, AECOM will provide a letter of reliance to the agreed third party in the form required by AECOM.

To the extent permitted by law, AECOM expressly disclaims and excludes liability for any loss,

damage, cost or expenses suffered by any third party relating to or resulting from the use of, or reliance on, any information contained in this Report. AECOM does not admit that any action, liability or claim may exist or be available to any third party.

AECOM does not represent that this Report is suitable for use by any third party.

Except as specifically stated in this section, AECOM does not authorise the use of this Report by any

third party.

It is the responsibility of third parties to independently make inquiries or seek advice in relation to their particular requirements and proposed use of the relevant property.

Any estimates of potential costs which have been provided are presented as estimates only as at the date of the Report. Any cost estimates that have been provided may therefore vary from actual costs

at the time of expenditure.



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Ownership of Report

Readers are advised that this Report has been produced under contractual arrangements such that AECOM grants to Defence a permanent, irrevocable, royalty free, non-exclusive licence (including the

right to grant a sub-licence) to use, reproduce, adapt and exploit the intellectual property rights in the Report anywhere in the world. Notwithstanding Part VII of the Copyright Act (1968), publication of the Report in accordance with this licence shall not affect such ownership.



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Appendix A Environmental Incident Reporting and Management (Rev 1.0, 1 Feb 2015)

Defence National Environmental Standard:

EP3 Environmental Incident Reporting & Management

Defence National Environmental Standard Environmental Incident Reporting & Management

Content

Purpose................................................................................................................................................................ 1

Scope................................................................................................................................................................... 1

Related Defence National Environmental Standards ........................................................................................... 1

Terms and definitions........................................................................................................................................... 1

Performance requirements................................................................................................................................... 6

Minimum performance levels............................................................................................................................ 6

Minimum process measures............................................................................................................................. 6

Incident, Emergency and non-conformance ................................................................................................... 11

Monitoring, audit and review........................................................................................................................... 11

Reporting........................................................................................................................................................ 11

User feedback ................................................................................................................................................ 12

Schedule A – Guidance for Assessment of Environmental Incident Severity..................................................... 13

Schedule B – Environmental Incident Management Forms ............................................................................... 17

Schedule C – Environmental Incident Management Responsibilities................................................................. 21


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8. Ship-based Navy environmental incidents including whale strikes, foreign fishing, sewage and fuel spills and other marine pollution, specified greenhouse gas emissions and marine pest fouling, must be reported through Navy’s Safety & Environment Reporting System (SERS) http://navy.defence.gov.au/SERS/.

9. The Environmental Incident Forms (refer Schedule B) can be accessed in many ways:

DEQMS intranet site

Defence Webforms on the http://intranet.defence.gov.au homepage (Form identification number AE444)

Defence webpage: www.defence.gov.au/environment

Via email from Environmental or Base staff.

10. Two versions of the Environmental Incident Register are maintained. A simplified version is available to anyone with DRN access via the DEQMS intranet site. A complete version of the Register is available on an as-needs basis to relevant personnel such as Base staff involved in environmental management and environmental policy owners. Personnel who require access to the complete Register should contact the Register manager via [email protected]. The Register draws data from the environmental incident forms and is managed by EE Branch.

11. An incident can occur whilst following an Standard Operating Procedure, RSO, Construction EMP, or similar, and must be reported.

12. Where an environmental impact occurs that is approved through an ECC, SOP, RSO, Construction EMP or similar, an incident report is not required. Where an environmental impact occurs that is greater than approved, even whilst following the approved procedure, an incident must be reported.

13. For incidents with Workplace Health and Safety (WHS) implications, personnel must also complete a WHS incident report. The following intranet webpage details the Defence WHS incident reporting rules and processes http://intranet.defence.gov.au/people/sites/WHS/.

14. Preventative and corrective actions should go through the normal approvals and funding processes.

Incident, Emergency and non-conformance

15. Refer to Base Emergency Management Plans (Base EMPs) for property-specific emergency management requirements and to Emergency Response Procedures (ERPs) and Base Instructions for response procedures.

Monitoring, audit and review

16. Environmental incident data is available for review and analysis via the Environmental Incidents Register to assist in improving Base or Training Area environmental performance.

17. The EE Branch policy owner may request the assistance of DSO Environmental personnel to review this DNES and related forms and documents for workability for users, usefulness for Base, environmental, policy and other relevant stakeholders, and compliance with legislation and other Defence policy.

18. SEMs and BSMs should regularly review outstanding corrective and preventative actions, close incidents and communicate results, and more general environmental performance, with stakeholders.

Reporting

19. The environmental incident registers can be viewed and used to inform reporting requirements.

20. EE Branch should prepare environmental incident data for Defence Annual Report in accordance with Australian Government Statutory Reporting requirements.

21. EE Branch should review and analyse trends in Environmental incident data, with a particular focus on Environmental Factors, to assist in policy review and development.

22. SEMs should review and analyse trends in Environmental incident data, with a particular focus on the Regional and Base scale on a regular basis, and communicate results to the relevant BSM, and other stakeholders, at the appropriate forum.


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User feedback

23. Personnel are encouraged to provide feedback on this DNES. Feedback will be used to inform future versions of this document, which will be reviewed at regular intervals in accordance with the Defence EMS continual improvement process.

24. Provide any feedback on this DNES via email to [email protected]. Please include the DNES title in the subject line of email/feedback.


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Schedule B – Environmental Incident Management Forms


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Documents

Environmental Management Plan - Department of Defence...This Environmental Management Plan (EMP) has been prepared for the environmental field investigations required to be carried