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Construction Environmental Management Plan

(Seahampton to Kurri Kurri Section of the Hunter Expressway)

HEA-PL-GL-EMP-001-00-04

Rev Date Prepared by Reviewed by Approved by Remarks

01 Feb 2010 T. Doczy H. Chemney P. Chatburn Prepared for HEA.

02 May 2010 A. Zambolt H. Chemney P. Chatburn

Includes DECCW, I&I NSW, NSW OoW, Utility providers, Relevant Councils, RTA & EMR review comments

03 June 2010 A. Zambolt H. Chemney P. Chatburn Amended based on minor comments from EMR

04 July 2010 H. Chemney T. Doczy P. Chatburn Amended based on DOP comments

Hunter Expressway Alliance

CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN

HEA-PL-GL-EMP-001-00-04 Page 2

DOCUMENT CONTROL

Title: Hunter Expressway Alliance Construction Framework Environmental Management Plan

Document No/Ref:

HEA-PL-GL-EMP-001-00-04

General Description:

Provides management measures, mitigation strategies and environmental management systems information to be implemented as they relate to pre-construction, construction and post-construction phases of the Project.

Document Path: S:\HEA\01 Environment\01_02_CEMP\1.2.4_Volume 1\Final for DoP Approval\HEA-PL-GL-EMP-001-00-04.doc

Approval Name Position Signed/Approved Date

Document Editor / Author

Tracey Doczy Environment Manager - Construction

Review Howard Chemney Environment Manager - Design

Alliance Project Director

Peter Chatburn Alliance Director

ENVIRONMENTAL MANAGEMENT SYSTEM AMENDMENT REGISTER

Section Amendments made Reasons for amendment




CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN DOCUMENT CONTROL

The Construction Environmental Management Plan (CEMP) (HEA-PL-GL-EMP-001-00-00) for the Hunter Expressway Alliance, is a controlled document.

The most recent and up to date version (controlled copy) of the CEMP shall be kept on Incite Keystone at Revisionable Documentations/ Plans and Procedures.

The following people shall have hard copies of the main document and sent information regarding any updates, however all personnel should refer to the Incite Keystone version of the plan to ensure the most recent copy is being used. The hard copies shall be updated periodically approximately each six months:

Copy No. Position Current Incumbent

1 Alliance Project Director Peter Chatburn

2 Environment Manager Howard Chemney/ Tracey Doczy

3 Environmental Management Representative Ken Holmes

4 Senior Environment Officer, Hunter Region, RTA David Ledlin

5 Department of Planning Kylie Seretis

6 Environmental Officer To be advised

Prior to being issued, any proposed amendments to this CEMP must be approved by the Alliance Project Director, following consultation with stakeholders as required and certified by the Environmental Management Representative




TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................................... 6

1.1 DESCRIPTION AND LOCATION OF THE PROJECT .................................................................... 10 1.2 ENVIRONMENTAL ISSUES ............................................................................................................ 13 1.3 BACKGROUND – ENVIRONMENTAL PLANNING PROCESS ...................................................... 13 1.4 HUNTER EXPRESSWAY ALLIANCE ENVIRONMENTAL CONTEXT ........................................... 15 1.5 CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN STRUCTURE ............................... 15 1.6 PURPOSE AND SCOPE OF THE CEMP ....................................................................................... 22 1.7 OBJECTIVES AND TARGETS OF THE CEMP .............................................................................. 22 1.8 ADDITIONAL ENVIRONMENTAL INCENTIVES ............................................................................ 23 1.9 ENVIRONMENTAL POLICY ............................................................................................................ 24

2 PLANNING ...................................................................................................................................... 25

2.1 LEGAL OBLIGATIONS .................................................................................................................... 25 2.2 PROJECT ENVIRONMENTAL OBLIGATIONS .............................................................................. 25 2.3 COMPLIANCE STANDARDS AND GUIDELINES .......................................................................... 25 2.4 ENVIRONMENTAL ASPECTS, IMPACTS AND RISKS ................................................................. 25 2.5 SENSITIVE AREAS ......................................................................................................................... 28 2.6 PLANNING FOR ANCILLARY CONSTRUCTION FACILITIES ...................................................... 28

3 IMPLEMENTATION AND OPERATION ......................................................................................... 30

3.1 CONSTRUCTION SCHEDULE ....................................................................................................... 30 3.2 SITE STRUCTURE .......................................................................................................................... 32 3.3 ENVIRONMENTAL MANAGEMENT TEAM .................................................................................... 33 3.4 ENVIRONMENTAL CONSULTANTS .............................................................................................. 38 3.5 UTILITIES ........................................................................................................................................ 38 3.6 RESOURCES .................................................................................................................................. 38 3.7 ENVIRONMENTAL CONTROL MEASURES AND PROCEDURES ............................................... 39 3.8 TRAINING, AWARENESS AND COMPETENCE ........................................................................... 44 3.9 COMMUNICATION AND CONSULTATION .................................................................................... 47 3.10 INCIDENT AND EMERGENCY PLANNING, PREPAREDNESS AND RESPONSE ...................... 53

4 COMPLIANCE ................................................................................................................................. 58

4.1 COMPLIANCE TRACKING STRATEGY ......................................................................................... 58 4.2 CHECKLISTS .................................................................................................................................. 58 4.3 INSPECTION AND SURVEILLANCE .............................................................................................. 59 4.4 AUDITS ............................................................................................................................................ 60 4.5 ENVIRONMENTAL MONITORING ................................................................................................. 62 4.6 NON-CONFORMANCE, PREVENTIVE AND CORRECTIVE ACTION SYSTEMS ........................ 63

5 REVIEW AND IMPROVEMENT OF CEMP .................................................................................... 65

6 REPORTING .................................................................................................................................... 66




LIST OF TABLES

Table 1.1: Alliance section design features ........................................................................................... 10

Table 1.2: CEMP structure .................................................................................................................... 16

Table 1.3: Sub Plan Contents ............................................................................................................... 18

Table 1.4: Consultation requirements for the CEMP and sub plans ..................................................... 20

Table 1.5: Objectives and targets .......................................................................................................... 23

Table 2.1: Likelihood criteria ................................................................................................................. 26

Table 2.2: Consequence criteria ........................................................................................................... 26

Table 2.3: Risk severity ......................................................................................................................... 27

Table 3.1: Construction schedule .......................................................................................................... 31

Table 3.2: Environmental consultants ................................................................................................... 38

Table 3.3: Training matrix ...................................................................................................................... 44

Table 3.4: Possible training topics ......................................................................................................... 46

Table 3.5: External consultation ............................................................................................................ 49

Table 4.1: Inspection frequency ............................................................................................................ 59

Table 4.2: Auditing report requirements ................................................................................................ 61

Table 4.3: Standard monitoring frequencies ......................................................................................... 63

LIST OF FIGURES

Figure 1.1: CEMP preparation, review and approval process ................................................................. 9

Figure 1.2: Location and alignment of the project ................................................................................. 12

Figure 1.3: Summary of the Hunter Expressway environmental planning process .............................. 14

Figure 1.4: Environmental document structure ..................................................................................... 19

Figure 2.1: Risk rating ........................................................................................................................... 27

Figure 3.1: HEA Organisational Chart ................................................................................................... 32

APPENDICES

APPENDIX A – ENVIRONMENTAL POLICY

APPENDIX B – SENSITIVE AREAS PLANS

APPENDIX C – REGULATORY REQUIREMENTS, POLICIES, GUIDELINES AND STANDARDS

APPENDIX D – ENVIRONMENTAL RISK REGISTER

APPENDIX E – EMERGENCY PROCEDURES AND EMERGENCY CONTACTS

APPENDIX F – EXAMPLE FORMS

APPENDIX G – REFUELLING PROTOCOL

APPENDIX H – ENVIRONMENTAL CONSTRUCTION METHOD STATEMENTS MATRIX

APPENDIX I – ANCILLARY ACTIVITIES/ FACILITIES

APPENDIX J – AUDIT SCHEDULE

APPENDIX K – SUMMARY OF CONDITIONS OF APPROVAL RELATING TO THE CEMP




LIST OF ABBREVIATIONS & DEFINITIONS

Term Definition

ALT Alliance Leadership Team

CAR Corrective Action Request

CCC Cessnock City Council

CEMP Construction Environmental Management Plan

CIG Community Interest Group

CoC Conditions of Concurrence

Construction

Includes construction work in respect of the Activity other than survey, acquisitions, fencing, investigative drilling or excavation, building/road dilapidation surveys, minor clearing (except where threatened species, populations or ecological communities would be affected), establishing site compounds (in locations meeting the criteria of the Conditions), or other activities determined by the EMR to have minimal environmental impact (e.g. minor access roads, minor adjustments to services/utilities, etc.)

COURs Commitments, obligations, undertakings and requirements that come from Environmental Impact Assessments, Conditions of Approval/Concurrence and other project related reports for the Hunter Expressway Alliance Project.

CURA Thiess’ risk management program

DECCW Department of Environment, Climate Change and Water

I&I NSW (Fisheries)

Industry and Investment NSW (Fisheries Ecosystems)

DIPNR Department of Infrastructure Planning and Natural Resources (now DoP)

DoP Department of Planning

DWE NSW Office of Water (ex- Department of Natural Resources - DNR)

EA Environmental Assessment

ECMS Environmental Construction Method Statements

EEC Ecologically Endangered Community

EMR NSW Department of Planning’s Environmental Management Representative

EMS Environmental Management Systems

EMSP Environmental Management Sub Plan

EP&A Act Environmental Planning and Assessment Act 1979

EPRG Environmental Peer Review Group




Term Definition

ERG Environmental Review Group (consists of Government agency representatives, RTA representatives and key Alliance staff).

e-table Access database, which contains all of COURS relating to Hunter Expressway Alliance.

FIS Fauna Impact Statement

Incite Keystone Online data management system.

JSEA Job Safety Environmental Analysis

HEA Hunter Expressway Alliance (Seahampton to Kurri Kurri)

HEx Hunter Expressway (F3 to Branxton)

LMCC Lake Macquarie City Council

MC Maitland Council

MCoA or CoA The Minister for Planning’s Conditions of Approval for the project.

MSDS Materials Safety Data Sheet

NCR Non conformance report

NVMSP Noise and Vibration Management Sub Plan

OoC Observation of Concern

RTA NSW Roads and Traffic Authority

Sensitive Area Plans

Maps showing locations of environmental sensitive areas such as heritage sites, threatened species and Ecologically Endangered Species (refer to Appendix B).

The Project F3 to Branxton (Hunter Expressway Alliance Section)

The Alliance Consists of four Alliance partners, Thiess, Parson Brinckerhoff, Hyder and RTA.

WMS Work Method Statements




1 INTRODUCTION

This Construction Environmental Management Plan (CEMP) provides for implementation of the required environmental safeguards during the construction of the Hunter Expressway – Alliance Section. The CEMP has been developed in accordance with the relevant environmental legislation, and specifically incorporates environmental control measures as outlined in the following documents:

i) the original request for approval of the proposal, including:

Proposed Highway Link – F3 Freeway to Branxton, Environmental Impact Statement (EIS) (Connell Wagner, June 1995);

Proposed Highway Link – F3 Freeway to Branxton, Fauna Impact Statement (FIS) (Connell Wagner, January 1997) and accompanying documentation, Flora and Fauna Modification approval dated 19 August 2007 Report (Mount King Ecological Surveys, 1995), Fauna Survey Greta Deviation (Connell Wagner, 1996) and Herptofauna Survey (Richard Wells, 1995);

Additional Flora and Fauna Assessment (AFFA) (Connell Wagner, May 2001), to supplement the original FIS;

Representations Report (three volumes) (RTA, October 2001);

Supplementary Review of Environmental Factors for the Allandale to Illalong Section Comparison of Options (SREF) (Connell Wagner, August 2000);

Kurri Sand Swamp Woodland Recovery Assessment (Biosis Research, August 2001), a report commissioned jointly by the RTA and NPWS;

Additional Environmental and Engineering Assessment (Connell Wagner, May 2001); and

Compensatory Habitat Proposal and Candidate Areas – Stage 2 Report (Connell Wagner, September 2001);

the Minister for Planning’s Conditions of Approval dated 7 November 2001;

ii) The staged construction modification request (MOD-10-1-2006-i), including:

correspondence from the RTA to the Department, dated 20 December 2005, accompanied by F3 Freeway to Branxton Link – Modification to Permit Staged Construction (Acacia Environmental Planning Pty Ltd, September 2005);

the Minister for Planning’s Modification Approval dated 31 July 2006;

iii) the alignment and ancillary infrastructure modification request (07_0033 Mod 1), including:

correspondence from the RTA to the Department, dated 12 March 2007;

F3 Freeway to Branxton Link: Modification to the Approved Project Environmental Assessment (Acacia Environmental Planning Pty Ltd, March 2007);

F3 Freeway to Branxton Link: Threatened Species Assessment for Proposed Design Changes (Biosis Research, January 2007);

Noise Assessment: National Network, F3 to Branxton Link (Atkins Acoustics, February 2007);

Socioeconomic Analysis of the Proposed Tuckers Lane to Black Creek Modification (Centre for International Economics, January 2005);




F3 Freeway to Branxton Link: Submissions Report (Stuart J Hill Pty Ltd, June 2007); and

the Minister for Planning’s Modification Approval dated 19 August 2007

iv) Modification request (07_003Mod 2), including:

Hunter Expressawy Proposed modification to the project approval (Bowditch Group, February 2010):

the Minister for Planning’s Modification Approval dated 28 June 2007

The CEMP is the lead document that provides the environmental management framework for controlling and reporting on the construction phase environmental impacts. The CEMP has been separated into two volumes for ease of access and review. In accordance with the relevant Minister’s Conditions of Approval (CoAs) the CEMP comprises a number of sub plans that contain more detailed information on control measures for specific environmental aspects. The main environmental management systems information is outlined in Volume 1 whilst the sub plans form Volume 2 of the CEMP.

Following consultation with various stakeholder and subsequent revision of the CEMP as required, the CEMP will be submitted to the Department of Planning (DoP) for approval before construction starts. Figure 1.1 identifies the process involved in preparing, reviewing, and approving the CEMP.

Condition of Approval (CoA) no. 24 states that the Construction EMP shall:

“outline the environmental management practices and procedures that are to be followed during construction and shall be prepared in accordance with the Guideline for the Preparation of Environmental Management Plans (DIPNR 2004).

The CEMP shall include, but not necessarily be limited to:

i. a description of all relevant activities to be undertaken during construction of the project including an indication of stages of construction, where relevant; (Section 1.1, 3.1 & Appendix H)

ii. statutory and other obligations that the Proponent is required to fulfil during construction, including all approvals, consultations and agreements required from authorities and other stakeholders , and key legislation and policies; (Section 3.1.4)

iii. define the role, responsibility, authority, accountability and reporting of personnel relevant to compliance with the CEMP (including the EMR); (Section 3.3)

iv. the Sub Plans required under this Approval; (Volume 2)

v. include a matrix of Construction Method Statements (CMS) required to construct the project, including an assessment of the predicted level of environmental and public risk and potential level of public interest associated with each CMS and indicative timeframes for completion; (Appendix H)

vi. details of how the environmental performance of the construction works will be monitored,




and what actions will be taken to address identified adverse environmental impacts; (Section 4) and

vii. complaints handling procedures during construction. (Section 3.9)

The CEMP for the project (or any stage of the project) shall be approved by the Director-General prior to the commencement of any construction work associated with the project (or stage as relevant). Construction works shall not commence until written approval has been received from the Director General.

The CEMP shall be certified by the EMR as being in accordance with the Conditions of Approval and all undertakings made in the EIS and Representations Report prior to seeking approval of the Director-General.




Figure 1.1: CEMP preparation, review and approval process

Reference Documents:

Conditions of Approval/ Concurrence

Alliance Scope of Works & Technical Criteria

EIS/Reps Report RTA Specifications

HEA prepares CEMP and required sub plans

Consultants assist in sub plan preparation

Consultation with Stakeholders including Agency Representatives+

Agency and/or stakeholder comments

provided to HEA Alliance

HEA considers all comments in CEMP & sub plan finalisation

RTA endorsement and issue to EMR

RTA issues CEMP to DoP.

DoP reviews and provides comment as necessary

HEA amends CEMP if necessary

DoP Approval

EMR Certification

+Agency Representatives include:

DECCW

I&I NSW

Cessnock City Council

Lake Macquarie City Council

Maitland Council




1.1 DESCRIPTION AND LOCATION OF THE PROJECT

The Hunter Expressway Project involves the construction of a 39 km, access controlled dual carriageway highway to link the F3 Freeway near Seahampton to the New England Highway west of Branxton. The project is being constructed in two components, the first component involves the construction of approximately 13 km of road between the F3 and the Kurri Kurri Interchange as depicted in Figure 1.2. This section of the Hunter Expressway is being constructed by the Hunter Expressway Alliance and it is this section that is the subject of this Plan.

Construction activities included in the delivery of the 13km section of new road include:

- implementation of environmental and safety controls,

- construction of site compounds, batching plants and storage areas,

- clearing and topsoil stripping activities,

- earthworks,

- drainage works,

- bridgeworks and culvert construction,

- paving activities which also include saw-cutting activities to prevent concrete cracking,

- construction of major interchanges at Buchanan and the existing F3 Newcastle Interchange, as well as,

- landscaping and vegetation rehabilitation activities.

The second component of approximately 28 km extends from the Kurri Kurri Interchange through to Branxton and will be constructed separately under a design and construction contract. Table 1.1 outlines some of the key design features of the Alliance section of the project.

Table 1.1: Alliance section design features

Length Approximately 13 km - starting at the F3 turn-off to Newcastle near Seahampton through to a location immediately west of the proposed Kurri Kurri Interchange

Local govt area Cessnock Council

Lake Macquarie Council

Maitland Council

Road specifications

Dual carriageway highway

Four x 3.5 m lanes with inner and outer shoulders

110 km/h design speed for the horizontal alignment

100 km/h design speed for the vertical alignment.




Cut and fill Cut material taken: 1 837 235 m3 (final volumes to be determined by detailed design).

Fill material required: 1 576 690 m3 (final volumes to be determined by detailed design).

Other features

Landscaping along the full project length

Vegetated median

Grassed swales/channels to control run-off

Diversion channels, contour drains to control erosion

Sediment traps, filters, basins, retention ponds to control sediment and nutrients in discharges

Fauna crossings/fish-friendly culverts

Concrete batch plant/ compound sites.

Timeframe The project is expected to take up to 2.5 years from when substantial construction works start.




Figure 1.2: Location and alignment of the project




1.2 ENVIRONMENTAL ISSUES

Some of the specific environmental issues relevant to the Alliance are as follows:

Reducing the amount of clearing required within the project alignment where possible, particularly within EECs and other sensitive environments and thus adhering to Project clearing restrictions.

Potential soil and water impacts of construction on aquatic flora and fauna, threatened species and endangered ecological communities (EEC)

Protection of Aboriginal artefacts/sites before construction and consultation with the relevant Aboriginal Land Councils before and during construction.

Translocation of threatened flora within the project alignment before construction.

Extensive rehabilitation & landscaping of the project corridor.

Management of European heritage items occurring along the route.

1.3 BACKGROUND – ENVIRONMENTAL PLANNING PROCESS

The Hunter Expressway project (originally called the “F3 to Branxton link”) was an activity that was assessed and determined under Part 5 of the Environmental Planning and Assessment Act 1979 (the EP&A Act). It is within the Cessnock, Lake Macquarie, Maitland and Singleton local government areas.

In June 1995, Connell Wagner (1995) finalised the environmental impact statement (the EIS) for the RTA. Following introduction of the Threatened Species Conservation Act 1995 (TSC Act) and consideration of impacts on threatened fauna, Connell Wagner (2001) finalised a fauna impact statement in January 1997 (the FIS). The RTA commissioned additional studies, including two reviews of environmental factors on detailed route selection between Allandale and Greta in 1998 and 2000.

The Director-General of the then National Parks and Wildlife Service granted concurrence subject to 15 conditions on 3 October 2001. The then Minister for Urban Affairs and Planning approved the F3 to Branxton link on 7 November 2001, subject to 129 conditions.

On 1 August 2005, the Minister’s approval became a project approval under Part 3A of the EP&A Act.

At the request of the RTA, the Minister modified the approval on 31 July 2006 to permit staged construction (but not opening). The approval was modified again on 31 August 2007 to allow various design changes and to increase the clearing limit and again on the 28 June 2010 to better consolidate the conditions. This is the Approved Project. This CEMP includes information based on the expected modification requested by the RTA pending approval by the Minister of Planning.

The planning process is summarised in Figure 1.3.




Figure 1.3: Summary of the Hunter Expressway environmental planning process

1995: F3 to Branxton Link (Hunter Expressway) EIS prepared

1997: Fauna Impact Statement

2001 (October): NPWS Concurrence

2001 (November): DoP Approval

2006, 2007 & 2010: Modifications issued

1998 & 2000: REFs for works between Allandale and Greta




1.4 HUNTER EXPRESSWAY ALLIANCE ENVIRONMENTAL CONTEXT

Particular constraints within the study area have influenced the location of the route. These include topography, rural development and the results of geological and flora and fauna investigations. Construction is scheduled to begin in August 2010.

The study area occurs within the Sydney Basin Biogeographic Region and passes through numerous vegetation communities and sensitive waterway environments. In particular:

Eastern section F3 Interchange to Buchanan Rest Areas

The eastern section ties into the existing F3 motorway just west of Newcastle with a grade separated interchange. The vegetation community at this location comprises Coastal Plains Smooth-barked Apple Woodland, before changing to Coastal Foothills Spotted Gum – Ironbark Forest as the alignment moves westward. Minmi Creek, Bluegum Creek and Surveyors Creek respectively are crossed by the route as the alignment moves west.

Three viaducts ranging from 27m to 36m in height shall be constructed within the Mount Sugarloaf ranges and will span Coastal Foothills Spotted Gum – Ironbark Forest and Alluvial Tall Moist Forest. Minimisation of vegetation impacts associated with viaduct construction shall be a heavy focus in this area of the HEA Project. Mine voids located within the area shall be filled as part of the proposed project, which adds additional challenges to minimising vegetation impacts.

From the third viaduct (Bluegum Creek) the alignment travels west through Alluvial Tall Moist Forest, Coastal Plains Smooth-barked Apple Woodland, Coastal Foothills Spotted Gum – Ironbark Forest, Lower Hunter Spotted Gum – Ironbark Forest (EEC)

Western section Buchanan Rest Areas to Kurri Kurri

The Expressway moves from the Sugarloaf ranges to a more gentle topography and open vegetated communities (including Lower Hunter Spotted Gum – Ironbark Forest EEC and Kurri Sand Swamp Woodland EECs) in the western section of the Project.

Surveyors Creek crosses the alignment east of the Buchanan Rest areas, as well both east and west of the Buchanan Interchange. Wallis Creek lies to the west of Buchanan Interchange

Threatened species including Acacia bynoeana, Grevillia parviflora sub species parviflora, Eucalyptus parramattensis subspecies decadens occur within the Kurri Sands Swamp Woodland at the western end of the alignment.

Refer to Environmentally Sensitive Area maps in Appendix B for further details.

1.5 CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN STRUCTURE

The CEMP has been developed to be consistent with the elements of AS/NZS ISO 14001, as well as comply with the general requirements and objectives stipulated within the Guideline for the Preparation of Environmental Management Plans (DIPNR, 2004), and RTA Environmental Management System Specification G36. The CEMP is the lead document that provides the environmental management framework for controlling and reporting on the environmental aspects and impacts associated with the project. It has been prepared in compliance with the Thiess Pty Ltd Environmental Management System which is an EMS prepared in accordance




with the AS/NZS ISO 14000 series and is certified.

Whilst the CEMP draws from all Alliance partners Environmental Management Systems, it will be managed in accordance with specific project objectives and targets over the life of the project. Table 1.2 outlines the structure of the CEMP consistent with RTA Environmental Management System Specification G36.

Table 1.2: CEMP structure

Section Description Relevant G36 Clause

Volume 1

1: Introduction Provides a broad summary of the project.

Outlines CEMP structure.

Describes why the CEMP has been developed

Describes the CEMP’s purpose and objectives.

Refer to the environmental policy which is contained within Appendix A.

Clause 1

Clause 2

Clause 3

2: Planning

Describes the project’s legislative and policy requirements.

Identifies the project’s environmental aspects, impacts and risks

Includes the project’s environmental obligations

Clause 3.2

Clause 3.6

3: Implementation and Operation

Outlines how environmental training needs will be identified and summarises the training methods to be used throughout the project.

Describes the key environmental control measures and procedures.

Describes environmental communication procedures and protocols the project will apply.

Provides emergency and incident management procedures to be put in place during the construction phase of the project.

Clauses 3.3, 3.4, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 4.10, 4.11, 4.12

4: Compliance

Describes environmental auditing protocols, including legislative and CEMP compliance auditing.

Describes inspection and surveillance requirements

Outlines potential environmental impacts to monitor, including air, water and noise pollution.

Clauses 3.7, 3.10, 4.1, 4.13

5: Review and Improvement of the CEMP

Describes how the project team will periodically review the CEMP and practices to ensure suitability, adequacy and effectiveness of environmental management strategies.

Clauses 3.10, 4.1, 3.5 and 4.9, 4.11, 4.13

Appendix A: Environment Policy

Appendix B: Environmental Sensitive Area Maps

Appendix C: Regulatory Requirements, Policies, Guidelines and Standards

Appendix D: Environmental Risk Register

Appendix E: Emergency Procedure and Contacts




Section Description Relevant G36 Clause

Appendix F: Example Forms

Appendix G: Refuelling Protocol

Appendix H: Construction Method Statements Matrix

Appendix I: Ancillary Activities/ Facilities

Appendix J: Audit Schedule

Appendix K: Summary of Conditions of Approval relating to the CEMP

Volume 2: Environmental Management Sub Plans

The CEMP consists of this main CEMP document plus a series of management sub plans.

The management sub plans document the aspects, impacts, safeguards and monitoring requirements for each specific environmental element, and also nominate who is responsible for implementing those controls and the frequency/timing of implementation. The sub plans apply throughout the duration of the construction phase of the project.

Management sub plans prepared as part of the CEMP follow the prescriptive content requirements of the CoA. The following sub plans are included in Volume 2 of the CEMP and the legal and other requirements they address are outlined in Appendix C:

Construction Noise & Vibration Sub Plan (incl. Blast Management Strategy)

Flora and Fauna Management Sub Plan

Soil & Water Management Sub Plan

Indigenous Heritage Management Sub Plan

Historical Heritage Management Sub Plan

Construction Air Quality Management Plan

Hazard & Risk Management Plan

Spoil Management Sub Plan

Waste Management & Re-Use Sub Plan

Utility Services Sub Plan

Each sub plan, except the Noise and Vibration Management Sub Plan generally consists of the headings outlined in Table 1.3. The structure of environmental documents is outlined in Figure 1.4.

Note: The preparation of the Indigenous Heritage Management Sub Plan is not specifically required under the CoA however a commitment is made in the Aboriginal Cultural Heritage Plan of Management (CoA 110) that it will be prepared and in consultation with DECCW and the Aboriginal Groups. It also requires certification by the EMR. In addition, the Historical Heritage Management Sub Plan is not required by the CoAs, however for consistency a sub plan has been prepared and included as part of this CEMP.




Table 1.3: Sub Plan Contents

Management sub plan contents Description

Introduction

Background information on the environmental aspect requiring management and its potential impacts on the environment.

The target or strategy to achieve through management during the construction phase of the project.

Legislative requirements and guidelines Reference to more detailed legislative requirements and guidelines, if applicable, to the environmental aspect and its potential impact.

Performance criteria Criteria against which the implementation of the actions and the level of achievement of the environmental objectives will be measured.

Potential impacts Potential adverse environmental impacts identified for the construction phase of the project, including those identified in the EIS and associated documents.

Management measures and mitigation strategies

The actions necessary to achieve the environmental objective, including any necessary approvals, applications and consultation.

Monitoring and reporting Process of measuring actual performance.

Corrective action Actions to take in the event of an incident or in the case of non-compliance.

The sub plans provided within Volume 2 of the CEMP will be used to develop Work Method Statements which will in turn provide direction for Job Safety Environmental Analyses and Environmental Construction Method Statements (ECMS).

Work Method Statements (WMS) provide the structure for documenting major areas of the work including risk and quality and align design and constructability early in the process. The WMS draws together or references other related documentation (including JSEAs and ECMS) to demonstrate to all stakeholders that all relevant issues have been considered in planning the works.

Job Safety Environmental Analyses (JSEA) will be prepared that will detail the specific safety and environmental risks and controls for each work area or specific construction activity for the Project.

Environmental Construction Method Statements (ECMS) are developed to show the environmental controls that will be in use on the site at any given time ECMSs shall be prepared for activities that present a higher environmental risk. This is further discussed in the methodology outlined in Section 3.7.4.




Figure 1.4: Environmental document structure

Environmental Management Sub Plans

Flora and Fauna Management Sub Plan


Waste and Re-use Management Sub Plan

Soil and Water Management Sub Plan



Environment Construction Method Statements

Construction Noise & Vibration Management

Sub Plan

Construction Air Quality Management

Plan

Hazard and Risk Management Sub Plan

Construction Environmental Management Plan





The CoA prescribe which regulatory authorities and other stakeholders are to be consulted in the preparation of each component of the CEMP. These requirements are summarised in Table 1.4:

Table 1.4: Consultation requirements for the CEMP and sub plans

Regulatory authority Plan/procedure

Department of Planning

CEMP

Flora & Fauna Sub Plan

Construction Noise & Vibration Sub Plan (incl. Blast Management Strategy)

Soil & Water Sub Plan



Construction Air Quality Management Sub Plan

Operational Noise Management Sub Plan

Hazard & Risk Management Sub Plan

Landscape Management Sub Plan




Environmental Protection Authority

(part of DECCW)

CEMP


Construction Noise & Vibration Sub Plan (incl. Blast

Management Strategy)




Construction Air Quality Management Sub Plan

Operational Noise Management Sub Plan

Hazard & Risk Management Sub Plan




Regulatory authority Plan/procedure

Landscape Management Sub Plan




Parks and Wildlife (Ex NPWS now part of DECCW)

CEMP


Mindaribba Local Aboriginal Land Council

Awabakal Local Aboriginal Land Council

Wonnarua Nation Aboriginal Corporation

Lower Wonnarua Tribal Consultancy Pty Ltd

Barkuma Neighbourhood Centre

Black Creek Aboriginal Corporation


Note: The preparation of the Indigenous Heritage Management Sub Plan is not specifically required under the CoA however a commitment is made in the Aboriginal Cultural Heritage Plan of Management (CoA 110) that it will be prepared and in consultation with DECCW and the Aboriginal Groups. It also requires certification by the EMR.

Industry and Investment NSW CEMP


NSW Office of Water

CEMP


Utility / Service Providers CEMP


Cessnock Council

Lake Macquarie City Maitland Council

Maitland Council

CEMP


Landscape Sub Plan


Community Liaison Group Landscape Sub Plan

Affected Land Owners Landscape Sub Plan

A copy of the draft CEMP and Management Sub Plans will be provided to relevant agencies and stakeholders for review and comment in accordance with Table 1.4.

Taking into account comments made during the review period, the Environmental Management




Representative (EMR) will review, and then certify the CEMP before the RTA submits the CEMP to DoP for approval. HEA will also prepare a table summarising the comments received on the draft CEMP and how they were addressed.

HEA will then provide a copy of the CEMP in accordance with the distribution list at the front of this CEMP (Refer to Construction Environmental Management Plan Document Control section at the front of the document).

1.6 PURPOSE AND SCOPE OF THE CEMP

The CEMP provides an easily interpreted reference document that ensures project environmental commitments, safeguards and mitigation measures from the following sources are being implemented, monitored, audited, and improved:

environmental planning documents

approvals

Project Scope of Works and Technical Criteria (SWTC).

The CEMP also documents the hazard and risk identification and management process for the construction techniques the Hunter Expressway Alliance will use, and the systematic process of implementing controls to minimise the impacts of the Hunter Expressway Alliance construction methods on the environment.

The CEMP’s requirements may need to be amended or varied during the course of project design, construction and operation. The need for modifications may occur as specific circumstances vary from those envisaged during the formulation of the environmental assessment for this project. The Hunter Expressway Alliance will consult with the EMR and relevant government agencies to certify that any amendments are consistent with the CoAs.

1.7 OBJECTIVES AND TARGETS OF THE CEMP

The key performance objective HEA has set is to ensure compliance with all environmental legislation, including minimising pollution and waste generation and minimising environmental impacts.

The CEMP’s additional aims include:

Facilitate the implementation of environmental best practice throughout the design, construction and post completion operations of HEA.

Adhere to Thiess, Parsons Brinkerhoff, Hyder and RTA policies and procedures.

Identify significant environmental risks associated with the design, construction and operation.

Provide procedures to manage environment risk in a consistent and practical manner (e.g. construction method statements).

Outline HEA’s environmental communication procedures (internally and with external stakeholders).

Demonstrate due diligence.

Continually improve environmental performance through review, monitoring, auditing and reporting on environmental outcomes.




HEA will also adopt the objectives and targets given in Table 1.5.

Table 1.5: Objectives and targets

No Objective Target

1 To employ best environmental management practices (BEMP) to minimise noise impacts.

Maintain noise levels within project goals.

2 To minimise the impacts of vibration from construction activities.

Maintain vibration levels within human comfort and structural damage criteria.

3 To apply BEMP to soil and water quality management

Meet DECCW water quality discharge criteria for all design storm events.

4 To minimise air pollution from construction and associated activities

Meet the Depositional Dust Goals of max 4 g/m2 per month.

5 To protect heritage items that HEA may affect No damage to known relics or heritage items uncovered during excavation

Identify and protect heritage sites in consultation with the key stakeholders including Local Councils, Local Aboriginal Land Councils, other Aboriginal Groups and DECCW.

7 To minimise impacts to the environment caused by the management of contaminated soil

Manage contaminated soil in accordance with Environmental Legislation, RTA and DECCW guidelines.

8 To protect vegetation and fauna within the construction zone

Maintain demarcation of the construction buffer zone boundary. No long-term impacts on trees, plants and other vegetation outside the construction zone No harm to fauna Minimise the removal of vegetation and related disturbance to threatened species and endangered ecological communities from construction activities.

9 To avoid pollution of the environment caused by fuels, oils or chemicals stored or used on HEA

No major spills of fuel, oil or chemicals.

10 To minimise waste resulting from construction. Maximise recycling.

1.8 ADDITIONAL ENVIRONMENTAL INCENTIVES

In addition to HEA objectives and targets to reduce environmental impact associated with the delivery of the Hunter Expressway, financial incentives have been set by the RTA with regards to specific environmental aspects. Such incentives are known as Key Result Areas and Modifiers, and include for example; clearing reductions and the installation of cross drainage structures prior to topsoil stripping. Performance against these Key Result Areas and Modifiers shall be tracked monthly by HEA Environment Manager and submitted to the HEA Alliance Leadership Team (ALT). The ALT award points (or deduct points) dependent on environmental outcome.




1.9 ENVIRONMENTAL POLICY

HEA will seek to ensure that the environmental policy, including references to procedures and construction methods is understood, implemented and maintained by personnel throughout the duration of the HEA project. The environmental policy is provided in Appendix A.




2 PLANNING

2.1 LEGAL OBLIGATIONS

There are a number of legal requirements, policies, guidelines and standards relevant to the Hunter Expressway outlined in the subsequent sub plans and Appendix C. Changes may occur to some existing legislation before the Hunter Expressway is complete. If this occurs, it will be necessary to review and amend the CEMP as appropriate. Licences, permits and approvals received for this project will also be kept onsite as they are received.

2.2 PROJECT ENVIRONMENTAL OBLIGATIONS

The environmental planning documents and conditions of approval identify a comprehensive range of requirements designed to safeguard the environment and community.

2.3 COMPLIANCE STANDARDS AND GUIDELINES

Relevant compliance standards, policies and guidelines are detailed in the sub plans and Appendix C.

The requirements of these standards were taken into account in preparing the CEMP and will be considered during the preparation of Environmental Construction Method Statements.

2.4 ENVIRONMENTAL ASPECTS, IMPACTS AND RISKS

The identification of the significant environmental aspects and impacts that could eventuate while constructing the Hunter Expressway is central to the selection of appropriate environmental safeguards.

The environmental aspects are those operations that may result in an environmental impact. The relationship of aspects and impacts is one of cause and effect. The process of identifying impacts is one of progressively breaking down each activity into its environmental aspects.

HEA will identify aspects and impacts for all construction activities that:

could cause the discharge or release of pollutants to the water, air, or land

impact on flora, fauna or heritage

could degrade, alter, and create change to the existing environment

generate wastes.

Each sub plan will identify aspects and impacts relevant to each element of the Hunter Expressway.

Environmental risks associated with the Project shall be identified using the Risk Assessment Process outlined below. All environmental risks currently identified for the project have been outlined in Appendix D of Volume 1 of the CEMP. Appendix D shall be updated if future risks are identified.

The following tables outline the risk assessment process using three steps to identify the




appropriate management measures required.

Table 2.1 is used to determine the likelihood that the aspect will have an impact on the environment.

Table 2.2 is used to determine the potential consequence rating of the risk identified

From these two tables, a risk rating can then be assigned by using Figure 2.1 to determine how severe the potential impact will be.

Table 2.3 can then be used to assess what level of management each type of risk will require.

Where a significant risk to the environment has been identified, environmental protection measures to reduce the risk to an acceptable level shall be implemented. Aspects with a medium or low risk shall also have practicable management measures implemented if these can further reduce risk.

Table 2.1: Likelihood criteria

Occurrence (likelihood) Description

A Rare/improbable The event may only occur in exceptional circumstances.

B Unlikely/remote The event may occur at some time (about once every five years).

C Possible The event is likely to occur at some time (about once every year).

D Likely The event will probably occur in most circumstances (at least once every six months).

E Almost certain The event is expected to occur in most circumstances (at least once every month).

Table 2.2: Consequence criteria

Consequence (impact) Description

1 Insignificant/negligible Short-term disturbance with minor environmental release or damage that is non-reportable.

No impact outside site boundary.

No community complaints or media reports.

2 Minor/low Minor violation of regulation or guideline with minimal damage to the environment and small clean-up.

Immediately contained on site.

Local government action, minor community complaints.

Potential or actual breach of legislation.

3 Moderate Violation of regulation or guideline with moderate damage to the environment and significant clean-up costs.

Release of pollution off site.

Detrimental media reports, community concerns and complaints.




Consequence (impact) Description

4 Major Significant environmental damage – potentially permanent.

Release of pollution off site. Significant loss of environmental resources.

Detrimental media reports in the national or state media, organised community concern.

High likelihood of EPA fine or court action.

5 Catastrophic Long-term environmental harm.

Permanent irreparable damage to the environment.

Sustained detrimental state and national media reports. Sustained community outrage.

Penalty Infringement Notice/court action.

A B C D E Risk Severity

1 Priority

2 High

3 Moderate

4 Low

5

Co

nseq

uen

ce

Likelihood

Figure 2.1: Risk rating

Table 2.3: Risk severity

Risk severity Management required

Priority Immediate management action required.

High Priority management action warranted.

Moderate Management action warranted.

Low Management action should be considered, particularly for low-level impacts that nevertheless occur on a continual basis.




The Environment Manager in consultation with the person(s) responsible for the activity will determine how the risks can be successfully remedied to ensure sound environmental management.

This may include updating the CEMP or associated documents (e.g. Daily Hazard Pre-start Risk Assessments or Job Safety and Environmental Assessments) to cover any further identified management measures and mitigation strategies.

Environmental risks associated with the Project shall be monitored and tracked through the Thiess CURA risk management program. This program includes all risks identified for the project, management processes to reduce or eliminate the risk and identified staff responsible for each risk.

2.5 SENSITIVE AREAS

To help identify potential environmental risks, Sensitive Area Plans have been prepared to highlight the following elements to construction personnel:

river and creek crossings

Indigenous and non-Indigenous heritage sites

proximity to neighbouring properties

flora and fauna – including threatened species, ecological communities, riparian areas,

These figures are included as Appendix B in this CEMP and will be updated throughout the project as necessary. They will be provided to all relevant staff, including the Superintendent and Site Engineers and available through the online document management system Incite Keystone.

2.6 PLANNING FOR ANCILLARY CONSTRUCTION FACILITIES

Any ancillary construction facilities e.g. batch plants and construction compounds required for the project, must satisfy the following criteria (as stated in MCoA 129), unless otherwise approved by the Director-General:

a) be located more than 100 metres from a waterway

b) have ready access to the road network;

c) do not cause exceedance of the maximum native vegetation clearing limit specified under condition 60 of the approval;

d) be located on relatively level land;

e) be separated from the nearest residences by at least 200 metres (or at least 250 metres for a temporary batching plant and stockpiling sites);

f) be above the 20 ARI flood level unless a contingency plan to manage flooding is prepared and implemented;

g) shall not unreasonably affect the land use of adjacent properties;

h) provide sufficient area for the storage of raw materials to minimise, to the greatest extent practical, the number of deliveries required outside standard construction hours; and

i) shall not impact on heritage sites beyond those already impacted by the project.




Each site chosen for the ancillary construction facilities will be checked against the criteria outlined in MCoA 129 prior to the recommendation of any particular site. This may take the form of a brief compliance report, impact assessment or checklist which will detail how ancillary facilities comply with MCoA 129. The assessment documentation will exist separately to the CEMP, however any mitigation measures or associated actions relevant to using a particular facility shall be incorporated into the CEMP as appropriate.

If location(s) of ancillary construction facilities, including site compound and batch plant(s), are to be sited in areas which do not satisfy the above criteria then an appropriate level of environmental impact assessment will be undertaken before construction of facilities can start in that location.1

All new construction activities not previously assessed under the project approval will be assessed to determine consistency with the project approval. The EMR will certify any minor amendments required to the CEMP and Sub Plans provided the new activities are consistent. It is the responsibility of the Director-General to assess and approve new activities that are not consistent with the approval.

If additional work activities are to be undertaken other than those stipulated in the CEMP, an environmental risk assessment of the potential impacts of the activity will be undertaken prior to commencing the new activity.

It is the responsibility of the Environment Manager in consultation with the person(s) responsible for requesting the additional work activities to undertake the risk assessment.

The risk methodology identified in Section 2.4 will be used to carry out the risk assessment.

Initial ancillary sites have been identified as potential compound, storage and batching sites for HEA, as detailed in Appendix I.

1 Note NPWS CoC 4 states:

Without further environmental assessment, no clearing for ancillary infrastructure or associated works including permanent or temporary detention or sediment control basins; materials stores; access roads; utility corridors; works areas, depots or any other activity or development (as defined by the Environmental Planning and Assessment Act 1979) shall be carried out, or be allowed to be carried out, within areas shown as habitat for endangered ecological communities or threatened species in any of the documents (see section 2 of this Concurrence Report) received by the NPWS in assessing the concurrence proposal.




3 IMPLEMENTATION AND OPERATION

3.1 CONSTRUCTION SCHEDULE

The construction works are expected to last approximately 30 months, with a start date scheduled for August 2010. Table 3.1 describes work activities, work areas and expected work duration for each work package, based on the current design.




Table 3.1: Construction schedule




Alliance Administrator

Vicki Sedgwick

Alliance Project Manager

Peter Chatburn

ALLIANCE LEADERSHIP TEAM

Brendan Donohue, Geoff Fogarty, Bob HandleyDavid Stuart-Watt, Geoff Murrant, Greg Steele

Bold

Ray Dallon

Independent Verification

Peter AlfordPB / Hyder

Design Coordination Manager

Garry Ewen

Design Coordination Assistant

Toni McPherson

Bold

Kristy Fairburn

HR Advisor

Alison Fietz

L&D Coordinator

Vacant

HR Officer

Vacant

HR Graduate

Vacant

Bold

Robert Thompson

Safety Coordinator

Vacant

Project Dev Manager

James Naylor / Greg Fell

Stakeholder & Community Manager

Louise Neville

Community Consultation Team

Environmental Manager

Howard Chemney / Tracy Doczy

Environmental Approvals Manager

Neville Moran

Soil Conservation

Michael Frankcombe

TOC Manager

Adrian Levido

Estimators

Tony CalingoJohn BendelGerry Vassi

Ben DumazelMichael Hall

Estimating Engineers

Scott TyrrellMarcin Zwolanski

Commercial Manager

Greg Ovens /Shane O’Leary

Finance & Admin

Contracts & Procurement

Admin Support

Quality & Systems Manager

Siri Siritharan

Senior Project / QA Engineer

Miranda Kossen

Constructability Manager

Todd Myers

Surveyor

Rob McPhan

F3 Bridges incl. E/works to Minmi Cr

Vacant

Buchanan & Other Bridges

name

Structures Engineers

Theepan ChelvarajanGraham Nuss

Traffic Manager P/T

Matt Perkins

Bold

Aidan McCann

Site Establishment Manager

Site establishment Engineers

Damon McLean

Highways & Drainage Engineer

Vacant

Materials Movement

Cameron McConville

Mine Voids

Mikael Whalberg

Earthworks

Vacant

Planners & Programmers

Sean Carroll

Quality Manager Construction

TBA

Senior Product Improvement Officers

Vacant

Structural Design Manager

Iain Hespe

Durability Design Leader

Vacant

Proof/Engineering

PB/Hyder

Viaduct Zone Design Team Leader

Irene Scott

Interchange Zone Design Team Leader

Bob Taylor

Structural Designers

Paul HarberClaudio Grandi

Annie ZagninskiHari PokharelKashif Khan

Structural CADD Team Leader

Stephen Coyle

Structural Drafters

Kristen BoltonHui Tan

Mark AssafMark Schwarze

Kevin DoanGus Viswasm

Michael HackettRussell Hampson

Rony SafarianDavid Gollan

Ancillary Design Manager

Kevin Radford

CADD Coordinator

John Benstead (p/t)

GIS Analyst

Dan Bowles

ITS, Power & Communications

Daniel Roesner

Utilities

Stephen McDonald

Urban & Landscape Design Team Leader

Susanne Fraedrich

Lead Urban Designer

HBO+EMTBJamie Kemp

Lead Landscape Designer

HBO+EMTBDarren Mansfield

Landscape Rehabilitation

Manager

Vacant

Noise Team Leader

Steve Walker

Lead Modeller

Dave Davies

Highways Design Manager

Elaine Gazzini

Zone Managers Buchanan Int.

David Pendlebury

Main Alignment

Peter Rees

F3 Interchange

Mark Kelleher

MX Team Leader

Steve Ellis

MX Designers

Martin HeneghanAndy FrithTara Dias

Jarrod TaylorJarrad BromleyAlan Dulnuan

Ranjith Weeraratne

Hydrology & Drainage TL

Terry Swanson

Senior Water & Drainage Engineer

Loretta Bray

Water & Drainage Engineers

Alexandra BennettMark HausfeldPeter Edwards

Hydrology

Colm MageeStephen Home

Ed Bond

Traffic Design TL

Terry Swanson

Senior Traffic Engineer

Sam Black

Traffic Engineers

Jacky LeungChris Chun

Lighting

Venera Betova

CADD Team Leader

Victor Peralta

CADD Advisor

David Arnold

Civil Drafters

Craig DunninghamSue Tyler

Chris YatesAdam Crow

Christine EvansFranz Bathan

Geotechnical Design Manager

Rob Kingsland

Geotechnical Design Team Leader

Kaiyu Lin

Yuffrey Huang (p/t)Glen BurtonBrian Choi

Keiran WrightMark Ransom (p/t)Pablo Balmaceda

Henry ZhangJames Pan

Mine Subsidence Team Leader

Bob Butcher

Yuffrey Huang (p/t)

Cuttings & Materials Management TL

Vacant

Sudar AryalDavid Och (p/t)

Site Investigations Team Leader

Nitin Wazir

Jonothan HaleMark Ransom (p/t)Mahendra ParmarStamatis Loizides

Alena StewartClaudina Ngyuen

Pavements

Pablo Balmaceda

Expert Panel

Jim GalvinPatrick Macgregor

Phillip PellsArthur Love

Design Manager

Bruce Sweet

Project Services

Emma Makey

Viaducts

Axel Armstrong

3.2 SITE STRUCTURE

HEA’s organisational structure, including site personnel, is shown in Figure 3.1.

Figure 3.1: HEA Organisational Chart



HEA-PL-EMP-001-00-04 Page 33

3.3 ENVIRONMENTAL MANAGEMENT TEAM

The responsibility and authority pertaining to environmental performance of key HEA personnel, environmental specialists and subcontractors is described below. In addition the management sub plans outline specific responsibilities. These responsibilities are categorised in relation to relevant positions and will be issued as part of the site induction.

3.3.1 Project Director

HEA’s Project Alliance Director is principally responsible for delivery of the design and construction phase of Hunter Expressway (Alliance Section) to ensure impacts are minimised and obligations met. An Environment Manager reporting directly to the HEA Project Director is responsible to ensure HEA delivers prescribed environmental outcomes through various design and construction divisions. The HEA Project Director shall:

Ensure adequate resources are made available for effective environmental management.

Ensure effective overall management of environmental performance during construction.

Ensure compliance with all COURs by delegating responsibilities for compliance management to various section heads within HEA.

Incorporate environmental management aspects in project planning, including environment as a standing agenda at weekly management meetings.

Ensure all complaints are resolved satisfactorily.

Proactive management of community and environmental issues and effective liaison with affected external groups.

Stop work activities that have (or are likely to) lead to an unacceptable level of environment risk.

Ensure site management teams comply with applicable obligations by working in accordance with Community and Environmental Management Plans and procedures.

Notify HEA leadership team of significant community and environment issues.

Make available resources and contractor relationships for the EM to perform their function(s)

Provide leadership and drive the performance of site management personnel in the areas of:

o Project recruitment and selection to ensure the right team is in place to achieve project area objectives.

o Performance management to ensure project area team members clearly understand their roles, receive feedback on their performance and are held accountable.

o Learning and development of team members to ensure the project retains and develops the right people to support project performance.

o Recognition and reward of project area team members to ensure individual and team performance is recognised.




o Site employee relations to ensure cooperative relationships with the workforce and unions are established and maintained by identifying issues and needs and resolving effectively.

3.3.2 Project Environment Manager

The Environment Manager reports directly to the Project Director. The Environment Manager has primary responsibility for managing all aspects of environmental management and compliance for HEA’s design and construction phase. The Environment Manager will be qualified with at least five years of environmental-related experience and hold minimum bachelor level environmental education. The key responsibilities of the Environment Manager are to:

Prepare the CEMP

Consult with regulatory requirements regarding environmental design issues

Implement the project environmental management system (including compliance tracking system)

Maintain, assess and monitor the CEMP

Ensure all project environmental obligations are met and prepare reports on compliance

Obtain relevant licences, permits and approvals

Complete environmental checklists

Participate in monthly inspections carried out by Regulatory Agencies.

Provide input and advice to engineers on construction method statements

Identify, prepare, and ensure environmental induction and training materials are provided

Liaise with government agencies and relevant stakeholders

Manage the environmental budget

Respond to environmental incidents

Coordinate environmental consultants

Maintain environmental documents

Conduct system environmental audits

Identify and stop work activities that have (or are likely to) lead to an unacceptable level of environmental risk or may lead to a non-compliance with Conditions of Approval.

3.3.3 Project Environment Officer/Coordinator

Reports directly to the Project Environmental Manager and assists in all aspects of environmental management systems implementation, including the CEMP, sub plans and Progressive Erosion and Sediment Control Plans. The key responsibilities of the Environmental Coordinator are to:

Responsible for the implementation of the CEMP on a day-to-day basis.

Provide support to the project team in relation to environmental matters in the absence of the Environmental Manager.





Undertake and assist with site inspections, environmental monitoring and compliance tracking.

3.3.4 Environmental Management Representative

The EMR’s principal role is to provide an independent check on the implementation of the Minister’s conditions and to generally monitor environmental compliance. To achieve this, the EMR will periodically audit implementation of the CEMP and the day-to-day environmental management of the project. The EMR shall demonstrate compliance with AS/NZS ISO 14012:1996 Guidelines for Environmental Auditing : Qualification criteria for environmental auditors.

The EMR will have the authority to stop work immediately if an unacceptable impact is likely to occur, or to require reasonable steps to be taken to avoid or minimise any adverse impact. The EMR shall be available during construction activity at the site and be present on-site during any critical construction activities as defined in the Environmental Construction Method Statement Matrix. The EMR shall:

i) have responsibility for considering and advising on matters specified in the conditions of approval and compliance with such;

ii) review and approve induction and training program for all persons involved in the construction activities and monitor implementation;

iii) periodically audit the environmental activities to evaluate the implementation, effectiveness and level of compliance of on-site construction activities with the CEMP and associated plans and procedures, including carrying out site inspections at least fortnightly;

iv) record and provide a written report of non-conformances with the CEMP and require mitigation measures to avoid or minimise any adverse impacts on the environment or report required changes to the CEMP;

v) direct the contractor to stop work immediately where considered necessary, if in the view of the EMR an unacceptable impact on the environment is likely to occur, or require other reasonable steps to be taken to avoid or minimise any adverse impacts;

vi) review corrective and preventive actions to ensure the implementation of recommendations made from the audits and site inspections;

vii) report monthly;

viii) review and approve minor revisions to the CEMP and sub plans;

ix) provide information for community consultation, liaison with regulators, and respond to customer environmental complaints as required;

x) provide reports to DoP on matters relevant to the carrying out of the EMR role as necessary including notifying DoP of any stop work notices; and

xi) certify the CEMP, sub plans, and ECMS in accordance with the Minister’s Conditions of Approval Nos. 21, 24 and 30.

3.3.5 Community Relations Manager

For specific roles and responsibilities of the Community Relations Manager and the community




relations team refer to the Community Involvement Plan (CIP), however, a summary is outlined below.

Chair Community Meetings.

Forward reasonable requests from the community to HEA team for information on the project’s environmental performance.

Forward reasonable requests from the community to HEA consultant(s) for to explanation of technical information.

Engage with property owners to inform on construction timetable or activities and resolve matters as reasonably practical that are raised by any owner/complainant.

3.3.6 Section/Structures/Pavement Managers

Key responsibilities of Section Managers are to:

Ensure the environmental controls are established and maintained as per the CEMP.

Ensure environmental protection requirements are communicated and acted upon by all personnel and contractors under their control.

Ensure all requirements requested by the HEA Project Director and Project Environmental Manager are acted upon by all personnel and contractors under their control.

Ensure complaints escalated to them are rectified and prepare reports to the HEA Project Director as required.

Ensure the work designs are installed in accordance with the approved engineering drawings.

Monitor daily work routines, including subcontractor performance, so that environmental controls are established and maintained as per the CEMP.

Monitor daily work routines so that environmental protection requirements are communicated to all personnel and contractors under his/her control.

Perform verification of environmental measures as requested by the HEA Project Director/Environment Manager.

Undertake compliance tracking as delegated by HEA Project Director/ Environment Manager

Implement measures and rectify work to comply with environmental requirements.

3.3.7 Section/Structures/Pavement Engineers

Responsible for ensuring environmental considerations are integral to the decision making for all construction activities in close consultation with the Environmental Manager to ensure that the environmental controls and procedures contained in the CEMP are implemented. Specific activities include:

Ensuring work instructions reflect the requirements of this CEMP and sub plans.

Ensuring CEMP’s requirements are implemented.

Ensuring all required records/documentation are maintained and submitted to the Environment Manager.




Ensuring training/induction of personnel is carried out and that staff operate in an environmentally responsible manner.


Undertake and report on all monitoring and inspections completed.

Undertake compliance tracking as delegated by Section Managers.

Report all environmental incidents and near misses.

3.3.8 Project Field Construction Manager/Superintendent/ Foremen

Responsible for supervising all construction work and has a direct role in the compliance with identified environmental procedures and controls. The key responsibilities of the Field Construction Manager are to:

Ensure complaints are acted upon and consult with Senior Project Engineers to address issues raised.

Monitor daily work routines so that environmental controls are established and maintained as per the CEMP.

Monitor daily work routines so that environmental protection requirements are communicated to all personnel and contractors under his/her control.

Perform verification of environmental measures as requested by the Environment Manager/EMR/Environment Officer.

Implement measures and rectify work to comply with environmental requirements.

Ensure personnel are provided with appropriate environmental ‘toolbox’ training.


3.3.9 Contractors

The key responsibilities of Contractors include:

Ensure work instructions reflect the requirements of this CEMP and sub plans.

Ensure all requirements of the CEMP and Ministers CoA relevant to their work activities are implemented.

Ensure all required records/documentation are maintained and submitted to Environment Officer.

Ensure training/induction of personnel is carried out and staff operate in an environmentally responsible manner.

Undertake and report on all monitoring and inspections completed.

Undertake compliance tracking as delegated by Section or Environment Managers


3.3.10 All staff

The key responsibilities of all staff include:

Attend environmental site inductions and training relevant to their activities




Consult with Environment Staff prior to the commencement of all activities to ensure environmental and planning requirements are documented, conveyed to relevant staff and implemented.

Implement control measures identified in the CEMP


Get it right the first time.

3.4 ENVIRONMENTAL CONSULTANTS

HEA will commission environmental consultants (as required) to provide specialist input and advice on environmental matters, undertake surveys and inspections, implement monitoring programs or prepare environmental reports. Table 3.2 lists the specialists commissioned for the HEA.

Table 3.2: Environmental consultants

Acoustic Consultant Parsons Brinckerhoff

Ecologist Parsons Brinckerhoff

Seed Collector To be appointed

Heritage Consultant Umwelt Pty Ltd

Soil Conservationist TREES Pty Ltd

Landscape/Rehabilitation Specialist To be appointed

3.5 UTILITIES

HEA personnel, including Project Engineers and the Field Construction Manager/ Foremen, will discuss, agree and oversee work by utilities. Before work begins, the environmental and safety risks associated with the work will be identified and documented and if necessary discussed with the utility. The Ground Disturbance Permit System shall be implemented to prevent damage to utilities. This system requires all existing and newly install utilities to be shown on construction plans and provided to Foremen/site staff. The system also provides for specialists to locate utilities in the field prior to the commencement of construction activities. Ground Disturbance Permits shall also contain environmentally sensitive area information as relevant to the construction activities to be undertaken.

3.6 RESOURCES

The resources required to implement the control measures and obligations identified in the environmental documents are detailed in the respective management plans.

Resources will include:

general labour to install and maintain controls during construction activities and following storm/wet weather events

specialist input from consultants, including:

o development of design solutions consistent with environmental documents and agency requirements




o ecologist/botanist to identify significant flora and fauna, oversee translocation activities and advise on habitat restoration

o soil conservationist to inspect erosion and sediment controls and provide on-site advice on selecting and maintaining controls

o EMR to advise on MCoA and compliance issues.

heavy plant and equipment, such as bulldozers and excavators

hand tools

fencing and flagging tape to secure protected areas or trees

erosion and sediment equipment, including sand bags and sediment fences

emergency response equipment, including booms and absorbent materials.

The Project Director, Field Construction Manager and Environmental Manager will be responsible for ensuring sufficient resources are allocated to install, inspect, maintain and repair environmental controls, particularly after wet weather.

3.7 ENVIRONMENTAL CONTROL MEASURES AND PROCEDURES

3.7.1 General approach

A range of environmental commitments, obligations, undertakings and requirements (COURs), as well as, control measures have been identified in the environmental documents, including the EIS, SIS, Conditions of Approval/ Concurrence and RTA documents. These shall be tabled within the Project’s online compliance tracking system (Keystone/Incite).

Specific measures and procedures have been identified to address each of the obligations and included in relevant management plans. This process of matching actions with obligations and assigning responsibility for each action will ensure that each project obligation is implemented.

The timing of installation of control measures will be critical to ensuring that environmental obligations are met within the required timeframe and that controls are effective in achieving their purpose. For example, the installation of controls or crossings in a watercourse must consider seasonal weather patterns (flooding or scouring), fish migration times and general disturbance issues.

A program of routine maintenance will be carried out on environmental controls. Daily inspections of work areas by Project Engineers and Site Foreman and weekly (minimum) inspections by the Environment Staff will provide a means for identifying maintenance requirements before they reach a critical stage.

3.7.2 Work Method Statements

Work Method Statements (WMSs) provide the structure for documenting major areas of the work including risk and quality and align design and constructability early in the process. The WMS draws together or references other related documentation (including Work Procedures, JSEAs and ECMS) to demonstrate to all stakeholders that all relevant issues have been considered in planning the works.

3.7.3 Work Procedures




Work Procedures will be prepared for all activities to ensure sound construction practices are implemented and to minimise the risk of environmental and safety incidents, quality non-conformances or system failures.

The Section Managers, Construction Field Manager and the Environment Manager (or delegates) will develop Work Procedures to ensure suitability and adequacy of meeting specified contract and CEMP requirements. They are to include controls identified in the sub plans relevant to the activity considered. General environmental management controls or requirements, such as standard working hours and waste management principles, will be outlined in the environmental induction package and not necessary repeated in the Work Procedures unless sensitive environment exists nearby (e.g. nearby residents occur). The Work Procedures will take the form of a list of activities and relevant controls/actions and responsibilities.

The following work procedures that are likely to be developed include, but are not limited to:

pipe culverts

drainage structures

open drains

kerb and/or gutter

precast concrete box culverts

earthworks excavation

embankment and select

rock fill embankment

blasting

construction of verges

stabilisation of earthworks – in situ

rock fill gabions and mattresses

placing concrete in sub base

placing concrete in base

batter protection

fencing

excavation and backfill for bridges

concrete works for bridges

paving operations, application of curing and bitumen compounds to pavements, saw-cutting, equipment washout.

3.7.4 Environmental Construction Method Statements

Environmental Construction Method Statements shall be prepared as necessary to cover key activities during construction. ECMSs will be submitted to the EMR for certification prior to the commencement of any activities which are relevant to the ECMSs.

Condition of Approval 30 requires each CMS to include, but not be limited to:




i) construction activities and processes associated with the relevant construction site(s), including staging and timing of the proposed works;

ii) specific hours of operation for all key elements including off-site movements;

iii) cover specific environmental management objectives and strategies for the environmental system elements and include, but not be limited to: noise and vibration; air quality; water quality; erosion and sedimentation; access and traffic; property acquisition and/or adjustments; heritage and archaeology; flora and fauna, groundwater; acid sulfate soils, spoil stockpiling and disposal; waste/resource management; weed management; flooding and stormwater control; geotechnical issues; visual screening, landscaping and rehabilitation; safety, hazards and risks; energy use, resource use and recycling; and utilities; and

iv) address, but not be limited to:

a. identification of the statutory and other obligations which the Proponent is required to fulfil during project construction, including all approvals and consultations/agreements required from other authorities and stakeholders, and key legislation and policies which control the Proponent’s construction of the project;

b. measures to avoid and/or control the occurrence of environmental impacts;

c. measures (where practicable and cost effective) to provide positive environmental offsets to unavoidable environmental impacts;

d. definition of the role, responsibility, authority, accountability and reporting of personnel relevant to compliance with the CMS;

e. site specific environmental management techniques and processes for all construction processes which are important for the quality of the environment in respect of permanent and/or temporary works;

f. site specific monitoring, inspection and test plans for all activities and environmental qualities which are important to the environmental management of the project, including performance criteria, tests, and protocols (eg. frequency and location);

g. locational details of important elements such as temporary noise barriers; portable offices and amenities; truck, plant and materials storage; access locations; provision of site hoardings etc;

h. environmental management instructions for all complex environmental control processes which do not follow common practice or where the absence of such instructions could be potentially detrimental to the environment;

i. steps the Proponent intends to take to ensure that all Plans and Sub Plans are being complied with;

j. consultation requirements with relevant government agencies; and,

k. community consultation and notification strategy (including local community, businesses, relevant government agencies, and all relevant Councils), and complaint handling procedures.

Specific requirements of the main environmental system elements referred to in (iii) shall be as required under the conditions of this approval and/or as required under any licence or approval. All ECMS shall be made publicly available.

An Environmental Construction Method Statement Matrix is presented in Appendix H.

3.7.5 Subcontractor management




HEA recognises that subcontractors can present environmental risks to a project due to:

Their detachment from the main construction delivery teams, and therefore the potential for poor communication regarding environmental risks.

The large number of subcontractors on site.

HEA acknowledges responsibility to ensure that all people on the project, including subcontractors and their employees, comply with the relevant environmental requirements. As a minimum, subcontractors and their employees will be required to comply in full with the environmental requirements outlined in the CEMP and all relevant sub plans/ECMS. All subcontractors’ personnel are considered equivalent to HEA’s project personnel in all aspects of environmental management and control, and their responsibilities in this respect mirrors those of HEA’s personnel.

Prior to engagement sub-contractor’s environmental management knowledge, skills and systems shall be assessed. Sub-contractor engagement will be undertaken in accordance with the Procurement and Subcontract Management Plan (HEA-PL-GL-PRM-001) and Pre-award evaluation - Part D Environmental management (HEA-PL-GL-PRM-001-J-00). All sub-contractor work method statements and procedures must be in accordance with the Alliance CEMP.

Appropriate references to environmental management and control reflecting HEA and broader RTA requirements will be included in subcontract documentation. Subcontractor personnel will be included in the on-site induction process.

Subcontractors working on HEA will be required to:

Observe subcontract and statutory requirements relating to environmental protection and to follow instructions issued by HEA’s management and supervisory personnel.

Nominate site representatives to liaise with HEA’s representatives with respect to, and take responsibility for, environmental/planning requirements for the site activities.

Adhere to HEA’s management systems as they apply to their operations on the site.

Cooperate fully with site emergency incident procedures and consultative arrangements.

Follow procedures/systems outlined in the CEMP.

Adhere to the project’s Environmental Policy.

Depending upon the complexity of the subcontractor’s work, HEA may require the subcontractor to produce documentation detailing their own proposed environmental management systems and where necessary to prepare their own CEMPs and/or environmental procedures to augment HEA’s environmental requirements. Details within the subcontractors’ CEMPs will be consistent with this CEMP and the environmental requirements.

Such documentation will include:

responsibilities and authorities

training and qualifications in relation to work to be performed

environmental procedures in relation to the scope of works

control measures adopted by the subcontractor.

HEA will ensure the subcontractor’s work is monitored through the site inspection process.




Observations will be made by relevant personnel to assess the effectiveness of the environmental protection measures being used on site by the subcontractor and to determine compliance with the requirements of the CEMP.

3.7.6 Construction hours

All construction activities, including entry and departure of heavy vehicles, are restricted to the hours of 7 am to 6 pm (Monday to Friday); 8 am to 1 pm (Saturday) and at no time on Sundays and public holidays unless otherwise agreed by the DECCW in the conditions of the EPL (MCoA 73). Works outside these hours that may be permitted include:

i. any works which do not cause noise emissions to exceed the rating background noise level by not more that 5dB(A) at any nearby residential property;

ii. the delivery of materials which is required outside these hours as requested by police or other authorities for safety reasons;

iii. dust suppression works;

iv. emergency work to avoid the loss of lives, property and/or to prevent environmental harm; and

v. any other work as agreed through negotiations between the Proponent and potentially affected noise receivers or as otherwise agreed by DECCW in accordance with Condition 73 through the NVMSP (Construction) process. (MCoA 74)

3.7.7 Blasting associated with construction

Approved hours for blasting activities are:

10 am to 3 pm Monday to Friday

10 am to 1 pm on Saturdays (MCoA 83).

All reasonable attempts will be made to contact sensitive receivers (and/or asset owners) located within 500m of a blast location. The contact will be made at least 48 hours before a blast and advice given to the receiver will include a schedule of blast time(s) and a telephone number and contact name.




3.8 TRAINING, AWARENESS AND COMPETENCE

The HEA Project Director will ensure all staff performing the duties of this CEMP are properly trained. Table 3.3 lists the environmental skills which will be needed for certain positions. Where a need is identified, arrangements will be made for the appropriate training. Where necessary, assistance will be provided until the required training has been obtained.

Table 3.3: Training matrix

Position Skills training

Note: TBD = To be determined through inspections, performance reviews, monitoring and auditing systems.

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Management

Project Director TBD

Construction Manager/Project Managers

TBD

Design Manager TBD

Contracts Manager TBD

Health and Safety Manager

TBD

Environment Manager TBD

Line management

Project Engineers TBD

Site Engineers TBD

Superintendent TBD

Remaining site personnel

Administration Staff TBD

Leading Hands TBD

Labourers TBD

Subcontractors

Note: Training will be determined on signing of contract – however the following training

TBD




Position Skills training

requirements are likely.

Environmental Officers TBD

As outlined above, environmental training will include, but not be limited to, the following:

environmental induction

heritage management and cultural issues awareness

protected flora and fauna

erosion and sedimentation awareness courses

advanced soil conservation seminars

toolbox discussions

due diligence training

incident response and notification procedure (refer to Appendix E).

Three main forms of training will be provided on site:

site induction

specific environmental awareness training

‘toolbox’ training

environmental updates (information fact sheets).

Records of induction and training will be kept on a database, including the topic of the training carried out, dates, names and trainer details. Inductees will be required to sign off that they have been informed of the environmental issues and that they understand their responsibilities.

3.8.1 Induction

Before working on site all personnel and subcontractors will receive an environmental induction that will address a range of issues including, but not limited to:

the CEMP (purpose, objectives and key issues)

lessons learnt from environmental incidents

legal requirements including due diligence, duty of care and potential consequences of infringements

environmental responsibilities

complaints handling

conditions of licences, permits and approvals

HEA environmental policy

significant environmental issues and areas of the site including identification of boundaries for vegetation clearing, location of refuse bins, washing, refuelling and maintenance of vehicles, plant and equipment




environmental management techniques for critical environmental elements (soil and water, waste and recycling, flora and fauna, heritage etc.)

incident management and emergency plans

reporting process for environmental harm/incidents

protection and maintenance of environmental controls.

The EMR shall review and approve the induction package in accordance with MCoA21.

3.8.2 Environmental awareness training

Staff and sub-contractors working on site will be provided with environmental training to achieve a level of awareness and competence appropriate to their assigned activities.

Targeted environmental awareness training will be provided to individuals or groups of workers with a specific authority or responsibility for environmental management or those engaged in an activity with a high risk of environmental impact.

The Environmental Manager will generally prepare and deliver this training. Table 3.4 lists the target groups and suggested topics for this training.

Table 3.4: Possible training topics

Target group Topic

Project Engineers content and requirements of the CEMP and sub plans; and

requirements for temporary waterway crossings.

The Erosion and Sediment Control Team (or personnel responsible for ensuring these controls are installed on site)

selection, installation and maintenance of erosion and sediment controls;

flocculation of basins;

monitoring water quality in sediment basins; and

incident response.

Leading Hand management and maintenance of sediment basins.

Bridge Crew construction of crossings and bridges; and

significance of wetlands/waterways.

Work Crew

working near sensitive receivers or waterways;

working near areas of protected vegetation;

basic weed identification; and

incident response.

Emergency response crew location of emergency response equipment;

use of such equipment;

safety issues;

internal notification procedures; and

disposal of clean-up materials.

3.8.3 Toolbox training

Toolbox training will help to ensure that relevant information is communicated to the workforce and that feedback can be provided on issues of interest or concern. Toolbox training will




generally be prepared and delivered by the Project Engineers or Site Foreman. Toolbox training topics may include:

the efficient use of plant and materials

waste management, minimisation and recycling

noise and vibration minimisation

flora and fauna protection

dust control

protecting waterways and riparian zones

wastewater control

work methods

management of contaminated soil

general site issues.

3.9 COMMUNICATION AND CONSULTATION

3.9.1 Community consultation

HEA will ensure that all relevant consultation is undertaken in accordance with MCoA 18 during the project. Specific actions will include consultation with the general community through:

the development and implementation of a Community Communication Strategy

the formation of community-based forums that focus on key design, environmental management and construction issues for the project.

issuing information sheets

advertising activity timetables

making the CEMP and sub plans publicly available;

publicising a general project contact number prior to construction

establishing a publicised contractor’s hotline during construction, with associated procedures to ensure prompt responses to all enquiries and complaints and that complaints are properly addressed.

A Community Communication Strategy shall be developed and implemented for the project (MCoA 18). This Strategy shall be designed to provide mechanisms to facilitate communication between the Proponent, the Contractor, the Environmental Management Representative, Council and local community (broader and local stakeholders) on the detailed design, progress and the related environmental management of the project. All communication with the local community will take place in accordance with the Community Communication Strategy (MCoA 18) and the HEA project specific Community Involvement Plan (CIP). The CIP will:

Demonstrate how the community involvement requirements of the Project requirements will be delivered.

Describe the overall approach that will be taken when dealing with the community and other stakeholder groups.




Outline the methods that will be used to inform the community about the project and upcoming works.

Identify whom, why and what needs to be communicated when.

Key community groups along the upgrade include:

rural landholders and managers

interest groups (environmental and commercial)

adjacent residential communities (e.g. Seahampton, Kurri Kurri).

Information prepared for distribution to the community will be tailored to the needs of the target group and approved by the RTA before release. It may address progress, traffic disruptions and controls, temporary detours, work outside normal hours and will be provided as:

a community notice

advertisements (e.g. progress updates, road closures, disruption to traffic)

newsletters

brochures

internet updates

noticeboard information

in a display/information area.

Before construction starts and then at three-monthly intervals, an advertisement will be placed in local newspapers outlining the nature of the works proposed for the forthcoming three months, the areas in which these works are proposed, the hours of operation and a contact telephone number (MCoA 15).

The project internet site shall be established prior to the commencement of construction and maintained until 6 months after commencement of operation of the project. The internet site shall contain monthly updates of work progress and consultation activities, including but not be limited to:

i) a description of relevant approval authorities and their areas of responsibility;

ii) a list of environmental management reports that are publicly available and the executive summaries of those reports;

iii) minutes of meetings with stakeholder groups identified in the Community Communication Strategy;

iv) newsletters every three months;

v) contact names and phone numbers of the project communications staff; and

vi) 24 hour toll-free complaints contact telephone number.

Updates of work progress and construction activities shall be provided more frequently where significant changes in the noise impacts are expected (MCoA 17)

3.9.2 Complaints management

Any complaints received will be treated with respect. Should any complaints be received, the




Community Manager will maintain a complaints register. The Community Manager will establish and maintain a complaints management system and register and will receive, log, track and respond to complaints within specified timeframes. An initial response to a complaint shall be provided within 24 hours and a detailed response within 10 days. On receiving a complaint, works shall be reviewed to determine whether issues relating to the complaint can be avoided or minimised. Information on all complaints received shall be made available on request to the Director-General and all relevant government agencies (MCoA 12). All complaints received shall be detailed in the Project’s Six (6) Monthly Construction Compliance Reports.

All project staff will be advised of the procedures to be followed on receipt of a complaint during the project induction. The following details will be recorded in the register:

date

time

type of communication (telephone, letter, meeting etc.)

name, address, contact number of complainant

nature of complaint

details

action taken in response, including who the complaint was referred to (if not resolved immediately)

details of any monitoring to confirm the complaint has been satisfactorily resolved.

A written report will be provided to the RTA’s representative within one working day of receiving a complaint about any environmental issue, including pollution, arising from the works. The report will provide details of the complaint and the action taken. A final report with proposed measures to prevent the occurrence of a similar incident will be submitted to the RTA’s representative within five working days.

A 24-hour toll free complaints contact number (1800 001 267) has / will be established, publicised and listed with a telephone company. This would enable any member of the general public to reach a person who can arrange appropriate response action to a complaint (MCoA 11).

Further details of the operation of the community consultation and complaint management systems are provided in the Community Involvement Plan.

3.9.3 External stakeholders

Consultation with a range of non-community, external stakeholders will be required throughout the project. A list of relevant contact details for project stakeholders will be maintained by the Environmental Manager. Table 3.5 provides examples of typical consultation with external parties.

Prior to the commencement of construction, the Alliance shall notify the NSW Department of Planning and relevant authorities in writing of the project commencement (construction) date.

Table 3.5: External consultation

Stakeholder Consultation requirements





Government agencies including:

CEMP and sub plans

DECCW CEMP and sub plans (as required by CoC 15)

Contaminated soil management (if found)

Permit/licences and approvals

Heritage issues

Changes in route, design, structures or construction of the proposal that may contribute to adverse impacts on threatened species

Measures (visual identification, fencing and buffers of sufficient width for the protection of threatened flora species during the period of clearing and construction) to protect threatened flora and fauna

Feasibility of translocation options (report to DECCW)

Uncovering of threatened species during clearing

Flora and fauna mitigation measures

Weed Management Strategy

Water quality measures (monitoring program) to be implemented in the vicinity of the wetland

Design of stormwater drainage, erosion, sedimentation and water pollution control systems and facilities

Culvert and bridge design, construction and demolition

Water quality monitoring program

Noise issues/ hours of construction

NSW Office of Water Groundwater issues

Flooding impacts

Water quality monitoring program

Industries and Investment NSW

relocation, lopping or removal of Large Woody Debris (snags) in waterways and removal of any boulders, gravel beds or native freshwater vegetation from waterways

Blockage of waterways

Notification for dredging and reclamation

Utility provider Relocation of services

Director-General Activities likely to require Modification of Approval

Lake Macquarie, Maitland and Cessnock City

CEMP and relevant sub plans

Traffic management on local roads (construction vehicles on local roads, pavement





Councils design, design and management)

Maintenance of existing highway and proposed service roads

Work on public open space

Establishment of any site facilities outside of the road reserve

Noxious weeds

Local Aboriginal Land Councils and other relevant interest groups

Indigenous heritage items

Indigenous Heritage Sub Plan

The name and contact numbers for two site personnel who are available to DECCW on a 24-hour basis and who have authority to take immediate action to shut down any activity or to effect any pollution control measure as directed by an authorised officer of DECCW are:

1. Peter Chatburn, Alliance Project Director Mob: 0418 233 905

2. Tracey Doczy, Construction Environment Manager Mob: 0439 300 118

3. Howard Chemney, Design Environment Manager Mob: 0410 542 009

These contacts will be provided to the DECCW Regional Manager and Project DECCW representative(s).

3.9.4 Environmental Review Group

To facilitate consultation with environmental regulatory agencies, an Environmental Review Group (ERG) will be established.

The ERG will meet at least every three months and consist of the following core members:

EMR (Chairperson)

HEA Environmental Manager

RTA Client Representatives

DECCW (Environment Protection & Regulatory Group, as well as Parks and Wildlife Group representatives).

I&I NSW, NSW Office of Water and local councils will be notified in advance of the meetings to allow them to decide if their attendance would be beneficial.

The ERG will examine the following issues:

the CEMP’s adequacy and effectiveness

inspection and monitoring results

non-conformances

current and upcoming issues

community concerns




construction method statements

upcoming works, especially in sensitive areas

any design issues

training requirements.

The ERG may also be called upon to facilitate the prompt and effective resolution of issues raised by regulatory authorities, councils and/or RTA.

3.9.5 Environmental Peer Review Group

An Environmental Peer Review Group (EPRG) has been established to provide expert environmental advice and assistance to the Alliance. The Peer Review Group shall consist of RTA (&/or delegated consultants), Thiess, PB and Hyder Consulting senior representatives. The role of EPRG includes:

peer review of environmental design for example: fauna, fish, waterway, erosion and sediment, alignment and other design issues as appropriate. The EPRG will ensure that environmental outcomes, progress on environmental design, design innovation and agency requirements are addressed

review project design refinements against EP&A Act requirements, including consistency and environmental assessment as appropriate

input and review draft CEMP and sub plans

review of draft ECMSs and procedures

review of environmental controls and management for all environmental areas, for example, ESC, sediment basins, pollution, vegetation/ threatened species / EEC management, progressive re-vegetation, noise management, handling of complaints, actioning monitoring exceedances

review resources allocated to environmental management, for example, erosion and sediment control, environmental innovation, getting controls right the first time, meeting contract and environment documentation requirements

review and provide input into the Alliance’s actioning of environmental management issues, for example, inspections, audits, incidents, complaints, ERG issues, EMR issues, and project checklist issues

review and provide input into Alliance compliance against Conditions of Approval, Statement of Commitments and project licences and permits

periodically assess the quality and timing of key reports required to be sent to DoP, to ensure agreed timeframes are met

assist with project training, reducing the number of incidents, incident management, sub contractor selection and management, agency relationships and environmental culture on the project

provide advice to the Alliance on approaches to resolution of issues that are not progressing as well as expected.




3.10 INCIDENT AND EMERGENCY PLANNING, PREPAREDNESS AND RESPONSE

3.10.1 Emergency planning

Activities associated with potential or major environmental incidents are identified in the respective management plans. Incident management procedures are included in Appendix E.

3.10.2 Preparedness

The key to effective prevention of incidents is risk assessment, procedure development, monitoring and training. During construction activities, HEA’s inspections and preventive actions will include:

activity specific and daily risk assessments

development of work procedures and construction method statements in consultation with relevant HEA staff such as work teams, environment team members and senior management

daily inspections of active work sites

completion of routine environmental checklists

issue and quick close-out of non-compliance notices

ongoing environmental training

environmental audits of work sites, subcontractors and compliance issues.

Environmental and safety information on hazardous substances (e.g. MSDS) will be available at the main site office and where such substances are stored.

Environmental response procedures may be tested in areas where a pollution risk is present, such as in workshops. Personnel involved in emergency response activities will be provided with specific training.

An up-to-date list of emergency response personnel and organisations will be maintained at the main office and compounds. An example of the format that will be used is in Appendix E.

The following specific measures will also be implemented to minimise the risk of an incident occurring due to spillage, storage of hazardous materials or fire.

3.10.3 Spills and leaks (chemicals, fuel, hazardous liquids)

Plan and implement works involving the use of chemicals, dangerous goods or other potential contaminants, to minimise the possibility of pollution.

Use and store chemicals and dangerous goods strictly in accordance with relevant legislation, manufacturer instructions and the MSDS.

Establish transport, handling, storage and application methods (with the relevant method statement) to prevent chemical, fuel and lubricant spillage on or around the site.




Keep adequate quantities of emergency response materials, such as oil spill kits, absorbent materials, sand bags, flocculating agents and pH buffer solutions, readily available and in designated compounds. Also keep oil-spill kits in emergency response, superintendents’ and the Environmental Manager’s vehicles and vehicles that carry substantial quantities of chemicals.

Provide temporary bunding for refuelling or maintenance of plant and equipment, mixing cutting oil with bitumen or any other activity that could result in spilling a chemical, fuel or lubricant (where the activity occurs in a location with direct drainage to a waterway or environmentally sensitive area). Refer to the Refuelling Protocol in Appendix G.

Do not leave chemical drums removed from bunded areas unattended. Where this is not practical, manage the unbunded and unattended drums to minimise the risk of spillage and only use them on that day.

Drums used as markers must not contain chemicals or fuels or have been used to contain chemicals and fuels unless appropriately cleaned.

The major response to spills and leaks will involve containing the offending material.

Where safe to do so, install containment measures such as sandbags, booms, earth bunds or cut drains to capture and retain spilled material and prevent it from leaving site, entering any watercourse or impacting on vegetation stands.

3.10.4 Storage of liquids (chemicals, fuel, hazardous materials)

Bund all liquid storage areas in a manner that meets DECCW and WorkCover NSW requirements.

Suitably locate and bund chemical, fuel and lubricant storage areas to minimise the impact of any spillage or contaminated on or around the site.

Do not locate storage areas within 20 m of a natural or built drainage line, flood-prone areas or on slopes steeper than 1:10 or near vegetated areas.

Monitor and drain water captured in a bunded storage area after each rain event to ensure bund capacity is maintained at all times.

Before discharging water from bunded areas, implement a verification procedure to ensure the water complies with water quality criteria nominated by DECCW.

Arrange appropriate treatment or removal if the water is not suitable for discharge.

Call Emergency Response Team if required.

Record water quality checks, discharges and any remedial actions taken.

3.10.5 Fire

Fire fighting equipment will be available on site to facilitate an immediate response to a fire incident and help ensure the safety of public and property.

Fit spark arrestors to plant that could discharge sparks while being used during proclaimed high fire danger periods.

No cutting, welding, grinding and other activities with the potential to generate sparks will take place in the open on total fire ban days.

In areas of high risk fire mats will be placed under areas being used for welding.




Provide personnel involved in work where there is a risk of fire being caused by hot work, such as welding or in burning-off operations, with adequate training about fire prevention, safety and basic fire fighting skills.

Equip personnel and vehicles involved in such activities with fire fighting and safety gear.

3.10.6 Notification

The Environmental Manager will notify the DECCW Regional Manager (or DECCW Pollution Line should an incident occur outside normal business hours) of pollution incidents on or around the site which have occurred in the course of activities in the following circumstances:

If the actual or potential harm to the health or safety of human beings or ecosystems is not minor.

If actual or potential loss or property damage (including clean-up costs) associated with a pollution incident exceeds $10,000.

The HEA’s RTA Interface Manager will be notified verbally within 2 hours and in writing within 24 hours of any pollution incidents involving DECCW.

All incidents shall be notified to the EMR and RTA (i.e. Interface & Environment Manager) via the Alliance incident reporting system (e.g. HSE reporting system) in accordance with RTA Incident Management and Reporting Procedure (April 2008 or updated version) and Thiess HSE system. All incidents shall be recorded within the HEA Monthly Environment Report.

3.10.7 Incident investigation

All incidents will be documented, investigated and action plans established to prevent a re-occurrence. Where lessons are learnt from the investigation or current procedures are identified as being ineffective, the CEMP or associated documents will be revised by the Environmental Manager to include the improved procedures or requirement.

An environmental investigation includes the following basic elements:

identifying the cause, extent and responsibility of the incident

identifying and implementing the necessary corrective action

identifying the personnel responsible for carrying out the corrective action

implementing or modifying controls necessary to avoid a repeat occurrence of the incident

recording any changes in written procedures required

advising the environmental authority(ies) if any substantial pollution has occurred.

All personnel are required to report all incidents or near hits (misses), as it is regarded as a valuable method of addressing shortcomings in procedures, training or equipment, and is an opportunity for improvement.

3.10.8 Records

The Alliance will maintain the following records:




the CEMP (all versions), and associated regulatory licences and permits

regulatory authority inspection reports

correspondence with regulatory authorities and other key stakeholders

monitoring results

employee induction and training records

environmental monitoring records

sediment basin checklists and release records

environmental accidents/incidents/emergency reports

non-conformance reports

six-monthly reports to DoP

complaint reports

community involvement information

waste records

audit reports

check sheets and field sheets

any relevant reports submitted to the DoP

management review minutes and action taken.

Records will be held for at least five years after the date of Final Completion and be accessible to RTA’s representative and to authorised DECCW officers.

3.10.9 Document and data control

The Environmental Manager will coordinate the preparation, review and distribution, as appropriate, of the environmental documents listed above.

During construction, environmental documents will be stored at either the main site office, zone office or within the HEA electronic data management systems (e.g. site project drives/ Incite Keystone) and can be accessed on request to the Environmental Manager.

A document and data control procedure will be implemented to control the flow of documents and data within HEA and between HEA and the RTA, stakeholders and subcontractors.

Documents and data that are to be issued and liable to change will be controlled to ensure that they are approved before issue and that the current issue or revision is known to and available to those requiring them.

Controlled documents and data will be uniquely identified and will bear a defined revision number recorded on each page of the document.

After a number of changes have been made to a document it will be withdrawn and reissued as a new revision. Data will be issued on a revision basis only. Obsolete documents and data will be kept for contractual or other reasons, but will be clearly marked “superseded”. At all times the most current documentation shall be available on Incite.




3.10.10 Reporting to RTA

Monthly environmental reports will be prepared for the RTA and DECCW, and tabled for discussion at site meetings. These reports will summarise:

Progress of construction

Monitoring results

Complaints

Incidents

Non-conformances

Inspections by agencies

Internal and external audits

Positive environmental outcomes

Community consultation activities

ERG and PERG meeting outcomes as applicable

Other issues as necessary

3.10.11 Reporting to DoP

A pre-construction compliance report has been prepared before substantial construction starts. The report details compliance with all relevant conditions that apply before substantial construction starts.

A report on the environmental performance of construction works and compliance with the CEMP and MCoA will be prepared on a six-monthly basis (from the start of substantial construction) and thereafter at six-monthly intervals. The report will be prepared in accordance with MCoA 31 and address:

Applications for consents, licences and approvals and the response of authorities.

An assessment of the implementation and effectiveness of environmental controls and conditions.

Identification of construction impact predictions made in the EIS/SIS and the extent to which the actual impacts reflect the predictions.

Details and analysis of results of monitoring and flora and fauna management.

Number and details of any complaints, including a summary of the main areas of complaint, response given and intended strategies to reduce complaints of a similar nature.

Any other matter relating to compliance.

These reports will be submitted to the Director General (via RTA) and will be made publicly available on the Project’s website. The reports shall be provided to the DECCW (EPA, NPWS), I&I NSW, and relevant Councils, and any other relevant government agency nominated by the Director-General




4 COMPLIANCE

4.1 COMPLIANCE TRACKING STRATEGY

CoA 6 requires that the Proponent (RTA) ensures compliance with all of the Director General’s requirements arising from the Conditions of Approval. In order to achieve this, a compliance tracking strategy has been developed by the Alliance and shall be implemented throughout the duration of the construction phase (and operational phase as necessary).

The compliance tracking strategy includes;

1. provisions for periodic review of project compliance with the requirements of the MCoA, and documents referred to in Condition 1 of the MCoA. Note these are referred to as COURs (commitment, obligation, undertaking or requirement). Review of COURs occurs during the development of management plans, construction method statements, work procedures, risk assessments and when undertaking audits.

2. provision for reporting of compliance status to the Director-General (6 monthly Construction Compliance Reports)

3. provisions for the notification of the Director-General before construction and operation of the project start

Tracking the various obligations will be maintained through the Alliance’s online document management system Incite Keystone. The following information is recorded for each MCoA:

reference number

full text of the requirement

name of the document and section containing the response to the requirement, or a

description of how the requirement has been addressed (if response does not form part of a project document)

timing (e.g. pre-construction, construction, pre-operation, operation);

responsibility

notes including, where relevant:

o consultation requirements and status

o approval requirements and status

o independent audit requirements and status

o any other comments.

4.2 CHECKLISTS

The effectiveness of environmental protection measures is assessed using the checklist provided in Appendix F. The checklist addresses the key issues and approval requirements contained in each of the management sub plans. The checklist:

provides a guidance tool to ensure safeguards are being implemented

facilitate the identification and early resolution of problems, and




highlights where sound environmental practices are being implemented well.

Any non-conformances identified through the checklist process will be highlighted and an environmental inspection report (minor issues) or an environmental improvement notice/environmental incident report completed. The checklist will remain ‘open’ until:

the issue has been resolved

a new or revised procedure has been established and implemented

training has been provided to relevant personnel/subcontractors.

4.3 INSPECTION AND SURVEILLANCE

Inspections and surveillance of work activities and subcontractors will take place on a day-to-day basis by:

Superintendents and Foreman

Project Engineers

Environmental Staff

The activities of subcontractors will be monitored. The frequency of different levels of inspections will be completed in the times outlined in Table 4.1

Table 4.1: Inspection frequency

Management plan Inspection completed by Frequency

Environmental checklist Environmental Staff/Project Engineers

Weekly

Flora and fauna – prior clearing checklist

Environmental Staff/Ecologist Prior to clearing

Soil and Water Foreman/ Site Engineer/ Environment Staff

Daily during rain and then post rain. Also use the foreman daily diary records as a form of record of daily rain inspections.

Commitment Matrix (inspections by all staff covering safety, quality and environmental aspects of construction activities)

All staff Monthly

In addition to Table 4.1, the following inspections may take place:

The EMR will be involved in regular surveillance inspections with HEA personnel to assess compliance, review the CEMP’s effectiveness and identify issues and/or improvements.

External organisations, such as DECCW and I&I NSW, may undertake inspections to assess specific sites or work activities (e.g. culvert and crossing installation).

Inspections will be part of internal and external audits.




The RTA’s representative and/or Environmental Manager will undertake inspections to confirm that environmental controls are being implemented and to identify any current or upcoming issues.

The ERG may make an inspection as part of its meeting.

Where inspections are made by an external party (such as DECCW) details of the inspection will be provided to relevant site personnel or discussed in site meetings. The Environmental Manager will collate and file completed inspection reports and will include details in the six-monthly reports to DoP.

4.4 AUDITS

4.4.1 Internal

The HEA Environmental Staff will perform internal audits. Elements that may be audited include:

compliance with the conditions of approval and relevant RTA specifications

compliance with the CEMP

compliance with approval, permit and licence obligations

compliance with method statements

complaint response

sub-contactor activities

training records

non-conformances

monitoring results

system documentation, such as checklist completion.

Results of all audits will be brought to the attention of the personnel responsible for the area audited and reported to the relevant manager. Subcontractors will be subject to the same inspection, monitoring and auditing process as if they were HEA staff. Note the development of the Pre-construction Compliance Report will also be used by the Alliance as an auditing process to ensure compliance prior to the commencement of construction where appropriate.

The Environment Manager will act on and close out as quickly as possible inspections and audits by external bodies, including the RTA, DECCW or DoP. Details of these actions will be reported back to the auditors.

Table 4.2 provides an outline of proposed audits and reporting requirements.




Table 4.2: Auditing report requirements

Audit report Reporting frequency

Pre-construction

Pre-construction Compliance Report

Submit report at least four weeks before construction begins (or within any other time agreed to by the Director-General of DoP).

Construction

Construction Compliance Reports

Compliance reports (to include compliance assessment with MCoA, and other obligations) every six months for duration of construction.

Internal Construction Audits

Within the first 3 months of construction and every three months for the duration of construction.

Note: In compliance with CoA 32, internal audits are to be certified by the EMR and are to cover compliance with the CEMP, the conditions of approval and all other relevant licences and approvals. Each audit must be completed within 6 weeks of the end of the 3 month period and be made available to the Director-General upon request.

Construction Environmental Impact Audit Report

Submit report a maximum three months after the project begins operation (or at any other time interval agreed to by the Director-General of DoP).

Pre-Operation Compliance Report

Submit report at least four weeks before operations begins (or within any other time agreed to by the Director-General of DoP).

Operation

Pre-operational compliance report

Submit report at least four weeks before operations begins (or within any other time agreed to by the Director-General of DoP).

The content of these reports are to cover those requirements as detailed in the CoAs for the project.

The CEMP will be reviewed and amended in response to an environmental incident, non-conformance or the outcomes of an environmental audit. The EMR will also carry out site inspections of active work sites to evaluate compliance with the CEMP and provide notice to the Alliance of any non-compliance.

The HEA environmental audit schedule is included in Appendix J.

4.4.2 Internal management review

An internal management review will take place annually. The review will assess effectiveness of the CEMP, taking into account items such as environmental audit outcomes (from external or project-based internal audits), monitoring records, performance in achieving environmental targets and compliance limits, complaints, non-conformance, corrective and preventive actions and any changes to statutory requirements.

The results of the review will be brought to the attention of people responsible for the area reviewed.




4.4.3 External

The RTA, EMR and DoP may carry out external audits. If Corrective Action Requests (CAR) and Observations of Concern (OoC) are raised during such audits, these shall be addressed as soon as possible on completion of the audit. Responses and resolution of CARs and OoCs shall be documented and provided to HEA Management and the relevant external auditor.

4.5 ENVIRONMENTAL MONITORING

Environmental monitoring shall involve collecting and interpreting data to provide quantification of the effectiveness of management strategies outlined in the CEMP. The monitoring programs will help audit safeguard measures to ensure they achieve their objectives and to facilitate modification where necessary.

Monitoring shall assess the following aspects:

noise and vibration

air quality

water quality

erosion and sedimentation, including sediment basin discharges

archaeology and heritage

flora and fauna monitoring

re-vegetation management

Monitoring programs for these elements shall consider the following issues

background data

sampling procedures

reporting and data interpretation

recommendations

laboratory and chain of custody procedures

statutory limits

actioning systems.

The timing, frequency, methodology, locations and responsibilities for the proposed environmental monitoring programs are specified in the respective management plans. Monitoring program(s) can include formal sample collection, analysis and measurement, and qualitative assessments. A summary of monitoring frequencies is given in Table 4.3.

Where a non-conformance is detected or monitoring results are outside of the expected range, follow-up investigations shall be undertaken to determine if construction activities are contributing to the results observed as outlined in Section 4.6.




Table 4.3: Standard monitoring frequencies

Monitoring requirement Frequency (and location)

Dust monitoring Monthly

Noise monitoring Monthly

Surface water monitoring Twice per Month (i.e. dry and wet weather monitoring)

Groundwater monitoring Monthly (at locations detailed in the Soil and Water Management Sub Plan)

Sediment and erosion control monitoring

Daily by site staff, weekly by environmental staff and after any major rain event

Sediment basin monitoring Before releasing (at locations detailed in the Soil and Water Management Plan)

Note: These are the standard monitoring requirements. In the event of incident or complaint, specific monitoring may be required.

4.6 NON-CONFORMANCE, PREVENTIVE AND CORRECTIVE ACTION SYSTEMS

Non conformances or potential non conformances are:

failure to implement/maintain a critical environmental control (e.g. controls around waterways)

failure to implement environmental controls as per developed CMS or activity work procedure

failure to close-out identified environmental deficiencies within a specified timeframe (e.g. sediment fences not repaired within 4 days)

identification of repeat occurrences of deficiencies (e.g. sediment fences not reinstated).

identification of monitoring results outside of specified criteria that are related to construction activities

Non conformances or potential non conformances may be identified in any of the following situations:

as part of regular site inspections, supervision or monitoring of normal operating activities

during internal or external audits

following significant verbal or written third party complaints.

Any environmental non-conformances and subsequent corrective actions shall be resolved in accordance with procedure HEA-MP-GL-OPS-010 Non-compliance and Corrective Action.

All environmental non-conformance report forms are copied to the Environment Manager who ensures that they are investigated and corrective and preventive actions are taken.




The Environment Manager shall determine:

how the impacts can be successfully remedied to ensure sound environmental management

whether the regulatory authority requires to be notified of the non-conformance

notify the complainant of any action taken to address the complaint, where appropriate.

Corrective and preventive actions provide the mechanism to:

undertake corrective (reactive) action to eliminate the causes of non-conformance

undertake preventive (proactive) action to eliminate potential causes of non conformances

suggest improvements to the CEMP.

Environmental Corrective Action Reports, Non-conformance Reports and actions from inspections are tracked via the HEA Environment Issues Register.




5 REVIEW AND IMPROVEMENT OF CEMP

HEA’s Environmental Manager will review the CEMP and its implementation at least every twelve months from when construction begins. Between the scheduled reviews, a register of issues will be maintained to ensure that any issue raised by internal and external personnel associated with HEA is recorded.

The purpose of the review is to ensure that the system is meeting the requirements of the standards, policies and objectives and if not to amend the CEMP to meet the shortfalls. The Project Alliance Director will review and approve changes to the systems.

The review will consider:

client’s comments

site personnel comments

agency comments

audit findings

minutes of ERG meetings

environmental monitoring records

complaints

inspections

details of corrective and preventive actions taken

environmental non-conformances

incident reports

changes in organisation structures and responsibilities

extent of compliance with objectives and targets

compliance with COURs (and certification by EMR)

effect of changes in standards and legislation.

The EMR may review and approve minor revisions to the Construction Framework EMP and Sub Plans in accordance with CoA 21. Consultation with the Department of Planning, RTA and other regulatory agencies shall be carried out with regards to proposed changes that are not considered minor by the EMR.

Site staff shall implement any changes arising from the reviews of the policies and/or the Management Plan.




6 REPORTING

The Environmental Manager will prepare a summary reports on environmental matters on a monthly basis as required by the Environment Protection Licence.

The reports shall be used to facilitate the preparation of the six-monthly Compliance Reports required by MCoA 31 and the monthly project report provided to the RTA. The Reports shall also be useful in helping the Environmental Manager identify any recurring issues or impacts to develop environmental training programs and identify areas of the CEMP that may require review.

The report will include details of:

good environmental performance,

non-compliance with environmental obligations and the CEMP,

environmental monitoring results,

actioning and reporting of all incidents.