Drill Exercise Pollution Incident Response Plan –

Gypsum Resources Australia

1.0Introduction

Amendments to the Protection of the Environment Operations Act 1997 (POEO Act) requires the holder of an Environment Protection Licence (EPL) to prepare, test and maintain a pollution incident response management plan (PIRMP). Key compliance requirements with respect to training employees assigned to undertake PIRMP actions and testing incident responses are:

•training to be provided to staff to ensure that they can effectively implement the PIRMP

•records of the name of each staff member that has completed the training and the date when the training was completed

•how the plan will be tested and maintained in accordance with the requirements under the POEO Act

•a record of the dates when the plan was last tested and reviewed

2.0Compliance with PIRMP training and testing

On 3/12/14GRA managers and employees were provided follow-up training on PIRMP complianceand specific actions required in responding to pollution incidents that could potentially occur at the GRA port facility. The PIRMP details GRA operations with associated environmental risks ranked as high, medium and low.

3.0PIRMP incident adopted for drill

Date of Drill 3/012/14
Date of Report 5/12/14 / Version of PIRMP used for Drill 18/6/13
Drill Response Team /
  • Scott & Chris

Incident Stakeholder Communications /
  • Chris McLaughlin

Drill Review Team /
  • Attila Balazs (National Environment Manager)
  • Scott (Site personnel)

PIRMP Incidents used for Drill / Loss ofhydraulic oil from 205L Drum over sealed car park area with stormwater drains.

4.0Simulated incident

The simulated drill was undertaken around potential significant loss of hydraulic oilfrom a 205L drum that was being manually relocated using a trolley in the main car park area that is service by two stormwater drains(see Photo 1). The hydraulic drum has a maximum capacity of 200L which has potential for material if diesel loss enters on-site stormwater drains which discharge into Port Jackson.

Photo 2: Incident locality adjoins Port Jackson

5.0Overview of drill actions

The observations undertaken during the drill is presented in Table 1.

Table 1PIRMP Incidents #2 –Diesel fuel flowing towards stormwater drains

Time / Drill Actions / Key Review Comments
11:00am /
  • Drum being manually relocated.
/
  • Manual handling of drum without straps to secure it to trolley.
  • There is potential the drum to become dislodged and rupture with contents entering stormwater drain.

11:01 – 11:02am /
  • Drum has become dislodged from trolley andhydraulic oil leaking onto sealed car park area. No spill kit in immediate area and approximately one minute is required to mobilise spill kit to the incident area.
/
  • The spill kit is located within the Gypsum storage building some 50m from where the incident took place.
  • The spill kit was located in a cluttered area and access was partially limited.
  • The Site Manager correctly calls GRA environment manager to notify him of incident.


11:03 – 11:04am /
  • Site employeesutilises spill kit

  • Site Manager calls GRA Environment Manager to inform him of incident and whether notification is required
/
  • Site response effectively reduces potential for diesel loss to reach stormwater drains but has not used appropriate PPE during response to incident (i.e. Gloves).

  • Site Manager correctly continues to inform GRA environment manager of the incident and response actions.

11:05 – 11:07am /
  • Site Manager continues to report incident to GRA environment manager
/
  • Site Manager correctly continues to inform GRA environment manager of the incident and response actions.

11:07 /
  • Hydraulic oil hadstopped flowing from righted drum
  • The spill kit booms and absorbent media have been effective in preventing diesel fuel entering stormwater drain that flow into Port Jackson.
  • No hydraulic oil has entered the stormwater drain that flows into the on-site retention basin which was essentially empty at the time of incident with no potential for overflow.
/
  • At 11;11am the Site Manager is informed by GRA environment manager that the incident was not required to be reported to the PIRMP incident agencies (i.e. EPA, Council , Fire Dept, Dept of health).

11:11am /
  • Site Manger inform GRA environment Manager that incident is under control with no loss of diesel into stormwater drain that flowed into Port Jackson.

11:12am / Onsite response completed and preliminary clean-up of the impacted area commenced.
Incident response drill is considered complete and a brief discussion on response issues was undertaken with a follow-up report with recommendations to be provided by GRA Environment Manager

5.0Drill Summary

The PIRMP response teamresponded quickly and maintained an appropriate level of communication between each other throughout the incident. The Site Manager maintained appropriate communication with the GRA Environment Manger for assessing a requirement for the immediate reporting of the incident to EPA and other required departments.

In this instant it was decided not to report the incident for the following reasons:

  • Hydraulic oil was prevented from entering the stormwater drain that flows into Port Jackson. The loss of hydraulic oil was minor and completely cleaned-up immediately after the spill.
  • Site Manger had provided continual incident status reports to GRA environmental manager during which advice was that the potential for diesel flow reaching stormwater drain was minimal due to rapid and effective response.
  • The flow of hydraulic oil from drum had been significantly reducing during the incident by righting the dislodged drum.
  • Weather during the incident was fine with no imminent rain evident.

However, there would have been an increased potential for immediate reporting had:

  • There been more of the hydraulic oil escaping from the drum.
  • Response using spill kit been less effective.
  • It been raining during the incident.
  • Any other circumstance that increased the risk to human and environmental health.

6.0Review and update of PIRMP

The current version of the PIRMP should be reviewed with consideration to the above observations and recommendations. The revised PIRMP should be sent to the GRA Environmental Manager and Regional HSE Manager for review, distribution and implementation.