Independent Environmental Audit Erosion and Sediment Control

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1 Independent Environmental Audit Erosion and Sediment Control Commencement of YOUNG TO BETHUNGRA LOOPING PIPELINE JUNE 2016 suite 1, 39 fitzmaurice st (po box 5464) wagga wagga nsw 2650 australia t (02) /21 mary st surry hills nsw 2010 australia t (02) suite 1, 216 carp st (po box 470) bega nsw 2550 australia t (02) unit 17/27 yallourn st (po box 62) fyshwick act 2609 australia t (02) e ngh@nghenvironmental.com.au 35 morrisset st (po box 434) bathurst nsw 2795 australia tudor st hamilton nsw

2 Project Title: Document Verification Project Number: 6639 Project File Name: Y2B ERSED Audit Report Environment Revision Date Prepared by (name) Reviewed by (name) Approved by (name) Final 1/06/16 Nicole Isles Erwin Budde Erwin Budde nghenvironmental prints all documents on environmentally sustainable paper including paper made from bagasse (a byproduct of sugar production) or recycled paper. nghenvironmental is a registered trading name of NGH Environmental Pty Ltd; ACN: ABN: suite 1, 39 fitzmaurice st (po box 5464) wagga wagga nsw 2650 australia t (02) /21 mary st surry hills nsw 2010 australia t (02) suite 1, 216 carp st (po box 470) bega nsw 2550 australia t (02) unit 17/27 yallourn st (po box 62) fyshwick act 2609 australia t (02) e ngh@nghenvironmental.com.au 35 morrisset st (po box 434) bathurst nsw 2795 australia tudor st hamilton nsw

3 Erosion and Sediment Control Audit Commencement of CONTENTS 1 REPORT SUMMARY INTRODUCTION SCOPE OF THE AUDIT SUMMARY OF CORRECTIVE ACTIONS SUMMARY OF OBSERVATIONS OF CONCERN SUMMARY OF OPPORUNITIES FOR IMPROVEMENT AUDIT PROCESS OPENING MEETING CLOSING MEETING DESIGNATED FOLLOW-UP DETAILS OF AUDIT FINDINGS EROSION AND SEDIMENT CONTROL PLAN PREPARATION EROSION AND SEDIMENT CONTROL IMPLEMENTATION MAINTENANCE AND MONITORING...9 APPENDIX A AUDIT PROTOCOL... A-I 6639 Final i

4 Erosion and Sediment Control Audit Commencement of AUDITED ORGANISATION PROJECT APA Group ADDRESS Young Site Compound CONTACT DETAILS Derek Prentice DEPTH OF AUDIT Erosion and Sedimentation SCOPE OF AUDIT Statement of Commitment SG6 compliance audit of erosion and sedimentation controls within 6 months of the commencement of ground works DATE OF AUDIT AUDIT CRITERIA 25 th May 2016 APA Surface Water and Water SCL Environmental (as it relates to Erosion and Sedimentation) Relevant guidelines including the NSW Blue Book AUDIT PROGRAM Opening meeting 10:30am Project Site Office in Young Site Inspection Closing Meeting 3:00pm Project Site Office in Young PERSONS REQUIRED AUDIT TEAM Derek Prentice Nicole Isles, NGH Environmental Lead auditor Graham Stewart PREVIOUS AUDIT DATE PREVIOUS AUDIT REFERENCE NIL NIL 6639 Final 2

5 Erosion and Sediment Control Audit Commencement of 1 REPORT SUMMARY 1.1 INTRODUCTION This audit represents one of two erosion and sediment control audits required to be undertaken for the construction of the project by a suitably qualified person independent of APA (Nicole Isles). The requirement for the audit is identified in the Statement of Commitment SG6, which requires two compliance audits of erosion and sediment controls to be undertaken within 6 month of the commencement of construction of on ground works and again at the completion of pipeline laying. started in early February. At the time of the audit, the following activities were being undertaken: Preparation for trenching at Burrengong Creek Dewatering of trenches Rehabilitation works over waterway at CH SCOPE OF THE AUDIT The scope of the audit focused on the implementation of erosion and sediment control measures outlined in the Managing Urban Stormwater Soils and Vol 1 (Landcom, 2004) (Blue Book) to minimise soil erosion and the discharge of sediment and other pollutants to land and/or water. Compliance with the project s approved CEMP and Surface Water and Water was also assessed. A specific site inspection was conducted for this audit on 25 May 2016 by Nicole Isles (NGH Environmental). Also on the inspection were Erwin Budde (Project Environmental Representative), Graham Stewart (CNC Projects), Vladeo Maric (APA Group Approvals Manager), James Beckett (APA Project Access and Approvals Manager) and Channy Tong (Monarc Environmental). 1.3 SUMMARY OF CORRECTIVE ACTIONS Two Corrective Actions Request (CAR) was issued to the project team at the audit Closing Meeting. CAR No. CAR SW 2016/001 CAR SW 2016/002 Section of Report Details 3.1 Section 2.1 of the Blue Book suggests that an erosion and sediment control plan (ESCP) should be prepared for areas of disturbance above 250m 2. No site specific ESCP has been prepared and should at a minimum be prepared for individual water crossings. 3.1 Erosion and sediment controls at Burrengong Creek are insufficient. This was supported by the volume of sediment that has exceeded the current erosion and sediment controls and entered the creek Final 3

6 1.4 SUMMARY OF OBSERVATIONS OF CONCERN Erosion and Sediment Control Audit Commencement of The following Observation of Concern (OoC) was identified and explained to the project team during the audit Closing Meeting. It is considered to be a deficiency in meeting specified requirements and if not rectified, which if not addressed, may lead to a risk of non-compliance. OoC No. OoC SW 2016/001 Section of Report Details 3.3 A checking process should be in place to verify that ESCP have been prepared. 1.5 SUMMARY OF OPPORUNITIES FOR IMPROVEMENT The following Opportunities for Improvement (OFI) were identified and explained to the project team during the audit Closing Meeting. They are considered to be areas of improvements that could prevent future problems. OFI No. OFI SW 2016/001 OFI SW 2016/002 Section of Report Details 3.2 Separate clean and dirty water on the ROW by preventing water from entering site. 3.2 Earthworks and clearing should be staged and programmed to limit the area of soil exposed and to minimise the potential for erosion Final 4

7 Erosion and Sediment Control Audit Commencement of 2 AUDIT PROCESS 2.1 OPENING MEETING An opening meeting was held on the morning of the 25 May Attendees were: Nicole Isles (Independent Erosion and Sedimentation Auditor) Erwin Budde (Environmental Representative) Graham Stewart (Project s Site Environmental Officer) Vladeo Maric (APA Group Approvals Manager) James Beckett (APA Project Access and Approvals Manager) Channy Tong (Monarc Environmental) 2.2 CLOSING MEETING A closing meeting was held in the afternoon of the 25 May Attendees were Nicole Isles (Independent Erosion and Sedimentation Auditor) Erwin Budde (Environmental Representative) Graham Stewart (Project s Site Environmental Officer) Vladeo Maric (APA Group Approvals Manager) James Beckett (APA Project Access and Approvals Manager) Channy Tong (Monarc Environmental) 2.3 DESIGNATED FOLLOW-UP No previous audit had been conducted by the Independent Erosion and Sedimentation Auditor. It is the responsibility of APA to follow up all actions identified in the audit report Final 5

8 Erosion and Sediment Control Audit Commencement of 3 DETAILS OF AUDIT FINDINGS This section details the findings of the audit report. It only details those findings requiring action. For complete details of the findings of the Audit, refer to the Audit Protocol contained in Appendix A. 3.1 EROSION AND SEDIMENT CONTROL PLAN PREPARATION Section 2.1 of the Blue Book details that ESCP s should be prepared where more than 250m 2 of land will be disturbed or where a high risk of polluting waters exists. A standard ESCP is included in Attachment A of the Surface Water and Water (Dated 9 November 2015) however this does not adequately identify the specific erosion and sediment controls required at each waterway. Given the high risk of erosion and sediment impacts within waterways, a specific ESCP should be prepared for each waterway to ensure that the risks areas of each waterway is identified and site specific erosion and sediment controls are implemented. Corrective Action (CAR SW 2016/001). The Blue Book also details that Soil and Water s (SWMPs) should generally be prepared for all projects where more than 2,500m 2 of land will be disturbed. The Surface Water and Water satisfies this requirement 3.2 EROSION AND SEDIMENT CONTROL IMPLEMENTATION Separating clean and dirty water on site by directing clean water around disturbed ground is the most effective way of reducing the volume of water that becomes sediment laden from coming in contact with exposed area. This also reduces the volume of runoff that has the potential to cause erosion. Clean water from the wider catchment that flows towards the construction area is directed into the work area and then treated and discharged as required (refer to Figure 3-1) It is recommended that clean and dirty water are separated on site by preventing clean water from entering site. This could be done by ensuring the berm along the alignment is continuous. Opportunity for Improvement (OFI SW 2016/001). Sediment is being adequately filtered by discharging water from excavations onto grassed area, usually through a sediment trap. Discharge is being undertaken at least 200 metres from drainage lines. Staging of work and programming of construction activities are required to minimise the extent and duration of disturbance to vegetation. This includes leaving clearing and initial earthworks in intermittent and permanent watercourses until subsequent works are about to commence. This limits the areas of soil exposed at any time to those areas being actively worked and minimises the potential for erosion and sedimentation. Opportunity for Improvement (OFI SW 2016/002). Progressive stabilisation and rehabilitation is being undertaken along the alignment and is shown in Figure 3-2 and Figure 3-3. During the site inspection is was observed that there were inadequate erosion and sediment controls within Burrengong Creek. This was supported by the volume of sediment that has exceeded the current erosion and sediment controls and entered the creek (refer to Figure 3-4). The current controls rely on secondary sediment controls instead of primary erosion controls. The erosion and sediment controls for this area should be reviewed immediately and controls installed that slow the water first, such as earthen bunds, before the water is filtered by the sediment fence. Corrective Action (CAR SW 2016/002) Final 6

9 Erosion and Sediment Control Audit Commencement of Figure 3-1 Clean water being allowed to enter site through an excavation in the berm. Figure 3-2 Progressive stabilisation and rehabilitation of a drainage line 6639 Final 7

10 Erosion and Sediment Control Audit Commencement of Figure 3-3 Progressive topsoiling and rehabilitation of the alignment Figure 3-4 Inadequate erosion and sediment controls within Burrengong Creek 6639 Final 8

11 3.3 MAINTENANCE AND MONITORING Erosion and Sediment Control Audit Commencement of Proper maintenance of erosion and sediment controls are being adequately undertaken by the Project s Site Environmental Officer and weather is being monitored to provide advice to site when particular high risk works should be postponed. This is being well managed by site personnel. planning should be undertaken by the Client to ensure that adequate erosion and sediment control have been planned for at each stage of work and in particular for works in waterways. There is currently not process in place to check and ensure that ESCP are developed with the required detail and implemented on site. A checking process should be in place to verify that ESCP have been prepared. It is recommended that a checking program, such as an Inspection and Test for ESCP, be implemented to ensure that working in high risk areas are planned for and include controls specific to the nature of each waterway Observation of Concern (OoC SW 2016/001) Final 9

12 APPENDIX A AUDIT PROTOCOL Erosion and Sediment Control Audit Commencement of 6639 Final A-I

13 Erosion and Sediment Control Audit Commencement of Objective SoC Ref # Commitment Timing Resource CEMP/Sub- reference Compliance Status Comment Soils and Geology Minimise scour impacts S1 Scour protection will be installed in creek bank areas at risk of erosion as necessary. Pre- and GS4 Comply Scour protection was being installed as part of the rehabilitation works over waterways at the time of the audit Minimise loss of top soil. S2 Erosion and sediment management controls will be prepared as part of the CEMP to manage and minimise erosion and control sediment impacts associated with the construction of the pipeline. Controls will be continually maintained in good working order Pre- and Managing Urban Stormwater: Soils and (Landcom, 2004) APIA Code GS1 to GS15 and Surface and CAR Refer to CAR SW 2016/001 S3 Soil types will be identified and delineated along the alignment. Pre- Manage soils S4 Soil management measures will be developed according to local soil type and be documented in the CEMP. Pre- and Managing Urban Stormwater: Soils and (Landcom, 2004) GS1 to GS15 and Surface and Not audited N/A APIA Code Surface and Minimise pollution to surface and groundwater SG1 Soil and water management measures will be implemented during the construction phase through the CEMP. measures will incorporate prevention strategies and a spill response procedure including aspects such as: - Spill response equipment is to be located at each work site - Routine maintenance or refuelling of mobile equipment and vehicles will not be conducted within 40m of any water course During Managing Urban Stormwater: Soils and Surface and Comply Spill response kits are available on site Fuel, storage sites and equipment are not parked up or located within 40m of anyt watercourse 6639 Final A-I

14 Erosion and Sediment Control Audit Commencement of - Storage sites will not to be located in the vicinity of any watercourse. (Landcom, 2004). Minimise changes to existing surface and groundwater regimes SG2 SG3 SG4 SG5 SG6 Where practicable, waterway crossings during construction would be undertaken during no or low flow. Bank and floor restoration techniques will be adopted to assist in stabilising watercourses and the prevention of scouring, as soon as practicable after the pipe has been laid and backfilled. Where necessary, temporary surface water diversion berms will be installed to encourage runoff discharging onto stable (vegetated) areas. The CEMP will be developed in consultation with the NSW Office of Water, and include procedures for: - Activities within 40 m of a watercourse being carried out consistently with the Guidelines for Controlled Activities on Waterfront Land. - The identification of appropriate water sources and re-use options. - The timing of rehabilitation works. Two compliance audits of erosion and sediment controls will be undertaken by a suitably qualified person independent of the APA within 6 months of the commencement of on ground works and again at the completion of pipeline laying. A copy of each audit report will be provided to Fisheries NSW for review. During construction During construction During operation Prior to construction During construction Guidelines for Controlled Activities on Waterfront Land (available from Surface and Surface and Surface and Surface and Surface and N/A Not audited Comply N/A Comply Waterway crossings were all constructed prior to the audit Bank and floor restoration was being installed as part of the rehabilitation works over waterways at the time of the audit Temporary berms are in place along alignment and runoff is discharged onto stable grassed areas N/A This audit satisfies the first audit 6639 Final A-II

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