EPA NSW

POLLUTION INCIDENT RESPONSE MANAGEMENT PLAN
NU-ROCK RESPONSE PROTOCOL TO SPILLAGE ON SITE

This plan is to cover preparing for any spillage incident that may occur on the Nu-Rock test plant site. Pollution incidents causing or threatening material harm the environment or person to be notified.

1. Kinds of incidents to be notified to the manager of the site and to the EPA are any spoilage that may or does cause harm to the Environment. The Nu-Rock Test plant has only limited number of materials that might spill and they are recorded in the section under Identified Materials, which are Dry and Liquid materials.
2. Every person that works on the site has a duty to notify the plant manager immediately of any incident, which has occurred and to follow the relevant procedures detailed in this PIRMP.
3. Every employee carrying out an activity on the plant site is required to notify the Plant Manager and to implement the PIRMP for the material that has been spilled. Nu-Rocks management as soon as it is notified of a spillage must act on the notification following the procedure set out in the PRIMP and notify each relevant authority which on this site is Energy Australia NSW Ltd. Environmental manager, WorkCover Authority if a person is hurt in the incident, Fire and Rescue NSW and the EPA Orange branch.
4. It is the Duty of the Nu-Rocks management as the occupier and its employees working on the site premises building are to make sure that every employee notifies the Plant Manager about the incident and to immediately implement the PIRMP.
5. Nu-Rocks Plant Management must take all reasonable steps to ensure that, if a pollution incident occurs while carrying out the plants activity on the premises the plants employees’ or any agent employed on the site premises are to notify the Nu-Rock Plant Manager.
6. The extension of Nu-Rock as the principle and any Agent employed on the site and carrying out an activity in the plant is that they must notify the Plant Manager of any incident. The reference of an Agent extends to the employees and the reference of employer as to the Principle being Nu-Rock.
7. This PIRMP does not extend to the emission of an odour unless it is continues and does not abate after an hour.
8. The relevant authority in this PIRMP are the following:

• EPA Orange Branch
• The Minister of Health – if the incident requires such notification
• Work cover – if a person is hurt
• Fire and Rescue – if there is need for a person on-site being hurt or a fire on the premises.

MANNER AND FORM OF NOTIFICATIONS

Manner of how the notification is to be carried out to the Plant Manager from any employee and Agent on site is to be first verbal and then when the incident is attended to and under control a written Report is to be prepared by the Employees or Agents to the Plant Manager of Nu-Rock.

This notification would be considered provided when it is given to the designated Plant Manager or the relevant Authority.

RELEVANT INFORMATION TO BE ON THE PIRMP REPORT

1. The written Report after the verbal notification and after the incident has been dealt with and controlled is to include the following information:

• The time, date, nature of incident, duration of the incident and the location of the incident.
• The location on the plant site of Nu-Rock as to where the pollution incident occurred.
• The nature of the incident, the estimated quantity or volume and the concentration of any pollutants.
• The circumstances in which the incident occurs.
• The action taken during and after the incident to deal with the incident and any threatening pollution if it is known.
• And any other information prescribed by the regulation.

2. The information required by this section is the information known to the person notifying the incident when the notification is required to be given.
3. The the Nu-Rock Plant Manager, Employee, Agent or is not know at the time but becomes known afterwards,the information must be notified in accordance with Section 148 after it becomes known.

INCIDENTS NOT REQUIRED TO BE NOTIFIED IN THE PIRMP

A person is not required to notify a pollution incident under Section 148 if the person is aware that the incident has already come to the notice of each person or authority required to be notified.

A person is not required to report an incident under Section 148 if an ordinary result of action required to be taken to comply with an Environment Protection notice or other requirement of or made under this Act.

EPA MAY REQUIRE OTHER NOTIFICATION OF POLLUTION INCIDENTS

1. This Section applies to Nu-Rock as the occupier of the Premises where a pollution incident has occurred in the course of an activity so that material harm to the environment is a caused or threatened.
2. EPA may require the Nu-Rock employees to whom this section applies may be required to notify such incident, as the EPA requires.
3. The direction by the EPA to the Nu-Rock personnel or Agent is not required to be in writing.
4. The direction may specify the manor or form of notifying the pollution incident and the information that must be provided.
5. The direction to the Nu-Rock personnel or Agent may require that an initial verbal notification to be followed by a written notification.
6. A Nu-Rock personnel must not fail to comply with a direction given under this Section.
7. This Section does not extend to a pollution incident where the only emission is an odour.
8. If a direction under this section is given to a Nu-Rock personnel who is carrying out an activity, is engaged as an employee in carrying out an activity, or is the employer of such a person, the obligation under this section are in addition to and not in derogation of, the obligation under Section 148 (except as provided by Section 1 above).

OFFENCE

A person who contravenes this PIRMP will be subject to a penalty in the case of a Corporation a max $2 million and if continuing a further $240,000 per day.

An individual a max $500,000 and if it continues a further $120,000 per day.

INCRIMINATION INFORMATION

1. A person is required to notify of an incident of pollution even if to do so might incriminate the person or make the person liable to a penalty.
2. Any notification given by Nu-Rock personnel under this part is not an admissible in evidence against the personnel for an offence or for the imposition of a penalty.
3. Subsection 2. above does not apply to evidence obtained following or as a result of the notification so long as no legal obligations on the EPA are not abused with regards to the Law of the State of New South Wales.

IDENTIFIED MATERIALS THAT COULD CAUSE AN INCIDENT

The materials covered in this document are listed below in liquids and solid form:

Dry Form Materials-
a. Fly ash
b. Run of station ash
c. Bottom ash
d. Test material such as EAF Dust or PGP
e. Dry Binders NR 3 & NR 4

Protocol for dealing with dry material that are spilled are as follows:
Fly Ash and run of station ash if split while loading of hoppers from drum is the to have the material swept up using a broom and dust pan and feeding the material split into the hopper for this material. Their is no issue with any spoil being picked up with the split ash and it will not affect the use of the ASH.

The Bottom Ash being transported from the Bunker to the hopper by bucket if there is a spillage the Bottom Ash is to be swept up and put back onto the bucket carrying the material.

The Bottom ash can still be used if any spoil is picked up with the Bottom Ash and it has no effect on the ash and its use in the process.

Equipment required pick up material spilled is a broom, square shovel, dust pan and 20 Lt Bucket. It would be possible to use an industrial vacuum if the area is larger than 3 meters square.

It is recommended that protective eye wear and face mask are worn during this procedure and steel capped boots, with long sleeve shirt and long pants.

Liquid Form Materials-
a. NR 1 & NR 2 Binders
b. Hydraulic Oil

These materials if spilt the best and fastest procedure to deal with them if they fall outside of the bundled areas they are contained in during delivery would be to throw Bottom Ash on them and to consolidate the spill so that they stop flowing away.

Leave the Bottom Ash on the liquid that is spilt and then allow 1 hour to dry and then pick up the consolidated materials with a square shovel and a bucket. This material can be put with materials that are rejected products and crushed again and feed into the hopper to reprocess back through the plant. Even if the spillage picks up any form of spoil this is not detrimental to the process of manufacture, and this can
include all material picked up around the plant building that is picked up by sweeping
or hovering can be disposed by throwing them in the Hopper for the Bottom Ash.

This plan is to be kept on the site in the EPA License Folder.

TESTING OF PLAN

This Plan is to be tested with all personnel and if any improvements can be developed with regards to the Plant site specific plant they are to be implemented and added into the PLAN.

This plan is to be checked and revised every 12 months on site and if any alteration and addition is required it is to be updated and implemented as well as a full

IMPLEMENTATION OF PLAN

If a pollution Incident occurs in the course of an activity so that material harm to the environment (within the Section 147) is caused or threatened, the person carrying out the activity must immediately implemented any pollution any pollution incident response management plan in relation to the activity required by this Part.

NU-ROCK PERSONNEL WILL REVIEW THIS PLAN EACH TIME THE ANNUAL WHS IS REVISED AND IMPLIMENTED ON THE PLANT SITE.
…………………………………
MAROUN G. RAHME
Managing Director