Construction Air Quality Management Plan...Construction Air Quality Management Plan Bodangora Wind...

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Construction Air Quality Management Plan Bodangora Wind Farm

JUNE 2017

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Document Verification

Project Title: Bodangora Wind Farm

Construction Air Quality Management Plan

Project Contractor: CATCON Project Number: 16-415 Project File Name: Bodangora Wind Farm CAQMP Revision Date Prepared by (name) Reviewed by (name) Approved by (name)

Draft v1 23/01/2017 J Murphy Erwin Budde Draft v4 16/02/2017 J Murphy Erwin Budde Draft v5 29/03/2017 M Sutherland Nick Graham-Higgs Nick Graham-Higgs Draft v6 2/06/2017 J Murphy M Sutherland Erwin Budde Draft v7 19/06/2017 M Sutherland Nick Graham-Higgs Nick Graham-Higgs

Final 28/06/2017 M Sutherland Nick Graham-Higgs Nick Graham-Higgs

Plan Control

The latest version of this plan will be available on the electronic database for the Project for all Project personnel. Distribution of the plan will be to those detailed in the distribution listing below. This distribution will be by ‘hard copy’ or electronically via email.

Copy Number Issued To Date Name 1 Department of Planning and Environment 2 CATCON Project Manager 3 Infigen Project Manager 4 Environmental Representative 5 Site Environmental Manager 6 TransGrid Project Manager

Change No. Text Change Date 1.

Record each change to the Final document in the table above.

nghenvironmental prints all documents on environmentally sustainable paper including paper made from bagasse (a by-product of sugar production) or recycled paper.

NGH Environmental is a registered trading name of NGH Environmental Pty Ltd; CAN: 124 444 622. ABN: 31 124 444 622.

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CONTENTS 1 INTRODUCTION ........................................................................................................................ 1

1.1 CONTEXT ..............................................................................................................................................1

1.2 BACKGROUND ......................................................................................................................................1

1.3 ENVIRONMENTAL MANAGEMENT SYSTEMS OVERVIEW .....................................................................2

2 PURPOSE AND OBJECTIVES ....................................................................................................... 2

2.1 PURPOSE ..............................................................................................................................................2

2.2 OBJECTIVES ..........................................................................................................................................2

2.3 TARGETS ...............................................................................................................................................2

3 ENVIRONMENTAL REQUIREMENTS ........................................................................................... 3

3.1 RELEVANT LEGISLATION AND GUIDELINES ..........................................................................................3

4 EXISTING ENVIRONMENT ......................................................................................................... 2

4.1 AIR QUALITY .........................................................................................................................................2

4.2 SOIL CHARACTERISTICS ........................................................................................................................2

4.3 RAINFALL ..............................................................................................................................................2

4.4 SENSITIVE RECEIVERS ...........................................................................................................................2

5 EMISSION SOURCES .................................................................................................................. 4

5.1 DUST .....................................................................................................................................................4

5.2 PLANT & VEHICLE EMISSIONS ..............................................................................................................4

5.3 GREENHOUSE GAS REPORTING ............................................................................................................4

6 AIR QUALITY CRITERIA .............................................................................................................. 5

7 ENVIRONMENTAL ASPECTS AND IMPACTS ................................................................................ 6

7.1 CONSTRUCTION ACTIVITIES .................................................................................................................6

7.2 FACTORS LIKELY TO AFFECT DUST GENERATION AND IMPACTS .........................................................6

7.3 IMPACTS ...............................................................................................................................................6

8 ENVIRONMENTAL CONTROL MEASURES ................................................................................... 7

9 COMPLIANCE MANAGEMENT ................................................................................................. 10

9.1 ROLES AND RESPONSIBILITIES ........................................................................................................... 10

9.2 TRAINING .......................................................................................................................................... 10

9.3 MONITORING AND INSPECTION ....................................................................................................... 10

9.4 AUDITING .......................................................................................................................................... 11

9.5 REPORTING ........................................................................................................................................ 11

10 REVIEW AND IMPROVEMENT ................................................................................................. 12

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10.1 CONTINUOUS IMPROVEMENT .......................................................................................................... 12

10.2 CAQMP UPDATE AND AMENDMENT ................................................................................................ 12

APPENDIX A CONSTRAINTS MAPS................................................................................................ 13

APPENDIX B CAQMP CONSULTATION .......................................................................................... 18

Tables

Table 3-1: Location of information in this plan addressing the requirements of CoA E21. (g). ..................... 1

Table 4-1 Summary of rainfall records ............................................................................................................ 2

Table 6-1 Air quality monitoring criteria for deposited dusta ........................................................................ 5

Table 8-1 Air quality management and mitigation measures (blue text = CoA, green text = SoC). .............. 7

Table 9-1 Monitoring requirements ............................................................................................................. 10

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ACRONYMS AND ABBREVIATIONS AHIMS Aboriginal Heritage Management Information System

ANZECC Australian and New Zealand Environment Conservation Council

API Aerial Photo Interpretation

ARA Appropriate regulatory authority

ARI Average recurrence interval

ARR Australian rainfall and runoff

AS Australian Standard

BBAMP Bird and Bat Adaptive Management Program

BWFPL Bodangora Wind Farm Pty Ltd (Proponent)

CATCON CATCON Civil & Allied Technical Construction Pty Ltd

CAQMP Construction Air Quality Management Plan

CBMP Construction Biodiversity Management Plan

CCAMP Construction Compound and Ancillary Facility Management Plan

CCC Community Consultation Committee

CO Carbon monoxide

CoA Consolidated Conditions of Approval, Modification 2

CCR Construction Compliance Report

CEMP Construction Environmental Management Plan

CHMP Construction Heritage Management Plan

CNVMP Construction Noise and Vibration Management Plan

CTAMP Construction Traffic and Access Management Plan

CLM Act Contaminated Land Management Act 1997 (NSW)

Consortium EPC Contract Partnership between CATCON and GE, where both parties are signatories to the EPC Contract. CATCON assumes Lead Contractor role. GE are responsible for supply of towers and turbines. CATCON are responsible for the remainder of works including civil, electrical, substation and installation of towers and turbines.

CSWMP Construction Soil and Water Management Plan

dB(A) decibels “A” weighted

DECC NSW Department of Environment and Climate Change (Now EPA)

DRC Dubbo Regional Council (incorporating Wellington Council)

DPE (NSW) Department of Planning and Environment

EEC Endangered ecological community EA Environmental Assessment, and Modification Reports EIAR Environmental Impact Audit Report EMS Environmental Management System Environmental Auditor

A person with tertiary qualifications, relevant specialist knowledge and experience, and training and experience in verification and/or auditing.

EPA Environment Protection Authority (Previously DECCW and/or OEH)

EP&A Act Environmental Planning and Assessment Act 1979 (NSW)

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EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cwth)

EPL Environment Protection Licence

ER Environmental Representative, reporting to DPE (CoA – E19)

ERSED Erosion and Sediment

EWMS Environmental Work Methods Statement

ESCP Erosion and Sediment Control Plan (aka PESCP)

FM Act Fisheries Management Act 1994 (NSW)

GE GE General Electric International Inc

GEDO Greenhouse and Energy Data Officer

GHG Greenhouse gas

GWh Gigawatt hours

ha Hectares

HSE Advisor Health, Safety, and Environment Advisor

ICNG NSW EPA Interim Construction Noise Guideline

ISEPP State Environmental Planning Policy (Infrastructure) 2007 (NSW)

km Kilometres

kV Kilovolts

m Metres

m3 Cubic metres

ML Megalitre

MW Megawatts

NEPC National Environment Protection Council

NML Noise Management Level

NPW Act National Parks and Wildlife Act 1974 (NSW)

NSW New South Wales

NGER Act National Greenhouse and Energy Reporting Act 2007

NOW NSW Office of Water

NOx Nitrogen oxides

NTSCORP Native Title Services Corporation Limited

NV Act Native Vegetation Act 2003 (NSW)

NW Act Noxious Weeds Act 1993 (NSW)

OOHW Out of hours work

PAH Aromatic hydrocarbons

PCCR Pre-construction Compliance Report

PCT Plant Community Type

PESCP Progressive Erosion and Sediment Control Plan (aka ESCP)

PMP Project Management Plan

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POCR Pre-operation Compliance Report

POEO Act Protection of the Environment Operations Act 1997 (NSW)

QSE Manager Quality, Safety, and Environment Manager

RAV restricted access vehicles

RBL Rating Background Level

RET Scheme Renewable Energy Target Scheme

RFD Rock Filter Dam

RMS Roads and Maritime Services

R[x] Sensitive receiver [number]

SoC Statement of Commitments in Environmental Assessment

SOx Sulphur oxides

Sp./spp. Species/species (plural)

TCP Traffic Control Plans

TSC Act Threatened Species Conservation Act 1995 (NSW)

The Principal Bodangora Wind Farm Pty Ltd (Infigen Energy Development Pty Ltd subsidiary)

The Project Bodangora Wind Farm The Proponent Bodangora Wind Farm Pty Ltd

VOC Volatile organic compounds WTG [xx] Wind turbine generator [unit number]


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1 INTRODUCTION

1.1 CONTEXT

This Construction Air Quality Management Plan (CAQMP) forms part of the Construction Environmental Management Plan (CEMP) for Bodangora Wind Farm (the Project).

This CAQMP has been prepared to address the requirements of:

• Department of Planning and Environment (DPE) consolidated Conditions of Approval (CoA) Modification 2 (December 2016)

• all applicable legislation, during the construction of the Project • mitigation and management measures listed in the Statement of Commitments (SoC) in the

Bodangora Wind Farm Environmental Assessment (EA)

CoA E21 states: As part of the Construction Environmental Management Plan for the Project required under condition E20 the Proponent shall prepare and implement:

(g) a Construction Air Quality Management Plan to detail how construction impacts on air quality will be minimised and managed. The Plan shall include, but not necessarily be limited to:

a. the identification of potential sources of dust;

b. dust management objectives;

c. mitigation measures to be implemented, including measures during weather conditions where high dust level episodes are probable (such as strong winds in dry weather);

d. a monitoring program to assess compliance with the identified objectives; and

e. mechanisms for the monitoring, review and amendment of this Plan.

1.2 BACKGROUND

Bodangora Wind Farm Pty Ltd (BWFPL), a subsidiary of Infigen Energy Development Pty Ltd, received planning approval for the construction and operation of a wind farm and ancillary infrastructure at Bodangora, in central west New South Wales (NSW). The Project is a State Significant Development project and environmental initiative that represents an important contribution to renewable energy generation in New South Wales.

The EA for Bodangora Wind Farm summarised the key findings of the assessment of the impacts of the construction and operation of the Project on air quality. It identified the potential for minor impacts on air quality during construction typically associated with dust and emissions from machinery. The main sources of dust are construction earthworks, wind erosion of exposed surfaces and temporary stockpiling of materials, transport of large amounts of equipment and materials, and drilling/explosive operations. The EA concluded that given the scale of the Project and existing farming activities such as the ploughing of fields, it is expected that dust generated by construction of the wind farm can be effectively managed and will form only a minor contribution to air emissions in the wider region. The EA also proposed the implementation of mitigation and management measures to minimise these impacts.

A Consortium has been awarded the contract to construct the Project. The Consortium comprises an EPC Contract Partnership between CATCON and GE, where both parties are signatories to the EPC Contract, with CATCON being the Lead Contractor. GE are responsible for the supply of towers and turbines, while


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CATCON are responsible for the remainder of works including civil, electrical, substation, and installation of towers and turbines. The switchyards and overhead powerlines will be constructed by TransGrid. All TransGrid staff and contractors will be inducted into and operate under this CEMP.

This CAQMP describes the environmental management measures CATCON will implement during the construction work.

1.3 ENVIRONMENTAL MANAGEMENT SYSTEMS OVERVIEW

The overall Environmental Management System (EMS) for construction of the Project is described in the CEMP. This CAQMP is part of the environmental management framework for the Project. Mitigation and management measures identified in this CAQMP will be incorporated into site or activity specific Environmental Work Method Statements (EWMS) or Procedures.

Used together, the CEMP, CAQMP and other sub-plans, procedures and EWMS form management guides that clearly identify required environmental management actions for reference by CATCON personnel and contractors.

The review and document control processes for this plan are described in the CEMP.

2 PURPOSE AND OBJECTIVES

2.1 PURPOSE

The purpose of this plan is to describe how impact on air quality will be minimised and within the scope permitted by the planning approval during construction of the Project.

2.2 OBJECTIVES

The key objective of the CAQMP is to ensure that impacts to air quality are minimised and within the scope permitted by the planning approval. To achieve this objective, the following will be undertaken:

• Ensure appropriate controls and procedures are implemented during construction activities to avoid or minimise impacts on air quality

• Ensure appropriate measures are implemented to address the mitigation measures detailed in the EA and CoA

• Ensure appropriate measures are implemented to comply with all relevant legislation and other requirements as described in section 3.1 of this plan

2.3 TARGETS

The following targets have been established for the management of air quality impacts during the Project:

• Full compliance with the relevant legislative requirements • Full compliance with relevant requirements of the EA and CoA • No dust complaints from sensitive receivers • Minimisation of soil exposure within the project area


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3 ENVIRONMENTAL REQUIREMENTS

3.1 RELEVANT LEGISLATION AND GUIDELINES

3.1.1 Legislation

Legislation relevant to air quality management includes:

• Environmental Planning and Assessment Act 1979 (EP&A Act) • Protection of the Environment Operations Act 1997 (POEO Act) • National Greenhouse and Energy Reporting Act 2007

Relevant provisions of the above legislation are explained in the register of legal and other requirements included in section 3 and Appendix A of the CEMP.

3.1.2 Guidelines and standards

The main guidelines, specifications and policy documents relevant to this plan include:

• National Environment Protection Council’s (NEPC) National Environment Protection Measure for Ambient Air Quality guidelines

• Protection of the Environment Operations (Clean Air) Regulation, 2002 • Australian Standard (AS) 2922 Ambient Air Guide for Citing of Sampling Equipment • AS 3580.10.1-1991 Methods of Sampling Analysis of Ambient Air • Action for Air 1998 (NSW DEC) • Approved Methods & Guidance for the Modeling & Assessment of Air Pollutants in NSW (2005) • Approved Methods for the Sampling and Analysis of Air Pollutants in New South Wales (DEC 2006) • Air Quality Monitoring Criteria for Deposited Dust (DEC Guideline)

3.1.3 Conditions of approval

CoA E1 states: The Project shall be constructed in a manner that minimises dust emissions from the site, including wind-blown and traffic-generated dust and tracking of material onto public roads. All Project related activities on the site shall be undertaken with the objective of preventing visible emissions of dust from the site. Should such visible dust emissions occur at any time, the Proponent shall identify and implement all feasible and reasonable dust mitigation measures, including cessation of relevant works as appropriate such that emissions of visible dust cease.

CoA E14 states: Where available, and of appropriate chemical and biological quality, stormwater, recycled water or other water sources shall be used in preference to potable water for construction activities, including concrete mixing and dust control.

CoA E21 requires the Construction Environmental Management Plan (CoA E20) to have a Construction Air Quality Management Plan to detail how construction impacts on air quality will be minimised and managed. The requirements of CoA 21 subsection G are addressed in this plan (Table 3-1).


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CoA Condition requirement Location E21. (g) a Construction Air Quality Management Plan to detail how construction

impacts on air quality will be minimised and managed. Including: This plan

E21. (g) i the identification of potential sources of dust S. 5.1 E21. (g) ii dust management objectives S. 2.2, S. 6 E21. (g) iii mitigation measures to be implemented, including measures during

weather conditions where high dust level episodes are probable (such as strong winds in dry weather)

S. 8

E21. (g) iv a monitoring program to assess compliance with the identified objectives; and S. 9.3 E21. (g) v mechanisms for the monitoring, review and amendment of this Plan S. 10

Table 3-1: Location of information in this plan addressing the requirements of CoA E21. (g).


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4 EXISTING ENVIRONMENT The following sections summarise what is known about factors influencing air quality within and adjacent to the project corridor.

4.1 AIR QUALITY

The existing air quality in the local area can vary with the seasons in response to airborne particulate matter associated with windy and dusty conditions, and events such as bushfires. Sources of air pollution include agricultural activities, including the ploughing of fields and the spraying of crops during drier conditions, and to a limited extent highway vehicle emissions from the Mitchell Highway around 12 kilometres (km) from the site.

4.2 SOIL CHARACTERISTICS

The Project is located on flat to gently sloping ground with steeper slopes on the sides of valleys, which have been avoided in most cases. The Project is primarily underlain by deep alluvial loams and shallow loams, often stony and/or sandy. Overall, existing instances of erosion are rare, and for most parts of the site substantial grass cover is present.

4.3 RAINFALL

Dust generation is a particular impact where there are low levels of soil moisture, most common during summer due to a combination of lower rainfall and higher evaporation. Due to the moderate rainfall in the region and reasonable grass cover, there is less likelihood of airborne dust than for other, drier parts of NSW.

The rainfall records from Wellington (D&J Rural) have been selected to reflect the potential rainfall conditions across the project area as the closest weather station to the site. A summary of the rainfall records from the Bureau of Meteorology is provided in Table 4-1.

Table 4-1 Summary of rainfall records

Summer/Autumn Winter/Spring

Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Year

Mean rainfall (mm)

56.2 59.7 51.8 50.6 45.1 47.5 51.5 49.6 48.9 45.1 55.7 58.0 616.1

4.4 SENSITIVE RECEIVERS

Sensitive residential receivers are shown in the constraints map in Figure 4-1. Closeups of this map are presented in Appendix A. High resolution constraint maps provided electronically as PDFs and shape files to design and construction teams.


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Figure 4-1: Overall Constraints in project area, additional map inset in Appendix A.


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5 EMISSION SOURCES The EA assessed the impacts of construction of the Project on air quality and identified the potential for minor impacts on air quality during construction from dust and emissions from machinery and vehicles. Any impacts are likely to be short-term and mainly associated with and limited to construction activity.

5.1 DUST

The major source of particulate matter is dust. The main sources of dust are construction earthworks including wind erosion of exposed surfaces and temporary stockpiling of materials, transport of large amounts of equipment and materials, and drilling/explosive operations. These can potentially impact local air quality. The EA concluded that given the scale of the Project and existing farming activities such as the ploughing of fields, it is expected that dust generated by construction of the wind farm can be effectively managed and will form only a minor contribution to air emissions in the wider region.

5.2 PLANT & VEHICLE EMISSIONS

Another major source of particulate matter from construction sites are those generated from operating vehicles and machinery. Diesel–fired engines emit particulate matter (soot), gaseous emissions, and greenhouse gases, such as carbon monoxide (CO), sulphur oxides (SOx), nitrogen oxides (NOx) and organic compounds including aromatic hydrocarbons (PAHs) and Volatile organic compounds (VOCs).

Every practicable effort shall be made by site personnel to conserve energy and reduce greenhouse gas emissions as a result of construction activities. Whilst the release of carbon dioxide and other pollutants are unavoidable, all plant, equipment and all vehicles must be operated in the correct manner and maintained to manufacturer specifications.

5.3 GREENHOUSE GAS REPORTING

The basic requirement of National Greenhouse & Energy Reporting (NGER) is that the controlling corporation of a corporate group whose members have operational control over facilities that meet certain Greenhouse Gas (GHG) emission, energy consumption and energy production thresholds, must register with, and then report annually, to the Greenhouse and Energy Data Officer (GEDO) within the Commonwealth Government.

CATCON is below the specified thresholds, so reporting of GHG emissions, energy consumption and energy production is not required.


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6 AIR QUALITY CRITERIA The Environment Protection Agency (EPA) sets goals for ambient dust concentrations and dust deposition, which is a measure of the impacts of nuisance (EPA 2001).

The acceptable increment in annual average dust deposition depends on the existing deposition level. These are based on research by Dean (1990) and other investigations, which detail community response to dust fallout. It should be remembered that the air quality goals relate to the total dust burden in the air and not just the dust from the Project. In other words, there needs to be some consideration of background levels when using these goals to assess impacts.

Table 6-1 details the air quality monitoring criteria for deposited dust.

Table 6-1 Air quality monitoring criteria for deposited dusta

Pollutant Annual concentration Source

Deposited dustb 2 g/m2/monthc 4 g/m2/monthd NERDDC (1998)

Note:

a. Adapted from DECCW guideline; Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (DECCW 2005).

b. Dust is assessed as insoluble solids as defined by AS 3580.10.1-1991 (AM-19). c. Maximum increase in deposited dust level. This is the maximum increase in dust deposition in a month over the amount of dust

deposited in the previous month d. Maximum total deposited dust level. This is the maximum amount of dust that can be deposited in any month.


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7 ENVIRONMENTAL ASPECTS AND IMPACTS

7.1 CONSTRUCTION ACTIVITIES

Construction activities that have the potential to cause adverse impacts to air quality include:

• Generation of dust particles during earthworks and other construction activities • Air blast drilling in preparation for rock anchors, which can be associated with dust plumes • Clearing of vegetation • Transport of soil and fill by trucks and other construction vehicles • Wind erosion from unsealed surfaces and stockpiles • Wheel generated dust by construction vehicles travelling along unsealed tracks • Vehicle emissions from plant and machinery

7.2 FACTORS LIKELY TO AFFECT DUST GENERATION AND IMPACTS

In addition to the inherent risks of specific construction activities creating the potential to generate dust, a number of other environment factors also affect the likelihood of dust emissions. These include:

• Wind direction – determines whether dust and particles are transported towards sensitive receivers

• Wind speed – governs the potential suspension and drift resistance of particles • Soil type - more erodible soil types have an increased soil or dust erosion potential • Soil moisture – increased soil moisture reduces soil or dust erosion potential • Rainfall or dew –wets the surface of the soil and reduces the risk of dust generation

7.3 IMPACTS

The potential for impacts on air quality will depend on a number of factors. Impacts will primarily be dependent on the nature, extent and magnitude of construction activities and their interaction with the natural environment. Potential impacts attributable to construction might include:

• Impacts on water quality and/or vegetation health from dust deposition • Aesthetic effects that arise from visible airborne dust plumes and from deposits of dust on surfaces • Potential adverse health effects including eye, nose and throat irritation from excessive inhalation

of fine particles • Impacts on residential sensitive receivers, including impacts on living areas, swimming pools and

general amenities • Deposition of dust on surfaces where it may cause damage and/or lead to a need for increased

cleaning or repair • Need for increased maintenance of air filtering systems (e.g. air conditioners, etc.)

Section 8 provides a suite of mitigation measures that will be implemented to avoid or minimise those impacts.


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8 ENVIRONMENTAL CONTROL MEASURES A range of environmental requirements and control measures are identified in the EA and CoA. Specific measures and requirements to address impacts on air quality are outlined in Table 8-1 (blue text = CoA, green text = SoC).

Table 8-1 Air quality management and mitigation measures.

Measure / Requirement Resources needed

When to implement

Responsibility Reference

GENERAL Training will be provided to all Project personnel, including relevant sub-contractors on sound air quality control practices and the requirements from this plan through inductions, toolboxes and targeted training.

Induction package Toolbox training material Targeted training material

Pre-construction Construction Operation

HSE Advisor (CATCON) CEMP Section 5

PRE-CONSTRUCTION As part of the CEMP for the Project required under condition E20, the Proponent shall prepare and implement a Construction Air Quality Management Plan to detail how construction impacts on air quality will be minimised and managed.

This plan Pre-construction

CATCON CAQMP

CONSTRUCTION Topsoil suitable for stripping and re-use in revegetation will be stockpiled:

• stockpiles will be clearly identified; • stockpile locations will be selected free of traffic and away from drainage lines and watercourses; • stockpiles will be managed to minimise erosion and loss of topsoil, with surface stabilisation

to prevent wind erosion where necessary.

Stockpile location ID plan Stockpile signage Mulching/seeding of stockpile. Geo-fabric lining of stockpiles Maximum stockpile height of 2 m Stockpiles surfaces made smooth

Pre-construction Construction

CATCON Relevant EWMS PESCP


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When to implement


The Project shall be constructed in a manner that minimises dust emissions from the site, including wind-blown and traffic-generated dust and tracking of material onto public roads. All Project related activities on the site shall be undertaken with the objective of preventing visible emissions of dust from the site. Should such visible dust emissions occur at any time, the Proponent shall identify and implement all feasible and reasonable dust mitigation measures, including cessation of relevant works as appropriate such that emissions of visible dust cease (CoA E1).

This plan Toolbox training material Dust management Surveillance

Construction HSE Advisor CATCON

CAQMP

Earthworks: • rolling and wetting of access tracks with water as necessary to compact loose soil exposed

during track formation; • the application of an approved wetting agent to exposed soils during dry and windy periods; • the capping of access tracks with gravel to suit the track usage requirements and to limit dust

generation; • the stabilisation of exposed soils and stockpiles; • the placement of stockpiles in locations sheltered from wind and surface water flows as necessary;

and • the rehabilitation of disturbed areas as soon as possible.

Rollers/water carts Wetting agent Gravels/seal roads Mulching/seeding of stockpiles Geo-fabric lining of stockpiles Maximum stockpile height of 2 m Stockpile surfaces made smooth Covered vehicles for material transport Restriction of traffic to completed road where possible Limit area of construction footprint to minimum area necessary for safe conduct of work

Construction CATCON Relevant EWMS PESCP

With regard to drilling for rock anchor installations: • rock anchors may be required to ensure stability of the turbine footings; • air blast drilling in preparation for rock anchors will be subject to controls to avoid dust plumes; and • dust filters and/or mist sprays will be applied to control any dust resulting from the air blast drilling.

Water carts Wetting agent Dust filters

Construction CATCON Relevant EWMS


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When to implement


All construction vehicles will be registered vehicles that are required to maintain the necessary emission controls.

Plant register Inspections Switch vehicles off when not in use and minimise idling

Construction CATCON CAQMP

Local water supplies will be used for dust control management measures, and will be balanced between the amount of available water supply and the severity of dust events, in consultation with the Wellington Shire Council and the DECCW Guidelines.

Farm dams Sediment ponds Standpipes


Where available, and of appropriate chemical and biological quality, stormwater, recycled water or other water sources shall be used in preference to potable water for construction activities, including concrete mixing and dust control.

Water testing as required



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9 COMPLIANCE MANAGEMENT

9.1 ROLES AND RESPONSIBILITIES

The Project Team’s organisational structure and overall roles and responsibilities are outlined in section 4.2 of the CEMP.

9.2 TRAINING

All employees, contractors and utility staff working on site will undergo site induction training relating to air quality management issues. Targeted training in the form of toolbox talks or specific training will also be provided to personnel with a key role in air quality management. Further details regarding staff induction and training are outlined in the CEMP.

9.3 MONITORING AND INSPECTION

Dust emissions will be visually monitored by site workers during the works. Any observations of dust being blown from the site should be reported to the Site Construction Manager for recording and appropriate action. Monitoring requirements are provided in Table 9-1 Monitoring requirements.

Table 9-1 Monitoring requirements

Item Frequency Applicable standards/comments Responsibility Reporting

Site observations Daily Dust not excessive. Control measures in place.

Site Construction Manager

Diary

Weather forecast check

Daily Planning and preparation for adverse weather conditions

Site Construction Manager

Daily Prestart Meeting and in Daily Diary

Weekly environmental site inspection

Weekly Dust not excessive. Effective control measures in place.

HSE Advisor Weekly Environmental Checklist

Dust deposition monitoring

As required for complaint resolution

4 g/m2/month total deposited dust

2 g/m2/month maximum increase in deposited dust compared to previous month

Approved methods for the sampling and analysis of air pollutants in NSW (DECCW, 2007)

HSE Advisor in consultation with the Environmental Representative

Incorporate into monthly Environmental Report

Requirements and responsibilities in relation to monitoring and inspections are documented in the CEMP.


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9.4 AUDITING

Audits (both internal and external) will be undertaken to assess the effectiveness of environmental controls, compliance with this sub-plan and other relevant approvals, licenses and guidelines. Audit requirements are detailed in Section 8 of the CEMP.

9.5 REPORTING

Reporting requirements and responsibilities are documented in the Section 8 of the CEMP. Any additional mitigation or management measures will be incorporated into Section 8 of this plan as required.


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10 REVIEW AND IMPROVEMENT

10.1 CONTINUOUS IMPROVEMENT

Continuous improvement of this plan will be achieved by the ongoing evaluation of environmental management performance against environmental policies, objectives and targets to identify opportunities for improvement, as detailed in Section 9.1 of the CEMP.

10.2 CAQMP UPDATE AND AMENDMENT

This CAQMP will need to be revised whenever the construction program, scope of work, or work methods change, whenever the work methods and control structures are found to be ineffective, or if so directed by the Principal. This will occur as needed and in accordance with the process outlined in Section 9.2 of the CEMP.


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APPENDIX A CONSTRAINTS MAPS High resolution constraint maps are provided electronically as PDFs and shape files to design and construction teams.


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Figure 10-1: Constraints map of sector 1, south-western project area (draft map).


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Figure 10-2: Overall constraints map of sector 2, north-western project area


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Figure 10-3: Constraints map of sector 3, central project area.


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Figure 10-4: Constraints map of sector 4, south-eastern project area (draft map).


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APPENDIX B CAQMP CONSULTATION Draft plan sent to the Central West office of the NSW EPA 18 May 2017

A response was received from the EPA on the 31 May 2017

Issue ID

EPA Comment/Issue Response

1

The EPA encourages the development of management plans to ensure that proponents have determined how they will meet their statutory obligations and environmental objectives as specified by any planning approval and/or conditions of an environmental protection licence. Please note the EPA does not review or endorse these documents as our role is to set environmental objectives for environmental management, not to be directly involved in the development strategies to achieve these objectives.

Noted

2

The proponent must ensure all activities at the premise are carried out in a manner that ensures compliance with the Protection of the Environment Operations Act 1997 (POEO) and its associated regulations. The premise will be regulated by an Environment Protection Licence (EPL) and a draft was sent to the proponent for comment on 3 May 2017. Please not that no scheduled development works can be started until EPL is issued by the EPA and requirements of the EPL must be complied with at all times

Construction environmental management planning for the project has considered the POEO Act and the need for an EPL. The Final EPL requirements will be incorporated into the management documents when received.


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Department of Planning and Environment Review 14 June 2017 Response to recommended action recorded in Green

Construction Air Quality Management Plan

Condition E21(g), Schedule E

Satisfactory

(Yes/No)

Comment

Recommended Action

(g) a Construction Air Quality Management Plan to detail how construction impacts on air quality will be minimised and managed. The Plan shall include, but not necessarily be limited to:

Yes Construction Air Quality Management Plan (CAQMP) (Draft Version 6) submitted on 6 June 2017. Evidence of consultation with EPA provided in Appendix B. EPA provided comments on 31 May 2017. Minor comments not directly relevant to the CAQMP. Consultation table in Appendix B incomplete.

• Complete table in Appendix B. Formatting error when converting to pdf, now corrected

i. the identification of potential sources of dust;

Yes Dust sources identified in Section 5. Nil

ii. dust management objectives;

Yes Objectives provided in Section 2.2. Nil

iii. mitigation measures to be implemented, including measures during weather conditions where high dust level episodes are probable (such as strong winds in dry weather);

Yes Control measures provided in Table 8-1. Considered adequate.

Nil

iv. a monitoring program to assess compliance with the identified objectives; and

Yes Dust monitoring described in Section 9.3. Considered adequate.

Nil

v. mechanisms for the monitoring, review and amendment of this Plan.

Yes Review and improvement of plan described in Section 10.

Nil

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