Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 601
Title: PRP 2 - Site Water Management Improvements
Start date: 04 Mar 2013
 
Licence Condition
The licensee must prepare a feasibility report on reasonable and feasible improvements to the site water management system operating at the premises to increase on-site containment capacity and to reduce the annual discharged load via Discharge Point 11 to the Hunter River. The feasibility report must be submitted to the EPA's Regional Manager - Hunter at PO Box 488G, Newcastle NSW 2300. Date for completion: 31 July 2013
Audit purpose Subject to conditions E2.2 - E2.20 below, the licensee must engage an auditor to undertake a mandatory environmental audit (“the Audit”).  The purpose of the Audit is to: a)  provide information to the licensee about the adequacy of its systems to comply with regulatory requirements including compliance with the Act and licence conditions in order to: •  prevent the occurrence of sewage overflows from rising mains and minimise the community and environmental health risks posed by these sewage overflows; •  prevent the occurrence of sewage overflows from sewage pumping stations caused by failure and minimise the community and environmental health risks posed by these sewage overflows; and b)  identify improvements to be made by the licensee so that the licensee’s systems in place for managing sewage pumping stations and rising mains comply with the regulatory requirements including under the Act and licence conditions.
Independent Auditor The licensee must engage a suitably qualified and experienced independent certified environmental auditor (the “Auditor”). The Auditor may obtain the services of additional Auditor/s and relevant technical experts. At a minimum, the Auditor and team members must comprise of expertise in the areas of sewage and environmental engineering, logistics and systems auditing. It is noted that the EPA encourages the licensee to consider relevant international as well as national expertise. The Auditor and team members must be approved of in writing by the EPA before being engaged.
By 2 December 2022, the licensee must provide the EPA by email addressed as “ATTENTION Manager ROMS” to info@epa.nsw.gov.au and copied to metrowater.infrastructure@epa.nsw.gov.au,with the details of at least three Auditors (and team members) that are suitably qualified to undertake the Audit under condition E2.6 - E2.14. The licensee may identify a preferred Auditor and team to undertake the Audit. For the purposes of this condition, the licensee must provide the EPA with the following details for the Auditor and each proposed team member: •  name; •  contact details; •  the area in which they have expertise; •  relevant qualifications; •  relevant experience; and •  availability.
The EPA will approve an Auditor and team and advise the licensee in writing. The licensee must engage the approved Auditor team within two weeks after the EPA’s approval.
Within five weeks of engagement of the Auditor and team, the licensee must arrange for the Auditor and their team to meet with the EPA to discuss the background and context for the Audit.
The requirement to prepare an audit in relation to this licence can be satisfied by the licensee providing a single combined report that addresses issues relevant to each of the 23 licences the subject of these mandatory audit requirements.
In relation to systems currently in place for managing and operating sewage pumping stations and rising mains, the Audit must: •  detail and examine those systems and the licensee’s adherence to those systems; •  detail and examine any deficiencies in those systems and the licensee’s adherence to those systems; and •  make recommendations and conclusions in respect of the following (E2.8 - E2.14), without limitation:
Construction and design a.  systems for considering the following in the construction and design of new upgraded or replacement sewage pumping stations and rising mains:          i.  locational, environmental, and operational risk factors, including capacity of pumping stations and rising mains to account for future state planning needs;          ii.  future maintenance and resource requirements;          iii.  redundancy; b.  systems for ensuring the construction and design of new, upgraded or replacement sewage pumping stations and rising mains comply with relevant design and construction standards; c.  systems for ensuring quality control and quality assurance for new, upgraded or replacement sewage pumping stations and rising mains to comply with relevant standards; d.  adequacy of the systems in place for constructing and designing new, upgraded or replacement sewage pumping stations and rising mains including those at a.- c. to meet the regulatory requirements at condition E2.1. e.  adequacy of the systems in place for constructing and designing new, upgraded or replacement sewage pumping stations and rising mains including those at a.- c. to meet best international practice, codes of practice and relevant policies relating to the protection of the environment and human health.
Operation f.  the licensee’s requirements for staff competency in relation to operating rising mains and pumping stations, including staff training by the licensee; g.  adequacy of the systems for operating sewage pumping stations and rising mains in a manner which reduces risk factors related to failure, prevents the occurrence of sewage overflows and minimises the human health and environmental impact of resultant sewage overflows; h.  adequacy of the systems for operating sewage pumping stations and rising mains to meet the regulatory requirements at condition E2.1; i.  adequacy of the operating systems for sewage pumping stations and rising mains to meet best international practice, codes of practice and relevant policies relating to the protection of the environment and human health.
Assessment of condition j.  systems for identifying the need to undertake condition assessment for sewage pumping stations and rising mains including methodology, timeliness, frequency, resource and financial allocation towards condition assessment and amongst different condition assessment activities; k.  systems for planning and scheduling for short, medium and long term condition assessment for sewage pumping stations and rising mains including methodology, timeliness, frequency and, resource and financial allocation at the level of the officer staff overseeing condition assessment activities and at the business level of staff overseeing remedial activities, resource supply and, financial allocation; l.  systems for undertaking condition assessment of rising mains and sewage pumping stations including methodology, timeliness, frequency and, resource and financial allocation; m.  technology and techniques used to undertake condition assessment; n.  systems to develop better technology and improved techniques to undertake condition assessment on sewage pumping stations and rising mains; o.  systems for planning and undertaking of follow-up actions for sewage pumping stations and rising mains when condition assessment results are received, in particular what processes are followed when a condition assessment identifies recommendations, makes conclusions or proposes improvements or identifies that risk of failure factors have changed; p.  systems for prioritising assessment of condition activities against both:         •  other rising main and sewage pumping station assets; and         •  other licensee plant systems and works; q.  adequacy of the systems, technology and techniques including those at j.-p. for undertaking condition assessment for rising mains and pumping stations to reduce risk factors related to failure, prevent sewage overflows and minimise the human health and environmental impact of resultant sewage overflows; r.  adequacy of the systems, technology and techniques including those at j.-p. for undertaking condition assessment for rising mains and pumping stations to meet the regulatory requirements at condition E2.1. s.  adequacy of the systems, technology and techniques at j.-p. for condition assessment of rising mains and pumping stations to meet best international practice, codes of practice and relevant policies relating to the protection of the environment.
Remedial activities t.  systems for identifying remedial activities needs including methodology, timeliness, frequency and, resource and financial allocation; u.  systems for planning and scheduling for short, medium and long term remedial activities for sewage pumping stations and rising mains including methodology, timeliness, frequency and, resource allocation, at the level of the officer staff overseeing remedial activities and at the business level of staff overseeing remedial activities, resource supply and, financial allocation; v.  systems for undertaking remedial activities including methodology, technology, timeliness, frequency and, resource and financial allocation; w.  technology and techniques used to undertake remedial activities for sewage pumping stations and rising mains; x.  systems to develop better technology and improved techniques to undertake remedial activities on sewage pumping stations and rising mains; y.  systems for considering all relevant risk factors related to failure of sewage pumping stations and rising mains in identifying and undertaking remedial activities; z.  systems for prioritising remedial activities for rising mains and sewage pumping stations against both:         •  other rising main and sewage pumping station assets; and         •  other licensee plant systems and works; aa.  systems for updating remedial schedules and plans when relevant and new or previously unaccounted for information is identified; bb.  the adequacy of systems for remedial activities for sewage pumping stations and rising mains including those at t.-aa. to reduce risk factors related to failure, prevent sewage overflows and minimise the human health and environmental impact of resultant sewage overflows; cc.  the adequacy of systems for remedial activities for sewage pumping stations and rising mains including those at t.-aa. to meet the regulatory requirements at condition E2.1. dd.  the adequacy of systems for remedial activities for sewage pumping stations and rising mains including those at t.-aa. to meet best international practice, codes of practice and relevant policies relating to the protection of the environment.
Contingency planning and response ee.  the systems for contingency planning and response to prevent a sewage overflow after failure occurs for sewage pumping stations and rising mains including:          i.  the timeliness and availability of resources and information about contingency planning and response;          ii.  the licensee’s requirements for staff competency in relation to responding to failures of rising mains and pumping stations, including staff training by the licensee; ff.  after a sewage overflow occurs from a sewage pumping station or rising main, the systems for contingency planning and response to minimise the volume of sewage discharged to the environment and minimise environmental/human health impacts including:          i.  the timeliness and availability of resources and information about contingency planning and response;          ii.  the licensee’s requirements for staff competency in relation to responding to failures of rising mains and sewage pumping stations, including staff training by the licensee; gg.  the systems for contingency planning before failure occurs in a sewage pumping station and rising main to:          i.  identify risk factors;          ii.  identify asset failure scenarios;          iii.  test and update plans; hh.  the adequacy of systems for contingency planning and response to prevent a sewage overflow after failure occurs for sewage pumping stations and rising mains to meet the regulatory requirements at condition E2.1; ii.  the adequacy of systems for contingency planning and response to minimise the volume of sewage discharged to the environment and minimise environmental/human health impacts after a sewage overflow from a sewage pumping station or rising main occurs, to meet the regulatory requirements at condition E2.1; jj.  the adequacy of systems for contingency planning before failure occurs in a sewage pumping station or rising main to meet the regulatory requirements at condition E2.1; kk.  the adequacy of systems for contingency planning and response to prevent a sewage overflow after failure occurs in sewage pumping stations and rising mains to meet best international practice, codes of practice and relevant policies relating to the protection of the environment; ll.  the adequacy of systems for contingency planning and response to minimise the volume of sewage discharge to the environment and minimise environment and human health impacts after a sewage overflow occurs from a sewage pumping station and rising mains to meet best international practice, codes of practice and relevant policies relating to the protection of the environment mm.  the adequacy of systems for contingency planning before failure occurs or issue arises in a sewage pumping station or rising main to meet best international practice, codes of practice and relevant policies relating to the protection of the environment.
Risk assessment and risk management nn.  the systems to undertake risk assessment/s including methodology, data sources and significance weightings given to components of the risk assessment to determine and manage the risk and consequence of failure; oo.  the systems to review and update risk assessment/s including methodology, data sources, frequency and timeliness; pp.  the systems for using risk assessment information for contingency planning qq.  the systems for implementing action to mitigate risks; rr.  the adequacy of the risk assessment systems including those at nn.-qq. to account for all relevant risk factors which could contribute to failure including (but not limited to) infrastructure characteristics, sewage characteristics, environmental conditions, locational, redundancy, accessibility and operational risk factors; ss.  adequacy of risk assessment and risk management systems including those at nn.-qq.  to reduce risk factors related to failure, prevent sewage overflows and minimise the human health and environmental impact of resultant sewage overflows; tt.  adequacy of risk assessment and risk management systems including those at nn.-qq. for rising mains and sewage pumping stations to meet the regulatory requirements at condition E2.1; uu.  the adequacy of risk assessment/s process to enable the licensee to prioritise and make decisions about rising main and sewage pumping station condition assessment and remedial activities.
Recommendations vv.  Recommendations for any improvements that the licensee should make so that its rising mains and pumping stations are operated and managed:         i.  in accordance with best international practice and best available technology;         ii.  in a manner which prevents future rising main and sewage pumping station failures and resultant sewage overflows;         iii.  in a manner so that they are not carried on in an environmentally unsatisfactory manner;         iv.  in order to meet the regulatory requirements at condition E2.1. ww.  Recommendations for a broad strategic plan that the licensee should undertake for improvements made under vv., in time frames of less than 5 years, 10 years, 20 years and 30 years plus.
The licensee must instruct the Auditor to prepare a draft environmental audit report (“Draft Audit Report”), being a single, combined report prepared by the Auditor, which includes: a)  all of the matters described in conditions E2.1, E2.6 and E2.7 - E2.14; b)  a list of documents considered and reviewed, including any of the licensee procedures specifically referenced in the Draft Audit Report; c)  names, roles and organisations of personnel interviewed by the Auditor (including their team members) in preparing the Draft Audit Report; d)  the two declarations required under Section 176 of the Act; and e)  a summary of the Audit including the conclusions and recommendations, in electronic format so it can be entered into the Public Register (as required by section 308 of the POEO Act).
The licensee must instruct the Auditor to provide the Draft Audit Report to the EPA by email addressed as “ATTENTION Manager ROMS” to info@epa.nsw.gov.au and copied to metrowater.infrastructure@epa.nsw.gov.au, within 6 months of the date of the EPA’s written approval of the Auditor and at the same time as, or before, the Draft Audit Report is provided to the licensee.
The licensee must ensure the Draft Audit Report is updated by the Auditor to address any comments made by the EPA.
The licensee must submit the Final Audit Report to the EPA by email addressed as “ATTENTION Manager ROMS” to info@epa.nsw.gov.au and copied to metrowater.infrastructure@epa.nsw.gov.au, no later than one month after receipt of the EPA’s comments on the Draft Audit Report. A PDF version of the report is to be provided.
The licensee must submit an Audit Implementation Report to the EPA by email addressed as “ATTENTION Manager ROMS” to info@epa.nsw.gov.au and copied to metrowater.infrastructure@epa.nsw.gov.au, by no later than 3 months after receipt of the Final Audit Report.
The Audit Implementation Report must: a) identify what actions the licensee proposes to take in response to the Audit Report; b) propose a timeframe for these action(s); and c) provide an explanation for the licensee’s proposals where there is any variance from the recommendations of the Auditor in the Final Auditor Report.
Mandatory Environmental Audit Dictionary For the purposes of conditions E2.1 to E2.20 the following definitions apply: Rising main means: a sewer pressure main which transfers sewage collected by sewage pumping station to a point of discharge such as a gravity sewer main or sewage treatment plant between the last valve inside a pumping station site and the discharge point. Sewage pumping station means: a structure which controls the transport of sewage through the sewer pipes, where steep hills and other variations in the land topography can prevent or limit the gravity flow of sewage to the sewage treatment plant. The sewage pumping station includes infrastructure from the collecting manhole to the start of the rising main and all infrastructure relevant to the function of the sewage pumping station. Environmentally unsatisfactory manner means: the definition as specified in section 95 of the Act. Systems means: the licensee’s interacting or interdependent policies, plans, procedures, practices, processes, standards, strategies and resources (not limited to those) which are currently in place for managing and operating sewage pumping stations and rising mains. Condition assessment means: activities undertaken for the purpose of determining the condition of an asset. This includes (but is not limited to) activities undertaken to identify whether there are any leaks or defects on an asset, activities undertaken to determine how much life the asset has left, and activities to decide upon preventative maintenance or remedial work to extend its life or replacement of the asset. Remedial activities means: activities related to maintenance, repair, renewal, upgrade and redundancy upgrades. Failure means: an issue which inhibits or prevents normal operation of a sewage pumping station or rising main which could lead to sewage overflows.
Audit Scope
Environmental Audit Report Requirements
Implementation of Recommendations of Mandatory Environmental Audit