naturally occurring asbestos management plan

Naturally occurring asbestos management plan

4646 Mitchell Highway, Lucknow NSW

Ref: R 12608amp Date: 10 December 2020

Envirowest Consulting eyuaav to»sss as • 9 Cameron Place, PO Box 8158, Orange NSW 2800 • Tel (02) 6361 4954 • • 6/72 Corporation Avenue, Bathurst NSW • Tel (02) 6334 3312 • • Email [email protected] • Web www.envirowest.net.au •

Environmental Geotechnica/ Asbestos Services

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Document control

Client Matthew McQueen Level 41, Chifley Tower 2 Chifley Square Sydney NSW 2000

Rev Report number Date Prepared by Checked by Revision details/status 0 R12608amp 10/12/2020 Leah Desborough BNatRes (Hons) Ashleigh Adams BSc

Senior Environmental Scientist Environmental Scientist

Envirowest Consulting Pty Ltd 9 Cameron Place PO Box 8158 Orange NSW 2800 T 02 6361 4954

6/72 Corporation Avenue Bathurst NSW 2795 T 02 6334 3312

E [email protected] W envirowest.net.au

Copyright© 2020 Envirowest Consulting Ply Ltd. This document is copyright apart from specific uses by the client. No part may be reproduced by any process or persons without the written permission of Envirowest Consulting Ply Ltd. All rights reserved. No liability is accepted for unauthorised use of the report.

1. Introduction A contamination investigation undertaken at 4646 Mitchell Highway, Lucknow NSW by Envirowest Consulting Pty Ltd and reported on 8 December 2016 (report number R7372c), identified arsenic and lead at levels exceeding residential land-use thresholds in fill material on the site. The arsenic and lead impacted areas were remediated in accordance with a remediation action plan by capping the material on-site. Validation of the remediation (R7372val) confirmed the material had been capped appropriately and the site was suitable for residential land-use.

Additional remediation works are proposed to be undertaken to remove the arsenic and lead impacted material from the site and disposed to landfill. The area to be remediated is located adjacent an unnamed drainage line.

The Orange Local Government Area is located within a region containing serpentinite rock belts. Some of these belts contain naturally occurring asbestos ( chrysotile). The site at 4646 Mitchell Highway, Orange NSW is mapped as a geological unit with high naturally occurring asbestos (NOA) potential

Clause 432 of the Work Health and Safety Regulations 2011 requires that a site-specific Asbestos Management Plan be prepared where naturally occurring asbestos has been identified or is likely to be present at a workplace.

2. Scope Preparation of a site-specific Asbestos Management Plan including:

• Description of the NOA and potential hazards • Requirement for control measures; • Dust prevention/suppression; • Use of PPE for personnel working on the site; • Personnel and machinery decontamination requirements • Procedures for detailing incidents or emergencies involving naturally occurring asbestos at

the site; • Consultation, responsibilities, information and training for workers carrying out work

involving naturally occurring asbestos; • Disposal methods including the options of on-site encapsulation or disposal to landfill • Air monitoring during disturbance works.

3. Identification Asbestos is the general term for six fibrous, naturally occurring minerals. Each of these minerals has the potential to cause adverse health impacts if elevated levels of asbestos fibres are released into the air (either by human activities or by natural weathering) and inhaled by people.

The site is mapped in a geological unit with high asbestos potential (NSW Seed Portal accessed 30 November 2020) (Figure 1).

Twenty seven boreholes were drilled in the location of the area to be remediated as part of previous investigations. The boreholes were drilled to natural soil identified at depths from 0.5 to 0.8m. Naturally occurring asbestos or serpentinite rock was not identified in the boreholes.

A historically constructed rock wall was identified in the southern section of the drainage line which traverses the site. The rocks are expected to have been imported to the site to form the rock wall. Naturally occurring asbestos was identified in one of the rocks.

4. Remediation measures Previous remediation works were undertaken in 2018 and comprised covering the surface of the two impacted areas with geotextile. Capping with a minimum of 500mm of classified excavated natural material (ENM) subsoil material and covered with a minimum of 100mm of classified ENM topsoil material.

Remediation area 1 is located adjacent the drainage line and is approximately 460m2 (Figure 2) in size. The area has been fenced. The capping material will be excavated to the depth of the geotextile and topsoil and subsoil material stockpiled separately. The arsenic and lead impacted material will be excavated and loaded directly into trucks for disposal to landfill. The impacted material is visually distinctive and expected to be at depths of up to 400mm below the geotextile. The subsoil capping material will be used to backfill the excavation pit. The topsoil capping material will be spread over the subsoil to create a suitable medium for natural regeneration of grasses

Remediation area 2 is located 60m east of the drainage line (Figure 2) and outside the Office of Water vegetated riparian zone for second order water courses. It is expected to comprise an area of approximately 50m2. Remediation area 2 will be excavated and impacted material disposed to landfill.

Access to the site will be along the existing access track which was formed during the 2018 remediation works.

The asbestos management plan will be implemented if naturally occurring asbestos is identified during the works.

5. Naturally occurring asbestos management plan Where serpentinite rocks or naturally occurring asbestos is identified as being present or likely to be present, the safe work procedures and control measures detailed in the following sections, may be implemented during the works as required.

5.1 Site access and signage • Ensure all work areas, including a 10m exclusion zone, are fenced, delineated and/or signposted

prior to commencement of works to warn workers and the public of the presence of naturally occurring asbestos within the workplace.

• Secure all work areas appropriately to limit the potential for non-authorised personnel to enter the workplace.

• Limit the number of access points to the workplace. • Ensure all workers and/or visitors required to access the workplace are provided with a site

specific induction relevant to the tasks to be undertaken, identifying how to recognise naturally occurring asbestos and the safe work method statement to be implemented.

5.2 Dust suppression • Ensure disturbed surfaces and uncapped stockpiles are kept moist to prevent the generation of

airborne fibres.

• Restrict vehicle speeds and works on hot, windy days to limit dust lift off. • Stop work immediately if airborne dust is visible • Cover all disturbed surfaces and uncapped stockpiles with a suitable cover within 30 days. The

nature and thickness of the cover should be determined based on the risk assessment undertaken.

5.3 Operation of mobile and fixed plant • Ensure that a 10m exclusion zone is enforced around naturally occurring asbestos-ground

disturbing activities. This may be achieved through the use of fencing or flagging. All personnel within the exclusion zone must wear Personal Protective Equipment (PPE) until an asbestos assessor has provided approval to enter the zone without PPE.

• Select appropriate plant and machinery to minimise dust generation. • Close all windows, doors and other openings in machinery cabs and set air conditioning to

recycle. • Use machinery with High Efficiency Particulate Air (HEPA) filters in preference to other

machinery and ensure that filters are inspected, cleaned and replaced as appropriate, particularly on hot dry days.

• Ensure all material containing naturally occurring asbestos is kept moist to suppress dust prior to and during handling. This may be achieved through the use of a water cart or sprays.

• Avoid practices that are likely to generate dust when handling naturally occurring asbestos material.

• Ensure that all plant and machinery is washed down and inspected by an asbestos assessor prior to leaving the site.

• Stop work immediately during periods of hot, dry winds or if airborne dust is visible.

5.4 Transportation • Ensure that all loads are:

moist prior to loading and remain so during transportation; not permitted to spill from the truck during transportation; and covered prior to leaving the work area.

• Ensure that the wheels of all vehicles that have entered the site are washed in a bunded area prior to leaving the site.

5.5 Waste disposal • Ensure that all naturally occurring asbestos material is retained and encapsulated on site, where

practicable. Where on-site encapsulation has been achieved, Site Management Plan describing the location and management of asbestos material must be prepared and provided to subsequent landholders.

• Where on site storage is not practicable, dispose of all material as asbestos waste at a licenced waste facility unless a clearance inspection had been undertaken by a licensed asbestos assessor or competent person and a clearance certificate issued.

• Used PPE should be placed in plastic bags labelled asbestos and disposed to landfill. • Waste disposal dockets will be obtained for all asbestos waste disposed to landfill.

5.6 Personnel Protective Equipment (PPE) within the exclusion zone • Ensure that all personnel wear Personal Protective Equipment (PPE) at all times within the

exclusion zone. • Respirator -- use a P2 rated respirator at all times.

• Clothing - implement a procedure to ensure that contaminated clothing is not permitted to leave the workplace. Clothing options may include disposable overalls and shoe covers. Alternatively, boots and socks may be treated as disposable items, with socks disposed of daily as asbestos waste and boots disposed of at the completion of the works. Depending on the works undertaken, other clothing may also be required to be disposed as asbestos waste during or at the completion of the works.

5.7 Air monitoring • Air monitoring will be undertaken around the boundary of the NOA work areas during disturbance

each day of works. • Asbestos monitoring will be undertaken by an independent licensed asbestos assessor in

accordance with the requirements of How to safely remove asbestos: Code of practice. Table 1 identifies air quality criteria for asbestos monitoring, as well as required control measures and actions in the event of particular criteria being exceeded.

• Undertake a thorough investigation should monitoring provide positive results for fibres. Matters for consideration may include whether workers were strictly following protocols, whether there was an environmental change such as a strong or dry wind or whether there was a non-standard activity occurring that caused cross contamination of clean and dirty areas such as the sharing of cleaning equipment.

Table 1. Criteria for asbestos fibres action levels (Safe Work Australia 2018) Action level (airborne asbestos fibres/ml) Control Action

Less than 0.01 Between 0.01 and 0.02

More than 0.02

No new control measures are necessary 1. Review 2. Investigate 3. Implement

1. Stop removal work 2. Notify regulator

3. Investigate the cause

4. implement controls to eliminate or minimise exposure and prevent further release

5. Do not recommence removal work until further air monitoring is conducted

Continue with control measures Review control measures Investigate the cause Implement controls to eliminate or minimise exposure and prevent further release Stop removal work Notify the relevant regulator by phone followed by fax or written statement that work has ceased and the results of the air monitoring Conduct a thorough visual inspection of the enclosure (if used) and associated equipment in consultation with all workers involved with the removal work. Extend the isolated/barricaded area around the removal area as far as reasonable practicable (until fibre levels are at or below 0.01 fibres/ml), wet wipe and vacuum the surrounding area (as required). Do not recommence until fibre levels are at or below 0.01 fibres/ml.

5.8 Decontamination 5.8.1 Personnel

• All personnel will be required to undergo decontamination prior to leaving the site. • Decontamination will comprise wet wiping of disposable overalls and careful removal to minimise

dust generation. • Personnel will shower or as a minimum wash hands and face. • The respirator should be removed and hands and face washed a second time.

5.8.2 Vehicle, plant and machinery • All machinery and plant are to be decontaminated prior to leaving site. • Decontamination will comprise thoroughly washing exterior surfaces of the vehicle, plant or

machinery. The washing will occur in a dedicated vehicle, plant or machinery decontamination area. Plastic encapsulating soft furnishings within the cabin will be removed and internal surfaces wet wiped. A clearance inspection including air monitoring will be undertaken by an asbestos assessor/competent person.

5.9 Site clearance The clearance inspections will be undertaken in accordance with WH&S Regulations and SafeWork NSW guidelines and authorised by Envirowest Consulting Pty Ltd.

5.9.1 Work area • Ensure that the work area is inspected by an asbestos assessor/competent person to ensure

that all areas of naturally occurring asbestos have been appropriately managed, taking in to account the final land-use, prior to removing fencing and signposts.

• Clearance will be undertaken for the work area and include stockpile footprints and decontamination areas.

5.9.2 Vehicles, plant and machinery • Clearance of vehicles, plant and machinery will be undertaken by an asbestos

assessor/competent person. • The clearance inspection will include a visual inspection of the machinery cabin and exterior and

air monitoring within the cabin.

5.10 Documentation • Ensure records of all inductions, monitoring, material and waste movements, placement location

and capping (type and thickness) and disposal are retained. • On large civil worksites, such as road construction sites, where regular air monitoring is being

undertaken, provide staff and neighbours (who express an interest) with monitoring results promptly to reassure them that controls are adequate.

6. Incidents and emergencies When an incident is identified, it will be recorded. The Project Manager or the Asbestos Assessor will usually make these observations during routine site inspections.

All incidents are to be managed in accordance with the AMP and the emergency procedures detailed and illustrated in Appendix 1.

All reportable incidents are to be documented on the asbestos incident report located in Appendix 2.

7. Consultation, responsibilities, information and training for workers 7.1 Consultation 7.1.1 Reviewing an AMP The AMP must be reviewed when:

• There is a review of the control measures • Asbestos is removed from or disturbed, sealed or enclosed at the site

• The plan is no longer adequate for managing asbestos at the site • A health and safety representative requests a review

7.1.2 Accessing an asbestos management plan The person with management or control of the workplace must ensure the AMP is relatively accessible to:

• A worker who has carried out, carries out or intends to carry out work at the site • Health and safety representatives of workers that carry out or intend to carry out work at

the site • A person conducting a business or undertaking who has carried out, carries out or intends

to carry out work at the site • A person conducting a business or undertaking who has required, requires or intends to

require work to be carried out at the site

The AMP should be kept at the site to ensure it is accessible.

7.1.3 Transferring an asbestos register If the person with management control of the site is to relinquish control they should ensure a copy of the asbestos register is given to the new person with management control.

7.2 Responsibilities The Project Manager is responsible for ensuring that appropriate preventative and control measures are implemented and maintained. The AMP is a commandment to preventative and control measures. Guidance and resources will be provided to ensure all personnel required to work with NOA are adequately informed and protected and that their health, safety and wellbeing is maintained.

Employees must also be committed to working in accordance with this AMP and participate in maintaining the health and safety of themselves and their co-workers.

To achieve the goals, consultation must occur between both management and employees in maintaining and improving the intentions of this AMP and ultimately ensuring health and safety conditions are maintained.

Full consultation, involvement and information sharing shall occur between management, WH&S Working Groups and employees through a well-established consultative mechanism.

The property owner has a responsibility in relation to asbestos to: • Provide and maintain, so far as practicable, safe and healthy work environments and

practices generally, and have written policies on the control of asbestos • Comply with legislative provisions • Liaise where appropriate with employees on a continuous basis so that the existence and

condition of asbestos in the working environment is known • Provide adequate instruction and training for employees and supervision of health and

safety measures • Consult with employees, their representatives and organisations and the SafeWork NSW

on the control of exposure to airborne asbestos • Anticipate the need for the control of asbestos risks to be initiated in any particular case • Provide appropriate protective clothing and equipment, hygiene procedures and personal

decontamination facilities

• Prepare, complete, and submit documents for obtaining necessary approvals.

Employees and Contractors have a responsibility in relation to asbestos to: • Comply with instructions given for their own safety and health and that of others generally • Comply with all work procedures and instructions related to asbestos • Co-operate with supervisors and managers in their fulfilment of legislative obligations • Take care of their safety and health and that of others, and abide by their duty of care

provided for in legislation • Report immediately to their supervisor any perceived safety or health risk • Wear and maintain in good order all protective clothing and apparatus provided by the

manager or supervisor for personal protection and maintain same in good order • Ensure all equipment is in good working order.

Employer and employee organisations have a responsibility, in relation to asbestos for: • Consulting on health and safety matters generally and on measures that may need to be

taken on asbestos in work areas • Keeping themselves informed of advice given by competent persons in relation to

inspections and meeting health and safety commitments • Co-operating on any reasonable request for the variation to work hours and hours of work • Advising members of their obligations and responsibilities under occupational health

legislation.

Visitors have a responsibility in relation to asbestos to: • Comply with instructions given for their own safety and health and that of others generally • Comply with all work procedures and instructions related to asbestos • Co-operate with staff in their fulfilment of legislative obligations • Take care of their safety and health and that of others • Report immediately to the employer any perceived safety or health risk.

7.3 Organisational responsibilities and authorities The following key personnel are responsible for the implementation of the control measures discussed in this document:

Asbestos Management Plan Organisational Responsibilities

Plan Preparation, Maintenance and Audit Item Activities Responsibility Plan compliance Implementation

Establish document controls AMP process audit Communication to key stakeholders

Director/ Manager

Asbestos Awareness Training

Prepare program Director/ Manager

Workplace Implementation Item Activities Responsibility Contractor compliance

Asbestos identification and management

Implement asbestos awareness training

Special conditions in work specifications Provision of safe operating procedures

Establish identification systems

Communication of safe operating procedures

Director/ Manager

Owner

Director/ Manager

7.4 Information and training for workers As required by the Work Health and Safety Act 2011and Work Health and Safety Regulation 2011, the site manager will:

• provide any information, training, instruction or supervision that is necessary to protect all persons at the site from risks to their health and safety arising from work carried out on the site;

• ensure workers who may be involved in asbestos-related work are trained in the identification, safe handling and suitable control measures for asbestos.

All workers will be given appropriate Asbestos Awareness Training to ensure adequate awareness of the health risks of asbestos, methods of prevention and control, proper work practices, emergencies and use of personal protective equipment. Asbestos Awareness Training will be provided for workers who may become involved with:

• the handling of asbestos containing materials; • ground disturbing activities in areas of naturally occurring asbestos; • responding to asbestos related emergencies or incidents; or • the management or supervision of workers involved with the above.

Asbestos Awareness Training may include topics outlined within the documents How to manage and control asbestos in the workplace: Code of practice and How to safely remove asbestos: Code of practice and would be delivered by appropriately qualified individuals.

Contractors and visitors will be provided with an appropriate level of site specific training during their induction to ensure that they are aware of the requirements of this Plan and any naturally occurring asbestos within their work environment. Site specific induction procedures will include, as appropriate:

• a copy of the relevant section(s) of the this Plan; • the identification and safe handling of, and suitable control measures for asbestos

including details relating to any personal protective requirements; and • general information in relation to asbestos and asbestos management, including the

hazards and risks associated with naturally occurring asbestos for workers who carry out work where naturally occurring asbestos is likely to be found.

A record of asbestos training undertaken by each worker and visitor will be kept for at least five years after the date of the visit.

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Legend

• Approximate site location

■ Geological units with high asbestos potential

Geological units with medium asbestos potential

Geological units with low asbestos potential

Figure 1. NOA map

4646 Mitchell Highway, Lucknow NSW ■- · - Envirowest Consulting Pty Ltd

Job: R 12608amp Drawn by: - Date: 7/12/2020

Remediation area 1 Remediation area 2

• d • • • • • • • • • • I • • • I • • ! I • • • • I • • • I • • • • I • • • I

• • • I

Lot boundary

Existing access

Drainage line

Proposed access Figure 2. Aerial photograph and site plan

4646 Mitchell Highway, Lucknow NSW ■- ■- - Envirowest Consulting Pty Ltd

Job: R 12608amp Drawn by: LO Date: 7/12/2020

Appendix 1. Emergency procedures

In the event of identification of suspected naturally occurring

asbestos ,/

+ r ' Immediately cease work and

contact site foreman

'-

+ Site foreman to arrange

inspection by environmental consultant/asbestos assessor +

' Environmental consultant to

undertake detailed inspection and samplina (if reauired)

I v • If substance assessed as not If substance assessed as

presenting an unacceptable risk presenting an unacceptable risk to human health to human health .,

+ I' ' Site foreman to remove safety Environmental consultant to barricades and environmental supervise remediation and controls and continue work undertake any assessment'

validation/clearance \

+ r Site foreman to remove

barricades and environmental controls and continue work

./

I • r Environmental consultant to submit assessment/validation /clearance to site foreman

Appendix 2. Asbestos incident report

Report Number: Date.....

Location of Incident (including Building Name & Number):

Date & Time of Incident:

Date Incident reported:

Incident Reported By:

Names of persons present/affected:

Reported To:

Details of Incident

Signed by Reporter:

Classification of Incident:

Signed by Repartee:

□ Minor Asbestos Incident

D Breach of Regulations

□ Major Asbestos Incident

D WorkCover Inspection

□ Complaint

D Uncovering of ACM

Immediate Action Taken:

Supervisor: .

naturally occurring asbestos management plan

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