July 2013
GHD
Report
PRIMP
Pollution Incident Response
Management Plan
Cowra STP,
WTP and
Saleyards
Table of contents
1.
2.
3.
Background .................................................................................................................................... 3
1.1
Water and Sewer Operations .............................................................................................. 3
1.2
Cowra Saleyards .................................................................................................................. 3
1.3
PIRMP Purpose ................................................................................................................... 3
Pollution Incident Response Planning ........................................................................................... 4
2.1
Risk Assessment ................................................................................................................. 4
2.2
Potential Pollutants and Safety Equipment ......................................................................... 5
2.3
Maps .................................................................................................................................... 5
2.4
Notifiable Incidents ............................................................................................................... 6
Incident Response ......................................................................................................................... 7
3.1
4.
Immediate Notification Incident ............................................................................................ 7
Training & Review ........................................................................................................................ 13
4.1
Training .............................................................................................................................. 13
4.2
PIRMP Review ................................................................................................................... 13
Table index
Table 1
Hazards ................................................................................................................................ 4
Table 2
Inventory of Pollutants and Safety Equipment ..................................................................... 5
Table 3
Incident Contact Details – Council – Saleyards ................................................................. 10
Table 4
Incident Contact Details – External.................................................................................... 11
Table 5
Incident Response Training ............................................................................................... 13
Figure index
Figure 1
Incident Response Flowchart – WTP .................................................................................. 8
Figure 2
Incident Response Flowchart – STP ................................................................................... 9
Figure 3
Incident Response Flowchart – Saleyards ........................................................................ 10
Appendices
Appendix A - Maps
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1.
Background
1.1
Water and Sewer Operations
1.1.1
Cowra Sewage Treatment Plant
Cowra’s sewage treatment plant (STP) was commissioned in 2011, replacing the original facility
built in the 1930s. The new plant operates on a process of intermittently decanted extended
aeration (IDEA) with UV disinfection. Flows through this plant currently average approximately
2 ML per day. The capacity of the plant is 14,800 EP. Effluent from this plant is able to be
reused or discharged directly to the Lachlan River under licence from the EPA.
1.1.2
Cowra Water Treatment Plant
Cowra’s water treatment plant (WTP) was constructed in the 1930s and has been upgraded in
1959 and 1985. Another upgrade is currently being undertaken (2012-2013). The plant operates
on a conventional treatment process and has a theoretical capacity of 32 ML per day although
in recent years, the peak production has been approximately 23 ML per day. Backwash from
this plant is discharged to the Lachlan River under licence from the EPA.
1.2
Cowra Saleyards
Cowra Saleyards is located on the Young Road and operates as a livestock selling centre.
There are two sales per week, with a cattle sale held every Monday and a sheep sale every
Friday.
1.3
PIRMP Purpose
The licensed properties operate under the following Environment Protection Licences (EPL):

EPL 1572 Cowra Water Treatment Plant

EPL 3648 Cowra Sewage Treatment Plant

EPL 11336 Cowra Saleyards.
These EPLs are issued under Section 55 of the Protection of the Environment Operations Act
1997 by the NSW Office of Environment and Heritage (OEH). The EPLs contain requirements to
report pollution incidents as outlined in condition R2:
Note: The licensee or its employees must notify the EPA of incidents causing or threatening
material harm to the environment immediately after the person becomes aware of the incident in
accordance with the requirements of Part 5.7 of the Act.
R2.1
Notifications must be made by telephoning the Environment Line service on 131 555.
R2.2
The licensee must provide written details of the notification to the EPA within seven
days of the date on which the incident occurred.
The introduction of the Protection of the Environment Legislation Amendment Act 2011 (POELA
Act) in February 2012 requires that holders of EPLs maintain a Pollution Incident Response
Management Plan (PIRMP).
The PIRMP is held by the Technical Services section and is applicable to the Council water
supply, sewerage and saleyard operations. Council maintain a separate PIRMP for landfill
operations.
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2.
Pollution Incident Response Planning
2.1
Risk Assessment
The main hazards which were identified for the licensed facilities are detailed in Table 1 along
with control measures to minimise the occurrence and consequences (people and environment)
of the identified risks.
Table 1
Hazards
Location
Hazard
Control Measure/s
Consequence
WTP
Chemical
spill to land
Bund
Training of WTP
operators
STP
Insufficient
sewage
treatment –
overflow of
STP
New STP with
storage designed to
manage inflows up
to a 1 in 100 year
rainfall event.
Any overflow
throughout the plant
is pumped back to
the beginning of the
treatment process.
Lagoon height
logged weekly to
maintain freeboard.
STP connected to
SCADA with alarms
to STP Manager.
Training of STP
operators
Offsite soil
contamination
Potential
exposure of
community to
water treatment
chemicals
Pollution of
downstream
waterbody
Saleyards
Fuel spill to
land (truck
fuel tank)
Designated traffic
control/routes
Effluent dam
overflow
Effluent irrigation
across site.
Mechanical
screening of
contaminants
Wetland filtration for
nutrient removal
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Likelihood
of material
harm
Moderate
Escalating
Factors
Low
Nil
Localised soil
contamination
Low
Localised soil
contamination
Low
Increased
traffic flow
through
saleyards.
Poor vehicle
maintenance.
Failure to
follow
designated
routes.
High rainfall
High stock
throughput
Failure of
bund
2.2
Potential Pollutants and Safety Equipment
Details of potential pollutants and safety equipment are provided in Table 2.
Table 2
Inventory of Pollutants and Safety Equipment
Potential Pollutant
Location
Polyaluminium Chloride
Caustic Soda (NaOH)
Chlorine gas (Cl2)
Potassium Permanganate
(KMnO4)
Sodium Fluoride
(Na2SiF6)
Sodium hypochlorite
solution
Calcium hypochlorite
tablets
Caustic
Alum
Sewage
WTP
STP
1,000 L
23,000 L
2 ML/day
Roundup
Saleyards
2L
2.3
Maximum
Quantity
60 kL
60 kL
2910 kg
500 kg
Safety Equipment &
Devices
Glasses, safety boots and
high vis vests
Goggles and gloves
Respirators
Alarms
Fire fighting equipment
Glasses, safety boots and
high vis vests
Goggles and gloves
Respirators
PPE as per MSDS
SCADA
SCADA
1000 kg
50 kg
1000 kg
Nil
Maps
Pollution incident response maps have been prepared to facilitate planning for incident
response and provide readily accessible and accurate information to support the assessment of
an incident and assist in the implementation of incident response procedures and clean up.
The following maps are provided in Appendix A:

Cowra Locality Map

Features Map – WTP

Features Map – Saleyards

Features Map – STP
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2.4
Notifiable Incidents
2.4.1
POEO Act Definitions
A pollution incident is defined by the POEO Act as:
an incident or set of circumstances during or as a consequence of which there is or is likely to
be a leak, spill or other escape or deposit of a substance, as a result of which pollution has
occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in
which a substance has been placed or disposed of on premises, but it does not include an
incident or set of circumstances involving only the emission of any noise.
Material harm is defined by the POEO Act as:
(1) For the purposes of this Part:
(a) harm to the environment is material if:
(i) it involves actual or potential harm to the health or safety of human beings or to ecosystems
that is not trivial, or
(ii) it results in actual or potential loss or property damage of an amount, or amounts in
aggregate, exceeding $10,000 (or such other amount as is prescribed by the regulations), and
(b) loss includes the reasonable costs and expenses that would be incurred in taking all
reasonable and practicable measures to prevent, mitigate or make good harm to the
environment.
(2) For the purposes of this Part, it does not matter that harm to the environment is caused only
in the premises where the pollution incident occurs.
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3.
Incident Response
3.1
Immediate Notification Incident
3.1.1
Incident Response and Notification
As per the definition of an immediate notification incident in section 2.4.1 and resulting from the
risk assessment in Table 1, Council have identified the following incident related to their water,
sewer and saleyard operations that requires immediate notification:

Offsite spill of chemicals from the WTP.
Council’s procedures for responding to an immediate notification incident are outlined in
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Figure 1
Incident Response Flowchart – WTP
Incident Occurs
Customer call to
Council
WTP Staff identify
incident
Water & Wastewater
Engineer Notified
WTP Staff assess
severity
WTP Staff to take
necessary action to
eliminate infiltration
of stormwater system
WTP Staff hand over
cleanup to Cowra RFS
and assist as required
Inform customer that
job completed
Notify Water &
Wastewater Engineer
of completion of job
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Water & Wastewater
Engineer to conduct
notifications as per
section 3.1.2
Table 2
Incident Contact Details – Council – STP
Incident Occurs
Customer call to
Council
STP Staff identify
incident
Water & Wastewater
Engineer Notified
STP Staff assess
severity
STP Staff to take
necessary action to
eliminate infiltration
of stormwater system
STP Staff hand over
cleanup to Cowra RFS
and assist as required
Inform customer that
job completed
Notify Water &
Wastewater Engineer
of completion of job
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Water & Wastewater
Engineer to conduct
notifications as per
section 3.1.2
Table 3
Incident Contact Details – Council – Saleyards
Incident Occurs
Customer call to
Council
Saleyard Staff identify
incident
Manager Cowra
Services Notified
Saleyard Staff assess
severity
Saleyard Staff sandbag
stormwater drains
Saleyard Staff hand
over cleanup to Cowra
RFS and assist as
required
Inform customer that
job completed
Notify Manager of
Cowra Services of
completion of job
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Manager Cowra
Services to conduct
notifications as per
section 3.1.2
Name
Peter Ford
Role
Water and Wastewater Engineer
Ken Keliher
WTP Supervisor
Paul Gregg
STP Supervisor
Chris Cannard
Manager – Cowra Services
Bob Bowd
Saleyard Supervisor
Paul Devery
General Manager
Council Emergency contact number
After hours emergency contact
Table 4
Incident Contact Details – External
Organisation
Emergency Services
EPA
Bathurst Regional Office
NSW Ministry of Health
On Call Public Health Officer
Bathurst Regional Office
Workcover
Fire & Rescue NSW
Cowra Rural Fire Service
3.1.2
Contact Number
6340 2104
0428 863 084
6340 2170
0428 422 409
6340 2160
0428 674 238
6340 2088
0428 636 663
6342 2654
6340 2013
6340 2000
0419 219 231
Contact Number
000
131 555
6332 1838
0428 400 526
6339 5601
13 10 50
1300 729 579
6363 6666
Responsibilities
In the event of an immediate notification incident responsibilities for incident management are
as follows:

On Call WTP Officer is responsible for actioning response to the incident.

Water & Wastewater Engineer is responsible for notifying external authorities, potentially
affected community and ensuring adequate resources are available for incident response.

General Manager is responsible for liaising with the media.
The Water & Wastewater Engineer shall determine the most appropriate means of contacting
potentially affected community including:

Door knocking

Letterbox drops

Phone

Local media

Signage.
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Information provided to the community would depend on the incident but could include:

Description of the incident

Status of incident

Response actions

Actions to minimise harm

Likely duration.
As per the EPLs, the licensee must provide written details of the notification to the EPA within
seven days of the date on which the incident occurred.
3.1.3
Notification of External Authorities
EPL 3648 requires details of sewage incidents be recorded. Where sewage or partially treated
sewage is discharged from the premises as a result of a bypass of the sewage treatment plant,
or an observed or reported overflow has occurred from the reticulation system, and overflow or
a bypass may pose a risk to public health, the licensee is to promptly give appropriate
notification to any parties that are likely to be affected, including:

the potentially affected community

the Department of Health

other parties as appropriate.
When the licensee notifies the Department of Health or Safe Food NSW Shellfish Quality
Assurance Program of a bypass or overflow incident, the licensee must also notify the EPA.
Notifications are to be given as soon as practicable after the licensee or one of the licensee’s
employees or agents becomes aware of the incident, and must include all relevant information
including the information required under the EPL.
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4.
Training & Review
4.1
Training
Personnel involved in water, sewer and saleyard operations undertake a range of training to
assist in the response to potential incidents and to test the adequacy of incident response
procedures and plans. Details of the training and testing of the PIRMP is provided in Table 5.
Table 5
Incident Response Training
Type of Training
NSW Office of Water
Part 1 – Chemical Dosing
Systems
NSW Office of Water
Part 2 – Water Treatment
Operations
NSW Officer of Water
Part 1 – Waste Water
Treatment Operations
NSW Officer of Water
Part 2 – Advanced
Treatment
Water quality analysis
Confined space
Toolbox meetings
Overflow clean up
Site induction
Emergency simulation
Incident debrief
4.2
Personnel Involved
WTP Operators
Frequency
Once
Records
Human
Resources
WTP Operators
Once
Human
Resources
STP Operators
Once
Human
Resources
STP Operators
Once
Human
Resources
WTP and STP
Operators
WTP, STP and
Reticulation Operators
Site staff
All Sewer staff
New staff
On-the-job
NOW training
As required by
training provider
Weekly
On-the-job
Once
All Water/ Sewer staff
Personnel involved in
incident
Independent chair
Annual
Within one month of
an incident
Human
Resources
Human
Resources
Minutes
Nil
Records
Department
Minutes
Minutes
PIRMP Review
The PIRMP will be reviewed when there is a material change to operations including but not
limited to:

Modification of EPL 3648, 1572 or 11336

Changes in standard operating procedures referred to in this PIRMP

Change in legislative requirements

Recommendations arising from an incident debrief, emergency drill or emergency
simulation exercise.
The responsibility for reviewing the PIRMP is the Manager Technical Services.
An update of the PIRMP would trigger all staff to undergo refresher training as part of the team
toolbox meetings as per Table 5.
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Appendices
GHD | Report for Cowra Shire Council - Pollution Incident Response Management Plan, 21/21831
Appendix A – Maps
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GHD
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Document Status
Rev
No.
Author
Reviewer
Name
0
D. Scott
1
D. Scott
Approved for Issue
Name
Signature
Date
G. Metcalfe
G. Metcalfe
16/01/2013
G. Metcalfe
G. Metcalfe
27/03/2013
Signature
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