Consents C1 Air Quality

Auckland City Rail Link In association with:

ENABLING WORKS CONTRACT 1 AIR QUALITY DELIVERY WORK PLAN

Document ref: CRL-BTM-ENV-DOW-PLN-000363

Revision 8 FINAL June 2016

COMMERCIAL IN CONFIDENCE Air Quality Delivery Work Plan

June 2016

Version history Rev

Report date

Version details

Prepared by

Reviewed by

1

December 2015

Draft for Auckland Transport review

Andrew Curtis

J Urquhart, R Purdy

2

December 2015

Draft for CLG review

Andrew Curtis

R Jenkins

3

January 2016

Draft for independent peer review

Andrew Curtis

R Purdy, R Jenkins

4

April 2016

Review incorporating revised BTC designation conditions, Independent Peer Review and Auckland Council comments

Andrew Curtis

R Purdy, P Roan

5

April 2016

Draft for consultation/CLG review

Andrew Curtis

R Purdy, R Jenkins

6

May 2016

Draft incorporating CLG comments for Independent Peer Review

Andrew Curtis

R Purdy, P Roan

7

May 2016

Draft incorporating CLG and Independent Peer Review comments for Auckland Transport Review

Andrew Curtis

J Urquhart, P Roan

8

June 2016

Final

Andrew Curtis

J Urquhart, P Roan, R Jenkins

Distribution Date

Version

Issued to

Quantity & type

Approved for the DSBJV by

8 December 2015

Draft

Auckland Transport

1x Electronic

D Burtenshaw

18 December 20115

Draft

Community Liaison Group

1x Electronic

D Burtenshaw

28 January 2016

Draft

Independent Peer Review

1x Electronic

D Burtenshaw

8 April 2016

Draft

Auckland Transport

1x Electronic

D Burtenshaw

12 April 2016

Draft

Community Liaison Group

1x Electronic

D Burtenshaw

9 May 2016

Draft

Independent Peer Review

1x Electronic

D Burtenshaw

27 May 2016

Draft

Auckland Transport

1x Electronic

D Burtenshaw

2 June 2016

Final

Auckland Transport

1x Electronic 1 x Hard copy

D Burtenshaw

This document remains the property of DSBJV. Its contents are confidential and shall not be reproduced, destroyed or given away without express, written permission of DSBJV. The electronic version of this document in FULCRUM on designated serves(s) is the Master Copy and is a controlled document. Unless specifically noted, thereon, other copies of this document are uncontrolled. \\albtpfile.ttgroup.local\data\rep\auckland\live\tt\projects\30850\30850.0500 planning\30850.0508 (air quality)\workingmaterial\dwp\crl-btm-env-dow-pln-000363 - air quality dwp final 30 05 16.docx

Air Quality Delivery Work Plan

June 2016

Table of contents 1

Introduction 1.1 Purpose of the Air Quality DWP 1.2 Relevant Conditions 1.3 Sustainability 1.4 DWP Review and updates 1.5 Air Quality DWP Author 1.6 Preparation Standards

2

Project Description 2.1 Overview 2.2 Construction Zones 2.3 Discharges to Air 2.4 Location of Activities

8 8 8 10 10

3

Environmental Aspects 3.1 Receiving Environment 3.2 Meteorology 3.3 Environmental Performance 3.4 Sensitive Receptors Monitoring Requirements 4.1 Dust Monitoring 4.2 Visual Inspection and Monitoring Methods 4.3 Instrumental Monitoring 4.3.1 Dust 4.3.2 Meteorological Monitoring 4.3.3 Dust Trigger Alerts 4.3.4 Wind Speed Trigger Dust Trigger Alerts 4.4 Monitoring Locations 4.5 Monitoring Data 4.6 Monitoring Equipment Maintenance 4.7 Odour Monitoring Management Procedures 5.1 General Methods of Dust Control 5.2 Dust Risk Index 5.3 Dust Mitigation Measures 5.3.1 Methods of Dust Control – All Areas (Low Risk) 5.3.2 Further Methods of Dust Control (Medium Risk Conditions) 5.3.3 Further Methods of Dust Control (High and Extreme Risk Conditions) 5.3.4 Operation of Dust Control Equipment 5.3.5 Equipment Malfunction 5.4 Review of Dust Mitigation 5.4.1 Sources of Information 5.4.2 Odour Control during Contaminated Material Handling 5.5 Control of Vehicle Exhaust Emissions 5.6 Dust Contingency Measures Communication and Complaints 6.1 Project Communications 6.2 Complaints 6.2.1 Complaints Response

11 11 11 11 12 13 13 13 13 13 14 14 15 15 16 16 16 18 18 18 19 19 20 21 21 21 21 22 22 22 22 24 24 24 24

Environmental Training

25

4

5

6

7

Air Quality Delivery Work Plan

1 1 2 6 6 7 7

June 2016

7.1 8 9 10

Project Staff

25

Record Keeping 8.1 Air Quality Log Roles and Responsibilities 9.1 Specific Roles and Responsibilities

26 26 27 27

DWP Review and Updating 10.1 Review Process 10.2 DWP Updates

28 28 28

Appendix A :

ISCA Requirements

Appendix B :

Dust Risk Index

Appendix C :

CLG and Independent Peer Review comments

Air Quality Delivery Work Plan

June 2016

Glossary of abbreviations Acronym

Definition

AC

Auckland Council

ACZ

Active Construction Zone

AQMP

Air Quality Management Plan

AT

Auckland Transport

bgl

Below ground level

BTC

Britomart Transport Centre

CEMP

Construction Environmental Management Plan

CO

Carbon monoxide

CRL

City Rail Link

CPO

Former Chief Post Office building

DRI

Dust Risk Index

DSBJV

Downer Soletanche Bachy Joint Venture

DWP

Delivery Work Plan

IS

Infrastructure Sustainability

ISCA

Infrastructure Sustainability Council of Australia

km/h

Kilometres per hour

m

metres

MfE

Ministry for the Environment

m/s

Metres per second

NoR

Notice of Requirement

NO

Nitric oxide

NO2

Nitrogen dioxide

TSP

Total Suspended Particulate

VOC Âľg/m

Volatile organic compounds 3

Air Quality Delivery Work Plan

Micrograms per cubic metre

June 2016

1

1

Introduction

The City Rail Link (CRL) project comprises the construction, operation and maintenance of a 3.4 km underground passenger railway, running between Britomart Station and the North Auckland Rail Line in the vicinity of Mt Eden station. The works relating to this Air Quality Delivery Work Plan (DWP) constitute part of the enabling works for the CRL. The works (the Project) involve the construction of an extension to the existing passenger rail network from the current termination point within the Britomart Transport Centre (BTC), westwards underneath the former Chief Post Office building (CPO) and Lower Queen Street. The Project footprint is shown generally by the blue shaded area in Figure 1.1 below.

LEGEND CRL alignment BTC designation CRL designation C1 worksite

Figure 1.1: Project Footprint

1.1

Purpose of the Air Quality DWP

This Air Quality DWP has been prepared to manage, mitigate and monitor adverse air quality effects, primarily dust, during construction of the Project. The objective of the DWP is to detail the best practicable option to avoid dust and odour nuisance being caused by construction works and to remedy any such effects should they occur. This DWP incorporates the requirements of: 

The CRL designation Condition 59;



The BTC designation Condition 33A; and



Conditions 64 to 76 of discharge permit R/REG/2014/5437 for the CRL Britomart to Wyndham Street enabling works.

Both the CRL and BTC designations require the preparation of a DWP while the discharge permit requires the preparation of an Air Quality Management Plan (AQMP). These requirements have been combined and are addressed in this single Air Quality DWP. This DWP is an updated version of the draft AQMP – Britomart to Wyndham, dated December 2014 (“draft AQMP”), prepared by Golder Associates (NZ) as part of the resource consent applications for the Project. The DWP outlines the following: Air Quality Delivery Work Plan

June 2016

2 

Relevant designation and discharge permit conditions;



Various sources of dust, odour and hazardous air pollutants that may be created during the construction project;



Specific sensitive locations;



Dust mitigation and prevention methods;



Odour mitigation and prevention methods;



Methods to minimise the discharge of hazardous air pollutants;



Monitoring methods; and,



Methods for managing complaints regarding discharges into air and keeping compliance records.

This Air Quality DWP has been prepared by AECOM New Zealand Limited (AECOM) for the Downer Soletanche Bachy Joint Venture (the Contractor – DSBJV) and forms part of the Construction Environmental Management Plan (CEMP) for the Project.

1.2

Relevant Conditions

Table 1.1 identifies the CRL and BTC designation and discharge permit conditions relevant to this Air Quality DWP, and where they are addressed in the document. Table 1.1: Condition Number

Relevant Conditions and section where addressed in the DWP Condition

Relevant Section of DWP CRL Designation Conditions

59.1

An Air Quality DWP shall be prepared to avoid, remedy or mitigate the adverse effects on air quality during the construction of the City Rail Link or any part of it.

This document

59.2

The objective of the Air Quality DWP is to detail the best practicable option to avoid dust and odour nuisance being caused by construction works and to remedy any such effects should they occur.

This document

59.3

To achieve the above objective the following shall be included in the Air Quality DWP and implemented as required: (a) The procedures to be implemented for the continuous monitoring of Total Suspended Particulate (TSP) concentrations and meteorology including, but not limited to, the establishment of two monitoring sites (to the north and south of the site); (b) Identification of the sensitive locations, and the specific methods for monitoring, including trigger limits to determine whether further action (such as implementation of the mitigation measures discussed below or other mitigation measures) is required; (c) Procedures for responding to malfunctions with construction machinery or works causing accidental dust discharges including, but not limited to, the requirement to remedy any malfunction within 24 hours; (d) Procedures for monitoring weather conditions and the requirement that water spray is used on soil stockpiles, any nonpaved construction areas, and the wheels of trucks where dust may disperse beyond the site; (e) Procedures for establishing when the covering of trucks will be required;

Air Quality Delivery Work Plan

4

3.4, 4

4.6, 5.3

4, 5.3

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3

Condition Number

Condition

Relevant Section of DWP

(f) Procedures for determining when hard surfaced areas in construction yards and active construction areas should be cleaned including, but not limited to, the requirement that such areas be cleaned whenever dust generation occurs due to traffic on these surfaces; (g) Procedures for responding to discharges of odour (including in the event of excavation of contaminated sites) including, but not limited to, the requirement to address discharge of objectionable odour by immediately ceasing the activity causing the discharge; (h) Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including baghouses, pressure relief valves and high level alarms to mitigate dust emissions; (i) Procedures for, where practicable, limiting dust and odour nuisance and the methods for monitoring these procedures including identification of contingency measures to address identified and verified adverse effects on sensitive receptors. Contingency measures may include options such as: I. Cleaning of air filtration intakes; or II. Cleaning of other buildings and infrastructure; and (j) Procedures for responding to any complaints received and the timeframes for response to complaints and reporting; (k) Cross references to the specific sections in the Communication and Consultation Plan which detail how the communities in the vicinity of construction works are to be communicated with on the management of the adverse effects relating to air quality.

5.4 5.4

4.7, 5.4.2

5.3.4

4.7, 5.4

5.6 6.2 6.1

BTC Designation Conditions1 33A.1

An Air Quality DWP shall be prepared to avoid, remedy or mitigate the adverse effects on air quality during the construction of the Project or any part of it.

This document

33A.2

The objective of the Air Quality DWP is to detail the best practicable option to avoid dust and odour nuisance being caused by construction works and to remedy any such effects should they occur.

This document

33A.3

To achieve the above objective the following shall be included in the Air Quality DWP and implemented as required: (a) The procedures to be implemented for the continuous monitoring of Total Suspended Particulate (TSP) concentrations and meteorology including, but not limited to, the establishment of two monitoring sites (to the north and south of the site); (b) Identification of the sensitive locations, and the specific methods for monitoring, including trigger limits to determine whether further action (such as implementation of the mitigation measures discussed below or other mitigation measures) is required; (c) Procedures for responding to malfunctions with construction machinery or works causing accidental dust discharges including,

4

3.4, 4

4.6

1

Conditions as attached to Auckland Transport’s Confirmation Notice of 17 March 2016 on Notice of Requirement to alter Britomart Transport Centre Designation

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4

Condition Number

Condition

(d)

(e) (f)

(g)

(h)

(i)

(j) (k)

Relevant Section of DWP

but not limited to, the requirement to remedy any malfunction within 24 hours; Procedures for monitoring weather conditions and the requirement that water spray is used on soil stockpiles, any nonpaved construction areas, and the wheels of trucks where dust may disperse beyond the site; Procedures for establishing when the covering of trucks will be required; Procedures for determining when hard surfaced areas in construction yards and active construction areas should be cleaned including, but not limited to, the requirement that such areas be cleaned whenever dust generation occurs due to traffic on these surfaces; Procedures for responding to discharges of odour (including in the event of excavation of contaminated sites) including, but not limited to, the requirement to address discharge of objectionable odour by immediately ceasing the activity causing the discharge; Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including baghouses, pressure relief valves and high level alarms to mitigate dust emissions; Procedures for, where practicable, limiting dust and odour nuisance and the methods for monitoring these procedures including identification of contingency measures to address identified and verified adverse effects on sensitive receptors. Contingency measures may include options such as: (i) Cleaning of air filtration intakes; or (ii) Cleaning of other buildings and infrastructure; Procedures for responding to any complaints received and the timeframes for response to complaints and reporting; Cross references to the specific sections in the Communication and Consultation Plan which detail how the communities in the vicinity of construction works are to be communicated with on the management of the adverse effects relating to air quality.

4, 5.3

5.4 5.4

4.7, 5.4

5.3.4

4.7, 5.4

5.6 6.2 6.1

Discharge Permit R/REG/2014/5437 64

This resource consent shall expire 15 years after the consent commences unless it has been surrendered or been cancelled at an earlier date pursuant to the RMA.

This document

65

The Consent Holder shall ensure that all processes on the Project worksite shall be implemented, operated, maintained, supervised, monitored and controlled so that any emissions authorised by this consent are maintained at the minimum practicable level.

This document

66

Unless provided for by Condition 67, there shall be no dust or odour beyond the boundary of the Project worksite caused as a result of on-site processes which, in the opinion of Council, is noxious, offensive or objectionable.

This document

67

All offensive or objectionable dust or odours beyond the boundary of the Project worksite caused as a result of construction and earthworks activities associated with the Project shall be mitigated as soon as practicable in accordance with the requirements of the certified Air Quality Management Plan as required by Condition 69.

This document

Air Quality Delivery Work Plan

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5

Condition Number

Condition

Relevant Section of DWP

68

The Consent Holder shall ensure that beyond the boundary of the Project worksite, there shall be no hazardous air pollutant, caused as a result of construction and earthworks activities associated with the Project that causes, or is likely to cause, adverse effects on human health, environment or property.

This document

69

The Consent Holder shall review the draft Air Quality Management Plan – Britomart to Wyndham dated December 2014 (“draft AQMP”), prepared by Golder Associates (NZ) Limited and submit to Council (Team Leader Central Monitoring) a final AQMP(s) which is (are) generally consistent with the draft AQMP provided in support of the application material.

This document

70

The final AQMP(s) shall be prepared by a senior qualified person, provided to the Council (Team Leader Central Monitoring) for certification at least 20 working days prior to the commencement of construction and shall include: (a) clear identification of the type and location of the controls proposed; (b) a detailed framework for the management, mitigation and monitoring of construction and earthworks activities associated with the Project; (c) a focus principally on the sources of dust discharges, and (d) an assessment of the risk of discharges from each Active Construction Zone and the associated Construction Support Areas.

71

The final AQMP(s) shall also provide detailed methods including, but not limited to, the following matters: (a) methods to ensure the exposed surfaces remain dampened to minimise dust emissions (possible examples include a suspended water spray system or other suitable system, water carts and other suppression methods); (b) a 20 km/hr vehicle speed limit within the Active Construction Zones and Construction Support Areas (c) installation of wheel washes (d) regular sweeping of public roads around the exit points of Active Construction Zones and Construction Support Areas and sealed vehicle accessways within these areas; (e) measures for dampening any temporary stock piles (which are to be limited to no more than 24 m³ of spoil at any one time in each Active Construction Zone); (f) measures for the handling of cement associated with forming of cement stabilised columns, including filter systems and high level alarms where a silo is used; (g) covering of loads of material being delivered and removed from the site; (h) instrumental monitoring of dust concentrations (identification of a monitoring methodology, monitoring network and appropriate alert thresholds) to ensure that any significant dust effects arising from the Active Construction Zones or Construction Support Areas are identified and remedied as soon as practicable throughout the Project; (i) the locations of instrumental dust monitoring sites, including one re-locatable monitor to be associated with Active Construction Zones A to D and fixed monitors associated with Active Construction Zone E;

Air Quality Delivery Work Plan

1.4 5 This document This document 2.2 - 2.4

5.3.1, Table 5.1

Table 5.1 Table 5.1 Table 5.1 Section 5.1 and Table 5.1 Table 5.1

Table 5.1, 5.2 4.3

4.4

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6

Condition Number

Condition

(j) measures for responding to continuous instrumental dust monitoring trigger alarms, including contingency measures to reduce measured concentrations below the trigger thresholds and provisions for responding after standard operating hours; (k) measures for undertaking meteorological observations and visual inspections of dust or other air discharges from the Project, to be completed at least on a daily basis, with all relevant information logged; and (l) information regarding complaint logging, investigation and response procedures, training and roles and responsibilities.

Relevant Section of DWP 4.3.3, 5 and Appendix B

4.2, 4.3.2 and 8 6, 7, 8, 9

73

Any change to the AQMP(s) shall be submitted to the Council (Team Leader Central Monitoring) for certification. No activity reliant upon a change to the AQMP can be undertaken until the change has been certified. The Consent Holder shall request the Council’s (Team Leader Central Monitoring) determination as to whether the change can be certified, in writing, within 10 working days of submission of the change

10

74

All works shall be undertaken in accordance with the certified AQMP(s).

This document

75

Prior to construction commencing, and for the duration of excavation and construction associated with the Project which have the potential for significant dust emissions, the Consent Holder shall install, operate and maintain mobile instrumental continuous dust monitors for the purposes of monitoring Total Suspended Particulates (TSP) and/or fine particulate matter (PM10). The monitors shall be operated at locations and according to methods detailed in the certified AQMP(s) required by Condition 69.

4

76

The instrumental dust monitoring equipment shall be fitted with an alarm system that, when dust concentrations exceed alert levels specified by the certified AQMP(s), send a warning to the responsible person identified by the AQMP(s). The Consent Holder shall ensure that the responsible person, or other nominated person, is available at all times to take immediate action to reduce dust emissions from the site.

4

1.3

Sustainability

Auckland Transport (AT) is seeking an Infrastructure Sustainability Council of Australia (ISCA) Infrastructure Sustainability (IS) Rating. Further details can be found in the Project CEMP and Sustainability Rating Management Plan. Project sustainability requirements that relate directly to this Air Quality DWP are included in Appendix A. These requirements are imbedded within the Delivery Work Plans and management plans for the Project to ensure that sustainability is a key focus and ‘the way we do things’. In some cases the IS requirements and sustainability goals enhance the designation and resource consent requirements.

1.4

DWP Review and updates

This Air Quality DWP is a live document that will be reviewed and updated if needed during the course of the Project to reflect material changes associated with construction techniques or the natural environment. Any material changes to this DWP must be certified by Auckland Council (AC) prior to any on-site activity reliant upon the change commencing. A formal review process is described in Section 10 of this DWP.

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7

1.5

Air Quality DWP Author

This Air Quality DWP has been prepared by Andrew Curtis, an Associate Director and leader of the air quality team for AECOM. Andrew has more than 28 years’ engineering experience and almost 19 years’ experience as an air quality consultant, in which time he has been responsible for leading some of New Zealand’s largest air quality projects.

1.6

Preparation Standards

In preparing this DWP, information has been drawn from practical experience with the management of air quality emissions from large construction processes as well as the following documents: 

The Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emissions prepared by the Ministry for the Environment; September 2001;



Draft Guide for Assessing Air Quality Effects for State Highway Asset Improvement Project, prepared by the NZ Transport Agency; Version 0.6 September 2012; and



NZ Transport Agency Draft Erosion and Sediment Control Field Guide for Contractors.

Air Quality Delivery Work Plan

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8

2

Project Description

2.1

Overview

The Project involves the construction of an extension to the existing passenger rail network from the current termination point within the BTC, westwards underneath the CPO and Lower Queen Street. Separate works are being undertaken to continue the CRL tunnels from this point under the Downtown Shopping Centre site (which is to be redeveloped by Precinct Properties), and then up Albert Street. Significant works beneath the CPO will be undertaken, with the construction of two new rail tunnels extending westwards beneath the basement floor level. In Lower Queen Street, sheet piling will be extended across the road corridor, excavation undertaken to form the tunnels followed by reinstatement of the road corridor following the completion of works. During construction, existing ticketing and retail functions and pedestrian access to the station will be accommodated in Station Plaza, at the rear of the CPO building. Surface works will also be required in QEII Square associated with the Downtown Shopping Centre redevelopment, including construction of the CRL rail tunnels beneath this site (Precinct Properties scope of work). A detailed description of the construction works is provided in the CEMP.

2.2

Construction Zones

The Project will be divided into four discrete active construction zones (ACZ) as shown in Figure 2.1.

Figure 2.1: Active Construction Zones2

2

The referencing of Project ACZs adopted in this DWP reflects that of the BTC designation in order to ensure consistency across all Project Delivery Work Plans and Environmental Management Plans. It is noted that under the resource consents, the Project area is separated into two larger ACZ’s – ACZ A (CPO) and ACZ B (Lower Queen Street). Air Quality Delivery Work Plan

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9 This Air Quality DWP relates to the proposed works summarised in Table 2.1. Table 2.1:

Summary of key construction activities3

Active Construction Zone

Key construction activities

A

Britomart Station modifications  Modification of existing platforms and track lines  Installation of temporary access stairs, station entry and egress

B

Accommodation within Station Plaza  Construction of temporary accommodation buildings and facilities and relocation of ticketing, staff facilities, public amenities, retail/kiosk areas from the CPO building  Installation of services.

C

CPO Building Works  Removal of the CPO fixtures and fittings  Saw cutting and demolition of the CPO ground floor and processing concrete for use as backfill later  Installation of guide walls, diaphragm walls and underpinning structures to provide support for the CPO  Soil excavation  Construction of the base slab, walls and roof for the new rail tunnels  Backfill excavation  Reinstatement and fit out of CPO building

D

Lower Queen Street  Bentonite plant located adjacent to the south west corner of the CPO building on Lower Queen Street  Jet grouting plant located adjacent to the north west corner of the CPO building on Lower Queen Street  Carry out piling and underpinning works  Soil excavation  Construct base slab, walls and roofs for new rail tunnels  Backfill excavation  Reinstatement of Lower Queen Street

Excavation of both Lower Queen Street and beneath the CPO will be conducted concurrently. The proposed excavations will extend approximately 16 m below ground level (bgl) beneath the CPO and Lower Queen Street with the excavations in Lower Queen Street extending approximately 28 m from the western edge of the CPO building. Spoil will be loaded directly onto truck and trailers and transported from the site. The Lower Queen Street excavation will be covered by a partial roof structure, which will serve to minimise the potential for discharges to air from the open working area. Works within the CPO will be contained within the CPO building structure. A detailed description of the construction methodology is provided in the Project CEMP.

3

Note these activities are not in order of programme

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10

2.3

Discharges to Air

The main discharge to air from the construction activities outlined in Table 2.1 will be particulate matter (dust). The following activities have the potential to result in discharges to air: 

Demolition activities;



Storage of materials;



Forming of cement stabilised columns;



Mixing of bentonite powder and bentonite slurry as part of the diaphragm wall construction;



Excavation and spoil removal;



Movement of vehicles (this includes trucks, loaders and excavators required for the tunnel excavation and spoil removal, and the delivery of construction materials such as concrete and steel);



Backfilling of the excavation; and



Excavation of potentially contaminated material.

2.4

Location of Activities

The location of activities that have the potential to result in discharges to air are as follows: 

Construction of temporary accommodation buildings in Station Plaza to the rear of the BTC;



Footpath widening along Galway and Tyler Streets;



Removal of fixtures and fittings within the CPO building;



Processing of concrete within the CPO building;



Piling and excavation works within the CPO building;



Road surface removal, excavation and piling works in Lower Queen Street;



Small stockpiles of excavated material located across the Project area;



Mixing of bentonite powder and bentonite slurry in Lower Queen Street;



Operation of the jet grouting plant, including cement handling in Lower Queen Street;



Spoil removal from the CPO and Lower Queen Street; and



Vehicle movements within the Project area.

Air Quality Delivery Work Plan

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11

3

Environmental Aspects

This section of the Air Quality DWP sets out relevant background information as well as the environmental standards recommended by AECOM.

3.1

Receiving Environment

The Project is being undertaken in the centre of the Auckland CBD, close to the waterfront and a range of business, residential, and tourist activities such as Princess Wharf. Despite the large traffic volumes in the Project area, it is considered that the receiving environment is likely to be highly sensitive to nuisance dust.

3.2

Meteorology

Figure 3.1 presents a windrose for the Britomart area, which has been generated using synthetic data. As shown in this figure, the predominant winds are from the southwest and northeast, which is essentially the orientation of Lower Queen Street. This means that any dust generated by the construction works has the potential to be carried towards Queens Wharf in southerly winds and Queens Street during northerly winds. However, given the potential for buildings to disrupt and redirect wind flows, and cause localised eddies, it is likely that the Project area will potentially experience a greater percentage of strong winds towards the north than indicted by the windrose. Figure 3.1 will be updated once sufficient information is available from the weather station to be located at the bottom of Albert Street as part of Contract 2 of the CRL Enabling Works.

Figure 3.1 Britomart Windrose

3.3

Environmental Performance

As required by the CRL and BTC designation conditions and the Britomart to Wyndham Street discharge permit conditions, the purpose of this DWP is to ensure that construction air quality effects are kept to a practical minimum, recognising the sensitivity of the environment within which the works are being undertaken. Air Quality Delivery Work Plan

June 2016

12 Generally, the key compliance measure used in construction processes is that dust and other air discharges do not result in “off-site” nuisance, where off-site in this case is defined as being outside the area bound by Lower Queen Street, Commerce Street (north of Customs Street East), Galway and Tyler streets (west of Commerce Street). Because a “dust nuisance” cannot necessarily be identified until it has occurred, there are numerical guidelines that can be used in conjunction with Total Suspended Particulate monitoring to identify levels of dust that are likely to be considered a nuisance. These values, developed by the Ministry for the Environment (MfE), are set out in Table 3.1, together with additional values to deal with short term emissions that are most likely to result in effects. Table 3.1 also contains Trigger levels for odour, wind and dust deposition. Table 3.1:

Environmental Trigger Levels for Air Discharges

Discharge

Trigger Level

Dust Monitoring

 MfE Maximum Values not to be exceeded: - 80 μg/m³ (24 hour average) – sensitive area Upper Limit  Trigger values for Action: - 160 μg/m³ (1 hour average) - 60 μg/m³ (24 hour average)

Wind Speed

 Wind warning level (3 second gust) 10 m/s (measured at 10 m above ground level or equivalent value for other monitoring heights)

Dust Deposition

 Evidence of dust on windows (a finger run down the glass leaves a clear line)  Dirt on clean washing

Odour

 Presence of odour that is out of character with environment (e.g. smell of refuse in a residential area)

3.4

Sensitive Receptors

All receptors located within 100 m of the area bound by Lower Queen Street, Commerce Street (north of Customs Street East), Galway and Tyler streets (west of Commerce Street), are considered sensitive receptors for the purposes of this DWP.

Air Quality Delivery Work Plan

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13

4

Monitoring Requirements

4.1

Dust Monitoring

The overall approach to dust control for the construction works is primarily based on visual monitoring in combination with targeted ambient dust monitoring; good management of the construction areas; and a rapid response to any of the triggers outlined in Table 3.1 or complaints received. Good practice focusing on pre-emptive measures will aid in the avoidance of significant dust emissions, or if dust emissions occur, the subsequent mitigation or remediation of any adverse effects.

4.2

Visual Inspection and Monitoring Methods

Visual monitoring of all construction areas will be undertaken on a daily basis or more frequently, if conditions change. This type of monitoring relates to the control measures described in Section 5 of this DWP and will include pre-emptive measures to avoid dust emissions. Table 4.1 below describes the visual dust monitoring programme to be implemented during construction. Table 4.1:

Visual Dust Monitoring Programme

Monitoring Activity

Frequency

Check weather forecasts for strong winds and rainfall to plan appropriate work schedule and dust management response.

Daily

Inspect land adjacent to the site, construction exits and adjoining roads for the presence of dust deposition.

Twice daily

Observe weather conditions including wind and rain via observations and data outputs from weather stations.

Daily and as conditions change

Inspect all exposed surfaces for dampness and to ensure that the exposed un-stabilised area is minimised.

Daily and as conditions change

Inspect stockpiles to ensure enclosure, covering, stabilisation or dampness. Ensure stockpile is no greater than 24 m3 and less than 3 m in height where possible or appropriate.

Daily and as conditions change

Inspect dust generating activities to ensure dust emissions are effectively controlled.

Daily and as new activities are commenced

Inspect watering systems (sprays and water carts) to ensure equipment is maintained and functioning to effectively dampen exposed areas.

Weekly

Monitor dust generating activities and water application rate.

In winds over 5.5 m/s (11 knots or Beaufort Scale 3)

Check for dust on local roads being used to access the site.

Daily

Inspect any wheel wash equipment to ensure effective operation.

Weekly

4.3

Instrumental Monitoring

4.3.1

Dust

Continuous Total Suspended Particulate (TSP) dust monitoring will be carried out alongside the excavation on Lower Queen Street in order to provide real-time information on dust levels that can be used for managing dust events as they occur. This monitoring is to complement the visual inspections described in Section 4.2 of this DWP. As discussed in the Air Quality Assessment for the discharge permit (Golder 2014a), the Lower Queen Street excavation is considered to be the main potential source of dust emissions for this phase of the works. Air Quality Delivery Work Plan

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14 As required by Condition 75 of discharge permit R/REG/2014/5437, ambient dust monitoring will commence at least 4 weeks prior to activities, which have the potential for significant dust emissions. This will enable background data to be collected and compared against monitoring data to be collected during the construction phase of the Project. The pre-construction monitoring will also ensure that there is sufficient time to revise the trigger levels in the event that the initial values are too low, i.e. they are being exceeded by existing activities within the Project area, such as traffic emissions. Instrumental monitoring for the Project will include: 

Continuous instrumental TSP monitoring at the locations outlined in Section 4.4 of this DWP;



Calculation of 1 hour and 24 hour average concentrations from real-time monitoring data;



Remote display of real-time TSP and meteorological data (e.g. via the internet);



Provision for alarms on 24-hour and 1-hour average concentrations and wind measurements (visual and/or via internet, email and mobile phone);



Recording/logging of monitoring data; and



Where practicable the monitors shall be located in accordance with AS/NZ 3580.1.1:2007 Method for Sampling and Analysis of Ambient Air – Guide to Siting Air Monitoring Equipment; and AS 3580.14 -2011 Ambient Air – Guide for the Measurement of Horizontal Wind for Air Quality Applications.

Examples of the types of continuous TSP monitors that could be used include: 

Continuous particulate monitoring in accordance with United States Code of Federal Regulations, Title 40-Protection of Environment, Volume 2, Part 50, Appendix O-R Reference Method for the Determination of Coarse Particulate Matter as PM in the Atmosphere (e.g. Beta- Attenuation Monitor); and



Optical analysis methods with gravimetric calibration (e.g. E-Sampler).

4.3.2

Meteorological Monitoring

A meteorological station, which can continuously measure the following parameters, will be installed at a location (to be determined) on Albert Street as part of Contract 2 of the CRL enabling works. Given the proximity of the Project area, it is considered that location of the meteorological station in Albert Street will be appropriate for the works in Lower Queen Street. 

Wind direction;



Wind speed;



Rainfall; and



Temperature.

4.3.3

Dust Trigger Alerts

The monitoring equipment will be set up with text alerts to key personnel in the relevant work zone, when dust concentrations exceed the Trigger values set out in Table 3.1. At a minimum this will include: 

The Project Manager;



The Environmental and Sustainability Manager;



The Construction Manager; and



Site Manager.

If Project personnel change, the Instrument Technician will be contacted to update the alerts.

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15 If a dust trigger alert is sent, one of the above staff members will immediately (within 30 minutes) respond and investigate the cause of the alert. This investigation will: 

Determine if the alert is real and not caused by equipment malfunction; and



Identify the source of dust and check to see that all of the required mitigation measures are being implemented.

If it is determined that construction activities are the cause of dust, and that mitigation measures outlined in Sections 5.1 – 5.5 of this DWP are not effective for controlling dust, the contractor will implement the dust contingency measure outlined in Section 5.6 of this DWP. If these measures fail to effectively manage dust to acceptable levels, works shall be halted until it can be determined why dust emissions are occurring and what additional mitigation measures are required to control ambient dust to acceptable levels. The findings of the investigation will be recorded in the Air Quality Log (refer to Section 8.1 of this DWP).

4.3.4 Wind Speed Trigger Dust Trigger Alerts In the event that wind speeds exceed the trigger values set out in Tables 3.1 and 4.1 of this DWP, text alerts will be sent to nominated Project personnel in the relevant work zone. As a minimum, the nominated personnel will include: 

The Project Manager;



The Environmental and Sustainability Manager;



The Construction Manager; and



The Site Manager.

If wind speeds exceed 5.5 m/s then the Site Manager will appoint an appropriate member of the Project team to undertake visual monitoring of the work area, and ensure that all appropriate mitigation outlined in this DWP is being implemented. Should wind speeds exceed 10 m/s, all work that could give rise to dust generation and potential effects shall cease, unless the TSP monitoring demonstrates that TSP trigger levels are not being exceeded.

4.4

Monitoring Locations

Two portable and continuous TSP monitors will be deployed at pre-determined locations around the Project area when activities that have the potential to generate TSP (primarily the cut and cover tunnel works in Lower Queen Street) are occurring. These monitors will both be located within Lower Queen Street, one to the north close to the Tyler Street and Lower Queen Street intersection, and one to the south close to the Galway Street and Lower Queen Street intersection (refer to Figure 4.1). This will allow the monitoring to detect any high dust levels from construction activities as they occur, and enable the Contractor to reduce dust levels before it becomes a nuisance for sensitive receptors located in proximity to the Project.

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TSP Approximate Monitoring Locations

Figure 4.1: Indicative Monitoring Locations

4.5

Monitoring Data

All monitoring data from the dust (TSP) monitors and the on-site meteorological station will be available to Project staff on-line.

4.6

Monitoring Equipment Maintenance

The TSP monitoring equipment and meteorological equipment will require periodic maintenance. The monthly maintenance of the equipment will be carried out by either site personnel, who have received appropriate training, or an Instrument Technician. Quarterly maintenance and calibration will be carried out by an Instrument Technician familiar with the equipment installed. In the event that there is an equipment malfunction, or the equipment needs to be relocated for some reason, then the Instrument Technician will attend to this.

4.7

Odour Monitoring

Odour monitoring will be undertaken when it is considered likely that odorous material will be encountered (such as contaminated materials) during excavations. This decision to undertake monitoring will be made by the Environmental and Sustainability Manager. The frequency of monitoring will be dependent on the nature / scale of the source, location in relation to sensitive receptors, and meteorological conditions during exposure. Odour scouting will occur: 

When potentially contaminated material is excavated and loaded onto heavy vehicles; and



When odour complaints have been received.

Air Quality Delivery Work Plan

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17 The Environmental and Sustainability Manager will ensure that at least one person in each work area is trained as an odour scout. Monitoring will involve the odour scout being positioned downwind of the works and assessing odours on the intensity scale set out in Table 4.2. Where odours are identified as being “Distinct” and above, and the odour characteristic unpleasant, mitigation measures will be implemented. All observations will be recorded in the Air Quality Log (refer Section 8.1 of this DWP). Table 4.2:

Odour Intensity Scale

Intensity Scale

Criteria

0

No Odour

1

Very Weak

2

Weak

3

Distinct

4

Strong

5

Very Strong

6

Extremely Strong

The odour scout will reassess the level of odour once the mitigation measures have been implemented. If the odours are still ‘Distinct’, further mitigation will be implemented, and / or the works halted until more conducive meteorological conditions are present, i.e. not blowing towards the sensitive receptor. If it is suspected that sources upwind of the works are responsible for any odour, the odour scout shall make appropriate observations and document these also.

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5

Management Procedures

A range of routine measures will be used to manage and mitigate the effects of discharges of dust, odour or construction vehicle exhaust emissions during the Project. Additional mitigation may also be required in the event that: 

Monitoring indicates that abnormal discharges of dust are occurring;



Weather conditions are changing such that dust or odour discharges are more likely as determined using the Dust Risk Index; and / or



Complaints are received regarding discharges of dust, odour or construction vehicle exhaust emissions.

If the available mitigation methods are unsuccessful in controlling discharges (i.e. dust and odour) that cause significant adverse effects on receptors beyond the Project boundary, the activities causing the discharge shall be suspended until adequate mitigation can be put in place.

5.1

General Methods of Dust Control

Dust control methods are generally associated with reducing the potential for dust generation and transport associated with the activity factors described in Section 2 of this DWP that may reduce dust generation and transport potential. General measures that may be employed to control dust from construction activities include: 

Controlling dust from stockpiles (if used during the works). Note that in accordance with Condition 71(e) of discharge permit R/REG/2014/5437 stockpiles shall not exceed 24 m 3 of spoil in each ACZ;



Utilising windbreaks around stockpiles;



Controlling dust from exposed surfaces: Placing limits on vehicle speeds;



Limiting disturbance of soil or dusty materials: Design of earthworks to minimise cut volumes reduces dust emissions. Reduction in vehicle movements and speeds and the use of lighter vehicles will also reduce disturbance and dust generation;



Limiting area of exposed materials: Staging of works and minimisation of material exposure in works areas will reduce the potential for wind erosion;



Temporary stabilisation of unpaved roading surfaces or yard areas through the use of dust suppressants can also provide an alternative to wet suppression as a dust control method;



Maintenance of surface moisture content: Watering or wet suppression is used to dampen dry or dusty exposed areas; and



Removing excavated spoil from site on a regular basis.

5.2

Dust Risk Index

One of the main potential air quality impacts comes from dust associated with the construction process. To provide better guidance to the Environmental and Sustainability Manager, and area supervisors on implementation of dust mitigation, this Project will use a Dust Risk Index (DRI). The DRI process is described in Appendix B. A simple “traffic light” indication of dust risk will be posted in each work area, so that both Project staff and members of the public are aware of the dust risk. This system will indicate that dust risk on a particular day is: 

Low (Green Light);



Moderate (Orange Light); and

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19 

High or Extreme (Red Light).

5.3

Dust Mitigation Measures

The dust management methods recommended in Table 5.1 are methods that have been found to be effective for many construction sites across New Zealand. These methods can be used alone or in combination depending on the circumstances. Alternate methods may be employed after the effectiveness of those methods is demonstrated and this DWP updated accordingly. The scale of dust prevention methods required in a particular Project area will be dependent on the degree of risk and level of adverse effects from dust discharges on the surrounding area. The dust control methods for the various degrees of risk are described below.

5.3.1

Methods of Dust Control – All Areas (Low Risk)

The dust management measures outlined in Table 5.1 will be used, as applicable, in all areas of the Project. The list is not exhaustive and additional methods may be found to be effective. Table 5.1:

Dust management measures for all areas (Low Risk Conditions)

Source of Dust

Control

Stockpiles (if used during the works)

 Limit the height and slope of stockpiles to reduce wind entrainment. Stockpiles are to be no more than 24 m³ at any one time in each ACZ. Stockpiles exceeding 3 m in height have a higher risk of discharging dust  Orientate stockpiles to maximise wind sheltering as much as possible  Maximise shelter from winds as far as practicable  Keep active stockpiles damp at all times or bunker or cover stockpiles of fine materials4  Dampen inactive stockpiles if they are producing visible dust emissions  Stabilise stockpiles using various means depending on the length of inactivity (e.g. soil binders if inactive for 28 days).

Unpaved Surfaces such as Roads and Yards

 Limit the amount of exposed surfaces as much as possible  Keep exposed surfaces damp. Typical water requirements for most parts of New Zealand are up to 1 litre per square metre per hour  Cover surfaces with coarse materials where practicable (e.g. ballast)  Stabilise cleared areas not required for construction, access or for parking if liable to cause excessive dust during windy conditions. Methods may include placing metal on surfaces.

Sealed surfaces

 Regular removal of dust through washing or vacuum sweeping, particularly around the exit points of Active Construction Zones. Frequency determined by visual inspections  Clear all spillages on sealed surfaces as soon as practicable.

Vehicles

    

Demolition

 All potential dusty material is removed from the site using covered trucks

Limit vehicle speeds to 20 km/h Limit load sizes to avoid spillages Cover loads of fine materials Minimise travel distances through appropriate site layout and design Minimise mud and dust track out from unsealed areas to sealed areas by using wheel cleaning facilities at site exits to sealed roads  Installation of wheel wash equipment (likely to be a hose)

4

In the context of this AQ DWP, fine material is defined as material which has a mean diameter of less than 200 microns, and could contribute to TSP if it becomes airborne Air Quality Delivery Work Plan

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20

Source of Dust

Control  As required water sprays are used to dampen material to avoid dust generation.

Piling

 All spoil to be placed in a specific location and removed from site as soon as possible  All cement silos to be fitted with appropriate control equipment  Any spilt material to be cleaned up immediately.

Ground stabilisation

 All spoil to be placed in a specific location and removed from site as soon as possible  All cement silos to be fitted with appropriate control equipment  Any spilt material to be cleaned up immediately.

Bentonite powder handling

 All silos to be fitted with appropriate control equipment  All waste material to be contained until it is removed from site  Any spilt material is to be cleaned up immediately.

Miscellaneous

 Ensure sufficient water is available on site  Take account of daily weather forecast wind speed, wind direction and spoil conditions before commencing an operation that has a high wind potential;  Install wind fences where practicable and appropriate. Effectiveness is greatest where fencing is perpendicular to the prevailing wind direction with porosity of about 50%  Minimise the area of surfaces covered with fine materials.

Earthmoving and Construction

 Limit the extent of earthworks carried out during dry conditions as far as practicable  During periods of extreme dust risk, dampen areas that are to be earth-worked prior to any earthwork commencing. Allow time for penetration of the soil  Limit drop heights.  Stabilise exposed areas not required for construction, access or parking, along with completed fill and spoil areas as soon as practicable.

5.3.2

Further Methods of Dust Control (Medium Risk Conditions)

Medium risk conditions require a greater level of dust control and attention to dust suppression. The methods outlined in Table 5.2 shall be implemented in addition to the methods outlined in Table 5.1 during conditions presenting a medium risk. As above this list is not exhaustive and other methods may also be employed to control dust. Table 5.2:

Potential dust sources and control methods for medium risk areas

Source of Dust

Control

Vehicle Movements on unsealed surfaces

 Further limit vehicle speeds on unsealed surfaces  If winds are predicted in excess of 8 m/s (16 knots or Beaufort Scale factor 5), maintain unsealed surfaces in regular use in damp condition through surface watering (e.g. with water carts or fixed irrigation)  Where a suitable water supply is not available for surface watering, synthetic dust suppressants may be used as an alternative. The use of recycled oilbased suppressants is expressly prohibited.

Loading, unloading and transport of dusty materials

 Limit loading or unloading during windy conditions that cause dust to be emitted beyond the site boundary  Limit vehicle speeds on unsealed surfaces.

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Source of Dust

Control

Stockpiling (if used during the works)

 Bunker or cover stockpiles of fine, dry materials.

5.3.3

Further Methods of Dust Control (High and Extreme Risk Conditions)

The greatest attention to dust control shall be paid in extreme risk conditions and this is reflected in the further control measures outlined in Table 5.3. These methods shall be employed in addition to the measures outlined in Table 5.1 and Table 5.2 during extreme risk conditions. As above this list is not exhaustive and other methods may also be employed to control dust. Table 5.3:

Potential dust sources and control methods for high and extreme risk areas

Source of Dust

Control

Vehicle Movements on unsealed surfaces

 Maintain regularly used unsealed road surfaces in damp condition through surface watering in all wind conditions.

Earthmoving, excavation and construction

 Maintain surfaces of active earthworks areas in damp condition. This should include pre-watering of earthworks surfaces, prior to excavation allowing enough time for moisture to penetrate the soil.

Stockpiling (if used during the works)

 Maintain active stockpiles in damp condition with regular watering  Dampen inactive stockpiles if they are producing visible dust emissions  Utilise windbreak fences or temporary bunkers if they are producing visible dust.

5.3.4

Operation of Dust Control Equipment

The dust control equipment subcontractor will provide information on the following: 

5.3.5

Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including baghouses, pressure relief valves and high level alarms to mitigate dust emissions.

Equipment Malfunction

If construction equipment fails and causes accidental dust discharges, it will be shut-down immediately and the fault repaired and tested prior to being allowed to continue operation. If equipment associated with dust control fails (such as a baghouse) the activities reliant on the equipment will be suspended until the fault can be repaired. The location, duration and time of any dust discharge caused by equipment failure will be recorded in the Air Quality Log.

5.4

Review of Dust Mitigation

When site operators are alerted to a potential off-site dust nuisance through any of the monitoring techniques described in Section 4 of this DWP, or as a result of a complaint from a third party, the Site Supervisor will immediately undertake a review of site activities to determine the source of the dust and implement further mitigation measures as required in order to reduce the dust generation to acceptable levels. As appropriate the Site Supervisor will notify the Environmental and Sustainability Manager. In general, the additional mitigation will be those measures set out in Tables 5.1 to 5.3. Once the additional mitigation has been implemented the Site Supervisor will review the monitoring data to ensure that it has been effective. Air Quality Delivery Work Plan

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22

5.4.1

Sources of Information

The following are locations where information necessary for determining the DRI and general dust control can be obtained: 

Site Specific monitoring web site where TSP and meteorological data can be accessed (to be established); and



Met Service: http://www.metservice.com/towns-cities/auckland/auckland-central

5.4.2

Odour Control during Contaminated Material Handling

Odour may occur if contaminated soil is encountered during the excavation process. This section of the DWP sets out the mitigation required by CRL designation Condition 59.3(g) and BTC designation Condition 33A.3(g) for minimising any potential for odour if contaminated material is encountered. Odour emissions will be monitored by the odour scout during the excavation of contaminated material and the following techniques considered if necessary: 

Limiting the time that the odorous material in the excavation is exposed;



Removing excavated odorous material from site as quickly as possible in covered trucks; and



The use of odour masking agents, chemical counteractants or digestive deodorant sprays.

If significant odour is detected and the odorous material cannot be removed quickly and odour masking agents, chemical counteractants or digestive deodorant sprays are not immediately available, the odorous material shall be covered, and work in that area suspended until suitable mitigation measures can be put in place. Section 4.7 of this DWP sets out the odour monitoring procedure to be implemented during the works.

5.5

Control of Vehicle Exhaust Emissions

The following key actions shall be carried out to minimise emissions from vehicle exhausts: 

All construction machinery used on the site will be maintained at least in accordance with manufacturers’ requirements;



Where excessive exhaust smoke is identified from any construction vehicle that vehicle will be serviced as soon as is practicable and taken out of use until such maintenance has been completed; and



Unless warm-up or turbo maintenance procedures require it, construction vehicles will not be left idling while parked or unattended.

5.6

Dust Contingency Measures

In the event of a significant dust emission that results in either complaints or concentrations of dust that are significantly greater than the trigger values set out in Table 3.1, the contractor will implement the following contingency measures, dependent on the nature of the complaint: 

Dust inside buildings or at a level which prevents windows being opened - Following discussions with the building owner and/or occupiers, arrange to fit or retrofit dust filters to any building/apartment air supply systems. Where a building or specific apartment does not have an existing air supply system, then such a system will be installed, and all reasonable costs associated with the installation, operational and maintenance costs while the Project is occurring will be covered by AT.

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Air Quality Delivery Work Plan

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6

Communication and Complaints

6.1

Project Communications

Sections 11 of the Project Communication and Consultation Plan details how communities in the vicinity of the construction works will be communicated with in relation to the management of adverse effects relating to air quality. Communications will focus around informing communities of dust management and monitoring measures to be implemented during the Project and providing updates on these aspects as appropriate during the construction works.

6.2

Complaints

Although the measures described in this DWP are aimed at avoiding complaints regarding discharges to air, complaints may in practice be made on occasions by members of the public. It is important to ensure that any complaints are recorded and promptly investigated to identify and resolve the cause of the complaint. The requirements and procedures relating to complaints are detailed below.

6.2.1

Complaints Response

The Project Hotline will be clearly included in any written Project notifications and on signage located in proximity to the Project area. Any air quality complaints received by the Project Hotline will be recorded in a complaints file, and investigation will be undertaken as outlined in the CEMP and the Project Communication and Consultation Plan (refer to Section 5.3.1 of the CEMP and Section 12 of the Communication and Consultation Plan). The investigation will involve the following: 

Information about the incident as described by the complaint.



Acknowledge receipt of the concern or complaint. An initial response shall be undertaken within 24 hours of receiving a complaint, and resolved as soon practicable.



Weather conditions at the time of the complaint.



Reporting the findings and recommendations.



Actions and time taken to close-out complaint.



Communication with the complainant.



Reporting of the investigation in the complaints file.

A record of all concerns and / or complaints received will include, where applicable: 

The name of the person(s) who raised the concern or complaint (unless they elect not to provide this) and details of the concern or complaint.



Weather conditions at the time of the concern or complaint, including wind direction.



Details of any observed odour coming from the site by the person investigating the complaint.



Known construction activities at the time and in the vicinity of the complainant during the concern or complaint period.



Remedial actions undertaken (if any) and the outcome of these, including monitoring of the activity.

An investigation of the complaint will require the Site Supervisor or delegated staff member to go around the whole site and make visual observations about activities occurring on site. This may also include going to the location where the complainant observed the impact. At all times during the complaints investigation, appropriate health and safety procedures must be followed.

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7

Environmental Training

7.1

Project Staff

All Project staff (contractors and subcontractors) will undergo general environmental awareness training and training about their responsibilities relating to this Air Quality DWP. Training requirements are described in full detail within the CEMP. Specific training requirements relating to this DWP are outlined in Table 7.1. Table 7.1:

Air Quality DWP specific training requirements.

Training requirements

Frequency

Attendance

Introduction to the on-site monitoring equipment

As required and during new staff induction

All new staff members

Responding to continuous dust monitoring trigger alarm alerts

As required and during new staff induction

Site Manager, Environmental and Sustainability Manager, delegated staff member and duty managers

Responding to complaints regarding dust and air quality concerns

As required and during new staff induction

Site Manager, Environmental and Sustainability Manager, delegated staff member and duty managers

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8

Record Keeping

8.1

Air Quality Log

Construction activities can be affected by a number of different external and internal factors, such as weather conditions or equipment malfunction, which can contribute to an increase in dust emissions. Various control and mitigation measures will be carried out on the site in order to prevent such effects, and monitoring and inspection procedures will be used to assess the level of dust emissions both on the Project site and beyond its boundary. Recording relevant monitoring and inspection results, as well as the conditions of external and internal factors, can help to assess if control measures are being effective and to define appropriate corrective or preventive actions in case any undesirable effects are detected. The procedures for recording daily air quality inspections are detailed below: 

The site or duty manager will fill out an Air Quality Daily Log form each day and maintain the record on site.



The following information will be recorded: 

Records of TSP monitoring exceedances of the trigger levels specified by this DWP, including identification of the monitor ID which registered the exceedance, the time and the averaging period of the TSP exceedance (e.g. 1-hour or 15-minute average concentration);



Any dust control equipment malfunctions and any remedial action(s) taken;



Results of the Visual Inspections of dust emissions;



General weather conditions during the day (i.e. windy, calm, warm, rain, etc.);



The frequency of watercart and/or water sprinkling system use; and



The date and signature of the person entering the information.

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9

Roles and Responsibilities

9.1

Specific Roles and Responsibilities

The key management roles in relation to environmental management during construction are outlined in Section 4.1 of the Project CEMP. Specific roles relating to this Air Quality DWP are detailed in Table 9.1. Table 9.1:

Environmental management responsibilities.

Organisation

Role

Responsibilities

AT

Requiring Authority, Consent Holder and Project Manager

Compliance with the RMA. Overall responsibility for project compliance and performance in relation to environment, quality assurance and incident management. Obtaining any additional resource consents required during construction. Review of contractors’ site specific DWPs, EMPs, and relevant sub-plans.

DSBJV – The Contractor

Project Manager

Overall responsibility for site environmental management. Reviewing CEMP and sub-plans, including the Air Quality DWP. Reporting on environmental performance. Inspection of works to assess compliance with the Air Quality DWP and sub-plans. Assess the requirement for odour monitoring. Report to AT any changes to construction techniques or natural environmental changes which require alterations to existing consents or new resource consents. Prepare, review and update CEMP, including the Air Quality DWP and other sub-plans. Update and maintain the environmental portion of the Project Risk Register. Maintain Daily Logs and Complaint Records. Training of all staff including subcontractors.

Environmental and Sustainability Manager Construction Manager

AC

Consents and Compliance Teams

Air Quality Delivery Work Plan

Approve the CEMP, including the Air Quality DWP and other sub-plans. Auditing to assess that compliance with the Air Quality DWP.

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10

DWP Review and Updating

This Air Quality DWP has undergone a review process with the Community Liaison Group (CLG) established for the Project and an external Independent Peer Reviewer. An explanation of how any comments received from either the CLG or Peer Reviewer have been addressed is provided in Appendix C.

10.1

Review Process

The Air Quality DWP will be reviewed throughout the course of the Project: a

To reflect material changes associated with changes to construction techniques, the natural environment or due to unresolved complaints; and

b

As part of the annual management review of the DWP.

The annual review will be undertaken by the Project Management team and AT representatives. The management review will be organised by the Environmental and Sustainability Manager and the Project team will be informed of any changes to this DWP through the regular Project communications processes. The review will take into consideration: 

Compliance with the designation and discharge permit conditions, the CEMP, the suite of DWPs and EMPS (including site specific plans) and any material changes to these plans.



Any significant changes to construction activities or methods.



Key changes to roles and responsibilities within the Project team.



Changes in industry best practice standards.



Changes in legal or other requirements (social and environmental legal requirements, consent conditions, AT objectives and relevant policies, plans, standards, specifications and guidelines).



Results of inspections, monitoring and reporting procedures associated with the management of adverse effects during construction.



Comments or recommendations from AC regarding the CEMP, DWPs and EMPs.



Unresolved complaints and any response to complaints and remedial action taken to address the complaint.

10.2

DWP Updates

The process for updating this Air Quality DWP as a result of a material change to the Project or the annual review, is as follows (refer to CRL designation Condition 23 and BTC designation Condition 22 for further information): 

Any material change to this DWP must be consistent with the purpose and objective of the relevant conditions listed in Table 1.1 of this document.



Affected parties and the CLG must be notified of the review and any material change proposed to this DWP.



This DWP must clearly document the comments and inputs received from affected parties in relation to any material changes, along with a clear explanation of where any comments have not been incorporated, and the reasons why not.



Any material change proposed to this DWP shall be subject to an independent peer review as required by CRL Condition 11.



Any material change proposed to this DWP relating to an adverse effect shall be submitted for approval to Auckland Council Compliance and Monitoring Officer, at least 10 working days

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29 prior to the proposed changes taking effect. If any changes are not agreed, the relevant provisions of the RMA relating to approval of outline plans shall apply. A copy of the original DWP document and subsequent versions will be kept for the Project records, and marked as obsolete. Each new / updated version of the DWP documentation will be issued with a version number and date to eliminate obsolete DWP documentation being used. A summary of the review process will be provided annually to AC and otherwise be made available on request.

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Appendix A:

ISCA Requirements

Table A identifies the ISCA Credit Requirements relevant to this Air Quality DWP and where they are addressed in the document. Table A: ISCA Requirements Credit

Requirement *

Relevant section

Other relevant information / comments

DIS-4 Level 1

Measures to minimise adverse impacts to local air quality identified and implemented

Sections 1.1, 2.2, 5.1, 5.3, 5.4.2, 5.5, 8.1

Also refer to Project Erosion and Sediment Control Plan

DIS-4 Level 1

Monitoring of air emission and/or quality is undertaken at appropriate intervals

Sections 4.1, 4.2, 4.3, 4.4, 6

DIS-4 Level 1

Monitoring of air emission and/or quality is undertaken in response to complaints

Sections 4.7, 5.4, 6.1

DIS-4 Level 3

Monitoring and Modelling demonstrates no exceedances of air emission or air quality goals

Table 3.1

* Refer to ISCA Rating Tool for full details of the requirement

Note: MfE Maximum values are goals. Also refer to Monitoring Results and Reports

Appendix B:

Dust Risk Index

Example of Dust Risk Index (DRI) calculation One of the main potential air quality impacts comes from dust associated with the construction process. The foregoing discussion sets out some of the mitigation measures that can be used to control this. However there are work activities and locations where the need for dust mitigation is minimal and others where it is extremely important. To provide better guidance to the Construction Manager, and area supervisors on the implementation of dust mitigation, this project will use a Dust Risk Index (DRI). This is a technique recently developed for the construction phase of the Cambridge Expressway and Transmission Gully. The full NZTA version is detailed below. DSBJV may develop a simplified, project specific version going forward. Alternatively, DSBJV may employ an entirely different dust prediction process. The objectives of using the DRI are to highlight those areas and activities that are of higher risk of generating dust issues by: 

A systematic and consistent approach to risk identification in relation to dust generation;



A simplification of decision making in relation to the application of dust mitigation techniques and procedures; and



Improved Stakeholder satisfaction and a reduction of dust related complaints from them.

Factors and Weighting Assumptions The DRI uses a simple approach to generate a number that identifies the risk of dust generation and potential issues. The greater the number, the higher the likelihood of dust related issues. The formula involves combining a number of factors together in the following ways: 

DRI = Sum(E+S+M+WS+D+A)*R*WD



Where:



E = Surface exposure.



S = Stabilisation.



R = Rainfall.



M = Month of the Year.



WS = Wind Speed.



WD = Wind Direction



D = Distance to nearest receiver.



A = Construction Activity.

Surface Exposure This factor recognises that where material has been removed from the surface of the ground that dust is more likely to be generated than if the original surface is still in place. As such a value of 0 is used where the surface remains untouched and a value of 10 is used where the surface has been exposed and the vegetation removed, and a value of 50 is used when the exposed surface has been significantly disturbed.

Stabilisation This factor recognises that surfaces that have been exposed, in the manner referred to above and then subsequently stabilised are less likely to generate dust. Stabilisation measures associated with this project include: 

Water;



Chemical dust suppressant; and,



Aggregate covers such as Gap TNZ40, Gap 65, Drainage 200.

As such a value of 0 is used where the surface is fully stabilised in a manner described above, 5 when there is some degree of stabilisation and a value of 10 when no form of stabilisation has been used.

Rainfall This factor recognises that dust issues are neutralised by the presence of sufficient rainfall, or the receipt of sufficient rainfall within the previous 24-48 hours. As such a value of 0 has been assigned where it is currently raining and 1 where 5 mm or more of rainfall has been received in the previous 24 hours. A value of 1.5 has been assigned where 5 mm or more of rainfall has been received in the previous 48 hours. A value of 2 is assigned when it has not rained for more than 2 days.

Month of the Year This factor recognises that certain periods of the year are more likely to be periods of higher risk due to low soil moisture levels or higher wind speeds. As such the winter and spring months of June to September are assigned a value of 0; a value of 5 is used for April, May, October and November; and a value of 10 for the months of December to March.

Wind Speed Wind speed is recognised as a significant factor. Increases in dust issues coincide with an increase in wind speed. The following weightings have been applied to the wind speed groupings: 

0-9 km/h

0



10-18 km/h

10



19-27 km/h

50



28-36 km/h

200



Greater than 36 km/h

500

Wind Direction This factor recognises that the degree to which a stakeholder or sensitive receiver adjacent the Project is effected by dust is strongly influenced by the direction of the wind in relation to their position. Where the wind direction is such that the receiver is downwind of the works then a value of 1 has been assigned to the factor. However where the wind is blowing away from the sensitive receiver then the value assigned is 0. Given the narrow nature of the Project alignment it is accepted that a value of 0 is highly unlikely for most areas due to the close proximity of sensitive receptors.

Distance to the nearest Sensitive Receptor Closely related to the direction and speed of wind, as determining factors for dust issues, it is recognised that the distance to the nearest sensitive receiver also contributes to the risk involved. As such a value of 100 has been assigned to this factor.

Construction Activity The final factor recognises that certain construction activities are more or less likely to contribute to dust related issues. As such the following groups of construction activities have been assigned differing values. Where there are other activities occurring, choose the most similar activity or contact the Environment Manager for guidance.



No Activity

0



Piling Operations

1



Excavator cutting and shaping of natural ground

5



Tunnel Construction

5



Pavement Construction

5



Fill Placement

20

Overall DRI Value Once the DRI has been calculated for a particular location it needs to be assigned to a risk value using the following table. Conversion Values for DRI to Dust Risk DRI Value

Risk

0 to 250

Low

250 to 350

Moderate

350 to 500

High

Greater than 500

Extreme

Forecasting At the beginning of each week on a Monday morning a DRI forecast will be carried out in order to assist with planning of dust management mitigation measures for that week. The forecast will identify the likely DRI for each day Monday through Saturday, for each work area. The forecast will then be disseminated to the construction teams and staff responsible for dust mitigation such as supervisors and water cart drivers. The information will allow a more focussed and proactive approach to dust control and mitigation.

Daily DRI Calculation Review In addition to the forecast referred to above, a daily DRI calculation will be completed with a view to forecasting dust issues for the day by using more current information. The forecast will then be disseminated to the construction teams and staff responsible for dust mitigation such as supervisors and water cart drivers.

DRI Review Process At the conclusion of each month, as part of the monthly environmental reporting the Environment Manager will review the performance the Project in terms of dust management. As part of this review, the effectiveness of the DRI will be assessed and any amendments to the DRI advised and commented on.

Communication of the DRI One means of communicating the DRI to construction staff is via a warning board similar to that used to convey fire danger in rural areas. Therefore each work area will have a board in a prominent location such as beside the site office or canteen where the current DRI value is displayed.

Appendix C:



CLG and Independent Peer Review comments

Community Liaison Group Comments

Comments received from the CLG are as follows: Date

CLG Member

Comment

Response

15th December 2015

Ross Boswell

Will the roof over the Lower Queen Street excavation allow for the operation of vehicles with combustion engines?

The roof will be a partial roof over the excavation, with the sides open to enable truck and equipment to safely access the excavation. The purpose of the roof is to reduce the volume of water entering the excavation. No change required to DWP.

15th December 2015

Kathy Ross

Will dust result in health effects for surrounding residents?

Any dust generated from the excavations will not result in health effects as dust will be controlled and managed throughout the works. Construction dust typically falls to the ground and settles within 5-6m from the discharge point; as such it does not stay suspended in the air for long periods of time and will not therefore cause adverse health effects. No change to DWP required.

14th April 2016

Cooper and Company

Section 3.3 states that the key compliance measure used in construction processes is that dust and other air discharges do not result in “offsite” nuisance – where offsite means outside the CRL and BTC designations. This is pretty broad. It should be limited to where the construction works are occurring within the BTC designation or at the least restrict to the construction footprint not the entire designation. This is to ensure that effects on others within the Precinct are considered.

Text updated to refer to offsite being outside the area bound by Lower Queen Street, Commerce Street (north of Customs Street East), Galway and Tyler streets (west of Commerce Street) – the BTC designation area west of Commerce Street. Additional text has been provided in Section 5.1 outlining mechanisms on how communication of dust risk with residents and the public will be made available daily.

14th April 2016

Cooper and Company

Section 3.4 states that all receptors within 100m of the Project area are considered sensitive receptors for the purpose of this DWP. What is the project area? The BTC footprint?

Text updated to refer to sensitive receptors as being within 100m of the area bound by Lower Queen Street, Commerce Street (north of Customs Street East), Galway and Tyler streets (west of Commerce Street) – the BTC designation area west of Commerce Street.

14th April 2016

Cooper and Company

Section 4.3.2 refers to examples of TSP monitors that “could be employed”. Doesn’t state when or how it would be appropriate to employ them. Should it?

TSP monitoring is outlined in Section 4.3.1. The intent of this sentence, and associated bullet points, was to outline the type of TSP monitors that could be used to measure dust during the construction works. Wording updated in this regard. Details of how the TSP monitoring will be undertaken during the Project is outlined in Section 4.3.1 – no change in this regard.

14th April 2016

Cooper and Company

Section 4.4 - these are all geared around measuring dust effects on off-site neighbours – what about businesses within the designation footprint?

Wording updated to refer to sensitive receptors located in proximity to the Project as opposed to “off-site neighbours”. Additional information provided in Section 5.2 explaining how daily dust risks associated with the works will be communicated to the Project staff and members of the Public.

14th April 2016

Cooper and Company

Section 10 notes that any material changes to the DWP will require approval from Council. However it should also note that any material changes also need to be notified to the CLG under condition 8.7.

Section 10 updated with new subsections on the review and updating process, including CLG notification

20th May 2016

Cooper and Company

Section 2.3 there is a typo “wills” should be “will”.

Section 2.3 text updated to correct typo.



Independent Peer Review Comments

An Independent Peer Review of the draft Air Quality DWP was undertaken by Carol McSweeney from Air Matters Ltd, with peer review comments received on 17th February 2016. The comments received are as follows: Condition

Section of DWP (Rev 3)

Comment

Response

CRL Designation Conditions 59.1

This document

No comment

N/A

59.2

This document

No comment

N/A

59.3(a)

4.5, 4.6 4.3.2, 3.2

No comment

N/A

59.3(b)

3.4, 4

No comment

N/A

59.3(c)

5.3.5 Tables

No comment

N/A

Condition

Section of DWP (Rev 3)

Comment

Response

Nil Table 5.2 discusses wind speed and how that relates to water application for dust suppression. This is not consistent with the wind speed “trigger level” in Table 3.1. As the wind speed for water application in Table 5.2 is lower than the trigger level in Table 3.1, it is recommended that the lower level is used as the trigger.

Additional text included in new Section 4.3.4 to explain the different purposes associated with the two trigger values outlined in Table 3.1 and Table 5.2.

5.1, 5.2, 5.3 59.3(d)

4.3.2 5.2 (Table 5)

59.3(e)

Table 5.1

The procedure in Table 5.1 requires covering of all loads of fine materials. A definition for “fine material” would be useful for contractors.

A definition of the fine material has been added as a footnote to Table 5.1.

59.3(f)

Table 5.1

No comment

N/A

59.3(g)

5.4.2

Identification of the odour should be included as part of the response to discharges of odour in order to identify any hazardous component (HAPs) This can be linked into the contaminated land assessment.

It is not considered that identification of odour is specifically necessary as part of this DWP. Section 7.1 of the Contamination DWP sets out the requirements for instrumental monitoring when contaminated land is encountered.

59.3(h)

5.3.4

The AQ DWP suggests at Section 5.3.4 that the subcontractor is responsible for this. The designation conditions apply to the “Requiring Authority” who must take overall responsibility.

This is addressed in Table 9.1

59.3(i)

5

This is well outlined in Section 5.1 .5.4.1 for dust. The methodology for assessing dust risk and the associated mitigations is outlined in Appendix B. As the contingency measures are related to this appendix it would be useful to have definition of the risk level in Section 5.2 the same as in Appendix B. Section 5.3.1 low risk. Section 5.3.2 moderate risk and Section 5.3.3 higher or extreme risk.

Changes made to text in Section 5 to accommodate suggestion.

59.3(j)

6

No comment

N/A

59.3(k)

6

This reference sits in Section 6, Complaints. It is noted that Condition 59.3(k) refers to the consultation with the communities around the “management of adverse effects” and is not limited to communicating the “management of complaints”.

Changes made to this section of the DWP. Specifically:  New Section 6.1 refers to the Project Communication and Consultation Plan in relation to communication with communities in the vicinity of construction works.

Condition

Section of DWP (Rev 3)

Comment

Response

 New Section 6.2 relates to the complaints process.



Another Independent Peer Review of the draft Air Quality DWP was undertaken by Carol McSweeney to review amendments made to the draft Air Quality DWP as a result of Auckland Transports decision on the BTC designation conditions. Second round of peer review comments were received on 23rd May 2016. The comments received are as follows: Condition

Section of DWP (rev 6)

Comment

Response

N/A

Appendix C

Appendix C of Version 6 of the AQ-DWP, itemises the Community Liaison Group comments as well as those of the independent peer reviewer. The Auckland Transport response to those comments is also summarised and referenced where the AQ-DWP has been amended. The independent peer review suggestions made during the

No amendments to the DWP required.

review of Revision 3 have largely been included into Revision 6 of the AQ-DWP and I am satisfied that the air quality consent conditions for both the CRL and BTC designations are now well covered. N/A

Appendix C

I feel that the issues raised by the Community Liaison Group have also largely been dealt with. However the question from Kathy Ross (15/12/2015) has still not been fully dealt with. The question raised was “will dust result in health effects for surrounding residents?” It is true to say that the levels of dust will not cause health effects and this is because dust will be controlled and managed throughout the works. It is misleading to say “the project will involve the excavation of inert soil materials. ANY dust generated from the excavations will NOT result in health effects”. This suggests that dust from soil will never produce health effects and is misleading.

Response to Kathy Ross comment has been updated.

59.3(k), 59.3 (j), 33A.3(j)

Section 6 and Appendix C

I note that there have been improvements in the DWP in relation to communication with residents, especially in relation to dust risk with the Dust Risk Index summary being available to residents daily. The comments made here do not require a change in the DWP, but a more accurate representation in the response to the submitter would be helpful.

Response to CLG members has been updated.

33A.3(k) 71