City Rail Link In association with:
Albert Street Canopy Removal and Utilities Relocation AIR QUALITY DELIVERY WORK PLAN
Document ref:CRL-PAT-RME-000-RPT-0099 Revision: 0 October 2017
INTERNAL WORKING DOCUMENT COMMERCIAL IN CONFIDENCE
AUCKLAND CITY RAIL LINK Albert Street Canopy Removals and Utilities Relocation Air Quality Delivery Work Plan 1378206325-107-R-Rev0
ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
List of Abbreviations Acronym
Meaning
AC
Auckland Council
ACZ
Active Construction Zone
ADWP
Air Quality Delivery Work Plan
AT
Auckland Transport
AUP
Auckland Unitary Plan (Operative in Part)
CBLG
Community Business Liaison Group
CDWP
Contamination Delivery Work Plan
CEMP
Construction Environmental Management Plan
CRL
City Rail Link
CSA
Construction Support Area
ESM
Environment and Sustainability Manager
MfE
Ministry for the Environment
NAL
North Auckland Line
RMA
Resource Management Act 1991
List of Units Unit
Meaning
°C
Degrees Celsius
km
Kilometre
km/hr
Kilometres per hour
m
Metre
m/s
Metres per second
m²
Square metre
m³
Cubic metre
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ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
Record of Issue Company
Version
Date issued
Review detail/status
Aurecon
Revision A
17 August 2017
Draft for Aurecon review
Aurecon
Revision B
1 September 2017
Revised draft
Aurecon
Revision C
21 September 2017
Revised draft post CBLG review
Aurecon
Revision D
9 October 2017
Draft for consent post independent peer review
Aurecon
Revision 0
20 October 2017
Final for consent
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ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
Table of Contents 1.0
2.0
3.0
4.0
INTRODUCTION ........................................................................................................................................................ 1 1.1
Overview ....................................................................................................................................................... 1
1.2
Report Structure ........................................................................................................................................... 2
1.3
Environmental Objective ............................................................................................................................... 6
PROJECT DESCRIPTION ......................................................................................................................................... 6 2.1
Overview ....................................................................................................................................................... 6
2.2
Overview ....................................................................................................................................................... 6
2.3
Construction Sequence ................................................................................................................................ 7
2.4
Methodology – Canopy Removal/Dismantling .............................................................................................. 7
2.5
Methodology – Utility Services Relocation .................................................................................................... 8
2.6
Sensitive Locations ....................................................................................................................................... 9
DUST EMISSIONS SOURCES AND MITIGATION ................................................................................................... 9 3.1
Introduction ................................................................................................................................................... 9
3.2
Overview of Sources ................................................................................................................................... 10
3.3
Risk Assessment, Controls and Procedures ............................................................................................... 10
DUST MONITORING PROGRAMME ...................................................................................................................... 12 4.1
General Site Monitoring .............................................................................................................................. 12
4.2
Visual Inspections of Dust Emissions ......................................................................................................... 13
4.3
Continuous Monitoring of Total Suspended Particulate .............................................................................. 14
5.0
OTHER MINOR DISCHARGES TO AIR .................................................................................................................. 14
6.0
COMPLAINTS RESPONSE AND RECORDING ..................................................................................................... 14
7.0
ENVIRONMENTAL TRAINING ................................................................................................................................ 14 7.1
8.0
9.0
Project Staff ................................................................................................................................................ 14
RECORD KEEPING................................................................................................................................................. 15 8.1
Overview ..................................................................................................................................................... 15
8.2
Daily Log ..................................................................................................................................................... 16
ROLES AND RESPONSIBILITIES .......................................................................................................................... 16 9.1
Distribution .................................................................................................................................................. 16
9.2
Overview of Responsibility for this AQDWP ............................................................................................... 16
9.3
Specific Roles and Responsibilities ............................................................................................................ 17
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9.4
Contact Details ........................................................................................................................................... 18
10.0 AQDWP AUDITING AND REVIEW ......................................................................................................................... 18 10.1
Introduction ................................................................................................................................................. 18
10.2
Auditing ....................................................................................................................................................... 18
10.3
Review ........................................................................................................................................................ 18
11.0 LIMITATIONS .......................................................................................................................................................... 18 12.0 REFERENCES ......................................................................................................................................................... 19
TABLES Table 1: CRL designation and resource consent conditions for AQDWP. ........................................................................... 2 Table 2: Canopy removal methodology. .............................................................................................................................. 7 Table 3: Construction methodology and timing. .................................................................................................................. 8 Table 4: Risk assessment and controls/procedures for dust sources within the Project. .................................................. 11 Table 5: Training requirements. ........................................................................................................................................ 15 Table 6: Record keeping requirements. ............................................................................................................................ 15 Table 7: Environmental management responsibilities. ...................................................................................................... 17
FIGURES Figure 1: Location of the canopy removals and utilities relocation works. ........................................................................... 6
APPENDICES APPENDIX A Daily Log Form APPENDIX B Community Business Liaison Group and Peer Review Outcomes APPENDIX C Report Limitations
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1.0 1.1
INTRODUCTION Overview
This Air Quality Delivery Work Plan1 (AQDWP) has been developed by Golder Associates (NZ) Limited (Golder) to manage air quality during construction activities associated with the Albert Street Canopy Removals and Utilities Relocation (the Project), which is an element of the City Rail Link (CRL) project. The City Rail Link Limited (CRLL) is undertaking early works in advance of the main construction of Aotea Station (part of Construction Contract 3). The early works will be undertaken under Contracts 2.1 and 2.2 and involve the removal of canopies and the relocation of underground utilities along the western side of Albert Street from Wellesley Street to Victoria Street West. The canopies will be reinstated following completion of the Aotea Station construction, under Contract 3. As the early works lie within the project footprint, it is considered they are authorised by the CRL 1714 (Designation 12) and the Aotea Station to North Auckland Line (A2N) resource consents 3. This AQDWP manages the air quality for the Project. Condition 59 of the CRL Designation 1714 requires that an AQDWP be prepared to manage the adverse effects relating to air discharges during the construction of CRL, to avoid, remedy or mitigate the adverse effects of construction on air quality. Condition 222 of the A2N resource consents also requires the preparation and submission of an Air Quality Management Plan. This AQWP has been prepared to satisfy both condition requirements and takes a holistic approach in managing the effects relating to air discharge for the Project. This AQWP represents a combined Air Quality Management Plan and CDWP. The purpose of this AQDWP is to provide a framework for managing the air discharges, especially dust emissions, so that potential significant adverse environmental and human health effects beyond the construction site are avoided. This is to be primarily achieved by:
Identifying the sources of fugitive dust emissions associated with the construction activities. Describing controls and procedures to prevent fugitive dust emissions from each significant source. Describing inspection and monitoring programs. Describing the training of personnel necessary for the AQDWP to be implemented. Describing the necessary record-keeping to verify and document ongoing compliance with the AQDWP. Establishing the roles and responsibilities of staff throughout the organisation in relation to the AQDWP.
Dust emissions are considered to be the primary contaminant of concern discharged to air from the proposed works. Combustion emissions from the operation of vehicles, and any residual emissions from emission control equipment associated with the works are expected to give rise to air quality effects that are negligible. Regarding odour, it is expected that there is very limited potential for odour to be generated by the Project. As such, this AQDWP focuses on the management of dust emissions from the works as the effects of other emission sources are considered insignificant. This AQDWP fulfils the technical reporting requirements for management and mitigation of air quality effects under the Auckland Unitary Plan: Operative in Part (15 November 2016) (AUP). It has been prepared in accordance (where relevant and practicable) with the Ministry for the Environment (MfE 2016) good practice guide for assessing and managing dust.
1
The Air Quality Delivery Work Plan is analogous to an Air Quality Management Plan. The use of AQDWP has been adopted for consistency with CRL Designation Condition 59.
2
CRL Designation 1714 is comprised of six individual Notices of Requirement (NoR), referred to individually as Designations 1-6.
3
R/LUC/2016/1890, R/REG/2016/1892, R/REG/2016/1895, R/REG/2016/1896, REG/2016/1897, R/REG/2016/1898, R/REG/2016/1899, R/REG/2016/1900 and R/REG/2016/2038.
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1.2
Report Structure
The structure of the AQDWP is designed to provide a logical and practical framework for the management of air emissions from the Project construction site. The AQDWP has the following key sections:
Section 2.0 provides a description of the project and site construction activities.
Section 4.0 outlines a proposed dust monitoring programme.
Section 3.0 identifies the potential dust emissions sources and the structural and operational controls that are proposed to mitigate the risks associated with each source.
Section 5.0 discusses other minor discharges to air. Section 6.0 discusses complaints response and record keeping. Section 7.0 provides a program for training and awareness of staff. Section 8.0 outlines the records that are required to be kept as part of compliance with this AQDWP. Section 9.0 establishes the roles and responsibilities of staff. Section 10.0 outlines the procedures for auditing and reviewing this AQDWP.
The AQDWP has been prepared to satisfy CRL Designation 1714 condition 59 and also the requirements of the A2N resource consents. For reference, the relevant sections of this AQDWP as they relate to the designation and resource consent conditions are summarised in Table 1.
Table 1: CRL designation and resource consent conditions for AQDWP. Relevant section of AQDWP
Relevant condition CRL Designation 1714 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.
Whole AQDWP
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.
Whole AQDWP
59.3 To achieve the above objective the following shall be included in the Air Quality DWP and implemented as required: a)
b)
c)
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);
Section 4.3 of the AQDWP
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;
Section 2.2 and 4.0 of the AQDWP
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;
Sections 5.0 and 8.0 of the AQDWP
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Relevant section of AQDWP
Relevant condition d)
Procedures for monitoring weather conditions and the requirement that water spray is used on soil stockpiles, any non-paved construction areas, and the wheels of trucks where dust may disperse beyond the site;
Section 4.0 of the AQDWP
e)
Procedures for establishing when the covering of trucks will be required;
Table 4, Section 3.3 of the AQDWP
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;
Table 4, Section 3.3 of the AQDWP
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;
Section 5.0 of the AQDWP
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;
Section 5.0 of the AQDWP
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
Section 3.0 and 4.0 of the AQDWP
j)
Procedures for responding to any complaints received and the timeframes for response to complaints and reporting.
Section 6.0 of the AQDWP
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.
Section 6.0 of the AQDWP
g)
h)
i)
Discharge permit (air – construction) R/REG/2016/1899 218. The Consent Holder shall ensure that all processes on the Project work site shall be implemented, operated, maintained, supervised, monitored and controlled so that any emissions authorised by this consent are maintained at the minimum practicable level.
Whole AQDWP
219. Unless provided for by Condition 220, there shall be no dust or odour beyond the boundary of the Project work site caused as a result of onsite processes which, in the opinion of Council, is noxious, offensive or objectionable.
Whole AQDWP
220. Any noxious, offensive or objectionable dust or odour beyond the boundary of the Project work site 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 222.
Whole AQDWP
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Relevant condition
Relevant section of AQDWP
221. 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.
Table 4, Section 3.3 of the AQDWP
222. The Consent Holder shall review the draft Air Quality Management Plan – Aotea Station to North Auckland Line dated May 2016, and submit to Council (Team Leader Central Monitoring) a final AQMP/s which is generally consistent with the draft AQMP provided in support of the application. 223. 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. 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 ACZ and the associated CSA.
Whole AQDWP (Note: given the small footprint of the Project, it is not divided into ACZs and CSAs as other works associated with the CRL project.)
Air Quality Management Plan (AQMP) 224. The final AQMP/s shall also provide detailed methods including, but not limited to, the following matters: a. methods to ensure exposed surfaces remain dampened to minimise dust emissions (possible examples include a water spray system or other suitable system, water carts and other suppression methods); b. ensuring a 20 km/hr vehicle speed limit within the ACZs and CSAs;
c. operation of wheel washes;
Table 4, Section 3.3 of the AQDWP Not applicable. (Note: Given the small size of the trench associated with the Project, there will be no vehicles traveling within the Project area or over exposed surfaces.)
d. regular sweeping of public roads around the exit points of ACZs and CSAs and sealed vehicle accessways within these areas;
Not applicable given absence of vehicle accessways. Sweeping of any material spilled onto the road beside the trench is discussed in Table 4, Section 3.3 of the AQDWP.
e. measures for supressing dust from any temporary stock piles (demonstrating how they are to be limited to no more than 24 mÂł of uncovered spoil at any one time in each ACZ);
Not applicable.
f. measures for the handling of cement associated with the forming of cement stabilised columns, including filter systems and high level alarms where a silo is used;
Not applicable.
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Relevant section of AQDWP
Relevant condition g. covering of loads of material being delivered and removed from the site;
Table 4, Section 3.3 of the AQDWP
h. instrument monitoring of dust concentrations (including identification of a monitoring methodology, monitoring network and appropriate alert thresholds) to ensure that any significant dust effects arising from the ACZs or CSAs are identified and remedied as soon as practicable throughout the Project;
Section 4.3 of the AQDWP
i. the locations of instrument dust monitoring sites, including at least three
Section 4.3 of the AQDWP
j. re-locatable and/or fixed monitors to be associated with each of ACZs A, K and M, and the duration of this monitoring;
Section 4.3 of the AQDWP
k. measures for responding to continuous instrument dust monitoring trigger alarms, including contingency measures to reduce measured concentrations below the trigger thresholds and provisions for responding after standard operating hours;
Section 4.3 of the AQDWP
l. 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
Sections 4.1 and 4.2 of the AQDWP
m. information regarding complaint logging, investigation and response procedures, training and roles and responsibilities.
Section 6.0 of the AQDWP
The Team Leader Central Monitoring shall be requested to respond to the AQMP/s with any suggested changes within 10 working days from receipt of the AQMP; otherwise the AQMP may be considered by the Consent Holder to be certified by the Council. 225. Any change to the AQMP/ 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 Team Leader Central Monitoring shall be requested to respond to the proposed change within 10 working days from receipt of the change; otherwise the AQMP may be considered by the Consent Holder to be certified by the Council. 226. All works shall be undertaken in accordance with the certified AQMP/s.
Implementation of this AQDWP
Monitoring Requirements 227. Prior to the commencement of construction, 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 continuous dust monitoring undertaken using mobile instruments for the purposes of monitoring Total Suspended Particulates (TSP). The locations, durations and methods of TSP monitoring at each of ACZs A, K and M shall be in accordance with the details in the certified AQMP(s) required by Condition 222.
Section 4.3 of the AQDWP
228. The dust monitoring instruments shall be fitted with an alarm system that sends a warning to the responsible person identified by the
Section 4.3 of the AQDWP
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Relevant section of AQDWP
Relevant condition AQMP/s when dust concentrations exceed alert levels specified by the certified 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.
1.3
Environmental Objective
The primary environmental objective is to detail the best practicable option to avoid dust and odour nuisance being caused by the Project construction works and to remedy any such effects should they occur. This objective will be achieved by ensuring that all site activities are contained within appropriate areas and site activities will not result in any discharges to air resulting in unacceptable levels of contaminants within the surrounding environment.
2.0 2.1 2.2
PROJECT DESCRIPTION Overview Overview
The underground Aotea Station occupies the full width of Albert Street, with only a 2.5 m gap in places between the piled station wall and the existing buildings. Consequently, construction of the piled wall requires the temporary removal of the existing canopies from the AA (99 Albert Street), and Sky City (109125 Albert Street) buildings as well as the cutback of the existing canopies from the Manhattan Apartment (103-107 Albert Street) and Auckland Council (135 Albert Street) buildings. The network of buried pipes and cables under Albert Street will need to be permanently diverted to enable construction of the station. The existing services will be relocated into a shared services trench approximately 4.0 m in depth by 1.5 m in width, located in the space between the new station wall and the existing buildings. Figure 1 shows the general site location, layout, temporary pedestrian pathways, vehicle entrances and hoardings. Based on the approximate distance from the corners of Albert Street with Wellesley Street and Victoria Street West, it is estimated the trench will be about 220 m long and the excavated volume about 1,320 m 3.
Figure 1: Location of the canopy removals and utilities relocation works. October 2017 Report No. 1378206325-107-R-Rev0
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ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
2.3
Construction Sequence
The construction methodology focusses on minimising disruption to vehicle and pedestrian access, minimising disruption and outages to services, and providing advanced notice of works through public information and consultation with directly affected and in proximity parties. The construction work will require the closure of two lanes of traffic on the west side of Albert Street, from Wellesley Street to Victoria Street, for the 15 months duration of the works. Re-routing of buses and relocation of the bus stops away from this section is scheduled to take effect from 8th January 2018. The bus stops will not be reinstated after the main CRL project is completed. Above ground works commence with removal of the canopy at the AA building, cut back of the canopy at the Manhattan Apartments building, removal of the canopy and the glazed spa entrance at Sky City and cut-back of the canopy at the Auckland Council building. Once canopies have been removed or sufficiently cut-back, below ground works commence with excavation of the shared utility services trench between the AA building on the corner of Albert Street and Victoria Street and the Auckland Council Building on the corner of Albert Street and Wellesley Street. New pipes for the stormwater, wastewater and water supply services, and new ducts for the power and telecommunication cables, will then be installed in the trench. Following re-connection and testing of all relocated services, the footpath will be reinstated, all temporary hoardings and traffic management removed, and the site left clean and tidy in its normal condition (minus the building canopies).
Methodology – Canopy Removal/Dismantling
2.4
The canopy removal works, specifically the extent of dismantling / removal, is different for each building, however there are common methodologies that will apply to each stage, and similar tools and techniques will be used throughout, as detailed in the schedule below. The equipment listed in Table 2 below will be supplemented by normal hand tools, ladders and hand-held power tools. Table 2: Canopy removal methodology. Activity
Equipment & materials
Approx. duration
Set up and prepare site, install temporary traffic management (TTM), and erosion and sediment control (ESC) provisions and install pedestrian pathways; For AA and Manhattan – via existing undercroft For Sky City and Auckland Council – Container walkways Provide pedestrian access to affected building entrances. Provide vehicle access to Manhattan and Sky City car parks.
Trucks, signage, cones, mobile crane, excavator, containers, barriers, hoardings
2 weeks
Scaffold, gas welder / cutting torch, cherry picker, mobile crane, trucks. No hammer drills or percussion tools to be used, to minimize noise and vibration.
Up to 8 weeks, for each building
Terminate all power supplies to and relocate any and all plant, equipment and signage currently located on those parts of the canopy to be removed. Erect scaffold, dismantle and remove building canopy, including:
Remove glazing/panel/roof sections. Remove roof/secondary supports between main support beams. Remove primary support beams.
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Equipment & materials
Activity
Approx. duration
Install weatherproof flashing to building façade and make good.
Scaffold, trucks, cherry picker, mobile crane, hand tools
2 weeks, for each building
Total
Approximately
20 weeks
2.5
Methodology – Utility Services Relocation
Following canopy removal, below ground works will commence on the shared utility services trench. The trench will be excavated in two stages; first stage to 1.5m depth, around existing ducts and cables; second stage to approximately 4m depth, for installation of new stormwater and wastewater mains. Hydrovac excavation will be used where ever possible, to minimise noise and vibration, and to protect existing buried services. Temporary pedestrian and vehicle bridges will be provided where the trench runs across building entrances. The trench will also be backfilled in two discrete stages; first stage to backfill over the new pipes to approximately 1.5m below ground level; second stage to backfill around the new ducts and cables to the surface. After the first stage of backfilling, the new stormwater and wastewater mains will be tested, then individual property connections (branches) installed, allowing installation of the water supply main. The water main will be tested and then connected to the individual properties. Cable ducts for power and telecommunications cables are then laid in the trench, and the trench backfilled to the surface. Cable joint pits are then excavated, cables pulled through the ducts, and cable cutovers and connected to individual properties. This section of the work includes power and communications outages, which will be planned and coordinated with building occupants, to minimise disruption. Abandoned or redundant services will then be removed from the station wall piling line, all excavations backfilled and the footpath pavement reinstated. The equipment listed in Table 3 below will be supplemented by hand tools, ladders and hand-held power tools. Table 3: Construction methodology and timing. Activity
Equipment & materials
Approx. duration
Mark out proposed footprint of trench section (up to 50m length). Identify and locate existing services on surface.
Trucks, hand held service locator.
2 weeks
Concrete saw, handheld concrete breaker – only where necessary, excavator, trucks
2 - 3 weeks for the overall length of the trench; 2 – 3 days in front of each building
HydroVac excavator, trucks
6 weeks
Saw cut and remove existing pavement (pavement is primarily asphalt surfacing, with isolated granite tile inserts). This would be done in brief periods progressively along the trench. Expose and support existing services to 1.5 m depth – maintain all vehicle and pedestrian access with temporary crossings. This would be done in brief periods progressively along the trench.
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Activity
Equipment & materials
Approx. duration
Excavate trench to maximum 4 m depth, using mini excavator, carefully working around struts and services. Provide temporary strutting & shoring to trench sides, with timbers or trench shield, as appropriate.
Generally using HydroVac excavator, mini excavator if necessary. Truck mounted crane, trench shields
3 weeks
Lay pipe bedding and install new wastewater and stormwater pipes, connect to downstream discharge points.
Excavator, plate compactor, truck mounted or mobile crane.
4-6 weeks
Trucks, excavator, plate compactor (no vibrating rollers)
4-6 weeks
Draw cables through new ducts (where required) and cutover live mains. Place and compact remaining sections of trench backfill.
Truck mounted crane, excavator.
10 weeks
Total
Approximately
40 weeks
Backfill approximately half trench depth, Lay new power and comms ducts, place and compact trench backfill where possible. Excavation for draw pits and joint bays and connection points to be left open.
2.6
Sensitive Locations
Off-site locations within approximately 100 m from the Project are considered sensitive to potential dust and odour impacts given the nature of the receiving environment. Examples of activities surrounding the Project are as follows: Albert Street (overall assessment is high sensitivity):
Pedestrian access to offices and other places of work.
Shopping/Commercial/Business activities, including Auckland Council and AA buildings.
Bar patronage.
Residential apartments, including the Manhattan Apartments.
Hotels, including: Crowne Plaza, Econo Lodge and Sky City Grand Hotel.
3.0 3.1
DUST EMISSIONS SOURCES AND MITIGATION Introduction
This section provides a description of the dust emission sources and mitigation measures for the proposed construction activities. This is followed by a qualitative risk assessment for each key activity to identify the priority activities on the site that represent the highest risks in terms of creating an adverse dust effect beyond the boundary of the site. Finally, the emissions controls and procedures for each activity are described, as well as the person responsible for their implementation and management of dust control.
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Each of the potential risks is assessed in terms of the probability that they might occur (low, medium or high) and of the level of the consequence in case they do occur (low, medium or high). For instance, a potential risk with a low probability means that it is likely to occur only one to five times during the whole period of construction activities. A potential risk with a high probability means that it is likely to occur at least once per week during the period of construction activities. The consequence is independent of the probability and is related to effects on the environment (beyond the boundary of the Project) of that risk when it does occur. A low level consequence means that any effects to the environment should be less than minor and no sensitive receptors would be affected. A high level consequence, on the other hand, means effects on the environment may be significant and that sensitive receptors are likely to be affected. The risk level is assessed as low, medium or high based on the combination of the assessments of probability and consequence. The resulting risk level indicates the priority of that activity in terms of control measures and procedures for minimising dust emissions. The risk assessment has been undertaken on the basis of the construction activities as described in Section 2.0, which are based on information provided by Aurecon New Zealand Limited. Due to the relatively short duration of the Project, an annual review of the risk assessment is not considered necessary in this instance.
3.2
Overview of Sources
The main discharge into air arising from the proposed construction activities is particulate matter (dust). The following key activities have been identified in the Air Quality Assessment (Golder 2017a) as the potential sources of dust emissions from the proposed construction activities:
Trench excavation and spoil removal. Backfilling of the trench.
Section 4.0 describes how the above key activities relate to the Project, as well as their risks in terms of the potential to result in adverse effects on sensitive activities. Section 4.0 also details the associated mitigation measures that are to be used to control or suppress dust emissions from each activity.
3.3
Risk Assessment, Controls and Procedures
The risk assessment and the controls/procedures for mitigating dust emissions from the key activities within the Project are provided in Table 4. The probability that a risk of unmitigated dust emission occurring is denoted as ‘P’, the level of the consequence in case the risk does occur is denoted as ‘C’ and the overall risk assessment as ‘R’. The control/procedure for each activity is intended to ensure that dust emissions are effectively controlled such that off-site effects are of an acceptable level. In addition to the dust control/procedure noted below, consideration of dust management will form part of the daily prestart or weekly toolbox meeting required by the overarching Construction Environmental Management Plan (CEMP). The daily meeting is to include consideration of the weather forecast for that day and, where necessary, subsequent communication with immediate and potentially affected neighbours. Where it is verified that dust emissions from the Project have caused a significant impact on a neighbouring property, contingency response measures are to be determined and instigated, which may include the cleaning of air filtration intakes, or cleaning of buildings and infrastructure as necessary.
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Table 4: Risk assessment and controls/procedures for dust sources within the Project. Activity/ Potential P* C* R* Control/Procedure Facility unmitigated risk Prior to the canopies removals or cut-backs, an asbestos survey is to be carried out for each of the canopies by an ‘appropriately experienced, qualified and certified contractor’. If asbestos is present, the canopy removal or cut-backs Asbestos L H M shall be in accordance with recommendations from the contractor. However, it is expected that asbestos is unlikely to be present given the types and structures of those canopies. Canopies removals Dust from the removal of canopies is to be controlled by wetting any potentially dusty materials as they are broken up. Dust from the knocking down and breakup of any Dust from blockwork and concrete associated removal of with some of the canopies will be L L L canopies controlled using water sprays directed onto the activity during dry weather. In particular, water for dust suppression will be used during any use of concrete saws and breakers. Any concrete cutting associated with removal of the pavement surface and the use of a concrete breaker will be undertaken with a Dust emissions water supply to suppress dust. due to wind Excavation erosion of the The exposed surfaces of the trench and spoil trench’s exposed L L L will be kept damp if necessary by removal surfaces during spraying with water until such time dry weather and that the trench is sufficiently deep strong winds. to be protected from the wind. Additionally, the in-situ material to be excavated is likely to be relatively damp.
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Person responsible
Environment and Sustainability Manager (ESM) or delegated person
ESM or delegated person
ESM or delegated person
ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
Activity/ Facility
Potential unmitigated risk
Removal of spoil and delivery of fill material
Dust emissions from uncovered loads on trucks or from material spilled onto the road becoming entrained.
L
M
L-M
Backfilling of the trench
Dust emissions from the material being backfilled into the trench.
M
L
L-M
Hazardous air pollutants or odour associated Contaminated with planned or soils unexpected discovery of contaminated soils.
P*
L
C*
M
R*
Control/Procedure All trucks removing spoil and delivering fill to have loads covered to ensure no material is spilled onto the adjoining road. Notwithstanding this, visual inspections will be carried out (see Section 4.2) and any spilled material will be swept and removed. If needed, water will be used for dampening exposed surfaces and/or the filling material during the backfilling operation. However, the surface area of the trench and the amount of fill material is relatively small. This means there is limited potential for wind erosion of exposed surfaces Construction may occur within fill of unknown origin, where contaminated soils may be encountered. See the Contamination Delivery Work Plan (CDWP – Golder 2017b).
L-M
Person responsible
ESM or delegated person
ESM or delegated person
ESM or delegated person
Notes: P = Probability, C = Consequence, R = Risk assessment (Priority), L = Low, M = Medium, H = High. ESM = Environment and Sustainability Manager.
4.0 4.1
DUST MONITORING PROGRAMME General Site Monitoring
The following general site monitoring will be undertaken:
Daily – The project Environment and Sustainability Manager (ESM) or delegated person will conduct daily inspections of the Project area (including all subcontractor activities), and any issues identified will be recorded and where necessary appropriate response measures actioned. The daily monitoring will include wind conditions and visual inspections in order to check compliance with this AQDWP, and observations shall be recorded in a Daily Log (see Section 4.2 for further details).
Weekly – Formal site inspections are to be completed by the ESM. A specific checklist will be developed for the Project to check compliance with this AQDWP.
Monthly – A representative from CRLL, and relevant Site Manager will undertake a monthly site visit with the project ESM, to confirm the work procedures containing environmental controls are being implemented in accordance with this AQDWP. A review of the current risk assessment table (Table 4) will be carried out by project ESM, updating it as required.
At the end of each month, the project ESM will submit a site inspection and environmental performance report to CRLL. The report will include but not be limited to a summary of environmental issues that occurred and actions taken during the month to ensure compliance with this AQDWP. The report will include:
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i)
Completed checklists for the Project.
ii)
Any details of any action item requests.
iii)
Complaints received.
iv)
Incidents that occurred.
v)
Investigations and corrective actions associated with complaint or incident investigations.
vi)
Staff environmental inductions and awareness training.
4.2
Visual Inspections of Dust Emissions
This AQDWP outlines a number of controls and procedures that are to be carried out in order to ensure potential dust emissions are minimised from the Project’s sources. Visual inspections of the perimeter of the Project will be performed on daily basis during the construction activities and recorded. The visual inspections will help to further ensure dust control measures are being effective. Records from daily visual inspections recorded in the Daily Logs can also be a useful tool for investigating and responding to complaints. The specific procedures for carrying out visual inspections are outlined below:
Visual inspections will be performed each day of operation by the ESM or delegated person around the whole perimeter of the Project. Sections of the adjoining roads (i.e., parts of Albert Street, Wellesley Street and Victoria Street West surrounding the Project) will also be inspected in order to verify that significant levels of mud and dusty material is not being carried by trucks and machinery onto public roads, and remedial action taken where necessary.
If visible dust emissions are identified beyond the Project site boundary, the following details must be recorded in the Daily Log form:
the source of the visible dust emissions; the level (extent) of the visible dust emissions: 1) minor visible emissions (< 5 m from source), 2) moderate visible emissions (5 to < 30 m from source), 3) major visible emissions (> 30 m from source),
a brief description of the colour and opacity of the visible dust emissions (e.g., dim brown, hazy grey, dense black, etc.); and
the time and general weather conditions (i.e., windy, calm, warm, etc.) at the moment the visible dust emissions were identified.
The control and mitigation measures listed in Table 4, where relevant, apply at all times and are to be carried out as necessary to prevent or remedy any visible dust emissions beyond the site boundary, regardless of the assessed level. However, if the assessed level of visible dust emissions is moderate or major, the duty or site manager for the Project must be notified for further action, including ceasing on-site dust generating activities.
When notified for further action, the duty or site manager will investigate the situation and take necessary measures to ensure dust levels do not give rise to offensive or objectionable dust impacts. Such actions will also be recorded in the Daily Log.
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4.3
Continuous Monitoring of Total Suspended Particulate
The small extent of the earthworks areas and low potential for dust emissions means that continuous monitoring of total suspended particulate is not considered to be necessary for managing dust effects associated with these works. Instead, monitoring of dust emissions from activities via regular visual inspections (as outlined in Section 4.2) will be carried out to ensure the emissions of dust are minimised from the Project. It is considered that Condition 59.3 of the designation, as well as conditions 224 (h to k), 227 and 228 of the discharge permit (air – construction) R/REG/2016/1899, which require continuous monitoring of total suspended particulate, only applies to large scale earthworks associated with the actual construction of the CRL (which has far greater potential dust effects), not small scale enabling works such as those proposed for the Project. Accordingly, the monitoring proposed in the AQDWP is considered to be commensurate with the scale of the works and fulfils the intent of the conditions mentioned above.
5.0
OTHER MINOR DISCHARGES TO AIR
Combustion emissions from the operation of vehicles, and any residual emissions from emission control equipment associated with the Project are expected to give rise to air quality effects that are negligible. However, all machinery and control equipment will be subjected to prestart checks before arrival to site. They will also be serviced in accordance with the supplier’s recommendations if any excessive or prolonged visible emissions are observed. Any malfunctioning machinery is to be repaired or removed from site within 24 hours. Equipment emissions will be checked for particulate as part of the visual inspections and recorded in the Daily Log Form. The Project is not expected to give rise to any offensive or objectionable odour effects as there are no known sources of odour associated with the Project. Accordingly, odour effects are expected to be less than minor. If the Project results in unforeseen odour emissions or it becomes apparent that odour emissions may occur from an activity, then operations associated with that activity will cease and measures to address the discharge promptly investigated and implemented (including procedures for responding to discharges of odour and equipment inspection).
6.0
COMPLAINTS RESPONSE AND RECORDING
Although measures of this AQDWP are aimed at avoiding complaints regarding dust occurring (complaints regarding odour are not anticipated), in practice complaints may be made on occasions by members of the public. It is important to ensure that any complaints that are received are recorded, promptly investigated to identify and resolve the cause of the complaint and appropriately responded to. The requirements and procedures on how to accomplish this are detailed in the CEMP and the Project Communication and Consultation Plan (CCP).
7.0 7.1
ENVIRONMENTAL TRAINING Project Staff
To achieve an effective AQDWP and to ensure off site air quality impacts comply with the A2N resource consents and the CRL designation condition requirements, all Project staff (contractors and subcontractors) will undergo general air quality awareness training and training about their responsibilities under the AQDWP. As part of the site staff induction, matters relating to dust management will be provided to all staff and subcontractors prior to starting work on site. Information will be provided on any procedural and/or structural October 2017 Report No. 1378206325-107-R-Rev0
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controls employed on the Project area to mitigate risk to air quality. Site engineers responsible for writing work plans and undertaking site specific safety and environmental risk assessments will also be given guidance on how to assess and plan for the environmental issues considered within the AQDWP. Air quality and other environmental issues will form a regular part of toolbox meetings (to be attended by contractor staff and subcontractors) to ensure all workers are aware of the key issues. The training requirements outlined in Table 5 are aimed to ensure all staff will receive appropriate training to fully understand the risks of activities on the sites to the environment, particularly with regard to off-site dust impacts, and the requirements of this AQDWP. Regular review of training requirements will be undertaken to ensure all staff are appropriately trained.
Table 5: Training requirements. Training requirements
Frequency
Attendance
Internal training on general site environmental awareness and on their responsibilities relating to the activities under this AQDWP
As required during new staff induction
All new staff members
Responding to complaints regarding dust and air quality concerns
As required during new staff induction
Site manager, delegated staff member and duty managers
8.0 8.1
RECORD KEEPING Overview
The record keeping requirements of the AQDWP are outlined in Table 6. Details on the Daily Log are provided below.
Table 6: Record keeping requirements. Records
Responsibility
Location
Daily log and weekly/monthly environmental site inspections
ESM
Site office (if available) or ESM office
Complaint records
ESM and onsite personnel involved in the complaint response
Site office (if available) or ESM office
Environmental incident reports
ESM and onsite personnel involved in the environmental incident
Site office (if available) or ESM office
Environmental emergency reports
ESM and onsite personnel involved in the environmental emergency
ESM office
Annual environmental audit
ESM
ESM office
Training records
ESM
ESM office
Revisions to the AQDWP and relevant sub-plans
ESM
ESM office
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8.2
Daily 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 are to be carried out on the site in order to prevent such effects. Monitoring and inspection procedures will be used to assess the level of dust emissions both on the 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 Daily Log will provide a record of the relevant monitoring and inspection results. The ESM or their delegate for the Project will fill out the Daily Log form each day and file it in a designated file in the EMS office. A Daily Log form is located in Appendix A of this AQDWP. The following information will be recorded in the Daily Log form: i)
Any dust control equipment malfunctions (e.g. water sprays), and any remedial action(s) taken.
ii)
Results of the visual inspections of dust emissions and wind conditions (see Section 4.2 for Visual Inspections procedures).
iii)
General weather conditions during the day (i.e., windy, calm, warm, rain, etc.).
iv)
Complaints received and responses to complaints.
v)
The date, time and signature of the person entering the information.
vi)
The use of other mitigation measures, such as the use of chemical dust suppressants or covering of storage piles, and the reasons leading to their use.
9.0 9.1
ROLES AND RESPONSIBILITIES Distribution
This AQDWP shall be readily available on the Project office at all times and distributed by the Construction Contractor to all relevant parties undertaking the works at the Project site. The provisions of the AQDWP shall be outlined to all parties during the site health and safety induction and acknowledged formally as part of this Project (i.e., signed project induction register).
9.2
Overview of Responsibility for this AQDWP
Each person involved in the Project has equal responsibility to strive to avoid, remedy or mitigate adverse dust effects. There are three key groups with responsibility for environmental management during the Project:
CRLL as the Project owner, holder of the resource consents and Requiring Authority responsible for the designation.
The Construction Contractor as the contractor undertaking the works. AC as the consent authority who audits the works and monitors compliance with the designation conditions, the CEMP, DWPs and management plans (MPs).
An ESM will be appointed as part of the Construction Team during the construction phase of the Project. The ESM will be involved throughout this period to give advice and to ensure that the CEMP, DWPs and October 2017 Report No. 1378206325-107-R-Rev0
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MPs are implemented and maintained. Further details of responsibilities during the construction phase are included below.
9.3
Specific Roles and Responsibilities
The key organisations, management roles and responsibilities in relation to air quality management during the construction associated with the Project are outlined in the CEMP. Those particularly relevant to air quality matters are outlined in Table 7.
Table 7: Environmental management responsibilities. Organisation
City Rail Link Limited
Role
Consent holder and Project Manager
Responsibilities
Primary contractor
Project Manager ESM Construction Manager
Primary contractor
Project Manager ESM Construction Manager
Sub-contractors
Construction Manager
Auckland Council
N/A
Air Quality Consents Team
All Construction Team staff
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Compliance with the RMA and consent requirements. Applications for new resource consents associated with changes to the activities proposed within the Project. Review of contractor’s site specific environmental management plans and DWPs Overall responsibility for site environmental management. Reviewing and reporting on environmental performance. Inspection of works to assess compliance with the AQDWP other DWPs and MPs and resource consent requirements. Inspections, auditing and checking of environmental management practices and procedures. Report to CRLL any changes to construction techniques which require designation alterations and/or new resource consents. Review and update of specific management plans and relevant DWPs. Maintain Daily Logs and Complaint Records. Training of all staff including subcontractors. Communicate with adjoining and potentially affected neighbours about methodologies that could give rise to dust, and where relevant odour.
Adherence to the AQDWP, DWPs and MPs. Adherence to resource consent requirements. Variation of specific DWPs or MPs, as required.
Attend daily toolbox meetings as required. Be trained in dust and odour management. Responsible for reporting dust and odour incidents. Ensure dust and odour management procedures adhered to.
Reviewing and certifying the management plans. Auditing to assess compliance with the AQDWP. Auditing to assess compliance with resource consent requirements.
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9.4
Contact Details
Contact details for those with key responsibilities in the implementation of this AQDWP are provided in the CEMP and CCP.
10.0 AQDWP AUDITING AND REVIEW 10.1 Introduction This AQDWP may require review and amendment during the life of the Project to reflect changes to activities, risks, mitigation measures, responsibilities and management processes. The ability to make changes to the AQDWP is an important aspect of continually improving the effectiveness of the AQDWP. Internal auditing and review will be undertaken by the ESM at a minimum of three monthly intervals. Auditing and review will be used to provide an independent appraisal of the site’s performance in relation to the objectives of the AQDWP. The results of this review process will enable project staff, CRLL and AC to assess suitability, adequateness and effectiveness of site operations from an environmental perspective.
10.2
Auditing
AC may visit the site to undertake site inspections and assess compliance with the designation conditions and the A2N resource consent conditions. Site staff will be available to assist AC staff during these inspections and provide any information required. In particular, any information or records required to be available by any designation condition or resource consents held by CRLL will be kept on site and will be readily available upon request. All documentation relating to this AQDWP shall be appropriately filed for auditing and review purposes.
10.3
Review
This AQDWP will be reviewed and updated when necessary to reflect changes in the construction methodologies, and throughout the course of the Project as required to reflect material changes associated with a new or changed activity, equipment or location of activities. The procedure for making changes to this AQDWP are given in the CEMP. The AQDWP is subject to a review process with the Community Business Liaison Group (CBLG) established for the Project and a suitably qualified independent peer reviewer. A summary of the outcomes of this review process is attached in Appendix B.
11.0 LIMITATIONS Your attention is drawn to the document, “Report Limitations”, Appendix C. The statements presented in that document are intended to advise you of what your realistic expectations of this report should be, and to present you with recommendations on how to minimise the risks to which this report relates which are associated with this project. The document is not intended to exclude or otherwise limit the obligations necessarily imposed by law on Golder Associates (NZ) Limited, but rather to ensure that all parties who may rely on this report are aware of the responsibilities each assumes in so doing.
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12.0 REFERENCES Aurecon 2017. Project description for Albert St canopy removals and utilities relocations (C2.1/2.2). July 2017. Golder 2017a. Albert Street Canopy Removals and Utilities Relocation Project – Air Quality Assessment. Report prepared by Golder Associates (NZ) Limited for Aurecon New Zealand Limited, August 2017. Golder 2017b. Albert Street Canopy Removals and Utilities Relocation – Contamination Delivery Work Plan. Report prepared by Golder Associates (NZ) Limited for Aurecon New Zealand Limited, August 2017. MfE 2016. Good practice guide for assessing and managing dust. Ministry for the Environment. Publication number: ME 1277.
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APPENDIX A Daily Log Form
October 2017 Report No. 1378206325-107-R-Rev0
DAILY LOG FORM Date:___/___/_____ Mon Tue Wed Thu Fri Sat Sun
VISIBLE DUST EMISSIONS Source
Level*
Colour/Opacity
Time
Weather Cond.
Wind Speed / Wind Direction
(i.e. rain, windy, calm)
(e.g. “7 m/s / NE”)
_______________
____
___________
___:____
____________
__________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
_______________
____
___________
___:____
____________
_________/_________
*Levels (extent) of visible dust emissions: (1) Minor visible emissions (<5m from source); (2) Moderate visible emissions (<30m from source); (3) Major visible emissions (>30m from source).
INVESTIGATION AND RESPONSE Date event was investigated:___/___/_____ Person responsible for investigation and response:________________________________ Possible cause(s):
Corrective actions:
Dust from wind erosion of exposed ground
Date:
Description:
Watercart not used properly
___/___/_____
___________________________________________
Exceedance of speed limit in unpaved surface
___/___/_____
___________________________________________
Materials not handled or stored properly
___/___/_____
___________________________________________
Loading/Unloading not carried out properly Other_________________________________________ ________________________________________________ ________________________________________________ ________________________________________________
Preventive actions: Date:
Description:
___/___/_____
___________________________________________
___/___/_____
___________________________________________
___/___/_____
___________________________________________
________________________________________________
VEHICLES AND MACHINERY – PRESTART CHECK Equipment identification
Excessive or prolonged visible emissions observed?
If yes, describe action taken (e.g., equipment repaired or removed from site within 24 hours):
___________________
________________________
_________________________________________________________
___________________
________________________
_________________________________________________________
___________________
________________________
_________________________________________________________
Person responsible for the above information: Name:______________________ Job Title:_________________________ Signature:______________________ Date:___/___/_____
ALBERT STREET CANOPY REMOVALS AND UTILITIES RELOCATION
APPENDIX B Community Business Liaison Group and Peer Review Outcomes
October 2017 Report No. 1378206325-107-R-Rev0
APPENDIX B Community Business Liaison Group and Peer Review Outcomes
COMMUNITY BUSINESS LIAISON GROUP REVIEW OUTCOMES Comments from the Community Business Liaison Group (CBLG) regarding the Air Quality Delivery Work Plan are summarised below.
Comment ID
Date
Time
Forum
Commenter
Comment
Resolution
1
12/9/17
17:30
CBLG Liaison Meeting
SkyCity
Jack hammering and concrete cutting should be included as a dust generating activity
This has been clarified in and update of Table 4 of the Air Quality Delivery Work Plan (AQDWP)
2
12/9/17
17:30
CBLG Liaison Meeting
SkyCity
Cleaning of buildings, will this service be provided?
CRLL will address the need for cleaning of buildings on a case by case basis.
3
12/9/17
17:30
CBLG Liaison Meeting
Heart of the City
Comments should be included on how dust outside the project site will be managed
Given the relatively small dimensions of the trench the dust mitigation strategies proposed are expected to mitigate against dust effects outside the project site.
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APPENDIX B Community Business Liaison Group and Peer Review Outcomes
INDEPENDENT PEER REVIEW (IPR) OUTCOMES The following comments were received from Independent Peer Reviewer on the Air Quality Delivery Work Plan. Peer Reviewer: Air Matters Limited – Carol McSweeney Date: 2 October 2017
Condition numberŦ
AQDWP section
Comment
59.1
Whole document
Nil
59.2
Whole document, Table 4
Nil
59.3 (a)
Section 4.3
The document concludes that no continuous monitoring is required for these works. Condition 59.3 states that this is required. The document describes these works as “enabling works” and therefore outside the requirement of this condition. The assessment is considered appropriate.
No action required.*
59.3 (b)
Sections 2.5 and 4.2
Sensitive receptors are identified in Section 2.5 Trigger levels. These are based on visual assessment and Section 4.2 suggests a trigger limit of moderate to major visible emissions. The effect levels are reported on the Daily Log Form. The process for action on the identification of the dust emissions is generally considered appropriate. However in order to satisfy the intent of condition 59.3(b) visible dust emissions that are classified as “minor (<5 m from the source) may in fact be problematic depending on the location of the sensitive receptor. The Daily Log Form could be used to identify the sensitivity of the receiving environment thereby indicating if action is required for “minor visible emissions”.
The controls detailed in Table 4, where relevant, apply at all times and do not rely on a trigger level being exceeded. The trigger of visible dust emissions classified as “moderate” or “major” is only used to notify the duty or site manager for further action, including ceasing on-site dust generating activities. Section 4.2 has been amended to clarify that the control and mitigation measures, where relevant, apply at all times and are to be carried out as necessary to prevent or remedy any visible dust emissions beyond the site boundary, regardless of the assessed level.
59.3 (c)
Section 5.0
Section 5 discusses minor discharges including emissions from the operation of vehicles and states there will be prestart checks of all machinery and control equipment as well as regular maintenance. Removal of the malfunctioning machinery within 24 hours satisfies this condition.
No action required.*
59.3 (d)
Section 3.3 Table 4
Controls are well documented in Table 4. Concrete cutting has been added in here and meets the CBLG request to have this included.
No action required.*
59.3 (e)
Table 4
The procedure in Table 4 requires covering of all loads of fine materials.
No action required.*
59.3 (f)
Table 4
Control generally limited to sweeping and removing spilled material once identified in the daily visual check. Adequate for the scale of works.
No action required.*
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APPENDIX B Community Business Liaison Group and Peer Review Outcomes
Condition numberŦ
AQDWP section
Comment
Resolution
59.3 (g)
Table 4
Contaminated site response, document refers to the Contamination Delivery Work Plan. (This has not been seen by myself).
No action required.*
59.3 (h)
Section 5.0
Section 5 discusses minor discharges including emissions from the operation of vehicles. No regular service for machinery used on site is specified apart from a prestart check before arrival on site and a service if emissions are identified. This condition requires equipment inspection and it is recommended that this is added onto the Daily Log Form. Suggest adding into Section 5 (end of paragraph 1) “Visually check equipment emissions for particulate” as part of the daily checks and record in the Daily Log Form.
Section 5.0 and Appendix A (Daily Log Form) updated so that the prestart checks of vehicles and machinery are recorded in the Daily Log Form.
59.3 (i)
Section 3.3
This Section 3.3 discusses a mitigation approach for verified dust emissions. This is appropriate and also addresses the comment raised in the CBLG (Comment 2) relating to a process for discussing cleaning of buildings.
No action required.*
59.3 (j)
Section 6.0, Appendix 1
The Daily Log Form is used to record responses to events and corrective actions. Reference to Communication and Consultation Plan (CCP) that has not been seen by myself.
No action required.*
Other comments
Air Matters therefore recommends an addition of a timed audit is added to Section 10.1 Auditing. It is recommended that internal audits are carried out at a minimum of 3 monthly intervals to ensure that the all the requirements of the designation conditions and the AQDWP are appropriately met.
Section 10.1 updated to include a requirement that the internal auditing and review is undertaken at a minimum of three monthly intervals.
Other comments
It is noted that Section 8.2 iv requires the frequency of the watercart and/or water sprinkler use to be recorded in the Daily Log Form. There is currently nowhere on this form to record that data.
As detailed in Table 4 of the AQDWP, water will be applied as necessary to dampen exposed surfaces and/or filling material. However, given the scale of these enabling works, Golder does not consider necessary to record the frequency of water application on the Daily log Form, and therefore Section 8.2 iv has been updated accordingly.
Notes:
Ŧ
Conditions from the City Rail Link (CRL) Designation 1714 that are relevant to the Air Quality Delivery Work Plan (AQDWP).
* In cases where no action is required, the peer review comments only pointed out how the AQDWP addressed the relevant conditions and did not recommend or require any changes to be made.
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APPENDIX C Report Limitations
October 2017 Report No. 1378206325-107-R-Rev0
APPENDIX C Report Limitations
This Report/Document has been provided by Golder Associates (NZ) Limited (“Golder”) subject to the following limitations: i)
This Report/Document has been prepared for the particular purpose outlined in Golder’s proposal and no responsibility is accepted for the use of this Report/Document, in whole or in part, in other contexts or for any other purpose.
ii)
The scope and the period of Golder’s Services are as described in Golder’s proposal, and are subject to restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or circumstances that may exist at the site referenced in the Report/Document. If a service is not expressly indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any determination has been made by Golder in regards to it.
iii)
Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Report/Document. Accordingly, if information in addition to that contained in this report is sought, additional studies and actions may be required.
iv)
The passage of time affects the information and assessment provided in this Report/Document. Golder’s opinions are based upon information that existed at the time of the production of the Report/Document. The Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations.
v)
Any assessments, designs and advice made in this Report/Document are based on the conditions indicated from published sources and the investigation described. No warranty is included, either express or implied, that the actual conditions will conform exactly to the assessments contained in this Report/Document.
vi)
Where data supplied by the client or other external sources, including previous site investigation data, have been used, it has been assumed that the information is correct unless otherwise stated. No responsibility is accepted by Golder for incomplete or inaccurate data supplied by others.
vii)
The Client acknowledges that Golder may have retained subconsultants affiliated with Golder to provide Services for the benefit of Golder. Golder will be fully responsible to the Client for the Services and work done by all of its subconsultants and subcontractors. The Client agrees that it will only assert claims against and seek to recover losses, damages or other liabilities from Golder and not Golder’s affiliated companies. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have any legal recourse, and waives any expense, loss, claim, demand, or cause of action, against Golder’s affiliated companies, and their employees, officers and directors.
viii) This Report/Document is provided for sole use by the Client and is confidential to it. No responsibility whatsoever for the contents of this Report/Document will be accepted to any person other than the Client. Any use which a third party makes of this Report/Document, or any reliance on or decisions to be made based on it, is the responsibility of such third parties. Golder accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this Report/Document.
October 2017 Project No. 1378206325-107-R
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Auckland Office Level 4, Aurecon House 139 Carlton Gore Road Auckland 1023 New Zealand T +64 9 520 6019 F +64 524 7815
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