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Industrial and Trade Activities Environmental Management Plan

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Mt Eden Enabling Works Industrial and Trade Activities Environmental Management Plan

CRL-MTE-RME-LKA-PLN-800025

Revision: 000 Date: December 2019


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Industrial and Trade Activities Environmental Management Plan

Mt Eden Enabling Works Industrial and Trade Activities Environmental Management Plan CRL-MTE-RME-LKA-PLN-800025

This document is uncontrolled when printed. This document should be printed in colour

Revision Status Revision

Date

Version details

Prepared By

Approved By

Rev A00

27/09/2019

Draft for Community Liaison Group and Mana Whenua

R Van de Munckhof

Peter Roan

Rev A01

14/11/2019

Draft for Auckland Council review

R Van de Munckhof

Peter Roan

Rev 000

02/12/2019

Final for Submission

R Van de Munckhof

Peter Roan

Approval Status Name/Title Prepared by:

Rose Turnwald

Signature

Date 02/12/2019

Environmental Engineer

Rob Van de Munckhof Principal Environmental Engineer

Reviewed by:

Rob Van de Munckhof

02/12/2019

Principal Environmental Engineer

Approved by:

Peter Roan Link Alliance – Consenting Lead

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02/12/2019


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Industrial and Trade Activities Environmental Management Plan

Table of contents 1.

Introduction Overview of CRL works in Mt Eden Purpose of the ITA EMP Relevant conditions Sustainability ITA EMP review, updates and reporting ITA EMP author 2. Project description 2.1 Construction methodology 3. Industrial and Trade Activities 4. Site drainage 5. Management procedures and mitigation measures 5.1 Environmentally hazardous substance management 5.2 Stormwater and groundwater treatment 5.3 Waste management 5.4 Vehicle refuelling 5.5 Wash-down 6. Spill response 7. Discharge monitoring and reporting 7.1 Monitoring 7.2 Reporting 8. Environmental compliance management and review 8.1 Site inspections 8.2 Environmental audits 8.3 Non-conformance, corrective and preventative action 9. Training 9.1 Employees and subcontractors 9.2 Visitors 9.3 Training records Appendix A: ISCA Requirements Appendix B: Emergency Spill Response Plan Appendix C: Record of CLG and Auckland Council Comments C1. CLG Comments C2. Auckland Council Comments Appendix D: Register of Plan Updates

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5 5 6 7 11 11 12 13 13 14 18 19 19 19 20 20 20 21 22 22 22 23 23 23 23 24 24 24 24 25 26 31 31 31 32


Industrial and Trade Activities Environmental Management Plan Glossary of abbreviations Acronym

Definition

ACZ

Active Construction Zone

ANZECC

Australian and New Zealand Environment Conservation Council

AT

Auckland Transport

CEMP

Construction Environmental Management Plan

CLG

Community Liaison Group

CRL

City Rail Link

CSA

Construction Support Area

DWP

Delivery Work Plan

EHS

Environmentally Hazardous Substance

ESCP

Erosion and Sediment Control Plan

ESM

Environmental and Sustainability Manager

ESRP

Emergency Spill Response Plan

FTMP

Flocculant Treatment Management Plan

HSNO

Hazardous Substances and New Organisms

IS

Infrastructure Sustainability

ISCA

Infrastructure Sustainability Council of Australia

ITA EMP

Industrial and Trade Activities Environmental Management Plan

SDS

Safety Data Sheets

SRP

Sediment retention pond

WI

Work Instruction

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Industrial and Trade Activities Environmental Management Plan

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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 (NAL) in the vicinity of Mt Eden Station. The CRL involves the construction of two new underground stations at Aotea and Karangahape, and a redeveloped station at Mt Eden (refer to Figure 1-1). The design and construction of the CRL infrastructure between Aotea and Mt Eden Stations is being delivered by the Link Alliance. This Industrial and Trade Activities Environmental Management Plan (ITA EMP) has been prepared in relation to the Mt Eden Enabling Works (“the Project”) undertaken at CSA 4. Separate management plans are being prepared for CSAs 1, 2, 3 and 5.

Figure 1-1: CRL Route and Location

Overview of CRL works in Mt Eden The CRL works in the Mt Eden area involve the construction of the southern section of the tunnel structures and the tie-in to the existing NAL, including the construction of the redeveloped Mt Eden Station. The Mt Eden Active Construction Zone (ACZ) and CSA is generally located between Nikau Street to the north, State Highway 1 (SH1) to the east, Dominion Road to the west and the existing NAL to the south. The works in this area include: • • • • • • Page 5

Construction of an underground grade separation structure near Mt Eden Station; A new Mt Eden Station building incorporating passenger linkages; Modifications to the existing Mt Eden Station platforms; Road over rail bridges at Mt Eden Road, Normanby Road and Ruru Street with sections of road realignment; Grade separation structures for the existing and new rail lines to pass-over and connect with each other; Pedestrian and cyclist bridge structures at Fenton Street and Porters Avenue; and

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Industrial and Trade Activities Environmental Management Plan •

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New road linkages within the reinstated area post-construction.

Given the nature and scale of CRL works in Mt Eden, construction will be undertaken in a staged manner. This ITA EMP only relates to the first stage of these works, the Mt Eden Enabling Works at CSA 4. as described in Section 2 below. Following completion of the Mt Eden Enabling Works, works in this area will involve: Main construction works – these works will include: Tunnel Boring Machine (TBM) operations, structure construction and waterproofing/tanking for cut and cover tunnels, utilities installation, retaining wall for Ruru street extension, construction of the rail line tieins including junctions and grade separation structures, realignment of the existing Western Line including platform reconstruction, grade separation of Normanby Road, pedestrian / cyclist bridges at Fenton and Porters, construction of the new station buildings. The Main Works will be undertaken from Mid 2020 through to 2024. • Public realm reinstatement – these works will involve establishing the final finishings and features that will comprise the completed Mt Eden Station and surrounds and will likely to be undertaken from 2021 to first quarter-2024. Separate ITA EMPs will be prepared and implemented for the Mt Eden main construction works. •

Purpose of the ITA EMP This ITA EMP has been prepared to manage adverse effects relating to industrial and trade activities required during the Mt Eden Enabling Works, including portal construction, bulk excavation, piling, site establishment works and associated storage and handling of hazardous substances which occur within CSA 4. Specifically, the purpose of the plan is to identify those activities to be undertaken that may result in contamination of land and/or stormwater, and to document the procedures to be implemented to appropriately manage these risks. The ITA EMP outlines the following: • • • • •

Identification of industrial and trade activities to be undertaken during the Mt Eden Enabling Works that may result in contamination of land and/or water; Identification of potential contaminants associated with these activities; The methods to be used to prevent identified contaminants from contacting with stormwater runoff and methods to manage environmental risks from on-site activities; An appropriate monitoring and auditing programme to ensure site performance is undertaken in accordance with this ITA EMP; and Staff training.

This ITA EMP addresses the requirements of the Aotea to NAL resource consent (A2N resource consent) set out below and will be implemented throughout the construction period of the Mt Eden Enabling Works. The majority of the Mt Eden Enabling Works area is included in CSA 4, and utilises the maximum area of 36,000 m2. The utility relocation works at Fenton Street and the Mt Eden Road Bridge are not included in CSA 4 and are not Industrial and Trade Activities. These activities are addressed separately in the Construction Environmental Management Plan (CEMP). This ITA EMP has been prepared by Link Alliance and forms part of the CEMP for the Mt Eden Enabling Works. It has been developed in consultation with the Mt Eden Community and Business Liaison Group (CLG) (as per resource consent condition 19). Comments received from the CLG have been (where applicable and appropriate) incorporated in the ITA EMP, with an explanation provided where any comments have not been incorporated. A record of the consultation outcomes is provided in Appendix C of this ITA EMP. Page 6

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Industrial and Trade Activities Environmental Management Plan

A number of related management plans are referenced throughout this ITA EMP to avoid duplication of information and thereby enable efficient document control. The other relevant plans are the CEMP, Erosion and Sediment Control Plan (ESCP) (Appendix H of the CEMP, including Flocculent Treatment Management Plan (FTMP)) and the Emergency Spill Response Plan (ESRP) (Appendix B of this ITA EMP).

Relevant conditions Table 1-1 identifies the A2N resource consent conditions relevant to this ITA EMP and where they are addressed in the document. Table 1-1: Aotea to North Auckland Line resource consent conditions and location in Plan Condition No.

Condition

Relevant section of DWP

159

At least 20 working days prior to the commencement of construction, a final Industrial and Trade Activities Environmental Management Plan (EMP) shall be submitted to the Council (Team Leader Central Monitoring) for certification.

This document

160

The Consent Holder shall request the Council’s (Team Leader Central Monitoring) determination as to whether the EMP can be certified, in writing, within 10 working days following receipt of the EMP.

To be certified.

161

The EMP shall be prepared by a Senior Qualified Person and shall include, but not be limited to, the following:

Section 1.6

a)

identification of the specific activities conducted on the site;

Section 2

b) the identification of potential contaminants associated with these activities;

Section 3

c)

Section 5

methods used to prevent identified contaminants contacting stormwater runoff as far as practicable and methods to manage environmental risks from site activities;

d) an Emergency Spill Response Plan (which includes the provision that all spills over 20 litres, or any spill of Environmentally Hazardous Substances that has entered the stormwater system, a water-body or has contacted unsealed ground, shall be reported immediately to the Auckland Council’s 24 Hour Pollution Hotline (09-377-3107));

Appendix B of this ITA EMP

e)

an up-to-date and accurate site drainage plan showing the location of all site catch pits and the final discharge point(s) of the site stormwater system;

Section 4 ESCP (Appendix H of the CEMP)

f)

an appropriate auditing programme to ensure all components of the site’s EMP are implemented;

Section 7 ESCP (Appendix H of the CEMP)

g)

methods for providing and recording staff training; and

Section 9

h) a monitoring programme as outlined in Conditions 173 and 174.

Section 7

162

The Consent Holder shall ensure that the CSAs and ACZs are operated and managed in accordance with the certified EMP to ensure the risks from the site are managed appropriately.

Section 8.1

163

The Consent Holder shall ensure that a copy of the Council certified EMP is kept on site and accessible at all times.

Section 1.2

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Industrial and Trade Activities Environmental Management Plan Condition No.

Condition

Relevant section of DWP

164

Following any change to the EMP, the Consent Holder shall submit details of the change to the Council (Team Leader Central Monitoring) for certification and request that the Council’s (Team Leader Central Monitoring) written determination as to whether the change can be certified to be provided within 10 working days of submission of the change.

Section 1.5

165

The EMP shall be reviewed and updated annually from the date of granting of this consent, to ensure all components of the EMP remain relevant.

Section 1.5

166

The Industrial Trade and Activity area for each of the Construction Support Areas shall not exceed the following:

Section 3

167

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CSA

Exposed Area Not to Exceed (m2)

1

25,000

2

9,000

3

9,000

4

36,000

5

6,500

In the event that any CSA requires an increase in area, the following information shall be provided to the Team Leader – Central Monitoring whose certification shall be requested prior to implementation: a) Plans and drawings outlining the details of the modifications; and Supporting information that confirms how the proposal does not affect the capacity or performance of the existing structural and procedural controls.

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No increase in area is proposed.


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Industrial and Trade Activities Environmental Management Plan Condition No.

Condition

Relevant section of DWP

168

The Consent Holder shall ensure that the following structural controls are constructed for the following catchment areas and design standards and they are completed prior to discharges commencing from the site:

Settlement tanks and inlet protection described in the Stage-Specific ESCPs (Appendix H of the CEMP) Bunding of environmentally hazardous substances addressed in Section 5.4 of this ITA EMP

Works /controls

Device catchment area

Design requirements

2 x Settlement Tanks located on CSA 4

Activity area of grout plant (400m2), and segment storage yard (2660m2) on CSA 4

Settlement Tanks sizing to be based on 2% of the contributing catchment

Inlet protection measures

On all catch pits within CSA areas

Design in accordance with Auckland Council Best Management Practice: Catch pit Protection Area (AC 2011).

2 x Settlement Tanks located in CSA 1, CSA 2, CSA 3, CSA 4 and CSA 5

All Active Construction Zones (ACZ)

Settlement Tank sizing to be based on 2% of the contributing catchment

Bunding of Environmentally Hazardous Substances

As required

110% largest container

169

In the event that any minor modifications to the structural system are required, the following information shall be provided to the Team Leader – Central Monitoring whose certification shall be requested prior to implementation: a) Plans and drawings outlining the details of the modifications; and b) Supporting information that confirms how the proposal does not affect the capacity or performance of stormwater management system.

Any minor modification to the structural systems are outlined in the ESCP.

170

Within 30 days of implementation, As-Built certification and plans of the stormwater management works, certified (signed) by a suitably qualified registered surveyor or a Chartered Professional Engineer as a true record of the stormwater management system, shall be provided to the Team Leader – Central Monitoring.

Section 5.1 of the CEMP

171

The As-Built plans shall include, but not be limited to: a) The surveyed location (to the nearest 0.1m) of the discharge points, with co-ordinates expressed in terms of NZTM and LINZ datum; b) Location, dimensions and levels of any major overland flow paths including cross sections and long sections; c) Plans and cross sections of all stormwater management devices, including confirmation of the Water Quality Volume, storage volumes and levels of any outflow control structure d) Documentation of any discrepancies between the design plans and the As-Built plans.

Section 5.1 of the CEMP

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Industrial and Trade Activities Environmental Management Plan Condition No.

Condition

Relevant section of DWP

172

A meeting shall be held on site after the implementation of structural controls and the provision of As-Built documentation, and prior to the commencement of construction activities at each of the CSA/ACZs. The meeting shall include representation from the Team Leader Central Monitoring and the site stormwater engineer/contractors who have undertaken the work and shall confirm compliance with the relevant consent conditions.

Included in the ESCP (Appendix H of the CEMP)

173

Within 30 days of the installation of the water treatment systems, and prior to operation, the Consent Holder shall develop and submit to the Council (Team Leader Central Monitoring) for certification a discharge monitoring programme.

FTMP (Appendix H of the CEMP)

174

The water quality monitoring programme shall include, but not be limited to: a) Sampling locations (to include the final discharge from the treatment system located in CSA 1, CSA 2, CSA 3, CSA 5 and CSA 4); b) Methods and procedures for discharge sampling; and c) Monitoring parameters for analysis, which shall include: Daily − Water clarity (black disc) cm − Turbidity (NTU) − pH Weekly (in addition to the above) − Total Suspended Solids g/m3 − Total recoverable copper g/m3 − Dissolved copper g/m3 − Total recoverable zinc g/m3 − Dissolved zinc g/m3 − Total petroleum hydrocarbons g/m3 − Ammoniacal nitrogen* g/m3 − Nitrate nitrogen* g/m3 *only in discharge from treatment systems in CSA 3 and CSA 4 d) identified trigger levels for each of the above parameters. These trigger levels shall be developed with reference to the ANZECC Guidelines for water quality where applicable; and e) the methods and procedures for investigating and reporting stormwater discharge monitoring results to the Council (Team Leader Central Monitoring).

FTMP (Appendix H of the CEMP)

175

The discharge monitoring programme shall be implemented upon completion of works set out in Condition 168.

FTMP (Appendix H of the CEMP)

176

Within five working days of receipt of sample results showing contaminants exceeding the agreed trigger levels in Condition 174(d): a) An investigation shall be undertaken to determine why exceedances were detected and to identify any additional source controls or treatment required; and b) The results of the investigation shall be reported to the Council (Team Leader Central Monitoring).

Section 8.5.2 of the FTMP (Appendix H of the CEMP)

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Industrial and Trade Activities Environmental Management Plan Condition No.

Condition

Relevant section of DWP

177

Within eight weeks following the start of the monitoring required by Condition 173 a monitoring report shall be submitted to the Council (Team Leader Central Monitoring). The monitoring report shall include, but not be limited to, the following: a) a summary of the monitoring results to date; b) an interpretation of those results and suggestions for improvement to the site operations; c) a programme for ongoing monitoring including the reporting of results; and d) a programme for the ongoing maintenance of the discharge water management and treatment system.

Section 8.5 of the FTMP (Appendix H of the CEMP)

178

For the duration of the construction stages of the Project, the Consent Holder shall forward a report annually from the date of granting of this consent to the Council (Team Leader Central Monitoring) evaluating the site’s environmental performance for the year to date.

Section 6.5 of the CEMP and Section 10.1 of this ITA EMP

179

The Annual Report required by Condition 178 shall include but not be limited to: a) all aspects of the performance of the EMP relating to this consent; b) a summary of all revisions and revised sections of the EMP; c) details of all inspections and maintenance of the stormwater system for the preceding 12 months; d) details of and changes to the person(s) or body responsible for the maintenance of site and the organisational structure supporting this process; e) results and analysis of the preceding 12 months of stormwater monitoring, along with an interpretation of those results and suggestions for improvement to the site operations; and f) records of any spills or incidents which occurred within the previous 12 months and the response which was undertaken.

Section 6.5 of the CEMP and Section 10.1 of this ITA EMP

Sustainability The Link Alliance is seeking an Infrastructure Sustainability Council of Australia (ISCA) Infrastructure Sustainability (IS) Rating. Further details can be found in the CEMP and Sustainability Rating Management Plan. Project sustainability requirements that relate directly to this ITA EMP are included in Appendix A. These requirements are imbedded within the plans 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 consent requirements.

ITA EMP review, updates and reporting This ITA EMP is a live document that will be reviewed at least annually, or as a result of a material change to the project, or to address unforeseen settlement effects arising from construction, or unresolved complaints. Any proposed changes to this ITA EMP must be certified by Auckland Council prior to any on-site activity reliant upon the change commencing. Refer to Section 6 of the CEMP for further detail on the review and updating process.

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An annual report will be prepared and provided to Auckland Council in accordance with conditions 178 and 179 of the A2N resource consent to include: a. all aspects of the performance of the EMP relating to this consent; b. a summary of all revisions and revised sections of the EMP; c. details of all inspections and maintenance of the stormwater system for the preceding 12 months; d. details of and changes to the person(s) or body responsible for the maintenance of site and the organisational structure supporting this process; e. results and analysis of the preceding 12 months of stormwater monitoring, along with an interpretation of those results and suggestions for improvement to the site operations; and f. records of any spills or incidents which occurred within the previous 12 months and the response which was undertaken.

ITA EMP author This ITA EMP has been prepared by Rob Van de Munckhof. Rob holds a chemical engineering degree and has over 18 years’ experience in environmental management and has experience in Industrial and Trade Activity assessment and management. He has undertaken assessments of surface water discharges from a range of industrial sites and is experienced in undertaking risk assessments to identify priority contaminants. He is experienced in the development of environmental management plans and surface water monitoring plans.

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Industrial and Trade Activities Environmental Management Plan

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Project description

In order to launch the TBM and commence construction of the CRL tie-ins to the NAL, a range of ‘enabling’ works are proposed, which are the subject of this ITA EMP. These enabling works are described in detail in the CEMP. In summary, the Mt Eden Enabling Works involve: • • •

•

• • • •

Continuation of the demolition and clearance of the Mt Eden CSA (these works are authorised under the Mt Eden Demolitions Outline Plan). Set up of a temporary site office, which is anticipated to be a 2-3 storey modular building (likely made up of containers) located in the western extent of the CSA. Piling and excavation associated with the preparation of the portal. This will involve the demolition of the redundant stormwater shaft located in the portal area; the installation of bored solder piles and associated works (ground anchors and shotcrete) to support the excavation face; and removal of spoil. Bulk excavation to form what will become the rail trenches/cut and cover tunnels, which will also provide a ramp for the TBM to be manoeuvred into position. The excavation will encounter basalt, which is to be blasted in order to expedite the works and minimise the amount of rock-breaking required. In places, softer ground conditions are anticipated to be encountered, which may require the use of sheet piles. Local mined tunnelling to facilitate the launch of the TBM. Construction of the additional Mt Eden Road bridge (north of the existing bridge), including temporary diversion of utilities in this location. Construction of the Ruru Street bridge, including diversion of the Huia 2 watermain in this location. Temporary and permanent utility diversions (such as water, wastewater, stormwater, vector overhead cables and ducting, gas, and communications) along Fenton Street, Porters Avenue, Haultain Street and Wynyard Street to provide adequate clearance between the Huia 2 watermain and NAL, associated retaining walls, and the proposed Fenton Street pedestrian bridge.

2.1 Construction methodology The Project will be divided into stages as described in the CEMP.

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Industrial and Trade Activities Environmental Management Plan

3.

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Industrial and Trade Activities

The main industrial and trade related activities to be undertaken for the Mt Eden Enabling Works are outlined in Table 3-1. This table also outlines the potential contaminants associated with the activities and the relevant procedural and physical controls to be implemented during the Project to minimise any adverse environmental effects. The majority of the Mt Eden Enabling Works area is included in CSA 4, and utilises the maximum area of 36,000m2 which is consistent with condition 166 of the A2N resource consent. The utility relocation works at Fenton Street and the additional Mt Eden Road Bridge are not included in CSA 4 and are not Industrial and Trade Activities. These activities are addressed separately in the CEMP. References to several related plans/registers are provided in Table 3-1.

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Industrial and Trade Activities Environmental Management Plan Table 3-1: Summary of activities, potential contaminants and controls and risk ratings Activity

Contaminants

Initial risk

Procedural controls

Physical controls

Residual risk

Hazardous substances store

Hydrocarbons, oils and greases, fuels, cement

High

Risk register Site induction and staff training

All chemicals shall be stored within a bunded enclosure, such as a modified shipping container.

Medium

Water treatment plant and associated treatment chemical storage

pH, sediment

High

Risk register ESRP Site induction and staff training

Water treatment chemicals shall be stored within a bunded enclosure. Treatment tank size and pump rates to be set to allow required residence time and additional containment of any peak flows or over flows to be provided. Engineering controls in place to prevent overfill.

Medium

Grout mixing plant

Sediment, pH

High

Risk register Site induction and staff training

The grout mixing plant shall be located within a bunded area, or area draining to an Sediment Retention Pond (SRP) and/or containerised pH dosing system with pH monitoring undertaken.

Low

Cement/concrete application

Sediment, pH

High

Risk register ESRP Site induction and staff training

No washing out of concrete trucks shall be undertaken on-site. All runoff from the site construction and excavation areas shall be directed to an SRP and or containerised pH dosing system with pH monitoring undertaken.

Low

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Industrial and Trade Activities Environmental Management Plan Activity

Contaminants

Initial risk

Procedural controls

Physical controls

Residual risk

Handling and temporary storage of excavated or backfill materials

Sediment

Moderate

Risk register ESCP CDWP CEMP FTMP Site induction and staff training

Excavated material to be loaded directly onto truck where practicable or placed within designated stockpile areas for removal from site. Stockpile areas are covered to prevent rainwater contact and located with erosion and sediment controls to divert sediment laden water to the SRP and associated WTP.

Low

General site activities

Vehicle or generator refuelling

Hydrocarbons, fuels

Moderate

Risk register ESRP Site induction and staff training

Drip trays must be in place during refuelling. Spill kit to be available in close proximity to the activity.

Low

Unloading of Environmentally Hazardous Substances (EHS)

Hydrocarbons, pH

Moderate

Risk register ESRP Site induction and staff training

Transfer of EHS to the designated storage area promptly upon receipt. Spill kit available in close proximity to unloading area.

Low

Construction equipment storage (shotcrete pumps, compressors, generators etc.)

Oil, fuel and hydraulic fluid leakage

Moderate

Risk Register ESRP Site induction and staff training

Regular inspection and servicing of equipment. Repair to minimise leakage.

Low

Equipment washdown

Sediment, hydrocarbons, oil & grease, heavy metals

Moderate

Risk register Site induction and staff training

Washing of equipment shall only be undertaken within the excavation area. A wheel washing bay is provided at the eastern site access point to prevent sediment tracking off site. Wash bay runoff will be directed to the SRP and containerised pH dosing system with TSP monitoring undertaken. No vehicle washing shall otherwise be undertaken on-site.

Low

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Industrial and Trade Activities Environmental Management Plan Activity

Contaminants

Initial risk

Procedural controls

Physical controls

Residual risk

Waste handling and storage

Sediment, hydrocarbons, oil & grease, heavy metals

Moderate

Risk register ESRP Site induction and staff training

All waste bins shall be stored in a covered area on-site, or have lids.

Low

Equipment laydown

Oil & grease, heavy metals

Low

Risk register Site induction and staff training

Regular inspection and servicing of equipment. Repair to minimise leakage.

Low

Vehicle parking

Oil & grease, heavy metals

Low

Risk register Site induction and staff training

Spill kit available. Regular inspection and servicing of vehicles.

Low

Low

Risk register

Offices

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-

-

Low


Industrial and Trade Activities Environmental Management Plan

4.

Site drainage

All existing stormwater drains within the excavation areas have been removed/sealed. The drainage from the site will be either directly to the public stormwater network where no moderate or high risk activities are undertaken or via the sediment retention ponds (SRP) and water treatment plant. The release of contaminants to the stormwater network will be managed using the controls described in the ESCP and Stage-Specific Erosion and Sediment Control Plans (SSESCP) and this ITA EMP. Discharge to sewer network may also be undertaken where water quality requirements for stormwater cannot be met. Drainage plans have been prepared for each SSESCP (refer to Appendix H of the CEMP) to show the location of the SRPs, any catchpits, diversion bunds and the discharge monitoring points. A brief summary of the activities and key treatment methods in the relevant SSESCPs is provided in Table 4-1 below. For full detail regarding the methods to be used to prevent identified contaminants contacting stormwater runoff and methods for treatment of contaminated runoff, refer to the individual SSESCPs and FTMP in Appendix H to the CEMP. Table 4-1:

Summary of SSESCP controls

SSESCP reference

Risk

Key treatment measures proposed

001 – Office set up

Low - Up to 800 m2 area subject to topsoil removal.

Silt fences All catchpits within the CSA are installed with catchpit bags until they can be abandoned.

002 – Portal Piling

High - Up to 9000 m2 of works involving excavation and removal of concrete foundation and piling.

Installation of SRP1 at the lower extent of the works area, all discharge from the works area via SRP1 is subject to monitoring requirements set out in the FTMP. A dirty water diversion drain will channel potentially contaminated water to SRP1. Hotmix cleanwater diversion bund in place around perimeter of works area.

003 – Bulk Earthworks

High – Up to 36,000 m2 area subject to excavation, removal of concrete foundations, earthworks and tunnel support facilities construction.

Portal piling control measures are retained; SRP2 constructed as an interim measure within the lowest section of the work area, discharging to the existing stormwater network subject to monitoring requirements set out in the FTMP. SRP3 is constructed at the north east of the site and includes containerised treatment with capacity to service the full area of CSA 4. Once gravity draining to SRPs 1 & 2 is no longer viable, all discharges are collected via pumping from the low point of the excavation area and discharged to SRP 3. All discharges to the existing stormwater network from SRP3 are subject to monitoring requirements set out in the FTMP.

The public stormwater network drains via Motions Creek to the Waitematā Harbour at Point Chevalier to the west.

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Industrial and Trade Activities Environmental Management Plan

5.

Management procedures and mitigation measures 5.1 Environmentally hazardous substance management

The principal environmentally hazardous substances that will be stored and used during the construction works will include: • • • • •

Fuel (e.g. petrol, diesel); Oils and greases; Dry grout; Concrete (use only, will not be stored on site); and Water treatment chemicals (for sediment settling and pH adjustment e.g. flocculation agents and citric acid).

Dangerous and hazardous substances shall be stored on site in accordance with the Health and Safety at Work (Hazardous Substances) 2017 Regulations (HSW-HS), and subject to provisions relating to Location Compliance Certificates, as appropriate. All chemicals will be stored in a secure area with secondary containment to contain any spills. The main storage area is the Hazardous Goods shipping container located adjacent to the eastern site boundary near Mt Eden Road. There is also some local storage of chemicals at the WTP and mechanical workshop. For all local storage, chemicals must be stored on spill pallets to provide appropriate secondary containment. Safety Data Sheets (SDS) for all of the chemicals used or stored in the Mt Eden Enabling Works area will be kept in the site office with a sub-set on file at each storage location relevant to the specific materials being stored. A Hazardous Substances and SDS register shall be kept on-site and regularly maintained to ensure it is up to date with the chemicals and volumes of chemicals used and stored on-site. Spill kits and associated spill response equipment, will be available at the water treatment chemical storage area, the main chemical store, the main office and at each vehicle entrance (refer to Appendix B of this ITA EMP).

5.2 Stormwater and groundwater treatment Groundwater and stormwater which collects in the excavation area during construction works will be treated as detailed in the ESCP, the SSESCPs and the FTMP (refer to Appendix H of the CEMP). The SSESCPs have been developed to identify the appropriate diversion methods and treatment during the different stages of the Enabling Works as follows: • • • • •

SSESCP 001 – Office setup SSESCP 002 – Portal piling SSESCP 003 – Bulk earthworks SSESCP 004 – Mt Eden bridge SSESCP 005 – Fenton Road

The control measures outlined in the ESCP and SSESCPs to be implemented during the works include: • •

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Silt fences, diversion bunds and decanting earth bunds; Containerised sediment control devices for pumped flows from areas with high risk of contamination, in particular for activities associated with a high pH runoff such as concrete and grouting works. For high pH runoff the device will include acid dosing or CO2 injection; | Mt Eden Enabling Works


Industrial and Trade Activities Environmental Management Plan •

• •

Sediment Retention Ponds (SRP) for treatment of flows from works areas with moderate to high risk of contamination. Batch dosing will be undertaken at the SRPs in accordance with the FTMP Cleanwater diversions to existing cesspits located beyond the CSA to reduce the volume of contaminated runoff generated; and Wheel wash at vehicle exit to Shaddock Street during portal piling works, and at vehicle exit to Ngahura Street during the bulk earthworks.

Discharge to sewer network may also be undertaken where water quality requirements for stormwater cannot be met. Any discharges to the sewer network will be in accordance with the terms of a Trade Waste Agreement to be established with WaterCare.

5.3 Waste management For the purpose of the Mt Eden Enabling Works, waste material refers to items removed from worksites and road carriageways, such as surplus or reject spoil, excavated seal, pipes, rubbish detritus and any other unwanted materials. Appropriate disposal shall be arranged for any material that requires off-site disposal. If hazardous material requires off-site disposal, it will be disposed of safely, through an appropriate contractor authorised to handle, transport, process or safely dispose of the waste concerned to an approved disposal facility. Any waste bins on-site will either be stored undercover, or will be installed with covers to prevent rainwater ingress.

5.4 Vehicle refuelling No permanent storage of bulk fuels will occur on-site. Refuelling of plant and equipment will be undertaken using either a mini-tanker for larger equipment, or portable containers (such as jerry cans) for smaller plant and equipment. Portable containers of fuel will be stored in a dedicated hazardous goods store. Refuelling will be undertaken in accordance with key controls outlined in the environmental risk register

5.5 Wash-down No vehicle wash-down will be undertaken on-site, apart from localised washing of vehicles and tyres as required in order to prevent the tracking of sediment onto the surrounding road network. A wheel wash for this purpose is provided near the western site access onto Ngahura Street. The location and nature of the construction works, along with the construction methodology will serve to minimise the potential for site vehicles to drive over areas of open excavation or unpaved areas and track dirt onto the surrounding road network. In the event of material being spilled onto the ground around the excavation or from trucks transporting the spoil from the excavation, the material will be cleaned up prior to the vehicle leaving the site. This may involve some localised washing of vehicles and tyres. Any runoff from the wash down area will be directed to the on-site WTP with associated sediment settling pond and monitoring prior to discharge, in accordance with SSESCP 003. Some washing of machinery within the excavation area may be required. In this instance, washing of machinery will be undertaken using a hose or water blaster on-site within the excavation area only. All runoff within this area is captured and pumped to the WTP.

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6.

Spill response

A general ESRP has been prepared for the Mt Eden Enabling Works (refer to Appendix B of this ITA EMP). The ESRP includes provision that in the event of all spills over 20 litres, or any spill of Environmentally Hazardous Substances, which has entered the stormwater system, a water-body or has contacted unsealed ground, the spill shall be reported immediately to Auckland Council’s 24 Hour Pollution Hotline (09-377-3107). A site plan has also been developed, which shows the location of all spill kits in the Mt Eden Enabling Works area (refer to Appendix B of this ITA EMP). As described in Section 5.1, spill kits will be located at the water treatment chemical storage area, the main chemical store, the main office and at each vehicle entrance. Signage relating to spill response procedures will be located at each vehicle entrance to the site during each stage of work. Each spill kit will have a register of contents and an inspection sheet. Each spill kit will be inspected monthly to ensure all contents are present and there is no rubbish in the kits. The inspection sheet shall be signed during each inspection.

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7.

Discharge monitoring and reporting 7.1 Monitoring

Discharges from CSA 4 will be monitored as required by condition 173 of the A2N resource consent listed in Table 1-1. The water quality discharge monitoring programme is set out in Section 8 of the FTMP (Appendix H of the CEMP) which outlines the sampling locations, monitoring parameters, monitoring methods, trigger levels and monitoring reports.

7.2 Reporting Reporting of the monitoring results shall be undertaken in accordance with conditions 176 and 177 of the A2N resource consent as provided in in Table 1-1. Section 9.5 of the FTMP (Appendix H of the CEMP) details the different water quality reports that will be supplied to the Auckland Council (Team Leader Central Monitoring) throughout the Mt Eden Enabling Works. These include an initial monitoring report within eight weeks following the start of the monitoring, any non-conforming result report, and the annual monitoring report.

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8.

Environmental compliance management and review 8.1 Site inspections

Regular inspections of the Mt Eden Enabling Works area will be undertaken throughout the construction duration as outlined in Section 6 of the CEMP. Site inspections will include inspections of industrial and trade related activities to ensure the integrity of activities and devices is maintained and to minimise the potential for the discharge of contaminants from the Mt Eden Enabling Works area that might have adverse effects on the receiving environment. Site inspections will be conducted (and documented) weekly and include the following elements: • • • • • • • •

Check bunding and containment systems around hazardous substances are intact; Check water treatment systems are operating correctly to manage contaminated water; Check all loading and unloading areas are clear of spillage and debris; Check the appropriate storage of materials on-site in order to prevent spillage and have appropriate HAZCHEM warning and information signage; Check site for evidence of spills that require clean up; Check construction vehicles for signs of leakage; Check spill kits are fully stocked, clearly labelled and appropriately located; and Check waste skips and containers for capacity, signs of leakage and ensure they are covered to prevent rain water ingress.

8.2 Environmental audits An internal environmental and sustainability audit will be undertaken 30 days from commencement of each key stage of the Mt Eden Enabling Works and at least a quarterly basis (or more frequently as specified in the Audit Schedule). The purpose of the audit is to check the implementation of, and compliance with, environmental management procedures and controls, including those outlined in this ITA EMP. The audit findings will be reported accordingly to enable any discrepancies to be identified and actioned. External environmental and sustainability audits will be completed as per the Audit Schedule, and at least annually, to assess the effectiveness of the Environmental Management System. Refer to Section 6.3 of the CEMP for further detail on these audits.

8.3 Non-conformance, corrective and preventative action Corrective action is required on the basis of the occurrence of substandard performance being observed or experienced, resulting in an environmental complaint, incident or emergency or where a significant environmental incident or emergency could have occurred. Refer to Section 6.4 of the CEMP for further detail on corrective and preventative action during the Mt Eden Enabling Works.

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Industrial and Trade Activities Environmental Management Plan

9.

Training 9.1 Employees and subcontractors

All Project staff (including subcontractors) will undergo general environmental awareness training, along with training in relation to the risks associated with industrial and trade activities outlined in this ITA EMP and to ensure that the appropriate control measures are properly implemented. Suitable induction and ongoing environmental training will be established and maintained to ensure employees and subcontractors are aware of: • • • • • •

The importance of conformance with the Environmental Policy, the requirements of the CEMP and company procedure; The significant environmental aspects, actual or potential, of activities and the environmental benefits of improved performance; Their roles and responsibilities in achieving conformance with the environmental policy, company procedures and this ITA EMP; The potential consequences of departure from specified operating procedures; Spill response and emergency procedures; and Accident and incident reporting and methods of prevention.

Refer to Section 4.2 of the Mt Eden Enabling Works CEMP for further detail on employee training.

9.2 Visitors Visitors to the site are required to attend a site induction. This induction will cover the key environmental risks onsite, including those associated with industrial and trade activities outlined in this ITA EMP where relevant. A shortened visitor induction may be used when the visitor only requires access to the site for the day, and will be accompanied by a team member at all times (refer to Section 4.2 of the CEMP).

9.3 Training records Staff training will be recorded as outlined in Section 4.2 of the CEMP.

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Industrial and Trade Activities Environmental Management Plan

Appendix A: ISCA Requirements Table A identifies the ISCA Credit Requirements relevant to this ITA EMP and where they are addressed in the documents. Table A: ISCA Requirements Credit

Requirement *

Relevant section

Comments

DIS-1 Level 1

Baseline studies of existing receiving water environment have been carried out for the Project

Section 3.1

Refer also to the Water Quality Assessment Report and Update on Motions Creek Baseline Monitoring by Golder Associates, dated Dec 2014 and November 2018 respectively and the Flocculant Treatment Management Plan

DIS-1 Level 1

Predictions for receiving water quality impacts have been developed for construction

Section 4

Refer also to the Water Quality Assessment Report and Update on Motions Creek Baseline Monitoring by Golder Associates, dated Dec 2014 and November 2018 respectively and the Flocculant Treatment Management Plan

DIS-1 Level 1

Measures to minimise adverse impacts to local receiving water quality identified and implemented

Sections 3, 4, 5 and 6.

Refer also to the Flocculant Treatment Management Plan and Contaminated Soils Management Plan

DIS-1 Level 1

Monitoring of water discharges and receiving waters is undertaken at appropriate intervals and at times of discharge during construction

Section 7

Refer also to the Flocculant Treatment Management Plan

DIS-1 Level 2

Modelling demonstrates no exceedances of water quality goals

Section 7

Refer also to Flocculant Treatment Management Plan

DIS-1 Level 2

All stormwater leaving the site is treated or filtered in accordance with appropriate urban stormwater guidelines unless it occurs during a 6 hour 1 in 5 year storm event

Section 7

Refer to the Erosion and Sediment Control Plan and the Flocculant Treatment Management Plan

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

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Appendix B: Emergency Spill Response Plan 1.0

Purpose and Objective of Plan

Environmentally Hazardous Substances (EHS) will be present in CSA 4. These principally include: • • • • •

Fuel (e.g. petrol, diesel); Oils and greases; Dry grout; Concrete (use only, will not be stored on site); and Water treatment chemicals (for sediment settling and pH adjustment e.g. flocculation agents and sulfuric acid).

This Emergency Spill Response Plan (ESRP) relates to the management of spills of EHS’s and the prevention of adverse environmental effects. The objective of this ESRP is to ensure that emergency spills are handled in an appropriate manner to ensure safety of all personnel and to prevent damage to the environment. This ESRP covers the spill response procedures for the site including the CSA and works areas.

2.0

Spill Response

Spillages will be managed and cleaned up on site in accordance with this ESRP. Any contamination of stormwater or groundwater within the trench will be treated as per the Project ESCP prior to release or disposal. Spillages will be managed and controlled within the site. Spill risk will be managed through structural and procedural controls. In the event that these controls fail, management will be by way of adherence to the procedures outlined in this ESRP.

3.0

Hazardous Substances and Spill Response Procedures

Safety Data Sheets for all hazardous substances associated with the Project construction works are held at the site office. These will be consulted to determine the appropriate course of action to take in an emergency situation, e.g. spillage. Spill kits and associated equipment, are located at each vehicle entrance to the site as shown on the attached stage plans.

4.0

Key Contacts

Key Project contacts in the event of a spill or release of EHS are listed below: Role

Responsibilities

• Project Director – Francois Dudouit • Deputy Project Director – Dale Burtenshaw

• Construction Manager – Philippe Begou

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• Overseeing project planning, acquisition, design, constructability, procurement, stakeholder engagement, communications, programme and financial control. • Providing strategic direction to all workstreams to provide an integrated approach to project delivery. • Ultimate responsibility for compliance with resource consent and designation conditions. • Ultimate responsibility for achieving the sustainability outcomes.


Industrial and Trade Activities Environmental Management Plan

Role

Responsibilities

• Mt Eden Station Project Manager – Thibaut L’Hopital • Mt Eden Station Construction Manager – Dave Harris

• Link Alliance Communications and Engagement Manager – Rachel Blundell

• Overseeing the Mt Eden Enabling Works construction delivery. • Ensuring site personnel adhere to the CEMP and sub-plans and comply with environmental operating procedures. • Ensuring site personnel adhere to the project communication protocols and procedures. • Development, management and monitoring of Construction Execution Procedures (CEPs), including the integration of environmental and sustainability requirements. • Providing project progress/milestone information for stakeholder briefings (e.g. CLG, Mana Whenua Forum). • Coordinates emergency responses, along with the ESM. • Manages a Communications and Engagement team that is the main and readily accessible point of contact for stakeholders and persons affected by the works. • Implementation of Link Alliance Communications for the Mt Eden Enabling Works and responsible for communicating key aspects of the works to stakeholders, affected parties and the general public including: Informing the community / key stakeholders of the project, construction milestones, programme and progress. Notifying project neighbours / key stakeholders of project works that may affect them and regular liaison with the affected community. • Primary contact for project related complaints and enquiries. • Managing stakeholder enquiries and working with relevant team members to resolve complaints. • Immediately reporting any high-risk stakeholder / communication issues to the Mt Eden Station Project Manager and the CRLL GM Corporate Relations and Communications. • Assisting the CRLL Communications team with key stakeholder engagement including the Mana Whenua Forum and Local Boards. • Providing advice to the Mt Eden Station Project Manager / Construction Manager on critical stakeholder engagement, communications and relationship building. • Co-ordination of Mt Eden CLG meetings. • Assisting the Mt Eden Station Construction Manager in briefing site personnel on: - The mandatory site inductions regarding the standards and requirements for community relations; - Procedures to follow if staff are approached by a member of the public or the media; and - Behavioural procedures in and around the construction site boundaries.

• Environmental and Sustainability Manager (ESM) – Sarah Sutherland

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• Providing leadership to the Alliance team to achieve project environmental objectives and outcomes. • Undertaking regular site inspections, auditing and checking of environmental management practices and procedures/compliance with the CEMP, sub-plans and resource consent and designation conditions. • Tracking compliance information. • Coordinating environmental interfaces with consultants, subcontractors and suppliers.


Industrial and Trade Activities Environmental Management Plan

Role

Responsibilities

• Project and Site Engineers

• All Staff (including subcontractors)

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• Submitting relevant reporting and records to Auckland Council. • Attending compliance meetings with Auckland Council Compliance and Monitoring Officers. • Reporting any changes to construction techniques or environmental changes which may require changes to existing / new planning approvals. • Reviewing and updating CEMP and relevant sub-plans during works (at least annually). • Updating and maintaining the environmental portion of the project Risk Register. • Coordinating environmental monitoring as per the CEMP and sub-plans. • Training staff (including subcontractors) on environmental and sustainability aspects. • Reporting on the project environmental and sustainability KPIs. • Coordinating the interfaces and communications with external agencies and stakeholders in relation to environmental management on the project in conjunction with the Communication and Engagement Manager. • Coordinating environmental emergency / incident responses and undertaking incident investigations. • Informing the Project Director/Mt Eden Station Project Manager of environmental or sustainability non-compliances. • Resolving environmental non-compliances. • Ensuring staff are handling hazardous substances as per the Safety Data Sheets, are trained appropriately and are handling and storing hazardous substances appropriately. • Is an IS Accredited Professional. • Supervising subcontractors. • Undertaking daily site inspections and environmental monitoring. • Ensuring environmental erosion and sediment control works are installed and maintained. • Ensuring all staff are aware of environmental requirements and management measures are implemented and maintained to ensure ongoing effectiveness. • Adherence to the CEMP and sub-plans. • Attending tool-box talks and environmental training (including becoming familiar with the requirements of the CEMP and sub-plans, as directed by the ESM). • Reporting environmental incidents, complaints, defects and any other problems to senior staff. • Ensuring that environmental management processes and procedures are followed and mitigation/protection measures are maintained and working correctly. • Ensuring that the site and adjacent areas are protected and respected (litter placed in bins, site kept tidy). • Direct all public and media enquiries to the Communications and Engagement Manager. • Use approved haul routes, site access and designated site parking (if available) to minimise disruption to the local community. • Work within approved construction hours. • Work within the conditions specified in the Permits to Notify (refer CCP for further detail).


Industrial and Trade Activities Environmental Management Plan

Role

Responsibilities • Show consideration for stakeholders and community members at all times.

5.0

Key emergency services

Key emergency services to be contacted in the event of a spill or release of EHS are listed below: Emergency Service

Role/Responsibility

Phone Number

Auckland Council Pollution Hotline

Spills to stormwater systems

(09) 377 310

Watercare Services

Spills to stormwater/sewage systems

(09) 442 2222

Police

Traffic Control Evacuation Crowd Control Investigation of Fatalities

111

Ambulance

Treat Injured Transport Injured

111

Fire Service

Fight Fires Contain Spillage Rescue

111

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Industrial and Trade Activities Environmental Management Plan

Emergency Spill and Runoff Response Are you able to safely deal with the spill?

NO

YES YES

1.

BE SAFE:

Determine type of protective equipment required from SDS and use it – isolate

YES

2. STOP the SOURCE: Plug leak – right or reposition containers – turn off taps, valves or pumps

3. CONTAIN SPILT PRODUCT: Cover Sumps (drain covers, sandbags or booms) Close Interceptors Block stormwater drains (sandbags, temporary bunds or drain covers)

4. NOTIFY Immediately: Your Supervisor

and Auckland Council (09 377 3107) if greater than 20L or likely to enter stormwater drains

ASSESS EXTENT OF SPILL, if required notify Fire 111 Police 111 Advise neighbours (where applicable).

5. CLEAN UP:

Only if trained and proper equipment is available Do NOT wash away with water into drains, use materials in spill kit,

6. DISPOSE Properly: Safely collect and dispose of contaminated absorbents and clean up gear by licensed contractor (e.g. ChemWaste)

7. REORDER and REVIEW: Replace all used spill kits materials and absorbents immediately document/record incident - investigate cause of spill - take action to prevent

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Evacuate area and call Fire Service 111


Industrial and Trade Activities Environmental Management Plan

Appendix C: Record of CLG and Auckland Council Comments C1. CLG Comments A Mt Eden CLG meeting was held on 8 October to discuss the Mt Eden Enabling Works and for the CLG to provide comments / feedback on the CEMP and sub-plans, including this ITA EMP. No comments were received from the CLG on this ITA EMP.

C2. Auckland Council Comments The ITA EMP was reviewed by the Leon Blackburn. He provided the following comments on the ITA EMP: Section of this ITA EMP

Comment

Response

Overall

Clarification that the ITA EMP only applied to CSA 4

Confirmed scope of ITA EMP covers CSA 4 for the Mt Eden Enabling Works only.

Section 7.2

Insert timings from Condition 177 into management plan for reminder

Added “Within eight weeks following the start of the monitoring� to initial reporting requirement statement.

Appendix A

Queried whether more recent monitoring data for the receiving water environment

Reference updated to reflect most recent available monitoring data at Motions Creek.

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Appendix D: Register of Plan Updates Annual review 20XX Updates Updates have been made to the following sections:

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Date


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