Kppers Carbn Materials and Chemicals Pllutin Incident Respnse Management Plan 1. Backgrund Kppers Carbn Materials and Chemicals (KCMC) is required t prepare and implement a Pllutin Incident Respnse Management Plan (PIRMP) under the Prtectin f the Envirnment Legislatin Amendment Act 2011 (POELA Act). 2. Definitin Pllutin Incident and Material Harm t the Envirnment The PIRMP must be implemented in the event f a Pllutin Incident that causes r threatens material harm t the envirnment. A Pllutin Incident is defined under the Prtectin f the Envirnment Operatins Act (POEO Act) as fllws: pllutin incident means an incident r set f circumstances during r as a cnsequence f which there is r is likely t be a leak, spill r ther escape r depsit f a substance, as a result f which pllutin has ccurred, is ccurring r is likely t ccur. It includes an incident r set f circumstances in which a substance has been placed r dispsed f n premises, but it des nt include an incident r set f circumstances invlving nly the emissin f any nise. A pllutin incident is required t be ntified if there is a risk f material harm t the envirnment, which is defined in sectin 147 f the POEO Act as: (a) harm t the envirnment is material if: (i) it invlves actual r ptential harm t the health r safety f human beings r t ecsystems that is nt trivial, r (ii) it results in actual r ptential lss r prperty damage f an amunt, r amunts in aggregate, exceeding $10,000 (r such ther amunt as is prescribed by the regulatins), and (b) lss includes the reasnable csts and expenses that wuld be incurred in taking all reasnable and practicable measures t prevent, mitigate r make gd harm t the envirnment. The relevant infrmatin abut a pllutin incident required t be reprted cnsists f the fllwing: 1. The time, date, nature, duratin and lcatin f the incident 2. The lcatin f the place where pllutin is ccurring r is likely t ccur 3. The nature, the estimated quantity r vlume and the cncentratin f any pllutants invlved. 4. The circumstances in which the incident ccurred (including the cause f the incident, if knwn). 5. The actin taken r prpsed t be taken t deal with the incident and any resulting pllutin r threatened pllutin Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 1 f 11
If the infrmatin required by items (3) t (5) becmes knwn after the initial ntificatin is made, that infrmatin must be prvided t the authrities immediately after it becmes knwn. 3. Descriptin and Likelihd f hazards {POEO (G) Regulatin clause 98C(1)(a) and (b)}, and Pre-emptive actins t prevent r minimise risk {clause 98C(1)(c) The main hazards t human health r the envirnment assciated with activities undertaken at KCMC premises are: Serius Fire Emergency The KCMC site cntains many flammable and cmbustible liquids, flammable gases, and flammable slids. Emergency prcedures t deal with a Serius Fire Emergency are recrded in sectin 2 f the KCMC Emergency Prcedures flder, a cpy f which is under each site telephne. Pre-emptive actins t cntrl the risk f fire include : Nitrgen blanketing f certain strage tanks (identified by Risk Assessment) t prvide an inert atmsphere. Temperature measurement f key fume mains t identify temperature increases that may indicate the beginning f a fire. Ht wrk plicies and restrictins t manage ptential ignitin surces. Distillatin Unit shutdwn and wash dwn prcedures t remve flammable material befre allwing units t be pened and expsed t xygen in the atmsphere. Apprpriate design and selectin f electrical equipment t minimise ignitin surces. Earth Straps installed, used, and tested/maintained t manage static electricity when lading vehicles and minimise ignitin surces. Standard Operating Prcedures fr key activities n site, with cntrls t prevent prduct spillage (fuel surce) and ignitin surces. In the event f a majr fire, the fllwing risks are present: Harm t peple n the site frm heat/fire. Pre-emptive actins t prevent(minimise) this risk include: Autmatic deluge fire systems in distillatin areas. Ring Main and hydrants lcated strategically arund the plant t prvide water fr fire fighting. Regular testing and maintenance f fire prtectin systems and alarms. Apprpriate training fr emplyees (see sectin 10 f this plan). Apprpriate cntractr inductin infrmatin. Apprpriate emergency exercises / evacuatin drills. Harm t peple n and ff site due t expsure t stred chemicals, smke, r cmbustin prducts. Pre-emptive actins t prevent(minimise) this risk include: Apprpriate training fr emplyees (see sectin 10 f this plan). Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 2 f 11
Half face respiratrs issued t each emplyee suitable t filter ut smke particles and hydrcarbns. Inventry f Pllutants available fr Fire / Hazmat persnnel (see sectin 4 f this plan) Cmmunicatin plan in place fr ntifying immediate neighburs, cmmunity and relevant authrities (see sectin 7 f this plan). A barricade is t be set up n the radway utside the plant t prevent unauthrised peple frm entering the area. Air pllutin due t smke and cmbustin prducts. Water pllutin due t cntaminated fire fighting water entering strmwater. Preemptive actins t prevent (minimise) this risk include: Strage tanks cntained in bunded areas. Fire fighting water used in these areas will be caught in the bund and nt flw t strmwater. First Flush sump system utside bunded areas. The initial water landing utside a bunded area is caught in a first flush sump system. This allws time fr water flwing dwn radways and int drains t be diverted and reduce the risk f strmwater cntaminatin. Emergency Prcedures include fire water cntrl and strmwater prtectin measures. Serius Explsin Emergency The KCMC site cntains many flammable and cmbustible liquids, flammable gases, and flammable slids. Emergency prcedures t deal with a Serius Explsin Emergency are recrded in sectin 3 f the KCMC Emergency Prcedures flder, a cpy f which is under each site telephne. Pre-emptive actins t cntrl the risk f explsin include : Nitrgen blanketing f certain strage tanks (identified by Risk Assessment) t prvide an inert atmsphere. Ht wrk plicies and restrictins t manage ptential ignitin surces. Distillatin Unit shutdwn and wash dwn prcedures t remve flammable material befre allwing units t be pened and expsed t xygen in the atmsphere. Apprpriate design and selectin f electrical equipment t minimise ignitin surces. Earth Straps installed, used, and tested/maintained t manage static electricity when lading vehicles and minimise ignitin surces. Standard Operating Prcedures fr key activities n site, with cntrls t prevent prduct spillage (fuel surce) and ignitin surces. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 3 f 11
In the event f an explsin, the fllwing risks are present: Harm t peple n the site. Pre-emptive actins t prevent(minimise) this risk include: Apprpriate training fr emplyees (see sectin 10 f this plan). Apprpriate cntractr inductin infrmatin. Apprpriate emergency exercises / evacuatin drills. Harm t peple n and ff site due t expsure t stred chemicals, smke, r cmbustin prducts. Pre-emptive actins t prevent(minimise) this risk include: Apprpriate training fr emplyees (see sectin 10 f this plan). Half face respiratrs issued t each emplyee suitable t filter ut smke particles and hydrcarbns. Inventry f Pllutants available fr Fire / Hazmat persnnel (see sectin 4 f this plan) Cmmunicatin plan in place fr ntifying immediate neighburs, cmmunity and relevant authrities (see sectin 7 f this plan). A barricade is t be set up n the radway utside the plant t prevent unauthrised peple frm entering the area. Air pllutin due t smke and cmbustin prducts. Water pllutin due t bunds r strage tanks being damaged and prducts entering strmwater. Pre-emptive actins t prevent (minimise) this risk include: Strage tanks cntained in bunded areas. If strage tanks are damaged, prducts spilled in these areas will be caught in the bund and nt flw t strmwater. First Flush sump system utside bunded areas. The first quantity f prduct spilled utside a bunded area will be retained in a first flush sump system. This allws time fr material flwing dwn radways and int drains t be diverted and reduce the risk f strmwater cntaminatin. Emergency Prcedures include fire water cntrl and strmwater prtectin measures. Serius Gas Leak The KCMC site cntains piped Natural Gas. Emergency prcedures t deal with a Serius Gas Leak are recrded in sectin 3 f the KCMC Emergency Prcedures flder, a cpy f which is under each site telephne. Pre-emptive actins t cntrl the risk f gas leaks include : Islatin valve t shut ff gas supply lcated in the bilerhuse (near cntrl rm) fr quick respnse. Islatin valve t shut ff gas supply lcated at feeder statin, utside main gate, n Wdstck St, fr access if the site has been evacuated. In the event f serius gas leak, the fllwing risks are present: Fire (see previus sectin cntrl measures) Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 4 f 11
Explsin (see previus sectin cntrl measures) Harm t peple n and ff site due t gas expsure. Pre-emptive actins t prevent(minimise) this risk include: Apprpriate training fr emplyees (see sectin 10 f this plan). Cmmunicatin plan in place fr ntifying immediate neighburs, cmmunity and relevant authrities (see sectin 7 f this plan). A barricade is t be set up n the radway utside the plant t prevent unauthrised peple frm entering the area. Serius Prduct Release r Spillage n Site The KCMC site cntains many flammable and cmbustible liquids, flammable gases, and flammable slids. Emergency prcedures t deal with a Serius Prduct Spillage are recrded in sectin 5 f the KCMC Emergency Prcedures flder, a cpy f which is under each site telephne. Pre-emptive actins t cntrl the risk f serius prduct spillage include : Maintenance f plant and equipment t minimise the risk f equipment failure leading t serius prduct spillage. Apprpriate design and material selectin fr plant and equipment t minimise the risk f equipment failure. Standard Operating Prcedures fr key activities n site, with cntrls t prevent prduct spillage (fuel surce) and ignitin surces. In the event f a serius prduct spill n site, the fllwing risks are present: Fire (see previus sectin cntrl measures) Explsin (see previus sectin cntrl measures) Harm t peple n and ff site due t expsure t chemicals and prducts. Preemptive actins t prevent(minimise) this risk include: Half face respiratrs issued t each emplyee suitable t filter ut hydrcarbn prducts. Inventry f Pllutants available fr Fire / Hazmat persnnel (see sectin 4 f this plan). Apprpriate training fr emplyees (see sectin 10 f this plan). Cmmunicatin plan in place fr ntifying immediate neighburs, cmmunity, and relevant agencies (see sectin 7 f this plan). A barricade is t be set up n the radway utside the plant t prevent unauthrised peple frm entering the area. Air pllutin due t fumes r chemical vapurs. Water pllutin due t prducts r chemicals entering strmwater. Pre-emptive actins t prevent (minimise) this risk include: Strage tanks cntained in bunded areas. Prducts and chemicals spilled in these areas will be caught in the bund and nt flw t strmwater. First Flush sump system utside bunded areas. The first quantity f prduct spilled utside a bunded area will be retained in a first flush sump system. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 5 f 11
This allws time fr material flwing dwn radways and int drains t be diverted and reduce the risk f strmwater cntaminatin. Emergency Prcedures include strmwater prtectin measures. KCMC als maintains an Aspects and Impacts register which examines the risks assciated with specific activities n site, and details specific cntrl measures t deal with thse envirnmental risks. This Aspects and Impacts register is linked with Operatins Standard Operating Prcedure. Each Operatins SOP includes Safety and Envirnmental ntes and cntrl measures. 4. Inventry f Pllutants {POEO (G) Regulatin clause 98C(1)(d) and (e)} The inventry f pllutants is kept at Muster Pint 2 fr easy access by HAZMAT r ther emergency services. A cpy f the map is lcated in the supervisrs ffice, alng with MSDS flders cntaining infrmatin n all Kppers prducts as well as ther chemicals n site. 5. Safety Equipment {POEO (G) Regulatin clause 98C(1)(f)} Safety Equipment used t minimise the risks t human health r the envirnment r cntrl a pllutin incident include: Fire Extinguishers List f types, lcatins, and inspectin frequency as per Engineering and Maintenance Manual. Office Fire Detectin and Alarm System. Fire Deluge system details and inspectin/maintenance frequency as per Engineering and Maintenance Manual. Fire Ring Main, Hydrant and Hses, details and inspectin/maintenance frequency as per Engineering and Maintenance Manual. Spill Kits, Cntents, Lcatin, and inspectin frequency as per Engineering and Maintenance Manual. Gas Mnitrs, persnal and fixed naphthalene distillatin building mnitrs. Maintenance frequency as per Engineering and Maintenance Manual. First Aid Rm, First Aid Kits, restcking frequency and lcatins recrded by Supt Operatins. First Flush Sump system. Managed as per Standard Operating Prcedures. Persnal Prtective Equipment Safety Glasses, Respiratr, Lng Sleeved High Visibility Shirt, Lng Pants, Steel Capped enclsed ftwear, Safety Hat, Hearing Prtectin (ear plugs and ear muffs), glves. 6. Cntact Details {POEO (G) Regulatin clause 98C(1)(g) and (h)} Cntact details, including names, psitin titles, and 24 hur cntact details f key individuals respnsible fr activating this plan and managing the respnse t a pllutin incident are listed in sectin 11 f the KCMC Emergency Prcedures flder. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 6 f 11
This sectin f the emergency prcedures als includes the ntificatin details fr all 5 relevant authrities required under Sectin 148 f the POEO Act. These numbers are t be used in cnjunctin with the EPA ntificatin prtcl belw: Firstly, call 000 if the incident presents an immediate threat t human health r prperty. Fire and Rescue NSW, the NSW Plice and the NSW Ambulance Service are the first respnders, as they are respnsible fr cntrlling and cntaining incidents. If the incident des nt require an initial cmbat agency, r nce the 000 call has been made, ntify the relevant authrities in the fllwing rder. The 24-hur htline fr each authrity is given when available: EPA Envirnment Line 131 555 The Ministry f Health via the lcal Public Health Unit call Jhn Hunter Hspital, 4924 6477 the WrkCver Authrity phne 13 10 50 Newcastle City Cuncil 4974 2000 Fire and Rescue NSW phne 000. In a pllutin incident, the emergency respnse cntrller n site will take immediate steps t prtect safety and the envirnment, then will ntify (r delegate anther persn n site t ntify) Nick Mretti, Rbert Witherspn, r Shane Beasley. This persn will then have the respnsibility f making the required calls fr immediately ntifying the authrities as listed abve. The purpse f this is t ntify the authrities withut delay, while still allwing the emergency respnse cntrller t take necessary steps t bring the situatin under cntrl and minimise the impact f the incident. If nne f the peple nminated are immediately available, the emergency respnse cntrller must either ntify the authrities persnally straight away r delegate t anther persn n site t ntify the authrities withut delay. 7. Cmmunicating with neighburs and the lcal cmmunity {POEO (G) Regulatin clause 98C(1)(i)} In the event f a pllutin incident that meets the definitin f causing r threatening material harm t the envirnment, KCMC must cmmunicate with neighburs and the lcal cmmunity t infrm them abut the incident and give specific infrmatin that can minimise the risk f harm. If there is an immediate danger t life and health, the lcal cmbat agency (likely t be NSW Fire Brigade, HAZMAT Unit) in cnjunctin with ther emergency persnnel will c-rdinate necessary cmmunicatin with r evacuatin f the affected area. Plice Emergency Services have access t "Emergency Alert" which is an SMS based alert system, amngst ther means f cmmunicatin. Neighburing businesses in clse prximity t the site will be ntified by email and/r phne call and/r SMS abut the incident. The list f neighburing businesses and their cntact details is recrded in Sectin 11 f the KCMC Emergency Prcedures flder. This will be carried ut by either the management representative respnsible fr ntifying the authrities, r anther persn delegated t d this task, withut delay after ntifying the authrities. Sensitive cmmunity lcatins in reasnable prximity t the site will als be ntified by email and/r phne call and/r SMS abut the incident. This grup includes schls, child care centres, and nursing hmes / Aged Care facilities. The list f sensitive cmmunity lcatins and their cntact Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 7 f 11
details is recrded in Sectin 11 f the KCMC Emergency Prcedures flder. This will be carried ut by either the management representative respnsible fr ntifying the authrities, r anther persn delegated t d this task, withut delay after ntifying the authrities. Infrmatin abut any incident will als be accessible frm the KCMC website and updated withut delay. 8. Minimising harm t persns n the premises {POEO (G) Regulatin clause 98C(1)(j)} and Actins t be taken during r immediately after a pllutin incident {POEO (G) Regulatin clause 98C(1)(l)} KCMC Emergency Prcedures (lcated under each telephne n the plant) describe actins t be taken during r immediately after a pllutin incident (including actins t minimise harm t persns n the premises). This includes an evacuatin prcedure and emergency respnse sectin (sectin 12) cntaining a site map with muster pints shwn. The evacuatin prcedure is included in cntractr and emplyee inductins, and a cpy f the prcedure is given t all inductees. KCMC has at least ne first aid trained emplyee n site at all times. The site is fitted with emergency / evacuatin alarms t ntify peple t g t muster pints n site. The site is securely fenced, and a barricade will be set up n the rad befre the plant t ensure that unauthrised peple d nt access the area and put themselves at risk. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 8 f 11
9. Maps {POEO (G) Regulatin clause 98C(1)(k)} A map f the premises including the lcatin f ptential pllutants and strmwater drains is kept at Muster Pint 2 fr easy access by HAZMAT r ther emergency services. A cpy f the map is lcated in the supervisr s ffice. Fr security reasns this is nt included in the public versin f the PIRMP. KCMC Site 10.Staff Training {POEO (G) Regulatin clause 98C(1)(m)} KCMC shall ensure that all emplyees receive suitable envirnmental training, and are aware f their respnsibilities under the POEO and POELA Acts and regulatins. This will be dne by a cmbinatin f the fllwing : Desktp emergency respnse exercises including pllutin incidents with emergency respnse cntrllers twice per calendar year. Safety, Health and Envirnment Meetings. Tlbx meetings. Tlbx talks. Accredited training curses fr relevant emplyees. Evacuatin and emergency respnse drills. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 9 f 11
Standard Operating Prcedure nging training and awareness. Emplyee and cntractr inductin including Envirnmental Plicy Site Envirnmental and Safety Rules Incident reprting Site Safety and Envirnmental Hazards and cntrl measures Emergency Respnse and Evacuatin Plans Each year a training prgram will be apprved by KCMC management and implemented t ensure that emplyees receive necessary training. Curses that may be part f the training prgram in any particular year include: Fire Warden / Emergency Respnse Cntrller Basic Fire Fighting First Aid Cnfined Space Manual Handling Electrical Safety (als High Vltage awareness and Lw Vltage Rescue and Release) Hazard Identificatin and Risk Assessment Alchl and Other Drugs Mbile Equipment High Risk Wrk (eg Frklift, EWP) Biler training Dangerus Gds (Rad and IMDG) Cde f Cnduct Safety Health and Env. Management System Internal Auditing Persnnel perfrming tasks that can cause significant envirnmental impacts shall be cmpetent n the basis f apprpriate educatin, training, and/r experience. 11.Making Plans Available {POEO (G) Regulatin clause 98D} A full cpy f this plan is maintained n the KCMC main site (ff Wdstck St, Mayfield). Relevant sectins f this plan are lcated with Emergency Respnse flders at the T-661 cmpund n the ld BHP Steelwrks site and at #6 Berth n the ld BHP Steelwrks site. Sectins f this plan are publicly available in a prminent psitin n Kppers publicly accessible website. These sectins include the prcedures fr ntifying the relevant authrities and cmmunicating with the cmmunity. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 10 f 11
12. Testing Plans {POEO (G) Regulatin clauses 98C (1)(n), () and (p), 98C(2)(f) and (g), (98E(1) and 98E(2) } This plan will be part f KCMC cntrlled dcument system, with a review date f every 12 mnths. As such it is t be checked fr accuracy and currency and re-issued every 12 mnths. Recrds f reviews and superseded versins will be managed as part f the cntrlled dcument system. This plan is included in KCMC Internal Audit prgram, t be audited every 12 mnths (at a different time than the fficial review perid). Findings r discrepancies will be recrded and managed as part f the internal audit crrective actin prgram. Desktp emergency respnse exercises including pllutin incident management using the PIRMP will be carried ut with emergency respnse cntrllers twice per calendar year. Plans will als be tested within ne mnth f any pllutin incident ccurring. Reviewed Date: 20/8/12 Next Review Date: 20/8/13 Page 11 f 11