Environmental Management Plan - NSW - Georgiou
Transcript of Environmental Management Plan - NSW - Georgiou
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CONSTRUCTION ENVIRONMENTAL
MANAGEMENT PLAN
Site Details
Client Sydney Metro
Site Name Bays Road Relocation Works
Project Number 6119
ID Code 6119-ENV-MP-001
2020 Georgiou Group Pty Ltd
Reproduction of this document in whole or in part in any format or media is prohibited without express permission from the authorised Quality Representative of Georgiou
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Revision Date Revision Details Environmental Representative
Project Manager
A 81020 Draft for review Chloe Redman Brad Collins
B 21120 Sydney Metro 1st review Chloe Redman Brad Collins
C 101120 Sydney Metro 2nd review Chloe Redman Brad Collins
D 161120 Sydney Metro 3rd Review Chloe Redman Brad Collins
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TABLE OF CONTENTS
GLOSSARY ABBREVIATIONS 6
1 INTRODUCTION AND PURPOSE 8
Amendments and Authorisation 8
Communication of this Plan 8
Supporting Management Plans 8
2 SCOPE OF WORKS 9
3 LOCATION 9
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW 10
Environmental Management System 10
Policy 11
Environmental Management Plan 11
5 LEGAL AND OTHER OBLIGATIONS 12
General 12
Contractual Environmental Requirements 15
REF Determination Conditions of Approval 17
Environmental Licences and Permits 19
Infringement Improvement and Prohibition Notices 20
Availability of Statutory and Other Information 20
Objectives amp Targets 20
6 STRUCTURE AND RESPONSIBILITIES 21
Organisational Structure 21
Roles and Responsibilities and Authority 21
Communication and Acceptance of Accountabilities and Responsibilities 23
Field Leadership Visits 23
7 COMMUNICATION AND CONSULTATION 24
Internal Communication and Consultation 24
711 Inductions 24
712 HSE Notice Boards 25
713 HSE Alerts Bulletins 25
714 Site Meetings 25
Community and Stakeholder Involvement 25
721 Complaints Management 26
722 Urban Design of temporary works 26
723 Business and Property Impacts 27
8 HAZARD IDENTIFICATION AND RISK CONTROL 27
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Hierarchy of Control 27
Site Environmental Risk Analysis 28
Review of Risks 28
831 Change Management 28
Operational Control 28
841 Environmental Hazard Reporting 28
842 Take 5 29
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS) 29
844 Permit to Work 29
845 Environmental Control Maps 29
9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT 30
10 CLOSURE AND COMMISSIONING 30
11 TRAINING COMPETENCY AND RESOURCING 30
1111 Toolbox talks 30
1112 Recording of Training and Assessment 31
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE 31
EmergencyIncident Planning and Control 31
13 HSE REPORTING AND INVESTIGATION 31
Notifications and Reporting 31
1311 Internal 31
1312 Notification of Incidents to Sydney Metro 31
1313 Statutory Notifications 31
Investigations 32
Review and Communication of Incidents 32
14 ENVIRONMENTAL REPORTING 32
1411 Monthly Reports 32
Site Meetings 32
Project Performance Review 33
15 AUDITING REVIEWS AND INSPECTIONS 33
Inspections 33
1511 Environmental Inspections 33
Audits and Reviews 33
Monitoring 34
Corrective Actions 34
16 DOCUMENT AND RECORD CONTROL 34
17 APPENDICES 35
Appendix 1 - Waste Management Sub Plan 36
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Appendix 1A ndash Sydney Metro Waste Classification Procedure 42
Appendix 2- Soil and Water Management Sub Plan 43
Appendix 3- Hydrocarbon and Chemical Management Sub Plan 46
Appendix 4 - Flora amp Fauna Management Sub Plan 50
Appendix 5 - Cultural Heritage Management Sub Plan 53
Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure 55
Appendix 5B ndash Sydney Metro Exhumation Management Procedure 56
Appendix 6 - Air Quality amp Dust Management Sub Plan 57
Appendix 7- Noise Vibration and Light spill Management Sub Plan 59
Appendix 7A ndash Sydney Metro Out of Hours Application form 61
Appendix 8 ndash Contaminated Land Management Sub Plan 62
Appendix 8A ndash Unexpected Contamination finds procedure 67
Appendix 8B ndash Unexpected Asbestos finds procedure 71
Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure 78
Appendix 10 ndash Sydney Metro Environmental Inspection template 79
Appendix 11 ndash Georgiou Environmental Policy 80
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GLOSSARY ABBREVIATIONS
Term Expanded text
AFMP Ancillary Facilities Management Plan
BC Act Biodiversity Conservation Act 2016
CoA Condition of approval
Compliance audit Verification of how implementation is proceeding with respect to an CEMP (which incorporates the relevant approval conditions)
CPESC Certified practising erosion and sediment control professional
CRM Community Relations Manager
CPESC Certified practising erosion and sediment control professional
CSSI Critical State Significant Infrastructure
DEC Department of Environment and Conservation (NSW) (former)
DIPNR Department of Infrastructure Planning and Natural Resources (former)
DoEE Commonwealth Department of the Environment and Energy
DoI - Water NSW Department of Industry - Water
DPIE NSW Department of Planning Industry and Environment
Ecologically sustainable development (ESD)
Using conserving and enhancing the communityrsquos resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future can be increased (Council of Australian Governments 1992)
EIS Environmental Impact Statement
EMS Environmental Management System
Environmental aspect
Defined by ASNZS ISO 140012015 as an element of an organisationrsquos activities products or services that can interact with the environment
Environmental impact
Defined by ASNZS ISO 140012015 as any change to the environment whether adverse or beneficial wholly or partially resulting from an organisationrsquos environmental aspects
Environmental incident
An unexpected event that has or has the potential to cause harm to the environment and requires some action to minimise the impact or restore the environment
Environmental objective
Defined by ASNZS ISO 140012015 as an overall environmental goal consistent with the environmental policy that an organisation sets itself to achieve
Environmental policy
Statement by an organisation of its intention and principles for environmental performance
Environmental target
Defined by ASNZS ISO 140012015 as a detailed performance requirement applicable to the organisation or parts thereof that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives
EPA NSW Environment Protection Authority
EPampA Act NSW Environmental Planning and Assessment Act 1979
EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999
EPL NSW Environment Protection Licence under the Protection of the Environment Operations Act 1997
ERG Environmental Review Group
ESCP Erosion and Sediment Control Plan
EWMS Environmental Work Method Statement
Federal-CoA Condition of the Federal Department of the Environment and Energy Approval Decision
Hold point Is a verification point that prevents work from commencing prior to approval
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LGA Local Government Area
MNES Matters of National Environmental Significance
Non-compliance Failure to comply with the requirements of the Project approval or any applicable licence permit or legal requirements
NSW-CoA Condition of the NSW DPampE Infrastructure Approval
OEH NSW Office of Environment and Heritage
OOHW Out of hours work
PIRMP Pollution Incident Response Management Plan
POEO Act Protection of the Environment Operations Act 1997 (NSW)
RAP Registered Aboriginal Party
RBL Rating background level
REF Review of Environmental Factors
ROL Road occupancy licence
SAP Sensitive Area Plan
SEPP State Environmental Planning Policy
UXO Unexploded Ordnance
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1 INTRODUCTION AND PURPOSE
The purpose of this Construction Environmental Management Plan (CEMP) is to describe how environmental aspects
are to be managed so that the site and those engaged onsite will
Comply with Georgiou Policy Client legal and other obligations
Minimise the impacts on the environment
Achieve the Company client and site objectives and targets
implement mitigation measures identified and assessed through Review of Environmental Factors (REF) under
Part 5 of the EPampA Act
Comply with the requirements of the Construction Environmental Management Framework (CEMF) February
2020 version 41 Managing Contractor Contract (MCC) Works Brief licencing and other relevant documents
This Management Plan is written in accordance with Georgioursquos health safety and environment management
system that is 3rd party certified to ASNZS ISO 14001 It has been written in accordance with the Transport for
New South Wales (TfNSW) Sydney Metro Construction Environmental Management Framework (CEMF) and the
project specific Sydney Metro General Specification ndash Plans and Reporting
Amendments and Authorisation
This Management Plan will be approved by the Project Manager their Line Manager and a Representative from the
HSE Department This Management Plan and other related documents will be reviewed annually or as a result of
Changes to Company procedures or processes
Changes to key personnel or resources
Changes in legal and other obligations
Findings from an audit or inspection
Findings from a significant incident or near miss
Significant changes to site conditions andor work methods
Instructions from Sydney Metro
Reviews will be undertaken in consultation with key stakeholders to ensure all locationsfunctions are considered
A record of the date and comments relating to any revisions of this document will be included in the revision table
The only Georgiou authorisation required to amend this document after initial approval is the Project Managerrsquos
Communication of this Plan
The Project Manager is accountable for ensuring
Location and access to the management plans is communicated at induction Management Plans have been communicated to subcontractor personnel prior to commencement of works
onsite Any changes made to the management plan are communicated to affected persons on the site
Supporting Management Plans
The following management plans have been developed to support this management plan
Emergency Response and Preparedness Plan
Georgiou Crisis Management Plan (controlled by Georgioursquos Perth Head Office and available on Company Intranet)
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2 SCOPE OF WORKS
Sydney Metro is proposing to configure the internal port road network at Rozelle to facilitate the orderly urban
renewal of the Bays West area while maintaining access to the White Bay Cruise Terminal and other port operations
at Glebe Island and White Bay This includes long-term urban renewal initiatives for the Bays West area and works
for various future developments within the locality including critical works for the proposed Sydney Metro West
The proposal also provides the opportunity to improve road safety by reducing conflicting traffic movements in the
internal port road network
Georgioursquos scope of works is described as lsquoPhase 1rsquo works in the REF and it comprises of the following key
features
A reconfigured intersection at Port Access Road Solomons Way Sommerville Road including an interim
connection with the existing Port Access Road until it is relocated (as part of Phase 2)
Establishment of one-way traffic circulation along Solomons Way and Sommerville Road around the Glebe Island
Silos
Relocation of the Cement Australia Truck Parking Licenced Area to the north prior to the construction of the
reconfigured intersection due to the direct conflict with the reconfigured intersection
3 LOCATION
The proposal is located in an established industrial and port context at Rozelle within the Inner West Council local
government area
The lsquoproposal sitersquo refers to the area that would be directly impacted by the proposal as shown in Figure 1-1 The
proposal site is largely disused with the exception of the Port Access Road and port related lease areas including a
Cement Australia Truck Parking Licenced Area to service Cement Australiarsquos operations at the Glebe Island Silos
The proposal site is under the ownership of the Port Authority of NSW
To the north of the proposal site is the existing Port Access Road that supports access to the White Bay Cruise
Terminal and other port operations at White Bay To the east of the site is the existing Cement Australia and Sugar
Australia Glebe Island Silos and the Gypsum Resources Australia facility The south-eastern border of the site is
vegetated land adjoining Victoria Road Western Distributor The proposed location for the relocated Cement
Australia Truck Parking Licenced Area is currently a hardstand laydown area used by Port Authority of NSW
Beyond the proposal site the wider locality features a mix of land uses including retail commercial and urban
services along Robert Street to the north port and maritime uses to the east (Glebe Island and White Bay) and to
the south and City West Link Road and residential dwellings to the west in Rozelle
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Figure 3-1 Site location
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW
The following documents provide further information in regards to this topic
Management System Standard
Environmental Management System
The CEMP has been prepared in accordance with the overarching environmental management system (EMS) as
detailed below
Georgiou has a certified EMS consistent with ASNZS ISO 14001 Environmental Management Systems and will
prepare CEMPs in accordance with this EMS
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Policy
This Management Plan has been prepared in accordance with Georgioursquos Environmental Policy (appendix 11) All
relevant works including those conducted by subcontractors or by other companies on Georgioursquos behalf will
conform to this Policy
Georgioursquos Environmental Policy will be communicated to all workers at their site induction and displayed at the
site Georgioursquos policies will be made available to any interested party
Environmental Management Plan
This CEMP provides the system to manage and control the environmental aspects of the Project during pre-
construction and construction It identifies all the requirements applicable to manage the activities described in
Section 2 It also provides the overall framework for the system and procedures to ensure environmental impacts
are minimised and legislative and other requirements are fulfilled The strategies defined in this CEMP have been
developed with consideration of the Project approval requirements environmental management measures
presented in the approval documents This CEMP establishes the system for implementation monitoring and
continuous improvement to minimise impacts from the Project on the environment
This CEMP is consistent with
ASNZS ISO14001 2004 lsquoEnvironmental Management Systems - requirements with guidance for usersquo
Georgiou HSEQ Management System
Environmental Policy
Georgious Management is committed to regulatory
compliance pollution prevention and continous
improvement
Planning
Identify environmental interactions and signficant
aspects identify legal and other requirements and development
environmental objectives targets and the programs in
which to achieve them
Implementation and Operation
Define structure and responsibility identify and complete training
needs establish communication procedures document the EMS
through policies plans and procedures establish document
control establish operational control implement emergency
preparedness and response
Checking
Monitor and measure environmental interactions
evaluate compliance establish a non-conformance corrective
action and preventative action system maintain records and
perform periodic internal audits of the EMS
Management Review
Management to review environmental performance
EMS performance policy priorities and objectives and recommend improvements
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5 LEGAL AND OTHER OBLIGATIONS
The following documents provide further information in regards to this topic
Management System Standard
HSE Legal and Other Obligations Directory
General
The statutory requirements for this site have been identified within the Company HSE Legal and Obligations
Directories (available on Company Intranet) and have been incorporated into this management plan Legal and
other requirements specific to this contract which are not otherwise captured in the Company HSE Legal and
Obligations Directories are as follows
Legislation Other requirement
Requirement Comment
EPBC Act 1999
Under the EPBC Act a referral to the Commonwealth Department of Agriculture Water and the Environment is required for proposed lsquoactionsrsquo that have the potential to significantly impact on any matter of national environmental significance the environment in general or the environment of Commonwealth land (including leased land)
There are no matters of national environmental significance located within the general area of the proposal as confirmed in Appendix A of the REF Therefore an EPBC Act referral is not required
EPampA Act 1979
Clause 94 of the ISEPP outlines that development for the purpose of road and road infrastructure facilities which are permissible without the need for development consent under Part 4 of the EPampA Act when carried out by a public authority
Sydney Metro is a public authority and has prepared an REF and determination report to meet the assessment requirements under the EPampA Act
EPampA Regulation 1979 Under clause 228 of the factors to take into account concerning the impact on an activity on the environment
The REF and determination report prepared by Sydney Metro has considered factors under clause 228
ISEPP 2007
Division 1 of Part 2 of the ISEPP contains provisions for public authorities to consult with local councils and other public authorities prior to the commencement of certain types of development
Sydney Metro will conduct consultation with local councils and other authorities prior to commencement of construction
Biosecurity Act 2015
Under the Biosecurity Act 2015 all plants including weeds are regulated with a general biosecurity duty to prevent eliminate or minimise any biosecurity risk they may pose Any person who deals with any plant who knows (or ought to know) of any biosecurity risk has a duty to ensure the risk is prevented eliminated or minimised so far as is reasonably practicable
The State level priority weeds and associated legal requirements relevant to the region are outlined in the Greater Sydney Regional Strategic Weed Management Plan 2017-2022 (Greater Sydney Local Land Services 2017)
As such if present priority weeds on the site would be assessed and controlled to fulfil the General Biosecurity Duty and minimise biosecurity risks
Contaminated Land Section 60 of the Contaminated Land Management Act 1997 imposes a duty on
One site (former White Bay Power Station) that is currently regulated by
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Management Act 1997 landowners to notify the NSW EPA and potentially investigate and remediate land if contamination is above NSW EPA guideline levels
the NSW EPA is located within the proposal site
Given the proposed works are predominately surficial or up to one metre below existing site levels contamination risk is considered minor and manageable
Biodiversity
Conservation Act 2016
The Biodiversity Conservation Act 2016 provides for the protection of threatened species populations and ecological communities in NSW If a threatened species population or ecological community or its habitat is likely to occur in any area that may be affected by the proposal then an assessment of significance must be prepared to determine whether the proposal would have a significant impact
The site is unlikely to contain suitable habitat for any listed threatened species or community and is unlikely to have a significant impact on any threatened species or community
Heritage Act 1977
The NSW Heritage Act 1977 (Heritage Act) provides protection for items of lsquoEnvironmental heritagersquo in NSW Items considered to be significant to the State are listed on the State Heritage Register (SHR) and cannot be demolished altered moved or damaged or their significance altered without approval from the Heritage Council of NSW
Section 170 of the Heritage Act requires government agencies to maintain a heritage and conservation register (Section 170 register) These registers provide a list of government assets which may have State or local heritage significance
Sections 139 to 145 of the Heritage Act prevent the excavation or disturbance of land known or likely to contain relics unless in accordance with an excavation permit Excavation permits are issued under Section 140 of the Heritage Act or Section 60 for sites listed on the SHR Excavation Permit Applications must be supported by an Archaeological Research Design Section 146 of the Heritage Act requires that any discovery or location of a lsquorelicrsquo is reported to the Heritage Council
The road footprint for Georgioursquos scope of works is located outside of the heritage curtilage for the SHR-listed White Bay Power Station and does not extend north to the White Bay Power Station (Inlet) Canal (Port Authority of NSW s170 4560062)
The Glebe Island Silos (Port Authority of NSW s170 4560016) and the Glebe Island Dyke Exposures (Port Authority of NSW s170 4560056) are located immediately adjacent to the road footprint
As detailed in the REF it is unlikely that archaeological relics would be impacted by the works therefore a Section 139 exception or Section 140 permit are not required for the works
National Parks and
Wildlife Act 1974
Sections 86 87 and 90 of the National Parks and Wildlife Act 1974 require consent from the Environment Energy and Science Group of the Department of Planning Industry and Environment for the destruction or damage of Aboriginal objects
The proposal is unlikely to disturb any Aboriginal objects (refer Section 77)
However if unexpected archaeological items or items of Aboriginal heritage significance are discovered during the construction of the proposal the Sydney Metro Unexpected Finds procedure would be followed
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Protection of
the Environment
Operations Act 1997
The Protection of the Environment Operations Act 1997 (POEO Act) administers environment protection licences (EPLs) for specific activities relating to air water and noise pollution and waste management The Environment Protection Authority (EPA) and local government where relevant administer the POEO Act
Development activities require an EPL under the POEO Act if those activities meet the assessment criteria outlined in Schedule 1 of the Act
The proposal does not meet the definition of a scheduled activity under Schedule 1
In addition the POEO Act would require construction to be managed to prevent and avoid the potential to cause water noise andor air pollution The Act also includes requirements in relation to the management of waste
Notification to the EPA would also be required (as the administrators of this Act) in instances where any pollution incident has the potential to lsquocause or threaten material harm to the environmentrsquo (refer to Section 148 of the Act)
Roads Act 1993
In accordance with Section 138 of the Roads Act 1993 consent from NSW Transport for NSW would be required for the carrying out of work in on or over a classified road
For works on unclassified roads Clause 5 of Schedule 2 of the Act provides that a public authority is not required to obtain a road authorityrsquos consent
Ongoing consultation would be carried out with the relevant road authority (or authorities) in relation to the potential impacts that may occur to all of the roads and to identify any potential construction activities may be require consent
Waste avoidance and
Resource Recovery
Act 2001
The purpose of the Waste Avoidance and Resource Recovery Act 2001 is to develop and support the implementation of regional and local programs to meet the outcomes of a State-wide strategy for waste avoidance and resource recovery
It also aims to lsquominimise the consumption of natural resources and final disposal of waste by encouraging the avoidance of waste and the reuse and recycling of wastersquo
Waste generation and disposal reporting would be carried out during the construction and operation of the proposal Procedures would be implemented during construction in an attempt to promote the objectives of the Act
Water Act 1912 and
Water Management
Act 2000
The Water Act 1912 and the Water Management Act 2000 are the two key pieces of legislation for the management of water in NSW and contain provisions for the licensing of water access and use
The proposal would not involve any water use water management works drainage or food works controlled activities or aquifer interference
National Greenhouse and Energy Reporting Act 2007
The Act established a framework for reporting of greenhouse gas emissions abatement actions energy consumption and production data
The project will report on greenhouse gas and energy usage data as required by the Act
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Contractual Environmental Requirements
This Management Plan has been written to comply with the following Sydney Metro CEMF requirements
Requirement Reference
Scope of Applicability (Any Sections of the CEMF not addressed in the left hand column of
this table do not apply) Addressed by
CEMF Requirements
Section 1 full applicability This document
Section 4
Section 2 full applicability Section 5
Section 23
Standards and guidelines applicable to the works including o ISO14001 Environmental Management System ndash Requirements
with Guidelines for Use o Interim Construction Noise Guidelines (Department of
Environment and Climate Change 2009) o Managing Urban Stormwater Soil and Construction (Landcom
2008) o AS42821997 Control of the Obtrusive Effect of Outdoor Lighting o Waste Classification Guidelines (Department of Environment
Climate Change and Water 2008) o Australian and New Zealand Guidelines for Fresh and Marine
Water Quality
Section 41
Appendix 7
Appendix 2
Appendix 1
Section 32
Only applies with respect to Construction for o SMP1 o SMP2 o SMP5 o SMP6 o SMP7 o SMP14 o SMP18 o SMP19 o SMP30
Separate sustainability management plan
Section 34
34(d) (x) applies only to the extent of addressing environmental inspections
34(d) (xi) does not apply
Approval by DPIE is not required under 34(e)
34(f) Applies with respect to o Unexpected Finds Procedure (Heritage) o Environmental Incident and Non-compliance Reporting Procedure o Construction Noise and Vibration Standard o Out of Hours Work Application Form o Unexpected Finds Procedure (Contamination)
This document
Appendices 1-10
Section 36 36(b) only applies with respect to the drafting of a Waste Management Procedure and an Unexpected Finds Procedure for Contamination
Appendix 1
Appendix 8
Section 39 39(a) (iii) does not apply 39(b) does not apply
39(b) does not apply Section 11
Section 310 Applies except that a Pollution Incident Response Plan is not required Section 12
Section 312 312(a)(i) does not apply
312(a)(iv) does not apply Section 6
Section 313
313(b) does not apply
313(d) does not apply
313(e) does not apply
Section 15
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CEMP Bays Road Relocation Works
Section 314 Full Applicability Section 13
Appendix 9
Section 315 315(d) does not apply with respect to internal audits carried out by the Principal Contractor
Section 16
Section 316 316(d) does not apply where the Principal Contractors works last less than 1 year
Section 15
Section 4 42(a) does not apply
45(c) does not apply Section 72
Section 5 51(c) does not apply
54 does not apply Appendix 7
Section 6 Only 61 applies
Sustainability management plan
Section 7 71 does not apply
72 does not apply
Appendix 2
Section 8
81 full applicability
A Construction Noise and Vibration sub-plan is not required however the CEMP must address
82(a) (iii) and (b) for Site Establishment Activities
Appendix 7
Section 9
91 (a) (i) is not applicable
A Heritage Management plan is not required however the CEMP must address the following requirements
92 (iii)
92 (ix)
92 (c) (iii)
Appendix 5 5A 5B
Section 10
101 (ii) does not apply
102(a) (iii) applies with respect to the relocation of fauna only
102(b) (i) applies
102 (b) (ii) applies
All other sections are not applicable
Appendix 4
Section 11 111 (ii) does not apply
112 does not apply Section 72
Section 12
A Soil and Water Management Plan is not required however the CEMP must address the following requirements
122 (vi)
Appendix 2
Section 13 131 full applicability
132 does not apply Appendix 6
Section 14
141 full applicability
A Waste Management Plan is not required however the CEMP must address the following Requirements
142 (a) (iv)
142 (a) (v)
142 (b) (i)
142 (d)
Appendix 1
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CEMP Bays Road Relocation Works
REF Determination Conditions of Approval
The project is subject to compliance with the Conditions of Approval (CoA) identified below these are from the
REF Determination Report (August 2020) These Conditions of Approval are consistent with the management and
mitigation measures in the REF (April 2020) with some amendments due to the project changes identified in the
REF determination report
CoA Requirement Addressed by
REF Determination Conditions of Approval
NV1 Receivers that would potentially be affected by noise andor vibration from the works would be appropriately notified before the relevant works start
This would include details on the nature of works to be carried out the expected noise levels duration of noise generating construction works and contact details during construction
Appendix 7
NV2 Where vibration levels are predicted to exceed the screening criteria a more detailed assessment of the structure (in consultation with the relevant asset owner and a structural engineer) and attended vibration monitoring would be carried out to ensure vibration levels remain below appropriate limits for that structure
For heritage buildings and structures the more detailed assessment would specifically consider the heritage values of the structure in consultation with a heritage specialist to ensure sensitive heritage fabric is adequately monitored and managed
Appendix 7
NV3 Condition surveys of buildings and structures near to the proposal would be undertaken in consultation with the relevant owner prior to the commencement of vibration intensive works where appropriate For heritage buildings and structures the surveys would consider the heritage values of the structure in consultation with a heritage specialist
Sydney Metro
NV4 Alternative construction methodologies would be considered where vibration intensive works (typically site clearing ndash demolition) result in exceedances of cosmetic damage screening criteria and may include the following
The use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of rockbreakers for demolition of structures
Use of smaller capacity rockbreakers or lower vibration generating rockbreakers
Isolating the vibration sensitive structure from the vibration intensive work area by severing the vibration transmission path using non-vibration intensive means such a sawing
Appendix 7
NV5 The potential vibration impacts to underground utilities and services would be reviewed as the proposal progresses in consultation with the asset owners and the Port Authority of NSW
Appendix 7
T1 Clear wayfinding and safety signage would be provided to direct and guide vehicles not related to the proposal during road construction works This would be supplemented by Variable Message Signs to advise drivers of traffic diversions speed restrictions or alternative routes
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T2 The Port Authority of NSW and lease holders would be notified in advance of any proposed road changes within the port area and the potential for short term delays
Sydney Metro
Georgiou must provide written notifications to Sydney Metro on road changes in
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CEMP Bays Road Relocation Works
advance of each relevant road change within the port area
T3 Construction site traffic would be managed to minimise movements during peak periods
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T4 Access to Cement Australia and other leased areas would be maintained in consultation with Port Authority and lease holders
Sydney Metro
Georgiou will provide required information to SM
T5 All staff parking would be provided on-site and not on surrounding local streets
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
NAH1 An Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
(Transferred to Georgiou under VO-003)
C1 Sampling and testing of soils in areas of potential contamination concern would be conducted to characterise the soils (with respect to contamination) and determine the appropriate waste classification (which may include hazardous wastes or special wastes) and management response Waste classification would be carried out in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (NSW Environment Protection Authority 2014)
Appendix 1
Appendix 1A
C2 Soils would be managed in accordance with the Protection of the Environment Operations (Waste) Regulation 2014 and disposed of to an appropriately licensed waste management facility
Appendix 1
Appendix 1A
C3 Erosion and sediment measures would be implemented in accordance with the principles and requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Appendix 2
C4 All fuels chemicals and hazardous liquids would be stored in accordance with Australian standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Appendix 3
C5 Prior to ground disturbance in areas of potential acid sulfate soil occurrence testing would be carried out to determine the presence of actual andor potential acid sulfate soils If acid sulfate soils are encountered they would be managed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Appendix 2
LV1 The design and maintenance of construction site fencing would aim to minimise visual amenity impact where visible from public areas
Section 722
LV2 Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Appendix 7
WR1 All waste would be assessed classified managed transported and disposed of in accordance with the Waste Classification Guidelines and the Protection of the Environment Operations (Waste) Regulation 2014
Appendix 1
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The waste management hierarchy principles established under the Waste Avoidance and Resource Recovery Act 2001 of avoidreducereuserecycledispose would be applied to the construction of the proposal
AQ1 The following best-practice dust management measures would be implemented during all construction works
Regularly wet-down exposed and disturbed areas including stockpiles especially during dry weather
Adjust the intensity of activities based on measured and observed dust levels and weather forecasts
Minimise the amount of materials stockpiled and position stockpiles away from surrounding receivers
Regularly inspect dust emissions and apply additional controls as required
Appendix 6
AQ2 Plant and equipment would be maintained in a proper and efficient manner Visual inspections of emissions from plant would be carried out as part of pre-acceptance checks
Appendix 6
GHG1 Opportunities to reduce greenhouse gas emissions through the increased use of recycled materials would be investigated during detailed design
Sydney Metro
CI1 The likelihood of cumulative (ie concurrent and consecutive) construction impacts would be reviewed during detailed design when detailed construction schedules are available
Co-ordination and consultation with the following stakeholders would occur where required to manage the interface of projects under construction at the same time
Transport for NSW including Transport Coordination
Department of Planning Industry and Environment
Port Authority of NSW
Sydney Motorways Corporation
Construction contractors
Co-ordination would occur between potentially interacting projects to minimise concurrent or consecutive works in the same areas where possible
Sydney Metro
Georgiou must participate in any consultation as requested by the Principal and provide the Principal with all information and documentation the Principal requires to comply with condition
Environmental Licences and Permits
The Project Environmental Site Representative will be responsible for
Checking with the local government municipality to see if there are local environmental requirements Identifying the environmental licences and or permits under which the site will operate Obtaining a copy of any client held licences permitsapprovals to determine conditions of compliance or if not
available obtaining written verification that licences and permits are held Obtaining Georgiou held licences and or permits Monitoring compliance to the conditions of the licencepermit and report on the status in the Project HSEQ
Performance Report and to the client
Permits and licences relevant to the project are as follows
Permit licence Responsibility Status
Environmental protection licences (EPL) under the Protection of the Environment Operations Act 1997 for road construction
Georgiou Not required as this project does not trigger a scheduled activity under the POEO Act 1997
Road Occupancy Licences Georgiou To be applied for as required
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Infringement Improvement and Prohibition Notices
The Project Manager or delegate will ensure any infringement improvement or prohibition notice issued by a
regulatory authority recorded as a incident in Georgioursquos Incident reporting database (Beakon) and appropriate
actions taken in a timely manner A copy of the infringement improvement or prohibition will be added to the
incident report and forwarded to the HSE Business Unit Lead
The Project Manager will notify via email their General Manager Construction Manager Operations Manager
HSE Business Unit amp Environmental Site Representative Lead when the infringement improvement or prohibitions
notice has been closed out
Availability of Statutory and Other Information
Georgioursquos HSEQ Department maintains links to current statutory documents (Acts Regulations and Codes of
Practice) in the HSE Legal and Other Obligations Directories which are located on Georgioursquos Intranet
(GENIE)Georgiou subscribes to Environmental Essentials product Envirolaw which is available to all personnel
through the intranet link Envirolaw summarises environmental legal obligations provides links to legislation and
guidelines as well as providing search capabilities
Changes in legislation are monitored by the HSEQ Department and site management will be notified where a change
affects a site The Project Manager will be responsible for communicating changes in accordance with section 7
HSE will ensure the change is reflected in this Management Plan and other relevant plans and documents as
applicable
Objectives amp Targets
Objectives and targets have been set for the site taking into account the significant hazards and environmental
aspects of the job the group objectives and client and contractual requirements These are documented in the
table below
Item Description Measurement Target
1 Successful implementation of CEMP and contract requirements
Audits inspections reporting management reviews
0 NCRs associated with CEMP implementation
2 Compliance with all legal requirements Audits reporting management reviews
0 regulatory infringements (PINs or prosecutions)
3 Engage with the affected and broader community minimise complaints and respond to any complaints within a suitable timeframe
Review complaints register reporting audits
0 NCRs associated with CCS implementation
4 Environmental incidents with the potential to cause material harm to the environment
Number of material harm incidents 0
5 Continuously improve environmental performance
Regular environmental inspections
Regular Leadership visits
Share environmental best practice and innovations across projects
1 environmental inspection per week
1 Leadership visit per month
1 NSW Environmental meeting per month
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6 Environmental Awareness for all workers
Conduct all Toolboxes and training identified in this CEMP
1 environmental toolbox per month on relevant site issues
Additional objectives and targets may be set specifically for activities identified for upcoming works Performance
against all HSE objectives will be monitored as a minimum monthly at site meetings
6 STRUCTURE AND RESPONSIBILITIES
Organisational Structure
The site organisational structure has been documented in the Site Organisational Chart The Site Organisational
Chart identifies the roles that will support the site in fulfilling their HSE responsibilities
Roles and Responsibilities and Authority
The Project Manager is accountable for the environmental performance of the project and the implementation of
the projectrsquos management plans Key personnel and their site responsibilities are detailed below
Project Manager ndash Brad Collins
The environmental responsibilities of the Project Manager include (but are not limited to) the following
Ensure all works comply with relevant regulatory and Project requirements Ensure the requirements of this CEMP are fully implemented and in particular that environmental
requirements are not secondary to other construction requirements Endorse and support the environmental policy Be aware of their environmental responsibilities as detailed in the management plans Actively ensure that subcontractors and suppliers are complying with environmental requirements Liaise with the client and other government authorities as required Participate and provide guidance in the regular review of this CEMP and supporting documentation Provide adequate resources (personnel financial and technological) to ensure effective development
implementation and maintenance of this CEMP Ensure that all personnel receive appropriate induction training including details of the environmental and
community requirements Ensure that complaints are investigated to ensure effective resolution Stop work immediately if an unacceptable impact on the environment is likely to occur Hold monthly HSEQ management meetings to review environmental performance and monitor
implementation and effectiveness of the management system Ensure their direct reports fulfil their environmental responsibilities and achievement of KPIrsquos Support workers to immediately stop any lsquoat risk behaviourrsquo identified during their work activities
Project Site Engineer ndash Richard Kelly
The environmental responsibilities of the Project engineers include (but are not limited to) the following
Provide input into the preparation of environmental planning documents as required Ensure that instructions are issued and adequate information provided to employees that relate to
environmental risks on-site Ensure that the works are carried out in accordance with the requirements of the CEMP and supporting
documentation including the implementation of all environmental controls Identify any environmental risks Identify resource needs for implementation of CEMP requirements and related documents Ensure that complaints are investigated to ensure effective resolution
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Take action in the event of an emergency and allocate the required resources to minimise the environmental impact
Report any activity that has resulted or has the potential to result in an environmental incident immediately to the Supervisor and Environmental Site Representative
Supervisor ndash Eddie Storer
The Supervisor is responsible for creating an exemplary HSE culture and ensuring adherence to the Management System on their site The Supervisor is responsible for approving the commencement of works and to allocate necessary resources to complete a job safely in accordance with the Management Plan and will
Demonstrate commitment to the Environment by monitoring the workplace to ensure work practices are adhered to by way of routine checks of the workplace compliance to the Management Plan
Demonstrating through their actions and behaviour that safety and the environment are core values Hold Supervisors and leading hands (Georgiou amp subcontractors) accountable for the fulfilment of their
Environmental responsibilities including KPIrsquos Be given the authority and independence to require reasonable steps be taken to avoid or minimise
unintended or adverse environmental impacts Allocating work to ensure appropriate supervision for those with lesser experience Ensuring appropriate and necessary plant and equipment is provided for workers to carry out their work
safely and without undue harm to the environment Stopping rejecting or quarantining materials plant and equipment Supporting workers to immediately stop any lsquoAt Risk Behaviourrsquo identified during their work activities Participating in audits investigations and constructability reviews Management and HSE performance of the subcontractors utilised on site
Environmental Site Representative ndash Chloe Redman
The environmental responsibilities of the Environmental Site Representative include (but are not limited to)
overall responsibility for the implementation of environmental matters on the Project development implementation monitoring and updating of the EMP and sub-plans in accordance with
ISO14001 report to the Project Manager on the performance and implementation of the CEMP to ensure management
reviews of the CEMP are undertaken annually documented and actions implemented ensure environmental risks of the Project are identified and appropriate mitigation measures implemented identify where environmental measures are not meeting the targets set and where improvement can be
achieved ensure environmental protocols are in place and managed ensure environmental compliance obtain and update all environmental licences approvals and permits as required liaise with the approval authorities manage environmental document control reporting inductions and training manage environmental reporting within the Project team and to the Client and regulatory authorities prepare reports on a monthly basis outlining the Project works undertaken and the achievements that have
been met as well as identifying those areas where improvements were made oversee site monitoring inspections and audits manage all sub-contractors and consultants with regard to environmental matters including assessing their
environmental capabilities and overseeing the submission of their environmental documents develop and facilitate induction toolbox talks and other training programs regarding environmental
requirements for all site personnel notify the client and relevant authorities in the event of an environmental incident and manage close-out of
these stop activities where there is an actual or immediate risk of harm to the environment or to prevent
environmental non-conformities and advise the Project Manager and Supervisor assist the Community Relations Manager to resolve environment-related complaints
undertake site inspections carry out monitoring activities and complete site checklists ensure monitoring records are appropriately maintained reviewed and any non-compliance issues addressed assist in identifying environmental risks
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advise the Project Manager of the need to stop work immediately if an unacceptable impact on the environment is likely to occur or to require other reasonable steps to be taken by the site Construction staff to avoid or minimise impacts
Environmental Consultants
Georgiou has engaged consultancy contracts with the following companies
Ade Consulting - Contaminated land and hygienist services VMS ndash Noise and Vibration Management Services ARTEFACT ndash Archaeological and Heritage Consultants
Throughout the works there may be the requirement to engage other specialist environmental consultants or change the consultants listed above All Environmental consultants engaged to provide specialist advice on environmental matters are responsible to
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the Supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Adhering to all permit requirements Complying with all statutory and regulatory requirements
All Personnel
All personnel on site are responsible for
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident undertake remedial action as required to ensure environmental controls are maintained in good working
order Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Participating and adhering to SWIrsquos and JHArsquos Adhering to all permit requirements Immediately stopping any lsquoAt Risk Behaviourrsquo identified during daily work activities Complying with statutory and regulatory requirements
Communication and Acceptance of Accountabilities and Responsibilities
The Core Site Team will acknowledge their understanding and acceptance of the site accountabilities and
responsibilities by signing Appendix 1 in this plan
Field Leadership Visits
Senior Management with an operational role or functional support will demonstrate visible and proactive commitment by visiting site to engage in discussion with site management and workers in regard to HSE issues relevant to the business which may include any of the following
Active participation and contribution in Pre-start meetings Participation in Toolbox Talks Participation in the delivery of site safety and environmental messages on-site HSE programs or initiatives Participation in work inspections One-on-one discussions
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Behavioural observations Participation in monthly meetings discussing HSEQ performance
A record of the visit and the activity undertaken by the Senior Manager will be recorded and where appropriate feedback provided to the Site team A component of the Site Leadership visit will involve an environmental inspection of the site in accordance with section 151
7 COMMUNICATION AND CONSULTATION
The following documents provide further information in regards to this topic
HSEQ Communication and Consultation Standard
Community Relationship Management Guideline
Resolution of HSE Issues Procedure
Internal Communication and Consultation
Communication and consultative arrangements will be put in place to provide workers including subcontractors
with information and an opportunity to contribute to HSE and comply with applicable legislative requirements
The Site will use the methods detailed below to communicate to employees subcontractors and visitors
information in regard to the Georgiou Management System this management plan performance and environmental
issues
711 Inductions
All personnel (including sub-contractors) are required to attend a compulsory site induction that includes an
environmental component prior to commencement on-site This is undertaken to ensure all personnel involved in
the Project are aware of the requirements of the CEMP The environmental component of the induction must cover
all elements of the CEMP and will include as a minimum
relevant details of the CEMP including all sub-plans procedures and strategies their purpose and objectives
policies and KPIs
Requirements of due diligence and duty of care
relevant legislation and conditions of environmental licences permits and approvals
Potential environmental emergencies on-site and the emergency response procedures
Reporting and notification requirements for pollution and other environmental incidents
key environmental issues
Mitigation measures for the control of environmental issues
Complaints response and reporting
Communication protocols for interactions with community and stakeholders
site specific environmental management requirements and responsibilities
Incident and emergency response and reporting requirements
Environmentally sensitive locations and no-goexclusion zones
Erosion and sediment controls water quality controls and sediment basin management
Management of contaminated material (including asbestos impacted material)
Location of identified potential contaminated land sites
Signs of contaminated soil including visual asbestos identification protocols
Procedure for unexpected finds of contaminated land asbestos
Water quality management and protection measures
Location of identified Aboriginal and non-Aboriginal archaeological heritage sites areas of cultural sensitivity
and areas of archaeological potential and the kinds of historical relics structures or deposits which may be
encountered during the Construction works
Unexpected finds procedures for heritage
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noise vibration and air quality management controls
Standard Construction hours and the process for seeking approval for out of hours works including consultation
Road occupancy and other temporary and interim traffic arrangements
Specific responsibilities for the protection of flora and fauna
A record of all environment inductions will be maintained in a Project induction and training Register and kept on-
site The training register will identify who is trained when trained the trainer and what they were trained in
712 HSE Notice Boards
All worksites that have a crib room will set up a HSE notice board to display
Project HSEQ Performance Report
Environmental BulletinsAlerts
Site HSEQ Objectives and Targets
Organisational Chart
A Site Layout Plan and Emergency Evacuation Plan Emergency contacts and First Aiders list These will also be
posted in prominent locations throughout the site as described in the site Emergency Response Management
Plan
Risk Registers
713 HSE Alerts Bulletins
Incident Alerts will be used to communicate learningrsquos and actions required to assist in ensuring incidents that have
occurred in one workplace are not repeated in others HSE Bulletins will be used to communicate environmental
information to the workplace HSE Alerts and Bulletins will be developed by the Site Team using the approved
templates and approved by the HSE Business Unit Lead prior to communication
714 Site Meetings
The following meetings will be held on site to monitor implementation of the Georgiou Management System review
performance and communicate consult with workers in regards to HSE
Site Meetings (refer to section 142) Pre-Start Meetings Toolbox Meetings
Meeting agenda and minutes will be recorded maintained and be made available when required
Community and Stakeholder Involvement
A Community Communication Strategy will be developed for the project Key elements of the Community
Communication Strategy which will be implemented at appropriate times in the construction process will include
Notification (including targeted letterbox drops and email) of any works that may disturb local residents and businesses (such as noisy activities and night works) at least seven days prior to those works commencing
Notification (including targeted letterbox drops and email) of works that may affect transport (such as road closures changes to pedestrian routes and changes to bus stops)
Traffic alerts (via email) to all key traffic and transport stakeholders advising of any changes to access and local traffic arrangements (at least seven days prior to significant events)
Print and radio advertisements regarding major traffic changes 24-hour toll-free community project information phone line Complaints management Community information sessions as required Regular updates to the Sydney Metro website (sydneymetroinfo) including uploading of all relevant
documents and contact details for the stakeholder and community relations team
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Provision of information to the Sydney Metro Community Information Centre including community newsletters information brochures and fact sheets and interactive web-based activities
Clear signage at the construction sites Newspaper advertisements in local and metropolitan papers as required Regular inter-agency group meetings Community business and stakeholder satisfaction surveys and feedback forms Translator and interpreter services and The project team will liaise with the Sydney Metro Project Communications team as the point of contact for
the community
721 Complaints Management
Community liaison and complaints handling will be undertaken in accordance with the Construction Complaints
Management System and will include
dealing with complaints in a responsive manner so that stakeholdersrsquo concerns are managed effectively and promptly and
A verbal response will be provided to the complainant as soon as possible and within a maximum of two hours from the time of the complaint (unless the complainant requests otherwise) A detailed written response will then be provided if required to the complainant within one week
A complaints register will be maintained in Georgioursquos BEAKON database and in Sydney Metrorsquos Consultation
Manager TM which will contain
Date and time of complaint Method by which the complaint was made (telephone letter meeting etc) Name address and contact telephone number of complainant (if no such details were provided a note to that
effect) Nature of complaint Action taken in response including follow up contact with the complainant Any monitoring to confirm that the complaint has been satisfactorily resolved If no action was taken the reasons why no action was taken
The project will apply an adaptive approach to ensure that corrective actions are applied in consultation with the
appropriate construction staff to allow improvements in the management of issues resulting in community
complaints
722 Urban Design of temporary works
Temporary construction works will consider urban design and visual impacts including
Minimise impacts on existing landscape features as far as feasible and reasonable Artwork graphics and images to enhance the visual appearance of temporary works in high visibility locations Project information to raise awareness on benefits explain the proposed works at each site and provide
updates on construction progress Community information including contact numbers for enquiries complaints Signage and information to mitigate impacts on local businesses which may be obscured by the construction site Sydney Metro advertising public awareness campaigns Logos branding including Sydney Metro NSW Government and Contractor branding
The design of all temporary works will require Sydney Metro approval in relation to urban design and visual impacts
and Sydney Metro will stipulate the design of hording artwork including
Sydney Metro advertising public awareness campaigns and Logos branding including Sydney Metro NSW Government and Contractor branding
Construction hoardings scaffolding and acoustic sheds will be regularly inspected and kept clean and free of dust
build up Graffiti on construction hoardings scaffolding or acoustic sheds will be removed or painted over
promptly The principles of Crime Prevention Through Environmental Design will be applied to all works including
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temporary works that have a public interface
723 Business and Property Impacts
The project footprint is within any area managed by the Port Authority of NSW and several port related facilities
are adjacent to the work including Cement Australia Gypsum Resources Australia and Sugar Australia Georgiou will
undertake works to meet the following objectives
Minimise the potential impact of the project to businesses affected by construction works Ensure businesses are kept informed of the project and consulted in advance of major works or factors that are
likely to have a direct impact Ensure that business stakeholder enquiries and complaints regarding the project are managed and resolved
effectively
Consult with all business directly affected by changes to access arrangements regarding specific requirements at least two weeks prior to those changes coming into effect
8 HAZARD IDENTIFICATION AND RISK CONTROL
The following documents provide further information in regards to this topic
HSEQ Risk and Operational Control Standard Job Hazard Analysis (JHA) Procedure Permit to Work Procedure
Hierarchy of Control
The following hierarchy of control will be applied to controlling environmental risks and environmental aspects
within Georgiou This hierarchy recognises that the best controls act on the environment not on the people in it
HazardsAspects
Waste
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Site Environmental Risk Analysis
The Site Team has undertaken a construction risk assessment workshop (CRAW) and developed a HSEQ Risk
Register based on the Master Risk Register which incorporates the Companyrsquos mandatory controls and additional
site specific hazards and controls identified in the CRAW This Management Plan and the Emergency Response
Management Plan have been based upon this HSEQ Risk Register
Works on site will be undertaken in accordance with the HSEQ Risk Register The HSEQ Risk Register will be
made available to workers
Review of Risks
The aspects within the HSEQ Risk Register will be reviewed for adequacy
At site meetings Prior to the commencement of any new construction work that involves high impact risks After a significant incident
If there is a change made to the construction methodology and associated change in the risks and controls associated with the works the Risk register and Construction Environmental Management Plan will be updated as appropriate
831 Change Management
The following documents provide further information in regards to this topic
Change Management Procedure
Where there is a change to the planned scope design or construction methodology (including plant machinery
materials or sequence) the impact of the change must be assessed and a determination on whether the Change
Management Procedure applies If so then a formal analysis of the change will be undertaken using the
Management of Change Event Design Form
Changes to the project may require an assessment to determine consistency with the REF and Environmental
Documents The assessment will include
A description of the existing surrounding environment Details of the ancillary works and construction activities required to be carried out including the hours of works An assessment of the environmental impacts of the works including but not necessarily limited to traffic
noise and vibration air quality soil and water ecology and heritage Details of mitigation measures and monitoring specific to the works that would be implemented to minimise
environmental impacts Identification of the timing for completion of the construction works and how the sites would be reinstated
(including any necessary rehabilitation)
Operational Control
Operations and activities associated with significant environmental aspects will be planned to ensure they are
carried out under specific operating conditions An Environmental Control Map (ECM) Safe Work Method
Statements Job Hazard Analysis Take Five Hazard Report or a combination of these will be used to achieve this
requirement
841 Environmental Hazard Reporting
Environmental Hazard reporting will be conducted using the Hazard Report (contained within the Hazard
ReportTake 5 booklet)
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The Supervisor is responsible for ensuring environmental hazards are addressed in a timely manner using the
hierarchy of control and communicated to those who may be potentially affected Where hazards cannot be
addressed immediately and additional controls are required they are to be reported into the Beakon system for
follow-up and close-out
842 Take 5
Take 5 booklets will be available to all workers to perform risk assessments for work that is not high risk
construction Take 5 risk assessments include environmental aspects and the identified environmental controls for
these risks are to be documented on the Take 5 form and implemented for the works
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS)
JHASWMS will be completed for all high risk construction work JHASWMS developed will reflect the safety and
environmental risks and controls identified in the sites risk register and supporting work instructions
Subcontractors will be provided access to the sites HSEQ Risk Register and prior to undertaking the work will be
required to submit their JHArsquosSWMS to Georgiou for review and approval using the Subcontractor JHASWMS
Assessment (available in Beakon)
844 Permit to Work
The following high risk activities require written authority in the form of a ldquopermit to workrdquo from the Georgiou Site
Team
Vegetation Clearing Permit (Georgiou form) Dewatering Permit (Georgiou form) Out of Hours application (Sydney Metro form)
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices) will be included in the
environmental permits No work involving these activities will commence until the appropriate permit has been
completed Personrsquos issuing permits on the Site will be given training in the Georgiou Permit to Work system A
permit may be required for other high risk activities as determined by risk assessment the Sitersquos Manager andor
contractual requirements
845 Environmental Control Maps
To assist pre-construction planning and on-site construction management the environmental site constraints are
consolidated on a series of map-based sheets that extend the length of the Project Environmental Control maps
include information pertaining but not limited to
Noise and vibration sensitive receiverrsquos eg residential dwellings
Flora features including threatened species and endangered ecological communities
Aboriginal and non-Aboriginal heritage sites including items places objects and sites
Local waterways
Recorded threatened fauna sightings
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices)
The Environmental Control maps are a working element of the CEMP and will be revised throughout construction to
reflect true ground conditions and the most up-to-date information available on sensitive sites Sensitive area maps
will be used in conjunction with EWMS and ESCPs to help identify key risk areas and to promote ongoing
communication to construction personnel during the Project
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9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT
The following environment aspects have been identified as significant for this project Risks associated with these
significant aspects and appropriate controls have been identified during the construction risk assessment workshop
(CRAW) and included in the HSEQ Risk Register in accordance with section 82
In addition aspect specific sub-plans within this CEMP have been developed to detail how the environmental
aspects will be managed to comply with relevant legislation amp client requirements These aspect specific sub plans
include
Waste
Soil and Water
Hydrocarbon and Chemical
Cultural Heritage
Air Quality and Dust
Noise and Vibration
Contamination
10 CLOSURE AND COMMISSIONING
At completion of this project Georgiou will hand over the site in an environmentally responsible state) taking into
account the nature of the works in accordance with legislative amp contractual requirements
11 TRAINING COMPETENCY AND RESOURCING
All Georgiou personnel and contractors will undergo environmental training before commencing works on site
Training will be undertaken in the following forms
project site induction (section 711) and Environmental awareness training through regular tool box discussions Inductees will be required to sign-off that they have been informed of the environmental issues and that they
understand their responsibilities
1111 Toolbox talks
ldquoToolboxrdquo training will help to ensure that relevant information is communicated to the workforce and that
feedback can be provided on issues of interest or concern ldquoToolboxrdquo training will generally be prepared and
delivered by the Project Engineers Site Foreman or HSE Advisor Toolbox training topics are to be delivered to
provide refresher information on the environmental induction topics and associated environmental procedures In
the event of environmental near misses or incidents or changes to procedures that could result in changed levels of
environmental risks Toolbox talks may be used to deliver updates
Toolbox topics likely to be required include
work methods and efficient use of plant and materials waste management minimisation and recycling dust control protecting waterways spills and leaks emergency response procedures wet weather procedures and inspections and Legislation updates Please refer to the Toolbox schedule for a library of HSE toolboxes to deliver over the life of the project
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1112 Recording of Training and Assessment
Records of training and assessment will be maintained and will be readily available for verification Records of
induction and training will include the topic of the training carried out dates names and trainer details
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE
The following documents provide further information in regard to this topic
Emergency Preparedness and Response Standard
EmergencyIncident Planning and Control
The site has in place an Emergency Response Management Plan (ERMP) that addresses emergency response control
and recovery based upon credible emergency scenarios as identified in the Site Risk Register The Emergency
Response Management Plan has been developed in accordance with Emergency Preparedness and Standard
13 HSE REPORTING AND INVESTIGATION
The following documents provide further information in regard to this topic
Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
Notifications and Reporting
The Project Manager is accountable for ensuring all necessary reporting and notifications take place including
Client notification Statutory notification Scheme notification Community Complaints
Notifications and reporting regarding incidents will be done in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure
1311 Internal
The Environmental Site Representative or their delegate will be responsible for reporting all incidents into Beakon
database Incidents reported into Beakon will be reviewed by the Responsible Manager and approved within five
working days or before month end in which the incident occurred
1312 Notification of Incidents to Sydney Metro
Sydney Metro will be notified of any Georgiou environmental incident as soon as reasonably practicable Copies of
the incident reports and investigations incident will be made available to Sydney Metro within 48 hours in
accordance with the Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
1313 Statutory Notifications
An incident is an uncontrolled event or violation with serious or potentially serious negative consequences to
people property reputation or the environment Under Section 148 of the Protection of the Environment
Operations Act 1997 (POEO Act) Georgiou has a duty to immediately report pollution incidents causing or
threatening material harm to the environment Material harm is defined in Section 147 of the POEO Act as
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lsquoinvolves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding
$10000 and this loss includes the reasonable costs and expenses that would be incurred in taking all reasonable
and practicable measures to prevent mitigate or make good harm to the environmentrsquo
Investigations
Investigations regarding the incident will be completed in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure and commence as soon as practicable (preferably
immediately) but within 24 hours
All environmental incidents would be investigated in such a manner that the following basic elements can be
established
identifying the cause extent and responsibility of the incident
identifying and implementing the necessary corrective action
identifying the personnel responsible for carrying out the corrective action
implementing or modifying controls necessary to avoid a repeat occurrence of the incident
recording any changes in written procedures required and
Advising regulatory authorities in accordance with licence conditions
Review and Communication of Incidents
Incidents will be reviewed to check that causal factors and root causes were identified and that the findings have
been effectively addressed through assignment of actions at the
Site monthly meetings Business Unit meetings OHS Committee Meeting (if established)
Actual and potential class 1 incidents will be reviewed by senior management to ensure adequacy of closeout HSE
incidents and their preventative actionslearnings will be communicated at pre-start meetings toolbox meetings
and through HSE alertsbulletins as per section 7
14 ENVIRONMENTAL REPORTING
1411 Monthly Reports
Georgiou is required to submit an Environmental Monthly Report to the client including the information specified
below as evidence of implementation of the Environmental Management Plan
Implementation of environmental management including environmental monitoring implementation of environmental controls training inspections and testing
Implementation of incident management including emergency response - details of all environmental incidents or emergencies including non-compliance with environmental procedures and near misses complaints implementation of incident and emergency response management and implementation of corrective action
Implementation of reviews - details of internal reviews audits and inspections undertaken to verify that on-site environmental processes and practices conform to the Environmental Management Plan
Waste Statistics and NGERs reporting
Site Meetings
The Site will hold a monthly HSEQ Management Meeting in accordance with the Health amp Safety Management Plan
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Project Performance Review
At completion of the Project the Project Manager is responsible for arranging a review of project performance
which will include HSE management performance and lessons learnt for the purpose of continually improving
Georgiou Management Systems This review will be in accordance with the Project Close-Out Procedure
15 AUDITING REVIEWS AND INSPECTIONS
The following documents provide further information in regards to this topic
Auditing Reviews and Inspections Standard
Inspections
1511 Environmental Inspections
The following inspections will take place on site
Environmental Weekly Inspections Detailed Hazard Inspections considering timingavailability of activities Site leadership field visits These inspections will be used a process to monitor onsite environmental performance and they will cover all applied environmental mitigation measures including water quality erosion and sediment control structures fuel and chemical storage and waste management Attendees for the inspections can include Sydney Metro Environmental and project team members Georgiou Environmental and project team members and Georgiou Senior and Executive Management when conducting a Field Leadership Visit (section 64) The Environmental Site Representative will record inspection findings on the inspection report If any maintenance andor deficiencies in environmental controls or in the standard of environmental performance are observed they will be recorded on the inspection Records will also include details of any maintenance required the nature of the deficiency any actions required and an implementation priority Any Sydney Metro Environmental Inspections will occur on the Sydney Metro Inspection record template ndash Appendix 10
Audits and Reviews
The following audits are scheduled for this site
Internal
AuditReview
Purpose Commencement On-going requirement
Site HSE Mobilisation Audit
Review achievement towards site start-up activities
8 weeks after mobilisation NA
Internal HSEQ audit
Determine compliance to the management systems and an assessment as the effectiveness of those requirements to meet our legal and other obligations
Within 6 months of project start up
6 monthly
Sydney Metro (or an independent environmental auditor) Audit
EampSMS and compliance with the environmental aspects of contract documentation including Construction Environmental Management Framework
Construction Periodic
to be confirmed
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The Project Environmental Site Representative will be the principal contact for external auditors wishing to audit
the Sitersquos environmental management systems The Project Environmental Site Representative will be responsible
for responding to any external audits findings
Monitoring
Environment monitoring will be undertaken to validate the impacts predicted for the Project The monitoring
requirements for required aspects are included in the relevant environmental management sub-plans (Appendices)
All environmental monitoring equipment shall be maintained and calibrated according to manufacturerrsquos
specifications and appropriate records kept
Where monitoring results are outside of the expected range and are directly attributable to the Project (ie are
influenced by factors under the direct control of the Project eg noise from construction equipment) the process
described below will occur
An analysis of the results by the Environmental Site Representative in more detail with a view of determining possible causes for the non-conformance
A site inspection by the Environmental Site Representative or delegate Advising relevant personnel of the problem Identifying and agreeing on actions to resolve or mitigate the non-conformance Implementing actions to rectify or mitigate the non-conformance
Corrective Actions
Corrective actions identified through hazards inspections incidents auditing will be recorded in Beakon Close out of corrective actions are monitored through Site meetings and reported to senior management through the monthly and quarterly board reports
16 DOCUMENT AND RECORD CONTROL
Georgioursquos Health Safety and Environment Policies Standards Procedures Safe Work Instructions References
Guidelines Forms Templates are all accessible via the Companyrsquos Intranet - GENIE GENIE will maintain the
current and only authorised versions for use
Environment Management documentation that has been specifically developed for the site will be controlled on site
and recorded on the Site Document Register in accordance with the Site Quality Management Plan
The Project Manager is the owner of this plan and will apply change control to ensure the most recent plans are
approved and executed
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17 APPENDICES
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Appendix 1 - Waste Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise spoil generation where possible The project will mandate 100 reuse or recycling (on or off-site) of usable spoil Spoil will be managed with consideration to minimising adverse traffic and transport related issues Spoil will be managed to avoid contamination of land or water Spoil will be managed with consideration of the impacts on residents and other sensitive receivers Site contamination will be effectively managed to limit the potential risk to human health and the environment Minimise waste throughout the project life-cycle Avoidance of unnecessary resource consumption Resource recovery (including reuse reprocessing recycling and energy recovery) and Disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Project Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Training and Competency
As part of the Site Induction workers will be informed of
- The types of waste generated on site
- How the wastes are to be handled stored and disposed of Personnel responsible for clean-up of spills will be provided with instruction on how to use the sites
spill kits Personnel handling hazardous materials will be provided training to read and understand the SDS
Project Manager
Unidentified Waste Wastes that cannot be positively identified (ie unlabelled liquids potential asbestos) will be tested
before handling and disposal Any material that is unknown should be considered hazardous until positively identified
Project Engineer
Handling
Where practicable dust generating rubbish and debris will be removed to minimise dust release into the atmosphere
Handling of waste will be done in accordance with relevant state or local by-laws using suitable personal protective equipment
Project Engineer
Storage
Containers used for storage are not to be opened handled transported or stored in a manner that may rupture the container
All waste will be stored in waste receptacles and removed off site by a licensed contractor on a periodic basis
Dedicated recyclable and hazardous receptacles will be labelled Wastes stored on site will be stored in a manner to prevent the attraction of vermin and native
wildlife Waste is to be stored away from access and egress routes
All
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Appendix 1 - Waste Management Sub Plan Responsibility
The quantity and volume of wastes stored on site may be minimised where reasonably practical to reduce the risk to health safety and the Environment
Project Managers will be responsible for identifying and obtaining any required licenses andor permits to store wastes
Disposal
In deciding how to dispose of waste generated on site consideration will be given to reducing reusing or recycling waste where reasonably practical to minimize the volume sent to landfill Where reuse or recycling is not a feasible option the waste will be sent to a facility capable of accepting the waste
The burning of any type of wastes will not be permitted on any Georgiou site The use of stormwater drains for the disposal of waste is prohibited The disposal of waste will be done in a manner to prevent any damage to the environment
Project Engineer
Transportation
The removal and transportation of hazardous waste controlled waste (eg asbestos hydrocarbons and sewage) for disposal will only be conducted by licensed carriers Licensed operators will be engaged in accordance with the Procurement Procedure
Before a hazardous waste controlled waste is transported off site a waste tracking receipt will be collected from the operator as verification that the waste was correctly transported off site and to identify the proposed location for disposal The receipt will be scanned and filed into the DMS and linked to the Site Waste Register A copy of the receipt will be held for a minimum of 3 years
The transportation of other wastes for disposal will only be conducted if the load is covered or there is no risk of loaddebris falling and the load is disposed of at a registered landfill
Project Manager
Spoil
Although the Project would require the importation of fill material the excess spoil would be generated including from the following sources
Soils ndash This includes any topsoil and natural subsoils (ie soils between the topsoil and underlying bedrock)
Natural rock ndash This material would be generated from excavation of sandstone bed rock if required Road construction material ndash This would include material generated from the demolition of the
existing roads such as asphalt concrete geotechnically stabilised road sub-base and base material
Project Engineer
Spoil Classification
Spoil generated during the Construction of the Project will be firstly assessed for reuse in the project Should it not be suitable for onsite reuse it will be assessed in accordance with the Sydney Metro Classification Procedure (Appendix 1A) It will firstly be assessed against the requirements for Virgin Excavated Natural Material (VENM) detailed within the Protection of the Environment Operations Act 1997(POEO Act)
Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
If the material is not deemed to be VENM an assessment of the suitability of any current general resource recovery exemptions issued under the Protection of the Environment Operations (Waste) Regulation 2014 will be undertaken Current general resource recovery exemptions that may apply to the Project are
The excavated natural material exemption 2014 The excavated public road material exemption 2014 Spoil that cannot be re-used onsite or offsite under any of the exemptions stated above or classified as VENM will require waste classification in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (EPA 2014) prior to offsite disposal at an appropriately licensed facility
The management of spoil generated from the Project will be guided by the hierarchy detailed below
Rank Control Measure Implementation Example Potential to implement on Project
1 Avoid and reduce spoil
generation Reduce the amount of spoil being
generated through design and construction methodology
Limited
2 Prioritise reuse of contaminated
spoil onsite vs clean spoil Identify areas with lower risk of
contamination to spoil offsite as this will result in lower waste disposal costs for project
GSW and Contaminated Spoil is to
be utilised as fill on the project
prior to the use of excavated
sandstoneVENM The project will
produce excess spoil and the
priority is for this excess to be
sandstoneVENM
3 Reuse within Project Prioritise reuse of more contaminated
spoil onsite vs less contaminated spoil Reuse in the Project to fill
embankments and mounds within short haulage distance of source
Restoration of any pre-existing contaminated sites within the Project boundaries
Reuse as a feed product in Construction materials (eg concrete)
Preferred but dependant on area
available
Project Manager Project Engineer Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
4 Reuse for environmental works Reuse in revegetation and
rehabilitation projects Reuse in operational noise mitigation
works
Preferred as stockpiling on site is
restricted
5 Reuse on other development
projects Reuse for fill embankments and
mounds on projects within an economic transport distance from site
Preferred as stockpiling on site is
restricted
6 Reuse for land restoration Reuse for land reclamation or
remediation works Reuse to fill disused facilities eg
mines and quarries to enable ecological rehabilitation or other ecologically beneficial end use
Preferred as stockpiling on site is
restricted
7 Reuse for landfill management Reuse to cap completed landfill cells Reuse in daily covering of landfill
waste
Limited
8 Dispose offsite as waste Disposal of excess spoil as waste at an
approved facility licensed to receive that material
Potential but not preferred
Hazardous Waste - General
Hazardous wastes will be stored in sealed containers where practical and clearly labelled with waste type
Hazardous waste receptacles will be maintained in good condition to prevent leaks or spills Offensive odours should not be generated at any time when stored Hazardous wastes with a significant risk to human health and safety will be stored in containers that
comply with relevant legislation and guidelines Hazardous wastes will not be permitted to accumulate to a level that presents an unreasonable risk
to human health safety or the environment Controlled waste storage will be suitably contained to ensure debris does not travel beyond the boundary of the premise
Hazardous waste will be stored and segregated in accordance with their SDS Hazardous waste will be risk assessed to ensure they do not contaminate or interact with goods that are incompatible Where there may be a risk of fire hazardous waste will be segregated to prevent storage incompatibilities
Hazardous liquid waste will not be permitted to enter the environment
All
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Appendix 1 - Waste Management Sub Plan Responsibility
Design considerations for secondary containment will be given to the storage of liquid wastes to contain any potential spills Hazardous waste will be stored onin bunded palletsareas which will be compliant with AS1940-2004 443 (the bunded palletarea must have the capacity to contain 110 of the largest container
Hazardous waste such as batteries hydrocarbons sewage and asbestos will only be handled for final disposal recycling by certified waste removing contractors Sewage waste not plumbed directly into the main sewerage system will be contained within holding tanks on site compounds and emptied on a periodic basis or as required by a licenced contractor
Hazardous Waste - Batteries
Automotive and lead-based batteries will be stored in a manner that does not contaminate the natural surrounding environment This may include storage on bunded palletsareas on concrete hard stand or on any other sealed surface
All
Hazardous Waste - Asbestos
The disposal processes for asbestos will involve independent competent persons Identified ACM (Asbestos Contaminated Material) will be clearly marked out and controls put in place
to prevent contamination into surrounding areas
Project Manager
Hazardous Waste - Sanitary Sewage Waste
Sewage waste will either be plumbed directly into the main sewerage system or contained within holding tanks on site compounds and emptied as required
Sewage waste stored in bunded tanks underneath the toilets will be emptied by a licensed contractor on a periodic basis
Sanitary wastes will be stored in solid containers and clearly labelled for identification Sanitary wastes will not be re-handled after disposal to minimise the exposure and risk of double
handling Sanitary conveniences will be calculated based on the number of workers based on the site and meet
legislative requirements Sanitary waste will be stored away from food sources or where food is served Controls to prevent offensive odours to the public and workers will be implemented
Project Engineer
Recyclable Waste
On site paper and cardboard and scrap metal will be segregated to be collected and transported to a recycling facility
Green waste will be mulched and stockpiled with topsoil for use in revegetation Aggregate will be segregated during cut and fill operations for re-use
Project Engineer
Waste Water Any waste water or liquids must be disposed of to an approved receptacle and stored within an approved bunded location until they are removed from site
Project Engineer
Putrescible Waste Putrescibles waste will be stored into general waste containers that prevent the release of debris and leachate
Project Engineer
Clinical Waste In the event that clinical waste has been found the following control may be employed Project Engineer
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CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
Syringes and needles found on site will be stored in a clearly labelled solid sealed container to prevent access to contents They will be disposed of at a licenced provider
Clinical wastes will not be re-handled after disposal to minimise the exposure and risk of double handling
Concrete
Kibbles Concrete truck are to be washed out into a designated bunded area When the concrete is dried it will be disposed of with general waste
At no point will any Concrete truck or kibble be permitted to wash out at any point other than the designated area with all the associated controls in place
Project Engineer
Weekly (VisualDocumented)
DHI Environment to be completed via Beakon HSE Advisor
Reporting HSEQ Monthly Management Meeting Monitor and record the volumes of waste and the methods and locations of disposal Maintain records of all required waste dockets and receipts and provide to Sydney Metro monthly
Project Manager
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Appendix 1A ndash Sydney Metro Waste Classification Procedure
Unclassified
Unclassified
Waste Classification Procedure
SM-20-00040677
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Hugh Chapman Associate Director Environment Operations Customer amp Place-Making
System Owner Carolyn Riley Director Environment Sustainability amp Planning
Status Final
Version 30
Date of issue Pending
Review date Pending
copy Sydney Metro 2020
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 2 of 14
SM-20-00040677 Waste Classification Procedure V30
Table of contents
1 Introduction 3
11 Purpose and scope 3
12 Definitions 3
13 Spoil Management Decision Framework 5
14 Spoil Handling and Segregation 5
15 Typical Application of the Framework 6
16 Unexpected Finds Protocol 7
17 Accountabilities 14
2 Related documents and references 14
3 Superseded documents 14
4 Document history 14
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 3 of 14
SM-20-00040677 Waste Classification Procedure V30
1 Introduction
11 Purpose and scope
This framework describes the approach to classifying spoil and demolition materials generated during works in accordance with environmental legislation and guidelines
This framework considers the reuse of materials on site the beneficial reuse of materials transported off site as waste (for example as virgin excavated natural material [VENM]) the recycling of materials at offsite facilities and the offsite disposal of materials when reuserecycling is not achievable
The framework considers only the compliance and classification elements of the spoil management process and does not consider all of the practical issues associated with construction geotechnical properties of the spoil or market forces and costs that influence the reuse potential of spoil or other wastes
Section 16 of this framework outlines an Unexpected Find Protocol (UFP) to be implemented should unexpected potential contamination be found during works
12 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined within the SM-17-00000203 Sydney Metro glossary Acronyms specific to this document are listed below
Definitions
2014 Waste Regulation
Protection of the Environment Operations (Waste) Regulation 2014
CLM Act Contaminated Land Management Act 1997
Contamination
As defined in the CLM Act ldquomeans the presence in on or under the land of a substance at a concentration above the concentration at which the substance is normally presenthellipin the same localityhellipthat presents a risk of harm to human health or any other aspect of the environmentrdquo
Demolition materials
Materials such as concrete bricks and timber resulting from the demolition of buildings and structures Most demolition materials are pre-classified as General Solid Waste (non-putrescible) (see definition below) under the NSW EPA (2014) Waste Classification Guidelines However some demolition materials such as asbestos have other classifications as described below
EIS Environmental Impact Statement for the project which assesses potential environmental impacts and mitigation measures in accordance with the EPampA Act (see below)
ENM Excavated Natural Material as defined in The excavated natural material order 2014
being excavated material that is at least 98 (by weight) natural material that does not meet the definition of VENM (see below)
EPA NSW Environment Protection Authority
EPampA Act Environmental Planning amp Assessment Act 1979
EPL
Environment Protection Licence as may be held by an owner or operator of a premise licensed to receive process recover or store waste The EPL will contain a number of conditions that must be met by the holder These will specify the type(s) of waste the facility is permitted to receive process recover or store and include pollution prevention or monitoring requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 4 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Fill Soil and any associated extraneous materials (such as demolition wastes industrial by-products and refuse) imported to and placed at the location
GSW
General Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines GSW may be classified as putrescible or non-putrescible depending on the content of putrescible organic material Spoil and demolition materials are typically non-putrescible
HW
Hazardous Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines HW must be treated prior to disposal to landfill HW is typically
spoil that is contaminated with chemicals at concentrations that exceed all screening criteria specified in Step 5 of the Waste Classification Guidelines
Naturally Occurring Soil
Any soil which has not been significantly disturbed by human activities
NEPM National Environmental Protection (Assessment of Site Contamination) Measure 2013
POEO Act Protection of the Environment Operations Act 1997
Recycling Material that is removed from the project site (thereby becoming Waste) and is deposited at an appropriately licenced recycling facility for processing prior to reuse by others
REF Review of Environment Factors which addresses the likely environmental impacts and details protective measures to manage against any adverse effects in accordance with the EPampA Act
Remediation
As defined in the CLM Act remediation of contaminated land includes
(a) preparing a long-term management plan (if any) for the land and
(b) removing dispersing destroying reducing mitigating or containing the contamination of the land and
(c) eliminating or reducing any hazard arising from the contamination of the land (including by preventing the entry of persons or animals on the land)rdquo
Remediation is the act of mitigating exposure to contamination in its original location The process of remediation can generate spoil that may be subject to reuse within the project area (where that reuse is adequately controlled in order to mitigate exposure risks) or the removal of contaminated spoil for treatment andor disposal off site
Reuse offsite
Material to be reused by application to land at a location outside of the project site without the need for processing prior to reuse Material meeting the definition of VENM or ENM or material that is subject to an RRO and RRO are suitable (from an environmental perspective) for reuse at remote sites where all requirements of the POEO Act and CLM Act are met
Reuse onsite
Material that is excavated on the project site and reused on the project site Material to be reused onsite is not defined as Waste and does not require classification in accordance with NSW EPA (2014) Waste Classification Guidelines The material must be suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and must not cause pollution under the POEO Act If transport to another part of the project area requires material to be taken outside the site boundary temporarily this must be undertaken in accordance with the EIS or following consultation with relevant regulators
RRE Resource Recovery Exemption contains the conditions that must be met by consumers of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RRO Resource Recovery Order contains the conditions that must be met by generators and processors of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RSW Restricted Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines An example of RSW is spoil that is contaminated with chemicals above the criteria specified in Step 5 of the Waste Classification Guidelines
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 5 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Special Waste
As defined in the NSW EPA (2014) Waste Classification Guidelines a class of waste with
unique regulatory requirements Asbestos or any waste containing asbestos (eg spoil containing any fragments of asbestos cement sheeting) is Special Waste If Special Waste is mixed with RSW or HW (eg spoil classified as RSW that also contains asbestos) then the waste must be managed in accordance with both classifications
Spoil Soil or rock material generated from excavation activities
UFP Unexpected Find Protocol
VENM Virgin Excavated Natural Material as defined in Schedule 1 of the POEO Act being excavated natural material not mixed with any other waste and not from a contaminated area
WARR Act Waste Avoidance and Resource Recovery Act 2001
Waste Spoil or demolition material that has been taken off site which may be classified as Special Waste GSW RSW or HW
13 Spoil Management Decision Framework
Figure 1 provides a high-level flowchart for decisions regarding the fate of spoil generated on the site As reflected in Figure 1 the preferred spoil management hierarchy for the project listed from most preferred to least preferred is as follows
1 Spoil is reused within the project boundary
2 Spoil is beneficially reused at an appropriate offsite location
3 Spoil is recycled at an offsite licenced facility
4 Spoil is disposed to landfill
The approach to spoil classification is further detailed in Table 1 Table 1 describes the criteria information inputs and control measures required to be applied when reusing spoil on site reusing spoil offsite recycling spoil offsite or disposing of spoil
The framework does not account for the practical site based engineering or financial constraints associated with the hierarchy These must be addressed during delivery and the most appropriate efficient and sustainable method of spoil management adopted
14 Spoil Handling and Segregation
Careful excavation handling and segregation of spoil is critical to ensuring that materials with varying classifications are not mixed (cross-contaminated) and are not reused recycled or disposed in a manner inconsistent with their classifications
Appropriate segregation is also important in controlling the costs of spoil disposal to landfill noting that the inadvertent mixing of materials with low concentrations of contaminants with materials containing higher concentrations typically results in a higher classification and higher disposal rate (financial) being applied to all of the materials
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 6 of 14
SM-20-00040677 Waste Classification Procedure V30
The following processes are to be applied when excavating handling and segregating all spoil (for clarity a reference to a ldquogeological unitrdquo includes units or different layerstypes of Fill)
Spoil from each geological unit should be classified separately using sampling data that relates only to that unit Classification sampling may be performed in-situ (prior to excavation) or ex-situ (following excavation)
Spoil from each geological unit (as described in Part 4 below) should be excavated segregated and stored separately from spoil arising from other geological units
Excavations should be carefully monitored for visual indications of contamination such as stained soils odorous soils or the presence of anthropogenic waste materials Any spoil containing visual indicators of contamination will be excavated segregated and stored separately from other spoil Where unexpected contamination is identified an appropriate unexpected finds procedure must be implemented to manage potential human health or environmental risk (refer to Part 5)
Each spoil stockpile should be treated as a ldquobatchrdquo with its classification data clearly identifiable and will be handled stored transported and reusedrecycleddisposed as a batch Spoil stockpiles will not be managed in a ldquocontinuousrdquo manner with portions added taken away or mixed over a period of time and
Spoil should be tracked from cradle to grave to ensure a complete and accurate record of movement from the point of excavation to the final point of placement For clarity this includes tracking of spoil movement on the site as well as off the site
Tracking of spoil movement (whether the spoil is waste or not) requires must include written records of spoil excavation handling transport storage and placement via a centralised tracking system Personnel must be suitably trained in the use of the system and sufficient detail must be recorded and retained such that material typesclassifications volumes and location are tracked from the time the material is excavated until it is placed permanently (onsite or offsite) This includes accurate records of any interim handling or placement (such as stockpiling or treatment) Stockpiles onsite are to be clearly labelled at all times Tracking information is to be kept on-site and be available on request
15 Typical Application of the Framework
This section provides some practical guidance in implementing the spoil classification framework (further detailed in the attached Figure 1 and Table 1
An explanation of the likely classification of spoil excavated during works based on typical geological units is provided below
Fill ndash Fill is imported materials which have been placed on the site at some time in the past Fill generally exists at depths ranging up to 3m below ground surface on developed areas and brownfield sites Fill may exist to depths exceeding 20m in reclaimed lands landfill sites former brick pits footings and similar Fill cannot be classified as VENM Fill has an increased likelihood of being contaminated (compared to natural soils) and will predominantly be classifiable for offsite disposal as GSW Special Waste RSW or HW Some materials such as road base or crushed concrete may be recoverable under generic or specific RRERRO arrangements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 7 of 14
SM-20-00040677 Waste Classification Procedure V30
Naturally Occuring Soils ndash Soil which has not been significantly disturbed by human activities Naturally occurring soils may be residual soil sediments aeolian or other In the majority of cases naturally occurring soils will be classifiable as VENM or ENM for offsite reuse However where overlying contamination in Fill has leached and caused contamination of underlying natural soils where point sources of contamination are present (such as industrial facilities or fuel storage facilities) or where significant groundwater contamination has migrated into the area offsite reuse may not be appropriate and other classifications such as GSW RSW or HW may be applicable Where evidence of potential contamination exists spoil is required to be sampled and classified in accordance with NSW EPA (2014) Waste Classification Guidelines
Rock ndash Rock in-situ will in the majority of scenarios be classifiable as VENM or ENM unless significant contamination is present in overlying soils or significant contamination has migrated to the rock within groundwater Where the excavation of rock involves the use of additives (for example to facilitate tunnel boring) the material would no longer be classifiable as VENM or ENM and would instead likely be classifiable as GSW A project specific RRERRO would then be required to allow for offsite reuse
The type of material (ie geological unit) excavated during works will provide guidance on implementing the spoil classification framework in regard to reuse opportunities
Reuse Onsite ndash Any of the material excavated which is Fill a Natural Occurring Soil or Rock may be suitable for reuse on the project site Wherever reuse onsite is to occur the material does not require classification in accordance with the NSW EPA (2014) Waste Classification Guidelines Instead the material must be validated as being suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and the material must not cause pollution under the POEO Act For clarity the classifications GSW RSW and HW have no direct relationship to the potential for reuse of materials on the project site
Reuse Offsite ndash With the exception of Fill it is likely that the majority of spoil will be suitable from an environmental perspective for reuse off-site Specifically all VENM ENM and material to which an RRERRO apply will be suitable (from a legislative and environmental perspective) for reuse at an offsite location
16 Unexpected Finds Protocol
This section provides guidance on implementing the Unexpected Finds Protocol (UFP) which is detailed in the attached Figure 2 The purpose of the UFP is to provide a clear procedure in the event of an unexpected find of contamination or potential contamination The UFP is only to be implemented following an unexpected find The handling of known contamination should already be addressed in construction and environmental management plans
Key indicators of potential contamination include (but are not limited to)
Fibrous cement or other asbestos containing materials
Discolouration of soil
Odours from soil andor groundwater
Buried drums or underground storage tanks and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 8 of 14
SM-20-00040677 Waste Classification Procedure V30
Oily sheen on water
Should any of the above be discovered and is considered to be unexpected then the UFP in Figure 2 will need to be implemented
An explanation of key actions within the UFP is provided below
Notifying the Site Supervisor ndash Site Supervisor or an appropriate delegate are to be made aware of the find immediately
Securing the affected area ndash This includes restricting access to the area and implementing appropriate environmental controls around affected area in minimise risk to the environment and human health Examples of controls include barricading the affected area the diversion of water to minimise potential spread via surface water runoff covering the area re-burying andor wet-down Environmental controls are to be implemented appropriately in regard to the contamination source and site conditions
Emergency Response ndash In the event that the find presents andor creates health or environmental concerns which would require an emergency response call 000 andor implement the projects incident response and reporting process
Notify Principal or Sydney Metro ndash The Principalrsquos Representative and the Environmental Representative must be notified of the unexpected find
Recommence works ndash Works can be recommenced in an alternate area where practicable and where it is safe to do so
Assessment ndash The potential for any ongoing risk to the environment or human health during construction or operation of the site and whether or not the agreed scope appropriately manages the contamination will need to be assessed by a competent and qualified person (ie a contaminated land specialist or in the case of asbestos a hygienist or asbestos assessor)
Material Classification ndash Contaminated materials which are to be removed from the site are to be classified in accordance with the NSW EPA Waste Classification Guidelines and the Spoil Classification Framework detailed in this document See Figure 1 and Table 1
An unexpected find may result in additional works being required for the remediation of contaminated materials which fall outside of the current scope of the project Any such works will need to comply will all relevant legislation and guidelines and will require appropriately qualified persons to prepare the methodology and controls Any such works will require approval from Sydney Metro
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 9 of 14
SM-20-00040677 Waste Classification Procedure V30
Spoil classification process flow
Syd
ne
y M
etr
oN
SW
EP
A W
aste
Gu
ide
line
s C
lassific
ation
ndash P
art
1 (
20
14)
Syd
ne
y M
etr
o
Additional inputs or information requirementsProcess
Is there an opportunity to re-use the spoil
on site
Is there an opportunity to use the spoil at
an offsite locat ion
Can the spoil be recycled
The spoil must be classif ied in accordance with the NSW Environmental Protection Authority (EPA) Waste Classification
Guidelines
1) Is the waste Special Waste ie does the waste contain asbestos Refer to the Protection of the Environment Operations
(POEO) Act and Waste Regulation Part 4 Management of Special Waste
2) Is the waste Liquid Waste
3) Is the waste pre-classified
4) Does the waste have hazardous
characteristics
5) Classify by chemical assessment Waste generators must chemically assess their waste in accordance with Step 5 of the Waste
Classification Guidelines to determine the waste s classification where it has not been classified under Steps 1 to 4 of the Guidelines
Re-use onsite Cost time and engineering requirements to be
considered as well as environmental risks before placement
Re-use offsite To allow offsite use the material mist be classifiable
VENM ENM or be subject to Resource Recovery Exemption and Order
No matter the classification the offsite location must conf irm it can legally
accept the spoil
Recycle offsite The spoil must go to a licenced treatment facility and
must meet the specific requirements of that facilities licence
Liquid waste The waste is not spadable andor becomes free-flowing
at or below 60 degrees Celsius or when it is transported
Pre-classified waste Refer to NSW EPA Waste Classif ication guidelines
for pre-classificat ions of Hazardous Wastes General Solid Waste
Dangerous goods Meets Dangerous Goods Classificat ion for classes 1
2 41 42 43 5 61 and 8
The waste has been classified in accordance with the Waste Guidelines and is ready to be transported offsite Prior to transport
the following must be confirmed and all relevant requirements met
Is the landfill or facility licenced to accept the type of waste
Is the waste subject to waste tracking requirements under the POEO Act or any other regulation
Is the transport contractor licenced to carry the waste as classified
6) Is the waste putrescible
Sampling under Step 5 must meet the requirements of the NSW Waste Classification Guidelines
Sampling can be in-situ (ie prior to excavat ion) or ex-situ (from stockpiles after excavation) but in both
scenarios
Sampling density is to as a minimum meet the sampling densities recommended in the Victorian
EPA soil sampling guidance
httpsrefepavicgovau~mediaPublicationsIWRG702pdf
Analytes must reflect the contaminants of concern likely to be present at the site and as a
minimum consider Asbestos Metals TPH BTEX PAHs and PFAS Other side specific
contaminants may include hexavalent chromium PCBs pesticides etc
If retained onsite the Waste Classif ications Guidelines do not apply BUT the material must be suitable
from a human health and environment perspective to remain This requires assessment against the
NEPM and may include visual inspections or sampling and analysis The input of an appropriately
qualified professional is required prior to the re-use of any fill or potentially contaminated spoil
Once the spoil is removed from the site it becomes Waste All waste must be transported to a facility
that is licenced to accept it VENM ENM andor Resource Recovery ExemptionsOrders impart specific
requirements regarding assessment sampling analysis classificat ion and use of these types of spoil
The requirements regarding sampling and record retention must be adhered to
Once spoil is removed from the site it becomes Waste All Waste must be classified in accordance with
the NSW EPA Waste Classification Guidelines and be transported to a facility licenced to accept it
Note that whether or not the asbestos is present further classif ication is required under Steps 2 to 6 of
the EPA Waste Classification Guidelines
Yes or No
General solid waste restricted waste or hazardous waste
No
Yes
Yes
Yes
Yes or No
Yes
Yes
Yes
No
No
No
No
No
Figure 1 Spoil Classification process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 10 of 14
SM-20-00040677 Waste Classification Procedure V30
Table 1 Spoil Classification process flow
Decision Criteria InputsData ControlsReview
Reuse of the material on or within the approved project area
Most preferred option under WARR Act and Sydney Metro environment and sustainability policy
Suitable placement locations have been identified
The material is suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and will not cause pollution under the POEO Act
The spoil meets engineering requirements for placement locations
Where spoil or demolition materials require treatment or processing onsite to treat contaminants or to amend engineering properties the need for an EPL must be assessed and resulting conditions met
If transport to another project area is required and such transport requires material to be taken outside the site boundary temporarily this will need to be appropriately address in the projectrsquos environmental approvals (eg EIS or REF)
Appropriate risk-based assessment confirms the material is suitable for proposed final land use from a contamination perspective
Appropriate geotechnical assessment confirms the material is suitable for proposed final land use
EPL if required for onsite processing
Complete material tracking record including documentation of final placement location
Environmental controls to prevent cross-contamination of material prior to placement and pollution during placement
Training of relevant personnel in spoil reuse framework and underlying management plans
Audits of sampling data tracking and placement information and reuse locationssites
Long-term management plan and monitoring andor Environmental Protection Licence under the POEO Act (if required)
Reuse of the material off site
Spoil becomes waste under POEO Act once removed from site
Material meets VENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Assessment confirms material is VENM Sampling may be required depending on nature of material and source
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 11 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Material meets ENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Sampling conducted in accordance with ENM RRO prior to transport off site and results meet criteria
Statement of RRO compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
RRO records maintained for six years including details of sampling plan sampling results quantities supplied and receival sites
Material does not meet VENM or ENM definitions but has potential for reuse under a specific RRORRE An example is tunnel spoil containing additives
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Consult with the EPA prepare and submit application for specific RRORRE Characterisation data will be required for the application
Once specific RRORRE is granted obtain sampling data (and meet any other specific obligations) in accordance with conditions and confirm results meet criteria prior to transport off site
Statement of compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
As for reuse on site plus
Statement of compliance provided to each receival site
RRO records maintained for six years
Recycling off site
Material (spoil and demolition materials) becomes waste under POEO Act once removed from site
Material meets the EPL andor planning approval requirements for the receival facility and has value for recycling
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Assessmentsampling confirms the material meets the receival facility EPL conditions (typically GSW)
Appropriate EPL held by receival facility
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 12 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Disposal off site
Material does not fit one of the above categories andor suitable reuse or recycling locations could not be identified
Least preferred option
Waste is classified as GSW RSW or Special Waste
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by receival facilities
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Waste is classified as HW
Suitable treatment facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by treatment facilities
Treatment facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking treatment and disposal documentation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 13 of 14
SM-20-00040677 Waste Classification Procedure V30
Unexpected find process flow
Flo
w
Process Additional information
Unexpected potential
contamination find1 Immediate ly stop works
2 Notify the Site supervisor 3 Secure the affected area
Is an emergency
response required for any
health or environment
concerns
4b Notify Principal s Rep and
Environmenta l Rep
4a Trigger pro ject incident response and
reporting mechanism andor call 000
5b Inform the
Principal s Rep
Does the
contamination
present and ongoing risk to
environment or human
health dur ing
construction or
operation
Will the
agreed scope result in the
complete removal of the
contamination
Does the
disposal of the unexpected
find result in addi tional costs
to the Principa l
5a Materials to be classified in
accordance with the NSW EPA Waste
Classification Guidel ines (2014) (see
Figure 1 Spoil classification flow)
6a Inform the
Principal s Rep
6b Dispose of the material in
accordance with all relevant legislation
the project Spoil Classification amp
Management Framework and any
relevant directions from Sydney Metro
6c Develop
appropriate
methodology
plans to
manage the
contamination
and implement
Indicators of potentia l
contamination include
Fibre cement or other asbestos
containing materials
Discolouration of the so il
including staining andor
discolouration
Odours from soil or
groundwaterseepage
Bur ied drums and storage tanks
Oily sheen on water
Note this does not include on-
site contamination
Securing of the area should restrict
access to the affected area This
should include as a min imum
environmenta l controls around the
affected area to contain
contaminated material including
diversion of water to minimise
potential spread via surface water
runoff
Where contaminants are likely to
result in odours vapours or
airborne asbestos fibres immediate
action should be taken to prevent
their release (eg cover re-bury or
wet-down
Recommence works in alternate
area where practicable and safe
Assessment to be conducted by
suitably qualified and experienced
person
Methodology controls and p lans
are to be prepared by a sui tab ly
qualified and experienced person
and approved by Sydney Metro
prior to being actioned
Works may continue in the affected
area when it is safe and where
works will not exacerbate
contamination or hinder future
remediation works
Note Remediation of contaminated
materials may include (but not be
limited to) capping of
contaminating treatment andor off-
site disposal All associated
activities with the remediation of
contaminated materials such as
excavation handling stockpiling
and transport are to be addressed
an prepared methodology and
controls
Yes
No
Yes or unsure
No
No or unsure
Yes
Yes
No
Figure 2 Unexpected find process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 14 of 14
SM-20-00040677 Waste Classification Procedure V30
17 Accountabilities
The Director Program Sustainability Environment amp Planning is accountable for this document including approving the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document
2 Related documents and references
3 Superseded documents
4 Document history
Related documents and references
Entries should be formatted with IMSiCentral number followed by correct title and hyperlinked eg
SM-17-00000203 Sydney Metro glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
02 Pending New IMS document
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise pollution of surface water through appropriate erosion and sediment control Minimise leaks and spills from construction activities Maintain existing water quality of surrounding surface watercourses Source construction water from non-potable sources where feasible and reasonable
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp Targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Erosion and sediment measures would be implemented in accordance with the principles and
requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any significant water aspects and Site specific controls to minimise potential impacts
Emergency Management Team members will be provided training to respond to a discharge of contaminated water or hazardous substances into the environment
Project Manager
Notification The Site will not modify or remove any water utility assets without their approval Notification
of approval will be received by Sydney Water with a copy of authorisation Notification to the asset owner will be given as per their conditions of compliance
Project Engineer
ESCP
ESCPrsquos will be developed by construction staff with demonstrated skills and experience in preparing the ESCP in accordance with the Blue Book Guidelines ESCPrsquos plans will include but not be limited to
Title date and revision number Contours and clean and dirty water drainage paths Site layout including the location of access roads ancillary infrastructure Sediment basins and designated pump out locations Limit of disturbance Location and type of control measures Timing and order of control installation in sequence with work activities Specific construction details
Environmental Site Representative
Erosion and sediment control
The following key principals will apply to all areas and stages of construction on the Project
Minimise extent and duration of disturbance Control stormwater flows onto through and from the site
Project Engineer Supervisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Erosion control strategies to prevent on-site damage Sediment control strategies to prevent off-site damage Progressive stabilisation following completion of work areas Inspection Maintenance and Improvement of control measures throughout the site construction
until the site is successfully stabilised
Dewatering
Sediment laden water accumulated in trenches or excavations must not be discharged directly or indirectly to any stormwater natural watercourse or offsite
A suitable location to discharge will be identified considering site slope proximity to drainage lines soil permeability and ground cover ie well established existing vegetation
The water must be tested prior to any discharge by the Environmental Site Representative and may require treatment prior to discharge
Project Engineer Environmental Site Representative
Groundwater
Groundwater is unlikely to be intercepted during any excavation within the road footprint Deeper excavations for stormwater trenching may intercept groundwater however a method of pipe installation during low tide will removed the need for dewatering
If groundwater dewatering is required then a dewatering management plan should be developed
PlantVehicle Maintenance
The maintenance and cleaning of any vehicles plant or equipment must not be carried out in areas from which contaminants can be released into stormwater or natural watercourses
All
Acid Sulfate Soils
Prior to excavation for the Stormwater trench which will occur approximately 25m bgs testing would be carried out to determine the presence of actual andor potential acid sulfate soils
Testing for the presence of ASS shall be undertaken at proposed excavation locations and shall apply the following methodology Dig holes to the proposed depth of excavation conduct ASS pH field tests on material from the hole at 05m depth intervals and then conduct a SPOCAS plus or chromium suites on the most acidic ASS pH field test sample from the hole The testing and sampling to be undertaken in accordance with ASSMAC Laboratory method Guideline Aug 1998
If actual andor potential acid sulfate soils are present within the proposed area of excavation then an Acid Sulfate Management Plan will be developed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Project Engineer Environmental Site Representative
Water Discharge requirements
An Environmental Protection Licence (EPL) is not required for the project however Georgiou will test any water to be discharged offsite in accordance with the water quality parameters specified in the Blue Book (Landcom 2004) and ANZECCARMCANZ (2000) guidelines prior to discharge to ensure an incident of pollution to surrounding environment does not occur from the Project
Environmental Site Representative
Monitoring of Discharges
Waters released from site must be sampled prior to release The samples taken must be representative of the water being discharged
Project Engineer HSE Advisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Environmental Inspections amp Monitoring
The results of monitoring shall be recorded Environmental Site Representative
Daily (Visual) and weekly (documented)
Daily visual observation for evidence of water quality impacts including turbidity or hydrocarbon spills
Weekly inspections using Georgiou Beakon inspection form
Supervisor HSE Advisor
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report Dewatering records including all water quality test results
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 46 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Objectives and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise leaks and spills from construction activities All chemicals correctly stored and bunded in accordance with legislative requirements Any spills are controlled contained cleaned up and reported
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General All fuels chemicals and hazardous liquids would be stored in accordance with Australian
standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required to
manage hydrocarbon and chemical storage and use including
- Use and understanding of safety data sheets (SDS) - Use of personal protective equipment (PPE)
Emergency Management Team members will be provided training to respond to a hazardous substance spill
Project Manager
Register
All dangerous goods or hazardous substances must be approved by HSE Advisor prior to use on the site
ChemAlert will be used to register all site dangerous goods and hazardous substances manage electronic SDS and conduct and record product risk assessments
Consideration will be given to substitute products assessed as a high risk with a product of lesser risk
Project ManagerSupervisor
Transportation Containers holding hazardous substances or dangerous goods will be stored upright and secured
during transport Containers are not to be dropped tip or rolled sides The transportation of dangerous goods will be by licenced carriers
Project Engineer
Handling amp Use
Handling of products will be subject to the following requirements Hazardous substances and dangerous goods will be clearly labelled Current SDS (no older than 5 years) will be readily available when handling Controls stipulated in the SDS to be applied when handling and using Used oily rags oil filters and other left over hydrocarbon and chemical products hall be stored in
a designated area and removed by licensed carriers to either recycle or otherwise dispose of
All
Refuelling Refuelling of plant and vehicles must be monitored continually and conducted in designated areas
away from sensitive receptors
All in field refuelling must have a spill kits available to contain and clean up any spills
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Spill kits shall be stored in designated amp labelled containers and include a stock control register
All refuelling areas must be signed to prevent smoking or naked flame
Vehicles must be switched off when refuelling and the use of mobile phones prohibited
Fixed refuelling areas must have a plastic lined refuelling area
Fuel storage containers must be of a double bund construction
Site layout
Georgiou will develop a site plan (ie a diagram) showing the location of storage areas spill kit locations muster points firefighting equipment and 1st aid equipment including eye washflush locations
This site plan must be current and displayed at the work site at all times throughout construction
In the event of an emergency that involves the need for emergency services this site plan along with a product manifest must be provided to the emergency services
Project Manager
Storage of Hazardous Materials
Any Dangerous Goods andor Hazardous Substance must be stored in designated areas compliant
with statutory and industry codes of practice
Quantities of hazardous materials should be kept to a minimum commensurate with their usage
and shelf life
Safety Data Sheets of stored hazardous materials will be readily accessible at the place of
storagesite office
Permanent and temporary containers that hold hazardous materials must be labelled with the
appropriate signage
The volume and types of hazardous materials stored must be known current and documented and
must not exceed the design capacity of the storage area
Storage and containment areas (including secondary containment) must be inspected for signs of
loss or damage and any deficiencies must be addressed These areas must be inspected at least
monthly as part of the workplace inspection
Hazardous materials no longer in use must be identified and assessed to determine if they should
be removed from site
Hazardous materials storage areas must be kept clear of combustible material vegetation and refuse by a minimum of three metres
All
SpillEmergency Response
In the event of a spill the following generic procedure must be followed
1 Do not put yourself at risk 2 Notify personnel in the immediate area and remove yourself and others from danger 3 Report ALL SPILLS immediately to the Supervisor and Environmental Site Representative
(report location type and extent of incident)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Once safety has been considered spills should be contained and cleaned up with material from the spill kit All contaminated soil caused by leaks or spills to be disposed of in accordance with legal requirements Any uncontrolled release of hazardous substances which cause actual or threatens potential serious or material environmental harm will be reported to the EPA pollution hotline
Workplace Inspections
Hazardous Materials storage and use will be inspected monthly as part of workplace inspections amp within the DHI Environmental Inspections checklist
Supervisors
Concrete
Designated concrete washout should be constructed and designated to be impermeable and securely fastened
Placed away from waterways drainage lines and stormwater inlets Sufficient storage to handle concrete works occurring onsite When the concrete is dried it will be disposed of with general waste mixed into fill layers (if
approved by client) or recycled At no point will any Concrete truck or kibble be permitted to wash out at any point other than the
designated area with all the associated controls in place (unless approved by the environmental site representative)
Excess concrete should be scraped off equipment prior to washing (allow excess to set and recycle offsite or reuse in fill if itrsquos not contaminated with black plastic)
Set concrete should be removed from the washout to restore storage capacity and prevent overflows
Use of a high pressure low volume water spray nozzle may reduce water use All wastewater must be disposed of in accordance with the project CEMP dewatering conditions
Maintenance of the washout Monitoring and maintenance of concrete washouts is essential to ensure the washout is functional no evidence of damage or wear and tear is evident and that adequate storage capacity remains In addition to daily inspections washout areas should be inspected
During dry weather and
Prior to during and after rainfall and storm events
SupervisorEnvironmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for evidence of spills or poor storage practice with potential to lead environmental incident
Hazardous goods storage area inspection for adequacy of bunding and product loss Weekly inspections using Georgiou Beakon inspection form
All staff
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Page 49 of 80
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Objectives
and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on flora and fauna Retain and enhance existing flora and fauna habitat wherever possible Appropriately manage the spread of weeds and plant pathogens
Project Manager
Performance
Criteria
100 compliance with Client amp legal requirements
100 achievement with Site Objectives amp Targets
100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation
Measures
General Vehicles equipment plant materials and personnel are to remain within the designated construction
area at all times and not breach established environmentally sensitive exclusion zones All
Training and
Competency
As part of the Site Induction workers will be informed of the Site specific controls required to minimise potential impacts and protect flora and fauna including - the requirement to work within the designated disturbance zones - requirement to recognise protected flora or fauna species identified to be found on the site - tree protection zones - Specific licence conditions applicable to the Site
Project Manager
Fauna habitat
Prior to clearing pre-clearance surveys are to occur to identify individual trees to be retained and any hollow bearing trees and logs
Where possible clearance should avoid hollow bearing trees Where unavoidable hollow bearing trees should be flagged and left standing at least 24 hours
after clearing all other vegetation Excavator operator to lsquotaprsquo tree prior to felling hollow bearing trees to allow for fauna to escape Ecologist (or similar) to be present onside during clearing of hollow bearing trees to handle any
displaced fauna In the event of injury to fauna WIRES or similar to be contacted and suitable arrangements made
NOTE Handling of any active animal breeding place is only permitted to be conducted by an authorised fauna handler operating under a current permit granted in accordance with legislative requirements
All
Authorisation amp Compliance
Georgiou will not clear vegetation without written permission from the Client local Shire or relevant Regulatory Authority All clearing works under a permit approval or licence will be compliant with the conditions of permit approvals or licence and within the predetermined area
In the event of any unauthorised clearing works will cease immediately and the Project Manager client will be notified Unauthorised clearing of areas will be investigated immediately
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Marking
The Project Engineer will ensure the area to be cleared is clearly marked (eg pegging) and areas of vegetation or trees nominated to be excluded from the clearing works are to be visually identifiable to all personnel involved in the works
The method of marking is to be communicated to all persons involved in the clearing process All control measures are to be communicated to personnel involved in the tasks
All
Flora
Flora that is to be protected will be clearly marked using a method that will not harm or damage A Tree protection Zone (TPZ) is to be established for any trees on a construction site that are to
be protected This is to be fenced off or barricaded to ensure construction activities do not cause damage to the root plate of the tree
Native vegetation should be protected where reasonably possible Large areas that are to be protected from Site works will be demarcated to prevent intrusion and disturbance This requirement is to be communicated to personnel involved within the site area
When the pruning of trees is to be undertaken that are to be protected it will be done by suitably qualified personnel only Where branches are trimmed an assessment of the trees ability to survive should be conducted by a suitably qualified person and adequate area around the tree in accordance with AS49702009 Protection of trees of development sites
Trees should be felled into the construction site or in slots between stands of trees where practical to minimise damage to other trees during the clearing process Machinery contact with standing trees on vegetated margins is to be avoided
The clearing of vegetation outside the construction area will not be permitted except in the event of an emergency or as directed by emergency services
All
Fauna
If fauna are confirmed to be present onsite during clearing clearing works should proceed with care to enable the fauna to relocate freely Clearing is to be conducted in a sequential manner and in a way that encourages escaping wildlife away from the activity into adjacent natural areas and not across roads or into other areas of threat (eg trench)
All
Trenches
All open excavations and trenches will be visually inspected on a daily basis for trapped fauna Surveillance must occur along the entire length of the trench or excavated area and not merely those areas described as fauna habitats or sensitive areas Open trenches are to be checked for fauna immediately prior to backfill and any trapped animals removed by authorised fauna handlers
All
Fauna Handling
Fauna will not be intentionally harmed or maimed under State wildlife protection legislation This includes aquatic and terrestrial fauna (land and air animals)
Workers are not authorised handleto be in possession of native fauna The trapping and handling of fauna in particular dangerous species will only be undertaken by a competent qualified fauna handler
All
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Fire Management
Georgiou will not set fire to bush or use spark generating machinery (eg graders) during a prohibited or restricted burning time
If safe to do so Georgiou will extinguish any bush fire within the site boundary and request help from authorities if necessary Fire breaks will be established as requested by authorities
Project Manager
Environmental
Inspections amp
Monitoring
Daily (Visual) and weekly
(documented)
General observation for clearing boundary demarcation Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 5 - Cultural Heritage Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on items or places of heritage value Avoid accidental impacts on heritage items Maximise workerrsquos awareness of indigenous and non-indigenous heritage
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Maintain the integrity of the cultural (European amp Indigenous) aspects of the Site
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any identified cultural or heritage aspects on the Site and any specific controls to be adhered including - Management practices when working near protected areas - Respecting Heritage Sites - Reporting requirements
Georgiou personnel will participate in the Companyrsquos cross cultural awareness training for employees
Project Manager
Heritage Sites There are s170 heritage listed Glebe Island silos (Port Authority of NSW s170 4560056) that are approximately 5m from the edge of works
Project Engineer
Method statement
In accordance with the REF an Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
Unexpected heritage finds
In the event that an artefact or remains are found the Sydney Metro Unexpected Heritage Finds procedure (Appendix 5A) will be followed this includes - The works in that area will cease immediately - The Project Manager and Sydney Metro must be notified - The site must be made secure a buffer zone of ten meters is recommended - Sydney Metro to provide management recommendations
Georgiou will notify all site personnel of the object andor area and proposed treatment of that object andor area as soon as possible but prior to commencing work on the next working day
Works will not continue until written approval has been received from the client
All
discovery of human remains
In the event that human remains are found the Sydney Metro Exhumation Management procedure will be followed (Appendix 5B)
All
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Environmental Inspections amp Monitoring
Building condition inspections Building condition inspections will be undertaken in accordance with REF condition NV3 Sydney Metro
Vibration Monitoring
Continuous vibration monitoring will occur during any vibratory works in close proximity to the Glebe Island silos in accordance with the Sydney Metro Construction Noise and Vibration Standard
Environmental Site Representative
Daily (Visual) and weekly (documented)
General observation for that protection measures and methods are being applied Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure
Sydney Metro Unexpected
Heritage Finds Procedure [SM-18-00105232]
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final
Version 33
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2018
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Document history
Version Date of approval Notes
11 Incorporates ER comments 210617
12 Amends p13 step 8 reference to s146 added
13 Incorporates Planning Mods 1-4 including amended CoA E20
14 Incorporates ER comments 210318
20 Removes SSI 15-7400 COA reference
30 Revises definition
31 Revises flow chart
32 Revises roles and responsibilities
33 General edits and corrections
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Table of contents
1 Purpose 3
11 Legislation that does not apply 3
2 Scope 4
3 Definitions 4
4 Types of unexpected heritage items and corresponding statutory protections 5
41 Aboriginal objects 5
42 Historic heritage items 6
43 Human skeletal remains 7
5 Legislative Requirements 7
6 Unexpected heritage finds protocol 9
7 Responsibilities 15
8 Seeking Advice 16
9 Related documents and references 16
10 List of appendices 16
11 Document history 17
Appendix 1 Examples of finds encountered during construction works 18
Appendix 2 - Unexpected heritage item recording form 24
Appendix 3 - Photographing unexpected heritage items 26
Appendix 4 - Uncovering bones 29
Appendix 5 - Archaeologicalheritage advice checklist 33
Appendix 6 - Template notification letter 34
Tables
Table 1 Legislation and guidelines for management of unexpected heritage finds 8 Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item 10 Table 3 Roles and Responsibilities 15
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1 Purpose
This procedure is applicable to the Sydney Metro program of works including major projects delivered under Critical State Significant Infrastructure (CSSI) Planning Approvals early CSSI minor and enabling works and works that are subject to the NSW Heritage Act (1977) including s57139 and s60140 exemptions and permit approvals and the National Parks and Wildlife (NPW) Act 1974
This procedure has been prepared for Sydney Metro programs to provide a method for managing unexpected heritage items (both Aboriginal and non-Aboriginal) that are discovered during preconstruction (pre-Construction Heritage Management Plan approval) construction phases (post Construction Heritage Management Plan approval) and for works subject to the NSW Heritage Act (1977)
In NSW there are strict laws to protect and manage heritage objects and relics As a result appropriate heritage management measures need to be implemented to minimise impacts on heritage values ensure compliance with relevant heritage notification and other obligations and to minimise the risk of penalties to individuals Sydney Metro and its contractors This procedure includes Sydney Metrorsquos heritage notification obligations under the Heritage Act NPW Act and the Coronerrsquos Act 2009 and the requirements of the conditions of approval(CoA) issued by NSW Department of Planning Industry and Environment Note that a Contractor must not amend the Sydney Metro Unexpected Finds Procedure or use a different procedure without the prior approval of Sydney Metro
This procedure must be read in conjunction with the relevant CCSI conditions of approval (if applicable) the contract documents and other plans and procedures including the Sydney Metro Exhumation Procedure in addition to any other relevant documents as developed by the contractor during the delivery of the Sydney Metro works
2 Definitions and Abbreviations
An unexpected heritage find is
any unanticipated discovery of an actual or potential heritage item which Sydney Metro does not have approval to disturb andor does not have an existing management process in place
a find that has not been previously identified or assessed
a find that is not referenced in an Archaeological Research Design (ARD) Archaeological Method Statement (AMS) or other project document relating to heritage and archaeology
not covered by an existing approval under the Heritage Act 1977 (Heritage Act) or National Parks and Wildlife Act 1974 (NPW Act)
Note that locally significant areas of historical archaeological potential identified in an Archaeological Method Statement but not identified in an Archaeological Research Design would be managed as an ldquoexpectedrdquo find
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All terminology in this procedure is taken to mean the generally accepted or dictionary definition with the exception of the following terms which have a specifically defined meaning
Definitions
AHIP Aboriginal Heritage Impact Permit
Aboriginal object An Aboriginal object is any deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remains An Aboriginal object may include a shell midden stone tools bones rock art Aboriginal-built fences and stockyards scarred trees and the remains of fringe camps
ARD Archaeological Research Design
AMS Archaeological Method Statement
CEMP Construction Environmental Management Plan
CoA Conditions of Approval
CSSD Critical State Significant Development
CSSI Critical State Significant Infrastructure
EPampA Act NSW Environmental Planning and Assessment Act 1979
Disturbance Disturbance is considered to be any physical interference to an item that results in it
being destroyed defaced damaged harmed impacted or altered in any way (this
includes archaeological investigation activities)
Excavation Director
A person that has been determined by the NSW Heritage Division to meet the Heritage Council of NSWrsquos Criteria for Assessment of Excavation Directors (4 September 2019 and as updated) and can therefore competently archaeologically investigate a site of either local andor state significance
Heritage Act NSW Heritage Act 1977
NPW Act NSW National Parks and Wildlife Act 1974
Heritage NSW Formerly Office of Environment and Heritage (OEH) Now Heritage NSW as part of PNSW Premier and Cabinet
SM Sydney Metro
Relic (non- Aboriginal heritage)
A relic means any deposit artefact object or material evidence that
a) relates to the settlement of the area that comprises NSW not being Aboriginal settlement and
b) is of State or local significance
A relic may include items such as bottles utensils remnants of clothing crockery
personal effects tools machinery and domestic or industrial refuse
TfNSW Transport for New South Wales
Work (non- Aboriginal heritage)
Archaeological features such as historic utilities or buried infrastructure that provide evidence of prior occupations such as former rail or tram tracks timber sleepers kerbing historic road pavement fences culverts historic pavement buried retaining walls cisterns conduits sheds or building foundations but are also subject to assessment by the Excavation Director to determine its classification
Unclassified
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21 Legislation that does not apply
The following authorisations are not required for Sydney Metro approved Critical State Significant Infrastructure (and accordingly the provisions of any Act that prohibits an activity without such an authority do not apply)
Division 8 of Part 6 of the Heritage Act 1977 does not apply to prevent or interfere with the carrying out of approved State significant infrastructure
An approval under Part 4 or an excavation permit under section 139 of the Heritage Act 1977 and
An Aboriginal heritage impact permit under section 90 of the National Parks and Wildlife Act 1974
This document provides relevant background information in Section 4 followed by the technical procedure in Sections 6 and 7 Associated guidance referred to in the procedure can be found in Appendices 1-6
3 Scope
Even with early investigations unexpected finds may still occur during works on a Sydney Metro site When this happens this procedure must be followed This procedure provides direction on when to stop work where to seek technical advice how to notify the regulator if required and when works can recommence This procedure applies to the discovery of any unexpected heritage item relic or object where the find is not anticipated in an approved ARD or AMS or other project specific document related to archaeology
This procedure must be followed by all Sydney Metro staff contractors subcontractors or any person undertaking works for Sydney Metro It includes references to some of the relevant legislative and regulatory requirements but is not intended to replace them This procedure does not apply to
the discovery and disturbance of heritage items as a result of investigations being undertaken in accordance with the Code of Practice for Archaeological Investigations of Aboriginal Objects in NSW4376 20101 an Aboriginal Heritage Impact Permit (AHIP) issued under the NPW Act or a permit approval issued under the Heritage Act
the discovery and disturbance of heritage items as a result of construction related activities where the disturbance is permissible in accordance with an AHIP or an approval issued under the Heritage Act or CSSI CSSD planning approval or
locally significant non-Aboriginal archaeology identified in an AMS and not in an ARD
1 An act carried out in accordance with the Code of Practice for Archaeological Investigation of Aboriginal Objects
in NSW as published by the Department in the Gazette on 24 September 2010 is excluded from the definition of harm an object or place in section 5 (1) of the NPW Act
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4 Types of unexpected heritage finds and corresponding statutory protections
Project field and environmental personnel (including construction contractors) are critical to the early identification and protection of unexpected finds
Appendix 1 illustrates the wide range of heritage items uncovered to date during Sydney Metro projects and gives an indicative guide to what unexpected finds may look like
These discoveries are categorised as either
(a) Aboriginal objects
(b) Historic (non-Aboriginal) heritage items or
(c) Human skeletal remains
The relevant legislation that applies to each of these categories is described below
41 Aboriginal objects
The NPW Act protects Aboriginal objects which are defined as
ldquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrdquo2
Examples of Aboriginal objects include stone tool artefacts shell middens axe grinding grooves pigment or engraved rock art burials and scarred trees
42 Historic heritage items
Historic (non-Aboriginal) heritage items may include
Archaeological lsquorelicsrsquo or
Other historic items (ie works structures buildings or movable objects)
2 Section 5(1) NPW Act 3 This is required under section 89(A) of the NPW Act and applies to all Sydney Metro projects
IMPORTANT
All Aboriginal objects regardless of significance are protected under law
If any impact is expected to an Aboriginal object an AHIP is usually required from Heritage NSW When a person becomes aware of an Aboriginal object they must notify the Director-
General of Heritage NSW about its location3 Assistance on how to do this is provided in Section 7 (Step 5)
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421 Archaeological relics
The Heritage Act protects relics which are defined as ldquoany deposit artefact object or material evidence that relates to the settlement of the area that comprises NSW not being Aboriginal settlement and is of State or local heritage significancerdquo4
Relics are archaeological items of local or state significance which may relate to past domestic industrial or agricultural activities in NSW and can include bottles remnants of clothing pottery building materials and general refuse
422 Other historic items
Some historic heritage items are not considered to be lsquorelicsrsquo but are instead referred to as works buildings structures or movable objects Examples of these items that may be encountered include culverts historic pavements retaining walls tramlines rail tracks turn tables timber sleepers cisterns fences sheds buildings and conduits Although an approval under the Heritage Act may not be required to disturb these items their discovery must be managed in accordance with this procedure
Usually archaeological relics are uncovered via a process of excavation or soil removal When an unexpected find is uncovered an archaeological excavation permit under section 140 or section 60 of the Heritage Act may be required to further investigate or remove it if investigation is not covered by an existing approval In contrast lsquoother historic itemsrsquo either exist above the ground surface (for example a shed) or they are designed to operate and exist beneath the ground surface (for example a culvert)They may also need a permit to alter disturb or remove them if there is not an approval already in place
4 Section 4(1) Heritage Act
5 This is required under section 146 of the Heritage Act and applies to all Sydney Metro projects
IMPORTANT
All relics are subject to statutory controls and protections
If a relic is likely to be disturbed a heritage approval is usually required from the NSW Heritage Council When a person discovers a relic they must notify the NSW Heritage
Council of its location5
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43 Human skeletal remains
The Sydney Metro Exhumation Procedure provides a more detailed explanation of the approval processes related to human remains
Human skeletal remains can be identified as either an Aboriginal object or non-Aboriginal relic depending on the ancestry of the individual (Aboriginal or non-Aboriginal) and the burial context (archaeological or non-archaeological) Remains are considered to be archaeological when the time elapsed since death is suspected of being 100 years or more Depending on ancestry and context different legislation applies
As a simple example a pre-European settlement archaeological Aboriginal burial would be protected under the NPW Act while a historic (non-Aboriginal) archaeological burial within a cemetery would be protected under the Heritage Act For a non-Aboriginal archaeological burial the relevant heritage approval and notification requirement described in Appendix 4 would apply In addition to the NPW Act finding Aboriginal human remains also triggers notification requirements to the Commonwealth Minister for the Environment under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
Where it is suspected that less than 100 years has elapsed since death the human skeletal remains come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such cases are lsquoreportable deathsrsquo and under legal notification obligations set out in section 35(2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (whether Aboriginal or non-Aboriginal remains) Public health controls may also apply6
Guidance on what to do when suspected human remains are found is provided in Appendix 5
IMPORTANT
All human skeletal remains are subject to statutory controls and protections
All bones must be treated as potential human skeletal remains and work around them must stop while they are appropriately protected and investigated the relevant authorities advised and approvals received This includes skeletal material found during any phase of work including
geotechnical works early works construction works and any other site works
6 Under section 19 of the Coroners Act 2009 the coroner has no jurisdiction to conduct an inquest into reportable
death unless it appears to the coroner that (or that there is reasonable cause to suspect that) the death or suspected death occurred within the last 100 years
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5 Legislative Requirements Table 1 identifies some of the relevant legislationregulations for the protection of heritage and the management of unexpected heritage finds in NSW It should be noted that significant penalties exist for breaches of the legislation which result in unauthorised impacts to heritage items
To avoid breaches of legislation it is important that Sydney Metro and its contractors are aware of their statutory obligations under relevant legislation and that appropriate control measures are in place to ensure that unexpected finds are appropriately managed during all project phases Contractors will need to ensure that they undertake their own due diligence to identify any other legislative requirements that may apply for a given project
Table 1 Legislation and guidelines for management of unexpected heritage finds
Relevant Requirement Objectives and offences
Environmental Planning and Assessment Act 1979 (EPampA Act)
Part 5 Division 52 Subdivision 2 Section 519
Requires heritage to be considered within the environmental impact assessment of projects
Heritage Act 1977 (Heritage Act)
The Heritage Act provides for the care protection and management of heritage items in NSW Under section 139 it is an offence to disturb or excavate any land knowing or having reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered exposed moved damaged or destroyed unless the disturbance or excavation is carried out in accordance with an excavation permit issued by the Heritage NSW under the Act a relic is defined as lsquoany deposit artefact object or material evidence that (a) relates to the settlement of the area that comprises New South Wales not being Aboriginal settlement and (b) is of State or local heritage significancersquo
A person must notify the Heritage NSW if a person is aware or believes that they have discovered or located a relic (section 146) Penalties for offences under the Heritage Act can include six months imprisonment andor a fine of up to $11million
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Relevant Requirement Objectives and offences
National Parks and Wildlife Act 1974 (NPW Act)
The NPW Act provides the basis for the care protection and management of Aboriginal objects and places in NSW
An Aboriginal object is defined as lsquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrsquo
An lsquoAboriginal placersquo is an area declared by the Minister administering the Act to be of special significance with respect to Aboriginal culture An Aboriginal place does not have to contain physical evidence of occupation (such as Aboriginal objects)
Under section 87 of the Act it is an offence to harm or desecrate an Aboriginal object or place There are strict liability offences An offence cannot be upheld where the harm or desecration was authorised by an AHIP and the permitrsquos conditions were not contravened Defences and exemptions to the offence of harming an Aboriginal object or Aboriginal place are provided in section 87 87A and 87B of the Act A person must notify Heritage NSW if a person is aware of the location of an Aboriginal object
Penalties for some of the offences can include two years imprisonment andor up to $550000 (for individuals) and a maximum penalty of $11 million (for corporations)
6 Unexpected heritage finds protocol
61 What is an unexpected heritage find
An lsquounexpected heritage findrsquo can be defined as any unanticipated archaeological discovery that has not been identified during a previous assessment or is not covered by an existing permit under the Heritage Act The find may have potential cultural heritage value which may require a heritage permit or notification if any interference of the heritage item is proposed or anticipated
The range of potential unexpected finds can include but is not limited to
remains of rail infrastructure including buildings footings stations signal boxes rail lines bridges and culverts
remains of other infrastructure including sandstone or brick buildings wells cisterns drainage services conduits old kerbing and pavement former road surfaces timber and stone culverts bridge footings and retaining walls
artefact scatters including clustering of broken and complete bottles glass ceramics animal bones and clay pipes and
archaeological human skeletal remains
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62 Managing unexpected finds
In the event that an unexpected find is encountered on a Sydney Metro site the steps detailed in Table 2 must be followed There are seven steps in the procedure
Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item
Step Task Responsibility Guidance and tools
1 Stop work and protect the item
11 Stop all work including geotechnical investigations in the immediate area of the item and notify the Project Manager
Contractor Supervisor
Appendix 1
Identifying Unexpected Heritage items
12 Establish a lsquono-go zonersquo around the item Use high visibility fencing where practical No work is to be undertaken within this zone until further investigations are completed and if required appropriate approvals are obtained
Inform all site personnel about the no-go zone
Project Manager Contractor Supervisor
2 Engage an Archaeologist
21 If you have Excavation Director or an archaeologist andor Aboriginal heritage consultant has been previously appointed for the project contact them to discuss the location and nature of the item and arrange a site inspection The project Construction Environmental Management Plan (CEMP) may contain contact details of the archaeologistAboriginal heritage consultant
Provide as much information as possible including photos and completed recording form
Inform the Sydney Metro Environmental Manager and keep them involved in the process The Environmental Manager will inform the Sydney Metro Senior Heritage Advisor
Contractors Project Manager
Appendix 2
Unexpected Heritage Item Recording Form
22 Where there is no project archaeologist engaged for the works engage a suitably qualified consultant to assess the find
If the find is a non-Aboriginal item engage a suitably qualified and experienced historical archaeological consultant
If the find is likely to be an Aboriginal object engage an Aboriginal heritage consultant
Contractorrsquos Project Manager
IMPORTANT
Sydney Metro may have approval to impact certain heritage items during construction If you think that you may have discovered a heritage item and you are unsure whether an
approval is in place or not STOP works and follow this procedure
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Step Task Responsibility Guidance and tools
23 ArchaeologistExcavation Director and Sydney Metro Environmental Manager to advise the Project Manager whether Sydney Metro has approval to impact the lsquoitemrsquo
If yes work may recommence in accordance with that approval or permit There is no further requirement to follow this procedure
If no continue to next step
Contractorrsquos Project Manager
3 Arrange site access
31 Arrange site access for the archaeologistAboriginal heritage consultant to inspect the item as soon as practicable In most cases a site inspection is required to conduct a preliminary assessment
Contractorrsquo s Project Manager Excavation Director
32 Subject to the archaeologistAboriginal heritage consultantrsquos assessment work may recommence at a set distance from the item This is to protect any other archaeological material that may exist in the vicinity which may have not yet been uncovered Existing protective fencing established in Step 12 may need to be adjusted to reflect the extent of the newly assessed protective area No works are to take place within this area once established
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
33 Occasionally the archaeologistAboriginal heritage consultant may determine from the photographs provided at Step 21 that no site inspection is required because no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo a lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Archaeologist Aboriginal heritage consultant Excavation Director
Proceed to Step 8
4 Undertake Preliminary assessment and recording of the find
41 Has the lsquofindrsquo been damaged or harmed
If yes record the incident in the Incident
Management System Implement any additional reporting requirements related to the planning approval and CEMP where relevant
Contractors Project Manager Archaeologist and or Excavation Director
42 Can the works avoid further disturbance to the item Project Manager to confirm with Sydney Metro Environment Manager
Complete the remaining tasks
Contractorrsquos Project Manager
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Step Task Responsibility Guidance and tools
43 Inspect document and photograph the item Archaeologist and or Excavation Director
Appendix 2
Unexpected Heritage Item Recording Form
Appendix 3
Photographing Unexpected Heritage items
44 Is the item likely to be bone
If yes follow the steps in Appendix 4 ndash lsquoUncovering bonesrsquo Where it is obvious that the bones are human remains you must notify the local police by telephone immediately They may take command of all or part of the site Also refer to the Sydney Metro Exhumation Procedure
If no proceed to next step
Archaeologist and or Excavation Director
Appendix 4
Uncovering Bones
45 The archaeologistAboriginal heritage consultant may provide advice after the site inspection and preliminary assessment that no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo or a lsquoheritage itemrsquo or an lsquoAboriginal itemrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Metro Project Manager
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
Proceed to Step 7
Refer to Appendix 1
Examples of finds encountered during construction worksrsquo
46 Where required seek additional specialist technical advice (such as a forensic or physical anthropologist to identify skeletal remains) The archaeologistAboriginal heritage consultant can provide contacts for such specialist consultants
Excavation Director Archaeologist
47 Where the item has been identified as a lsquorelicrsquo or lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo the archaeologist should formally record it
Archaeologist Aboriginal heritage consultant
48 NSW Heritage for non-Aboriginal relics and NSW Department of Planning Industry and Environment for Aboriginal objects can be notified informally by telephone at this stage by the Sydney Metro Senior Heritage Advisor Any verbal conversations with regulators must be noted on the project file for future reference
Contractors Project Manager Excavation Director
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Unclassified
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Step Task Responsibility Guidance and tools
5 Notify the regulator if required
51 Based on the findings of the archaeological or heritage management plan and corresponding legislative requirements is notification of Heritage NSW and the Secretary required
If no proceed directly to Step 6
If yes proceed to next step
Sydney Metro Environmental Manager Contractorrsquos Excavation Director
52 If notification is required complete the template notification letter including the archaeological heritage management plan and other relevant supporting information and forward to the Sydney Metro Environmental Manager The Environmental Manager will seek the approval of the Sydney Metro Senior Heritage Advisor and the signature of the Principal Manager Sustainability Environment and Planning (Program)
Sydney Metro Environmental Manager Excavation Director
Appendix 6
Template Notification Letter
53 Forward the signed notification letter to Heritage NSW and the Secretary
Informal notification (via a phone call or email) to Heritage NSW prior to sending the letter is appropriate The archaeological or heritage management plan and the completed Unexpected Heritage Item Recording Form (Appendix 2) must be submitted with the notification letter (for both Aboriginal objects and non-Aboriginal relics)
The Department of Planning Industry and Environment may also need to be notified
54 A copy of the final signed notification letter archaeological or heritage management plan and the site recording form is to be kept on file and a copy sent to the Sydney Metro Project Manager
Contractorrsquos Project Manager Excavation Director
6 Implement archaeological or heritage management plan
61 Modify the archaeological or heritage management plan to take into account any additional advice resulting from notification and discussions with regulator
Contractorrsquos Project Manager Excavation Director
62 Implement the archaeological or heritage management plan Where impact is expected this may include a formal assessment of significance and heritage impact assessment preparation of excavation or recording methodologies consultation with Registered Aboriginal Parties obtaining heritage approvals etc if required
Contractorrsquos Project Manager Excavation Director
63 Where heritage approval is required contact the Sydney Metro Environment Manager for further advice and support material Please note there are time constraints associated with heritage approval preparation and processing
Contractorrsquos Project Manager Excavation Director
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64 Assess whether heritage impact is consistent with the project approval or if project approval modification is required from the Department of Planning Industry and Environment
Excavation Director Sydney Metro Environmental Manager
65 Where statutory approvals (or project approval modifications) are required impact upon relics andor Aboriginal objects must not occur until heritage approvals are issued by the appropriate regulator
Contractorrsquos Project Manager Excavation Director
66 Where statutory approval is not required but where recording is recommended by the archaeologistAboriginal heritage consultant sufficient time must be allowed for this to occur
Contractorrsquos Project Manager Excavation Director
67 Ensure short term and permanent storage locations are identified for archaeological material or other heritage material removed from site where required Interested third parties (for example museums local Aboriginal land councils or local councils) should be consulted on this issue Contact the archaeologist or Aboriginal heritage consultant for advice on this matter if required
Contractorrsquos Project Manager Excavation Director
7 Resume work
71 Seek written clearance to resume project work from the project Excavation Director Archaeologist Aboriginal heritage consultant
Clearance would only be given once all archaeological excavation andor heritage recommendations and approvals (where required) are complete Resumption of project work must be in accordance with the all relevant projectheritage approvalsdeterminations
Contractorrsquos Project Manager Excavation Director
72 If required ensure archaeological excavationheritage reporting and other heritage approval conditions are completed in the required timeframes This includes artefact retention repositories conservation andor disposal strategies
Contractorrsquos Project Manager Excavation Director
73 If additional unexpected items are discovered this procedure must begin again from Step 1
All
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7 Responsibilities
Table 3 Roles and Responsibilities
Role Responsibility or role under this guideline
Contractor Supervisor
Stop work immediately when an unexpected heritage find is encountered Cordon off area until Environmental Manager Excavation Director advises that work can recommence
Manage the process of identifying protecting and mitigating impacts on the lsquofindrsquo
Liaise with Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Assist the archaeologistAboriginal heritage consultant with mitigation and regulatory requirements
Complete Incident Report and review CEMP for any changes required Propose amendments to the CEMP if any changes are required
Contractors Project Manager
Ensures all aspects of this procedure are implemented Advise Contractor Supervisor to recommence work if all applicable requirements have been satisfied and the Excavation Director
Project Archaeologist has approved recommend of work
Contractorrsquos or Project Heritage Advisor or Consultant
Provide expert advice to the Sydney Metro Environment Manager on find identification significance mitigation legislative procedures and regulatory requirements
Environmental Representative
Ensure compliance with relevant approvals (new and existing)
Sydney Metro Environment Manager
Notify the Sydney Metro Principal Manager Environmental Management of find and manage Incident Reporting once completed by Environmental Manager
Sydney Metro Senior Heritage Advisor
Provide expert advice to Sydney Metro Environment Manager and project as required
8 Seeking Advice
Advice on this procedure should be sought from the Sydney Metro Environment Manager in the first instance Contractors and delivery partners should ensure their own project environment managers are aware of and understand this procedure
Technical archaeological or heritage advice regarding an unexpected heritage item should be sought from a suitably qualified and experienced archaeologistAboriginal heritage consultant
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9 Related documents and references
Sydney Metro Environmental Incident Classification and Reporting ndash SM-17-00000096
Transport for NSW Guide to Environmental Control Map ndash 3TP-SD-01570
NSW Heritage Office (1998) Skeletal remains guidelines for the management of human skeletal remains
Roads and Maritime Services (2015) Standard Management Procedure Unexpected Heritage Items
Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal remains
Sydney Metro Exhumation Procedure ndash SM ES-PW-31510
10 List of appendices
The following appendices are included to support this procedure
Appendix 1 Examples of finds encountered during construction works
Appendix 2 Unexpected Heritage Item Recording Form
Appendix 3 Photographing Unexpected Heritage Items
Appendix 4 Uncovering Bones
Appendix 5 Archaeological Advice Checklist
Appendix 6 Template Notification Letter
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Appendix 1 Examples of finds encountered during construction works
Photo 1 - Aboriginal artefacts found at the Wickham Transport Interchange 2015
Photo 2 ndash Aboriginal artefacts (shell material) found at the Wickham Transport Interchange 2015
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Photo 3 1840s seawall and 1880s retaining wall uncovered at Balmain East 2016
Photo 4 Sandstone pavers uncovered at Balmain East 2016
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Photo 5 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 6 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 7 - Sandstone flagging and cesspit - Wynyard Walk project 2014
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Photo 8 - Chinese Ming Dynasty pottery and English porcelainpottery dating back to early 19th century - Wynyard Walk project 2014
Photo 9 - Pottery made by convict potter Thomas Ball during the early settlement - Wynyard Walk project 2014
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The following images obtained from the Roads and Maritime Servicesrsquo Standard Management Procedure for Unexpected Heritage items 2015 can be used to assist in the preliminary identification of potential unexpected items during construction and maintenance works Photo 10 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones (Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights Newcastle area) (RMS 2015)
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Photo 11 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones
(Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork
recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights
Newcastle area) (RMS 2015)
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Appendix 2 - Unexpected Heritage Find Recording Form
Example of unexpected heritage item recording form
This form is to be completed Excavation Director on the discovery of an archaeological heritage find during construction or maintenance works
Date Recorded by
(include name and position)
Project name
Description of works
being undertaken
Description of exact
location of item
Description of item
found
(What type of item is it likely
to be Tick the relevant
boxes)
A A relic A lsquorelicrsquo is evidence of a past human activity
relating to the settlement of NSW with local
or state heritage significance A relic might
include bottle utensils plates cups
household items tools implements and
similar items
B A lsquoworkrsquo building or
structurersquo A lsquoworkrsquo can generally be defined as a form
infrastructure such as track or rail tracks
timber sleepers a culvert road base a
bridge pier kerbing and similar items
C An Aboriginal object An lsquoAboriginal objectrsquo may include stone
tools stone flakes shell middens rock art
scarred trees and human bones
D Bone Bones can either be human or animal
remains
Remember that you must contact the local
police immediately by telephone if you are
certain that the bone(s) are human
remains
E Other
Provide a short
description of the item
(Eg metal rail tracks
running parallel to the rail
corridor Good condition
Tracks set in concrete
approximately 10 cm below
the current ground surface)
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Sketch
(Provide a sketch of the
itemrsquos general location in
relation to other road
features so its approximate
location can be mapped
without having to re-
excavate it In addition
please include details of the
location and direction of any
photographs of the item
taken)
Action taken (Tick either
A or B)
A Unexpected item
would not be further
impacts on by the
works
Describe how works would avoid impact
on the item (Eg the rail tracks would be left in
situ and recovered with paving)
B Unexpected item
would be further
impacted by the works
Describe how works would impact on the
item (Eg milling is required to be continued to a
depth of 200 mm depth to ensure the pavement
requirements are met Rail tracks would need to
be removed)
Excavation Director Signature
Signature
It is a statutory offence to disturb Aboriginal objects and historic relics (including human
remains) without an approval All works affecting objects and relics must cease until an
approval is sought
Approvals may also be required to impact on certain works
Important
Unclassified
Appendix 3 - Photographing unexpected heritage finds
Photographs of unexpected finds in their current context (in situ) may assist archaeologistsAboriginal heritage consultants to better identify the heritage values of the item Emailing good quality photographs to specialists can allow for better quality and faster heritage advice The key elements that must be captured in photographs of the item include its position the item itself and any distinguishing features All photographs must have a scale (ruler scale bar mobile phone coin etc) and a note describing the direction of the photograph
Context and detailed photographs
It is important to take a general photograph (Figure 1) to convey the location and setting of the item This will add value to the subsequent detailed photographs also required (Figure 2)
Figure 1 Telford road uncovered on the Great Western Highway (Leura) in 2008 (RMS 2015)
Photographing distinguishing features
Where unexpected items have a distinguishing feature close up detailed photographs must be taken of these features where practicable In the case of a building or bridge this may include diagnostic details architectural or technical features See Figures 3 and 4 for examples
Unclassified
Removal of the item from its context (eg excavating from the ground) for
photographic purposes is not permitted
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Photographing bones
The majority of bones found on site will be animal bones often requiring no further assessment (unless they are in archaeological context) However if bones are human the police must be contacted immediately (see Appendix 5 for detailed guidance) Taking quality photographs of the bones can often resolve this issue quickly The project archaeologist can confirm if bones are human or non-human if provided with appropriate photographs
Ensure that photographs of bones are not concealed by foliage (Figure 5) as this makes it difficult to identify Minor hand removal of foliage can be undertaken as long as disturbance of the bone does not occur Excavation of the ground to remove bone(s) should not occur nor should they be pulled out of the ground if partially exposed
Where sediment (adhering to a bone found on the ground surface) conceals portions of a bone (Figure 6) ensure the photograph is taken of the bone (if any) that is not concealed by sediment
Ensure that all close up photographs include the whole bone and then specific details of the bone (especially the ends of long bones the epiphysis which is critical for species identification) Figures 7 and 8 are examples of good photographs of bones that can easily
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be identified from the photograph alone They show sufficient detail of the complete bone and the epiphysis
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Appendix 4 - Uncovering bones
This appendix provides advice regarding
what to do on first discovering bones
the range of human skeletal notification pathways and
additional considerations and requirements when managing the discovery of human remains
1 First uncovering bones
Refer to the Sydney Metro Exhumation Procedure
Stop all work in the vicinity of the find All bones uncovered during project works should be treated with care and urgency as they have the potential to be human remains The bones must be identified as either human or non-human as soon as possible by a qualified forensic or physical anthropologist
On the very rare occasion where it is immediately obvious from the remains that they are human the Project Manager (or a delegate) should inform the police by telephone prior to seeking specialist advice It will be obvious that it is human skeletal remains where there is no doubt as demonstrated by the example in Figure 17 Often skeletal elements in isolation (such as a skull) can also clearly be identified as human Note it may also be obvious that human remains have been uncovered when soft tissue andor clothing are present
7
After Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal
Remains 17
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This preliminary phone call is to let the police know that a specialist skeletal assessment to determine the approximate date of death which will inform legal jurisdiction The police may wish to take control of the site at this stage If not a forensic or physical anthropologist must be requested to make an on-site assessment of the skeletal remains
Where it is not immediately obvious that the bones are human (in the majority of cases illustrated by Figure 2) specialist assessment is required to identify the bones Photographs of the bones can assist this assessment if they are clear and taken in accordance with guidance provided in Appendix 3 Good photographs often result in the bones being identified by a specialist without requiring a site visit noting they are nearly always non-human In these cases non-human skeletal remains must be treated like any other unexpected archaeological find
If the bones are identified as human (either by photographs or an on-site inspection) a technical specialist must determine the likely ancestry (Aboriginal or non-Aboriginal) and burial context (archaeological or forensic) This assessment is required to identify the legal regulator of the human remains so urgent notification (as below) can occur
Preliminary telephone or verbal notification by the archaeologist to the Sydney Metro Senior Heritage Advisor is appropriate This must be followed up later by a formal letter notification to the relevant regulator when a management plan has been developed and agreed to by the relevant parties
2 Range of human skeletal notification pathways
The following is a summary of the different notification pathways required for human skeletal remains depending on the preliminary skeletal assessment of ancestry and burial context
A Human bones are from a recently deceased person (less than 100 years old)
B Human bones are archaeological in nature (more than 100 years old) and are likely to be Aboriginal remains
C Human bones are archaeological in nature (more than 100 years old) and likely to be non-Aboriginal remains
Figure 3 summarises the notification pathways on finding bones
Action
The Heritage NSW must be notified immediately
Action
The police must be notified immediately as per the obligations to report a death or suspected death under s35 of the Coroners Act 2009 (NSW) It should be assumed the police will then take command of the site until otherwise directed
Action
The Department of Planning Industry and Environment Aboriginal Heritage Section must be notified immediately The project Aboriginal Cultural Heritage Advisor must contact and inform the relevant Aboriginal community stakeholders who may request to be present on site
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Figure 3 Overview of steps to be undertaken on the discovery of bones
After the appropriate verbal notifications (as described in 2B and 2C above) the Project Manager must proceed through the Unexpected Heritage Items Exhumation Procedure (Step 4) It is noted that no Exhumation Procedure is required for forensic cases (2A) as all future management is a police matter Non-human skeletal remains must be treated like any other unexpected archaeological find and so must proceed to record the find
3 Additional considerations and requirements
Uncovering archaeological human remains must be managed intensively and needs to consider a number of additional specific issues These issues might include facilitating culturally appropriate processes when dealing with Aboriginal remains (such as repatriation and cultural ceremonies) Project Managers may need to consider overnight site security of any exposed remains and may need to manage the onsite attendance of a number of different external stakeholders during assessment andor investigation of remains
Project Managers may also be advised to liaise with local churchreligious groups and the media to manage community issues arising from the find Additional investigations may be required to identify living descendants particularly if the remains are to be removed and relocated
If exhumation of the remains (from a formal burial or a vault) is required Project Managers should also be aware of additional approval requirements under the NSW Public Health Act 1991 Specifically Sydney Metro may be required to apply to the Director General of NSW
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Department of Health for approval to exhume human remains as per Clause 26 of the NSW Public Health (Disposal of Bodies) Regulation 2002 8
Further the exhumation of such remains needs to consider health risks such as infectious disease control exhumation procedures and reburial approval and registration Further guidance on this matter can be found at the NSW Department of Health website
In addition due to the potential significant statutory and common law controls and prohibitions associated with interfering with a public cemetery project teams are advised when works uncover human remains adjacent to cemeteries to confirm the cemeteryrsquos exact boundaries where possible
8 This requirement is in addition to heritage approvals under the Heritage Act 1977
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Appendix 5 - Archaeologicalheritage advice checklist
The archaeologistAboriginal heritage consultant must advise the Sydney Metro Environment Manager and Senior Heritage Advisor of an appropriate archaeological or heritage management plan as soon as possible after an inspection of the site has been completed An archaeological or heritage management plan can include a range of activities and processes which differ depending on the find and its significance
In discussions with the archaeologistAboriginal heritage consultant the following checklist can be used as a prompt to ensure all relevant heritage issues are considered when developing this plan This will allow the project team to receive clear and full advice to move forward quickly Archaeological andor heritage advice on how to proceed can be received in a letter or email outlining all relevant archaeological andor heritage issues
Required Outcomenotes
Assessment and investigation
Assessment of significance YesNo
Assessment of heritage impact YesNo
Archaeological excavation YesNo
Archival photographic recording YesNo
Heritage approvals and notifications
AHIP section 140 section 139 exceptions section 60 exemptions etc
YesNo
Regulator relicsobjects notification YesNo
Notification to Sydney Trains for s170 heritage conservation register
YesNo
Compliance with CEMP or other project heritage approvals
YesNo
Stakeholder consultation
Aboriginal stakeholder consultation YesNo
Artefactheritage item management
Retention or conservation strategy (eg items may be subject to long conservation and interpretation)
YesNo
Disposal strategy YesNo
Short term and permanent storage locations (interested third parties should be consulted on this issue)
YesNo
Control Agreement for Aboriginal objects YesNo
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Appendix 6 - Template notification letter
Insert on Sydney Metro letterhead
Select and type date] [Select and type reference number]
XXX
Heritage NSW Department of Planning Industry and
Environment
xxx
Parramatta NSW 2124
[Select and type salutation and name]
Re Unexpected heritage item discovered during Sydney Metro activities
I write to inform you of an unexpected [select relic heritage item or Aboriginal object] found during Sydney Metro investigative and construction works at [insert location] on [insert date] in accordance with the notification requirement under select section 146 of the Heritage Act 1977 (NSW) [Where the regulator has been informally notified at an earlier date by telephone this should be referred to here]
[Provide a brief overview of the project background and project area Provide a summary of the description and location of the item including a map and image where possible Also include how the project was assessed under the Environmental Planning and Assessment Act 1979 (NSW) (eg Part 5) Also include any project approval number if available]
Sydney Metro [or contractor] has sought professional archaeological advice regarding the item A preliminary assessment indicates [provide a summary description and likely significance of the item] Please find additional information on the site recording form attached
Based on the preliminary findings Sydney Metro [or contractor] is proposing [provide a summary of the proposed archaeologicalheritage approach (eg develop archaeological research design (where relevant) seek heritage approvals undertake archaeological investigation or conservationinterpretation strategy) Also include preliminary justification of such heritage impact with regard to project design constraints and delivery program]
The proposed approach will be further developed in consultation with a nominated Office of Environment and Heritage staff member
Should you have any feedback on the proposed approach or if you require any further information please do not hesitate to contact [Environment and Planning Project Manager] on (02) XXXX XXXX
Yours sincerely
[Sender name]
Sydney Metro Director Environment Sustainability amp Planning [Attach the archaeologicalheritage management plan and site recording form]
NB On finding Aboriginal human skeletal remains this letter must also be sent to the Commonwealth Minister for the Environment in accordance with notification requirements under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 56 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 5B ndash Sydney Metro Exhumation Management Procedure
Unclassified
Exhumation Management
Procedure
SM ES-PW-31510
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final issued for Implementation
Version 40
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2017
Unclassified
Integrated
Management
System
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 2 of 24
Table of Contents
Contents 1 Introduction 3
2 Methodology 3 21 Overview of legislative requirements for dealing with human remains
4 22 Discovery of human remains and forensic cases NSW Coroners
Act 2009 (NSW) 4 23 Historic human remains Heritage Act 1977 and Guidelines for the
Management of Human Skeletal Remains under the Heritage Act 1977 5
24 Aboriginal human remains National Parks and Wildlife Act 1974 6 25 Exhumation of human remains Public Health Regulation 2012
(NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013) 7
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013) 7
27 Work Health and Safety Act 2011 7
3 Sydney Metro procedure for the discovery and management of human remains 8 31 Initial discovery of bones What do we do 8 32 Archaeological Exhumation Methodology 10
4 Excavation and post-excavation tasks 14 41 Research Questions 14 42 Process for DNA Testing Isotope Analysis and Environmental
Sampling 15 43 Reporting 16 44 Public Involvement 16 45 Temporary Storage and Permanent Repository or Resting Place for
Remains 17
5 Definitions 18
6 Related Documents and References 18
7 Superseded Documents 18
8 Document History 18
9 Schedule of Acronyms 18
Exhumation of Human Remains 20 EXHUMATION OF HUMAN REMAINS 1 MANDATORY REQUIREMENTS 1 IMPLEMENTATION 1 REVISION HISTORY 2 CONTENTS 4 APPENDIX 2 11 APPENDIX 3 12 APPENDIX 4 13 APPLICATION TO EXHUME REMAINS 16
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1 Introduction
This Exhumation Management Procedure (ExMP) has been developed to provide Sydney Metro and their contractors with guidance on managing the discovery of human skeletal remains during the course of the Sydney Metro program of works
Sydney Metro is Australiarsquos biggest public transport project From the northwest metro rail is being extended under Sydney Harbour through new underground city stations and beyond to the south west In 2024 Sydney will have 31 metro railway stations and a 66km standalone metro railway system revolutionising the way Australiarsquos biggest city travels (refer to Figure 1)
The purpose of this ExMP is to provide a clear and concise process to follow in the event of the discovery of potential human remains during Sydney Metro project works
This ExMP will be reviewed as required and prior to any future Sydney Metro project that has potential to impact on a known cemetery or burial ground A review may require amendment the ExMP to tailor additional controls or management procedures that are specific to the impacted cemetery or burial ground In addition the requirements of the relevant Planning Approval will be assessed during the review of this ExMP prior to its implementation
This procedure should be read in conjunction with the Sydney Metro Unexpected Finds Policy
2 Methodology
This ExMP outlines the procedure for the management of the discovery of human remains within the Sydney Metro program The ExMP addresses the following
Discussion of relevant legislation and guidelines (eg Coroners Act 2009 Heritage Act 1977 Guidelines for the Management of Human Skeletal Remains 1988 and the Public Health Regulations 2012)
Archaeological methodology for excavation of remains including processes for appropriately handling remains in accordance with the relevant guidelines
Preparation of a flow chart process to be used by contractors to respond to the discovery of suspected human remains
Post-exhumation management primarily around relocation processing and long- term arrangements
Process for nomination of a physical anthropologist and temporary storage location
Process for additional analysis including DNA testing isotope analysis and environmental sampling and discussion on requirements for public involvement
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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Figure 1 2020 Sydney Metro Program Project overview and station locations
21 Overview of legislative requirements for dealing with human remains
The following section provides an overview of the legislation that would apply to the discovery management and relocation of human remains A discovery of suspected human remains may be subject to different Acts and requirements thereby triggering different notification pathways based on the specific circumstances involved
The first step will always be to notify the NSW Police Confirmation of the age (antiquity) and nature of the skeletal remains as well as the reasons for the disturbance will dictate which Act and provisions will be applicable
22 Discovery of human remains and forensic cases NSW Coroners Act 2009 (NSW)
For a discovery of suspected human remains less than 100 years old the remains would come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such a case would be considered a lsquoreportable deathrsquo and under legal notification obligations set out in s35 (2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (ie both Aboriginal and non-Aboriginal remains)
Unclassified
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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35 Obligation to report death or suspected death
(1) This section applies to any person who has reasonable grounds to believe that a death or suspected death of another person
(a) is a reportable death or occurred in circumstances that would be examinable under Division 2 of Part 32 and
(b) has not been reported in accordance with subsection (2)
(2) A person to whom this section applies must report the death or suspected death concerned to a police officer a coroner or an assistant coroner as soon as possible after becoming aware of the grounds referred to in subsection (1)
Maximum penalty (subsection (2)) 10 penalty units
(3) A police officer to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner or assistant coroner as soon as possible after the report is made
(4) An assistant coroner to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner as soon as possible after the report is made
(5) A coroner to whom a death or suspected death is reported under this section is required to inform the State Coroner of the report as soon as practicable after the report is made
23 Historic human remains Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 19771 (the Guidelines) apply to historic burials in New South Wales It should be noted that the Guidelines are outdated in terms of the current statutory framework
A relic is defined as an archaeological deposit or artefact that has heritage significance at a local or State level The guidelines Assessing Significance for Historical Archaeological Sites and `Relics2 have been endorsed by the Heritage Council and should be used to assess the level of heritage or archaeological significance of the remains With reference to burial grounds objects such as headstones grave enclosures and grave goods as well as buried human remains may be a lsquorelicrsquo
1 NSW Heritage Office 1998
2 Heritage Branch of the Department of Planning 2009
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Approval under the Heritage Act 1977 and the National Parks and Wildlife Act 1974 is not required if human remains are uncovered during a Critical State Significant Infrastructure (CSSI) project However notification to the Heritage Council under s146 of the Heritage Act and notification of an Aboriginal object under the National Parks and Wildlife Act is required if archaeological human remains are uncovered
24 Aboriginal human remains National Parks and Wildlife Act 1974
The National Parks and Wildlife Act provides statutory protection for all Aboriginal lsquoobjectsrsquo (consisting of any material evidence of the Aboriginal occupation of NSW) under Section 90 of the Act and for lsquoAboriginal Placesrsquo (areas of cultural significance to the Aboriginal community) under Section 84
Discovery of Aboriginal burials andor human remains would be addressed in the projectrsquos Aboriginal Cultural Heritage Assessment Report (ACHAR) ACHARs would be prepared in accordance with the Heritage NSW
lsquoGuidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation3
Guide to investigating assessing and reporting on Aboriginal cultural heritage in NSW4
Aboriginal cultural heritage consultation requirements for proponents 20105
Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales6
If suspected human skeletal remains are uncovered at any time during the archaeological management program the process outlined in this ExMP and detailed in the flow chart is to be followed Management of the remains would be guided by consultation with the nominated Registered Aboriginal Parties (RAPs) for the project in adherence to the ACHAR
3 NSW Department of Environment and Conservation 2005
4 OEH 2011
5 Department of Environment Climate Change and Water 2010
6 OEH 2010
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(Uncontrolled when printed)
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25 Exhumation of human remains Public Health Regulation 2012 (NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013)
Public Health Regulation 2012 and the NSW Health Policy Statement ndash Exhumation of human remains of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies in NSW
Under Clause 70 of the Regulation an application for approval to exhume the remains of a dead person may be made to the Director-General via an approved form to the Director of the Local Public Health Unit that acts on behalf of the Director-General of NSW Health Exhumation is not to take place unless an authorised officer or a NSW Health member of staff is present at the exhumation (the grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer) (Clause 72) An authorised officer must be present at the exhumation to ensure the correct interment procedure is followed and that all of the remains are exhumed and to enforce the protection of public health should this be necessary
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013)
The NSW Ministry of Health Policy Statement on the exhumation of human remains provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation Under Clause 69 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General An application for permission to exhume the remains of a deceased person is to be made to the Public Health Unit on the approved form which is contained at the NSW Health website
The required form is appended to this ExMP for ease of reference
Note that the title of Director General of Health was replaced with the Secretary of Health when the Public Health Act and Public Health Regulation were amended However the Policy Directive PD2013-046 has not been amended to reflect this change
27 Work Health and Safety Act 2011
The Work Health and Safety Act 2011 provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices and are enforced by WorkCover NSW Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation More information on safe work practices is available at or by contacting SafeWork NSW via their website or directly
Health and safety aspects of working with human remains should be considered Generally working with archaeological human skeletal remains requires no extra precautions to be taken beyond normal health and safety regulations Once any necessary site health and safety precautions have been taken the exhumation of human remains can proceed
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 8 of 24
3 Sydney Metro procedure for the discovery and management of human remains
This procedure provides project managers principal contractors and the project archaeologistExcavation Director with advice on the steps to follow upon uncovering suspected human remains Information on the potential for burials and human remains would be included in the general project induction for all personnel The induction would include the procedure to manage these finds as set out in this ExMP
31 Initial discovery of bones What do we do
To avoid doubt all suspected bone items must be treated as potential human skeletal remains and work around them must stop while they are protected and investigated as a matter of urgency
Stop Work and preliminary notification
On discovery of bone (suspected human remains) all work in the area of the find must stop and the remains must be confirmed as being human or not
The Project ArchaeologistExcavation Director must be notified
Preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 2009
What When bones are uncovered at a site all work in the area the find must stop immediately and the
site must be secured
Who The discoverer will immediately notify machinery operators so that no further disturbance of the
remains will occur as well as notify the foremansite supervisor principal contractor project archaeologistExcavation Director and Sydney Metro Environmental Manager
Preliminary notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager Notification should provide verbal description of the remains and inform the police that consultation with technical specialists is being undertaken to confirm that the remains are human as well as the burial context (archaeological or less than 100 years old refer Step 2)
How Inform all site personnel of restricted access to the area of the discovery until further notice Area must be fenced off (flagging or temporary exclusion fencing)
Actions Notify site supervisor principal contractor project archaeologist Excavation Director and Sydney Metro Environmental Manger of the find and protect the suspected remains until an initial assessment can be undertaken by a technical specialist
Preliminary notification to NSW Police by Sydney Metro Environmental Manager
Confirm the remains are human
Skeletal remains could either be articulated and in a recognisable form of burial such as a coffin or common burial position of the body (eg supine prone or flexed) or they could be disarticulated or fragmented remains Within the boundaries of a known historic burial ground there is a high probability of the remains being human In a suspected forensic case (less than 100 years old) the remains may have clothing andor human tissue Disarticulated or fragmented bones are often uncovered and these may require specialist assessment to determine legal jurisdiction
If suspected human remains are identified during the course of project works preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 1999 (refer Step 1) NSW Police would be contacted immediately upon receipt of confirmation of human provenance
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 9 of 24
What Confirmation that the remains are human their burial context - whether they are forensic (less than 100 years) or archaeological (older than 100 years) and suspected ancestry (Aboriginal or non- Aboriginal)
Who Excavation Director and or Forensic or physical anthropologist or archaeologist with specialist skills such as an osteoarchaeologist
Notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager
How Consultation could be undertaken as either an on-site inspection or via good quality photos sent to the nominated technical specialist of 1) the remains and 2) the site general site location of the discovery
Actions Contact nominated technical specialists to confirm that the remains are a) human b) burial context (archaeological or forensic) and c) suspected ancestry (Aboriginal or non-Aboriginal)
For the duration of the Sydney Metro project the nominated technical specialists are
Forensic Anthropologist ndash TBC by contractor for project area
Nominated Excavation Director ndash TBC by contractor for project area
Sydney Metro Environmental Manager to conduct and or oversee liaison with NSW Police
The archaeologist may be able to identify the nature of remains without input from the Forensic Anthropologist The Forensic Anthropologist should be contacted as required
Notification based on jurisdiction (forensic or archaeological)
Once confirmation is received from the technical specialist that the remains are of human origin there are three possible statutory pathways to follow based on the assessment
What Forensic case remains are less than 100 years old
Who If it is determined by specialist assessment (Step 2) that the remains are forensic the remains come
under the jurisdiction of the State Coroner and the Coroners Act 2009
How The NSW Police would likely secure the site and will advise on the procedure to be followed
Actions Environmental Manager to liaise with NSW Police
What Archaeological ndash non-Aboriginal human remains -more than 100 years old
Who Follow the Archaeology Exhumation Methodology as set out in Step 4 below
How Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Actions Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 10 of 24
What Archaeological ndash suspected Aboriginal human remains -more than 100 years old
Who Recording of Aboriginal ancestral remains must be undertaken by or conducted under the direct supervision of a specialist with RAPs present
How The RAPs must be present where it is reasonably suspected that Aboriginal burials or human remains have been encountered
Actions Notify RAPs and follow ACHAR Notification to Heritage NSW
Follow the Archaeology Exhumation Methodology as set out in Step 4
32 Archaeological Exhumation Methodology
The following section provides the archaeological methodology for exhumation and the appropriate handling of human remains
Securing the Site
The strategy for the excavation and removal of human remains must be sensitive to public opinion and ethical issues and exhumation activities should not be visible to the general public The site may need to be screened off from public areas not only with hoarding but also in some cases with a roof to screen the site off from overlooking buildings At all times human remains should be treated with respect and dignity The perimeter of the excavation site should be demarcated by plastic tape or flagging with only technical staff allowed within this area for the duration of exhumation activities
The site should be protected from the elements including flooding contamination with dust or debris and other disturbance These measures would be formulated by the Excavation Director in consultation with the contractor and Sydney Metro where required and may differ from site to site
Excavation Director
Archaeological investigations are to be managed by a suitably qualified Excavation Director with experience in the historical archaeology of Sydney and the excavation and management of human remains For sites with potential for locally significant remains the Excavation Director should meet the NSW Heritage Council criteria for locally significant archaeological sites For sites with potential for State significant archaeology the Excavation Director should meet the NSW Heritage Council criteria for State significant archaeological sites
Excavation and recording
Exhumation and recording is to be undertaken in accordance with best practice forensic and Heritage Council guidelines Prior to removal the remains should be fully recorded in situ to understand their surrounding archaeological context This will include recording any disturbances to the burial and the identification of bones present In some cases the deposit of bones may be a mixture of articulated and disarticulated remains Care should be taken to distinguish articulated remains and to assess if they represent commingled individuals or disturbed remains belonging to one individual and to record them accordingly
Recording
A standard context recording system would be employed
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 11 of 24
Detailed survey andor measured drawings would be prepared and include location of remains within the overall site (position of the body the direction of the burial noting any stratigraphic relationships with other archaeological features)
Any associated artefacts (potential grave goods burial furniture) would be recorded and collected by context for later analysis
Digital photography in RAW format using photographic scales and photo boards where appropriate A photographic record of all phases of the work on site would be undertaken
Registers of contexts photos samples and drawings would be kept
Excavation
Detection of the extent of the graveremains (if disarticulated)
Surface soils removed in excavation units of 100mm (site dependent) using small hand tools
Expose remains with soft paint brushes and pedestal the remains
Record position and depth of remains
Soil removed would be sieved through 3mm mesh to examine for teeth and bone fragments
Soil samples may be taken from the abdominal andor chest areas of the body (articulated remains) to retrieve further evidence
Exhumation must be under the control of the Excavation Director with the assistance of a Forensic Anthropologist if required Exhumation permits provided by NSW Ministry of Health may also require the presence of an authorised officer or a member of staff of the Ministry of Health
Further excavation of the bottom of the pit (grave) following removal to confirm the absence of further remains
Relocation of bones
Removal and collection of skeletal remains to follow standard forensic practice of labelling
Remove remains from the ground systematically and place in plastic bags according to anatomical areas of the body
Bags should not be air-tight and should have ventilation holes to prevent deterioration of fragile skeletal material Each bag should contain labels and the separate bags should then be placed in a large plastic bag crate or box labelled with the context information
The remains should be placed in a sturdy large cardboard box (approximately 600 x 300 x 200 mm) for relocation to off-site processing location
Resume work
Construction work may only recommence upon receipt of clearance certificate from the Excavation Director and may require additional NSW Ministry of Health approval If a forensic case written authorisation from the NSW Police is required
Reporting
A report would be prepared following the completion of the program of exhumation works separate to the archaeological excavation report for the project This report would include skeletal analysis catalogue comprehensively describe the process of exhumation detail
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 12 of 24
the recording of the remains and synthesise the results of any further laboratory testing An assessment of significance for the remains would be provided and interpreted within the context of the archaeological research design (response to research questions)
Unclassified
Sydney Metro Exhumation Procedure v4 (Final)
Unclassified
Figure 2 Exhumation Procedure Flow chart
Page 13 of 24
Discovery of bone
Non-human remains
Archaeologist to investigate and work not
to recommence until instrcuted by ED
Work only to recommence when clearance given by Excavation Director
Human Remains
Forensic
Sydney Metro Environmental
Manager to advise NSW POlice
Archaoelogical work not to recommence until clearance given
by NSW Police or Coroner
Aboriginal
Sydney Metro Environmental Manager to advise NSW Policye notify RAPs and follow
ACHAR
Archaoelogical work not to
recommence until clearance firven by
NSW Police or Coroner
Non Aboriginal
Sydney Metro Environmental Manager to notifiy NSW Policce Heritage NSW and DPIE
Sydney Metrocontractor to apply to Secretary of
Health to exhume
Exhumation of human remains by nominated ED Construction work not to commence until
ED issues Clearance Certificate
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
4 Excavation and post-excavation tasks
The following tasks relate to responses to the identification of human remains on site All management should be in accordance with the AARD and relevant Archaeological Method Statement (AMS) and be overseen by the Excavation Director The Excavation Director would nominate a Forensic Anthropologist where required
41 Research Questions
The following research questions should be used guide exhumations should intact burials disarticulated remain burial cuttings or associated material culture be uncovered during works
The research questions are a guide only and could be added to or amended by the Excavation Director depending on the nature of the find
Social History and Burial Practices
Does the location of the burialburial cutting correspond with historic plansdescriptions Are these sources reliable
Is there evidence of exhumation
Do graves cut into older ones What can this tell us about nineteenth century burial practices and how does this compare to other excavated cemetery sites in the region
What is the distance between burials (if multiple burials uncovered) Does this conform to known nineteenth century burial practices
What type of fill was used within grave cuttings What can this tell us about the surrounding environment and burial practices at the time
What materialstree species were used to produce coffins Can coffin manufacturing techniques or fastening methods (use of mortar screws nails tacks) be identified Does this match known burial practices of the time If alternative methods are identified what can this tell us about the manufacturer or economicsocial landscape
Can the class or rank of the individual be identified via coffin materials grave goods or clothingshrouds
Which direction is the burial orientated How does this correspond with the knownhypothesised location of denomination areas
If the burial is associated with additional individuals can a familial relationship be assessed through DNA or other genetic markers identifiable within the skeletal remains (eg impacted third molar)
Can an exchange between burial practices in Britain and colonial Sydney be identified through the burial remains Is there evidence for alternative burial practices associated with additional cultures
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Environmental Factors and Scientific Analysis
What is the condition of the bones How does their condition compare to known or nearby burials of the same age What environmental or human factors may have influenced the decomposition process
Can the health nutrition sex race stature or age be identified through the skeletal remains Is there evidence of trauma on the bones Is there evidence of pathology on the bones (eg syphilis tuberculosis tumours)
If archaeobotanical analysis is carried out what can it tell us about the surrounding environment and nearby plant species Can prepost-European landscapes be determined within the archaeobotanical record
Can stable isotope analysis address any questions regarding diet country of origin and nutrition
Can DNA testing address any questions not answerable by the skeletal remains themselves such as sex familial relationships (if buried with another individuals) or race
Is there potential for DNA to be tested against any individuals who may come forward as a descendant of the deceased
42 Process for DNA Testing Isotope Analysis and Environmental Sampling
Pre-Excavation
The Excavation Director in consultation with the Forensic Anthropologist will nominate a suitable laboratory prior to works commencing Approval for the analysis of skeletal remains soil samples and material samples from the laboratory would also be sought prior to works commencing
Excavation
In order to prevent cross-contamination the following sample collection and excavation process should be followed
The location quantity and material (bone teeth hair soil wood) of samples will be determined by the Excavation Director or Forensic Anthropologist prior to its collection
Samples would be stored in a safe secure and climate controlled location while excavations are in progress This would be chosen by the Excavation Director or Forensic Anthropologist on site
Each collected sample would be given a unique catalogue number and a sample register would be recorded throughout the excavation
ldquoClean Excavationrsquo procedures would be followed during the excavation of burials and during the sample collection process7 This would include
7 Guidelines for lsquoclean excavationrsquo are based on procedures outlined in Yang D Y amp Watt K 2005
Contamination controls when preparing archaeological remains for ancient DNA analysis Journal of Archaeological Science vol 32 pp 331ndash336 and Society for Historical Archaeology 2015-2017 Research and Analysis of Artefacts Accessed online at httpsshaorgconservation- factsfaqanalysisC on 2552017
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Latex gloves would be worn by individuals excavating andor handling bone or soil samples Gloves would be changed for each bone andor individual to prevent cross-contamination
Excavation toolsbrushes would be cleaned prior to and after the collection of each sample to prevent cross-contamination
In some cases a face mask would be worn when samples for DNA analysis are being collected
Bone samples for DNA testing would be collected with surrounding in situ soil and should not be cleaned prior to bagging
It may be necessary for individuals involved in sample collection to submit DNA for comparison in the event of cross-contamination and
All bags containing samples for analysis would be bagged and labelled appropriately to prevent cross contamination and ensure they are handled and stored correctly
Post-Excavation
On completion of excavations samples will be transported to nominated laboratories for analysis A record of their location will be kept
43 Reporting
The results of the investigation of human remains and the exhumation will be included in the archaeological reporting for the project in accordance with the project AARD
Once finalised all archaeological excavation and data analysis reports will be submitted to
The relevant local Council and Library
The Heritage Office Library
The State Library of NSW and
Made available online for public access and educational purposes
Further if significant remains are identified during excavations the results and findings would be published in academic journals and conference papers where feasible
44 Public Involvement
Archaeological excavations may uncover remains directly associated with early settlement and burial practices Such remains are likely to generate public interest
Public involvement may include
Media releases
Public Open Days
Preparation of brochures detailing the archaeological excavations
Interpretive signage and online blog posts or site diaries while excavations are taking place and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The preparation of a Heritage Interpretation Plan designed to provide interpretation of the site within the new development upon the completion of works
Due to sensitive nature of human skeletal remains these recommendations would be adapted and modified as appropriate under the direction of Sydney Metro and the Excavation Director
Such recommendations would also be considered and require approval from relevant Stakeholder Groups such as known or potential descendants of the deceased NSW Heritage Heritage Council local Council and interest groups
45 Temporary Storage and Permanent Repository or Resting Place for Remains
Temporary Storage
Upon the completion of archaeological excavations skeletal remains should be boxed separately and temporarily stored within a safe secure and temperature controlled environment to allow for further analysis of the remains This location would be chosen by the Excavation Director and the Forensic Anthropologist and comply with NSW legislative requirements
Permanent Repository or Resting Place for Remains
A permanent repository or resting place for remains is dependent on the nature and volume of skeletal remains As this cannot be determined prior to excavations taking place the following recommendations should act as guidelines only Final arrangements would be dictated by Sydney Metro the Excavation Director Forensic Anthropologist identified descendants of the deceased andor Stakeholder Groups upon the completion of excavations and subsequent analysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
5 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined inhttpsicentraltdocstransportnswgovauotcscsexeappnodes3574566
6 Related Documents and References
Related Documents and References
na
7 Superseded Documents
Superseded Documents
Exhumation Management Plan Version 22
Exhumation Management Plan Version 30
8 Document History
Version Date of approval Notes
11 May 2017 New IMS document
20 July 2017 Incorporates Stage 2 (Section 3)
21
February 2019
Extended for Metro Program wide application includes changes specific Central Station management incorporates comments received from the State Coronerrsquos Office NSW Police NSW Health Sydney Metro Environmental Environmental Representatives engaged on the Central site and the Office of Environment and Heritage
22 February 2019 Incorporates comments received from Artefact Heritage and Denise Donlan issued to Health and OEH HD for consultation
30 May 2019 Incorporates Health Coroner and OEH comments
40 April 2020 Updates to remove specific references to City and South West and Central Station
Change of title to ldquoProcedurerdquo
Update to references
9 Schedule of Acronyms
Acronym Meaning
AARD Archaeological Assessment and Research Design
ACHAR Aboriginal Cultural Heritage Assessment Report
AMS Archaeological Method Statement
CSSI Critical State Significant Infrastructure
ER Environmental Representative (Independent)
ExMP Exhumation Management Plan (this plan)
OEH Office of Environment and Heritage
PHU Public Health Unit
RAPs Registered Aboriginal Parties
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Appendix 1
NSW Heath Policy Directive for Exhumation of Human Remains
Policy Directive
Ministry of Health NSW 73 Miller Street North Sydney NSW 2060
Locked Mail Bag 961 North Sydney NSW 2059 Telephone (02) 9391 9000 Fax (02) 9391 9101
httpwwwhealthnswgovaupolicies
Exhumation of Human Remains
Document Number PD2013_046
Publication date 05-Dec-2013
Functional Sub group Population Health - Environmental
Summary This document provides the policy to be observed by NSW Health in receipt of an application to seek permission for approval of the exhumation of human remains under clauses 69-72 of the Public Health Regulation 2012 This Policy Directive will provide the conditions on which approvals may be granted for exhumation of human remains
Replaces Doc No Burials - Exhumation of Human Remains [PD2008_022]
Author Branch Environmental Health
Branch contact Environmental Health 94245823
Applies to Local Health Districts Environmental Health Officers of Local Councils Ministry of Health Public Health Units Public Hospitals
Audience Authorised officers from Public Health Units and local councils
Distributed to Public Health System Environmental Health Officers of Local Councils NSW Ambulance Service Ministry of Health Public Health Units Public Hospitals
Review date 05-Dec-2018
Policy Manual Patient Matters
File No 081292
Status Active
Director-General
This Policy Directive may be varied withdrawn or replaced at any time Compliance with this directive is mandatory for NSW Health and is a condition of subsidy for public health organisations
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 1 of 2
EXHUMATION OF HUMAN REMAINS
PURPOSE
This document provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Common reasons for exhuming bodies include to repatriate the remains overseas or to relocate the body to another cemetery plot or vault
MANDATORY REQUIREMENTS
Under Clause 69 of the Public Health Regulation 2012 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General
An application for approval to exhume the remains of the body of a dead person may be made to the Director General by
An executor of the estate of the dead person
The nearest surviving relative of the dead person
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person may make the application
An application is to be made in the approved form and it is to be accompanied by
A certified copy of the death certificate relating to the dead person
A statutory declaration as to the relationship of the applicant to the dead person and the dead persons wishes if any regarding the disposal of his or her body
An application fee
Under Clause 71 of the Public Health Regulation 2012 the Director-General may
Grant an approval to exhume the remains of a body
Refuse the application
Under Clause 72 an exhumation cannot take place without an authorised officer or a Ministry of Health staff member present A person must not proceed with an exhumation if the authorised officer or Ministry of Health staff member who is present at the exhumation orders the exhumation to stop
Under Clause 78 if the applicant seeks to have the exhumed body cremated a separate application can be made for an exemption from providing the required cremation documentation provided the body has been buried for longer than 10 years The minimum 10 year period is strictly enforced An application under this clause is to be accompanied by a fee of $100
IMPLEMENTATION
Authorised officers in Public Health Units of Local Health Districts are responsible for assessing applications for exhumation of human remains and either approving with a set of conditions or rejecting the application Authorised officers should ensure that all of the required document has been submitted with the application fee and that an appropriate person has applied for the application The approval granted is valid for a period of three months after the approval is granted
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 2 of 2
REVISION HISTORY
Version Approved by Amendment notes
December 2013 PD2013_046
Deputy Director- General Population and Public Health
This document is an updating of the original document due to legal changes under the Public Health Regulation 2012
23 April 2008 PD2008_022
Director-General This document provided the policy to be observed by NSW Health in receipt of an application to seek permission for approval of exhumation of human remains under clauses 25 ndash 28 of the Public Health (Disposal of Bodies) Regulation 2002 It provided the conditions upon which approvals could be granted for the exhumation of human remains
ATTACHMENTS
1 Exhumation of Human Remains Procedures
Exhumation of Human Remains PROCEDURES
Issue date December-2013
PD2013_046
Exhumation of Human Remains
Issue date December-2013 PD2013_046 Contents Page
PROCEDURES
CONTENTS
1 BACKGROUND 2
11 Introduction 2
12 Key definitions 2
13 Legal and legislative framework 3
2 APPLICATION REQUIREMENTS 6
3 APPROVAL BY PUBLIC HEALTH UNITS 7
31 Delegation 7
32 Special Considerations on Exhumation Approval 7
33 Conditions of Approval 8
34 Approval Instrument 8
35 Notification of Approval 8
36 Refusals 8
37 Cremation of Remains 8
APPENDIX 1 10
APPENDIX 2 11
APPENDIX 3 12
APPENDIX 4 13
APPENDIX 5 14
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 2 of 14
1 BACKGROUND
11 Introduction
Exhumation of human remains may occur for a number of reasons including
To satisfy family wishes where the family of the deceased person may want the remains to be moved to another burial ground to another part of the state or country or abroad or even to have the remains cremated
To obey Coronial orders requiring exhumation for forensic (criminal) investigation
To enable the use of closed cemeteries for redevelopment or for the construction of new infrastructure such as a road or airport
A variety of people including authorised officers cemetery authorities and funeral directors are involved at different stages of exhumation procedures
Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation however there is no obligation to proceed with an exhumation once it has been approved
The objectives of this document are
To assist authorised officers with processing applications to exhume
To standardise the management of an exhumation so as to prevent a public health risk and protect community amenity in the handling of remains
12 Key definitions
These definitions are repeated from the Public Health Act 2010 and Public Health Regulation 2012 for clarity
Body Means the body of a dead person but does not include
the cremated remains of the person
Burial Includes putting the body in a vault
Cemetery Authority Means the person or body that directs the operations of a cemetery
Coroner Means a person who exercises or performs the functions of a coroner in accordance with the Coroners Act 2009
Dead person Includes a still-born child (see definition of Still birth)
Exhumation Means the removal of a dead personrsquos remains (not being cremated remains) from a grave or vault but does not include their removal from one vault for immediate transfer to another vault in the same cemetery or their temporary removal for the purposes of reburial in the same grave or vault
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 3 of 14
Funeral director Means a person (other than the operator of a mortuary transport service) who in the conduct of the personrsquos business engages for the purpose of burial cremation or transport in the collection transport storage preparation or embalming of bodies or engages in the conduct of exhumations
Prescribed infectious diseases
Means any one of the following diseases avian influenza in humans diphtheria plague respiratory anthrax smallpox severe acute respiratory syndrome tuberculosis and any viral haemorrhagic fever (including Lassa Marburg Ebola and Congo-Crimean fevers)
Proper person The Director General has the power to decide whether a person is a lsquoproper personrsquo to make an application to exhume the remains of a dead person
Nearest surviving relative
Means (a) In relation to a still-born child a parent or sibling at or above the age of 16 years of the child (b) In relation to a dead person who is not a still-born child ndash the spouse or de facto partner of the dead person immediately before death a parent of the dead person a child at or above the age of 16 years of the dead person or any relative of the dead person who was residing with the dead person when he or she died
Still-birth Consistent with the Births Deaths amp Marriages Act 1995 means the birth of a child that exhibits no sign of respiration or heartbeat or other sign of life after birth and that (a) Is of at least 20 weeksrsquo gestation (b) If it cannot be reliably established whether the period of gestation is more or less than 20 weeks has a body mass of at least 400 grams at birth
13 Legal and legislative framework
Public Health Regulation 2012
Division 4 of Part 8 of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies
Clause 69 Exhumation without approval prohibited
(1) A person must not exhume the remains of a body unless the exhumation of those remains has been
(a) Ordered by a coroner
(b) Approved by the Director-General
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 4 of 14
(2) However a funeral director may without a coronerrsquos order or Director-Generalrsquos approval transfer a coffin from a vault in a cemetery to a mortuary for the purpose of the coffin being immediately repaired and returned to the vault
(3) A funeral director must return the coffin to the cemetery within 24 hours of its transfer
Clause 70 Application to exhume remains
(1) An application for approval to exhume the remains of the body of a dead person may be made to the Director-General by
(a) An executor of the estate of the dead person
(b) The nearest surviving relative of the dead person
(c) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances may make the application
(2) An application is to be made in the approved form and is to be accompanied by
(a) A certified copy of the death certificate relating to the dead person
(b) A statutory declaration as to the relationship of the applicant to the dead person and the dead personrsquos wishes if any regarding the disposal of his or her body (so far as any such wishes are known to the applicant)
(c) An application fee (please check with the PHU for the current fee)
(3) In this clause death certificate means a certificate given by a medical practitioner as to the cause of death or issued under the Births Deaths and Marriages Registration Act 1995
All applications to exhume remains must be made in writing using an approved form to the Director of the local Public Health Unit that acts on behalf of the Director-General of the NSW Ministry of Health The application fee may increase periodically in line with the Consumer Price Index
Clause 71 Approval to exhume remains
(1) The Director-General may
(a) Grant an approval to exhume the remains of a body subject to any conditions specified in the approval
(b) Refuse the application
(2) An approval granted under this clause remains valid for three months from the date of the approval or for a period agreed to by the Director-General
The PHU is not bound to approve the application The PHU may approve subject to conditions or refuse the application An approval is normally given for 3 calendar months and this date will be specified in a schedule of conditions attached to the approval document Any further extension of time may require re-application and re-approval An approval initially for longer than three calendar months should be negotiated with the PHU
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 5 of 14
Clause 72 Exhumation not to take place without authorised officer present
(1) A person must not proceed with an exhumation unless an authorised officer or a member of staff of the Ministry of Health is present at the exhumation
(2) A person must not proceed with an exhumation if the authorised officer or Ministry staff member who is present at the exhumation orders the exhumation to stop
The grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer An authorised officer must be present at the exhumation to ensure that the correct interment is opened to ensure that all of the remains are exhumed and to enforce the protection of public health should this be necessary The authorised officer has the power to order that the exhumation be stopped immediately under adverse circumstances An example of where this may occur is where the weather is very poor with heavy rain The initial order to stop is to be given verbally and then confirmed in writing to all parties involved within 24 hours
Division 5 of Part 8 of the Public Health Regulation 2012 provides for cremation of deceased persons
Clause 78 No cremation without documentation
Clause 78 does not apply to a cremation of the body of a dead person that has been buried for at least 10 years if the cremation is carried out in accordance with an exemption granted by the Director-General following an application by
1) An executor of the estate of the dead person
2) The nearest surviving relative of the dead person
3) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
This is a new addition to the Exhumation section of the Regulation that may be used where a person makes a separate application to have the exhumed body cremated following the exhumation
Note The Director-Generalrsquos authority under Clause 78 (4) of the Public Health Regulation 2012 (Delegations Manual page 866 delegation (PH590)) is the power to decide whether a person is a ldquoproper personrdquo to make an application in the absence of an executor or surviving relative
Work Health and Safety Act 2011
The Work Health and Safety Act 2011 and Code of Practice for Excavation provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation The Work Health and Safety Act 2011 makes reference to working in confined spaces
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 6 of 14
WHampS matters are enforced by WorkCover NSW More information on safe work practices is available at httpwwwworkcovernswgovaudefault or by contacting Workcover NSW direct on 13 10 50
Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977 applies to relic burials Any burial site over 50 years old is considered to be relic under the Heritage Act If the site is listed on the State Heritage Register then approval is required from the Heritage Council of NSW
An application must be made to the Heritage Office before any disturbance removal or work commences on the site Approval for an exhumation under the Public Health Regulation 2012 does not obviate the necessity to obtain approval under the Heritage Act 1977 For further information contact the Heritage Office of NSW or visit httpwwwheritagenswgovau
Coronerrsquos Act 2009
A coroner may order an exhumation for the purposes of forensic investigation or a criminal investigation Such an order is outside the ambit of the Public Health Regulation 2012 The Police may request that an authorised officer from the Ministry of Health or the local Public Health Unit be present at the coronial exhumation
Births Deaths and Marriages Registration Act 1995
Section 41(2) of the Births Deaths and Marriages Registration Act 1995 requires that if human remains (other than cremated remains) are removed from NSW the funeral director or other person who arranges for the removal of the remains from NSW must within 28 days of disposal of the remains outside NSW give the Registrar notice of the new location of interment The act is available at httpwwwaustliieduauaulegisnswconsol_actbdamra1995383 The Registry of Births Deaths and Marriages may be contacted via httpwwwbdmnswgovau
2 APPLICATION REQUIREMENTS
An application for permission to exhume the remains of a deceased person is to be made to the PHU on the approved form which is contained at the NSW Ministry of Health website at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c70- application-to-exhumepdf
The application must be made by either
An executor of the estate of the deceased
The nearest surviving relative
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 7 of 14
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
The application must be accompanied by
A certified copy of the death certificate (death certificate issued by the Registry of Births Deaths and Marriages)
A statutory declaration that states
The relationship between the applicant and the deceased or the reason the applicant is the proper person to make the application
If the deceased left any instructions regarding the disposal of their bodyremains if known
In addition to the above an applicant should declare that he or she has consulted each nearest surviving relative and that they have no objection to the proposed exhumation
An application fee (please check with the PHU for the current fee)
Note If there is no agreement amongst nearest surviving relatives the applicant should seek independent legal advice regarding this issue The applicant should advise if there is an intention to cremate the body following the body being exhumed and the appropriate form completed
3 APPROVAL BY PUBLIC HEALTH UNITS
Approval by PHUs for an exhumation must be given by formal correspondence
31 Delegation
The Director-Generalrsquos authority under clauses 69(1) 70(1)(c) and 71 of the Public Health Regulation 2012 has been delegated to the Chief Health Officer Director Health Protection Public Health Officer or Public Health Unit Director as appointed under Section 121 of the Act (delegation PH308 PH309)
32 Special Considerations on Exhumation Approval
Special consideration should be given to the approval of an exhumation if the deceased was infected with a prescribed infectious disease For example if the deceased was infected with diphtheria or tuberculosis exhumation should not permitted in the first year of interment
Although not prohibited an exhumation of the remains of a body that was buried without a coffin will be approved only where the cemetery authority and funeral director have agreed to proceed with the exhumation especially during the first three years of interment
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 8 of 14
33 Conditions of Approval
After due consideration of the application and the statutory declaration(s) the PHU should then consider applying appropriate conditions to facilitate an approval
There are two standard sets of approval conditions which can be applied as appropriate
Appendix 2 ndash Schedule A - Conditions of Approval for Exhumation from a Grave
Appendix 3 ndash Schedule B - Conditions of Approval for Exhumation from an Above Ground Structure
Any other additional conditions that are deemed necessary to permit the exhumation may be added to schedule A or B based on the individual circumstances of the exhumation If some conditions are unwarranted they may be removed from the relevant schedule
34 Approval Instrument
An approval must be in writing and must be signed the Director General or their delegate A template to assist in the approval process can be found at Appendix 4 This template is to be completed by the Authorised Officer in order to facilitate approval by the delegate
35 Notification of Approval
The approval instrument is retained on file as a record that approval was granted by the Director General or their delegate Therefore it is necessary to advise the applicant the cemetery authority and the funeral director of the approval
The attached letter templates may be used for approval notification of the exhumation to the applicant funeral director and Cemetery Authority
Appendix 5 ndash Sample Letter to Applicant
Appendix 6 ndash Sample Letter to the Cemetery Authority and Funeral Director
36 Refusals
If after due consideration the application is to be refused then the applicant should be notified in writing specifying the reasons for refusal Ideally the applicant should consult the PHU in the first instance to discuss the requirements and possible restrictions on an application to exhume
37 Cremation of Remains
Division 5 of Part 8 of the Public Health Regulation 2012 sets out the requirements for documentation for cremations in NSW and includes the requirement for a cremation application form a cremation certificate and the cremation permit The documentation confirms the identity of the body to be cremated and the cause of death and ensures that a coronerrsquos investigation has been conducted where necessary
After the body is exhumed the next of kin may wish to have the body cremated However there may be cases whereby the body does not have the required paperwork necessary for cremation Clause 78 of the Public Health Regulation 2012 provides an exemption for
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 9 of 14
the required documentation for cremation where the body has been buried for longer than 10 years An application under this clause is to be accompanied by a fee
The Director General has the power to approve an exemption and the executor or the nearest surviving relative or another proper person may make application on form lsquoApplication for Exemption by the Director ndash General to the Requirement for Documentation for Cremation to Proceed Permission for Cremation of Exhumed Remains of a Body Buried more than 10 years ago with statutory declarationrsquo The minimum 10 year period will be strictly enforced and this matter should be clarified prior to any exhumation approval where it is planned for the remains to be subsequently cremated The application form is available at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c78-application-for- exemptionpdf
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 10 of 14
APPENDIX 1
Schedule A
CONDITIONS OF APPROVAL FOR EXHUMATION FROM GRAVE
1 The exhumation is to be carried out in the presence of a Public Health Unitrsquos authorised
officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Day and time of the exhumation shall be arranged by the participating parties and agreed
to by the Public Health Unit
4 The approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The presence of any relative of the deceased at the exhumation is strictly prohibited
6 No animals are to be permitted within the exhumation site
7 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
8 If during the course of the exhumation it is determined necessary to stop the exhumation
by either the exhumation supervisor cemetery manager or authorised Officer for any valid reason eg work health and or public health risk then the exhumation must cease
9 The remains of the deceased shall be enclosed in a body bag and placed into a new coffin
with a name plate attached inscribed with the name of the deceased
10 The remains of the original coffin are to be placed in the new coffin where possible Where there is an excess of remains of the original coffin these remains should be disposed in a sanitary and agreed manner
11 Excavated soil should be back filled The soil that was removed from immediately above
and around the coffin should be replaced first
12 If the exhumed remains are to be transferred to another cemetery a funeral director shall be contracted to transfer the remains from the cemetery grounds or carry out preparatory work for the safe reinterment of the remains
13 The exhumation will not proceed during or following a period of heavy rainfall within the preceding 24 hours of the appointed time of exhumation The cemetery manager is to confirm that satisfactory conditions exist for the exhumation to proceed two hours prior to the commencement of the exhumation
14 Used disposable protective equipment and materials are to be placed in a sealed plastic
bag and disposed of in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 11 of 14
APPENDIX 2
Schedule B
CONDITIONS OF APPROVAL FOR EXHUMATION FROM ABOVE GROUND STRUCTURE
1 The exhumation is to be carried out in presence of a Public Health Unit authorised officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Date and time of the exhumation shall be arranged by the participating parties and agreed to
by the Public Health Unit
4 An approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
6 If during the course of the exhumation it is determined necessary to stop the exhumation by
either the exhumation supervisor Cemetery Manager or authorised officer if for any valid reason eg worker health andor public health risks then the exhumation must cease
7 Used disposable protective equipment and materials are to be placed in a sealed plastic bag
and disposed in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 12 of 14
APPENDIX 3
LETTERHEAD
APPROVAL INSTRUMENT TEMPLATE
Public Health Unit Environmental Health Section
File Number [XXXXX]
PURPOSE To approve of the exhumation of the late
RECOMMENDATION
Approval is granted by the Director General pursuant to clause 71(1)(a) Public Health Regulation
2012 to [NAME OF APPLICANT] to exhume the remains of the late [NAME OF DECEASED]
KEY ISSUES
[DETAILS OF THE APPLICATION STATUTORY DECLARATION RELEVANT ISSUES
MANAGEMENT PLAN AND JUSTIFICATION OF SUGGESTED CONDITIONS ARE TO BE
INCLUDED HERE]
BACKGROUND (TO BE COMPLETED BY PHU)
CONSULTATION (TO BE COMPLETED BY PHU WHERE APPROPRIATE)
The approval be subject to compliance with the conditions specified in Schedule A Schedule B
and to expire on
Signature Authorised officer
Author Telephone Date
1 Authorised officer
2 Public Health Unit Director Public Health Officer [SIGN AND DATE]
Approved via delegation from the Director-General PH308 PH309 page 863 Public
Health Delegations Manual under clause 69(1) and 70(1) (C) Public Health Regulation
2012
3 Authorised officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 13 of 14
APPENDIX 4
LETTERHEAD
SAMPLE LETTER TO APPLICANT
[APPLICANTrsquoS NAME] [ADDRESS]
Dear [APPLICANTrsquoS NAME]
Reference is made to your application of [DATE] requesting approval to exhume the remains of
late [NAME OF DECEASED] from grave vault crypt No Section [NAME OF
PLACE OF INTERMENT OR CEMETERY] for the purpose of re-interment to [NAME OF PLACE
FOR RE-INTERMENT]
Approval has been granted by the Director-General pursuant to clause 71 (1) (a) Public Health
Regulation 2012 subject to compliance with the conditions specified in Schedule A Schedule B
attached
The funeral director and cemetery authority have been advised of the approval
Should you have any inquiries please contact the authorised officer [EHO] on [TELEPHONE] or (EMAIL ADDRESS)
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 14 of 14
APPENDIX 5
LETTERHEAD
SAMPLE LETTER TO CEMETERY AUTHORITY AND FUNERAL DIRECTORS
[NAME] [ADDRESS]
[DATE]
Dear [NAME]
EXHUMATION OF THE REMAINS OF THE LATE [NAME OF DECEASED]
Approval has been granted for the exhumation of the late [NAME OF DECEASED] from grave
vault crypt No Section [NAME OF PLACE OF INTERMENT OR
CEMETERY] in accordance with clause 71(1) (a) of the Public Health Regulation 2012 and
subject to compliance with the conditions specified in Schedule A Schedule B attached
A copy of the approval letter is attached for your information
Should you have any inquiries please contact [Authorised Officer) on [TELEPHONE] or email address
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
Unclassified
Addendum 2
NSW Heath Permit Application form
copy Sydney Metro 2017 Page 23 of 24
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
APPLICATION TO EXHUME REMAINS PUBLIC HEALTH REGULATION 2012 Clause 70(2)
In accordance with the requirements of Clause 70 (2) of the Public Health Regulation 2012 I helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Full name of applicant)
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip hereby (Address)
apply for permission to exhume the remains of the late helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Name of deceased)
from Grave Nohelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Section helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip being a single
interment within the helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipCemetery for the purpose of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
I seek permission to exhume for the following reasons
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
The deceased (cross out which is not applicable)
was not known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012 or
was known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012
I am entitled to make this application because I am (tick one)
1 [ ] The executor of the estate of the deceased or
2 [ ] The nearest surviving relative of the deceased or
3 [ ] If there is no such executor or relative available to make the application another the proper person to make the application for the reasons set out below
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Full reasons for proper person to make application) Attached is
1 A certified copy of the death certificate of the deceased
2 A statutory declaration as to
My relationship to the deceased and
the wishes of the deceased regarding the disposal of the body (if known)
the reasons why the Director-General may consider me the proper person in all the circumstances to make the application (if applicable)
3 The application fee of $helliphelliphelliphelliphelliphelliphellip
Signature helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Date helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Applicant)
The exhumation is to be supervised in strict accordance with the attached Plan of Management
by helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
employed with helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip(Funeral DirectorCemetery)
in the capacity of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
Form C70
Unclassified
copy Sydney Metro 2017 Unclassified Page 24 of 24
ExMP v30 (final)
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
bttp wwwshd nsw gay auQQpulat onhealthPubtic Healthhtml
NSW
Public Health Unit ll iI I
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 57 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise gaseous and particulate pollutant emissions from construction activities as far as feasible and reasonable Identify and control potential dust and air pollutant sources
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Site related dust identifiable fumes odours and vapours will not infringe beyond site boundaries where practical
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required for air quality and dust management including - Correct use of PPE - Use of monitoring equipment - Methods to control dust
Project Manager
Greenhouse Gases
Regular maintenance of plant and equipment for optimum performance will be undertaken to keep emissions to a minimum and increase plant productivity
Vehicles and equipment must be fitted with appropriate emission control equipment and routinely maintained Plant should be switched off when not in use wherever practicable
All plant equipment and vehicles are to be regularly monitored and maintained and records kept of maintenance Engine tampering to increase power output is prohibited
Air emissions from plant vehicles and equipment should be visually monitored throughout construction
Comply with National Greenhouse Emission Reporting Scheme (NGERS) reporting requirements
Project Manager
Dark Smoke
All internal combustion engines will be regularly serviced to ensure optimum operation and minimise the volume of visible smoke emitted Any Plant or light vehicles emitting unreasonable smoke (concentrations higher than normal operation) will cease operation and be serviced by a trained and qualified technician
Materials on site will not be burned intentionally without consulting and obtaining the authorisation of the relevant Local Shire Fire Authority and Client The burning of any material on site should be a last option after alternative methods have been considered
All
Dust Monitoring
The following dust monitoring methods will be applied on the Site
Obtaining weather reports from the Bureau of Meteorology (BOM) website Visual inspection
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 58 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Dust Control
Dust control methods to be applied on the site to keep dust generated within the site boundaries as reasonably practicable will be
- Wind fencing around the site or between the site and local residences - Application of waterdust suppressant via water carts - Hydro mulching to stabilise soils - Physical application of ground cover - Cessation of works in adverse weather conditions - Restricted speed limits on site - Reschedule dust generating activities to avoid adverse weather conditions - Communicate dust risk and mitigation measures to staff prior to commencing work
All
Fumes Odours and Vapours
The Site will endeavour to keep the generation of emission of unreasonable levels of fumes odours and vapours to a minimum Refer to the Waste Management Sub Plan and Hydrocarbon and Chemical Environmental Management Sub Plan which detail storage and handling controls that minimise fumes odours and vapours
All
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for dust mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 59 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise unreasonable noise and vibration impacts on residents and businesses Avoid structural damage to buildings or heritage items as a result of construction vibration Undertake active community consultation Reduce visual impact of construction to surrounding community Maintain positive cooperative relationships with schools childcare centres local residents and building owners
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Community
The nearest noise and vibration sensitive receivers will be notified of future works and expected levels of noise and vibration well in advance of the works occurring Notifications will be in accordance with the Community Communications Strategy
Information will be provided to the affected community before and during construction through media such as letterbox drops meetings or individual contact A website will also be established for the project to provide information
A toll-free 24hour project hotline will be provided for enquiries and complaints during the works
Sydney Metro and Georgiou Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the site specific management required
for noise and vibration including
- Sensitive receivers - Hours of works - Correct use of plant and equipment - Monitoring requirements
Standard hours of construction
Approved standard hours of construction are Monday to Friday
7 am to 6 pm Saturday 8 am to 1 pm No work on Sundays or public holidays
Project Manager
Out of Hours works Any out of hourrsquos works will require a noise assessment and approval by Sydney Metro through the out of hourrsquos application (Appendix 7A)
Project Engineer Environmental Site Representative
Plant Equipment amp Vehicles
All operators of plant will comply with requirements of the Construction Traffic Management Plan in relation to parking and laydown access and egress to site haulage routes and general site traffic movements
Plant will be fitted with appropriate noise emissionvibration control equipment Plant will be fitted with adequate seat suspension
Plant Department
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 60 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Plant should be switched off when not in use wherever practicable Tasks using equipment that causes vibration to hands will be rotated at intervals to reduce
exposure Consideration may be given to the use of anti-vibration PPE All plant equipment and vehicles are to be regularly monitored and maintained and records kept
of maintenance Any abnormalities in expected noise or vibration emissions will be recorded in the plantrsquos log
book and reported to the plant department Prioritise the use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of
rockbreakers for demolition of structures Use of smaller capacity rockbreakers or lower vibration generating rockbreakers Consider methods of isolating the vibration sensitive structure from the vibration intensive work
area by severing the vibration transmission path using non-vibration intensive means such a sawing
Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Monitoring
Continuous vibration monitoring will be undertaken whenever vibration generating plant will be working close to or within the recommended minimum working distances
When conducting vibration monitoring within or near the minimum working distances a warning system will be implemented including one or both of an audible andor visual warning alarm andor SMS andor email alerts to site staff
Attended noise monitoring will occur at the nearest noise sensitive receiver when - Requested by Sydney Metro - When noise levels are predicted to exceed the NML by more than 10dBA - When out of hours works continue past midnight - When noise complaints are received
Noise monitoring will determine if the predictions in the noise assessment were accurate
Project Engineer Environmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for noise and vibration mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 61 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7A ndash Sydney Metro Out of Hours Application form
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 1 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Out of hours work application form
This form is to be used for formal review and approval of out of hours (OOH) work as it may affect Residential and non-residential receivers This form can be used in accordance with the SM-17-00005396 City amp Southwest out of hours work protocol Each OOH application and all applicable appendices must be submitted to Sydney Metro as one PDF file at least 15 business days prior to the commencement of the proposed OOH work
1 OOH Application
Sydney Metro Project
Eg City amp Southwest Greater West West etc
Contract
Contractor
Application Title
Eg lsquoSmith St service relocation worksrsquo
Application Number
Eg 1 2 3 etc
Application Date
Original submission date (resubmission date in parentheses if applicable)
Relevant Planning Approval
Environment Protection Licence (EPL)
If subject to an EPL state title and number
2 Proposed OOH Work Details
Description of works including
Work methodologies
List of plantequipment to be used (worst case scenario)
Location Map (andor Environmental Control Map) attached as Appendix 1 indicating location of works plantequipment locations and receivers (including distance to nearest receiver for noisiest plantequipment)
Traffic Management Plan andor Traffic Control Plan if applicable as Appendix 2
Timing of works
Including proposed datestimes works are planned to be undertaken outside standard hours
Worst-case number of consecutive occasions affecting the same receiver
Refer to Section 4 for definition of lsquooccasionrsquo
Justification
Demonstrate how the proposed OOH work has been scheduled in accordance with the OOH work period prioritisation list Program acceleration is generally not accepted as a justification
Unless specified otherwise in project-specific documentation the prioritisation of work time periods is as follows
Standard Hours 7am to 6pm weekdays and 8am to 1pm Saturdays (note that Standard Hours for works subject to the City amp Southwest Sydenham to Bankstown planning approval also include 1pm to 6pm Saturdays)
Daytime OOH 1pm to 6pm Saturdays and 8am to 6pm Sundays and Public Holidays
Evening OOH 6pm to 9pm every day
Night Time OOH 9pm to 7am weekday mornings and 9pm to 8am weekend and Public Holiday mornings
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Assessed Noise and Vibration Impacts and Standard Mitigation Measures
Are the proposed works consistent with a prepared Construction Noise amp Vibration Impact Statement (CNVIS) (YN)
If lsquoNrsquo skip this section and move to Section 4
State the title of the CNVIS and attach the section(s) describing the noise and vibration impacts of the proposed works as Appendix 3
Quantitatively summarise the worst-case predicted noise and vibration impacts specific to the proposed OOH work for each OOH period on the nearest receivers and compare these against the respective management levels
For Night Time OOH Period works include a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Worst-case predicted noise impact summary
Worst-case predicted vibration impact summary
Potential sleep disturbance summary (for night time OOH periods only)
Using Table 4 and Table 5 indicate in Table 6
Which Additional Mitigation Measures (AMMs) are applicable for consideration
Which of those applicable for consideration are planned to be implemented
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered respite alternative accommodation etc)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
4 Non-Assessed Noise and Vibration Impacts
Skip this section if Section 3 has been completed in full
A quantitative noise assessment for OOH work is to be carried out in accordance with the Interim Construction Noise Guideline (DECC 2009) This section allows applicants to address these requirements through the following steps
1) Establishing Rating Background Levels (RBLs) and Noise Management Levels (NMLs)
2) Predicting the anticipated noise levels using a quantitative noise assessment
a Works that are not likely to generate high noise impacts for a significant duration may use a preliminary quantitative noise assessment (facilitated within this form) This ensures that all applications as a minimum include a preliminary quantitative noise assessment in accordance with the Interim Construction Noise Guideline (ICNG)
b Works that are likely to generate high noise impacts for a significant duration may require a detailed quantitative noise assessment (eg Construction Noise and Vibration Impact Statement) to be undertaken
c Works that are likely to generate ground-borne or structure-borne vibration andor noise require specialist advice and assessment
3) Comparing predicted noise levels against RBLsNMLs and applying standard mitigation measures as appropriate (ie implementing lsquoall feasible and reasonablersquo mitigation measures in accordance with the ICNG)
4) Considering additional mitigation measures when predicted noise levels exceed RBLsNMLs
The need for a detailed quantitative noise and vibration assessment will be considered by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable) collectively when the predicted noise levels are anticipated to
Exceed an RBL at a residential receiver or an NML at a non-residential receiver by more than 10dBA AND
Affect the same receiver on 10 or more consecutive occasions An occasion is anytime works are carried out
o Between 6pm on a weekday and the start of standard hours the next day OR
o Between 1pm on a Saturday and 8am on a Sunday (or between 6pm on a Saturday and 8am on a Sunday for works subject to the Sydenham to Bankstown planning approval) OR
o Between 8am on a Sunday or public holiday and the start of standard hours the next day
A detailed quantitative noise and vibration assessment should generally include
Derivation of RBLs for residential receivers andor derivation of NMLs for non-residential receivers based on noise monitoring at representative locations and local sensitivities
Detailed noise predictions for daytime evening and night time OOH periods (as applicable) in accordance with Section 45 of the ICNG (including an outline of timing duration and predicted noise levels for each OOH period)
For Night Time OOH Period works a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Detailed predictions of vibration levels for sensitive receivers
Please complete the following Steps 1 to 4
Step 1
RBLsNMLs
If RBLs for residential receivers or NMLs for non-residential receivers have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment or Construction Noise and Vibration Impact Statement for other work activities) enter into Table 3 and attach the supporting evidence as Appendix 3
If no RBLsNMLs have been established use Table 1 to estimate and enter into Table 3
Step 2
Predicted Anticipated Noise Levels
If predicted anticipated noise levels have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment) enter the predicted anticipated noise levels into Table 3 and attach the supporting evidence as Appendix 3
If predicted anticipated noise levels have not already been established use Table 2 to estimate anticipated noise aspects for the noisiest plantequipment and enter into Table 3 In Table 3 use these values to calculate the anticipated predicted noise levels
Step 3
Exceedances and Mitigation Measures
Compare the anticipated predicted noise levels to the applicable RBLsNMLs calculate the exceedances and enter into Table 3 In Section 5 provide a description of the standard mitigation measures that are planned to be implemented in order to mitigate the noise impacts (and vibration impacts if relevant) as much as lsquofeasible and reasonablersquo in accordance with the ICNG
Step 4
Consideration of Additional Mitigation Measures
Use Table 4 and the exceedances in Table 3 to determine the applicable Additional Mitigation Measures for consideration Use
Table 6 to indicate which of these measures are applicable for consideration which will be implemented and provide justificationdetails accordingly
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
5 Standard Mitigation Measures
Outline the standard noise mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Outline the standard vibration mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Table 1 Noise RBLs and NMLs
Skip this section RBLs and NMLs have already been established in other documentation
Sensitive Receiver Category Estimated RBLs (dBA)
Residential Daytime OOH Evening OOH Night Time OOH
Urban (eg city hubs near busy roads near industrial activity) 55 50 45
Suburban 45 40 35
Quiet rural or isolated 40 35 30
Non-Residential ICNG NMLs (dBA)
Industrial facilities 75 (only applicable when in use)
Offices or retail 70 (only applicable when in use)
Health and educational facilities 55 (only applicable when in use)
Table 2 Predicted Noise Level Aspects
Skip this section if predicted noise levels have already been established in other documentation
Noise Aspect Select the most applicable value for each noise aspect below and enter into Table 3 dBA
1 PlantEquipment Noise Level at 10m
Including non-continuous use reduction (-5dBA) and annoying activity penalty (+5dBA) for as per ICNG (refer to ICNG Appendix B for predicted noise level data)
Underline indicates vibratory generating plantequipment
Impact sheet piling rig 100
Hand-held tamper excavator with hammer rock-breaker drivenvibratory piling concrete saw diamond saw air track drill large dozer hand-held rail grinder
95
Jackhammer rock crusher angle grinder pneumatic hammer medium dozer tracked loader impact wrench
90
Mainline tamper ballast regulator dynamic track stabiliser vibratory roller mainline rail grinder ballast train (pourfill ballast) chainsaw tub grinderlarge mulcher scraper grader super-suckervacuum truck large backhoewheeled front-end loader bored piling pavement profiler fixed crane tracked excavator
85
Small bulldozer small excavator tower crane truck-mounted crane forklift bobcat skid-steer front-end loader road trucktruck and dog dump truck concrete truckpumpmixer compressor non-vibratorylarge pad foot roller whacker packercompactor water cart pavement laying machine asphalt truck and sprayer line marking truck standard penetration testing welder pin puller
80
Concrete vibrator cherry-picker scissor liftelevated work platformFranna crane small backhoe front end loader fence post driver electric drill rig hand held rattle gun generator (dieselpetrol) spreader
75
Lighting tower medium-rigid trucksemi-trailer welding equipment small front end loader 70
Light vehicle hand-tools (no impact) small cement mixer attenuated generator (inside housing)
65
2 Multiple Plant More than one of the noisiest plant being used simultaneously at roughly the same location +5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Local Screening
Existing screening between site and receiver (buildings cuttings canopies etc) - 5
Temporary screening to be implemented near work site - 10
Acoustic shed or enclosure - 25
4 Distance Attenuation
lt 10 metres 0
10 to 20 metres - 5
20 to 35 metres - 10
35 to 60 metres - 15
60 to 100 metres - 20
100 to 180 metres - 25
180 to 350 metres - 30
350 to 1000 metres - 40
Table 3 Predicted Noise Levels and Exceedances of RBLs andor NMLs (dBA)
Skip this section if Section 3 has been completed in full
Period
(only complete as applicable for each period)
Noisiest PlantEquipm
ent
(state the noisiest
plantequipment to be used during each applicable
OOH period)
Receiver Type
(state lsquoResrsquo or lsquoNon-Resrsquo as applicable for
closest receiver to noisiest
plantequipment)
Enter the most applicable values from Table 2 then add to determine
the Predicted Noise Level
Pre
dic
ted
No
ise L
evel
(1 +
2 +
3 +
4)
RB
L (
for
Res)
NM
L (
for
Non-R
es)
Exceedance
(Predicted Noise Level minus RBL for Res or NML for
Non-Res) 1
Pla
nt
Eq
uip
me
nt
No
ise L
evel
2
Mu
ltip
le
Pla
nt
Eq
uip
me
nt
3
Lo
cal
Scre
en
ing
4
Dis
tan
ce
Att
en
ua
tio
n
Daytime OOH
Evening OOH
Night Time OOH
Refer to OOH period timings under Section 2 of this form
Table 4 Additional Mitigation Measures (AMM) requiring Consideration for Implementation
OOH Period
AMMs that must be considered for implementation
(apply the exceedances from Table 3 to the two OOH period categories below as applicable)
lt= 10 dBA Exceedance
10 to lt= 20 dBA Exceedance
20 to lt= 30 dBA Exceedance
gt 30 dBA Exceedance
Daytime OOH Period ndash LB M LB M IB LB PC RO SN
Evening and Night Time OOH Periods
ndash M LB M IB LB PC SN RO M IB LB PC SN RO AA
AA is only applicable to Night Time OOH periods
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 5 List of Additional Mitigation Measures (AMM)
AMM Abbrev
AMM AMM Descriptions and Guidance
LB
Letterbox-drop
(generic to the project)
A newsletter is generally produced and distributed to the local community via letterbox-drop and the project mailing list These newsletters provide an overview of current and upcoming works across the project and other topics of interest The objective is to engage inform and provide project-specific messages The geographic extent of letterbox-drops is generally centred on the immediate surrounding community within 200 metres from the works site
For works that are subject to the Sydenham to Bankstown planning approval these will include an indicative schedule of likely OOH work for at least the upcoming two month period
M Monitoring
Where it has been identified that specific construction activities are likely to exceed the relevant Rating Background Levels (RBL) andor Noise Management Levels (NMLs) monitoring may be conducted at the affected receiver(s) or a nominated representative location (typically the nearest receiver where more than one receiver have been identified) Monitoring can be in the form of either unattended logging or operator attended surveys The purpose of monitoring is to inform the relevant personnel when the RBLNML has been exceeded so that additional management measures may be implemented
IB Individual Briefings
Individual briefings are used to inform stakeholders about the impacts of high noise activities and mitigation measures that will be implemented Communications representatives would visit identified stakeholders at least 48 hours ahead of potentially disturbing construction activities Individual briefings provide affected stakeholders with personalised contact and tailored advice with the opportunity to comment on the project
PC Phone calls
(andor emails)
Phone calls andor emails (with specific notifications attached) detailing relevant information would be made to identifiedaffected stakeholders within seven days of proposed work The objective of the phone calls andor emails is to support letterbox-drop and specific notifications Phone calls andor emails provide affected stakeholders with personalised contact and tailored advice with the opportunity to provide comments on the proposed work and specific needs
SN
Specific Notifications
(specific to the OOH work)
Specific notifications are letterbox-dropped to identified stakeholders no later than 7 days prior to out of hour construction activities commencing that are likely to exceed the RBLsNMLs Specific notifications may be produced by Sydney Trains or by Sydney Metro (or on behalf of Sydney Metro by a contractor as approved by Sydney Metro)
- Sydney Trains specific notifications cover all works being undertaken by various parties (including Sydney Metro) during designated rail possession periods These specific notifications are delivered 14 days prior to works commencing and are delivered to all properties located within 250m of the proposed works
- Sydney Metro specific notifications focus on proposed Sydney Metro works being undertaken outside of designated rail possession periods and are only produced in the absence of any Sydney Trains notifications covering the proposed works These notifications are delivered 7 days prior to works commencing and are delivered to all properties located within 100m of day works and within 200m of night works
All notifications are emailed to all registered stakeholders on site-specific email distribution lists
For works that are subject to the Sydenham to Bankstown planning approval these will include indicative information on the type of OOH work location duration expected noise characteristics expected noise level and likely mitigation and management measures
RO Respite Offer
The purpose of a project specific respite offer is to provide residents subjected to lengthy periods of noise andor vibration impacts respite during OOH periods Respite offers are offers made to affected receivers to provide a period of either no or limited noise impacts This can be in the form of stopping or limiting works onsite or offering affected receivers dinnermovie vouchers The first priority is to implement a period of no or limited noise impacts If this cannot be achieved dinnermovie vouchers may be offered on a case-by-case basis
AA Alternative
Accommodation (residential only)
Alternative accommodation options may be provided for residents living in close proximity to construction works that are likely to incur unreasonably high impacts during night time OOH periods Alternative accommodation will be considered on a case-by-case basis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 6 Consideration of Additional Mitigation Measures (AMM)
Additional Mitigation Measures
Applicable for Consideration
YN
(refer to Table 4)
To be Implemented
YN
JustificationDetails
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered RO AA etc)
LB
M
IB
PC
SN
RO
AA
For OOH work that is subject to the Sydenham to Bankstown approval and RO is required for consideration include in the lsquoJustificationCommentsrsquo column how community consultation influenced the decision to implement or not implement RO in accordance with Condition E23 If RO is being implemented include how community consultation influenced the manner in which RO is being implemented
6 Consideration Against Relevant Vibration Criteria
Using Table 2 indicate whether any vibratory plantequipment is planned to be used for the proposed works (YN)
If lsquoNrsquo skip this section and move to Section 7
lsquoPeoplersquo Criterion
Are the proposed works anticipated to have any perceptible sleep disturbance impacts (YN)
lsquoStructuresrsquo Criterion
Are the proposed works anticipated to generate greater than 75mms vibration impacts on surrounding structures (generally within 25 metres of works) (YN)
lsquoSensitive Equipmentrsquo Criterion
Are the proposed works anticipated to impact sensitive equipment located in surrounding non-residential receivers (YN)
If lsquoYrsquo is answered to ANY of the above criteria AND the impacts affect the same receiver for more than one consecutive occasion (refer to Section 4 for lsquooccasionrsquo definition) the need to prepare a detailed quantitative assessment will be considered collectively by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
7 City amp Southwest Construction Noise amp Vibration Strategy Addendum Mitigation Measures
If the proposed OOH work is part of the City amp Southwest project identify any mitigation measures to be implemented that have arisen from the City amp Southwest Construction Noise amp Vibration Strategy Addendum
8 Cumulative Impacts
Document the relevant details of any other OOH work (Sydney Metro or otherwise) that will impact the same receivers as those being impacted by these proposed works either concurrently or within 3 days of the start or end of these proposed works
If other works have been identified in the row above how have the proposed works been coordinated to ensure appropriate respite is provided
9 Community Consultation
What community consultation has been undertaken already
What community consultation is planned to be undertaken
If drafted already attach applicable Community Notification as Appendix 4
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
10 Contractorrsquos Signature
Contractorrsquos Identification of Risk Level
If subject to the Chatswood to Sydenham (C2S) or Sydenham to Bankstown (S2B) planning approval and not subject to an EPL provide Contractorrsquos Identification of Risk Level (refer to the City amp Southwest OOH Works StrategyProtocol for guidance)
Circle LOW or HIGH
Contractorrsquos Signature
Name
Title
Contact Number
Date
11 Contractorrsquos Contact Details
Contractor Personnel Name Mobile
Manager Environment
Manager Communications
Contractorrsquos Representative
Contractorrsquos 24hr contact person
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
C2SS2B Planning Approval Determination Page
Step 1 ndash Endorsement from Sydney Metro Director Public
Communications or Contractorrsquos Communications Manager
Step 2 ndash Risk IdentificationEndorsement from the AA under the C2S Planning Approval or from the
ER under the S2B Planning Approval
Step 3 ndash If works are under Sydney Trains EPL approval from Sydney Metro Director of Planning Environment and Sustainability
If works are not under an EPL approval from either the ER or the Secretary of the NSW Department of Planning amp Environment
Risk Level NA
If not subject to an EPL circle Risk Level as LOW or HIGH
If works are HIGH Risk Level and after 9pm Sydney Metro submits application to the Secretary of the
NSW Department of Planning amp Environment for approval
NA
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Role
Date
Comments
(including AAER Risk Level comments if applicable)
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Generic Determination Page (ie not subject to C2S or S2B planning approvals)
Step 1 ndash Sydney Metro Director of
Project Communications
Step 2 ndash Acoustic Advisor
(may be optional depending on planning approval or contract requirements)
Step 3 ndash Environmental Representative
(may be optional depending on planning approval or contract requirements)
Step 4 ndashSydney Metro Director of Planning Environment amp Sustainability
(only required if not approved already)
Action Endorsement Circle Endorsement or Approval Circle Endorsement or Approval Approval
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Date
Comments
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 12 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 1 Location Map (andor Environmental Control Map)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 13 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 2 Traffic Management Plan andor Traffic Control Plan
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 3 Supporting Evidence for Noise amp Vibration Impacts (eg Construction Noise amp Vibration Impact Statement noise assessment etc)
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 15 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 4 Community Notification
(if applicable and already drafted)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 62 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Any site contamination will be effectively managed to limit the potential risk to human health and the environment Spoil will be managed to avoid contamination of land or water Prioritise reuse of contaminated spoil into the project rather than offsite reuse or disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Planning and assessment
Planning
The Golders Douglas Partners contamination assessment report (June 2020) considered investigation results and data from previous relevant Sydney Metro West (SMW) investigations in the general area The physical characteristics of the soil on site as determined by the above report is described as ldquofill material described as containing evidence of anthropogenic materials including ash gravels terracotta tile fragments bricks and glass In addition to this sandstone bedrock was regularly encounteredsuspected to be present (eg drilling method refusal) during the pavement investigation This evidence implies that there is a wide variety of soil types and materials across the Site associated with natural and historical anthropogenic related activities The findings included elevated concentrations of heavy metals (copper nickel zinc) encountered at one location on the Site and several within close proximity to the Site However the exceedances were considered to pose a low risk to ecological receptors given that the majority of the Site is covered in asphalt hardstand with very low potential for exposure to subsurface soils Elevated concentrations of BaP were encountered in several boreholes within close proximity to the Site Once again the risks to ecological receptors from these were considered low due to the presence of asphalt hardstand at the Site Asbestos was identified at one borehole SMW_BH415 at a depth of 05 m The laboratory reported that chrysotile was detected below the reporting limit of 01 gkg The report considered due to the location access nature of the ACM (bonded) that there is a low risk of exposure to potential receptors Should the soil not be able to be reused on site further sampling assessment and waste classification must occur for any soil that is to be disposed offsite in accordance with the Sydney Metro Waste Classification Procedure (Appendix 1A)
Project Manager HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 63 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Unexpected finds of contamination onsite
In the event that contamination is identified on site Appendix 8A will be followed for soil contamination excluding Asbestos material For unexpected Asbestos Finds Appendix 8B will be followed
Supervisors All workers
Assessment
If any potential contamination is discovered during construction the soil will be excavated and transported to the stockpile area for assessment which may include sampling by a suitably qualified environmental consultant
The assessment must consider whether the material is suitable to return to site for reuse with consideration to the final land use and pathways and receptors for the contaminants
Laboratory testing associated with the assessment will be prioritised to 24 hour turnaround to mitigate any delay where required
The assessment detailing the type extent and management options for the contaminated soil must be provided to Sydney Metro before proceeding to either reuse or dispose of material
For unexpected Asbestos finds the controls listed in the section below must be followed before any excavation and transport to stockpile or offsite
Project Manager Supervisor Environmental scientist
Asbestos management measures
Access Restrictions
Signs and barriers will be erected to warn of the danger and to prevent unauthorised people entering areas where asbestos contaminated fill material is being excavated handled
The location and extent of any access control areas will be agreed in discussion between the Project Manager Project Engineer HSE Advisor and the Environmental Coordinator and will be established in accordance with NOHSC2002 (2005) Code of Practice for the Safe Removal of Asbestos (2nd Ed) guidelines
Potential entry points to the asbestos work area should be signposted or labelled in accordance with AS 1319 (1994) Safety Signs for the Occupational Environment and NOHSC 2002 (2005b)
Earthworks Engineers Licenced removal contractor Supervisors
Asbestos Removal
For unexpected Asbestos finds the Certified Occupational Hygienist will conduct a risk assessment to demine Air monitoring requirements and any other PPE and management controls prior to removal (see air monitoring section)
All removal procedures for asbestos should be undertaken under the supervision of an appropriately licensed contractor which is either ASA or ASB depending on the material being removed The removal of material shall be monitored by a relevantly trained supervisor in accordance with the Code of Practice for the Safe Removal of Asbestos [NOHSC 2002 (2011)]
You must be licensed to remove asbestos except if removing 10 square metres or less of non-friable asbestos
Engineers Certified Occupational Hygienist Licenced removal contractor
Workcover notification Permit to Work
A permit to work authority will need to be issued to and signed by the contractor Workers engaged in the removal of asbestos on site will not be issued with a permit to work unless
Engineers Licenced removal contractor
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 64 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
they are employed by a company holding a removal licence issued by WorkCover NSW appropriate for the type of asbestos materials concerned
Workcover must be notified at least five days prior to commencement of asbestos removal work
Safe Work Method Statement and Asbestos Removal Plan
All notification and permit applications for removal of asbestos in soils must be accompanied by a site risk assessment (Asbestos Removal Plan) carried out by a competent or licensed person who determines If the asbestos is bonded or friable The extent of contamination A safe work procedure for the remediation of the site
Engineers Licenced removal contractor
Dust Control
In order to remove the asbestos safely we shall be using the ldquowet methodrdquo to carry out these works The wet method includes continuously keeping the soil with asbestos fragments watered so as to eliminate the asbestos dustfibres becoming airborne An exclusion zone of 10m (or whatrsquos appropriate ndash depending on limitations) will be isolated from the rest of the site using fencing or bunting Any personnel that do not have the correct PPE or relevant training will not be allowed in this area
Supervisors Earthworks Engineers
Clearance
Following the excavation and removal of asbestos contaminated material a licenced asbestos assessor will conduct inspections and sampling (where required) in the excavation to confirm that no asbestos remains A clearance report will be issued and works can recommence in the area
Licenced Asbestos Assessor
All potential contaminated finds
Training
A toolbox must occur for all worker for unexpected contamination finds procedure They will also be informed of the Site specific controls required for management of contamination in soil Site access restrictions Correct use of PPE Decontamination procedures Use of monitoring equipment Waste handling procedures Dust control measures and performance measures
all workers
Stockpile Contingency Measures
The following contingency measures will be put in place should stockpiling of potential contaminated soils be required All potential contaminated stockpiles will be separated by lot numbers and sign posted to
avoid any cross contamination Any temporary stockpiles of asbestos contaminated soil will be maintained under moist
conditions and remain covered at all times Sediment controls will be installed downslope of all contaminated soil stockpiles In order to confirm that all contaminated soil has been removed an Environmental
Consultant (ADE) will conduct a visual inspection or sampling of the material below the
Supervisors Earthworks Engineers
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 65 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
stockpile and provide a clearance certificate or the like as legislated The Environmental Consultant will advise of the validation criteria dependant on the contamination of the soil
Material tracking for contaminated finds assessed as suitable for onsite reuse
Where suspected contaminated material is identified the material will be tracked from the area in which the material was identified to its location in stockpile (lot number)
For all material assessed as suitable for reuse onsite the material will be tracked from its stockpile location to final destination for reuse onsite Survey will determine the m3 and the location of the final destination
All materials movements associated with unexpected contamination finds will be recorded on the materials tracking register
Supervisors Earthworks Engineers
Waste classification for materials assessed unsuitable for onsite reuse
Waste classifications are required for any excavated soil or fill material which is to be disposed off-site Soil or fill material to be taken off-site for disposal shall be assessed in accordance with the waste classification guidelines (NSW EPA 2014) Materials excavated from the site should be tracked from lsquocradle to graversquo in order to provide detailed and accurate information about the location and quantity of all materials from the time of their excavation until their disposal For any truck or bin leaving the site the following information would be recorded origin of material material type waste classification report approximate volume truck andor bin registration number Receiving licenced facility For all soils known or having the potential to contain asbestos the following applies The POEO Act defines lsquoasbestos wastersquo as any waste that contains asbestos including
fragments or fibres It is understood that as a result the NSW EPA considers asbestos contaminated soil to be an asbestos waste In addition the Protection of the Environment Operations (Waste) Regulation 2014 provides certain requirements for the transportation of asbestos It is understood that the NSW EPA requires any management of soil containing asbestos waste on or off the site to be at least equal to controls set out by the Regulation
All asbestos contaminated soil or fill leaving site will be transported in a leak proof covered vehicle and disposed of at a licensed facility in accordance with waste classification guidelines (NSW EPA 2014)
Earthworks Engineers Licenced removal contractor ESR
Environmental Monitoring amp records
Air Monitoring
If asbestos removal work that requires a Class A licence that means it is friable then you must get the licensed asbestos assessor occupational Hygienist to undertake air monitoring of the asbestos removal area Monitoring for airborne asbestos in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres
Earthworks Engineers Licenced removal contractor Hygienist
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
[NOHSC 3003(2005)] the analysis should be carried out by a NATA accredited laboratory during the removal operations Refer to Clause 50 and 51 for the WorkCover 2011 Safety Regulation for requirements
For other contaminated soil the occupational hygienist may determine that the risks associated with their disturbance and handling requires air monitoring
Record Keeping
The records associated with management of contaminated land that should be kept include Material tracking register including lots volume and type Asbestos Removal Plan (ARP) Asbestos Register Airborne Monitoring Reports Calibration certificates for air monitors Clearance Inspection Reports or Certificates Waste classification reports Laboratory sampling results Landfill disposal dockets
Earthworks Engineers ESR HampS Manager
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Appendix 8A ndash Unexpected Contamination finds procedure
1 Introduction
The following unexpected contaminated finds procedure will be adopted in the event that potential contamination
is discovered during construction Implementation of this procedure will ensure that contamination is managed in
such a way as to avoid harm to the environment workers community and comply with relevant legislation
2 Identification of Contamination
An unexpected find of contamination is likely to comprise of any soil characteristic which is not a typical soil
material identified in previous contamination assessment reports The Golders Douglas Partners contamination
assessment report (June 2020) section 102 makes note of indicators of contamination as
Significant staining
Odours from Soils
Oily sheen on water leaving soils
Anthropogenic waste materials other than those identified in the report (ie Ash Gravels Terracotta Tile
Bricks and Glass)
Where the soil characteristics are consistent with the reports and the above indicators are not present then no
further assessment is required for onsite reuse
Examples of these indicators are shown below
Photo 1 - Significant Staining or odorous soils
Discoloured soil (soil with non-natural colouring) Pungent smelling soils - petroleum compost
putrefied sulphurous septic sweet aromatic odours
Photo 2 ndash Oily Sheen on water
Rainbow sheen on water surfaces in soil
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Photo 3 ndash Buried wastes
Buried oil drums chemical container
Photo 3 ndash Buried wastes
Buried demolition wastes (eg concrete tiles bricks asphalt timber metal
3 Potential risk areas of unexpected finds
The higher risk activities for encountering unexpected finds during construction activities are considered to be
excavation works that extend below road pavement layers and into general fill
Higher risk areas for encountering unexpected finds construction are considered to be
Areas of excavation that extend through general fill layers and into natural soils eg Stormwater trench
locations
Locations of excavation near previous Boreholes with identified contamination (see map below)
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4 Unexpected finds flow chart
If potentially contaminated soils are encountered the following steps must be followed
During excavationif visual indications of contamination are present such as significant stained soils
odorous soils sheen tarry or ashy material or unexpected anthropogenic material (other than what is
expected to be encountered on site) then
STOP EXCAVATION in the immediate affected area
Notify the Supervisor Environmental Site Rep and Client
Environmental consultant to conduct assessment on material to determine suitability for reuse onsite This
step may require sampling and lab analysis ndash undertake with quick 24hr turnaround
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No Yes
Sample test and classify in
accordance with Appendix
1A ndash Sydney Metro Waste
Classification procedure
Contact environmental consultant and hygienist and provide details of the find Depending on the nature and type
of the find they may be required to attend site before any further excavation disturbance
Excavate the material to the extent of the potential contamination in 200mm thick layers and in 500mm
horizontal increments (Do not exceed design excavation extents) and move to stockpile area (Where it will be
allocated a lot number and signposted to avoid any cross contamination) For Asbestos follow specific
requirements in the unexpected Asbestos Finds Procedure Cover the stockpile and install controls around the
stockpile
Offsite disposal at licenced
landfill facility Maintain all
waste tracking and disposal
records
No
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5 Materials Tracking
A Material tracking Register will be used to ensure information is collected for unexpected finds materials
identification and traceability This register records all unexpected finds materials The material is carefully
inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location and type of soil stored onsite
at the stockpile area The material class and stockpile number on the map will correspond with the information in
the register
6 Stockpile Management
The following contingency measures will be put in place should stockpiling of suspected contaminated soils be
required
All suspected contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Sediment controls will be installed downslope of all suspected contaminated soil stockpiles
7 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential contamination onsite as detailed in previous contamination assessment reports and this unexpected finds
procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works
Prior to commencement of each shift the Supervisor will inform all site personnel of any works involving
contaminated materials on site
8 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 8B ndash Unexpected Asbestos finds procedure
1 Introduction
The following Asbestos Management procedure will be adopted in the event that potential asbestos containing
material (ACM) or actual asbestos is uncovered during construction Implementation of this procedure will ensure
that asbestos is managed in such a way as to avoid harm to site personnel visitors and the community
2 Areas of known asbestos contamination
No asbestos was identified with the footprint of the proposed road construction works However there was one
Borehole (BH 415) from previous contamination assessments adjacent to the boundary that identified asbestos at
05m bgs The laboratory result was chrysotile detected below the reporting limit of 01 gkg (see location on map
below)
3 Identification of Asbestos
Asbestos has been used in the manufacturing of various products and these products can be found in either friable
or non-friable form All products are also known as asbestos-containing material Friable asbestos products are
generally quite loose and when dry can be crumbled into fine material or dust with light pressure such as
crushing with your hand
Non-friable asbestos products are made from a bonding compound (such as cement) mixed with a small proportion
(usually less than 15) of asbestos Non-friable asbestos products are solid rigid and non-friable and cannot be
crumbled pulverised or reduced to powder by hand pressure The asbestos fibres are tightly bound in the product
and are not normally released into the air When theyre in good condition non-friable asbestos products do not
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normally release any asbestos fibres into the air They are considered a very low risk for people who are in contact
with them as long as appropriate safety precautions are used when they are disturbed Non-friable asbestos
products that have been damaged or badly weathered may also become friable for example crushed asbestos
cement sheeting Examples of non-friable and friable asbestos are shown below
Photo 1 ndash example of non-friable asbestos in soil This is Asbestos cement sheeting that although broken it is solid rigid and cannot be crumbled or pulverised by hand pressure
Photo 2 ndash example of friable asbestos ndash this was a section of Asbestos cement sheeting that is weathered and crumbles under hand pressure
Photo 3 ndash example of non - friable asbestos ndash Asbestos cement water pipe in good condition
Photo 4 ndash example of friable asbestos ndash water pipe wrapped with friable woven ACM textile
4 Unexpected Asbestos ACM finds flow chart
In the event that a person on site identifies or disturbs asbestos ACM the unexpected asbestos management
procedure during Construction is summarised below
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Discovery of suspected asbestos containing materials
STOP EXCAVATION in the immediate affected area Demarcate and isolate area from workers
Notify the Supervisor
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next
step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No
Sample test and classify
in accordance with
Appendix 1A ndash Sydney
Metro Waste Classification
procedure
Yes
Friable Non Friable
Proceed with Licenced
Asbestos removal work in
accordance with section 6 -
11 Remove to stockpile for
reuse assessment by
Environmental Consultant
No
Greater than
10m2 of non-
friable asbestos
contamination
Less than 10m2 of
non-friable
asbestos
contamination
Proceed with non-
licenced asbestos
removal and
disposal in
accordance with
section 5
Trained and competent person to identify the asbestos
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5 Non Licence Asbestos removal work
Where small fragments of ACM or suspected ACM are found and provided that
the total number of fragments is lt 20 or
the total surface area of the fragmentpiece is lt 1 m2 or
the fragments are spread over an area of lt 10 m2 and
the fragments are non-friable
If the unexpected find meets the criteria above a trained and competent person will collect any fragments and
place it in a 200 mm polythene bag for later disposal at an appropriate waste facility A detailed visual inspection
of the area will be carried out by the Environmental consultant which will involve wet raking of the areas to a
depth of 10 cm for any further fragments If no further fragments are identified works can continue
If during the visual inspection the Environmental consultant determines that the criteria described above are
exceeded or if suspected asbestos ACM continues to be identified during excavation works andor if it is thought
that any uncovered material might be considered asbestos containing and friable works will cease and the
Environmental consultant will assess the situation and determine an appropriate course of action
6 Licenced Asbestos removal work
A licensed asbestos removalist will be required for removal works where there is friable asbestos or the
contaminated area is greater than 10 m2 There are two types of asbestos removal licences Class A and Class B
The type of licence required depends on the type and quantity of asbestos or ACM to be removed as outlined
below
Licence type What asbestos can be removed
Class A Can remove any amount or quantity of asbestos or ACM including any amount of friable asbestos or ACM any amount of asbestos-contaminated dust or debris (ACD) Any amount of non-friable asbestos or ACM
Class B Can remove
any amount of non-friable asbestos or ACM Note A Class B licence is required for removal of more than 10 m2
of non-friable asbestos or ACM but the licence holder can also remove up to 10 m2 of non-friable asbestos or ACM
ACD associated with the removal of non-friable asbestos or ACM Note A Class B licence is required for removal of ACD associated
with the removal of more than 10 msup2 of non-friable asbestos or ACM but the licence holder can also remove ACD associated with removal of up to 10msup2 of non-friable asbestos or ACM
No licence required Can remove
up to 10 m2 of non-friable asbestos or ACM ACD that is associated with the removal of less than 10 m2 of non-friable
asbestos or ACM Not associated with the removal of friable or non-friable asbestos
and is only a minor contamination
The licensed asbestos removalist will prepare an Asbestos Removal Control Plan prior to the removal of any
asbestos ACM The Asbestos Removal Control Plan documents the specific control measures to be implemented to
ensure site personnel and others are not at risk when asbestos removal work is being conducted It includes how
the asbestos removal will be carried out including temporary storage the method tools equipment and PPE to be
used and the asbestos ACM to be removed including the location type and condition of the asbestos ACM
The Client will be informed prior to excavation or removal of asbestos or ACM If the removal activity is to occur in
the vicinity of any occupied residence or business the project Community Advisor will notify the affected
residents or business owners
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7 Signage and demarcation
Georgiou will install warning signs and labels to clearly identify asbestos affected areas and where asbestos related
work is being carried out Flagging will be installed to delineate the asbestos related areas and restrict
unauthorised persons from entering the asbestos removal work Stockpiles will be covered and labelled Signage
and flagging will stay in place until all licensed asbestos removal work is complete and a clearance certificate is
provided
8 Notification
Prior to the commencement of licensed asbestos removal works notification to SafeWork NSW is required
SafeWork NSW requires a minimum of 5 daysrsquo notice prior to the removal of asbestos and the notification will be
made by the licensed asbestos removalist
9 Air Monitoring
All air monitoring requirements will be determined and conducted by a licensed asbestos assessor (LAA) The
location and layout of the air monitors will be detailed within the Asbestos Removal Control Plan
Air monitoring requirements will vary depending on the type of asbestos being removed the location and position
of the asbestos The following rules should be applied when determine if air monitoring is required (extract from
Safe Work Australia ndash Code of Practice on How to Safely Remove Asbestos (2016)
For friable asbestos removal ndash Air monitoring is mandatory for all friable asbestos removal This includes prior
to dismantling an enclosure and for the purposes of the clearance inspection
For more than 10 msup2 of non-friable asbestos removal ndash Air monitoring is not required but may be considered to
be carried out by a licensed asbestos assessor or competent person to ensure compliance with the duty to
eliminate or minimise exposure to airborne asbestos and to ensure the exposure standard is not exceeded
Public Location ndash Air monitoring should be considered where the asbestos removal work is being undertaken in
or next to a public location
Exposure air monitoring ndash Air monitoring should be carried out at other times to determine a workerrsquos exposure
to airborne asbestos if based on reasonable grounds there is uncertainty as to whether the exposure standard
may be exceeded and a risk assessment by a competent person indicates it is necessary Since most uses of
asbestos are prohibited exposure monitoring should not be required frequently
The results of air monitoring will be made available as soon as possible to all workers on site The asbestos
supervisor will be notified immediately if the fibre count exceeds the recommended level in the Exposure
Standards for Asbestos as set out in the National Code of Practice How to safely remove asbestos
10 Clearance
Following removal of asbestos ACM the licensed asbestos removalist will arrange for a clearance inspection of the
area to facilitate the issue of a clearance certificate and allow construction to recommence in the affected area
The clearance inspection is conducted by
an independent licensed asbestos assessor for work that was carried out by a Class A licensed asbestos
removalist
an independent competent person for asbestos work that is not required to be carried out by a Class A licensed
asbestos removalist
To be independent the licensed asbestos assessor must not be involved in the removal of asbestos for that specific
job and is not involved in a business or undertaking involved in the removal of the asbestos for that specific job
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A clearance certificate will be issued if the independent licensed asbestos assessor or competent person is satisfied
that the asbestos removal area and the immediate area are free from visible asbestos contamination Entry to the
area will be permitted following confirmation of certification
11 Decontamination
Decontamination of site personnel PPE and tools used in asbestos removal work will minimise exposure and spread
of asbestos outside of the removal area
Personal decontamination will occur every time a worker leaves the asbestos removal work area and involves
removal of all visible asbestos dustresidue from PPE and Respiratory Protective Equipment using an asbestos
vacuum cleaner and or wet wiping with a damp cloth Disposable PPE is considered asbestos waste and will be
disposed of at an appropriate waste facility Non-disposable protective clothing will be laundered in a suitable
laundering facility that is equipped to launder asbestos-contaminated clothing
Workers must be aware of personal hygiene and ensure that they carefully wash when leaving an asbestos removal
area paying particular attention to hands fingernails face and head
Tools will be dismantled (where appropriate) cleaned under controlled conditions and decontaminated prior to
removal from the area or disposed of at a suitable off site location
12 Stockpile Management
The following contingency measures will be put in place for any temporary stockpiling of asbestos contaminated
soils
All asbestos contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Any temporary stockpiles of asbestos contaminated soil will be maintained under moist conditions and remain
covered at all times
Sediment controls will be installed downslope of all contaminated soil stockpiles
In order to confirm that all contaminated soil has been removed validation sampling beneath stockpiles will
occur by an Environmental Consultant
13 Asbestos contaminated soil for reuse onsite
Stockpiled asbestos containing soils will be assessed for beneficial re-use with the Site (NEPC 2013) Any soils
identified to contain asbestos with concentrations of bonded ACM less than the NEPC (2013) Health Screening Level
(HSL)-D applicable for the future commercial industrial land use could be reused onsite providing the following
Placement in a designated location preferably beneath a road alignment or other suitably capped area (min
300 mm lsquocleanrsquo (ie ENMVENM soils) to eliminate any potential airborne exposure pathway
Occupational hygienist and asbestos removalists on-site supervising relocation and placement
Maintenance of an Site Asbestos Register to record the extent nature of the ACM materials retained or
identified on-site
Any other requirements by Sydney Metro such as adherence to the CEMP etc and or land conditions
A Long-term Environmental Management Plan to manage the presence of asbestos impacted materials remaining
on-site would be required if the proposed soils to be re-used are exceeding the HSL-D limits for non-friable or
friable asbestos
If stockpiled soils are identified to contain any detectable concentrations of Friable asbestos material is
recommended to be disposed off-site given its friable nature
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14 Waste disposal
Where the ACM is assessed as non-suitable for onsite reuse the licensed asbestos removalist will classify and dispose
of the ACM at a licensed asbestos waste disposal site in accordance with NSW EPA guidelines (including Waste
Classification Guidelines (EPA 2014)) and relevant industry codes of practice
Disposal of ACM will be to an approved asbestos waste facility listed on the NSW EPA website The transportation of
asbestos waste by trucks must comply with the following requirements
Transporter must have the appropriate EPA license to transport asbestos waste
Asbestos contaminated soils are wetted down
Any part of any vehicle in which a person transports asbestos waste is covered and leak proof during
transportation
Georgiou will notify the Client prior to removal of ACM from site and will provide details of the proposed method
and location of disposal Georgiou will maintain records of all asbestos ACM disposed off site the location of the
facility at which it was disposed and any receiptcertificate issued by the facilitydisposal authority
15 Materials Tracking
A Material tracking Register will be used to ensure information is collected for the movement of all asbestos
contaminated soils The material is carefully inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
and testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location of asbestos contaminated soil
stored onsite at the stockpile area The stockpile number on the map will correspond with the information in the
register
16 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential risks associated with asbestos management locations of asbestos as detailed in previous contamination
assessment reports and this unexpected finds procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works and include the unexpected asbestos finds procedure Prior to commencement of each shift the Supervisor
will inform all site personnel of any works involving contaminated materials on site
17 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure
Unclassified
Unclassified
Environmental Incident and Non-
compliance Reporting Procedure SM-17-00000096
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Manager Environment
System Owner Executive Director Safety Sustainability amp Environment
Status FINAL
Version 51
Date of issue 18 February 2019
Review date 11 February 2020
copy Sydney Metro 2019
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table of contents 1 Purpose and scope 4
2 Introduction 4
3 Definitions 4
4 Accountabilities 5
5 Environmental Events 5
51 Worked Example ndash Classifying Environmental Events 7
511 Soil and Water Issue 7
512 Soil and Water Non-compliance 7
513 Soil and Water Incident 7
52 Notifiable Events 8
53 Event Types 8
6 Environmental Incident Classification and Management 10
61 Incident Classification 11
611 Class 3 Incidents 11
612 Class 2 Incidents 11
613 Class 1 Incidents 12
62 Incident Notification 12
621 Principalrsquos Representative (PR) 12
622 Environmental Lead (EL) 13
63 Incident Notification Reports 14
64 Incident Investigations 14
65 Environmental Incidents with Health and Safety Impacts 14
66 Reporting Pollution Incidents to Relevant Authorities 15
661 Maritime Related Incident Notification and Reporting 16
67 Environmental Compliance Register 16
7 Environmental Non-compliance 17
71 Non-compliance Rate 17
8 Corrective and Preventative Actions 18
81 Action Status 18
9 Related Documents and References 19
10 Superseded Documents 19
11 Document History 19
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 19
Environmental Incident and Non-compliance Reporting Procedure
Figures Figure 1 Environmental Event Classification Process 6 Figure 2 Environment Incident notification process for Class 1 and 2 Incidents 13
Tables Table 1 Examples of Notifiable Events 8 Table 2 Environmental Event Types and their descriptions 9 Table 3 Examples of Environmental Incidents 10 Table 4 Classification System for Environmental Incidents 11 Table 5 Contact details for Relevant Authorities 15
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 19
Environmental Incident and Non-compliance Reporting Procedure
1 Purpose and scope
This procedure documents the process to be used when classifying and reporting Environmental Events
This procedure applies to Sydney Metro and any contractor Sydney Metro engages to carry out works Principal Contractors must ensure their processes for managing Environmental Events is consistent with this document The requirement for consistency is documented in the Construction Environmental Management Framework (Section 33(f)) and shall be allocated as a contractual requirement to each delivery partner
2 Introduction
Sydney Metro is committed to minimising risks to the environment the rapid identification and rectification of breaches to Environmental Requirements and efficient and effective responses to Environmental Incidents that grows our ability to minimise harm and prevent future re-occurrences
This procedure defines an approach to classifying Environmental Issues Incidents and Non-compliances and establishes the immediate interim and long term actions that are taken in response to Environmental Events
3 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition with the following exceptions
Term Definition
Environment
means components of the earth including
a) land air and water and
b) any layer of the atmosphere and
c) any organic or inorganic matter and any living organism and
d) human-made or modified structures and areas and includes interacting natural ecosystems that include components referred to in (a)-(c)
Environmental Event
An occurrence that identifies actual or potential environmental impacts or non-compliances Events cans include conversations inspections incidents or failures of process
Environmental Harm Includes any direct or indirect alteration of the environment that has the effect of degrading the environment and without limiting the generality of the above includes any act or omission that results in pollution
Environmental Incident
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Environmental Issue An occurrence or set of circumstances where Environmental Harm or Non-compliance could occur if not rectified
Environmental Non-compliance
A breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 19
Environmental Incident and Non-compliance Reporting Procedure
Term Definition
Material Harm to the Environment
harm to the environment is material if
a) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
b) it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding $10000 (or such other amount as is prescribed by the regulations) and
c) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent mitigate or make good harm to the environment
It does not matter that harm to the environment is caused only in the premises where the pollution incident occurs
Terms and jargon specific to this procedure are defined within the Sydney Metro Glossary
4 Accountabilities
The Executive Director Safety Sustainability amp Environment is accountable for this Procedure Accountability includes authorising the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
The Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document if specified in the relevant contracts
5 Environmental Events
Environmental surveillance data is relied upon to inform Sydney Metro of performance trends to provide assurance that legislative requirements are being met and indicate where surveillance activities should be directed In order to rely upon environmental data for this purpose there needs to be a high degree of consistency in the manner by which it is collected and interpreted Due to the need for consistency any incidentNon-compliance procedure produced by a delivery partner to Sydney Metro is required to be consistent with the requirements of this document
The concept of Environmental Events forms a common starting point for understanding what types of occurrences should be managed and reported as Incidents and what should be reported as Non-compliances or Issues When an Environmental Event occurs a series of questions can be asked to consistently determine what type of event it is Commonly Environmental Events lead to three different processes
1 Reporting of an Environmental Incident
2 Reporting of an Environmental Non-compliance or
3 Reporting of an Environmental Issue
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 19
Environmental Incident and Non-compliance Reporting Procedure
Incidents and Non-compliances are recorded using the Environmental Incident and Non-compliance Report Form (SM ES-FT-403) and Environmental Issues are recorded through environmental inspection reports using the Environmental Inspection Information amp Summary Form (SM ES-FT-406) These paper based records are subsequently entered into the Sydney Metro Compliance Register (Section 67) which is used to disseminate the data and facilities reporting internally and externally Note where a Principal Contractor has submitted alternative processes and these have been approved by Sydney Metro they may also be used
The figure below shows the process by which Environmental Events are classified (Figure 1)
Figure 1 Environmental Event Classification Process
Where Environmental Harm has been caused the event will always be classified as an Environmental Incident regardless of whether one or more Environmental Requirements have been breached Only when an event occurs without harm being caused to the environment will it be classified as a Non-compliance or Issue It should be noted that the Incident management process still captures any breaches of Environmental Requirements and these incidents contribute towards the calculation of the NC Rate (Section 71)
This flowchart above is intended to be a guide and there may be situations where it is unclear exactly how an Environmental Event should be classified In these situations a judgement call should be made in consultation with your Manager
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 19
Environmental Incident and Non-compliance Reporting Procedure
51 Worked Example ndash Classifying Environmental Events
This Section provides a fictitious example of Environmental Events which fall into each of the three different categories The situations outlined below are provided to explain how event classifications are made The background for these worked examples is as follows
Sydney Metro is carrying out works in a newly established site and substantial earthworks are occurring to construct piers for an elevated viaduct A nearby creek contains a variety of important fish species and the local community are known to use this creek for recreational fishing The Environmental Impact Statement identified the creek as being at risk of increased sedimentation from dirty water run-off and the Conditions of Approval include a requirement to have a Progressive Erosion and Sediment Control Plan in place This plan has been produced and indicates that sediment fences must be in place at specific locations to capture dirty water run-off Regular daily inspections of the sediment controls are carried out by the contractorrsquos Environment Manager and an Independent Environmental Representative has commenced a monthly inspection on this site at 7 am on Thursday morning
511 Soil and Water Issue
The Environmental Representative notices a sediment fence has been knocked over in one of the areas indicated as requiring fencing on the ERSED plan It appears to have occurred recently and there is no record of rainfall in the last few days During the course of the inspection all other ERSED controls appeared to be in good condition and erected in accordance with the requirements of the Blue Book In this example no harm has yet been caused and no environmental requirement has been breached so the event is classified as an Environmental Issue which is raised on the inspection report with an action to reinstall the fence
512 Soil and Water Non-compliance
Alternatively the Environmental Representative might have noticed many sediment fences had been knocked down and in some areas an absence of sediment fences where the plan indicates they are required Despite there being no rain in recent days the Environmental Representative concludes that the requirements of the plan are not being followed and have been breached The event is raised as non-compliance and actions are set in place to re-enforce the requirements of the ERSED plan for that sites workforce as well as the immediate reinstatement of controls
513 Soil and Water Incident
Finally in a third scenario the Environmental Representative notices many sediment fences are down and some are absent where required by the plan However significant rainfall has occurred in recent days and the Environmental Representative determines that it is likely dirty water has escaped through the area into the nearby creek potentially causing harm to the fish population This event is classified as an Incident by the inspector and immediate notification is undertaken Similar controls are implemented as described above
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 19
Environmental Incident and Non-compliance Reporting Procedure
52 Notifiable Events
There are a number of Acts and regulations that include a specific requirement to notify a Regulatory Authority When an Environmental Event triggers one of these notification requirements we then also refer to that event as a Notifiable Event (Table 1)
The Principal Contractorrsquos Environment Manager must determine whether an event is notifiable and may rely upon advice from Sydney Metro if it is provided
Table 1 Examples of Notifiable Events
Event type Legislation Trigger for Notification
Pollution Incident
1
POEO Act 1997 Part 57 Where Material Harm has occurred contact the EPA Pollution Line as soon as practicable POEO (General)
Regulation 2009 Section 101
Land contamination
Contaminated Land Management Act 1997
Section 60(1)
As soon as practicable after becoming aware of contamination that exceeds the relevant investigation levels in the National Environment Protection Measure where a person has or will be exposed to the contamination
Discovery of an Aboriginal relic
National Parks amp Wildlife Act 1974
Section 89A
Director General of EPA in writing within a reasonable time after becoming aware Note this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in the relevant Infrastructure Approval
Discover Aboriginal Remains
Commonwealth Aboriginal amp Torres Strait Islanders Heritage Protection Act 1984
Section 20 Commonwealth Minister of the Environment in writing as soon as practicable after becoming aware
Discovery of a relic
Heritage Act 1977 Section 146
Heritage Council in writing within a reasonable time after becoming aware
Note -this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in Infrastructure Approvals
53 Event Types
Each Environmental Event is assigned a secondary classification of an Event Type for the purpose of data analysis and general environmental management They are grouped by areas of environmental management so that targeted auditing training or awareness initiatives can be initiated in response to emergent trends Each Event Type is explained in Table 2
1 Further information on reporting pollution incidents to EPA is provided in Section 66 Environmental
IncidentNon-compliance Report
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table 2 Environmental Event Types and their descriptions
Event Type
Applies To
Description Issue Incident
Non-compliance
Soil and Water bull bull bull
Covers the physical location chemical composition and ecology of soils and waterways Any event which changes these compositions is a Soil and Water event Within this event type all instances of contamination erosion and sedimentation of waterways is covered
Flora and Fauna bull bull bull Covers vegetation and vegetation communities as well as animals and animal habitat Any event where vegetation is felled or damaged animals are killed or injured or habitat is harmed or destroyed is covered
Waste and Spoil bull bull bull
Covers the management of Excavated Natural Material (ENM) and Virgin Excavated Natural Material (VENM) including on-site management and disposal and also the classification and management of Waste materials
Note that the transportation of spoil is covered under Traffic Transport and Access
Heritage bull bull bull Covers the management of known heritage artefacts or sites and the treatment of unexpected finds archaeological investigations and other impacts
Air Quality bull bull bull Covers the management of emissions of particulate matter odours and gasses used as air quality parameters from worksites
Noise and Vibration bull bull bull
Covers the management of airborne and ground borne noise and vibration and includes hold points on the commencement of any work where Out of Hours Works permits or Construction Noise Impact Statements are required
Community Stakeholder and Business
bull bull bull Covers the management of Community and Stakeholder requirements and includes complaint response procedure community management protocols and the maintenance of information on websites
Traffic Transport and Access bull bull bull
Covers the management of traffic inside and outside of sites including access points and parking requirements This event type also covers any requirements in relation to vehicles and vehicle maintenance or the transportation of waste and spoil
Spills and Leaks bull bull bull
Covers all instances where environmentally sensitive substances are held within a container which has the potential to leak or spill and covers pipes hoses fuel tanks storage tanks and plastic containers
Note Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Management Systems bull bull bull
Covers procedural or administrate processes that are common across all areas It specifically does not cover procedural or administrate processes which are unique to any of the other event types For example not completing a vegetation removal form prior to vegetation clearing is still a Flora and Fauna event
Note A good example of a Management Systems NC would be not reporting an Environmental Incident within required timeframes
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 19
Environmental Incident and Non-compliance Reporting Procedure
6 Environmental Incident Classification and Management
Sydney Metro has defined an Environmental Incident as
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Adverse environmental impact includes contamination harm to flora and fauna (either individual species or communities) damage to heritage items or adverse community impacts
Planning Approvals and Environment Protection Licences permit some environmental impacts and these are not intended to be captured as Environmental Incidents
Table 3 Examples of Environmental Incidents
Type Example Incident
Air Quality Odour that travels beyond the site boundary
Air Quality Dust exceeding reasonable levels without active management measures in place
Air Quality Operation or maintenance of plant in a manner that causes or has likely caused excessive air pollution
Soil and Water Discharge of water on or off site in a manner that causes or has likely caused water pollution without required approvals
Noise and Vibration Noise that travels beyond the site boundary as a result of poorly maintained plant or operation of plant in an inefficient manner
Noise and Vibration Failure to comply with the approved hours of work
Soil and Water
Where the chemical composition of soil or water has been detrimentally modified by a contaminant leading to potential or actual environmental harm For example rainfall causes a flow of water across a site that erodes soil and enters a waterway increasing the total suspended solids of that water body
Spills and Leaks
Where a substance has leaked from or spilt from a container that is designed to prevent that substance from escaping into the environment (including bunds fuels tanks chemical bottles and other containers)
Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Soil and Water Dispose of waste in a manner that harms or is likely to harm the environment
Flora and Fauna Harm or ldquopickrdquo a threatened species endangered population or endangered ecological community without required approvals
Flora and Fauna Damage to vegetation fauna or habitat including watercourses without required approvals
Heritage Damage disturbance destruction or works to heritage itemsrelics without required approvals
Heritage Damage disturbance or destruction of Aboriginal objects or places without required approvals
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 19
Environmental Incident and Non-compliance Reporting Procedure
61 Incident Classification
Environmental Incidents are classified into one of three Classes that are based upon the consequence descriptors for environmental risks in the Sydney Metro Risk Matrix (refer to Sydney Metro Risk Management Standard) Each of these classifications trigger a variety of management actions andor legislative requirements depending on the severity of the consequence described where Class 3 represents minor consequences and Class 1 represents major consequences
This matrix is further sub-divided into consequence ratings ranging from C6 (low impact) to C1 (high impact) An incident transitions between a Class 3 to a Class 2 incident once material harm has been caused and transitions into a Class 1 incident once it is determined that the Environmental Harm caused in large-scale and cannot be remediated (Table 4)
Table 4 Classification System for Environmental Incidents
Class 3 Class 2 Class 1
C6 C5 C4 C3 C2 C1
No appreciable changes to
environment andor highly
localised event
Change from normal conditions
within environmental
regulatory limits and environmental effects are within site boundaries
Short-term andor well-contained environmental effects Minor
remedial actions probably required
Impacts external ecosystem and considerable
remediation is required
Long-term environmental impairment in
neighbouring or valued
ecosystems
Extensive remediation
required
Irreversible large-scale
environmental impact with loss of
valued ecosystems
611 Class 3 Incidents
These Incidents are events which cause Environmental Harm but do not cause Material Harm to the environment Normally Class 3 Incidents are not Notifiable Events and therefore a simple notification protocol is adopted whereby Sydney Metro must be notified within 48 hours verbally and in writing
In some cases it will be unclear whether Material Harm has been caused in the early stages of Incident Management If this is the case then the process for Class 2 Incidents is followed (see Section Class 2 Incidents) until it is clear that Material Harm has not been caused
A formal Incident Investigation report is not required for Class 3 Incidents however it is expected that the person responsible for completing the Incident Notification Report makes appropriate enquiries to determine the likely causal factors involved and assigns effective corrective actions
612 Class 2 Incidents
These Incidents are events which cause Material Harm to the environment and they always trigger notification of Regulatory Authorities These Incidents represent events that are far more serious than Class 3 Incidents and therefore strict communication protocols are required to ensure that effective and informed decisions are made (Figure 2)
The Environmental Lead contract Environment Manager and the Independent Environmental Representative must be notified verbally as soon as possible after the observer becomes aware of a Class 2 Incident
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Class 2 Incidents must be investigated and the investigation must produce an investigation report containing corrective or preventative actions This investigation report must be provided to Sydney Metro within 7 days of the event unless another timeframe is agreed with the EL
Despite any arrangements for the submission of investigation reports an Incident Notification Report must be provided with all available information and submitted to Sydney Metro within 48 hours It is not expected that initial Incident Notification Reports for Incidents under investigation initially include actions as these will be informed by the findings of the investigation The report should be updated with actions resulting from the investigation when available
613 Class 1 Incidents
Class 1 Environmental Incidents are managed in the same manner as Class 2 Incidents expect where a determination is made by the Chief Executive (or delegate) that a Crisis Management Team should be activated In this situation the Sydney Metro Crisis Management Implementation Plan is followed
62 Incident Notification
When and Environmental Event occurs which causes Environmental Harm in all cases both verbal and written communication of the incident must be carried out immediately and within 48 hours respectively For Class 1 and 2 Incidents the notification process shown in Figure 2 must be followed Written communication of Environmental Incidents is via an Incident Notification Report (Section 63)
This process includes specific roles and responsibilities within Sydney Metro and our delivery Partners who are required to take notification actions in response to Incidents
This notification process has been developed to ensure that crucial information about Incidents is captured early and communicated to specific individuals who can ensure the Environmental Impacts are minimised and efficient and effective responses to the event are implemented
In particular the Principals Representative and the Environmental Lead for Sydney Metro play a crucial role in the communication of Incidents within Sydney Metro and these roles are explained in more detail below
621 Principalrsquos Representative (PR)
Each works package establishes a contractual interface for communication between the contracted party and Sydney Metro Generally this interface is between the Principal Contractors Project Director and an appointed representative of Sydney Metro called the Principals Representative
All formal written communications must pass between these two individuals electronically using TeamBinder The Principals Representative holds certain responsibilities in the Incident management Process outlined in Figure 2
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
622 Environmental Lead (EL)
Where this procedure is applied to a works package an Environmental Lead (EL) will be selected for the relevant works package The Environmental Lead must possess environmental experience and competency in managing Incidents and be a representative of Sydney Metro for those works This representative holds specific responsibilities outlined in Figure 2
Figure 2 Environment Incident notification process for Class 1 and 2 Incidents
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 19
Environmental Incident and Non-compliance Reporting Procedure
63 Incident Notification Reports
For all Incidents an Incident Notification Report must be completed and submitted to Sydney Metro within 48 hours These reports satisfy the requirement for written communication to Sydney Metro and are completed using the Environmental Incident and Non-compliance Notification Report (SM ES-FT-403) or a similar and consistent form approved by Sydney Metro
64 Incident Investigations
Environmental Incident Investigations must be carried out for all Class 1 and Class 2 Incidents Investigations may also be requested for any other Environmental Event at the discretion of Sydney Metro This discretion is likely to be exercised where incidents of a similar nature are occurring repetitively
When conducting an Environmental Incident investigation they must
Be led by a lead investigator who is suitably independent investigator capable of arriving at objective findings and is experienced in conducting environmental incident investigations
Consider the need for legal privilege during the investigation process in consultation with legal counsel
Be informed by all available information that is relevant to the investigation
Analyse the timeline of events which led up to and followed the occurrence of Environmental Harm including the immediate incident response
Be conducted in a manner that is consistent with recognised investigation techniques such as ICAMS
Gather and record evidence
Seek the input of key stakeholders and
Identify Preventative and Corrective actions and document these in the Incident Notification Report
65 Environmental Incidents with Health and Safety Impacts
It is possible that where an Event occurs that causes Environmental Harm harm is also caused to the health safety or wellbeing of people In these situations there will also be a Health and Safety Incident process undertaken which is separate to the process outlined in this document
While the definition of the Environment covers people under the POEO Act the management of impacts upon them are carried out using the Health and Safety Incident Management protocols This is because Health Safety and Wellbeing requirements are governed by a range of legislation other than the POEO Act and this procedure is not comprehensive in that regard Sydney Metro has well established processes to manage impacts on people without the need for the Environmental Incident Process to intervene
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Furthermore where Environmental Events cause harm to both the lsquoenvironmentrsquo and people it is possible that the root causes for the respective impacts are different It is also possible that differences in the severity of the impacts trigger inconsistent notification requirements and investigation levels It is prudent to identify appropriate and effective corrective actions that reduce the risk of impacts to both people and the environment therefore separate Incident Management Processes are undertaken in these situations
For more detail on the management of Health and Safety Incidents please refer to the Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
66 Reporting Pollution Incidents to Relevant Authorities
If an Incident or Non-compliance is a Notifiable Event then a report must be provided to the relevant Regulatory Authority within the timeframe(s) specified by the relevant legislation Pollution Incidents which are causing or threatening Material Harm to the environment must be reported to each of the following authorities immediately after project personnel become aware of the Incident as required by Section 148 of the POEO Act 1997 The contact numbers for these authorities are listed in Table 5
Table 5 Contact details for Relevant Authorities
Type Example incident
EPA Environment Line 131 555
Local Authority Local Council (specific to area)
Ministry of Health Public Health Unit (refer to httpwwwhealthnswgovauPagesdefaultaspx to confirm local area contact details)
SafeWork NSW 131 050 or contactsafeworknswgovau
Fire and Rescue NSW 000
Relevant information required to be given to EPA when making a notification is specified in Section 150 of the POEO Act 1997 as follows
Time date nature duration and location of the incident
Location of the place where pollution is occurring or is likely to occur
Nature the estimated quantity or volume and the concentration of any pollutants involved
Circumstances in which the Incident occurred (including the cause of the Incident if known)
Action taken or proposed to be taken to deal with the Incident and any resulting pollution or threatened pollution and
Other information prescribed by the regulations
All relevant information known at the time of making the notification must be reported If the information required by (c) (d) or (e) above is not known at the time of initial notification but becomes known afterwards it must be reported to each authority immediately after it
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
becomes known Verbal notification must be followed by notification in writing within seven days of the date on which the Incident occurred
Pollution Incidents are not required to be reported if the Incident has already come to the attention of the EPA or the Incident involves only the emission of an odour
Failure to report a pollution Incident as required by the POEO Act 1997 is an offence
Where any work or activity is regulated by an Environment Protection License (EPL) notification of a pollution Incident to the EPA should be made by the licensee Thus where the contractor holds the EPL for the project notification to EPA shall be made by the contractor
For any work or activity that is not regulated by an EPL notification of pollution Incidents to EPA shall be made by Sydney Metro unless the contractor is instructed otherwise by Sydney Metro This includes pollution Incidents that occur as a result of pre-construction activities which may be undertaken prior to an EPL being required for a project Pre- construction activities are determined by the Planning Approval and may include for example geotechnical investigations or surveys
Where the Environmental Representative determines there to have been a significant off-site impact on people or the biophysical environment the program Director Sustainability Environment and Planning will notify the Secretary of the Department of Environment and Planning within 48 hours in accordance with Project Infrastructure Approval Conditions This notification will be followed by a full written report within seven days of the date on which the incident occurred
661 Maritime Related Incident Notification and Reporting
Marine Incidents involving vessels and personnel on board vessels must be reported to the Australian Maritime Safety Authority in accordance with the guidance published on their website at
Australian Maritime Safety Authority Incident Reporting and
Reporting obligations of owners and masters of domestic commercial vessels
67 Environmental Compliance Register
The Environmental Compliance Register is used to manage the information associated with reporting of Environmental Events This register is maintained by the Manager Environment and may be used by a variety of individuals to input data For access to the register or information on its use contact the Manager Environment
This register analyses the data it contains and produces environmental compliance statistics that are used to meet a range of reporting and environmental management requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
7 Environmental Non-compliance
An Environmental Non-compliance is a breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans It is important to note that regardless of whether an event is classified as a Non-compliance or an Incident the process behind managing the event remains the same with the following exceptions
Non-compliances are not notifiable to Regulatory Authorities under the POEO Act
Non-compliances are reported to have occurred on the day the breach was raised as opposed to the date when the requirement was breached (this is to preserve historical reporting and analysis ndash see Section 71)
Non-compliances are not divided into severity classes (Section 52)
Non-compliances do not have the potential to trigger crisis or emergency management processes and
There is an informal notification process in the immediate timeframe following a Non-compliance being raised
When an Environmental Event occurs that causes Environmental Harm and also breaches one or more Environmental Requirements then an Incident Notification Report will be created which records what requirements were breached
If a Non-compliance is identified then it must be raised using the Environmental Incident and Non-compliance Report Form within 48 hours by the party responsible for the breach
71 Non-compliance Rate
A key environmental performance statistic used by Sydney Metro is the Non-compliance Rate This statistic provides a standardised way of comparing the performance of different projects or contractors The NC Rate is calculated using the following formula
= (119873119862119904 + 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119903119886119894119904119890119889 119894119899 119898119900119899119905ℎ) + (119874119901119890119899 119873119862119904 + 119874119901119890119899 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119891119903119900119898 119901119903119890119907119894119900119906119904 119898119900119899119905ℎ119904)
119879119900119905119886119897 119873119906119898119887119890119903 119900119891 119874119899119892119900119894119899119892 119877119890119902119906119894119903119890119898119890119899119905119904) 119883 100
Each month a count of the number of NCs raised and Incident raised where Environmental Requirements have also been breached is counted Added to this number is the number of these events which were raised in previous months that still held an Open status in the current reporting period Non-compliance and incident Events are considered Open if any of the associated Actions are Open The total is divided by the number of Environmental Requirements which are actively being complied with (Ongoing Requirements) and a multiplying factor of 100 is applied
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
8 Corrective and Preventative Actions
Whenever an Environmental Event is raised actions will be assigned to the event irrespective of whether it is an Issue Incident or Non-compliance These actions will generally be Corrective Actions which are implemented to eliminate the cause of the Incident Non-compliance or Issue and can be thought of as reactive measures in response to the Environmental Event
Preventative Actions may also be assigned to prevent the occurrence of an Incident Non-compliance or Issue and can be considered pro-active measures which may be recommended following a detailed investigation of the event
Actions must
Limit impacts as far as is reasonably practicable
eliminate risk where practicable
where is it not practicable to eliminate the risk follow the hierarchy of controls
address root causes and contributing factors and
be prioritised based on risk
The Executive Director Safety Sustainability amp Environment must ensure there are systems in place to
monitor corrective action status
escalate issues to the executive where progress on a corrective action is inadequate and
retain all corrective action responses for recording purposes
81 Action Status
Actions are allocated to a person who will take accountability for ensuring it is carried out within a timely manner and completed by the due date
Actions are either closed immediately if the Action has already been carried out and verified by Sydney Metro or are created with an open status The Action will remain in an open state until such a time as Sydney Metro verifies that the responsible person has completed the Action in a satisfactory manner Until all actions associated with an Incident Non-compliance or Issue are closed the original Environmental Event is considered to be open as well This is relevant when calculating the NC Rate as open Non-compliances and Incidents contribute toward the calculation of this statistic
Verification is determined by the Environmental Lead by sighting evidence of the Actions implementation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 19 of 19
Environmental Incident and Non-compliance Reporting Procedure
9 Related Documents and References
10 Superseded Documents
11 Document History
Related Documents and References
Environmental amp Sustainability Management Manual
Risk Management Standard
Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
Crisis Management Implementation Plan
Environmental Incident and Non-compliance Notification Report
Environmental Inspection Information amp Summary
Sydney Metro Glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
10 31 March 2015 New document
20 7 July 2016 IMS Review
30 7 April 2017 IMS Review
40 23 November 2018 IMS Review
50 11 February 2019 IMS Review
51 18 February 2019 Minor correction to formula
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 79 of 80
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CEMP Bays Road Relocation Works
Appendix 10 ndash Sydney Metro Environmental Inspection template
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2016 CEMP Appendix 10 - Sydney Metro Inspection template Page 1 of 1
Environmental Inspection Report Template
Contract
Contractor Date
Inspection Number Time
Location
Weather
Attendees
Site Activities
Item No
Key Issues Action Party
Priority
(L M H)
Inspection by
Name Title Signature
Date
Copy to
- All attendees
-
-
-
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Page 80 of 80
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CEMP Bays Road Relocation Works
Appendix 11 ndash Georgiou Environmental Policy
COMPANY POLICY
Rob Monaci Chief Executive Officer Georgiou Group September 2020
ENVIRONMENTAL
Georgiou is committed to minimising where reasonably practicable its impact on the natural environment and social surroundings for the benefit of current and future generations while enhancing Georgioursquos environmental performance
In order to achieve this commitment Georgiou will
set environmental objectives and targets applicable to the aspects and potential impacts of projects and facilities
establish positive relationships with community and stakeholders
comply with all applicable environmental laws regulations statutory obligations and client environmental requirements
identify significant environmental aspects and develop effective and appropriate mitigation measures to minimise environmental impacts
provide measures to protect heritage biodiversity land and waterways
manage potential community impacts related to air quality noise and vibration
practice responsible resource use and waste management including the promotion of efficient use reuse and recycling of resources
implement and maintain Georgioursquos management system and practices to meet its business needs ASNZS ISO 14001 client and other obligations and
hold employees and subcontractors accountable for proactively meeting their environmental responsibilities
Achieving these commitments is fundamental to demonstrate a positive impact on the environment and communities associated with Georgioursquos activities and developments All employees and persons who work with Georgiou have a personal responsibility for implementing this Policy
SAFE
TY |
PRO
FIT
| RE
LATI
ON
SHIP
S |
PEO
PLE
| IN
NO
VAT
ION
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Revision Date Revision Details Environmental Representative
Project Manager
A 81020 Draft for review Chloe Redman Brad Collins
B 21120 Sydney Metro 1st review Chloe Redman Brad Collins
C 101120 Sydney Metro 2nd review Chloe Redman Brad Collins
D 161120 Sydney Metro 3rd Review Chloe Redman Brad Collins
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
TABLE OF CONTENTS
GLOSSARY ABBREVIATIONS 6
1 INTRODUCTION AND PURPOSE 8
Amendments and Authorisation 8
Communication of this Plan 8
Supporting Management Plans 8
2 SCOPE OF WORKS 9
3 LOCATION 9
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW 10
Environmental Management System 10
Policy 11
Environmental Management Plan 11
5 LEGAL AND OTHER OBLIGATIONS 12
General 12
Contractual Environmental Requirements 15
REF Determination Conditions of Approval 17
Environmental Licences and Permits 19
Infringement Improvement and Prohibition Notices 20
Availability of Statutory and Other Information 20
Objectives amp Targets 20
6 STRUCTURE AND RESPONSIBILITIES 21
Organisational Structure 21
Roles and Responsibilities and Authority 21
Communication and Acceptance of Accountabilities and Responsibilities 23
Field Leadership Visits 23
7 COMMUNICATION AND CONSULTATION 24
Internal Communication and Consultation 24
711 Inductions 24
712 HSE Notice Boards 25
713 HSE Alerts Bulletins 25
714 Site Meetings 25
Community and Stakeholder Involvement 25
721 Complaints Management 26
722 Urban Design of temporary works 26
723 Business and Property Impacts 27
8 HAZARD IDENTIFICATION AND RISK CONTROL 27
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CEMP Bays Road Relocation Works
Hierarchy of Control 27
Site Environmental Risk Analysis 28
Review of Risks 28
831 Change Management 28
Operational Control 28
841 Environmental Hazard Reporting 28
842 Take 5 29
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS) 29
844 Permit to Work 29
845 Environmental Control Maps 29
9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT 30
10 CLOSURE AND COMMISSIONING 30
11 TRAINING COMPETENCY AND RESOURCING 30
1111 Toolbox talks 30
1112 Recording of Training and Assessment 31
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE 31
EmergencyIncident Planning and Control 31
13 HSE REPORTING AND INVESTIGATION 31
Notifications and Reporting 31
1311 Internal 31
1312 Notification of Incidents to Sydney Metro 31
1313 Statutory Notifications 31
Investigations 32
Review and Communication of Incidents 32
14 ENVIRONMENTAL REPORTING 32
1411 Monthly Reports 32
Site Meetings 32
Project Performance Review 33
15 AUDITING REVIEWS AND INSPECTIONS 33
Inspections 33
1511 Environmental Inspections 33
Audits and Reviews 33
Monitoring 34
Corrective Actions 34
16 DOCUMENT AND RECORD CONTROL 34
17 APPENDICES 35
Appendix 1 - Waste Management Sub Plan 36
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 1A ndash Sydney Metro Waste Classification Procedure 42
Appendix 2- Soil and Water Management Sub Plan 43
Appendix 3- Hydrocarbon and Chemical Management Sub Plan 46
Appendix 4 - Flora amp Fauna Management Sub Plan 50
Appendix 5 - Cultural Heritage Management Sub Plan 53
Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure 55
Appendix 5B ndash Sydney Metro Exhumation Management Procedure 56
Appendix 6 - Air Quality amp Dust Management Sub Plan 57
Appendix 7- Noise Vibration and Light spill Management Sub Plan 59
Appendix 7A ndash Sydney Metro Out of Hours Application form 61
Appendix 8 ndash Contaminated Land Management Sub Plan 62
Appendix 8A ndash Unexpected Contamination finds procedure 67
Appendix 8B ndash Unexpected Asbestos finds procedure 71
Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure 78
Appendix 10 ndash Sydney Metro Environmental Inspection template 79
Appendix 11 ndash Georgiou Environmental Policy 80
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
GLOSSARY ABBREVIATIONS
Term Expanded text
AFMP Ancillary Facilities Management Plan
BC Act Biodiversity Conservation Act 2016
CoA Condition of approval
Compliance audit Verification of how implementation is proceeding with respect to an CEMP (which incorporates the relevant approval conditions)
CPESC Certified practising erosion and sediment control professional
CRM Community Relations Manager
CPESC Certified practising erosion and sediment control professional
CSSI Critical State Significant Infrastructure
DEC Department of Environment and Conservation (NSW) (former)
DIPNR Department of Infrastructure Planning and Natural Resources (former)
DoEE Commonwealth Department of the Environment and Energy
DoI - Water NSW Department of Industry - Water
DPIE NSW Department of Planning Industry and Environment
Ecologically sustainable development (ESD)
Using conserving and enhancing the communityrsquos resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future can be increased (Council of Australian Governments 1992)
EIS Environmental Impact Statement
EMS Environmental Management System
Environmental aspect
Defined by ASNZS ISO 140012015 as an element of an organisationrsquos activities products or services that can interact with the environment
Environmental impact
Defined by ASNZS ISO 140012015 as any change to the environment whether adverse or beneficial wholly or partially resulting from an organisationrsquos environmental aspects
Environmental incident
An unexpected event that has or has the potential to cause harm to the environment and requires some action to minimise the impact or restore the environment
Environmental objective
Defined by ASNZS ISO 140012015 as an overall environmental goal consistent with the environmental policy that an organisation sets itself to achieve
Environmental policy
Statement by an organisation of its intention and principles for environmental performance
Environmental target
Defined by ASNZS ISO 140012015 as a detailed performance requirement applicable to the organisation or parts thereof that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives
EPA NSW Environment Protection Authority
EPampA Act NSW Environmental Planning and Assessment Act 1979
EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999
EPL NSW Environment Protection Licence under the Protection of the Environment Operations Act 1997
ERG Environmental Review Group
ESCP Erosion and Sediment Control Plan
EWMS Environmental Work Method Statement
Federal-CoA Condition of the Federal Department of the Environment and Energy Approval Decision
Hold point Is a verification point that prevents work from commencing prior to approval
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LGA Local Government Area
MNES Matters of National Environmental Significance
Non-compliance Failure to comply with the requirements of the Project approval or any applicable licence permit or legal requirements
NSW-CoA Condition of the NSW DPampE Infrastructure Approval
OEH NSW Office of Environment and Heritage
OOHW Out of hours work
PIRMP Pollution Incident Response Management Plan
POEO Act Protection of the Environment Operations Act 1997 (NSW)
RAP Registered Aboriginal Party
RBL Rating background level
REF Review of Environmental Factors
ROL Road occupancy licence
SAP Sensitive Area Plan
SEPP State Environmental Planning Policy
UXO Unexploded Ordnance
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1 INTRODUCTION AND PURPOSE
The purpose of this Construction Environmental Management Plan (CEMP) is to describe how environmental aspects
are to be managed so that the site and those engaged onsite will
Comply with Georgiou Policy Client legal and other obligations
Minimise the impacts on the environment
Achieve the Company client and site objectives and targets
implement mitigation measures identified and assessed through Review of Environmental Factors (REF) under
Part 5 of the EPampA Act
Comply with the requirements of the Construction Environmental Management Framework (CEMF) February
2020 version 41 Managing Contractor Contract (MCC) Works Brief licencing and other relevant documents
This Management Plan is written in accordance with Georgioursquos health safety and environment management
system that is 3rd party certified to ASNZS ISO 14001 It has been written in accordance with the Transport for
New South Wales (TfNSW) Sydney Metro Construction Environmental Management Framework (CEMF) and the
project specific Sydney Metro General Specification ndash Plans and Reporting
Amendments and Authorisation
This Management Plan will be approved by the Project Manager their Line Manager and a Representative from the
HSE Department This Management Plan and other related documents will be reviewed annually or as a result of
Changes to Company procedures or processes
Changes to key personnel or resources
Changes in legal and other obligations
Findings from an audit or inspection
Findings from a significant incident or near miss
Significant changes to site conditions andor work methods
Instructions from Sydney Metro
Reviews will be undertaken in consultation with key stakeholders to ensure all locationsfunctions are considered
A record of the date and comments relating to any revisions of this document will be included in the revision table
The only Georgiou authorisation required to amend this document after initial approval is the Project Managerrsquos
Communication of this Plan
The Project Manager is accountable for ensuring
Location and access to the management plans is communicated at induction Management Plans have been communicated to subcontractor personnel prior to commencement of works
onsite Any changes made to the management plan are communicated to affected persons on the site
Supporting Management Plans
The following management plans have been developed to support this management plan
Emergency Response and Preparedness Plan
Georgiou Crisis Management Plan (controlled by Georgioursquos Perth Head Office and available on Company Intranet)
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2 SCOPE OF WORKS
Sydney Metro is proposing to configure the internal port road network at Rozelle to facilitate the orderly urban
renewal of the Bays West area while maintaining access to the White Bay Cruise Terminal and other port operations
at Glebe Island and White Bay This includes long-term urban renewal initiatives for the Bays West area and works
for various future developments within the locality including critical works for the proposed Sydney Metro West
The proposal also provides the opportunity to improve road safety by reducing conflicting traffic movements in the
internal port road network
Georgioursquos scope of works is described as lsquoPhase 1rsquo works in the REF and it comprises of the following key
features
A reconfigured intersection at Port Access Road Solomons Way Sommerville Road including an interim
connection with the existing Port Access Road until it is relocated (as part of Phase 2)
Establishment of one-way traffic circulation along Solomons Way and Sommerville Road around the Glebe Island
Silos
Relocation of the Cement Australia Truck Parking Licenced Area to the north prior to the construction of the
reconfigured intersection due to the direct conflict with the reconfigured intersection
3 LOCATION
The proposal is located in an established industrial and port context at Rozelle within the Inner West Council local
government area
The lsquoproposal sitersquo refers to the area that would be directly impacted by the proposal as shown in Figure 1-1 The
proposal site is largely disused with the exception of the Port Access Road and port related lease areas including a
Cement Australia Truck Parking Licenced Area to service Cement Australiarsquos operations at the Glebe Island Silos
The proposal site is under the ownership of the Port Authority of NSW
To the north of the proposal site is the existing Port Access Road that supports access to the White Bay Cruise
Terminal and other port operations at White Bay To the east of the site is the existing Cement Australia and Sugar
Australia Glebe Island Silos and the Gypsum Resources Australia facility The south-eastern border of the site is
vegetated land adjoining Victoria Road Western Distributor The proposed location for the relocated Cement
Australia Truck Parking Licenced Area is currently a hardstand laydown area used by Port Authority of NSW
Beyond the proposal site the wider locality features a mix of land uses including retail commercial and urban
services along Robert Street to the north port and maritime uses to the east (Glebe Island and White Bay) and to
the south and City West Link Road and residential dwellings to the west in Rozelle
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Figure 3-1 Site location
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW
The following documents provide further information in regards to this topic
Management System Standard
Environmental Management System
The CEMP has been prepared in accordance with the overarching environmental management system (EMS) as
detailed below
Georgiou has a certified EMS consistent with ASNZS ISO 14001 Environmental Management Systems and will
prepare CEMPs in accordance with this EMS
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Policy
This Management Plan has been prepared in accordance with Georgioursquos Environmental Policy (appendix 11) All
relevant works including those conducted by subcontractors or by other companies on Georgioursquos behalf will
conform to this Policy
Georgioursquos Environmental Policy will be communicated to all workers at their site induction and displayed at the
site Georgioursquos policies will be made available to any interested party
Environmental Management Plan
This CEMP provides the system to manage and control the environmental aspects of the Project during pre-
construction and construction It identifies all the requirements applicable to manage the activities described in
Section 2 It also provides the overall framework for the system and procedures to ensure environmental impacts
are minimised and legislative and other requirements are fulfilled The strategies defined in this CEMP have been
developed with consideration of the Project approval requirements environmental management measures
presented in the approval documents This CEMP establishes the system for implementation monitoring and
continuous improvement to minimise impacts from the Project on the environment
This CEMP is consistent with
ASNZS ISO14001 2004 lsquoEnvironmental Management Systems - requirements with guidance for usersquo
Georgiou HSEQ Management System
Environmental Policy
Georgious Management is committed to regulatory
compliance pollution prevention and continous
improvement
Planning
Identify environmental interactions and signficant
aspects identify legal and other requirements and development
environmental objectives targets and the programs in
which to achieve them
Implementation and Operation
Define structure and responsibility identify and complete training
needs establish communication procedures document the EMS
through policies plans and procedures establish document
control establish operational control implement emergency
preparedness and response
Checking
Monitor and measure environmental interactions
evaluate compliance establish a non-conformance corrective
action and preventative action system maintain records and
perform periodic internal audits of the EMS
Management Review
Management to review environmental performance
EMS performance policy priorities and objectives and recommend improvements
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5 LEGAL AND OTHER OBLIGATIONS
The following documents provide further information in regards to this topic
Management System Standard
HSE Legal and Other Obligations Directory
General
The statutory requirements for this site have been identified within the Company HSE Legal and Obligations
Directories (available on Company Intranet) and have been incorporated into this management plan Legal and
other requirements specific to this contract which are not otherwise captured in the Company HSE Legal and
Obligations Directories are as follows
Legislation Other requirement
Requirement Comment
EPBC Act 1999
Under the EPBC Act a referral to the Commonwealth Department of Agriculture Water and the Environment is required for proposed lsquoactionsrsquo that have the potential to significantly impact on any matter of national environmental significance the environment in general or the environment of Commonwealth land (including leased land)
There are no matters of national environmental significance located within the general area of the proposal as confirmed in Appendix A of the REF Therefore an EPBC Act referral is not required
EPampA Act 1979
Clause 94 of the ISEPP outlines that development for the purpose of road and road infrastructure facilities which are permissible without the need for development consent under Part 4 of the EPampA Act when carried out by a public authority
Sydney Metro is a public authority and has prepared an REF and determination report to meet the assessment requirements under the EPampA Act
EPampA Regulation 1979 Under clause 228 of the factors to take into account concerning the impact on an activity on the environment
The REF and determination report prepared by Sydney Metro has considered factors under clause 228
ISEPP 2007
Division 1 of Part 2 of the ISEPP contains provisions for public authorities to consult with local councils and other public authorities prior to the commencement of certain types of development
Sydney Metro will conduct consultation with local councils and other authorities prior to commencement of construction
Biosecurity Act 2015
Under the Biosecurity Act 2015 all plants including weeds are regulated with a general biosecurity duty to prevent eliminate or minimise any biosecurity risk they may pose Any person who deals with any plant who knows (or ought to know) of any biosecurity risk has a duty to ensure the risk is prevented eliminated or minimised so far as is reasonably practicable
The State level priority weeds and associated legal requirements relevant to the region are outlined in the Greater Sydney Regional Strategic Weed Management Plan 2017-2022 (Greater Sydney Local Land Services 2017)
As such if present priority weeds on the site would be assessed and controlled to fulfil the General Biosecurity Duty and minimise biosecurity risks
Contaminated Land Section 60 of the Contaminated Land Management Act 1997 imposes a duty on
One site (former White Bay Power Station) that is currently regulated by
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Management Act 1997 landowners to notify the NSW EPA and potentially investigate and remediate land if contamination is above NSW EPA guideline levels
the NSW EPA is located within the proposal site
Given the proposed works are predominately surficial or up to one metre below existing site levels contamination risk is considered minor and manageable
Biodiversity
Conservation Act 2016
The Biodiversity Conservation Act 2016 provides for the protection of threatened species populations and ecological communities in NSW If a threatened species population or ecological community or its habitat is likely to occur in any area that may be affected by the proposal then an assessment of significance must be prepared to determine whether the proposal would have a significant impact
The site is unlikely to contain suitable habitat for any listed threatened species or community and is unlikely to have a significant impact on any threatened species or community
Heritage Act 1977
The NSW Heritage Act 1977 (Heritage Act) provides protection for items of lsquoEnvironmental heritagersquo in NSW Items considered to be significant to the State are listed on the State Heritage Register (SHR) and cannot be demolished altered moved or damaged or their significance altered without approval from the Heritage Council of NSW
Section 170 of the Heritage Act requires government agencies to maintain a heritage and conservation register (Section 170 register) These registers provide a list of government assets which may have State or local heritage significance
Sections 139 to 145 of the Heritage Act prevent the excavation or disturbance of land known or likely to contain relics unless in accordance with an excavation permit Excavation permits are issued under Section 140 of the Heritage Act or Section 60 for sites listed on the SHR Excavation Permit Applications must be supported by an Archaeological Research Design Section 146 of the Heritage Act requires that any discovery or location of a lsquorelicrsquo is reported to the Heritage Council
The road footprint for Georgioursquos scope of works is located outside of the heritage curtilage for the SHR-listed White Bay Power Station and does not extend north to the White Bay Power Station (Inlet) Canal (Port Authority of NSW s170 4560062)
The Glebe Island Silos (Port Authority of NSW s170 4560016) and the Glebe Island Dyke Exposures (Port Authority of NSW s170 4560056) are located immediately adjacent to the road footprint
As detailed in the REF it is unlikely that archaeological relics would be impacted by the works therefore a Section 139 exception or Section 140 permit are not required for the works
National Parks and
Wildlife Act 1974
Sections 86 87 and 90 of the National Parks and Wildlife Act 1974 require consent from the Environment Energy and Science Group of the Department of Planning Industry and Environment for the destruction or damage of Aboriginal objects
The proposal is unlikely to disturb any Aboriginal objects (refer Section 77)
However if unexpected archaeological items or items of Aboriginal heritage significance are discovered during the construction of the proposal the Sydney Metro Unexpected Finds procedure would be followed
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Protection of
the Environment
Operations Act 1997
The Protection of the Environment Operations Act 1997 (POEO Act) administers environment protection licences (EPLs) for specific activities relating to air water and noise pollution and waste management The Environment Protection Authority (EPA) and local government where relevant administer the POEO Act
Development activities require an EPL under the POEO Act if those activities meet the assessment criteria outlined in Schedule 1 of the Act
The proposal does not meet the definition of a scheduled activity under Schedule 1
In addition the POEO Act would require construction to be managed to prevent and avoid the potential to cause water noise andor air pollution The Act also includes requirements in relation to the management of waste
Notification to the EPA would also be required (as the administrators of this Act) in instances where any pollution incident has the potential to lsquocause or threaten material harm to the environmentrsquo (refer to Section 148 of the Act)
Roads Act 1993
In accordance with Section 138 of the Roads Act 1993 consent from NSW Transport for NSW would be required for the carrying out of work in on or over a classified road
For works on unclassified roads Clause 5 of Schedule 2 of the Act provides that a public authority is not required to obtain a road authorityrsquos consent
Ongoing consultation would be carried out with the relevant road authority (or authorities) in relation to the potential impacts that may occur to all of the roads and to identify any potential construction activities may be require consent
Waste avoidance and
Resource Recovery
Act 2001
The purpose of the Waste Avoidance and Resource Recovery Act 2001 is to develop and support the implementation of regional and local programs to meet the outcomes of a State-wide strategy for waste avoidance and resource recovery
It also aims to lsquominimise the consumption of natural resources and final disposal of waste by encouraging the avoidance of waste and the reuse and recycling of wastersquo
Waste generation and disposal reporting would be carried out during the construction and operation of the proposal Procedures would be implemented during construction in an attempt to promote the objectives of the Act
Water Act 1912 and
Water Management
Act 2000
The Water Act 1912 and the Water Management Act 2000 are the two key pieces of legislation for the management of water in NSW and contain provisions for the licensing of water access and use
The proposal would not involve any water use water management works drainage or food works controlled activities or aquifer interference
National Greenhouse and Energy Reporting Act 2007
The Act established a framework for reporting of greenhouse gas emissions abatement actions energy consumption and production data
The project will report on greenhouse gas and energy usage data as required by the Act
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Contractual Environmental Requirements
This Management Plan has been written to comply with the following Sydney Metro CEMF requirements
Requirement Reference
Scope of Applicability (Any Sections of the CEMF not addressed in the left hand column of
this table do not apply) Addressed by
CEMF Requirements
Section 1 full applicability This document
Section 4
Section 2 full applicability Section 5
Section 23
Standards and guidelines applicable to the works including o ISO14001 Environmental Management System ndash Requirements
with Guidelines for Use o Interim Construction Noise Guidelines (Department of
Environment and Climate Change 2009) o Managing Urban Stormwater Soil and Construction (Landcom
2008) o AS42821997 Control of the Obtrusive Effect of Outdoor Lighting o Waste Classification Guidelines (Department of Environment
Climate Change and Water 2008) o Australian and New Zealand Guidelines for Fresh and Marine
Water Quality
Section 41
Appendix 7
Appendix 2
Appendix 1
Section 32
Only applies with respect to Construction for o SMP1 o SMP2 o SMP5 o SMP6 o SMP7 o SMP14 o SMP18 o SMP19 o SMP30
Separate sustainability management plan
Section 34
34(d) (x) applies only to the extent of addressing environmental inspections
34(d) (xi) does not apply
Approval by DPIE is not required under 34(e)
34(f) Applies with respect to o Unexpected Finds Procedure (Heritage) o Environmental Incident and Non-compliance Reporting Procedure o Construction Noise and Vibration Standard o Out of Hours Work Application Form o Unexpected Finds Procedure (Contamination)
This document
Appendices 1-10
Section 36 36(b) only applies with respect to the drafting of a Waste Management Procedure and an Unexpected Finds Procedure for Contamination
Appendix 1
Appendix 8
Section 39 39(a) (iii) does not apply 39(b) does not apply
39(b) does not apply Section 11
Section 310 Applies except that a Pollution Incident Response Plan is not required Section 12
Section 312 312(a)(i) does not apply
312(a)(iv) does not apply Section 6
Section 313
313(b) does not apply
313(d) does not apply
313(e) does not apply
Section 15
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CEMP Bays Road Relocation Works
Section 314 Full Applicability Section 13
Appendix 9
Section 315 315(d) does not apply with respect to internal audits carried out by the Principal Contractor
Section 16
Section 316 316(d) does not apply where the Principal Contractors works last less than 1 year
Section 15
Section 4 42(a) does not apply
45(c) does not apply Section 72
Section 5 51(c) does not apply
54 does not apply Appendix 7
Section 6 Only 61 applies
Sustainability management plan
Section 7 71 does not apply
72 does not apply
Appendix 2
Section 8
81 full applicability
A Construction Noise and Vibration sub-plan is not required however the CEMP must address
82(a) (iii) and (b) for Site Establishment Activities
Appendix 7
Section 9
91 (a) (i) is not applicable
A Heritage Management plan is not required however the CEMP must address the following requirements
92 (iii)
92 (ix)
92 (c) (iii)
Appendix 5 5A 5B
Section 10
101 (ii) does not apply
102(a) (iii) applies with respect to the relocation of fauna only
102(b) (i) applies
102 (b) (ii) applies
All other sections are not applicable
Appendix 4
Section 11 111 (ii) does not apply
112 does not apply Section 72
Section 12
A Soil and Water Management Plan is not required however the CEMP must address the following requirements
122 (vi)
Appendix 2
Section 13 131 full applicability
132 does not apply Appendix 6
Section 14
141 full applicability
A Waste Management Plan is not required however the CEMP must address the following Requirements
142 (a) (iv)
142 (a) (v)
142 (b) (i)
142 (d)
Appendix 1
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CEMP Bays Road Relocation Works
REF Determination Conditions of Approval
The project is subject to compliance with the Conditions of Approval (CoA) identified below these are from the
REF Determination Report (August 2020) These Conditions of Approval are consistent with the management and
mitigation measures in the REF (April 2020) with some amendments due to the project changes identified in the
REF determination report
CoA Requirement Addressed by
REF Determination Conditions of Approval
NV1 Receivers that would potentially be affected by noise andor vibration from the works would be appropriately notified before the relevant works start
This would include details on the nature of works to be carried out the expected noise levels duration of noise generating construction works and contact details during construction
Appendix 7
NV2 Where vibration levels are predicted to exceed the screening criteria a more detailed assessment of the structure (in consultation with the relevant asset owner and a structural engineer) and attended vibration monitoring would be carried out to ensure vibration levels remain below appropriate limits for that structure
For heritage buildings and structures the more detailed assessment would specifically consider the heritage values of the structure in consultation with a heritage specialist to ensure sensitive heritage fabric is adequately monitored and managed
Appendix 7
NV3 Condition surveys of buildings and structures near to the proposal would be undertaken in consultation with the relevant owner prior to the commencement of vibration intensive works where appropriate For heritage buildings and structures the surveys would consider the heritage values of the structure in consultation with a heritage specialist
Sydney Metro
NV4 Alternative construction methodologies would be considered where vibration intensive works (typically site clearing ndash demolition) result in exceedances of cosmetic damage screening criteria and may include the following
The use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of rockbreakers for demolition of structures
Use of smaller capacity rockbreakers or lower vibration generating rockbreakers
Isolating the vibration sensitive structure from the vibration intensive work area by severing the vibration transmission path using non-vibration intensive means such a sawing
Appendix 7
NV5 The potential vibration impacts to underground utilities and services would be reviewed as the proposal progresses in consultation with the asset owners and the Port Authority of NSW
Appendix 7
T1 Clear wayfinding and safety signage would be provided to direct and guide vehicles not related to the proposal during road construction works This would be supplemented by Variable Message Signs to advise drivers of traffic diversions speed restrictions or alternative routes
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T2 The Port Authority of NSW and lease holders would be notified in advance of any proposed road changes within the port area and the potential for short term delays
Sydney Metro
Georgiou must provide written notifications to Sydney Metro on road changes in
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CEMP Bays Road Relocation Works
advance of each relevant road change within the port area
T3 Construction site traffic would be managed to minimise movements during peak periods
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T4 Access to Cement Australia and other leased areas would be maintained in consultation with Port Authority and lease holders
Sydney Metro
Georgiou will provide required information to SM
T5 All staff parking would be provided on-site and not on surrounding local streets
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
NAH1 An Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
(Transferred to Georgiou under VO-003)
C1 Sampling and testing of soils in areas of potential contamination concern would be conducted to characterise the soils (with respect to contamination) and determine the appropriate waste classification (which may include hazardous wastes or special wastes) and management response Waste classification would be carried out in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (NSW Environment Protection Authority 2014)
Appendix 1
Appendix 1A
C2 Soils would be managed in accordance with the Protection of the Environment Operations (Waste) Regulation 2014 and disposed of to an appropriately licensed waste management facility
Appendix 1
Appendix 1A
C3 Erosion and sediment measures would be implemented in accordance with the principles and requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Appendix 2
C4 All fuels chemicals and hazardous liquids would be stored in accordance with Australian standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Appendix 3
C5 Prior to ground disturbance in areas of potential acid sulfate soil occurrence testing would be carried out to determine the presence of actual andor potential acid sulfate soils If acid sulfate soils are encountered they would be managed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Appendix 2
LV1 The design and maintenance of construction site fencing would aim to minimise visual amenity impact where visible from public areas
Section 722
LV2 Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Appendix 7
WR1 All waste would be assessed classified managed transported and disposed of in accordance with the Waste Classification Guidelines and the Protection of the Environment Operations (Waste) Regulation 2014
Appendix 1
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CEMP Bays Road Relocation Works
The waste management hierarchy principles established under the Waste Avoidance and Resource Recovery Act 2001 of avoidreducereuserecycledispose would be applied to the construction of the proposal
AQ1 The following best-practice dust management measures would be implemented during all construction works
Regularly wet-down exposed and disturbed areas including stockpiles especially during dry weather
Adjust the intensity of activities based on measured and observed dust levels and weather forecasts
Minimise the amount of materials stockpiled and position stockpiles away from surrounding receivers
Regularly inspect dust emissions and apply additional controls as required
Appendix 6
AQ2 Plant and equipment would be maintained in a proper and efficient manner Visual inspections of emissions from plant would be carried out as part of pre-acceptance checks
Appendix 6
GHG1 Opportunities to reduce greenhouse gas emissions through the increased use of recycled materials would be investigated during detailed design
Sydney Metro
CI1 The likelihood of cumulative (ie concurrent and consecutive) construction impacts would be reviewed during detailed design when detailed construction schedules are available
Co-ordination and consultation with the following stakeholders would occur where required to manage the interface of projects under construction at the same time
Transport for NSW including Transport Coordination
Department of Planning Industry and Environment
Port Authority of NSW
Sydney Motorways Corporation
Construction contractors
Co-ordination would occur between potentially interacting projects to minimise concurrent or consecutive works in the same areas where possible
Sydney Metro
Georgiou must participate in any consultation as requested by the Principal and provide the Principal with all information and documentation the Principal requires to comply with condition
Environmental Licences and Permits
The Project Environmental Site Representative will be responsible for
Checking with the local government municipality to see if there are local environmental requirements Identifying the environmental licences and or permits under which the site will operate Obtaining a copy of any client held licences permitsapprovals to determine conditions of compliance or if not
available obtaining written verification that licences and permits are held Obtaining Georgiou held licences and or permits Monitoring compliance to the conditions of the licencepermit and report on the status in the Project HSEQ
Performance Report and to the client
Permits and licences relevant to the project are as follows
Permit licence Responsibility Status
Environmental protection licences (EPL) under the Protection of the Environment Operations Act 1997 for road construction
Georgiou Not required as this project does not trigger a scheduled activity under the POEO Act 1997
Road Occupancy Licences Georgiou To be applied for as required
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Infringement Improvement and Prohibition Notices
The Project Manager or delegate will ensure any infringement improvement or prohibition notice issued by a
regulatory authority recorded as a incident in Georgioursquos Incident reporting database (Beakon) and appropriate
actions taken in a timely manner A copy of the infringement improvement or prohibition will be added to the
incident report and forwarded to the HSE Business Unit Lead
The Project Manager will notify via email their General Manager Construction Manager Operations Manager
HSE Business Unit amp Environmental Site Representative Lead when the infringement improvement or prohibitions
notice has been closed out
Availability of Statutory and Other Information
Georgioursquos HSEQ Department maintains links to current statutory documents (Acts Regulations and Codes of
Practice) in the HSE Legal and Other Obligations Directories which are located on Georgioursquos Intranet
(GENIE)Georgiou subscribes to Environmental Essentials product Envirolaw which is available to all personnel
through the intranet link Envirolaw summarises environmental legal obligations provides links to legislation and
guidelines as well as providing search capabilities
Changes in legislation are monitored by the HSEQ Department and site management will be notified where a change
affects a site The Project Manager will be responsible for communicating changes in accordance with section 7
HSE will ensure the change is reflected in this Management Plan and other relevant plans and documents as
applicable
Objectives amp Targets
Objectives and targets have been set for the site taking into account the significant hazards and environmental
aspects of the job the group objectives and client and contractual requirements These are documented in the
table below
Item Description Measurement Target
1 Successful implementation of CEMP and contract requirements
Audits inspections reporting management reviews
0 NCRs associated with CEMP implementation
2 Compliance with all legal requirements Audits reporting management reviews
0 regulatory infringements (PINs or prosecutions)
3 Engage with the affected and broader community minimise complaints and respond to any complaints within a suitable timeframe
Review complaints register reporting audits
0 NCRs associated with CCS implementation
4 Environmental incidents with the potential to cause material harm to the environment
Number of material harm incidents 0
5 Continuously improve environmental performance
Regular environmental inspections
Regular Leadership visits
Share environmental best practice and innovations across projects
1 environmental inspection per week
1 Leadership visit per month
1 NSW Environmental meeting per month
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6 Environmental Awareness for all workers
Conduct all Toolboxes and training identified in this CEMP
1 environmental toolbox per month on relevant site issues
Additional objectives and targets may be set specifically for activities identified for upcoming works Performance
against all HSE objectives will be monitored as a minimum monthly at site meetings
6 STRUCTURE AND RESPONSIBILITIES
Organisational Structure
The site organisational structure has been documented in the Site Organisational Chart The Site Organisational
Chart identifies the roles that will support the site in fulfilling their HSE responsibilities
Roles and Responsibilities and Authority
The Project Manager is accountable for the environmental performance of the project and the implementation of
the projectrsquos management plans Key personnel and their site responsibilities are detailed below
Project Manager ndash Brad Collins
The environmental responsibilities of the Project Manager include (but are not limited to) the following
Ensure all works comply with relevant regulatory and Project requirements Ensure the requirements of this CEMP are fully implemented and in particular that environmental
requirements are not secondary to other construction requirements Endorse and support the environmental policy Be aware of their environmental responsibilities as detailed in the management plans Actively ensure that subcontractors and suppliers are complying with environmental requirements Liaise with the client and other government authorities as required Participate and provide guidance in the regular review of this CEMP and supporting documentation Provide adequate resources (personnel financial and technological) to ensure effective development
implementation and maintenance of this CEMP Ensure that all personnel receive appropriate induction training including details of the environmental and
community requirements Ensure that complaints are investigated to ensure effective resolution Stop work immediately if an unacceptable impact on the environment is likely to occur Hold monthly HSEQ management meetings to review environmental performance and monitor
implementation and effectiveness of the management system Ensure their direct reports fulfil their environmental responsibilities and achievement of KPIrsquos Support workers to immediately stop any lsquoat risk behaviourrsquo identified during their work activities
Project Site Engineer ndash Richard Kelly
The environmental responsibilities of the Project engineers include (but are not limited to) the following
Provide input into the preparation of environmental planning documents as required Ensure that instructions are issued and adequate information provided to employees that relate to
environmental risks on-site Ensure that the works are carried out in accordance with the requirements of the CEMP and supporting
documentation including the implementation of all environmental controls Identify any environmental risks Identify resource needs for implementation of CEMP requirements and related documents Ensure that complaints are investigated to ensure effective resolution
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Take action in the event of an emergency and allocate the required resources to minimise the environmental impact
Report any activity that has resulted or has the potential to result in an environmental incident immediately to the Supervisor and Environmental Site Representative
Supervisor ndash Eddie Storer
The Supervisor is responsible for creating an exemplary HSE culture and ensuring adherence to the Management System on their site The Supervisor is responsible for approving the commencement of works and to allocate necessary resources to complete a job safely in accordance with the Management Plan and will
Demonstrate commitment to the Environment by monitoring the workplace to ensure work practices are adhered to by way of routine checks of the workplace compliance to the Management Plan
Demonstrating through their actions and behaviour that safety and the environment are core values Hold Supervisors and leading hands (Georgiou amp subcontractors) accountable for the fulfilment of their
Environmental responsibilities including KPIrsquos Be given the authority and independence to require reasonable steps be taken to avoid or minimise
unintended or adverse environmental impacts Allocating work to ensure appropriate supervision for those with lesser experience Ensuring appropriate and necessary plant and equipment is provided for workers to carry out their work
safely and without undue harm to the environment Stopping rejecting or quarantining materials plant and equipment Supporting workers to immediately stop any lsquoAt Risk Behaviourrsquo identified during their work activities Participating in audits investigations and constructability reviews Management and HSE performance of the subcontractors utilised on site
Environmental Site Representative ndash Chloe Redman
The environmental responsibilities of the Environmental Site Representative include (but are not limited to)
overall responsibility for the implementation of environmental matters on the Project development implementation monitoring and updating of the EMP and sub-plans in accordance with
ISO14001 report to the Project Manager on the performance and implementation of the CEMP to ensure management
reviews of the CEMP are undertaken annually documented and actions implemented ensure environmental risks of the Project are identified and appropriate mitigation measures implemented identify where environmental measures are not meeting the targets set and where improvement can be
achieved ensure environmental protocols are in place and managed ensure environmental compliance obtain and update all environmental licences approvals and permits as required liaise with the approval authorities manage environmental document control reporting inductions and training manage environmental reporting within the Project team and to the Client and regulatory authorities prepare reports on a monthly basis outlining the Project works undertaken and the achievements that have
been met as well as identifying those areas where improvements were made oversee site monitoring inspections and audits manage all sub-contractors and consultants with regard to environmental matters including assessing their
environmental capabilities and overseeing the submission of their environmental documents develop and facilitate induction toolbox talks and other training programs regarding environmental
requirements for all site personnel notify the client and relevant authorities in the event of an environmental incident and manage close-out of
these stop activities where there is an actual or immediate risk of harm to the environment or to prevent
environmental non-conformities and advise the Project Manager and Supervisor assist the Community Relations Manager to resolve environment-related complaints
undertake site inspections carry out monitoring activities and complete site checklists ensure monitoring records are appropriately maintained reviewed and any non-compliance issues addressed assist in identifying environmental risks
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advise the Project Manager of the need to stop work immediately if an unacceptable impact on the environment is likely to occur or to require other reasonable steps to be taken by the site Construction staff to avoid or minimise impacts
Environmental Consultants
Georgiou has engaged consultancy contracts with the following companies
Ade Consulting - Contaminated land and hygienist services VMS ndash Noise and Vibration Management Services ARTEFACT ndash Archaeological and Heritage Consultants
Throughout the works there may be the requirement to engage other specialist environmental consultants or change the consultants listed above All Environmental consultants engaged to provide specialist advice on environmental matters are responsible to
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the Supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Adhering to all permit requirements Complying with all statutory and regulatory requirements
All Personnel
All personnel on site are responsible for
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident undertake remedial action as required to ensure environmental controls are maintained in good working
order Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Participating and adhering to SWIrsquos and JHArsquos Adhering to all permit requirements Immediately stopping any lsquoAt Risk Behaviourrsquo identified during daily work activities Complying with statutory and regulatory requirements
Communication and Acceptance of Accountabilities and Responsibilities
The Core Site Team will acknowledge their understanding and acceptance of the site accountabilities and
responsibilities by signing Appendix 1 in this plan
Field Leadership Visits
Senior Management with an operational role or functional support will demonstrate visible and proactive commitment by visiting site to engage in discussion with site management and workers in regard to HSE issues relevant to the business which may include any of the following
Active participation and contribution in Pre-start meetings Participation in Toolbox Talks Participation in the delivery of site safety and environmental messages on-site HSE programs or initiatives Participation in work inspections One-on-one discussions
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Behavioural observations Participation in monthly meetings discussing HSEQ performance
A record of the visit and the activity undertaken by the Senior Manager will be recorded and where appropriate feedback provided to the Site team A component of the Site Leadership visit will involve an environmental inspection of the site in accordance with section 151
7 COMMUNICATION AND CONSULTATION
The following documents provide further information in regards to this topic
HSEQ Communication and Consultation Standard
Community Relationship Management Guideline
Resolution of HSE Issues Procedure
Internal Communication and Consultation
Communication and consultative arrangements will be put in place to provide workers including subcontractors
with information and an opportunity to contribute to HSE and comply with applicable legislative requirements
The Site will use the methods detailed below to communicate to employees subcontractors and visitors
information in regard to the Georgiou Management System this management plan performance and environmental
issues
711 Inductions
All personnel (including sub-contractors) are required to attend a compulsory site induction that includes an
environmental component prior to commencement on-site This is undertaken to ensure all personnel involved in
the Project are aware of the requirements of the CEMP The environmental component of the induction must cover
all elements of the CEMP and will include as a minimum
relevant details of the CEMP including all sub-plans procedures and strategies their purpose and objectives
policies and KPIs
Requirements of due diligence and duty of care
relevant legislation and conditions of environmental licences permits and approvals
Potential environmental emergencies on-site and the emergency response procedures
Reporting and notification requirements for pollution and other environmental incidents
key environmental issues
Mitigation measures for the control of environmental issues
Complaints response and reporting
Communication protocols for interactions with community and stakeholders
site specific environmental management requirements and responsibilities
Incident and emergency response and reporting requirements
Environmentally sensitive locations and no-goexclusion zones
Erosion and sediment controls water quality controls and sediment basin management
Management of contaminated material (including asbestos impacted material)
Location of identified potential contaminated land sites
Signs of contaminated soil including visual asbestos identification protocols
Procedure for unexpected finds of contaminated land asbestos
Water quality management and protection measures
Location of identified Aboriginal and non-Aboriginal archaeological heritage sites areas of cultural sensitivity
and areas of archaeological potential and the kinds of historical relics structures or deposits which may be
encountered during the Construction works
Unexpected finds procedures for heritage
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noise vibration and air quality management controls
Standard Construction hours and the process for seeking approval for out of hours works including consultation
Road occupancy and other temporary and interim traffic arrangements
Specific responsibilities for the protection of flora and fauna
A record of all environment inductions will be maintained in a Project induction and training Register and kept on-
site The training register will identify who is trained when trained the trainer and what they were trained in
712 HSE Notice Boards
All worksites that have a crib room will set up a HSE notice board to display
Project HSEQ Performance Report
Environmental BulletinsAlerts
Site HSEQ Objectives and Targets
Organisational Chart
A Site Layout Plan and Emergency Evacuation Plan Emergency contacts and First Aiders list These will also be
posted in prominent locations throughout the site as described in the site Emergency Response Management
Plan
Risk Registers
713 HSE Alerts Bulletins
Incident Alerts will be used to communicate learningrsquos and actions required to assist in ensuring incidents that have
occurred in one workplace are not repeated in others HSE Bulletins will be used to communicate environmental
information to the workplace HSE Alerts and Bulletins will be developed by the Site Team using the approved
templates and approved by the HSE Business Unit Lead prior to communication
714 Site Meetings
The following meetings will be held on site to monitor implementation of the Georgiou Management System review
performance and communicate consult with workers in regards to HSE
Site Meetings (refer to section 142) Pre-Start Meetings Toolbox Meetings
Meeting agenda and minutes will be recorded maintained and be made available when required
Community and Stakeholder Involvement
A Community Communication Strategy will be developed for the project Key elements of the Community
Communication Strategy which will be implemented at appropriate times in the construction process will include
Notification (including targeted letterbox drops and email) of any works that may disturb local residents and businesses (such as noisy activities and night works) at least seven days prior to those works commencing
Notification (including targeted letterbox drops and email) of works that may affect transport (such as road closures changes to pedestrian routes and changes to bus stops)
Traffic alerts (via email) to all key traffic and transport stakeholders advising of any changes to access and local traffic arrangements (at least seven days prior to significant events)
Print and radio advertisements regarding major traffic changes 24-hour toll-free community project information phone line Complaints management Community information sessions as required Regular updates to the Sydney Metro website (sydneymetroinfo) including uploading of all relevant
documents and contact details for the stakeholder and community relations team
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Provision of information to the Sydney Metro Community Information Centre including community newsletters information brochures and fact sheets and interactive web-based activities
Clear signage at the construction sites Newspaper advertisements in local and metropolitan papers as required Regular inter-agency group meetings Community business and stakeholder satisfaction surveys and feedback forms Translator and interpreter services and The project team will liaise with the Sydney Metro Project Communications team as the point of contact for
the community
721 Complaints Management
Community liaison and complaints handling will be undertaken in accordance with the Construction Complaints
Management System and will include
dealing with complaints in a responsive manner so that stakeholdersrsquo concerns are managed effectively and promptly and
A verbal response will be provided to the complainant as soon as possible and within a maximum of two hours from the time of the complaint (unless the complainant requests otherwise) A detailed written response will then be provided if required to the complainant within one week
A complaints register will be maintained in Georgioursquos BEAKON database and in Sydney Metrorsquos Consultation
Manager TM which will contain
Date and time of complaint Method by which the complaint was made (telephone letter meeting etc) Name address and contact telephone number of complainant (if no such details were provided a note to that
effect) Nature of complaint Action taken in response including follow up contact with the complainant Any monitoring to confirm that the complaint has been satisfactorily resolved If no action was taken the reasons why no action was taken
The project will apply an adaptive approach to ensure that corrective actions are applied in consultation with the
appropriate construction staff to allow improvements in the management of issues resulting in community
complaints
722 Urban Design of temporary works
Temporary construction works will consider urban design and visual impacts including
Minimise impacts on existing landscape features as far as feasible and reasonable Artwork graphics and images to enhance the visual appearance of temporary works in high visibility locations Project information to raise awareness on benefits explain the proposed works at each site and provide
updates on construction progress Community information including contact numbers for enquiries complaints Signage and information to mitigate impacts on local businesses which may be obscured by the construction site Sydney Metro advertising public awareness campaigns Logos branding including Sydney Metro NSW Government and Contractor branding
The design of all temporary works will require Sydney Metro approval in relation to urban design and visual impacts
and Sydney Metro will stipulate the design of hording artwork including
Sydney Metro advertising public awareness campaigns and Logos branding including Sydney Metro NSW Government and Contractor branding
Construction hoardings scaffolding and acoustic sheds will be regularly inspected and kept clean and free of dust
build up Graffiti on construction hoardings scaffolding or acoustic sheds will be removed or painted over
promptly The principles of Crime Prevention Through Environmental Design will be applied to all works including
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temporary works that have a public interface
723 Business and Property Impacts
The project footprint is within any area managed by the Port Authority of NSW and several port related facilities
are adjacent to the work including Cement Australia Gypsum Resources Australia and Sugar Australia Georgiou will
undertake works to meet the following objectives
Minimise the potential impact of the project to businesses affected by construction works Ensure businesses are kept informed of the project and consulted in advance of major works or factors that are
likely to have a direct impact Ensure that business stakeholder enquiries and complaints regarding the project are managed and resolved
effectively
Consult with all business directly affected by changes to access arrangements regarding specific requirements at least two weeks prior to those changes coming into effect
8 HAZARD IDENTIFICATION AND RISK CONTROL
The following documents provide further information in regards to this topic
HSEQ Risk and Operational Control Standard Job Hazard Analysis (JHA) Procedure Permit to Work Procedure
Hierarchy of Control
The following hierarchy of control will be applied to controlling environmental risks and environmental aspects
within Georgiou This hierarchy recognises that the best controls act on the environment not on the people in it
HazardsAspects
Waste
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Site Environmental Risk Analysis
The Site Team has undertaken a construction risk assessment workshop (CRAW) and developed a HSEQ Risk
Register based on the Master Risk Register which incorporates the Companyrsquos mandatory controls and additional
site specific hazards and controls identified in the CRAW This Management Plan and the Emergency Response
Management Plan have been based upon this HSEQ Risk Register
Works on site will be undertaken in accordance with the HSEQ Risk Register The HSEQ Risk Register will be
made available to workers
Review of Risks
The aspects within the HSEQ Risk Register will be reviewed for adequacy
At site meetings Prior to the commencement of any new construction work that involves high impact risks After a significant incident
If there is a change made to the construction methodology and associated change in the risks and controls associated with the works the Risk register and Construction Environmental Management Plan will be updated as appropriate
831 Change Management
The following documents provide further information in regards to this topic
Change Management Procedure
Where there is a change to the planned scope design or construction methodology (including plant machinery
materials or sequence) the impact of the change must be assessed and a determination on whether the Change
Management Procedure applies If so then a formal analysis of the change will be undertaken using the
Management of Change Event Design Form
Changes to the project may require an assessment to determine consistency with the REF and Environmental
Documents The assessment will include
A description of the existing surrounding environment Details of the ancillary works and construction activities required to be carried out including the hours of works An assessment of the environmental impacts of the works including but not necessarily limited to traffic
noise and vibration air quality soil and water ecology and heritage Details of mitigation measures and monitoring specific to the works that would be implemented to minimise
environmental impacts Identification of the timing for completion of the construction works and how the sites would be reinstated
(including any necessary rehabilitation)
Operational Control
Operations and activities associated with significant environmental aspects will be planned to ensure they are
carried out under specific operating conditions An Environmental Control Map (ECM) Safe Work Method
Statements Job Hazard Analysis Take Five Hazard Report or a combination of these will be used to achieve this
requirement
841 Environmental Hazard Reporting
Environmental Hazard reporting will be conducted using the Hazard Report (contained within the Hazard
ReportTake 5 booklet)
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The Supervisor is responsible for ensuring environmental hazards are addressed in a timely manner using the
hierarchy of control and communicated to those who may be potentially affected Where hazards cannot be
addressed immediately and additional controls are required they are to be reported into the Beakon system for
follow-up and close-out
842 Take 5
Take 5 booklets will be available to all workers to perform risk assessments for work that is not high risk
construction Take 5 risk assessments include environmental aspects and the identified environmental controls for
these risks are to be documented on the Take 5 form and implemented for the works
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS)
JHASWMS will be completed for all high risk construction work JHASWMS developed will reflect the safety and
environmental risks and controls identified in the sites risk register and supporting work instructions
Subcontractors will be provided access to the sites HSEQ Risk Register and prior to undertaking the work will be
required to submit their JHArsquosSWMS to Georgiou for review and approval using the Subcontractor JHASWMS
Assessment (available in Beakon)
844 Permit to Work
The following high risk activities require written authority in the form of a ldquopermit to workrdquo from the Georgiou Site
Team
Vegetation Clearing Permit (Georgiou form) Dewatering Permit (Georgiou form) Out of Hours application (Sydney Metro form)
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices) will be included in the
environmental permits No work involving these activities will commence until the appropriate permit has been
completed Personrsquos issuing permits on the Site will be given training in the Georgiou Permit to Work system A
permit may be required for other high risk activities as determined by risk assessment the Sitersquos Manager andor
contractual requirements
845 Environmental Control Maps
To assist pre-construction planning and on-site construction management the environmental site constraints are
consolidated on a series of map-based sheets that extend the length of the Project Environmental Control maps
include information pertaining but not limited to
Noise and vibration sensitive receiverrsquos eg residential dwellings
Flora features including threatened species and endangered ecological communities
Aboriginal and non-Aboriginal heritage sites including items places objects and sites
Local waterways
Recorded threatened fauna sightings
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices)
The Environmental Control maps are a working element of the CEMP and will be revised throughout construction to
reflect true ground conditions and the most up-to-date information available on sensitive sites Sensitive area maps
will be used in conjunction with EWMS and ESCPs to help identify key risk areas and to promote ongoing
communication to construction personnel during the Project
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9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT
The following environment aspects have been identified as significant for this project Risks associated with these
significant aspects and appropriate controls have been identified during the construction risk assessment workshop
(CRAW) and included in the HSEQ Risk Register in accordance with section 82
In addition aspect specific sub-plans within this CEMP have been developed to detail how the environmental
aspects will be managed to comply with relevant legislation amp client requirements These aspect specific sub plans
include
Waste
Soil and Water
Hydrocarbon and Chemical
Cultural Heritage
Air Quality and Dust
Noise and Vibration
Contamination
10 CLOSURE AND COMMISSIONING
At completion of this project Georgiou will hand over the site in an environmentally responsible state) taking into
account the nature of the works in accordance with legislative amp contractual requirements
11 TRAINING COMPETENCY AND RESOURCING
All Georgiou personnel and contractors will undergo environmental training before commencing works on site
Training will be undertaken in the following forms
project site induction (section 711) and Environmental awareness training through regular tool box discussions Inductees will be required to sign-off that they have been informed of the environmental issues and that they
understand their responsibilities
1111 Toolbox talks
ldquoToolboxrdquo training will help to ensure that relevant information is communicated to the workforce and that
feedback can be provided on issues of interest or concern ldquoToolboxrdquo training will generally be prepared and
delivered by the Project Engineers Site Foreman or HSE Advisor Toolbox training topics are to be delivered to
provide refresher information on the environmental induction topics and associated environmental procedures In
the event of environmental near misses or incidents or changes to procedures that could result in changed levels of
environmental risks Toolbox talks may be used to deliver updates
Toolbox topics likely to be required include
work methods and efficient use of plant and materials waste management minimisation and recycling dust control protecting waterways spills and leaks emergency response procedures wet weather procedures and inspections and Legislation updates Please refer to the Toolbox schedule for a library of HSE toolboxes to deliver over the life of the project
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1112 Recording of Training and Assessment
Records of training and assessment will be maintained and will be readily available for verification Records of
induction and training will include the topic of the training carried out dates names and trainer details
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE
The following documents provide further information in regard to this topic
Emergency Preparedness and Response Standard
EmergencyIncident Planning and Control
The site has in place an Emergency Response Management Plan (ERMP) that addresses emergency response control
and recovery based upon credible emergency scenarios as identified in the Site Risk Register The Emergency
Response Management Plan has been developed in accordance with Emergency Preparedness and Standard
13 HSE REPORTING AND INVESTIGATION
The following documents provide further information in regard to this topic
Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
Notifications and Reporting
The Project Manager is accountable for ensuring all necessary reporting and notifications take place including
Client notification Statutory notification Scheme notification Community Complaints
Notifications and reporting regarding incidents will be done in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure
1311 Internal
The Environmental Site Representative or their delegate will be responsible for reporting all incidents into Beakon
database Incidents reported into Beakon will be reviewed by the Responsible Manager and approved within five
working days or before month end in which the incident occurred
1312 Notification of Incidents to Sydney Metro
Sydney Metro will be notified of any Georgiou environmental incident as soon as reasonably practicable Copies of
the incident reports and investigations incident will be made available to Sydney Metro within 48 hours in
accordance with the Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
1313 Statutory Notifications
An incident is an uncontrolled event or violation with serious or potentially serious negative consequences to
people property reputation or the environment Under Section 148 of the Protection of the Environment
Operations Act 1997 (POEO Act) Georgiou has a duty to immediately report pollution incidents causing or
threatening material harm to the environment Material harm is defined in Section 147 of the POEO Act as
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lsquoinvolves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding
$10000 and this loss includes the reasonable costs and expenses that would be incurred in taking all reasonable
and practicable measures to prevent mitigate or make good harm to the environmentrsquo
Investigations
Investigations regarding the incident will be completed in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure and commence as soon as practicable (preferably
immediately) but within 24 hours
All environmental incidents would be investigated in such a manner that the following basic elements can be
established
identifying the cause extent and responsibility of the incident
identifying and implementing the necessary corrective action
identifying the personnel responsible for carrying out the corrective action
implementing or modifying controls necessary to avoid a repeat occurrence of the incident
recording any changes in written procedures required and
Advising regulatory authorities in accordance with licence conditions
Review and Communication of Incidents
Incidents will be reviewed to check that causal factors and root causes were identified and that the findings have
been effectively addressed through assignment of actions at the
Site monthly meetings Business Unit meetings OHS Committee Meeting (if established)
Actual and potential class 1 incidents will be reviewed by senior management to ensure adequacy of closeout HSE
incidents and their preventative actionslearnings will be communicated at pre-start meetings toolbox meetings
and through HSE alertsbulletins as per section 7
14 ENVIRONMENTAL REPORTING
1411 Monthly Reports
Georgiou is required to submit an Environmental Monthly Report to the client including the information specified
below as evidence of implementation of the Environmental Management Plan
Implementation of environmental management including environmental monitoring implementation of environmental controls training inspections and testing
Implementation of incident management including emergency response - details of all environmental incidents or emergencies including non-compliance with environmental procedures and near misses complaints implementation of incident and emergency response management and implementation of corrective action
Implementation of reviews - details of internal reviews audits and inspections undertaken to verify that on-site environmental processes and practices conform to the Environmental Management Plan
Waste Statistics and NGERs reporting
Site Meetings
The Site will hold a monthly HSEQ Management Meeting in accordance with the Health amp Safety Management Plan
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Project Performance Review
At completion of the Project the Project Manager is responsible for arranging a review of project performance
which will include HSE management performance and lessons learnt for the purpose of continually improving
Georgiou Management Systems This review will be in accordance with the Project Close-Out Procedure
15 AUDITING REVIEWS AND INSPECTIONS
The following documents provide further information in regards to this topic
Auditing Reviews and Inspections Standard
Inspections
1511 Environmental Inspections
The following inspections will take place on site
Environmental Weekly Inspections Detailed Hazard Inspections considering timingavailability of activities Site leadership field visits These inspections will be used a process to monitor onsite environmental performance and they will cover all applied environmental mitigation measures including water quality erosion and sediment control structures fuel and chemical storage and waste management Attendees for the inspections can include Sydney Metro Environmental and project team members Georgiou Environmental and project team members and Georgiou Senior and Executive Management when conducting a Field Leadership Visit (section 64) The Environmental Site Representative will record inspection findings on the inspection report If any maintenance andor deficiencies in environmental controls or in the standard of environmental performance are observed they will be recorded on the inspection Records will also include details of any maintenance required the nature of the deficiency any actions required and an implementation priority Any Sydney Metro Environmental Inspections will occur on the Sydney Metro Inspection record template ndash Appendix 10
Audits and Reviews
The following audits are scheduled for this site
Internal
AuditReview
Purpose Commencement On-going requirement
Site HSE Mobilisation Audit
Review achievement towards site start-up activities
8 weeks after mobilisation NA
Internal HSEQ audit
Determine compliance to the management systems and an assessment as the effectiveness of those requirements to meet our legal and other obligations
Within 6 months of project start up
6 monthly
Sydney Metro (or an independent environmental auditor) Audit
EampSMS and compliance with the environmental aspects of contract documentation including Construction Environmental Management Framework
Construction Periodic
to be confirmed
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The Project Environmental Site Representative will be the principal contact for external auditors wishing to audit
the Sitersquos environmental management systems The Project Environmental Site Representative will be responsible
for responding to any external audits findings
Monitoring
Environment monitoring will be undertaken to validate the impacts predicted for the Project The monitoring
requirements for required aspects are included in the relevant environmental management sub-plans (Appendices)
All environmental monitoring equipment shall be maintained and calibrated according to manufacturerrsquos
specifications and appropriate records kept
Where monitoring results are outside of the expected range and are directly attributable to the Project (ie are
influenced by factors under the direct control of the Project eg noise from construction equipment) the process
described below will occur
An analysis of the results by the Environmental Site Representative in more detail with a view of determining possible causes for the non-conformance
A site inspection by the Environmental Site Representative or delegate Advising relevant personnel of the problem Identifying and agreeing on actions to resolve or mitigate the non-conformance Implementing actions to rectify or mitigate the non-conformance
Corrective Actions
Corrective actions identified through hazards inspections incidents auditing will be recorded in Beakon Close out of corrective actions are monitored through Site meetings and reported to senior management through the monthly and quarterly board reports
16 DOCUMENT AND RECORD CONTROL
Georgioursquos Health Safety and Environment Policies Standards Procedures Safe Work Instructions References
Guidelines Forms Templates are all accessible via the Companyrsquos Intranet - GENIE GENIE will maintain the
current and only authorised versions for use
Environment Management documentation that has been specifically developed for the site will be controlled on site
and recorded on the Site Document Register in accordance with the Site Quality Management Plan
The Project Manager is the owner of this plan and will apply change control to ensure the most recent plans are
approved and executed
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
17 APPENDICES
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Appendix 1 - Waste Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise spoil generation where possible The project will mandate 100 reuse or recycling (on or off-site) of usable spoil Spoil will be managed with consideration to minimising adverse traffic and transport related issues Spoil will be managed to avoid contamination of land or water Spoil will be managed with consideration of the impacts on residents and other sensitive receivers Site contamination will be effectively managed to limit the potential risk to human health and the environment Minimise waste throughout the project life-cycle Avoidance of unnecessary resource consumption Resource recovery (including reuse reprocessing recycling and energy recovery) and Disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Project Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Training and Competency
As part of the Site Induction workers will be informed of
- The types of waste generated on site
- How the wastes are to be handled stored and disposed of Personnel responsible for clean-up of spills will be provided with instruction on how to use the sites
spill kits Personnel handling hazardous materials will be provided training to read and understand the SDS
Project Manager
Unidentified Waste Wastes that cannot be positively identified (ie unlabelled liquids potential asbestos) will be tested
before handling and disposal Any material that is unknown should be considered hazardous until positively identified
Project Engineer
Handling
Where practicable dust generating rubbish and debris will be removed to minimise dust release into the atmosphere
Handling of waste will be done in accordance with relevant state or local by-laws using suitable personal protective equipment
Project Engineer
Storage
Containers used for storage are not to be opened handled transported or stored in a manner that may rupture the container
All waste will be stored in waste receptacles and removed off site by a licensed contractor on a periodic basis
Dedicated recyclable and hazardous receptacles will be labelled Wastes stored on site will be stored in a manner to prevent the attraction of vermin and native
wildlife Waste is to be stored away from access and egress routes
All
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Appendix 1 - Waste Management Sub Plan Responsibility
The quantity and volume of wastes stored on site may be minimised where reasonably practical to reduce the risk to health safety and the Environment
Project Managers will be responsible for identifying and obtaining any required licenses andor permits to store wastes
Disposal
In deciding how to dispose of waste generated on site consideration will be given to reducing reusing or recycling waste where reasonably practical to minimize the volume sent to landfill Where reuse or recycling is not a feasible option the waste will be sent to a facility capable of accepting the waste
The burning of any type of wastes will not be permitted on any Georgiou site The use of stormwater drains for the disposal of waste is prohibited The disposal of waste will be done in a manner to prevent any damage to the environment
Project Engineer
Transportation
The removal and transportation of hazardous waste controlled waste (eg asbestos hydrocarbons and sewage) for disposal will only be conducted by licensed carriers Licensed operators will be engaged in accordance with the Procurement Procedure
Before a hazardous waste controlled waste is transported off site a waste tracking receipt will be collected from the operator as verification that the waste was correctly transported off site and to identify the proposed location for disposal The receipt will be scanned and filed into the DMS and linked to the Site Waste Register A copy of the receipt will be held for a minimum of 3 years
The transportation of other wastes for disposal will only be conducted if the load is covered or there is no risk of loaddebris falling and the load is disposed of at a registered landfill
Project Manager
Spoil
Although the Project would require the importation of fill material the excess spoil would be generated including from the following sources
Soils ndash This includes any topsoil and natural subsoils (ie soils between the topsoil and underlying bedrock)
Natural rock ndash This material would be generated from excavation of sandstone bed rock if required Road construction material ndash This would include material generated from the demolition of the
existing roads such as asphalt concrete geotechnically stabilised road sub-base and base material
Project Engineer
Spoil Classification
Spoil generated during the Construction of the Project will be firstly assessed for reuse in the project Should it not be suitable for onsite reuse it will be assessed in accordance with the Sydney Metro Classification Procedure (Appendix 1A) It will firstly be assessed against the requirements for Virgin Excavated Natural Material (VENM) detailed within the Protection of the Environment Operations Act 1997(POEO Act)
Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
If the material is not deemed to be VENM an assessment of the suitability of any current general resource recovery exemptions issued under the Protection of the Environment Operations (Waste) Regulation 2014 will be undertaken Current general resource recovery exemptions that may apply to the Project are
The excavated natural material exemption 2014 The excavated public road material exemption 2014 Spoil that cannot be re-used onsite or offsite under any of the exemptions stated above or classified as VENM will require waste classification in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (EPA 2014) prior to offsite disposal at an appropriately licensed facility
The management of spoil generated from the Project will be guided by the hierarchy detailed below
Rank Control Measure Implementation Example Potential to implement on Project
1 Avoid and reduce spoil
generation Reduce the amount of spoil being
generated through design and construction methodology
Limited
2 Prioritise reuse of contaminated
spoil onsite vs clean spoil Identify areas with lower risk of
contamination to spoil offsite as this will result in lower waste disposal costs for project
GSW and Contaminated Spoil is to
be utilised as fill on the project
prior to the use of excavated
sandstoneVENM The project will
produce excess spoil and the
priority is for this excess to be
sandstoneVENM
3 Reuse within Project Prioritise reuse of more contaminated
spoil onsite vs less contaminated spoil Reuse in the Project to fill
embankments and mounds within short haulage distance of source
Restoration of any pre-existing contaminated sites within the Project boundaries
Reuse as a feed product in Construction materials (eg concrete)
Preferred but dependant on area
available
Project Manager Project Engineer Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
4 Reuse for environmental works Reuse in revegetation and
rehabilitation projects Reuse in operational noise mitigation
works
Preferred as stockpiling on site is
restricted
5 Reuse on other development
projects Reuse for fill embankments and
mounds on projects within an economic transport distance from site
Preferred as stockpiling on site is
restricted
6 Reuse for land restoration Reuse for land reclamation or
remediation works Reuse to fill disused facilities eg
mines and quarries to enable ecological rehabilitation or other ecologically beneficial end use
Preferred as stockpiling on site is
restricted
7 Reuse for landfill management Reuse to cap completed landfill cells Reuse in daily covering of landfill
waste
Limited
8 Dispose offsite as waste Disposal of excess spoil as waste at an
approved facility licensed to receive that material
Potential but not preferred
Hazardous Waste - General
Hazardous wastes will be stored in sealed containers where practical and clearly labelled with waste type
Hazardous waste receptacles will be maintained in good condition to prevent leaks or spills Offensive odours should not be generated at any time when stored Hazardous wastes with a significant risk to human health and safety will be stored in containers that
comply with relevant legislation and guidelines Hazardous wastes will not be permitted to accumulate to a level that presents an unreasonable risk
to human health safety or the environment Controlled waste storage will be suitably contained to ensure debris does not travel beyond the boundary of the premise
Hazardous waste will be stored and segregated in accordance with their SDS Hazardous waste will be risk assessed to ensure they do not contaminate or interact with goods that are incompatible Where there may be a risk of fire hazardous waste will be segregated to prevent storage incompatibilities
Hazardous liquid waste will not be permitted to enter the environment
All
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Appendix 1 - Waste Management Sub Plan Responsibility
Design considerations for secondary containment will be given to the storage of liquid wastes to contain any potential spills Hazardous waste will be stored onin bunded palletsareas which will be compliant with AS1940-2004 443 (the bunded palletarea must have the capacity to contain 110 of the largest container
Hazardous waste such as batteries hydrocarbons sewage and asbestos will only be handled for final disposal recycling by certified waste removing contractors Sewage waste not plumbed directly into the main sewerage system will be contained within holding tanks on site compounds and emptied on a periodic basis or as required by a licenced contractor
Hazardous Waste - Batteries
Automotive and lead-based batteries will be stored in a manner that does not contaminate the natural surrounding environment This may include storage on bunded palletsareas on concrete hard stand or on any other sealed surface
All
Hazardous Waste - Asbestos
The disposal processes for asbestos will involve independent competent persons Identified ACM (Asbestos Contaminated Material) will be clearly marked out and controls put in place
to prevent contamination into surrounding areas
Project Manager
Hazardous Waste - Sanitary Sewage Waste
Sewage waste will either be plumbed directly into the main sewerage system or contained within holding tanks on site compounds and emptied as required
Sewage waste stored in bunded tanks underneath the toilets will be emptied by a licensed contractor on a periodic basis
Sanitary wastes will be stored in solid containers and clearly labelled for identification Sanitary wastes will not be re-handled after disposal to minimise the exposure and risk of double
handling Sanitary conveniences will be calculated based on the number of workers based on the site and meet
legislative requirements Sanitary waste will be stored away from food sources or where food is served Controls to prevent offensive odours to the public and workers will be implemented
Project Engineer
Recyclable Waste
On site paper and cardboard and scrap metal will be segregated to be collected and transported to a recycling facility
Green waste will be mulched and stockpiled with topsoil for use in revegetation Aggregate will be segregated during cut and fill operations for re-use
Project Engineer
Waste Water Any waste water or liquids must be disposed of to an approved receptacle and stored within an approved bunded location until they are removed from site
Project Engineer
Putrescible Waste Putrescibles waste will be stored into general waste containers that prevent the release of debris and leachate
Project Engineer
Clinical Waste In the event that clinical waste has been found the following control may be employed Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
Syringes and needles found on site will be stored in a clearly labelled solid sealed container to prevent access to contents They will be disposed of at a licenced provider
Clinical wastes will not be re-handled after disposal to minimise the exposure and risk of double handling
Concrete
Kibbles Concrete truck are to be washed out into a designated bunded area When the concrete is dried it will be disposed of with general waste
At no point will any Concrete truck or kibble be permitted to wash out at any point other than the designated area with all the associated controls in place
Project Engineer
Weekly (VisualDocumented)
DHI Environment to be completed via Beakon HSE Advisor
Reporting HSEQ Monthly Management Meeting Monitor and record the volumes of waste and the methods and locations of disposal Maintain records of all required waste dockets and receipts and provide to Sydney Metro monthly
Project Manager
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Appendix 1A ndash Sydney Metro Waste Classification Procedure
Unclassified
Unclassified
Waste Classification Procedure
SM-20-00040677
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Hugh Chapman Associate Director Environment Operations Customer amp Place-Making
System Owner Carolyn Riley Director Environment Sustainability amp Planning
Status Final
Version 30
Date of issue Pending
Review date Pending
copy Sydney Metro 2020
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 2 of 14
SM-20-00040677 Waste Classification Procedure V30
Table of contents
1 Introduction 3
11 Purpose and scope 3
12 Definitions 3
13 Spoil Management Decision Framework 5
14 Spoil Handling and Segregation 5
15 Typical Application of the Framework 6
16 Unexpected Finds Protocol 7
17 Accountabilities 14
2 Related documents and references 14
3 Superseded documents 14
4 Document history 14
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
1 Introduction
11 Purpose and scope
This framework describes the approach to classifying spoil and demolition materials generated during works in accordance with environmental legislation and guidelines
This framework considers the reuse of materials on site the beneficial reuse of materials transported off site as waste (for example as virgin excavated natural material [VENM]) the recycling of materials at offsite facilities and the offsite disposal of materials when reuserecycling is not achievable
The framework considers only the compliance and classification elements of the spoil management process and does not consider all of the practical issues associated with construction geotechnical properties of the spoil or market forces and costs that influence the reuse potential of spoil or other wastes
Section 16 of this framework outlines an Unexpected Find Protocol (UFP) to be implemented should unexpected potential contamination be found during works
12 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined within the SM-17-00000203 Sydney Metro glossary Acronyms specific to this document are listed below
Definitions
2014 Waste Regulation
Protection of the Environment Operations (Waste) Regulation 2014
CLM Act Contaminated Land Management Act 1997
Contamination
As defined in the CLM Act ldquomeans the presence in on or under the land of a substance at a concentration above the concentration at which the substance is normally presenthellipin the same localityhellipthat presents a risk of harm to human health or any other aspect of the environmentrdquo
Demolition materials
Materials such as concrete bricks and timber resulting from the demolition of buildings and structures Most demolition materials are pre-classified as General Solid Waste (non-putrescible) (see definition below) under the NSW EPA (2014) Waste Classification Guidelines However some demolition materials such as asbestos have other classifications as described below
EIS Environmental Impact Statement for the project which assesses potential environmental impacts and mitigation measures in accordance with the EPampA Act (see below)
ENM Excavated Natural Material as defined in The excavated natural material order 2014
being excavated material that is at least 98 (by weight) natural material that does not meet the definition of VENM (see below)
EPA NSW Environment Protection Authority
EPampA Act Environmental Planning amp Assessment Act 1979
EPL
Environment Protection Licence as may be held by an owner or operator of a premise licensed to receive process recover or store waste The EPL will contain a number of conditions that must be met by the holder These will specify the type(s) of waste the facility is permitted to receive process recover or store and include pollution prevention or monitoring requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Definitions
Fill Soil and any associated extraneous materials (such as demolition wastes industrial by-products and refuse) imported to and placed at the location
GSW
General Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines GSW may be classified as putrescible or non-putrescible depending on the content of putrescible organic material Spoil and demolition materials are typically non-putrescible
HW
Hazardous Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines HW must be treated prior to disposal to landfill HW is typically
spoil that is contaminated with chemicals at concentrations that exceed all screening criteria specified in Step 5 of the Waste Classification Guidelines
Naturally Occurring Soil
Any soil which has not been significantly disturbed by human activities
NEPM National Environmental Protection (Assessment of Site Contamination) Measure 2013
POEO Act Protection of the Environment Operations Act 1997
Recycling Material that is removed from the project site (thereby becoming Waste) and is deposited at an appropriately licenced recycling facility for processing prior to reuse by others
REF Review of Environment Factors which addresses the likely environmental impacts and details protective measures to manage against any adverse effects in accordance with the EPampA Act
Remediation
As defined in the CLM Act remediation of contaminated land includes
(a) preparing a long-term management plan (if any) for the land and
(b) removing dispersing destroying reducing mitigating or containing the contamination of the land and
(c) eliminating or reducing any hazard arising from the contamination of the land (including by preventing the entry of persons or animals on the land)rdquo
Remediation is the act of mitigating exposure to contamination in its original location The process of remediation can generate spoil that may be subject to reuse within the project area (where that reuse is adequately controlled in order to mitigate exposure risks) or the removal of contaminated spoil for treatment andor disposal off site
Reuse offsite
Material to be reused by application to land at a location outside of the project site without the need for processing prior to reuse Material meeting the definition of VENM or ENM or material that is subject to an RRO and RRO are suitable (from an environmental perspective) for reuse at remote sites where all requirements of the POEO Act and CLM Act are met
Reuse onsite
Material that is excavated on the project site and reused on the project site Material to be reused onsite is not defined as Waste and does not require classification in accordance with NSW EPA (2014) Waste Classification Guidelines The material must be suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and must not cause pollution under the POEO Act If transport to another part of the project area requires material to be taken outside the site boundary temporarily this must be undertaken in accordance with the EIS or following consultation with relevant regulators
RRE Resource Recovery Exemption contains the conditions that must be met by consumers of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RRO Resource Recovery Order contains the conditions that must be met by generators and processors of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RSW Restricted Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines An example of RSW is spoil that is contaminated with chemicals above the criteria specified in Step 5 of the Waste Classification Guidelines
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Definitions
Special Waste
As defined in the NSW EPA (2014) Waste Classification Guidelines a class of waste with
unique regulatory requirements Asbestos or any waste containing asbestos (eg spoil containing any fragments of asbestos cement sheeting) is Special Waste If Special Waste is mixed with RSW or HW (eg spoil classified as RSW that also contains asbestos) then the waste must be managed in accordance with both classifications
Spoil Soil or rock material generated from excavation activities
UFP Unexpected Find Protocol
VENM Virgin Excavated Natural Material as defined in Schedule 1 of the POEO Act being excavated natural material not mixed with any other waste and not from a contaminated area
WARR Act Waste Avoidance and Resource Recovery Act 2001
Waste Spoil or demolition material that has been taken off site which may be classified as Special Waste GSW RSW or HW
13 Spoil Management Decision Framework
Figure 1 provides a high-level flowchart for decisions regarding the fate of spoil generated on the site As reflected in Figure 1 the preferred spoil management hierarchy for the project listed from most preferred to least preferred is as follows
1 Spoil is reused within the project boundary
2 Spoil is beneficially reused at an appropriate offsite location
3 Spoil is recycled at an offsite licenced facility
4 Spoil is disposed to landfill
The approach to spoil classification is further detailed in Table 1 Table 1 describes the criteria information inputs and control measures required to be applied when reusing spoil on site reusing spoil offsite recycling spoil offsite or disposing of spoil
The framework does not account for the practical site based engineering or financial constraints associated with the hierarchy These must be addressed during delivery and the most appropriate efficient and sustainable method of spoil management adopted
14 Spoil Handling and Segregation
Careful excavation handling and segregation of spoil is critical to ensuring that materials with varying classifications are not mixed (cross-contaminated) and are not reused recycled or disposed in a manner inconsistent with their classifications
Appropriate segregation is also important in controlling the costs of spoil disposal to landfill noting that the inadvertent mixing of materials with low concentrations of contaminants with materials containing higher concentrations typically results in a higher classification and higher disposal rate (financial) being applied to all of the materials
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
The following processes are to be applied when excavating handling and segregating all spoil (for clarity a reference to a ldquogeological unitrdquo includes units or different layerstypes of Fill)
Spoil from each geological unit should be classified separately using sampling data that relates only to that unit Classification sampling may be performed in-situ (prior to excavation) or ex-situ (following excavation)
Spoil from each geological unit (as described in Part 4 below) should be excavated segregated and stored separately from spoil arising from other geological units
Excavations should be carefully monitored for visual indications of contamination such as stained soils odorous soils or the presence of anthropogenic waste materials Any spoil containing visual indicators of contamination will be excavated segregated and stored separately from other spoil Where unexpected contamination is identified an appropriate unexpected finds procedure must be implemented to manage potential human health or environmental risk (refer to Part 5)
Each spoil stockpile should be treated as a ldquobatchrdquo with its classification data clearly identifiable and will be handled stored transported and reusedrecycleddisposed as a batch Spoil stockpiles will not be managed in a ldquocontinuousrdquo manner with portions added taken away or mixed over a period of time and
Spoil should be tracked from cradle to grave to ensure a complete and accurate record of movement from the point of excavation to the final point of placement For clarity this includes tracking of spoil movement on the site as well as off the site
Tracking of spoil movement (whether the spoil is waste or not) requires must include written records of spoil excavation handling transport storage and placement via a centralised tracking system Personnel must be suitably trained in the use of the system and sufficient detail must be recorded and retained such that material typesclassifications volumes and location are tracked from the time the material is excavated until it is placed permanently (onsite or offsite) This includes accurate records of any interim handling or placement (such as stockpiling or treatment) Stockpiles onsite are to be clearly labelled at all times Tracking information is to be kept on-site and be available on request
15 Typical Application of the Framework
This section provides some practical guidance in implementing the spoil classification framework (further detailed in the attached Figure 1 and Table 1
An explanation of the likely classification of spoil excavated during works based on typical geological units is provided below
Fill ndash Fill is imported materials which have been placed on the site at some time in the past Fill generally exists at depths ranging up to 3m below ground surface on developed areas and brownfield sites Fill may exist to depths exceeding 20m in reclaimed lands landfill sites former brick pits footings and similar Fill cannot be classified as VENM Fill has an increased likelihood of being contaminated (compared to natural soils) and will predominantly be classifiable for offsite disposal as GSW Special Waste RSW or HW Some materials such as road base or crushed concrete may be recoverable under generic or specific RRERRO arrangements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Naturally Occuring Soils ndash Soil which has not been significantly disturbed by human activities Naturally occurring soils may be residual soil sediments aeolian or other In the majority of cases naturally occurring soils will be classifiable as VENM or ENM for offsite reuse However where overlying contamination in Fill has leached and caused contamination of underlying natural soils where point sources of contamination are present (such as industrial facilities or fuel storage facilities) or where significant groundwater contamination has migrated into the area offsite reuse may not be appropriate and other classifications such as GSW RSW or HW may be applicable Where evidence of potential contamination exists spoil is required to be sampled and classified in accordance with NSW EPA (2014) Waste Classification Guidelines
Rock ndash Rock in-situ will in the majority of scenarios be classifiable as VENM or ENM unless significant contamination is present in overlying soils or significant contamination has migrated to the rock within groundwater Where the excavation of rock involves the use of additives (for example to facilitate tunnel boring) the material would no longer be classifiable as VENM or ENM and would instead likely be classifiable as GSW A project specific RRERRO would then be required to allow for offsite reuse
The type of material (ie geological unit) excavated during works will provide guidance on implementing the spoil classification framework in regard to reuse opportunities
Reuse Onsite ndash Any of the material excavated which is Fill a Natural Occurring Soil or Rock may be suitable for reuse on the project site Wherever reuse onsite is to occur the material does not require classification in accordance with the NSW EPA (2014) Waste Classification Guidelines Instead the material must be validated as being suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and the material must not cause pollution under the POEO Act For clarity the classifications GSW RSW and HW have no direct relationship to the potential for reuse of materials on the project site
Reuse Offsite ndash With the exception of Fill it is likely that the majority of spoil will be suitable from an environmental perspective for reuse off-site Specifically all VENM ENM and material to which an RRERRO apply will be suitable (from a legislative and environmental perspective) for reuse at an offsite location
16 Unexpected Finds Protocol
This section provides guidance on implementing the Unexpected Finds Protocol (UFP) which is detailed in the attached Figure 2 The purpose of the UFP is to provide a clear procedure in the event of an unexpected find of contamination or potential contamination The UFP is only to be implemented following an unexpected find The handling of known contamination should already be addressed in construction and environmental management plans
Key indicators of potential contamination include (but are not limited to)
Fibrous cement or other asbestos containing materials
Discolouration of soil
Odours from soil andor groundwater
Buried drums or underground storage tanks and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Oily sheen on water
Should any of the above be discovered and is considered to be unexpected then the UFP in Figure 2 will need to be implemented
An explanation of key actions within the UFP is provided below
Notifying the Site Supervisor ndash Site Supervisor or an appropriate delegate are to be made aware of the find immediately
Securing the affected area ndash This includes restricting access to the area and implementing appropriate environmental controls around affected area in minimise risk to the environment and human health Examples of controls include barricading the affected area the diversion of water to minimise potential spread via surface water runoff covering the area re-burying andor wet-down Environmental controls are to be implemented appropriately in regard to the contamination source and site conditions
Emergency Response ndash In the event that the find presents andor creates health or environmental concerns which would require an emergency response call 000 andor implement the projects incident response and reporting process
Notify Principal or Sydney Metro ndash The Principalrsquos Representative and the Environmental Representative must be notified of the unexpected find
Recommence works ndash Works can be recommenced in an alternate area where practicable and where it is safe to do so
Assessment ndash The potential for any ongoing risk to the environment or human health during construction or operation of the site and whether or not the agreed scope appropriately manages the contamination will need to be assessed by a competent and qualified person (ie a contaminated land specialist or in the case of asbestos a hygienist or asbestos assessor)
Material Classification ndash Contaminated materials which are to be removed from the site are to be classified in accordance with the NSW EPA Waste Classification Guidelines and the Spoil Classification Framework detailed in this document See Figure 1 and Table 1
An unexpected find may result in additional works being required for the remediation of contaminated materials which fall outside of the current scope of the project Any such works will need to comply will all relevant legislation and guidelines and will require appropriately qualified persons to prepare the methodology and controls Any such works will require approval from Sydney Metro
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Spoil classification process flow
Syd
ne
y M
etr
oN
SW
EP
A W
aste
Gu
ide
line
s C
lassific
ation
ndash P
art
1 (
20
14)
Syd
ne
y M
etr
o
Additional inputs or information requirementsProcess
Is there an opportunity to re-use the spoil
on site
Is there an opportunity to use the spoil at
an offsite locat ion
Can the spoil be recycled
The spoil must be classif ied in accordance with the NSW Environmental Protection Authority (EPA) Waste Classification
Guidelines
1) Is the waste Special Waste ie does the waste contain asbestos Refer to the Protection of the Environment Operations
(POEO) Act and Waste Regulation Part 4 Management of Special Waste
2) Is the waste Liquid Waste
3) Is the waste pre-classified
4) Does the waste have hazardous
characteristics
5) Classify by chemical assessment Waste generators must chemically assess their waste in accordance with Step 5 of the Waste
Classification Guidelines to determine the waste s classification where it has not been classified under Steps 1 to 4 of the Guidelines
Re-use onsite Cost time and engineering requirements to be
considered as well as environmental risks before placement
Re-use offsite To allow offsite use the material mist be classifiable
VENM ENM or be subject to Resource Recovery Exemption and Order
No matter the classification the offsite location must conf irm it can legally
accept the spoil
Recycle offsite The spoil must go to a licenced treatment facility and
must meet the specific requirements of that facilities licence
Liquid waste The waste is not spadable andor becomes free-flowing
at or below 60 degrees Celsius or when it is transported
Pre-classified waste Refer to NSW EPA Waste Classif ication guidelines
for pre-classificat ions of Hazardous Wastes General Solid Waste
Dangerous goods Meets Dangerous Goods Classificat ion for classes 1
2 41 42 43 5 61 and 8
The waste has been classified in accordance with the Waste Guidelines and is ready to be transported offsite Prior to transport
the following must be confirmed and all relevant requirements met
Is the landfill or facility licenced to accept the type of waste
Is the waste subject to waste tracking requirements under the POEO Act or any other regulation
Is the transport contractor licenced to carry the waste as classified
6) Is the waste putrescible
Sampling under Step 5 must meet the requirements of the NSW Waste Classification Guidelines
Sampling can be in-situ (ie prior to excavat ion) or ex-situ (from stockpiles after excavation) but in both
scenarios
Sampling density is to as a minimum meet the sampling densities recommended in the Victorian
EPA soil sampling guidance
httpsrefepavicgovau~mediaPublicationsIWRG702pdf
Analytes must reflect the contaminants of concern likely to be present at the site and as a
minimum consider Asbestos Metals TPH BTEX PAHs and PFAS Other side specific
contaminants may include hexavalent chromium PCBs pesticides etc
If retained onsite the Waste Classif ications Guidelines do not apply BUT the material must be suitable
from a human health and environment perspective to remain This requires assessment against the
NEPM and may include visual inspections or sampling and analysis The input of an appropriately
qualified professional is required prior to the re-use of any fill or potentially contaminated spoil
Once the spoil is removed from the site it becomes Waste All waste must be transported to a facility
that is licenced to accept it VENM ENM andor Resource Recovery ExemptionsOrders impart specific
requirements regarding assessment sampling analysis classificat ion and use of these types of spoil
The requirements regarding sampling and record retention must be adhered to
Once spoil is removed from the site it becomes Waste All Waste must be classified in accordance with
the NSW EPA Waste Classification Guidelines and be transported to a facility licenced to accept it
Note that whether or not the asbestos is present further classif ication is required under Steps 2 to 6 of
the EPA Waste Classification Guidelines
Yes or No
General solid waste restricted waste or hazardous waste
No
Yes
Yes
Yes
Yes or No
Yes
Yes
Yes
No
No
No
No
No
Figure 1 Spoil Classification process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 10 of 14
SM-20-00040677 Waste Classification Procedure V30
Table 1 Spoil Classification process flow
Decision Criteria InputsData ControlsReview
Reuse of the material on or within the approved project area
Most preferred option under WARR Act and Sydney Metro environment and sustainability policy
Suitable placement locations have been identified
The material is suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and will not cause pollution under the POEO Act
The spoil meets engineering requirements for placement locations
Where spoil or demolition materials require treatment or processing onsite to treat contaminants or to amend engineering properties the need for an EPL must be assessed and resulting conditions met
If transport to another project area is required and such transport requires material to be taken outside the site boundary temporarily this will need to be appropriately address in the projectrsquos environmental approvals (eg EIS or REF)
Appropriate risk-based assessment confirms the material is suitable for proposed final land use from a contamination perspective
Appropriate geotechnical assessment confirms the material is suitable for proposed final land use
EPL if required for onsite processing
Complete material tracking record including documentation of final placement location
Environmental controls to prevent cross-contamination of material prior to placement and pollution during placement
Training of relevant personnel in spoil reuse framework and underlying management plans
Audits of sampling data tracking and placement information and reuse locationssites
Long-term management plan and monitoring andor Environmental Protection Licence under the POEO Act (if required)
Reuse of the material off site
Spoil becomes waste under POEO Act once removed from site
Material meets VENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Assessment confirms material is VENM Sampling may be required depending on nature of material and source
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 11 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Material meets ENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Sampling conducted in accordance with ENM RRO prior to transport off site and results meet criteria
Statement of RRO compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
RRO records maintained for six years including details of sampling plan sampling results quantities supplied and receival sites
Material does not meet VENM or ENM definitions but has potential for reuse under a specific RRORRE An example is tunnel spoil containing additives
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Consult with the EPA prepare and submit application for specific RRORRE Characterisation data will be required for the application
Once specific RRORRE is granted obtain sampling data (and meet any other specific obligations) in accordance with conditions and confirm results meet criteria prior to transport off site
Statement of compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
As for reuse on site plus
Statement of compliance provided to each receival site
RRO records maintained for six years
Recycling off site
Material (spoil and demolition materials) becomes waste under POEO Act once removed from site
Material meets the EPL andor planning approval requirements for the receival facility and has value for recycling
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Assessmentsampling confirms the material meets the receival facility EPL conditions (typically GSW)
Appropriate EPL held by receival facility
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 12 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Disposal off site
Material does not fit one of the above categories andor suitable reuse or recycling locations could not be identified
Least preferred option
Waste is classified as GSW RSW or Special Waste
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by receival facilities
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Waste is classified as HW
Suitable treatment facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by treatment facilities
Treatment facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking treatment and disposal documentation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 13 of 14
SM-20-00040677 Waste Classification Procedure V30
Unexpected find process flow
Flo
w
Process Additional information
Unexpected potential
contamination find1 Immediate ly stop works
2 Notify the Site supervisor 3 Secure the affected area
Is an emergency
response required for any
health or environment
concerns
4b Notify Principal s Rep and
Environmenta l Rep
4a Trigger pro ject incident response and
reporting mechanism andor call 000
5b Inform the
Principal s Rep
Does the
contamination
present and ongoing risk to
environment or human
health dur ing
construction or
operation
Will the
agreed scope result in the
complete removal of the
contamination
Does the
disposal of the unexpected
find result in addi tional costs
to the Principa l
5a Materials to be classified in
accordance with the NSW EPA Waste
Classification Guidel ines (2014) (see
Figure 1 Spoil classification flow)
6a Inform the
Principal s Rep
6b Dispose of the material in
accordance with all relevant legislation
the project Spoil Classification amp
Management Framework and any
relevant directions from Sydney Metro
6c Develop
appropriate
methodology
plans to
manage the
contamination
and implement
Indicators of potentia l
contamination include
Fibre cement or other asbestos
containing materials
Discolouration of the so il
including staining andor
discolouration
Odours from soil or
groundwaterseepage
Bur ied drums and storage tanks
Oily sheen on water
Note this does not include on-
site contamination
Securing of the area should restrict
access to the affected area This
should include as a min imum
environmenta l controls around the
affected area to contain
contaminated material including
diversion of water to minimise
potential spread via surface water
runoff
Where contaminants are likely to
result in odours vapours or
airborne asbestos fibres immediate
action should be taken to prevent
their release (eg cover re-bury or
wet-down
Recommence works in alternate
area where practicable and safe
Assessment to be conducted by
suitably qualified and experienced
person
Methodology controls and p lans
are to be prepared by a sui tab ly
qualified and experienced person
and approved by Sydney Metro
prior to being actioned
Works may continue in the affected
area when it is safe and where
works will not exacerbate
contamination or hinder future
remediation works
Note Remediation of contaminated
materials may include (but not be
limited to) capping of
contaminating treatment andor off-
site disposal All associated
activities with the remediation of
contaminated materials such as
excavation handling stockpiling
and transport are to be addressed
an prepared methodology and
controls
Yes
No
Yes or unsure
No
No or unsure
Yes
Yes
No
Figure 2 Unexpected find process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 14 of 14
SM-20-00040677 Waste Classification Procedure V30
17 Accountabilities
The Director Program Sustainability Environment amp Planning is accountable for this document including approving the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document
2 Related documents and references
3 Superseded documents
4 Document history
Related documents and references
Entries should be formatted with IMSiCentral number followed by correct title and hyperlinked eg
SM-17-00000203 Sydney Metro glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
02 Pending New IMS document
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise pollution of surface water through appropriate erosion and sediment control Minimise leaks and spills from construction activities Maintain existing water quality of surrounding surface watercourses Source construction water from non-potable sources where feasible and reasonable
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp Targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Erosion and sediment measures would be implemented in accordance with the principles and
requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any significant water aspects and Site specific controls to minimise potential impacts
Emergency Management Team members will be provided training to respond to a discharge of contaminated water or hazardous substances into the environment
Project Manager
Notification The Site will not modify or remove any water utility assets without their approval Notification
of approval will be received by Sydney Water with a copy of authorisation Notification to the asset owner will be given as per their conditions of compliance
Project Engineer
ESCP
ESCPrsquos will be developed by construction staff with demonstrated skills and experience in preparing the ESCP in accordance with the Blue Book Guidelines ESCPrsquos plans will include but not be limited to
Title date and revision number Contours and clean and dirty water drainage paths Site layout including the location of access roads ancillary infrastructure Sediment basins and designated pump out locations Limit of disturbance Location and type of control measures Timing and order of control installation in sequence with work activities Specific construction details
Environmental Site Representative
Erosion and sediment control
The following key principals will apply to all areas and stages of construction on the Project
Minimise extent and duration of disturbance Control stormwater flows onto through and from the site
Project Engineer Supervisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Erosion control strategies to prevent on-site damage Sediment control strategies to prevent off-site damage Progressive stabilisation following completion of work areas Inspection Maintenance and Improvement of control measures throughout the site construction
until the site is successfully stabilised
Dewatering
Sediment laden water accumulated in trenches or excavations must not be discharged directly or indirectly to any stormwater natural watercourse or offsite
A suitable location to discharge will be identified considering site slope proximity to drainage lines soil permeability and ground cover ie well established existing vegetation
The water must be tested prior to any discharge by the Environmental Site Representative and may require treatment prior to discharge
Project Engineer Environmental Site Representative
Groundwater
Groundwater is unlikely to be intercepted during any excavation within the road footprint Deeper excavations for stormwater trenching may intercept groundwater however a method of pipe installation during low tide will removed the need for dewatering
If groundwater dewatering is required then a dewatering management plan should be developed
PlantVehicle Maintenance
The maintenance and cleaning of any vehicles plant or equipment must not be carried out in areas from which contaminants can be released into stormwater or natural watercourses
All
Acid Sulfate Soils
Prior to excavation for the Stormwater trench which will occur approximately 25m bgs testing would be carried out to determine the presence of actual andor potential acid sulfate soils
Testing for the presence of ASS shall be undertaken at proposed excavation locations and shall apply the following methodology Dig holes to the proposed depth of excavation conduct ASS pH field tests on material from the hole at 05m depth intervals and then conduct a SPOCAS plus or chromium suites on the most acidic ASS pH field test sample from the hole The testing and sampling to be undertaken in accordance with ASSMAC Laboratory method Guideline Aug 1998
If actual andor potential acid sulfate soils are present within the proposed area of excavation then an Acid Sulfate Management Plan will be developed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Project Engineer Environmental Site Representative
Water Discharge requirements
An Environmental Protection Licence (EPL) is not required for the project however Georgiou will test any water to be discharged offsite in accordance with the water quality parameters specified in the Blue Book (Landcom 2004) and ANZECCARMCANZ (2000) guidelines prior to discharge to ensure an incident of pollution to surrounding environment does not occur from the Project
Environmental Site Representative
Monitoring of Discharges
Waters released from site must be sampled prior to release The samples taken must be representative of the water being discharged
Project Engineer HSE Advisor
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Environmental Inspections amp Monitoring
The results of monitoring shall be recorded Environmental Site Representative
Daily (Visual) and weekly (documented)
Daily visual observation for evidence of water quality impacts including turbidity or hydrocarbon spills
Weekly inspections using Georgiou Beakon inspection form
Supervisor HSE Advisor
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report Dewatering records including all water quality test results
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Objectives and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise leaks and spills from construction activities All chemicals correctly stored and bunded in accordance with legislative requirements Any spills are controlled contained cleaned up and reported
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General All fuels chemicals and hazardous liquids would be stored in accordance with Australian
standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required to
manage hydrocarbon and chemical storage and use including
- Use and understanding of safety data sheets (SDS) - Use of personal protective equipment (PPE)
Emergency Management Team members will be provided training to respond to a hazardous substance spill
Project Manager
Register
All dangerous goods or hazardous substances must be approved by HSE Advisor prior to use on the site
ChemAlert will be used to register all site dangerous goods and hazardous substances manage electronic SDS and conduct and record product risk assessments
Consideration will be given to substitute products assessed as a high risk with a product of lesser risk
Project ManagerSupervisor
Transportation Containers holding hazardous substances or dangerous goods will be stored upright and secured
during transport Containers are not to be dropped tip or rolled sides The transportation of dangerous goods will be by licenced carriers
Project Engineer
Handling amp Use
Handling of products will be subject to the following requirements Hazardous substances and dangerous goods will be clearly labelled Current SDS (no older than 5 years) will be readily available when handling Controls stipulated in the SDS to be applied when handling and using Used oily rags oil filters and other left over hydrocarbon and chemical products hall be stored in
a designated area and removed by licensed carriers to either recycle or otherwise dispose of
All
Refuelling Refuelling of plant and vehicles must be monitored continually and conducted in designated areas
away from sensitive receptors
All in field refuelling must have a spill kits available to contain and clean up any spills
All
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Spill kits shall be stored in designated amp labelled containers and include a stock control register
All refuelling areas must be signed to prevent smoking or naked flame
Vehicles must be switched off when refuelling and the use of mobile phones prohibited
Fixed refuelling areas must have a plastic lined refuelling area
Fuel storage containers must be of a double bund construction
Site layout
Georgiou will develop a site plan (ie a diagram) showing the location of storage areas spill kit locations muster points firefighting equipment and 1st aid equipment including eye washflush locations
This site plan must be current and displayed at the work site at all times throughout construction
In the event of an emergency that involves the need for emergency services this site plan along with a product manifest must be provided to the emergency services
Project Manager
Storage of Hazardous Materials
Any Dangerous Goods andor Hazardous Substance must be stored in designated areas compliant
with statutory and industry codes of practice
Quantities of hazardous materials should be kept to a minimum commensurate with their usage
and shelf life
Safety Data Sheets of stored hazardous materials will be readily accessible at the place of
storagesite office
Permanent and temporary containers that hold hazardous materials must be labelled with the
appropriate signage
The volume and types of hazardous materials stored must be known current and documented and
must not exceed the design capacity of the storage area
Storage and containment areas (including secondary containment) must be inspected for signs of
loss or damage and any deficiencies must be addressed These areas must be inspected at least
monthly as part of the workplace inspection
Hazardous materials no longer in use must be identified and assessed to determine if they should
be removed from site
Hazardous materials storage areas must be kept clear of combustible material vegetation and refuse by a minimum of three metres
All
SpillEmergency Response
In the event of a spill the following generic procedure must be followed
1 Do not put yourself at risk 2 Notify personnel in the immediate area and remove yourself and others from danger 3 Report ALL SPILLS immediately to the Supervisor and Environmental Site Representative
(report location type and extent of incident)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Once safety has been considered spills should be contained and cleaned up with material from the spill kit All contaminated soil caused by leaks or spills to be disposed of in accordance with legal requirements Any uncontrolled release of hazardous substances which cause actual or threatens potential serious or material environmental harm will be reported to the EPA pollution hotline
Workplace Inspections
Hazardous Materials storage and use will be inspected monthly as part of workplace inspections amp within the DHI Environmental Inspections checklist
Supervisors
Concrete
Designated concrete washout should be constructed and designated to be impermeable and securely fastened
Placed away from waterways drainage lines and stormwater inlets Sufficient storage to handle concrete works occurring onsite When the concrete is dried it will be disposed of with general waste mixed into fill layers (if
approved by client) or recycled At no point will any Concrete truck or kibble be permitted to wash out at any point other than the
designated area with all the associated controls in place (unless approved by the environmental site representative)
Excess concrete should be scraped off equipment prior to washing (allow excess to set and recycle offsite or reuse in fill if itrsquos not contaminated with black plastic)
Set concrete should be removed from the washout to restore storage capacity and prevent overflows
Use of a high pressure low volume water spray nozzle may reduce water use All wastewater must be disposed of in accordance with the project CEMP dewatering conditions
Maintenance of the washout Monitoring and maintenance of concrete washouts is essential to ensure the washout is functional no evidence of damage or wear and tear is evident and that adequate storage capacity remains In addition to daily inspections washout areas should be inspected
During dry weather and
Prior to during and after rainfall and storm events
SupervisorEnvironmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for evidence of spills or poor storage practice with potential to lead environmental incident
Hazardous goods storage area inspection for adequacy of bunding and product loss Weekly inspections using Georgiou Beakon inspection form
All staff
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Objectives
and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on flora and fauna Retain and enhance existing flora and fauna habitat wherever possible Appropriately manage the spread of weeds and plant pathogens
Project Manager
Performance
Criteria
100 compliance with Client amp legal requirements
100 achievement with Site Objectives amp Targets
100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation
Measures
General Vehicles equipment plant materials and personnel are to remain within the designated construction
area at all times and not breach established environmentally sensitive exclusion zones All
Training and
Competency
As part of the Site Induction workers will be informed of the Site specific controls required to minimise potential impacts and protect flora and fauna including - the requirement to work within the designated disturbance zones - requirement to recognise protected flora or fauna species identified to be found on the site - tree protection zones - Specific licence conditions applicable to the Site
Project Manager
Fauna habitat
Prior to clearing pre-clearance surveys are to occur to identify individual trees to be retained and any hollow bearing trees and logs
Where possible clearance should avoid hollow bearing trees Where unavoidable hollow bearing trees should be flagged and left standing at least 24 hours
after clearing all other vegetation Excavator operator to lsquotaprsquo tree prior to felling hollow bearing trees to allow for fauna to escape Ecologist (or similar) to be present onside during clearing of hollow bearing trees to handle any
displaced fauna In the event of injury to fauna WIRES or similar to be contacted and suitable arrangements made
NOTE Handling of any active animal breeding place is only permitted to be conducted by an authorised fauna handler operating under a current permit granted in accordance with legislative requirements
All
Authorisation amp Compliance
Georgiou will not clear vegetation without written permission from the Client local Shire or relevant Regulatory Authority All clearing works under a permit approval or licence will be compliant with the conditions of permit approvals or licence and within the predetermined area
In the event of any unauthorised clearing works will cease immediately and the Project Manager client will be notified Unauthorised clearing of areas will be investigated immediately
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Marking
The Project Engineer will ensure the area to be cleared is clearly marked (eg pegging) and areas of vegetation or trees nominated to be excluded from the clearing works are to be visually identifiable to all personnel involved in the works
The method of marking is to be communicated to all persons involved in the clearing process All control measures are to be communicated to personnel involved in the tasks
All
Flora
Flora that is to be protected will be clearly marked using a method that will not harm or damage A Tree protection Zone (TPZ) is to be established for any trees on a construction site that are to
be protected This is to be fenced off or barricaded to ensure construction activities do not cause damage to the root plate of the tree
Native vegetation should be protected where reasonably possible Large areas that are to be protected from Site works will be demarcated to prevent intrusion and disturbance This requirement is to be communicated to personnel involved within the site area
When the pruning of trees is to be undertaken that are to be protected it will be done by suitably qualified personnel only Where branches are trimmed an assessment of the trees ability to survive should be conducted by a suitably qualified person and adequate area around the tree in accordance with AS49702009 Protection of trees of development sites
Trees should be felled into the construction site or in slots between stands of trees where practical to minimise damage to other trees during the clearing process Machinery contact with standing trees on vegetated margins is to be avoided
The clearing of vegetation outside the construction area will not be permitted except in the event of an emergency or as directed by emergency services
All
Fauna
If fauna are confirmed to be present onsite during clearing clearing works should proceed with care to enable the fauna to relocate freely Clearing is to be conducted in a sequential manner and in a way that encourages escaping wildlife away from the activity into adjacent natural areas and not across roads or into other areas of threat (eg trench)
All
Trenches
All open excavations and trenches will be visually inspected on a daily basis for trapped fauna Surveillance must occur along the entire length of the trench or excavated area and not merely those areas described as fauna habitats or sensitive areas Open trenches are to be checked for fauna immediately prior to backfill and any trapped animals removed by authorised fauna handlers
All
Fauna Handling
Fauna will not be intentionally harmed or maimed under State wildlife protection legislation This includes aquatic and terrestrial fauna (land and air animals)
Workers are not authorised handleto be in possession of native fauna The trapping and handling of fauna in particular dangerous species will only be undertaken by a competent qualified fauna handler
All
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Fire Management
Georgiou will not set fire to bush or use spark generating machinery (eg graders) during a prohibited or restricted burning time
If safe to do so Georgiou will extinguish any bush fire within the site boundary and request help from authorities if necessary Fire breaks will be established as requested by authorities
Project Manager
Environmental
Inspections amp
Monitoring
Daily (Visual) and weekly
(documented)
General observation for clearing boundary demarcation Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
Appendix 5 - Cultural Heritage Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on items or places of heritage value Avoid accidental impacts on heritage items Maximise workerrsquos awareness of indigenous and non-indigenous heritage
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Maintain the integrity of the cultural (European amp Indigenous) aspects of the Site
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any identified cultural or heritage aspects on the Site and any specific controls to be adhered including - Management practices when working near protected areas - Respecting Heritage Sites - Reporting requirements
Georgiou personnel will participate in the Companyrsquos cross cultural awareness training for employees
Project Manager
Heritage Sites There are s170 heritage listed Glebe Island silos (Port Authority of NSW s170 4560056) that are approximately 5m from the edge of works
Project Engineer
Method statement
In accordance with the REF an Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
Unexpected heritage finds
In the event that an artefact or remains are found the Sydney Metro Unexpected Heritage Finds procedure (Appendix 5A) will be followed this includes - The works in that area will cease immediately - The Project Manager and Sydney Metro must be notified - The site must be made secure a buffer zone of ten meters is recommended - Sydney Metro to provide management recommendations
Georgiou will notify all site personnel of the object andor area and proposed treatment of that object andor area as soon as possible but prior to commencing work on the next working day
Works will not continue until written approval has been received from the client
All
discovery of human remains
In the event that human remains are found the Sydney Metro Exhumation Management procedure will be followed (Appendix 5B)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Environmental Inspections amp Monitoring
Building condition inspections Building condition inspections will be undertaken in accordance with REF condition NV3 Sydney Metro
Vibration Monitoring
Continuous vibration monitoring will occur during any vibratory works in close proximity to the Glebe Island silos in accordance with the Sydney Metro Construction Noise and Vibration Standard
Environmental Site Representative
Daily (Visual) and weekly (documented)
General observation for that protection measures and methods are being applied Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure
Sydney Metro Unexpected
Heritage Finds Procedure [SM-18-00105232]
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final
Version 33
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2018
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Document history
Version Date of approval Notes
11 Incorporates ER comments 210617
12 Amends p13 step 8 reference to s146 added
13 Incorporates Planning Mods 1-4 including amended CoA E20
14 Incorporates ER comments 210318
20 Removes SSI 15-7400 COA reference
30 Revises definition
31 Revises flow chart
32 Revises roles and responsibilities
33 General edits and corrections
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Table of contents
1 Purpose 3
11 Legislation that does not apply 3
2 Scope 4
3 Definitions 4
4 Types of unexpected heritage items and corresponding statutory protections 5
41 Aboriginal objects 5
42 Historic heritage items 6
43 Human skeletal remains 7
5 Legislative Requirements 7
6 Unexpected heritage finds protocol 9
7 Responsibilities 15
8 Seeking Advice 16
9 Related documents and references 16
10 List of appendices 16
11 Document history 17
Appendix 1 Examples of finds encountered during construction works 18
Appendix 2 - Unexpected heritage item recording form 24
Appendix 3 - Photographing unexpected heritage items 26
Appendix 4 - Uncovering bones 29
Appendix 5 - Archaeologicalheritage advice checklist 33
Appendix 6 - Template notification letter 34
Tables
Table 1 Legislation and guidelines for management of unexpected heritage finds 8 Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item 10 Table 3 Roles and Responsibilities 15
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1 Purpose
This procedure is applicable to the Sydney Metro program of works including major projects delivered under Critical State Significant Infrastructure (CSSI) Planning Approvals early CSSI minor and enabling works and works that are subject to the NSW Heritage Act (1977) including s57139 and s60140 exemptions and permit approvals and the National Parks and Wildlife (NPW) Act 1974
This procedure has been prepared for Sydney Metro programs to provide a method for managing unexpected heritage items (both Aboriginal and non-Aboriginal) that are discovered during preconstruction (pre-Construction Heritage Management Plan approval) construction phases (post Construction Heritage Management Plan approval) and for works subject to the NSW Heritage Act (1977)
In NSW there are strict laws to protect and manage heritage objects and relics As a result appropriate heritage management measures need to be implemented to minimise impacts on heritage values ensure compliance with relevant heritage notification and other obligations and to minimise the risk of penalties to individuals Sydney Metro and its contractors This procedure includes Sydney Metrorsquos heritage notification obligations under the Heritage Act NPW Act and the Coronerrsquos Act 2009 and the requirements of the conditions of approval(CoA) issued by NSW Department of Planning Industry and Environment Note that a Contractor must not amend the Sydney Metro Unexpected Finds Procedure or use a different procedure without the prior approval of Sydney Metro
This procedure must be read in conjunction with the relevant CCSI conditions of approval (if applicable) the contract documents and other plans and procedures including the Sydney Metro Exhumation Procedure in addition to any other relevant documents as developed by the contractor during the delivery of the Sydney Metro works
2 Definitions and Abbreviations
An unexpected heritage find is
any unanticipated discovery of an actual or potential heritage item which Sydney Metro does not have approval to disturb andor does not have an existing management process in place
a find that has not been previously identified or assessed
a find that is not referenced in an Archaeological Research Design (ARD) Archaeological Method Statement (AMS) or other project document relating to heritage and archaeology
not covered by an existing approval under the Heritage Act 1977 (Heritage Act) or National Parks and Wildlife Act 1974 (NPW Act)
Note that locally significant areas of historical archaeological potential identified in an Archaeological Method Statement but not identified in an Archaeological Research Design would be managed as an ldquoexpectedrdquo find
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All terminology in this procedure is taken to mean the generally accepted or dictionary definition with the exception of the following terms which have a specifically defined meaning
Definitions
AHIP Aboriginal Heritage Impact Permit
Aboriginal object An Aboriginal object is any deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remains An Aboriginal object may include a shell midden stone tools bones rock art Aboriginal-built fences and stockyards scarred trees and the remains of fringe camps
ARD Archaeological Research Design
AMS Archaeological Method Statement
CEMP Construction Environmental Management Plan
CoA Conditions of Approval
CSSD Critical State Significant Development
CSSI Critical State Significant Infrastructure
EPampA Act NSW Environmental Planning and Assessment Act 1979
Disturbance Disturbance is considered to be any physical interference to an item that results in it
being destroyed defaced damaged harmed impacted or altered in any way (this
includes archaeological investigation activities)
Excavation Director
A person that has been determined by the NSW Heritage Division to meet the Heritage Council of NSWrsquos Criteria for Assessment of Excavation Directors (4 September 2019 and as updated) and can therefore competently archaeologically investigate a site of either local andor state significance
Heritage Act NSW Heritage Act 1977
NPW Act NSW National Parks and Wildlife Act 1974
Heritage NSW Formerly Office of Environment and Heritage (OEH) Now Heritage NSW as part of PNSW Premier and Cabinet
SM Sydney Metro
Relic (non- Aboriginal heritage)
A relic means any deposit artefact object or material evidence that
a) relates to the settlement of the area that comprises NSW not being Aboriginal settlement and
b) is of State or local significance
A relic may include items such as bottles utensils remnants of clothing crockery
personal effects tools machinery and domestic or industrial refuse
TfNSW Transport for New South Wales
Work (non- Aboriginal heritage)
Archaeological features such as historic utilities or buried infrastructure that provide evidence of prior occupations such as former rail or tram tracks timber sleepers kerbing historic road pavement fences culverts historic pavement buried retaining walls cisterns conduits sheds or building foundations but are also subject to assessment by the Excavation Director to determine its classification
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21 Legislation that does not apply
The following authorisations are not required for Sydney Metro approved Critical State Significant Infrastructure (and accordingly the provisions of any Act that prohibits an activity without such an authority do not apply)
Division 8 of Part 6 of the Heritage Act 1977 does not apply to prevent or interfere with the carrying out of approved State significant infrastructure
An approval under Part 4 or an excavation permit under section 139 of the Heritage Act 1977 and
An Aboriginal heritage impact permit under section 90 of the National Parks and Wildlife Act 1974
This document provides relevant background information in Section 4 followed by the technical procedure in Sections 6 and 7 Associated guidance referred to in the procedure can be found in Appendices 1-6
3 Scope
Even with early investigations unexpected finds may still occur during works on a Sydney Metro site When this happens this procedure must be followed This procedure provides direction on when to stop work where to seek technical advice how to notify the regulator if required and when works can recommence This procedure applies to the discovery of any unexpected heritage item relic or object where the find is not anticipated in an approved ARD or AMS or other project specific document related to archaeology
This procedure must be followed by all Sydney Metro staff contractors subcontractors or any person undertaking works for Sydney Metro It includes references to some of the relevant legislative and regulatory requirements but is not intended to replace them This procedure does not apply to
the discovery and disturbance of heritage items as a result of investigations being undertaken in accordance with the Code of Practice for Archaeological Investigations of Aboriginal Objects in NSW4376 20101 an Aboriginal Heritage Impact Permit (AHIP) issued under the NPW Act or a permit approval issued under the Heritage Act
the discovery and disturbance of heritage items as a result of construction related activities where the disturbance is permissible in accordance with an AHIP or an approval issued under the Heritage Act or CSSI CSSD planning approval or
locally significant non-Aboriginal archaeology identified in an AMS and not in an ARD
1 An act carried out in accordance with the Code of Practice for Archaeological Investigation of Aboriginal Objects
in NSW as published by the Department in the Gazette on 24 September 2010 is excluded from the definition of harm an object or place in section 5 (1) of the NPW Act
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4 Types of unexpected heritage finds and corresponding statutory protections
Project field and environmental personnel (including construction contractors) are critical to the early identification and protection of unexpected finds
Appendix 1 illustrates the wide range of heritage items uncovered to date during Sydney Metro projects and gives an indicative guide to what unexpected finds may look like
These discoveries are categorised as either
(a) Aboriginal objects
(b) Historic (non-Aboriginal) heritage items or
(c) Human skeletal remains
The relevant legislation that applies to each of these categories is described below
41 Aboriginal objects
The NPW Act protects Aboriginal objects which are defined as
ldquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrdquo2
Examples of Aboriginal objects include stone tool artefacts shell middens axe grinding grooves pigment or engraved rock art burials and scarred trees
42 Historic heritage items
Historic (non-Aboriginal) heritage items may include
Archaeological lsquorelicsrsquo or
Other historic items (ie works structures buildings or movable objects)
2 Section 5(1) NPW Act 3 This is required under section 89(A) of the NPW Act and applies to all Sydney Metro projects
IMPORTANT
All Aboriginal objects regardless of significance are protected under law
If any impact is expected to an Aboriginal object an AHIP is usually required from Heritage NSW When a person becomes aware of an Aboriginal object they must notify the Director-
General of Heritage NSW about its location3 Assistance on how to do this is provided in Section 7 (Step 5)
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421 Archaeological relics
The Heritage Act protects relics which are defined as ldquoany deposit artefact object or material evidence that relates to the settlement of the area that comprises NSW not being Aboriginal settlement and is of State or local heritage significancerdquo4
Relics are archaeological items of local or state significance which may relate to past domestic industrial or agricultural activities in NSW and can include bottles remnants of clothing pottery building materials and general refuse
422 Other historic items
Some historic heritage items are not considered to be lsquorelicsrsquo but are instead referred to as works buildings structures or movable objects Examples of these items that may be encountered include culverts historic pavements retaining walls tramlines rail tracks turn tables timber sleepers cisterns fences sheds buildings and conduits Although an approval under the Heritage Act may not be required to disturb these items their discovery must be managed in accordance with this procedure
Usually archaeological relics are uncovered via a process of excavation or soil removal When an unexpected find is uncovered an archaeological excavation permit under section 140 or section 60 of the Heritage Act may be required to further investigate or remove it if investigation is not covered by an existing approval In contrast lsquoother historic itemsrsquo either exist above the ground surface (for example a shed) or they are designed to operate and exist beneath the ground surface (for example a culvert)They may also need a permit to alter disturb or remove them if there is not an approval already in place
4 Section 4(1) Heritage Act
5 This is required under section 146 of the Heritage Act and applies to all Sydney Metro projects
IMPORTANT
All relics are subject to statutory controls and protections
If a relic is likely to be disturbed a heritage approval is usually required from the NSW Heritage Council When a person discovers a relic they must notify the NSW Heritage
Council of its location5
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43 Human skeletal remains
The Sydney Metro Exhumation Procedure provides a more detailed explanation of the approval processes related to human remains
Human skeletal remains can be identified as either an Aboriginal object or non-Aboriginal relic depending on the ancestry of the individual (Aboriginal or non-Aboriginal) and the burial context (archaeological or non-archaeological) Remains are considered to be archaeological when the time elapsed since death is suspected of being 100 years or more Depending on ancestry and context different legislation applies
As a simple example a pre-European settlement archaeological Aboriginal burial would be protected under the NPW Act while a historic (non-Aboriginal) archaeological burial within a cemetery would be protected under the Heritage Act For a non-Aboriginal archaeological burial the relevant heritage approval and notification requirement described in Appendix 4 would apply In addition to the NPW Act finding Aboriginal human remains also triggers notification requirements to the Commonwealth Minister for the Environment under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
Where it is suspected that less than 100 years has elapsed since death the human skeletal remains come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such cases are lsquoreportable deathsrsquo and under legal notification obligations set out in section 35(2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (whether Aboriginal or non-Aboriginal remains) Public health controls may also apply6
Guidance on what to do when suspected human remains are found is provided in Appendix 5
IMPORTANT
All human skeletal remains are subject to statutory controls and protections
All bones must be treated as potential human skeletal remains and work around them must stop while they are appropriately protected and investigated the relevant authorities advised and approvals received This includes skeletal material found during any phase of work including
geotechnical works early works construction works and any other site works
6 Under section 19 of the Coroners Act 2009 the coroner has no jurisdiction to conduct an inquest into reportable
death unless it appears to the coroner that (or that there is reasonable cause to suspect that) the death or suspected death occurred within the last 100 years
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5 Legislative Requirements Table 1 identifies some of the relevant legislationregulations for the protection of heritage and the management of unexpected heritage finds in NSW It should be noted that significant penalties exist for breaches of the legislation which result in unauthorised impacts to heritage items
To avoid breaches of legislation it is important that Sydney Metro and its contractors are aware of their statutory obligations under relevant legislation and that appropriate control measures are in place to ensure that unexpected finds are appropriately managed during all project phases Contractors will need to ensure that they undertake their own due diligence to identify any other legislative requirements that may apply for a given project
Table 1 Legislation and guidelines for management of unexpected heritage finds
Relevant Requirement Objectives and offences
Environmental Planning and Assessment Act 1979 (EPampA Act)
Part 5 Division 52 Subdivision 2 Section 519
Requires heritage to be considered within the environmental impact assessment of projects
Heritage Act 1977 (Heritage Act)
The Heritage Act provides for the care protection and management of heritage items in NSW Under section 139 it is an offence to disturb or excavate any land knowing or having reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered exposed moved damaged or destroyed unless the disturbance or excavation is carried out in accordance with an excavation permit issued by the Heritage NSW under the Act a relic is defined as lsquoany deposit artefact object or material evidence that (a) relates to the settlement of the area that comprises New South Wales not being Aboriginal settlement and (b) is of State or local heritage significancersquo
A person must notify the Heritage NSW if a person is aware or believes that they have discovered or located a relic (section 146) Penalties for offences under the Heritage Act can include six months imprisonment andor a fine of up to $11million
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Relevant Requirement Objectives and offences
National Parks and Wildlife Act 1974 (NPW Act)
The NPW Act provides the basis for the care protection and management of Aboriginal objects and places in NSW
An Aboriginal object is defined as lsquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrsquo
An lsquoAboriginal placersquo is an area declared by the Minister administering the Act to be of special significance with respect to Aboriginal culture An Aboriginal place does not have to contain physical evidence of occupation (such as Aboriginal objects)
Under section 87 of the Act it is an offence to harm or desecrate an Aboriginal object or place There are strict liability offences An offence cannot be upheld where the harm or desecration was authorised by an AHIP and the permitrsquos conditions were not contravened Defences and exemptions to the offence of harming an Aboriginal object or Aboriginal place are provided in section 87 87A and 87B of the Act A person must notify Heritage NSW if a person is aware of the location of an Aboriginal object
Penalties for some of the offences can include two years imprisonment andor up to $550000 (for individuals) and a maximum penalty of $11 million (for corporations)
6 Unexpected heritage finds protocol
61 What is an unexpected heritage find
An lsquounexpected heritage findrsquo can be defined as any unanticipated archaeological discovery that has not been identified during a previous assessment or is not covered by an existing permit under the Heritage Act The find may have potential cultural heritage value which may require a heritage permit or notification if any interference of the heritage item is proposed or anticipated
The range of potential unexpected finds can include but is not limited to
remains of rail infrastructure including buildings footings stations signal boxes rail lines bridges and culverts
remains of other infrastructure including sandstone or brick buildings wells cisterns drainage services conduits old kerbing and pavement former road surfaces timber and stone culverts bridge footings and retaining walls
artefact scatters including clustering of broken and complete bottles glass ceramics animal bones and clay pipes and
archaeological human skeletal remains
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62 Managing unexpected finds
In the event that an unexpected find is encountered on a Sydney Metro site the steps detailed in Table 2 must be followed There are seven steps in the procedure
Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item
Step Task Responsibility Guidance and tools
1 Stop work and protect the item
11 Stop all work including geotechnical investigations in the immediate area of the item and notify the Project Manager
Contractor Supervisor
Appendix 1
Identifying Unexpected Heritage items
12 Establish a lsquono-go zonersquo around the item Use high visibility fencing where practical No work is to be undertaken within this zone until further investigations are completed and if required appropriate approvals are obtained
Inform all site personnel about the no-go zone
Project Manager Contractor Supervisor
2 Engage an Archaeologist
21 If you have Excavation Director or an archaeologist andor Aboriginal heritage consultant has been previously appointed for the project contact them to discuss the location and nature of the item and arrange a site inspection The project Construction Environmental Management Plan (CEMP) may contain contact details of the archaeologistAboriginal heritage consultant
Provide as much information as possible including photos and completed recording form
Inform the Sydney Metro Environmental Manager and keep them involved in the process The Environmental Manager will inform the Sydney Metro Senior Heritage Advisor
Contractors Project Manager
Appendix 2
Unexpected Heritage Item Recording Form
22 Where there is no project archaeologist engaged for the works engage a suitably qualified consultant to assess the find
If the find is a non-Aboriginal item engage a suitably qualified and experienced historical archaeological consultant
If the find is likely to be an Aboriginal object engage an Aboriginal heritage consultant
Contractorrsquos Project Manager
IMPORTANT
Sydney Metro may have approval to impact certain heritage items during construction If you think that you may have discovered a heritage item and you are unsure whether an
approval is in place or not STOP works and follow this procedure
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Step Task Responsibility Guidance and tools
23 ArchaeologistExcavation Director and Sydney Metro Environmental Manager to advise the Project Manager whether Sydney Metro has approval to impact the lsquoitemrsquo
If yes work may recommence in accordance with that approval or permit There is no further requirement to follow this procedure
If no continue to next step
Contractorrsquos Project Manager
3 Arrange site access
31 Arrange site access for the archaeologistAboriginal heritage consultant to inspect the item as soon as practicable In most cases a site inspection is required to conduct a preliminary assessment
Contractorrsquo s Project Manager Excavation Director
32 Subject to the archaeologistAboriginal heritage consultantrsquos assessment work may recommence at a set distance from the item This is to protect any other archaeological material that may exist in the vicinity which may have not yet been uncovered Existing protective fencing established in Step 12 may need to be adjusted to reflect the extent of the newly assessed protective area No works are to take place within this area once established
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
33 Occasionally the archaeologistAboriginal heritage consultant may determine from the photographs provided at Step 21 that no site inspection is required because no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo a lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Archaeologist Aboriginal heritage consultant Excavation Director
Proceed to Step 8
4 Undertake Preliminary assessment and recording of the find
41 Has the lsquofindrsquo been damaged or harmed
If yes record the incident in the Incident
Management System Implement any additional reporting requirements related to the planning approval and CEMP where relevant
Contractors Project Manager Archaeologist and or Excavation Director
42 Can the works avoid further disturbance to the item Project Manager to confirm with Sydney Metro Environment Manager
Complete the remaining tasks
Contractorrsquos Project Manager
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Step Task Responsibility Guidance and tools
43 Inspect document and photograph the item Archaeologist and or Excavation Director
Appendix 2
Unexpected Heritage Item Recording Form
Appendix 3
Photographing Unexpected Heritage items
44 Is the item likely to be bone
If yes follow the steps in Appendix 4 ndash lsquoUncovering bonesrsquo Where it is obvious that the bones are human remains you must notify the local police by telephone immediately They may take command of all or part of the site Also refer to the Sydney Metro Exhumation Procedure
If no proceed to next step
Archaeologist and or Excavation Director
Appendix 4
Uncovering Bones
45 The archaeologistAboriginal heritage consultant may provide advice after the site inspection and preliminary assessment that no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo or a lsquoheritage itemrsquo or an lsquoAboriginal itemrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Metro Project Manager
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
Proceed to Step 7
Refer to Appendix 1
Examples of finds encountered during construction worksrsquo
46 Where required seek additional specialist technical advice (such as a forensic or physical anthropologist to identify skeletal remains) The archaeologistAboriginal heritage consultant can provide contacts for such specialist consultants
Excavation Director Archaeologist
47 Where the item has been identified as a lsquorelicrsquo or lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo the archaeologist should formally record it
Archaeologist Aboriginal heritage consultant
48 NSW Heritage for non-Aboriginal relics and NSW Department of Planning Industry and Environment for Aboriginal objects can be notified informally by telephone at this stage by the Sydney Metro Senior Heritage Advisor Any verbal conversations with regulators must be noted on the project file for future reference
Contractors Project Manager Excavation Director
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Step Task Responsibility Guidance and tools
5 Notify the regulator if required
51 Based on the findings of the archaeological or heritage management plan and corresponding legislative requirements is notification of Heritage NSW and the Secretary required
If no proceed directly to Step 6
If yes proceed to next step
Sydney Metro Environmental Manager Contractorrsquos Excavation Director
52 If notification is required complete the template notification letter including the archaeological heritage management plan and other relevant supporting information and forward to the Sydney Metro Environmental Manager The Environmental Manager will seek the approval of the Sydney Metro Senior Heritage Advisor and the signature of the Principal Manager Sustainability Environment and Planning (Program)
Sydney Metro Environmental Manager Excavation Director
Appendix 6
Template Notification Letter
53 Forward the signed notification letter to Heritage NSW and the Secretary
Informal notification (via a phone call or email) to Heritage NSW prior to sending the letter is appropriate The archaeological or heritage management plan and the completed Unexpected Heritage Item Recording Form (Appendix 2) must be submitted with the notification letter (for both Aboriginal objects and non-Aboriginal relics)
The Department of Planning Industry and Environment may also need to be notified
54 A copy of the final signed notification letter archaeological or heritage management plan and the site recording form is to be kept on file and a copy sent to the Sydney Metro Project Manager
Contractorrsquos Project Manager Excavation Director
6 Implement archaeological or heritage management plan
61 Modify the archaeological or heritage management plan to take into account any additional advice resulting from notification and discussions with regulator
Contractorrsquos Project Manager Excavation Director
62 Implement the archaeological or heritage management plan Where impact is expected this may include a formal assessment of significance and heritage impact assessment preparation of excavation or recording methodologies consultation with Registered Aboriginal Parties obtaining heritage approvals etc if required
Contractorrsquos Project Manager Excavation Director
63 Where heritage approval is required contact the Sydney Metro Environment Manager for further advice and support material Please note there are time constraints associated with heritage approval preparation and processing
Contractorrsquos Project Manager Excavation Director
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64 Assess whether heritage impact is consistent with the project approval or if project approval modification is required from the Department of Planning Industry and Environment
Excavation Director Sydney Metro Environmental Manager
65 Where statutory approvals (or project approval modifications) are required impact upon relics andor Aboriginal objects must not occur until heritage approvals are issued by the appropriate regulator
Contractorrsquos Project Manager Excavation Director
66 Where statutory approval is not required but where recording is recommended by the archaeologistAboriginal heritage consultant sufficient time must be allowed for this to occur
Contractorrsquos Project Manager Excavation Director
67 Ensure short term and permanent storage locations are identified for archaeological material or other heritage material removed from site where required Interested third parties (for example museums local Aboriginal land councils or local councils) should be consulted on this issue Contact the archaeologist or Aboriginal heritage consultant for advice on this matter if required
Contractorrsquos Project Manager Excavation Director
7 Resume work
71 Seek written clearance to resume project work from the project Excavation Director Archaeologist Aboriginal heritage consultant
Clearance would only be given once all archaeological excavation andor heritage recommendations and approvals (where required) are complete Resumption of project work must be in accordance with the all relevant projectheritage approvalsdeterminations
Contractorrsquos Project Manager Excavation Director
72 If required ensure archaeological excavationheritage reporting and other heritage approval conditions are completed in the required timeframes This includes artefact retention repositories conservation andor disposal strategies
Contractorrsquos Project Manager Excavation Director
73 If additional unexpected items are discovered this procedure must begin again from Step 1
All
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7 Responsibilities
Table 3 Roles and Responsibilities
Role Responsibility or role under this guideline
Contractor Supervisor
Stop work immediately when an unexpected heritage find is encountered Cordon off area until Environmental Manager Excavation Director advises that work can recommence
Manage the process of identifying protecting and mitigating impacts on the lsquofindrsquo
Liaise with Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Assist the archaeologistAboriginal heritage consultant with mitigation and regulatory requirements
Complete Incident Report and review CEMP for any changes required Propose amendments to the CEMP if any changes are required
Contractors Project Manager
Ensures all aspects of this procedure are implemented Advise Contractor Supervisor to recommence work if all applicable requirements have been satisfied and the Excavation Director
Project Archaeologist has approved recommend of work
Contractorrsquos or Project Heritage Advisor or Consultant
Provide expert advice to the Sydney Metro Environment Manager on find identification significance mitigation legislative procedures and regulatory requirements
Environmental Representative
Ensure compliance with relevant approvals (new and existing)
Sydney Metro Environment Manager
Notify the Sydney Metro Principal Manager Environmental Management of find and manage Incident Reporting once completed by Environmental Manager
Sydney Metro Senior Heritage Advisor
Provide expert advice to Sydney Metro Environment Manager and project as required
8 Seeking Advice
Advice on this procedure should be sought from the Sydney Metro Environment Manager in the first instance Contractors and delivery partners should ensure their own project environment managers are aware of and understand this procedure
Technical archaeological or heritage advice regarding an unexpected heritage item should be sought from a suitably qualified and experienced archaeologistAboriginal heritage consultant
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9 Related documents and references
Sydney Metro Environmental Incident Classification and Reporting ndash SM-17-00000096
Transport for NSW Guide to Environmental Control Map ndash 3TP-SD-01570
NSW Heritage Office (1998) Skeletal remains guidelines for the management of human skeletal remains
Roads and Maritime Services (2015) Standard Management Procedure Unexpected Heritage Items
Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal remains
Sydney Metro Exhumation Procedure ndash SM ES-PW-31510
10 List of appendices
The following appendices are included to support this procedure
Appendix 1 Examples of finds encountered during construction works
Appendix 2 Unexpected Heritage Item Recording Form
Appendix 3 Photographing Unexpected Heritage Items
Appendix 4 Uncovering Bones
Appendix 5 Archaeological Advice Checklist
Appendix 6 Template Notification Letter
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Appendix 1 Examples of finds encountered during construction works
Photo 1 - Aboriginal artefacts found at the Wickham Transport Interchange 2015
Photo 2 ndash Aboriginal artefacts (shell material) found at the Wickham Transport Interchange 2015
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Photo 3 1840s seawall and 1880s retaining wall uncovered at Balmain East 2016
Photo 4 Sandstone pavers uncovered at Balmain East 2016
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Photo 5 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 6 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 7 - Sandstone flagging and cesspit - Wynyard Walk project 2014
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Photo 8 - Chinese Ming Dynasty pottery and English porcelainpottery dating back to early 19th century - Wynyard Walk project 2014
Photo 9 - Pottery made by convict potter Thomas Ball during the early settlement - Wynyard Walk project 2014
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Sydney Metro ndash Integrated Management System (IMS)
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The following images obtained from the Roads and Maritime Servicesrsquo Standard Management Procedure for Unexpected Heritage items 2015 can be used to assist in the preliminary identification of potential unexpected items during construction and maintenance works Photo 10 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones (Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights Newcastle area) (RMS 2015)
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Sydney Metro ndash Integrated Management System (IMS)
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Photo 11 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones
(Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork
recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights
Newcastle area) (RMS 2015)
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Sydney Metro ndash Integrated Management System (IMS)
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Appendix 2 - Unexpected Heritage Find Recording Form
Example of unexpected heritage item recording form
This form is to be completed Excavation Director on the discovery of an archaeological heritage find during construction or maintenance works
Date Recorded by
(include name and position)
Project name
Description of works
being undertaken
Description of exact
location of item
Description of item
found
(What type of item is it likely
to be Tick the relevant
boxes)
A A relic A lsquorelicrsquo is evidence of a past human activity
relating to the settlement of NSW with local
or state heritage significance A relic might
include bottle utensils plates cups
household items tools implements and
similar items
B A lsquoworkrsquo building or
structurersquo A lsquoworkrsquo can generally be defined as a form
infrastructure such as track or rail tracks
timber sleepers a culvert road base a
bridge pier kerbing and similar items
C An Aboriginal object An lsquoAboriginal objectrsquo may include stone
tools stone flakes shell middens rock art
scarred trees and human bones
D Bone Bones can either be human or animal
remains
Remember that you must contact the local
police immediately by telephone if you are
certain that the bone(s) are human
remains
E Other
Provide a short
description of the item
(Eg metal rail tracks
running parallel to the rail
corridor Good condition
Tracks set in concrete
approximately 10 cm below
the current ground surface)
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Sketch
(Provide a sketch of the
itemrsquos general location in
relation to other road
features so its approximate
location can be mapped
without having to re-
excavate it In addition
please include details of the
location and direction of any
photographs of the item
taken)
Action taken (Tick either
A or B)
A Unexpected item
would not be further
impacts on by the
works
Describe how works would avoid impact
on the item (Eg the rail tracks would be left in
situ and recovered with paving)
B Unexpected item
would be further
impacted by the works
Describe how works would impact on the
item (Eg milling is required to be continued to a
depth of 200 mm depth to ensure the pavement
requirements are met Rail tracks would need to
be removed)
Excavation Director Signature
Signature
It is a statutory offence to disturb Aboriginal objects and historic relics (including human
remains) without an approval All works affecting objects and relics must cease until an
approval is sought
Approvals may also be required to impact on certain works
Important
Unclassified
Appendix 3 - Photographing unexpected heritage finds
Photographs of unexpected finds in their current context (in situ) may assist archaeologistsAboriginal heritage consultants to better identify the heritage values of the item Emailing good quality photographs to specialists can allow for better quality and faster heritage advice The key elements that must be captured in photographs of the item include its position the item itself and any distinguishing features All photographs must have a scale (ruler scale bar mobile phone coin etc) and a note describing the direction of the photograph
Context and detailed photographs
It is important to take a general photograph (Figure 1) to convey the location and setting of the item This will add value to the subsequent detailed photographs also required (Figure 2)
Figure 1 Telford road uncovered on the Great Western Highway (Leura) in 2008 (RMS 2015)
Photographing distinguishing features
Where unexpected items have a distinguishing feature close up detailed photographs must be taken of these features where practicable In the case of a building or bridge this may include diagnostic details architectural or technical features See Figures 3 and 4 for examples
Unclassified
Removal of the item from its context (eg excavating from the ground) for
photographic purposes is not permitted
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Photographing bones
The majority of bones found on site will be animal bones often requiring no further assessment (unless they are in archaeological context) However if bones are human the police must be contacted immediately (see Appendix 5 for detailed guidance) Taking quality photographs of the bones can often resolve this issue quickly The project archaeologist can confirm if bones are human or non-human if provided with appropriate photographs
Ensure that photographs of bones are not concealed by foliage (Figure 5) as this makes it difficult to identify Minor hand removal of foliage can be undertaken as long as disturbance of the bone does not occur Excavation of the ground to remove bone(s) should not occur nor should they be pulled out of the ground if partially exposed
Where sediment (adhering to a bone found on the ground surface) conceals portions of a bone (Figure 6) ensure the photograph is taken of the bone (if any) that is not concealed by sediment
Ensure that all close up photographs include the whole bone and then specific details of the bone (especially the ends of long bones the epiphysis which is critical for species identification) Figures 7 and 8 are examples of good photographs of bones that can easily
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be identified from the photograph alone They show sufficient detail of the complete bone and the epiphysis
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Appendix 4 - Uncovering bones
This appendix provides advice regarding
what to do on first discovering bones
the range of human skeletal notification pathways and
additional considerations and requirements when managing the discovery of human remains
1 First uncovering bones
Refer to the Sydney Metro Exhumation Procedure
Stop all work in the vicinity of the find All bones uncovered during project works should be treated with care and urgency as they have the potential to be human remains The bones must be identified as either human or non-human as soon as possible by a qualified forensic or physical anthropologist
On the very rare occasion where it is immediately obvious from the remains that they are human the Project Manager (or a delegate) should inform the police by telephone prior to seeking specialist advice It will be obvious that it is human skeletal remains where there is no doubt as demonstrated by the example in Figure 17 Often skeletal elements in isolation (such as a skull) can also clearly be identified as human Note it may also be obvious that human remains have been uncovered when soft tissue andor clothing are present
7
After Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal
Remains 17
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This preliminary phone call is to let the police know that a specialist skeletal assessment to determine the approximate date of death which will inform legal jurisdiction The police may wish to take control of the site at this stage If not a forensic or physical anthropologist must be requested to make an on-site assessment of the skeletal remains
Where it is not immediately obvious that the bones are human (in the majority of cases illustrated by Figure 2) specialist assessment is required to identify the bones Photographs of the bones can assist this assessment if they are clear and taken in accordance with guidance provided in Appendix 3 Good photographs often result in the bones being identified by a specialist without requiring a site visit noting they are nearly always non-human In these cases non-human skeletal remains must be treated like any other unexpected archaeological find
If the bones are identified as human (either by photographs or an on-site inspection) a technical specialist must determine the likely ancestry (Aboriginal or non-Aboriginal) and burial context (archaeological or forensic) This assessment is required to identify the legal regulator of the human remains so urgent notification (as below) can occur
Preliminary telephone or verbal notification by the archaeologist to the Sydney Metro Senior Heritage Advisor is appropriate This must be followed up later by a formal letter notification to the relevant regulator when a management plan has been developed and agreed to by the relevant parties
2 Range of human skeletal notification pathways
The following is a summary of the different notification pathways required for human skeletal remains depending on the preliminary skeletal assessment of ancestry and burial context
A Human bones are from a recently deceased person (less than 100 years old)
B Human bones are archaeological in nature (more than 100 years old) and are likely to be Aboriginal remains
C Human bones are archaeological in nature (more than 100 years old) and likely to be non-Aboriginal remains
Figure 3 summarises the notification pathways on finding bones
Action
The Heritage NSW must be notified immediately
Action
The police must be notified immediately as per the obligations to report a death or suspected death under s35 of the Coroners Act 2009 (NSW) It should be assumed the police will then take command of the site until otherwise directed
Action
The Department of Planning Industry and Environment Aboriginal Heritage Section must be notified immediately The project Aboriginal Cultural Heritage Advisor must contact and inform the relevant Aboriginal community stakeholders who may request to be present on site
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Figure 3 Overview of steps to be undertaken on the discovery of bones
After the appropriate verbal notifications (as described in 2B and 2C above) the Project Manager must proceed through the Unexpected Heritage Items Exhumation Procedure (Step 4) It is noted that no Exhumation Procedure is required for forensic cases (2A) as all future management is a police matter Non-human skeletal remains must be treated like any other unexpected archaeological find and so must proceed to record the find
3 Additional considerations and requirements
Uncovering archaeological human remains must be managed intensively and needs to consider a number of additional specific issues These issues might include facilitating culturally appropriate processes when dealing with Aboriginal remains (such as repatriation and cultural ceremonies) Project Managers may need to consider overnight site security of any exposed remains and may need to manage the onsite attendance of a number of different external stakeholders during assessment andor investigation of remains
Project Managers may also be advised to liaise with local churchreligious groups and the media to manage community issues arising from the find Additional investigations may be required to identify living descendants particularly if the remains are to be removed and relocated
If exhumation of the remains (from a formal burial or a vault) is required Project Managers should also be aware of additional approval requirements under the NSW Public Health Act 1991 Specifically Sydney Metro may be required to apply to the Director General of NSW
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Department of Health for approval to exhume human remains as per Clause 26 of the NSW Public Health (Disposal of Bodies) Regulation 2002 8
Further the exhumation of such remains needs to consider health risks such as infectious disease control exhumation procedures and reburial approval and registration Further guidance on this matter can be found at the NSW Department of Health website
In addition due to the potential significant statutory and common law controls and prohibitions associated with interfering with a public cemetery project teams are advised when works uncover human remains adjacent to cemeteries to confirm the cemeteryrsquos exact boundaries where possible
8 This requirement is in addition to heritage approvals under the Heritage Act 1977
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Appendix 5 - Archaeologicalheritage advice checklist
The archaeologistAboriginal heritage consultant must advise the Sydney Metro Environment Manager and Senior Heritage Advisor of an appropriate archaeological or heritage management plan as soon as possible after an inspection of the site has been completed An archaeological or heritage management plan can include a range of activities and processes which differ depending on the find and its significance
In discussions with the archaeologistAboriginal heritage consultant the following checklist can be used as a prompt to ensure all relevant heritage issues are considered when developing this plan This will allow the project team to receive clear and full advice to move forward quickly Archaeological andor heritage advice on how to proceed can be received in a letter or email outlining all relevant archaeological andor heritage issues
Required Outcomenotes
Assessment and investigation
Assessment of significance YesNo
Assessment of heritage impact YesNo
Archaeological excavation YesNo
Archival photographic recording YesNo
Heritage approvals and notifications
AHIP section 140 section 139 exceptions section 60 exemptions etc
YesNo
Regulator relicsobjects notification YesNo
Notification to Sydney Trains for s170 heritage conservation register
YesNo
Compliance with CEMP or other project heritage approvals
YesNo
Stakeholder consultation
Aboriginal stakeholder consultation YesNo
Artefactheritage item management
Retention or conservation strategy (eg items may be subject to long conservation and interpretation)
YesNo
Disposal strategy YesNo
Short term and permanent storage locations (interested third parties should be consulted on this issue)
YesNo
Control Agreement for Aboriginal objects YesNo
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Appendix 6 - Template notification letter
Insert on Sydney Metro letterhead
Select and type date] [Select and type reference number]
XXX
Heritage NSW Department of Planning Industry and
Environment
xxx
Parramatta NSW 2124
[Select and type salutation and name]
Re Unexpected heritage item discovered during Sydney Metro activities
I write to inform you of an unexpected [select relic heritage item or Aboriginal object] found during Sydney Metro investigative and construction works at [insert location] on [insert date] in accordance with the notification requirement under select section 146 of the Heritage Act 1977 (NSW) [Where the regulator has been informally notified at an earlier date by telephone this should be referred to here]
[Provide a brief overview of the project background and project area Provide a summary of the description and location of the item including a map and image where possible Also include how the project was assessed under the Environmental Planning and Assessment Act 1979 (NSW) (eg Part 5) Also include any project approval number if available]
Sydney Metro [or contractor] has sought professional archaeological advice regarding the item A preliminary assessment indicates [provide a summary description and likely significance of the item] Please find additional information on the site recording form attached
Based on the preliminary findings Sydney Metro [or contractor] is proposing [provide a summary of the proposed archaeologicalheritage approach (eg develop archaeological research design (where relevant) seek heritage approvals undertake archaeological investigation or conservationinterpretation strategy) Also include preliminary justification of such heritage impact with regard to project design constraints and delivery program]
The proposed approach will be further developed in consultation with a nominated Office of Environment and Heritage staff member
Should you have any feedback on the proposed approach or if you require any further information please do not hesitate to contact [Environment and Planning Project Manager] on (02) XXXX XXXX
Yours sincerely
[Sender name]
Sydney Metro Director Environment Sustainability amp Planning [Attach the archaeologicalheritage management plan and site recording form]
NB On finding Aboriginal human skeletal remains this letter must also be sent to the Commonwealth Minister for the Environment in accordance with notification requirements under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 56 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 5B ndash Sydney Metro Exhumation Management Procedure
Unclassified
Exhumation Management
Procedure
SM ES-PW-31510
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final issued for Implementation
Version 40
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2017
Unclassified
Integrated
Management
System
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 2 of 24
Table of Contents
Contents 1 Introduction 3
2 Methodology 3 21 Overview of legislative requirements for dealing with human remains
4 22 Discovery of human remains and forensic cases NSW Coroners
Act 2009 (NSW) 4 23 Historic human remains Heritage Act 1977 and Guidelines for the
Management of Human Skeletal Remains under the Heritage Act 1977 5
24 Aboriginal human remains National Parks and Wildlife Act 1974 6 25 Exhumation of human remains Public Health Regulation 2012
(NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013) 7
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013) 7
27 Work Health and Safety Act 2011 7
3 Sydney Metro procedure for the discovery and management of human remains 8 31 Initial discovery of bones What do we do 8 32 Archaeological Exhumation Methodology 10
4 Excavation and post-excavation tasks 14 41 Research Questions 14 42 Process for DNA Testing Isotope Analysis and Environmental
Sampling 15 43 Reporting 16 44 Public Involvement 16 45 Temporary Storage and Permanent Repository or Resting Place for
Remains 17
5 Definitions 18
6 Related Documents and References 18
7 Superseded Documents 18
8 Document History 18
9 Schedule of Acronyms 18
Exhumation of Human Remains 20 EXHUMATION OF HUMAN REMAINS 1 MANDATORY REQUIREMENTS 1 IMPLEMENTATION 1 REVISION HISTORY 2 CONTENTS 4 APPENDIX 2 11 APPENDIX 3 12 APPENDIX 4 13 APPLICATION TO EXHUME REMAINS 16
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1 Introduction
This Exhumation Management Procedure (ExMP) has been developed to provide Sydney Metro and their contractors with guidance on managing the discovery of human skeletal remains during the course of the Sydney Metro program of works
Sydney Metro is Australiarsquos biggest public transport project From the northwest metro rail is being extended under Sydney Harbour through new underground city stations and beyond to the south west In 2024 Sydney will have 31 metro railway stations and a 66km standalone metro railway system revolutionising the way Australiarsquos biggest city travels (refer to Figure 1)
The purpose of this ExMP is to provide a clear and concise process to follow in the event of the discovery of potential human remains during Sydney Metro project works
This ExMP will be reviewed as required and prior to any future Sydney Metro project that has potential to impact on a known cemetery or burial ground A review may require amendment the ExMP to tailor additional controls or management procedures that are specific to the impacted cemetery or burial ground In addition the requirements of the relevant Planning Approval will be assessed during the review of this ExMP prior to its implementation
This procedure should be read in conjunction with the Sydney Metro Unexpected Finds Policy
2 Methodology
This ExMP outlines the procedure for the management of the discovery of human remains within the Sydney Metro program The ExMP addresses the following
Discussion of relevant legislation and guidelines (eg Coroners Act 2009 Heritage Act 1977 Guidelines for the Management of Human Skeletal Remains 1988 and the Public Health Regulations 2012)
Archaeological methodology for excavation of remains including processes for appropriately handling remains in accordance with the relevant guidelines
Preparation of a flow chart process to be used by contractors to respond to the discovery of suspected human remains
Post-exhumation management primarily around relocation processing and long- term arrangements
Process for nomination of a physical anthropologist and temporary storage location
Process for additional analysis including DNA testing isotope analysis and environmental sampling and discussion on requirements for public involvement
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Figure 1 2020 Sydney Metro Program Project overview and station locations
21 Overview of legislative requirements for dealing with human remains
The following section provides an overview of the legislation that would apply to the discovery management and relocation of human remains A discovery of suspected human remains may be subject to different Acts and requirements thereby triggering different notification pathways based on the specific circumstances involved
The first step will always be to notify the NSW Police Confirmation of the age (antiquity) and nature of the skeletal remains as well as the reasons for the disturbance will dictate which Act and provisions will be applicable
22 Discovery of human remains and forensic cases NSW Coroners Act 2009 (NSW)
For a discovery of suspected human remains less than 100 years old the remains would come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such a case would be considered a lsquoreportable deathrsquo and under legal notification obligations set out in s35 (2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (ie both Aboriginal and non-Aboriginal remains)
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Sydney Metro Exhumation Procedure v40 (final)
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35 Obligation to report death or suspected death
(1) This section applies to any person who has reasonable grounds to believe that a death or suspected death of another person
(a) is a reportable death or occurred in circumstances that would be examinable under Division 2 of Part 32 and
(b) has not been reported in accordance with subsection (2)
(2) A person to whom this section applies must report the death or suspected death concerned to a police officer a coroner or an assistant coroner as soon as possible after becoming aware of the grounds referred to in subsection (1)
Maximum penalty (subsection (2)) 10 penalty units
(3) A police officer to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner or assistant coroner as soon as possible after the report is made
(4) An assistant coroner to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner as soon as possible after the report is made
(5) A coroner to whom a death or suspected death is reported under this section is required to inform the State Coroner of the report as soon as practicable after the report is made
23 Historic human remains Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 19771 (the Guidelines) apply to historic burials in New South Wales It should be noted that the Guidelines are outdated in terms of the current statutory framework
A relic is defined as an archaeological deposit or artefact that has heritage significance at a local or State level The guidelines Assessing Significance for Historical Archaeological Sites and `Relics2 have been endorsed by the Heritage Council and should be used to assess the level of heritage or archaeological significance of the remains With reference to burial grounds objects such as headstones grave enclosures and grave goods as well as buried human remains may be a lsquorelicrsquo
1 NSW Heritage Office 1998
2 Heritage Branch of the Department of Planning 2009
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(Uncontrolled when printed)
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Approval under the Heritage Act 1977 and the National Parks and Wildlife Act 1974 is not required if human remains are uncovered during a Critical State Significant Infrastructure (CSSI) project However notification to the Heritage Council under s146 of the Heritage Act and notification of an Aboriginal object under the National Parks and Wildlife Act is required if archaeological human remains are uncovered
24 Aboriginal human remains National Parks and Wildlife Act 1974
The National Parks and Wildlife Act provides statutory protection for all Aboriginal lsquoobjectsrsquo (consisting of any material evidence of the Aboriginal occupation of NSW) under Section 90 of the Act and for lsquoAboriginal Placesrsquo (areas of cultural significance to the Aboriginal community) under Section 84
Discovery of Aboriginal burials andor human remains would be addressed in the projectrsquos Aboriginal Cultural Heritage Assessment Report (ACHAR) ACHARs would be prepared in accordance with the Heritage NSW
lsquoGuidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation3
Guide to investigating assessing and reporting on Aboriginal cultural heritage in NSW4
Aboriginal cultural heritage consultation requirements for proponents 20105
Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales6
If suspected human skeletal remains are uncovered at any time during the archaeological management program the process outlined in this ExMP and detailed in the flow chart is to be followed Management of the remains would be guided by consultation with the nominated Registered Aboriginal Parties (RAPs) for the project in adherence to the ACHAR
3 NSW Department of Environment and Conservation 2005
4 OEH 2011
5 Department of Environment Climate Change and Water 2010
6 OEH 2010
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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25 Exhumation of human remains Public Health Regulation 2012 (NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013)
Public Health Regulation 2012 and the NSW Health Policy Statement ndash Exhumation of human remains of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies in NSW
Under Clause 70 of the Regulation an application for approval to exhume the remains of a dead person may be made to the Director-General via an approved form to the Director of the Local Public Health Unit that acts on behalf of the Director-General of NSW Health Exhumation is not to take place unless an authorised officer or a NSW Health member of staff is present at the exhumation (the grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer) (Clause 72) An authorised officer must be present at the exhumation to ensure the correct interment procedure is followed and that all of the remains are exhumed and to enforce the protection of public health should this be necessary
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013)
The NSW Ministry of Health Policy Statement on the exhumation of human remains provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation Under Clause 69 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General An application for permission to exhume the remains of a deceased person is to be made to the Public Health Unit on the approved form which is contained at the NSW Health website
The required form is appended to this ExMP for ease of reference
Note that the title of Director General of Health was replaced with the Secretary of Health when the Public Health Act and Public Health Regulation were amended However the Policy Directive PD2013-046 has not been amended to reflect this change
27 Work Health and Safety Act 2011
The Work Health and Safety Act 2011 provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices and are enforced by WorkCover NSW Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation More information on safe work practices is available at or by contacting SafeWork NSW via their website or directly
Health and safety aspects of working with human remains should be considered Generally working with archaeological human skeletal remains requires no extra precautions to be taken beyond normal health and safety regulations Once any necessary site health and safety precautions have been taken the exhumation of human remains can proceed
Unclassified
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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3 Sydney Metro procedure for the discovery and management of human remains
This procedure provides project managers principal contractors and the project archaeologistExcavation Director with advice on the steps to follow upon uncovering suspected human remains Information on the potential for burials and human remains would be included in the general project induction for all personnel The induction would include the procedure to manage these finds as set out in this ExMP
31 Initial discovery of bones What do we do
To avoid doubt all suspected bone items must be treated as potential human skeletal remains and work around them must stop while they are protected and investigated as a matter of urgency
Stop Work and preliminary notification
On discovery of bone (suspected human remains) all work in the area of the find must stop and the remains must be confirmed as being human or not
The Project ArchaeologistExcavation Director must be notified
Preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 2009
What When bones are uncovered at a site all work in the area the find must stop immediately and the
site must be secured
Who The discoverer will immediately notify machinery operators so that no further disturbance of the
remains will occur as well as notify the foremansite supervisor principal contractor project archaeologistExcavation Director and Sydney Metro Environmental Manager
Preliminary notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager Notification should provide verbal description of the remains and inform the police that consultation with technical specialists is being undertaken to confirm that the remains are human as well as the burial context (archaeological or less than 100 years old refer Step 2)
How Inform all site personnel of restricted access to the area of the discovery until further notice Area must be fenced off (flagging or temporary exclusion fencing)
Actions Notify site supervisor principal contractor project archaeologist Excavation Director and Sydney Metro Environmental Manger of the find and protect the suspected remains until an initial assessment can be undertaken by a technical specialist
Preliminary notification to NSW Police by Sydney Metro Environmental Manager
Confirm the remains are human
Skeletal remains could either be articulated and in a recognisable form of burial such as a coffin or common burial position of the body (eg supine prone or flexed) or they could be disarticulated or fragmented remains Within the boundaries of a known historic burial ground there is a high probability of the remains being human In a suspected forensic case (less than 100 years old) the remains may have clothing andor human tissue Disarticulated or fragmented bones are often uncovered and these may require specialist assessment to determine legal jurisdiction
If suspected human remains are identified during the course of project works preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 1999 (refer Step 1) NSW Police would be contacted immediately upon receipt of confirmation of human provenance
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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What Confirmation that the remains are human their burial context - whether they are forensic (less than 100 years) or archaeological (older than 100 years) and suspected ancestry (Aboriginal or non- Aboriginal)
Who Excavation Director and or Forensic or physical anthropologist or archaeologist with specialist skills such as an osteoarchaeologist
Notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager
How Consultation could be undertaken as either an on-site inspection or via good quality photos sent to the nominated technical specialist of 1) the remains and 2) the site general site location of the discovery
Actions Contact nominated technical specialists to confirm that the remains are a) human b) burial context (archaeological or forensic) and c) suspected ancestry (Aboriginal or non-Aboriginal)
For the duration of the Sydney Metro project the nominated technical specialists are
Forensic Anthropologist ndash TBC by contractor for project area
Nominated Excavation Director ndash TBC by contractor for project area
Sydney Metro Environmental Manager to conduct and or oversee liaison with NSW Police
The archaeologist may be able to identify the nature of remains without input from the Forensic Anthropologist The Forensic Anthropologist should be contacted as required
Notification based on jurisdiction (forensic or archaeological)
Once confirmation is received from the technical specialist that the remains are of human origin there are three possible statutory pathways to follow based on the assessment
What Forensic case remains are less than 100 years old
Who If it is determined by specialist assessment (Step 2) that the remains are forensic the remains come
under the jurisdiction of the State Coroner and the Coroners Act 2009
How The NSW Police would likely secure the site and will advise on the procedure to be followed
Actions Environmental Manager to liaise with NSW Police
What Archaeological ndash non-Aboriginal human remains -more than 100 years old
Who Follow the Archaeology Exhumation Methodology as set out in Step 4 below
How Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Actions Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 10 of 24
What Archaeological ndash suspected Aboriginal human remains -more than 100 years old
Who Recording of Aboriginal ancestral remains must be undertaken by or conducted under the direct supervision of a specialist with RAPs present
How The RAPs must be present where it is reasonably suspected that Aboriginal burials or human remains have been encountered
Actions Notify RAPs and follow ACHAR Notification to Heritage NSW
Follow the Archaeology Exhumation Methodology as set out in Step 4
32 Archaeological Exhumation Methodology
The following section provides the archaeological methodology for exhumation and the appropriate handling of human remains
Securing the Site
The strategy for the excavation and removal of human remains must be sensitive to public opinion and ethical issues and exhumation activities should not be visible to the general public The site may need to be screened off from public areas not only with hoarding but also in some cases with a roof to screen the site off from overlooking buildings At all times human remains should be treated with respect and dignity The perimeter of the excavation site should be demarcated by plastic tape or flagging with only technical staff allowed within this area for the duration of exhumation activities
The site should be protected from the elements including flooding contamination with dust or debris and other disturbance These measures would be formulated by the Excavation Director in consultation with the contractor and Sydney Metro where required and may differ from site to site
Excavation Director
Archaeological investigations are to be managed by a suitably qualified Excavation Director with experience in the historical archaeology of Sydney and the excavation and management of human remains For sites with potential for locally significant remains the Excavation Director should meet the NSW Heritage Council criteria for locally significant archaeological sites For sites with potential for State significant archaeology the Excavation Director should meet the NSW Heritage Council criteria for State significant archaeological sites
Excavation and recording
Exhumation and recording is to be undertaken in accordance with best practice forensic and Heritage Council guidelines Prior to removal the remains should be fully recorded in situ to understand their surrounding archaeological context This will include recording any disturbances to the burial and the identification of bones present In some cases the deposit of bones may be a mixture of articulated and disarticulated remains Care should be taken to distinguish articulated remains and to assess if they represent commingled individuals or disturbed remains belonging to one individual and to record them accordingly
Recording
A standard context recording system would be employed
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 11 of 24
Detailed survey andor measured drawings would be prepared and include location of remains within the overall site (position of the body the direction of the burial noting any stratigraphic relationships with other archaeological features)
Any associated artefacts (potential grave goods burial furniture) would be recorded and collected by context for later analysis
Digital photography in RAW format using photographic scales and photo boards where appropriate A photographic record of all phases of the work on site would be undertaken
Registers of contexts photos samples and drawings would be kept
Excavation
Detection of the extent of the graveremains (if disarticulated)
Surface soils removed in excavation units of 100mm (site dependent) using small hand tools
Expose remains with soft paint brushes and pedestal the remains
Record position and depth of remains
Soil removed would be sieved through 3mm mesh to examine for teeth and bone fragments
Soil samples may be taken from the abdominal andor chest areas of the body (articulated remains) to retrieve further evidence
Exhumation must be under the control of the Excavation Director with the assistance of a Forensic Anthropologist if required Exhumation permits provided by NSW Ministry of Health may also require the presence of an authorised officer or a member of staff of the Ministry of Health
Further excavation of the bottom of the pit (grave) following removal to confirm the absence of further remains
Relocation of bones
Removal and collection of skeletal remains to follow standard forensic practice of labelling
Remove remains from the ground systematically and place in plastic bags according to anatomical areas of the body
Bags should not be air-tight and should have ventilation holes to prevent deterioration of fragile skeletal material Each bag should contain labels and the separate bags should then be placed in a large plastic bag crate or box labelled with the context information
The remains should be placed in a sturdy large cardboard box (approximately 600 x 300 x 200 mm) for relocation to off-site processing location
Resume work
Construction work may only recommence upon receipt of clearance certificate from the Excavation Director and may require additional NSW Ministry of Health approval If a forensic case written authorisation from the NSW Police is required
Reporting
A report would be prepared following the completion of the program of exhumation works separate to the archaeological excavation report for the project This report would include skeletal analysis catalogue comprehensively describe the process of exhumation detail
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 12 of 24
the recording of the remains and synthesise the results of any further laboratory testing An assessment of significance for the remains would be provided and interpreted within the context of the archaeological research design (response to research questions)
Unclassified
Sydney Metro Exhumation Procedure v4 (Final)
Unclassified
Figure 2 Exhumation Procedure Flow chart
Page 13 of 24
Discovery of bone
Non-human remains
Archaeologist to investigate and work not
to recommence until instrcuted by ED
Work only to recommence when clearance given by Excavation Director
Human Remains
Forensic
Sydney Metro Environmental
Manager to advise NSW POlice
Archaoelogical work not to recommence until clearance given
by NSW Police or Coroner
Aboriginal
Sydney Metro Environmental Manager to advise NSW Policye notify RAPs and follow
ACHAR
Archaoelogical work not to
recommence until clearance firven by
NSW Police or Coroner
Non Aboriginal
Sydney Metro Environmental Manager to notifiy NSW Policce Heritage NSW and DPIE
Sydney Metrocontractor to apply to Secretary of
Health to exhume
Exhumation of human remains by nominated ED Construction work not to commence until
ED issues Clearance Certificate
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
4 Excavation and post-excavation tasks
The following tasks relate to responses to the identification of human remains on site All management should be in accordance with the AARD and relevant Archaeological Method Statement (AMS) and be overseen by the Excavation Director The Excavation Director would nominate a Forensic Anthropologist where required
41 Research Questions
The following research questions should be used guide exhumations should intact burials disarticulated remain burial cuttings or associated material culture be uncovered during works
The research questions are a guide only and could be added to or amended by the Excavation Director depending on the nature of the find
Social History and Burial Practices
Does the location of the burialburial cutting correspond with historic plansdescriptions Are these sources reliable
Is there evidence of exhumation
Do graves cut into older ones What can this tell us about nineteenth century burial practices and how does this compare to other excavated cemetery sites in the region
What is the distance between burials (if multiple burials uncovered) Does this conform to known nineteenth century burial practices
What type of fill was used within grave cuttings What can this tell us about the surrounding environment and burial practices at the time
What materialstree species were used to produce coffins Can coffin manufacturing techniques or fastening methods (use of mortar screws nails tacks) be identified Does this match known burial practices of the time If alternative methods are identified what can this tell us about the manufacturer or economicsocial landscape
Can the class or rank of the individual be identified via coffin materials grave goods or clothingshrouds
Which direction is the burial orientated How does this correspond with the knownhypothesised location of denomination areas
If the burial is associated with additional individuals can a familial relationship be assessed through DNA or other genetic markers identifiable within the skeletal remains (eg impacted third molar)
Can an exchange between burial practices in Britain and colonial Sydney be identified through the burial remains Is there evidence for alternative burial practices associated with additional cultures
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Environmental Factors and Scientific Analysis
What is the condition of the bones How does their condition compare to known or nearby burials of the same age What environmental or human factors may have influenced the decomposition process
Can the health nutrition sex race stature or age be identified through the skeletal remains Is there evidence of trauma on the bones Is there evidence of pathology on the bones (eg syphilis tuberculosis tumours)
If archaeobotanical analysis is carried out what can it tell us about the surrounding environment and nearby plant species Can prepost-European landscapes be determined within the archaeobotanical record
Can stable isotope analysis address any questions regarding diet country of origin and nutrition
Can DNA testing address any questions not answerable by the skeletal remains themselves such as sex familial relationships (if buried with another individuals) or race
Is there potential for DNA to be tested against any individuals who may come forward as a descendant of the deceased
42 Process for DNA Testing Isotope Analysis and Environmental Sampling
Pre-Excavation
The Excavation Director in consultation with the Forensic Anthropologist will nominate a suitable laboratory prior to works commencing Approval for the analysis of skeletal remains soil samples and material samples from the laboratory would also be sought prior to works commencing
Excavation
In order to prevent cross-contamination the following sample collection and excavation process should be followed
The location quantity and material (bone teeth hair soil wood) of samples will be determined by the Excavation Director or Forensic Anthropologist prior to its collection
Samples would be stored in a safe secure and climate controlled location while excavations are in progress This would be chosen by the Excavation Director or Forensic Anthropologist on site
Each collected sample would be given a unique catalogue number and a sample register would be recorded throughout the excavation
ldquoClean Excavationrsquo procedures would be followed during the excavation of burials and during the sample collection process7 This would include
7 Guidelines for lsquoclean excavationrsquo are based on procedures outlined in Yang D Y amp Watt K 2005
Contamination controls when preparing archaeological remains for ancient DNA analysis Journal of Archaeological Science vol 32 pp 331ndash336 and Society for Historical Archaeology 2015-2017 Research and Analysis of Artefacts Accessed online at httpsshaorgconservation- factsfaqanalysisC on 2552017
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Latex gloves would be worn by individuals excavating andor handling bone or soil samples Gloves would be changed for each bone andor individual to prevent cross-contamination
Excavation toolsbrushes would be cleaned prior to and after the collection of each sample to prevent cross-contamination
In some cases a face mask would be worn when samples for DNA analysis are being collected
Bone samples for DNA testing would be collected with surrounding in situ soil and should not be cleaned prior to bagging
It may be necessary for individuals involved in sample collection to submit DNA for comparison in the event of cross-contamination and
All bags containing samples for analysis would be bagged and labelled appropriately to prevent cross contamination and ensure they are handled and stored correctly
Post-Excavation
On completion of excavations samples will be transported to nominated laboratories for analysis A record of their location will be kept
43 Reporting
The results of the investigation of human remains and the exhumation will be included in the archaeological reporting for the project in accordance with the project AARD
Once finalised all archaeological excavation and data analysis reports will be submitted to
The relevant local Council and Library
The Heritage Office Library
The State Library of NSW and
Made available online for public access and educational purposes
Further if significant remains are identified during excavations the results and findings would be published in academic journals and conference papers where feasible
44 Public Involvement
Archaeological excavations may uncover remains directly associated with early settlement and burial practices Such remains are likely to generate public interest
Public involvement may include
Media releases
Public Open Days
Preparation of brochures detailing the archaeological excavations
Interpretive signage and online blog posts or site diaries while excavations are taking place and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The preparation of a Heritage Interpretation Plan designed to provide interpretation of the site within the new development upon the completion of works
Due to sensitive nature of human skeletal remains these recommendations would be adapted and modified as appropriate under the direction of Sydney Metro and the Excavation Director
Such recommendations would also be considered and require approval from relevant Stakeholder Groups such as known or potential descendants of the deceased NSW Heritage Heritage Council local Council and interest groups
45 Temporary Storage and Permanent Repository or Resting Place for Remains
Temporary Storage
Upon the completion of archaeological excavations skeletal remains should be boxed separately and temporarily stored within a safe secure and temperature controlled environment to allow for further analysis of the remains This location would be chosen by the Excavation Director and the Forensic Anthropologist and comply with NSW legislative requirements
Permanent Repository or Resting Place for Remains
A permanent repository or resting place for remains is dependent on the nature and volume of skeletal remains As this cannot be determined prior to excavations taking place the following recommendations should act as guidelines only Final arrangements would be dictated by Sydney Metro the Excavation Director Forensic Anthropologist identified descendants of the deceased andor Stakeholder Groups upon the completion of excavations and subsequent analysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
5 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined inhttpsicentraltdocstransportnswgovauotcscsexeappnodes3574566
6 Related Documents and References
Related Documents and References
na
7 Superseded Documents
Superseded Documents
Exhumation Management Plan Version 22
Exhumation Management Plan Version 30
8 Document History
Version Date of approval Notes
11 May 2017 New IMS document
20 July 2017 Incorporates Stage 2 (Section 3)
21
February 2019
Extended for Metro Program wide application includes changes specific Central Station management incorporates comments received from the State Coronerrsquos Office NSW Police NSW Health Sydney Metro Environmental Environmental Representatives engaged on the Central site and the Office of Environment and Heritage
22 February 2019 Incorporates comments received from Artefact Heritage and Denise Donlan issued to Health and OEH HD for consultation
30 May 2019 Incorporates Health Coroner and OEH comments
40 April 2020 Updates to remove specific references to City and South West and Central Station
Change of title to ldquoProcedurerdquo
Update to references
9 Schedule of Acronyms
Acronym Meaning
AARD Archaeological Assessment and Research Design
ACHAR Aboriginal Cultural Heritage Assessment Report
AMS Archaeological Method Statement
CSSI Critical State Significant Infrastructure
ER Environmental Representative (Independent)
ExMP Exhumation Management Plan (this plan)
OEH Office of Environment and Heritage
PHU Public Health Unit
RAPs Registered Aboriginal Parties
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Appendix 1
NSW Heath Policy Directive for Exhumation of Human Remains
Policy Directive
Ministry of Health NSW 73 Miller Street North Sydney NSW 2060
Locked Mail Bag 961 North Sydney NSW 2059 Telephone (02) 9391 9000 Fax (02) 9391 9101
httpwwwhealthnswgovaupolicies
Exhumation of Human Remains
Document Number PD2013_046
Publication date 05-Dec-2013
Functional Sub group Population Health - Environmental
Summary This document provides the policy to be observed by NSW Health in receipt of an application to seek permission for approval of the exhumation of human remains under clauses 69-72 of the Public Health Regulation 2012 This Policy Directive will provide the conditions on which approvals may be granted for exhumation of human remains
Replaces Doc No Burials - Exhumation of Human Remains [PD2008_022]
Author Branch Environmental Health
Branch contact Environmental Health 94245823
Applies to Local Health Districts Environmental Health Officers of Local Councils Ministry of Health Public Health Units Public Hospitals
Audience Authorised officers from Public Health Units and local councils
Distributed to Public Health System Environmental Health Officers of Local Councils NSW Ambulance Service Ministry of Health Public Health Units Public Hospitals
Review date 05-Dec-2018
Policy Manual Patient Matters
File No 081292
Status Active
Director-General
This Policy Directive may be varied withdrawn or replaced at any time Compliance with this directive is mandatory for NSW Health and is a condition of subsidy for public health organisations
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 1 of 2
EXHUMATION OF HUMAN REMAINS
PURPOSE
This document provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Common reasons for exhuming bodies include to repatriate the remains overseas or to relocate the body to another cemetery plot or vault
MANDATORY REQUIREMENTS
Under Clause 69 of the Public Health Regulation 2012 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General
An application for approval to exhume the remains of the body of a dead person may be made to the Director General by
An executor of the estate of the dead person
The nearest surviving relative of the dead person
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person may make the application
An application is to be made in the approved form and it is to be accompanied by
A certified copy of the death certificate relating to the dead person
A statutory declaration as to the relationship of the applicant to the dead person and the dead persons wishes if any regarding the disposal of his or her body
An application fee
Under Clause 71 of the Public Health Regulation 2012 the Director-General may
Grant an approval to exhume the remains of a body
Refuse the application
Under Clause 72 an exhumation cannot take place without an authorised officer or a Ministry of Health staff member present A person must not proceed with an exhumation if the authorised officer or Ministry of Health staff member who is present at the exhumation orders the exhumation to stop
Under Clause 78 if the applicant seeks to have the exhumed body cremated a separate application can be made for an exemption from providing the required cremation documentation provided the body has been buried for longer than 10 years The minimum 10 year period is strictly enforced An application under this clause is to be accompanied by a fee of $100
IMPLEMENTATION
Authorised officers in Public Health Units of Local Health Districts are responsible for assessing applications for exhumation of human remains and either approving with a set of conditions or rejecting the application Authorised officers should ensure that all of the required document has been submitted with the application fee and that an appropriate person has applied for the application The approval granted is valid for a period of three months after the approval is granted
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 2 of 2
REVISION HISTORY
Version Approved by Amendment notes
December 2013 PD2013_046
Deputy Director- General Population and Public Health
This document is an updating of the original document due to legal changes under the Public Health Regulation 2012
23 April 2008 PD2008_022
Director-General This document provided the policy to be observed by NSW Health in receipt of an application to seek permission for approval of exhumation of human remains under clauses 25 ndash 28 of the Public Health (Disposal of Bodies) Regulation 2002 It provided the conditions upon which approvals could be granted for the exhumation of human remains
ATTACHMENTS
1 Exhumation of Human Remains Procedures
Exhumation of Human Remains PROCEDURES
Issue date December-2013
PD2013_046
Exhumation of Human Remains
Issue date December-2013 PD2013_046 Contents Page
PROCEDURES
CONTENTS
1 BACKGROUND 2
11 Introduction 2
12 Key definitions 2
13 Legal and legislative framework 3
2 APPLICATION REQUIREMENTS 6
3 APPROVAL BY PUBLIC HEALTH UNITS 7
31 Delegation 7
32 Special Considerations on Exhumation Approval 7
33 Conditions of Approval 8
34 Approval Instrument 8
35 Notification of Approval 8
36 Refusals 8
37 Cremation of Remains 8
APPENDIX 1 10
APPENDIX 2 11
APPENDIX 3 12
APPENDIX 4 13
APPENDIX 5 14
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 2 of 14
1 BACKGROUND
11 Introduction
Exhumation of human remains may occur for a number of reasons including
To satisfy family wishes where the family of the deceased person may want the remains to be moved to another burial ground to another part of the state or country or abroad or even to have the remains cremated
To obey Coronial orders requiring exhumation for forensic (criminal) investigation
To enable the use of closed cemeteries for redevelopment or for the construction of new infrastructure such as a road or airport
A variety of people including authorised officers cemetery authorities and funeral directors are involved at different stages of exhumation procedures
Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation however there is no obligation to proceed with an exhumation once it has been approved
The objectives of this document are
To assist authorised officers with processing applications to exhume
To standardise the management of an exhumation so as to prevent a public health risk and protect community amenity in the handling of remains
12 Key definitions
These definitions are repeated from the Public Health Act 2010 and Public Health Regulation 2012 for clarity
Body Means the body of a dead person but does not include
the cremated remains of the person
Burial Includes putting the body in a vault
Cemetery Authority Means the person or body that directs the operations of a cemetery
Coroner Means a person who exercises or performs the functions of a coroner in accordance with the Coroners Act 2009
Dead person Includes a still-born child (see definition of Still birth)
Exhumation Means the removal of a dead personrsquos remains (not being cremated remains) from a grave or vault but does not include their removal from one vault for immediate transfer to another vault in the same cemetery or their temporary removal for the purposes of reburial in the same grave or vault
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 3 of 14
Funeral director Means a person (other than the operator of a mortuary transport service) who in the conduct of the personrsquos business engages for the purpose of burial cremation or transport in the collection transport storage preparation or embalming of bodies or engages in the conduct of exhumations
Prescribed infectious diseases
Means any one of the following diseases avian influenza in humans diphtheria plague respiratory anthrax smallpox severe acute respiratory syndrome tuberculosis and any viral haemorrhagic fever (including Lassa Marburg Ebola and Congo-Crimean fevers)
Proper person The Director General has the power to decide whether a person is a lsquoproper personrsquo to make an application to exhume the remains of a dead person
Nearest surviving relative
Means (a) In relation to a still-born child a parent or sibling at or above the age of 16 years of the child (b) In relation to a dead person who is not a still-born child ndash the spouse or de facto partner of the dead person immediately before death a parent of the dead person a child at or above the age of 16 years of the dead person or any relative of the dead person who was residing with the dead person when he or she died
Still-birth Consistent with the Births Deaths amp Marriages Act 1995 means the birth of a child that exhibits no sign of respiration or heartbeat or other sign of life after birth and that (a) Is of at least 20 weeksrsquo gestation (b) If it cannot be reliably established whether the period of gestation is more or less than 20 weeks has a body mass of at least 400 grams at birth
13 Legal and legislative framework
Public Health Regulation 2012
Division 4 of Part 8 of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies
Clause 69 Exhumation without approval prohibited
(1) A person must not exhume the remains of a body unless the exhumation of those remains has been
(a) Ordered by a coroner
(b) Approved by the Director-General
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 4 of 14
(2) However a funeral director may without a coronerrsquos order or Director-Generalrsquos approval transfer a coffin from a vault in a cemetery to a mortuary for the purpose of the coffin being immediately repaired and returned to the vault
(3) A funeral director must return the coffin to the cemetery within 24 hours of its transfer
Clause 70 Application to exhume remains
(1) An application for approval to exhume the remains of the body of a dead person may be made to the Director-General by
(a) An executor of the estate of the dead person
(b) The nearest surviving relative of the dead person
(c) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances may make the application
(2) An application is to be made in the approved form and is to be accompanied by
(a) A certified copy of the death certificate relating to the dead person
(b) A statutory declaration as to the relationship of the applicant to the dead person and the dead personrsquos wishes if any regarding the disposal of his or her body (so far as any such wishes are known to the applicant)
(c) An application fee (please check with the PHU for the current fee)
(3) In this clause death certificate means a certificate given by a medical practitioner as to the cause of death or issued under the Births Deaths and Marriages Registration Act 1995
All applications to exhume remains must be made in writing using an approved form to the Director of the local Public Health Unit that acts on behalf of the Director-General of the NSW Ministry of Health The application fee may increase periodically in line with the Consumer Price Index
Clause 71 Approval to exhume remains
(1) The Director-General may
(a) Grant an approval to exhume the remains of a body subject to any conditions specified in the approval
(b) Refuse the application
(2) An approval granted under this clause remains valid for three months from the date of the approval or for a period agreed to by the Director-General
The PHU is not bound to approve the application The PHU may approve subject to conditions or refuse the application An approval is normally given for 3 calendar months and this date will be specified in a schedule of conditions attached to the approval document Any further extension of time may require re-application and re-approval An approval initially for longer than three calendar months should be negotiated with the PHU
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 5 of 14
Clause 72 Exhumation not to take place without authorised officer present
(1) A person must not proceed with an exhumation unless an authorised officer or a member of staff of the Ministry of Health is present at the exhumation
(2) A person must not proceed with an exhumation if the authorised officer or Ministry staff member who is present at the exhumation orders the exhumation to stop
The grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer An authorised officer must be present at the exhumation to ensure that the correct interment is opened to ensure that all of the remains are exhumed and to enforce the protection of public health should this be necessary The authorised officer has the power to order that the exhumation be stopped immediately under adverse circumstances An example of where this may occur is where the weather is very poor with heavy rain The initial order to stop is to be given verbally and then confirmed in writing to all parties involved within 24 hours
Division 5 of Part 8 of the Public Health Regulation 2012 provides for cremation of deceased persons
Clause 78 No cremation without documentation
Clause 78 does not apply to a cremation of the body of a dead person that has been buried for at least 10 years if the cremation is carried out in accordance with an exemption granted by the Director-General following an application by
1) An executor of the estate of the dead person
2) The nearest surviving relative of the dead person
3) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
This is a new addition to the Exhumation section of the Regulation that may be used where a person makes a separate application to have the exhumed body cremated following the exhumation
Note The Director-Generalrsquos authority under Clause 78 (4) of the Public Health Regulation 2012 (Delegations Manual page 866 delegation (PH590)) is the power to decide whether a person is a ldquoproper personrdquo to make an application in the absence of an executor or surviving relative
Work Health and Safety Act 2011
The Work Health and Safety Act 2011 and Code of Practice for Excavation provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation The Work Health and Safety Act 2011 makes reference to working in confined spaces
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 6 of 14
WHampS matters are enforced by WorkCover NSW More information on safe work practices is available at httpwwwworkcovernswgovaudefault or by contacting Workcover NSW direct on 13 10 50
Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977 applies to relic burials Any burial site over 50 years old is considered to be relic under the Heritage Act If the site is listed on the State Heritage Register then approval is required from the Heritage Council of NSW
An application must be made to the Heritage Office before any disturbance removal or work commences on the site Approval for an exhumation under the Public Health Regulation 2012 does not obviate the necessity to obtain approval under the Heritage Act 1977 For further information contact the Heritage Office of NSW or visit httpwwwheritagenswgovau
Coronerrsquos Act 2009
A coroner may order an exhumation for the purposes of forensic investigation or a criminal investigation Such an order is outside the ambit of the Public Health Regulation 2012 The Police may request that an authorised officer from the Ministry of Health or the local Public Health Unit be present at the coronial exhumation
Births Deaths and Marriages Registration Act 1995
Section 41(2) of the Births Deaths and Marriages Registration Act 1995 requires that if human remains (other than cremated remains) are removed from NSW the funeral director or other person who arranges for the removal of the remains from NSW must within 28 days of disposal of the remains outside NSW give the Registrar notice of the new location of interment The act is available at httpwwwaustliieduauaulegisnswconsol_actbdamra1995383 The Registry of Births Deaths and Marriages may be contacted via httpwwwbdmnswgovau
2 APPLICATION REQUIREMENTS
An application for permission to exhume the remains of a deceased person is to be made to the PHU on the approved form which is contained at the NSW Ministry of Health website at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c70- application-to-exhumepdf
The application must be made by either
An executor of the estate of the deceased
The nearest surviving relative
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 7 of 14
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
The application must be accompanied by
A certified copy of the death certificate (death certificate issued by the Registry of Births Deaths and Marriages)
A statutory declaration that states
The relationship between the applicant and the deceased or the reason the applicant is the proper person to make the application
If the deceased left any instructions regarding the disposal of their bodyremains if known
In addition to the above an applicant should declare that he or she has consulted each nearest surviving relative and that they have no objection to the proposed exhumation
An application fee (please check with the PHU for the current fee)
Note If there is no agreement amongst nearest surviving relatives the applicant should seek independent legal advice regarding this issue The applicant should advise if there is an intention to cremate the body following the body being exhumed and the appropriate form completed
3 APPROVAL BY PUBLIC HEALTH UNITS
Approval by PHUs for an exhumation must be given by formal correspondence
31 Delegation
The Director-Generalrsquos authority under clauses 69(1) 70(1)(c) and 71 of the Public Health Regulation 2012 has been delegated to the Chief Health Officer Director Health Protection Public Health Officer or Public Health Unit Director as appointed under Section 121 of the Act (delegation PH308 PH309)
32 Special Considerations on Exhumation Approval
Special consideration should be given to the approval of an exhumation if the deceased was infected with a prescribed infectious disease For example if the deceased was infected with diphtheria or tuberculosis exhumation should not permitted in the first year of interment
Although not prohibited an exhumation of the remains of a body that was buried without a coffin will be approved only where the cemetery authority and funeral director have agreed to proceed with the exhumation especially during the first three years of interment
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 8 of 14
33 Conditions of Approval
After due consideration of the application and the statutory declaration(s) the PHU should then consider applying appropriate conditions to facilitate an approval
There are two standard sets of approval conditions which can be applied as appropriate
Appendix 2 ndash Schedule A - Conditions of Approval for Exhumation from a Grave
Appendix 3 ndash Schedule B - Conditions of Approval for Exhumation from an Above Ground Structure
Any other additional conditions that are deemed necessary to permit the exhumation may be added to schedule A or B based on the individual circumstances of the exhumation If some conditions are unwarranted they may be removed from the relevant schedule
34 Approval Instrument
An approval must be in writing and must be signed the Director General or their delegate A template to assist in the approval process can be found at Appendix 4 This template is to be completed by the Authorised Officer in order to facilitate approval by the delegate
35 Notification of Approval
The approval instrument is retained on file as a record that approval was granted by the Director General or their delegate Therefore it is necessary to advise the applicant the cemetery authority and the funeral director of the approval
The attached letter templates may be used for approval notification of the exhumation to the applicant funeral director and Cemetery Authority
Appendix 5 ndash Sample Letter to Applicant
Appendix 6 ndash Sample Letter to the Cemetery Authority and Funeral Director
36 Refusals
If after due consideration the application is to be refused then the applicant should be notified in writing specifying the reasons for refusal Ideally the applicant should consult the PHU in the first instance to discuss the requirements and possible restrictions on an application to exhume
37 Cremation of Remains
Division 5 of Part 8 of the Public Health Regulation 2012 sets out the requirements for documentation for cremations in NSW and includes the requirement for a cremation application form a cremation certificate and the cremation permit The documentation confirms the identity of the body to be cremated and the cause of death and ensures that a coronerrsquos investigation has been conducted where necessary
After the body is exhumed the next of kin may wish to have the body cremated However there may be cases whereby the body does not have the required paperwork necessary for cremation Clause 78 of the Public Health Regulation 2012 provides an exemption for
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 9 of 14
the required documentation for cremation where the body has been buried for longer than 10 years An application under this clause is to be accompanied by a fee
The Director General has the power to approve an exemption and the executor or the nearest surviving relative or another proper person may make application on form lsquoApplication for Exemption by the Director ndash General to the Requirement for Documentation for Cremation to Proceed Permission for Cremation of Exhumed Remains of a Body Buried more than 10 years ago with statutory declarationrsquo The minimum 10 year period will be strictly enforced and this matter should be clarified prior to any exhumation approval where it is planned for the remains to be subsequently cremated The application form is available at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c78-application-for- exemptionpdf
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 10 of 14
APPENDIX 1
Schedule A
CONDITIONS OF APPROVAL FOR EXHUMATION FROM GRAVE
1 The exhumation is to be carried out in the presence of a Public Health Unitrsquos authorised
officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Day and time of the exhumation shall be arranged by the participating parties and agreed
to by the Public Health Unit
4 The approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The presence of any relative of the deceased at the exhumation is strictly prohibited
6 No animals are to be permitted within the exhumation site
7 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
8 If during the course of the exhumation it is determined necessary to stop the exhumation
by either the exhumation supervisor cemetery manager or authorised Officer for any valid reason eg work health and or public health risk then the exhumation must cease
9 The remains of the deceased shall be enclosed in a body bag and placed into a new coffin
with a name plate attached inscribed with the name of the deceased
10 The remains of the original coffin are to be placed in the new coffin where possible Where there is an excess of remains of the original coffin these remains should be disposed in a sanitary and agreed manner
11 Excavated soil should be back filled The soil that was removed from immediately above
and around the coffin should be replaced first
12 If the exhumed remains are to be transferred to another cemetery a funeral director shall be contracted to transfer the remains from the cemetery grounds or carry out preparatory work for the safe reinterment of the remains
13 The exhumation will not proceed during or following a period of heavy rainfall within the preceding 24 hours of the appointed time of exhumation The cemetery manager is to confirm that satisfactory conditions exist for the exhumation to proceed two hours prior to the commencement of the exhumation
14 Used disposable protective equipment and materials are to be placed in a sealed plastic
bag and disposed of in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 11 of 14
APPENDIX 2
Schedule B
CONDITIONS OF APPROVAL FOR EXHUMATION FROM ABOVE GROUND STRUCTURE
1 The exhumation is to be carried out in presence of a Public Health Unit authorised officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Date and time of the exhumation shall be arranged by the participating parties and agreed to
by the Public Health Unit
4 An approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
6 If during the course of the exhumation it is determined necessary to stop the exhumation by
either the exhumation supervisor Cemetery Manager or authorised officer if for any valid reason eg worker health andor public health risks then the exhumation must cease
7 Used disposable protective equipment and materials are to be placed in a sealed plastic bag
and disposed in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 12 of 14
APPENDIX 3
LETTERHEAD
APPROVAL INSTRUMENT TEMPLATE
Public Health Unit Environmental Health Section
File Number [XXXXX]
PURPOSE To approve of the exhumation of the late
RECOMMENDATION
Approval is granted by the Director General pursuant to clause 71(1)(a) Public Health Regulation
2012 to [NAME OF APPLICANT] to exhume the remains of the late [NAME OF DECEASED]
KEY ISSUES
[DETAILS OF THE APPLICATION STATUTORY DECLARATION RELEVANT ISSUES
MANAGEMENT PLAN AND JUSTIFICATION OF SUGGESTED CONDITIONS ARE TO BE
INCLUDED HERE]
BACKGROUND (TO BE COMPLETED BY PHU)
CONSULTATION (TO BE COMPLETED BY PHU WHERE APPROPRIATE)
The approval be subject to compliance with the conditions specified in Schedule A Schedule B
and to expire on
Signature Authorised officer
Author Telephone Date
1 Authorised officer
2 Public Health Unit Director Public Health Officer [SIGN AND DATE]
Approved via delegation from the Director-General PH308 PH309 page 863 Public
Health Delegations Manual under clause 69(1) and 70(1) (C) Public Health Regulation
2012
3 Authorised officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 13 of 14
APPENDIX 4
LETTERHEAD
SAMPLE LETTER TO APPLICANT
[APPLICANTrsquoS NAME] [ADDRESS]
Dear [APPLICANTrsquoS NAME]
Reference is made to your application of [DATE] requesting approval to exhume the remains of
late [NAME OF DECEASED] from grave vault crypt No Section [NAME OF
PLACE OF INTERMENT OR CEMETERY] for the purpose of re-interment to [NAME OF PLACE
FOR RE-INTERMENT]
Approval has been granted by the Director-General pursuant to clause 71 (1) (a) Public Health
Regulation 2012 subject to compliance with the conditions specified in Schedule A Schedule B
attached
The funeral director and cemetery authority have been advised of the approval
Should you have any inquiries please contact the authorised officer [EHO] on [TELEPHONE] or (EMAIL ADDRESS)
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 14 of 14
APPENDIX 5
LETTERHEAD
SAMPLE LETTER TO CEMETERY AUTHORITY AND FUNERAL DIRECTORS
[NAME] [ADDRESS]
[DATE]
Dear [NAME]
EXHUMATION OF THE REMAINS OF THE LATE [NAME OF DECEASED]
Approval has been granted for the exhumation of the late [NAME OF DECEASED] from grave
vault crypt No Section [NAME OF PLACE OF INTERMENT OR
CEMETERY] in accordance with clause 71(1) (a) of the Public Health Regulation 2012 and
subject to compliance with the conditions specified in Schedule A Schedule B attached
A copy of the approval letter is attached for your information
Should you have any inquiries please contact [Authorised Officer) on [TELEPHONE] or email address
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
Unclassified
Addendum 2
NSW Heath Permit Application form
copy Sydney Metro 2017 Page 23 of 24
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
APPLICATION TO EXHUME REMAINS PUBLIC HEALTH REGULATION 2012 Clause 70(2)
In accordance with the requirements of Clause 70 (2) of the Public Health Regulation 2012 I helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Full name of applicant)
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip hereby (Address)
apply for permission to exhume the remains of the late helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Name of deceased)
from Grave Nohelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Section helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip being a single
interment within the helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipCemetery for the purpose of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
I seek permission to exhume for the following reasons
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
The deceased (cross out which is not applicable)
was not known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012 or
was known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012
I am entitled to make this application because I am (tick one)
1 [ ] The executor of the estate of the deceased or
2 [ ] The nearest surviving relative of the deceased or
3 [ ] If there is no such executor or relative available to make the application another the proper person to make the application for the reasons set out below
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Full reasons for proper person to make application) Attached is
1 A certified copy of the death certificate of the deceased
2 A statutory declaration as to
My relationship to the deceased and
the wishes of the deceased regarding the disposal of the body (if known)
the reasons why the Director-General may consider me the proper person in all the circumstances to make the application (if applicable)
3 The application fee of $helliphelliphelliphelliphelliphelliphellip
Signature helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Date helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Applicant)
The exhumation is to be supervised in strict accordance with the attached Plan of Management
by helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
employed with helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip(Funeral DirectorCemetery)
in the capacity of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
Form C70
Unclassified
copy Sydney Metro 2017 Unclassified Page 24 of 24
ExMP v30 (final)
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
bttp wwwshd nsw gay auQQpulat onhealthPubtic Healthhtml
NSW
Public Health Unit ll iI I
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 57 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise gaseous and particulate pollutant emissions from construction activities as far as feasible and reasonable Identify and control potential dust and air pollutant sources
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Site related dust identifiable fumes odours and vapours will not infringe beyond site boundaries where practical
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required for air quality and dust management including - Correct use of PPE - Use of monitoring equipment - Methods to control dust
Project Manager
Greenhouse Gases
Regular maintenance of plant and equipment for optimum performance will be undertaken to keep emissions to a minimum and increase plant productivity
Vehicles and equipment must be fitted with appropriate emission control equipment and routinely maintained Plant should be switched off when not in use wherever practicable
All plant equipment and vehicles are to be regularly monitored and maintained and records kept of maintenance Engine tampering to increase power output is prohibited
Air emissions from plant vehicles and equipment should be visually monitored throughout construction
Comply with National Greenhouse Emission Reporting Scheme (NGERS) reporting requirements
Project Manager
Dark Smoke
All internal combustion engines will be regularly serviced to ensure optimum operation and minimise the volume of visible smoke emitted Any Plant or light vehicles emitting unreasonable smoke (concentrations higher than normal operation) will cease operation and be serviced by a trained and qualified technician
Materials on site will not be burned intentionally without consulting and obtaining the authorisation of the relevant Local Shire Fire Authority and Client The burning of any material on site should be a last option after alternative methods have been considered
All
Dust Monitoring
The following dust monitoring methods will be applied on the Site
Obtaining weather reports from the Bureau of Meteorology (BOM) website Visual inspection
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 58 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Dust Control
Dust control methods to be applied on the site to keep dust generated within the site boundaries as reasonably practicable will be
- Wind fencing around the site or between the site and local residences - Application of waterdust suppressant via water carts - Hydro mulching to stabilise soils - Physical application of ground cover - Cessation of works in adverse weather conditions - Restricted speed limits on site - Reschedule dust generating activities to avoid adverse weather conditions - Communicate dust risk and mitigation measures to staff prior to commencing work
All
Fumes Odours and Vapours
The Site will endeavour to keep the generation of emission of unreasonable levels of fumes odours and vapours to a minimum Refer to the Waste Management Sub Plan and Hydrocarbon and Chemical Environmental Management Sub Plan which detail storage and handling controls that minimise fumes odours and vapours
All
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for dust mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 59 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise unreasonable noise and vibration impacts on residents and businesses Avoid structural damage to buildings or heritage items as a result of construction vibration Undertake active community consultation Reduce visual impact of construction to surrounding community Maintain positive cooperative relationships with schools childcare centres local residents and building owners
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Community
The nearest noise and vibration sensitive receivers will be notified of future works and expected levels of noise and vibration well in advance of the works occurring Notifications will be in accordance with the Community Communications Strategy
Information will be provided to the affected community before and during construction through media such as letterbox drops meetings or individual contact A website will also be established for the project to provide information
A toll-free 24hour project hotline will be provided for enquiries and complaints during the works
Sydney Metro and Georgiou Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the site specific management required
for noise and vibration including
- Sensitive receivers - Hours of works - Correct use of plant and equipment - Monitoring requirements
Standard hours of construction
Approved standard hours of construction are Monday to Friday
7 am to 6 pm Saturday 8 am to 1 pm No work on Sundays or public holidays
Project Manager
Out of Hours works Any out of hourrsquos works will require a noise assessment and approval by Sydney Metro through the out of hourrsquos application (Appendix 7A)
Project Engineer Environmental Site Representative
Plant Equipment amp Vehicles
All operators of plant will comply with requirements of the Construction Traffic Management Plan in relation to parking and laydown access and egress to site haulage routes and general site traffic movements
Plant will be fitted with appropriate noise emissionvibration control equipment Plant will be fitted with adequate seat suspension
Plant Department
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 60 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Plant should be switched off when not in use wherever practicable Tasks using equipment that causes vibration to hands will be rotated at intervals to reduce
exposure Consideration may be given to the use of anti-vibration PPE All plant equipment and vehicles are to be regularly monitored and maintained and records kept
of maintenance Any abnormalities in expected noise or vibration emissions will be recorded in the plantrsquos log
book and reported to the plant department Prioritise the use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of
rockbreakers for demolition of structures Use of smaller capacity rockbreakers or lower vibration generating rockbreakers Consider methods of isolating the vibration sensitive structure from the vibration intensive work
area by severing the vibration transmission path using non-vibration intensive means such a sawing
Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Monitoring
Continuous vibration monitoring will be undertaken whenever vibration generating plant will be working close to or within the recommended minimum working distances
When conducting vibration monitoring within or near the minimum working distances a warning system will be implemented including one or both of an audible andor visual warning alarm andor SMS andor email alerts to site staff
Attended noise monitoring will occur at the nearest noise sensitive receiver when - Requested by Sydney Metro - When noise levels are predicted to exceed the NML by more than 10dBA - When out of hours works continue past midnight - When noise complaints are received
Noise monitoring will determine if the predictions in the noise assessment were accurate
Project Engineer Environmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for noise and vibration mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 61 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7A ndash Sydney Metro Out of Hours Application form
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 1 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Out of hours work application form
This form is to be used for formal review and approval of out of hours (OOH) work as it may affect Residential and non-residential receivers This form can be used in accordance with the SM-17-00005396 City amp Southwest out of hours work protocol Each OOH application and all applicable appendices must be submitted to Sydney Metro as one PDF file at least 15 business days prior to the commencement of the proposed OOH work
1 OOH Application
Sydney Metro Project
Eg City amp Southwest Greater West West etc
Contract
Contractor
Application Title
Eg lsquoSmith St service relocation worksrsquo
Application Number
Eg 1 2 3 etc
Application Date
Original submission date (resubmission date in parentheses if applicable)
Relevant Planning Approval
Environment Protection Licence (EPL)
If subject to an EPL state title and number
2 Proposed OOH Work Details
Description of works including
Work methodologies
List of plantequipment to be used (worst case scenario)
Location Map (andor Environmental Control Map) attached as Appendix 1 indicating location of works plantequipment locations and receivers (including distance to nearest receiver for noisiest plantequipment)
Traffic Management Plan andor Traffic Control Plan if applicable as Appendix 2
Timing of works
Including proposed datestimes works are planned to be undertaken outside standard hours
Worst-case number of consecutive occasions affecting the same receiver
Refer to Section 4 for definition of lsquooccasionrsquo
Justification
Demonstrate how the proposed OOH work has been scheduled in accordance with the OOH work period prioritisation list Program acceleration is generally not accepted as a justification
Unless specified otherwise in project-specific documentation the prioritisation of work time periods is as follows
Standard Hours 7am to 6pm weekdays and 8am to 1pm Saturdays (note that Standard Hours for works subject to the City amp Southwest Sydenham to Bankstown planning approval also include 1pm to 6pm Saturdays)
Daytime OOH 1pm to 6pm Saturdays and 8am to 6pm Sundays and Public Holidays
Evening OOH 6pm to 9pm every day
Night Time OOH 9pm to 7am weekday mornings and 9pm to 8am weekend and Public Holiday mornings
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Assessed Noise and Vibration Impacts and Standard Mitigation Measures
Are the proposed works consistent with a prepared Construction Noise amp Vibration Impact Statement (CNVIS) (YN)
If lsquoNrsquo skip this section and move to Section 4
State the title of the CNVIS and attach the section(s) describing the noise and vibration impacts of the proposed works as Appendix 3
Quantitatively summarise the worst-case predicted noise and vibration impacts specific to the proposed OOH work for each OOH period on the nearest receivers and compare these against the respective management levels
For Night Time OOH Period works include a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Worst-case predicted noise impact summary
Worst-case predicted vibration impact summary
Potential sleep disturbance summary (for night time OOH periods only)
Using Table 4 and Table 5 indicate in Table 6
Which Additional Mitigation Measures (AMMs) are applicable for consideration
Which of those applicable for consideration are planned to be implemented
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered respite alternative accommodation etc)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
4 Non-Assessed Noise and Vibration Impacts
Skip this section if Section 3 has been completed in full
A quantitative noise assessment for OOH work is to be carried out in accordance with the Interim Construction Noise Guideline (DECC 2009) This section allows applicants to address these requirements through the following steps
1) Establishing Rating Background Levels (RBLs) and Noise Management Levels (NMLs)
2) Predicting the anticipated noise levels using a quantitative noise assessment
a Works that are not likely to generate high noise impacts for a significant duration may use a preliminary quantitative noise assessment (facilitated within this form) This ensures that all applications as a minimum include a preliminary quantitative noise assessment in accordance with the Interim Construction Noise Guideline (ICNG)
b Works that are likely to generate high noise impacts for a significant duration may require a detailed quantitative noise assessment (eg Construction Noise and Vibration Impact Statement) to be undertaken
c Works that are likely to generate ground-borne or structure-borne vibration andor noise require specialist advice and assessment
3) Comparing predicted noise levels against RBLsNMLs and applying standard mitigation measures as appropriate (ie implementing lsquoall feasible and reasonablersquo mitigation measures in accordance with the ICNG)
4) Considering additional mitigation measures when predicted noise levels exceed RBLsNMLs
The need for a detailed quantitative noise and vibration assessment will be considered by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable) collectively when the predicted noise levels are anticipated to
Exceed an RBL at a residential receiver or an NML at a non-residential receiver by more than 10dBA AND
Affect the same receiver on 10 or more consecutive occasions An occasion is anytime works are carried out
o Between 6pm on a weekday and the start of standard hours the next day OR
o Between 1pm on a Saturday and 8am on a Sunday (or between 6pm on a Saturday and 8am on a Sunday for works subject to the Sydenham to Bankstown planning approval) OR
o Between 8am on a Sunday or public holiday and the start of standard hours the next day
A detailed quantitative noise and vibration assessment should generally include
Derivation of RBLs for residential receivers andor derivation of NMLs for non-residential receivers based on noise monitoring at representative locations and local sensitivities
Detailed noise predictions for daytime evening and night time OOH periods (as applicable) in accordance with Section 45 of the ICNG (including an outline of timing duration and predicted noise levels for each OOH period)
For Night Time OOH Period works a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Detailed predictions of vibration levels for sensitive receivers
Please complete the following Steps 1 to 4
Step 1
RBLsNMLs
If RBLs for residential receivers or NMLs for non-residential receivers have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment or Construction Noise and Vibration Impact Statement for other work activities) enter into Table 3 and attach the supporting evidence as Appendix 3
If no RBLsNMLs have been established use Table 1 to estimate and enter into Table 3
Step 2
Predicted Anticipated Noise Levels
If predicted anticipated noise levels have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment) enter the predicted anticipated noise levels into Table 3 and attach the supporting evidence as Appendix 3
If predicted anticipated noise levels have not already been established use Table 2 to estimate anticipated noise aspects for the noisiest plantequipment and enter into Table 3 In Table 3 use these values to calculate the anticipated predicted noise levels
Step 3
Exceedances and Mitigation Measures
Compare the anticipated predicted noise levels to the applicable RBLsNMLs calculate the exceedances and enter into Table 3 In Section 5 provide a description of the standard mitigation measures that are planned to be implemented in order to mitigate the noise impacts (and vibration impacts if relevant) as much as lsquofeasible and reasonablersquo in accordance with the ICNG
Step 4
Consideration of Additional Mitigation Measures
Use Table 4 and the exceedances in Table 3 to determine the applicable Additional Mitigation Measures for consideration Use
Table 6 to indicate which of these measures are applicable for consideration which will be implemented and provide justificationdetails accordingly
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
5 Standard Mitigation Measures
Outline the standard noise mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Outline the standard vibration mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Table 1 Noise RBLs and NMLs
Skip this section RBLs and NMLs have already been established in other documentation
Sensitive Receiver Category Estimated RBLs (dBA)
Residential Daytime OOH Evening OOH Night Time OOH
Urban (eg city hubs near busy roads near industrial activity) 55 50 45
Suburban 45 40 35
Quiet rural or isolated 40 35 30
Non-Residential ICNG NMLs (dBA)
Industrial facilities 75 (only applicable when in use)
Offices or retail 70 (only applicable when in use)
Health and educational facilities 55 (only applicable when in use)
Table 2 Predicted Noise Level Aspects
Skip this section if predicted noise levels have already been established in other documentation
Noise Aspect Select the most applicable value for each noise aspect below and enter into Table 3 dBA
1 PlantEquipment Noise Level at 10m
Including non-continuous use reduction (-5dBA) and annoying activity penalty (+5dBA) for as per ICNG (refer to ICNG Appendix B for predicted noise level data)
Underline indicates vibratory generating plantequipment
Impact sheet piling rig 100
Hand-held tamper excavator with hammer rock-breaker drivenvibratory piling concrete saw diamond saw air track drill large dozer hand-held rail grinder
95
Jackhammer rock crusher angle grinder pneumatic hammer medium dozer tracked loader impact wrench
90
Mainline tamper ballast regulator dynamic track stabiliser vibratory roller mainline rail grinder ballast train (pourfill ballast) chainsaw tub grinderlarge mulcher scraper grader super-suckervacuum truck large backhoewheeled front-end loader bored piling pavement profiler fixed crane tracked excavator
85
Small bulldozer small excavator tower crane truck-mounted crane forklift bobcat skid-steer front-end loader road trucktruck and dog dump truck concrete truckpumpmixer compressor non-vibratorylarge pad foot roller whacker packercompactor water cart pavement laying machine asphalt truck and sprayer line marking truck standard penetration testing welder pin puller
80
Concrete vibrator cherry-picker scissor liftelevated work platformFranna crane small backhoe front end loader fence post driver electric drill rig hand held rattle gun generator (dieselpetrol) spreader
75
Lighting tower medium-rigid trucksemi-trailer welding equipment small front end loader 70
Light vehicle hand-tools (no impact) small cement mixer attenuated generator (inside housing)
65
2 Multiple Plant More than one of the noisiest plant being used simultaneously at roughly the same location +5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Local Screening
Existing screening between site and receiver (buildings cuttings canopies etc) - 5
Temporary screening to be implemented near work site - 10
Acoustic shed or enclosure - 25
4 Distance Attenuation
lt 10 metres 0
10 to 20 metres - 5
20 to 35 metres - 10
35 to 60 metres - 15
60 to 100 metres - 20
100 to 180 metres - 25
180 to 350 metres - 30
350 to 1000 metres - 40
Table 3 Predicted Noise Levels and Exceedances of RBLs andor NMLs (dBA)
Skip this section if Section 3 has been completed in full
Period
(only complete as applicable for each period)
Noisiest PlantEquipm
ent
(state the noisiest
plantequipment to be used during each applicable
OOH period)
Receiver Type
(state lsquoResrsquo or lsquoNon-Resrsquo as applicable for
closest receiver to noisiest
plantequipment)
Enter the most applicable values from Table 2 then add to determine
the Predicted Noise Level
Pre
dic
ted
No
ise L
evel
(1 +
2 +
3 +
4)
RB
L (
for
Res)
NM
L (
for
Non-R
es)
Exceedance
(Predicted Noise Level minus RBL for Res or NML for
Non-Res) 1
Pla
nt
Eq
uip
me
nt
No
ise L
evel
2
Mu
ltip
le
Pla
nt
Eq
uip
me
nt
3
Lo
cal
Scre
en
ing
4
Dis
tan
ce
Att
en
ua
tio
n
Daytime OOH
Evening OOH
Night Time OOH
Refer to OOH period timings under Section 2 of this form
Table 4 Additional Mitigation Measures (AMM) requiring Consideration for Implementation
OOH Period
AMMs that must be considered for implementation
(apply the exceedances from Table 3 to the two OOH period categories below as applicable)
lt= 10 dBA Exceedance
10 to lt= 20 dBA Exceedance
20 to lt= 30 dBA Exceedance
gt 30 dBA Exceedance
Daytime OOH Period ndash LB M LB M IB LB PC RO SN
Evening and Night Time OOH Periods
ndash M LB M IB LB PC SN RO M IB LB PC SN RO AA
AA is only applicable to Night Time OOH periods
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 5 List of Additional Mitigation Measures (AMM)
AMM Abbrev
AMM AMM Descriptions and Guidance
LB
Letterbox-drop
(generic to the project)
A newsletter is generally produced and distributed to the local community via letterbox-drop and the project mailing list These newsletters provide an overview of current and upcoming works across the project and other topics of interest The objective is to engage inform and provide project-specific messages The geographic extent of letterbox-drops is generally centred on the immediate surrounding community within 200 metres from the works site
For works that are subject to the Sydenham to Bankstown planning approval these will include an indicative schedule of likely OOH work for at least the upcoming two month period
M Monitoring
Where it has been identified that specific construction activities are likely to exceed the relevant Rating Background Levels (RBL) andor Noise Management Levels (NMLs) monitoring may be conducted at the affected receiver(s) or a nominated representative location (typically the nearest receiver where more than one receiver have been identified) Monitoring can be in the form of either unattended logging or operator attended surveys The purpose of monitoring is to inform the relevant personnel when the RBLNML has been exceeded so that additional management measures may be implemented
IB Individual Briefings
Individual briefings are used to inform stakeholders about the impacts of high noise activities and mitigation measures that will be implemented Communications representatives would visit identified stakeholders at least 48 hours ahead of potentially disturbing construction activities Individual briefings provide affected stakeholders with personalised contact and tailored advice with the opportunity to comment on the project
PC Phone calls
(andor emails)
Phone calls andor emails (with specific notifications attached) detailing relevant information would be made to identifiedaffected stakeholders within seven days of proposed work The objective of the phone calls andor emails is to support letterbox-drop and specific notifications Phone calls andor emails provide affected stakeholders with personalised contact and tailored advice with the opportunity to provide comments on the proposed work and specific needs
SN
Specific Notifications
(specific to the OOH work)
Specific notifications are letterbox-dropped to identified stakeholders no later than 7 days prior to out of hour construction activities commencing that are likely to exceed the RBLsNMLs Specific notifications may be produced by Sydney Trains or by Sydney Metro (or on behalf of Sydney Metro by a contractor as approved by Sydney Metro)
- Sydney Trains specific notifications cover all works being undertaken by various parties (including Sydney Metro) during designated rail possession periods These specific notifications are delivered 14 days prior to works commencing and are delivered to all properties located within 250m of the proposed works
- Sydney Metro specific notifications focus on proposed Sydney Metro works being undertaken outside of designated rail possession periods and are only produced in the absence of any Sydney Trains notifications covering the proposed works These notifications are delivered 7 days prior to works commencing and are delivered to all properties located within 100m of day works and within 200m of night works
All notifications are emailed to all registered stakeholders on site-specific email distribution lists
For works that are subject to the Sydenham to Bankstown planning approval these will include indicative information on the type of OOH work location duration expected noise characteristics expected noise level and likely mitigation and management measures
RO Respite Offer
The purpose of a project specific respite offer is to provide residents subjected to lengthy periods of noise andor vibration impacts respite during OOH periods Respite offers are offers made to affected receivers to provide a period of either no or limited noise impacts This can be in the form of stopping or limiting works onsite or offering affected receivers dinnermovie vouchers The first priority is to implement a period of no or limited noise impacts If this cannot be achieved dinnermovie vouchers may be offered on a case-by-case basis
AA Alternative
Accommodation (residential only)
Alternative accommodation options may be provided for residents living in close proximity to construction works that are likely to incur unreasonably high impacts during night time OOH periods Alternative accommodation will be considered on a case-by-case basis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 6 Consideration of Additional Mitigation Measures (AMM)
Additional Mitigation Measures
Applicable for Consideration
YN
(refer to Table 4)
To be Implemented
YN
JustificationDetails
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered RO AA etc)
LB
M
IB
PC
SN
RO
AA
For OOH work that is subject to the Sydenham to Bankstown approval and RO is required for consideration include in the lsquoJustificationCommentsrsquo column how community consultation influenced the decision to implement or not implement RO in accordance with Condition E23 If RO is being implemented include how community consultation influenced the manner in which RO is being implemented
6 Consideration Against Relevant Vibration Criteria
Using Table 2 indicate whether any vibratory plantequipment is planned to be used for the proposed works (YN)
If lsquoNrsquo skip this section and move to Section 7
lsquoPeoplersquo Criterion
Are the proposed works anticipated to have any perceptible sleep disturbance impacts (YN)
lsquoStructuresrsquo Criterion
Are the proposed works anticipated to generate greater than 75mms vibration impacts on surrounding structures (generally within 25 metres of works) (YN)
lsquoSensitive Equipmentrsquo Criterion
Are the proposed works anticipated to impact sensitive equipment located in surrounding non-residential receivers (YN)
If lsquoYrsquo is answered to ANY of the above criteria AND the impacts affect the same receiver for more than one consecutive occasion (refer to Section 4 for lsquooccasionrsquo definition) the need to prepare a detailed quantitative assessment will be considered collectively by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
7 City amp Southwest Construction Noise amp Vibration Strategy Addendum Mitigation Measures
If the proposed OOH work is part of the City amp Southwest project identify any mitigation measures to be implemented that have arisen from the City amp Southwest Construction Noise amp Vibration Strategy Addendum
8 Cumulative Impacts
Document the relevant details of any other OOH work (Sydney Metro or otherwise) that will impact the same receivers as those being impacted by these proposed works either concurrently or within 3 days of the start or end of these proposed works
If other works have been identified in the row above how have the proposed works been coordinated to ensure appropriate respite is provided
9 Community Consultation
What community consultation has been undertaken already
What community consultation is planned to be undertaken
If drafted already attach applicable Community Notification as Appendix 4
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
10 Contractorrsquos Signature
Contractorrsquos Identification of Risk Level
If subject to the Chatswood to Sydenham (C2S) or Sydenham to Bankstown (S2B) planning approval and not subject to an EPL provide Contractorrsquos Identification of Risk Level (refer to the City amp Southwest OOH Works StrategyProtocol for guidance)
Circle LOW or HIGH
Contractorrsquos Signature
Name
Title
Contact Number
Date
11 Contractorrsquos Contact Details
Contractor Personnel Name Mobile
Manager Environment
Manager Communications
Contractorrsquos Representative
Contractorrsquos 24hr contact person
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
C2SS2B Planning Approval Determination Page
Step 1 ndash Endorsement from Sydney Metro Director Public
Communications or Contractorrsquos Communications Manager
Step 2 ndash Risk IdentificationEndorsement from the AA under the C2S Planning Approval or from the
ER under the S2B Planning Approval
Step 3 ndash If works are under Sydney Trains EPL approval from Sydney Metro Director of Planning Environment and Sustainability
If works are not under an EPL approval from either the ER or the Secretary of the NSW Department of Planning amp Environment
Risk Level NA
If not subject to an EPL circle Risk Level as LOW or HIGH
If works are HIGH Risk Level and after 9pm Sydney Metro submits application to the Secretary of the
NSW Department of Planning amp Environment for approval
NA
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Role
Date
Comments
(including AAER Risk Level comments if applicable)
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Generic Determination Page (ie not subject to C2S or S2B planning approvals)
Step 1 ndash Sydney Metro Director of
Project Communications
Step 2 ndash Acoustic Advisor
(may be optional depending on planning approval or contract requirements)
Step 3 ndash Environmental Representative
(may be optional depending on planning approval or contract requirements)
Step 4 ndashSydney Metro Director of Planning Environment amp Sustainability
(only required if not approved already)
Action Endorsement Circle Endorsement or Approval Circle Endorsement or Approval Approval
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Date
Comments
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 12 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 1 Location Map (andor Environmental Control Map)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 13 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 2 Traffic Management Plan andor Traffic Control Plan
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 3 Supporting Evidence for Noise amp Vibration Impacts (eg Construction Noise amp Vibration Impact Statement noise assessment etc)
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 15 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 4 Community Notification
(if applicable and already drafted)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 62 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Any site contamination will be effectively managed to limit the potential risk to human health and the environment Spoil will be managed to avoid contamination of land or water Prioritise reuse of contaminated spoil into the project rather than offsite reuse or disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Planning and assessment
Planning
The Golders Douglas Partners contamination assessment report (June 2020) considered investigation results and data from previous relevant Sydney Metro West (SMW) investigations in the general area The physical characteristics of the soil on site as determined by the above report is described as ldquofill material described as containing evidence of anthropogenic materials including ash gravels terracotta tile fragments bricks and glass In addition to this sandstone bedrock was regularly encounteredsuspected to be present (eg drilling method refusal) during the pavement investigation This evidence implies that there is a wide variety of soil types and materials across the Site associated with natural and historical anthropogenic related activities The findings included elevated concentrations of heavy metals (copper nickel zinc) encountered at one location on the Site and several within close proximity to the Site However the exceedances were considered to pose a low risk to ecological receptors given that the majority of the Site is covered in asphalt hardstand with very low potential for exposure to subsurface soils Elevated concentrations of BaP were encountered in several boreholes within close proximity to the Site Once again the risks to ecological receptors from these were considered low due to the presence of asphalt hardstand at the Site Asbestos was identified at one borehole SMW_BH415 at a depth of 05 m The laboratory reported that chrysotile was detected below the reporting limit of 01 gkg The report considered due to the location access nature of the ACM (bonded) that there is a low risk of exposure to potential receptors Should the soil not be able to be reused on site further sampling assessment and waste classification must occur for any soil that is to be disposed offsite in accordance with the Sydney Metro Waste Classification Procedure (Appendix 1A)
Project Manager HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 63 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Unexpected finds of contamination onsite
In the event that contamination is identified on site Appendix 8A will be followed for soil contamination excluding Asbestos material For unexpected Asbestos Finds Appendix 8B will be followed
Supervisors All workers
Assessment
If any potential contamination is discovered during construction the soil will be excavated and transported to the stockpile area for assessment which may include sampling by a suitably qualified environmental consultant
The assessment must consider whether the material is suitable to return to site for reuse with consideration to the final land use and pathways and receptors for the contaminants
Laboratory testing associated with the assessment will be prioritised to 24 hour turnaround to mitigate any delay where required
The assessment detailing the type extent and management options for the contaminated soil must be provided to Sydney Metro before proceeding to either reuse or dispose of material
For unexpected Asbestos finds the controls listed in the section below must be followed before any excavation and transport to stockpile or offsite
Project Manager Supervisor Environmental scientist
Asbestos management measures
Access Restrictions
Signs and barriers will be erected to warn of the danger and to prevent unauthorised people entering areas where asbestos contaminated fill material is being excavated handled
The location and extent of any access control areas will be agreed in discussion between the Project Manager Project Engineer HSE Advisor and the Environmental Coordinator and will be established in accordance with NOHSC2002 (2005) Code of Practice for the Safe Removal of Asbestos (2nd Ed) guidelines
Potential entry points to the asbestos work area should be signposted or labelled in accordance with AS 1319 (1994) Safety Signs for the Occupational Environment and NOHSC 2002 (2005b)
Earthworks Engineers Licenced removal contractor Supervisors
Asbestos Removal
For unexpected Asbestos finds the Certified Occupational Hygienist will conduct a risk assessment to demine Air monitoring requirements and any other PPE and management controls prior to removal (see air monitoring section)
All removal procedures for asbestos should be undertaken under the supervision of an appropriately licensed contractor which is either ASA or ASB depending on the material being removed The removal of material shall be monitored by a relevantly trained supervisor in accordance with the Code of Practice for the Safe Removal of Asbestos [NOHSC 2002 (2011)]
You must be licensed to remove asbestos except if removing 10 square metres or less of non-friable asbestos
Engineers Certified Occupational Hygienist Licenced removal contractor
Workcover notification Permit to Work
A permit to work authority will need to be issued to and signed by the contractor Workers engaged in the removal of asbestos on site will not be issued with a permit to work unless
Engineers Licenced removal contractor
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
they are employed by a company holding a removal licence issued by WorkCover NSW appropriate for the type of asbestos materials concerned
Workcover must be notified at least five days prior to commencement of asbestos removal work
Safe Work Method Statement and Asbestos Removal Plan
All notification and permit applications for removal of asbestos in soils must be accompanied by a site risk assessment (Asbestos Removal Plan) carried out by a competent or licensed person who determines If the asbestos is bonded or friable The extent of contamination A safe work procedure for the remediation of the site
Engineers Licenced removal contractor
Dust Control
In order to remove the asbestos safely we shall be using the ldquowet methodrdquo to carry out these works The wet method includes continuously keeping the soil with asbestos fragments watered so as to eliminate the asbestos dustfibres becoming airborne An exclusion zone of 10m (or whatrsquos appropriate ndash depending on limitations) will be isolated from the rest of the site using fencing or bunting Any personnel that do not have the correct PPE or relevant training will not be allowed in this area
Supervisors Earthworks Engineers
Clearance
Following the excavation and removal of asbestos contaminated material a licenced asbestos assessor will conduct inspections and sampling (where required) in the excavation to confirm that no asbestos remains A clearance report will be issued and works can recommence in the area
Licenced Asbestos Assessor
All potential contaminated finds
Training
A toolbox must occur for all worker for unexpected contamination finds procedure They will also be informed of the Site specific controls required for management of contamination in soil Site access restrictions Correct use of PPE Decontamination procedures Use of monitoring equipment Waste handling procedures Dust control measures and performance measures
all workers
Stockpile Contingency Measures
The following contingency measures will be put in place should stockpiling of potential contaminated soils be required All potential contaminated stockpiles will be separated by lot numbers and sign posted to
avoid any cross contamination Any temporary stockpiles of asbestos contaminated soil will be maintained under moist
conditions and remain covered at all times Sediment controls will be installed downslope of all contaminated soil stockpiles In order to confirm that all contaminated soil has been removed an Environmental
Consultant (ADE) will conduct a visual inspection or sampling of the material below the
Supervisors Earthworks Engineers
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 65 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
stockpile and provide a clearance certificate or the like as legislated The Environmental Consultant will advise of the validation criteria dependant on the contamination of the soil
Material tracking for contaminated finds assessed as suitable for onsite reuse
Where suspected contaminated material is identified the material will be tracked from the area in which the material was identified to its location in stockpile (lot number)
For all material assessed as suitable for reuse onsite the material will be tracked from its stockpile location to final destination for reuse onsite Survey will determine the m3 and the location of the final destination
All materials movements associated with unexpected contamination finds will be recorded on the materials tracking register
Supervisors Earthworks Engineers
Waste classification for materials assessed unsuitable for onsite reuse
Waste classifications are required for any excavated soil or fill material which is to be disposed off-site Soil or fill material to be taken off-site for disposal shall be assessed in accordance with the waste classification guidelines (NSW EPA 2014) Materials excavated from the site should be tracked from lsquocradle to graversquo in order to provide detailed and accurate information about the location and quantity of all materials from the time of their excavation until their disposal For any truck or bin leaving the site the following information would be recorded origin of material material type waste classification report approximate volume truck andor bin registration number Receiving licenced facility For all soils known or having the potential to contain asbestos the following applies The POEO Act defines lsquoasbestos wastersquo as any waste that contains asbestos including
fragments or fibres It is understood that as a result the NSW EPA considers asbestos contaminated soil to be an asbestos waste In addition the Protection of the Environment Operations (Waste) Regulation 2014 provides certain requirements for the transportation of asbestos It is understood that the NSW EPA requires any management of soil containing asbestos waste on or off the site to be at least equal to controls set out by the Regulation
All asbestos contaminated soil or fill leaving site will be transported in a leak proof covered vehicle and disposed of at a licensed facility in accordance with waste classification guidelines (NSW EPA 2014)
Earthworks Engineers Licenced removal contractor ESR
Environmental Monitoring amp records
Air Monitoring
If asbestos removal work that requires a Class A licence that means it is friable then you must get the licensed asbestos assessor occupational Hygienist to undertake air monitoring of the asbestos removal area Monitoring for airborne asbestos in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres
Earthworks Engineers Licenced removal contractor Hygienist
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 66 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
[NOHSC 3003(2005)] the analysis should be carried out by a NATA accredited laboratory during the removal operations Refer to Clause 50 and 51 for the WorkCover 2011 Safety Regulation for requirements
For other contaminated soil the occupational hygienist may determine that the risks associated with their disturbance and handling requires air monitoring
Record Keeping
The records associated with management of contaminated land that should be kept include Material tracking register including lots volume and type Asbestos Removal Plan (ARP) Asbestos Register Airborne Monitoring Reports Calibration certificates for air monitors Clearance Inspection Reports or Certificates Waste classification reports Laboratory sampling results Landfill disposal dockets
Earthworks Engineers ESR HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 67 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8A ndash Unexpected Contamination finds procedure
1 Introduction
The following unexpected contaminated finds procedure will be adopted in the event that potential contamination
is discovered during construction Implementation of this procedure will ensure that contamination is managed in
such a way as to avoid harm to the environment workers community and comply with relevant legislation
2 Identification of Contamination
An unexpected find of contamination is likely to comprise of any soil characteristic which is not a typical soil
material identified in previous contamination assessment reports The Golders Douglas Partners contamination
assessment report (June 2020) section 102 makes note of indicators of contamination as
Significant staining
Odours from Soils
Oily sheen on water leaving soils
Anthropogenic waste materials other than those identified in the report (ie Ash Gravels Terracotta Tile
Bricks and Glass)
Where the soil characteristics are consistent with the reports and the above indicators are not present then no
further assessment is required for onsite reuse
Examples of these indicators are shown below
Photo 1 - Significant Staining or odorous soils
Discoloured soil (soil with non-natural colouring) Pungent smelling soils - petroleum compost
putrefied sulphurous septic sweet aromatic odours
Photo 2 ndash Oily Sheen on water
Rainbow sheen on water surfaces in soil
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Photo 3 ndash Buried wastes
Buried oil drums chemical container
Photo 3 ndash Buried wastes
Buried demolition wastes (eg concrete tiles bricks asphalt timber metal
3 Potential risk areas of unexpected finds
The higher risk activities for encountering unexpected finds during construction activities are considered to be
excavation works that extend below road pavement layers and into general fill
Higher risk areas for encountering unexpected finds construction are considered to be
Areas of excavation that extend through general fill layers and into natural soils eg Stormwater trench
locations
Locations of excavation near previous Boreholes with identified contamination (see map below)
GC-HSE-PLA-437 Uncontrolled when saved or printed
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12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
4 Unexpected finds flow chart
If potentially contaminated soils are encountered the following steps must be followed
During excavationif visual indications of contamination are present such as significant stained soils
odorous soils sheen tarry or ashy material or unexpected anthropogenic material (other than what is
expected to be encountered on site) then
STOP EXCAVATION in the immediate affected area
Notify the Supervisor Environmental Site Rep and Client
Environmental consultant to conduct assessment on material to determine suitability for reuse onsite This
step may require sampling and lab analysis ndash undertake with quick 24hr turnaround
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No Yes
Sample test and classify in
accordance with Appendix
1A ndash Sydney Metro Waste
Classification procedure
Contact environmental consultant and hygienist and provide details of the find Depending on the nature and type
of the find they may be required to attend site before any further excavation disturbance
Excavate the material to the extent of the potential contamination in 200mm thick layers and in 500mm
horizontal increments (Do not exceed design excavation extents) and move to stockpile area (Where it will be
allocated a lot number and signposted to avoid any cross contamination) For Asbestos follow specific
requirements in the unexpected Asbestos Finds Procedure Cover the stockpile and install controls around the
stockpile
Offsite disposal at licenced
landfill facility Maintain all
waste tracking and disposal
records
No
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
5 Materials Tracking
A Material tracking Register will be used to ensure information is collected for unexpected finds materials
identification and traceability This register records all unexpected finds materials The material is carefully
inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location and type of soil stored onsite
at the stockpile area The material class and stockpile number on the map will correspond with the information in
the register
6 Stockpile Management
The following contingency measures will be put in place should stockpiling of suspected contaminated soils be
required
All suspected contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Sediment controls will be installed downslope of all suspected contaminated soil stockpiles
7 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential contamination onsite as detailed in previous contamination assessment reports and this unexpected finds
procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works
Prior to commencement of each shift the Supervisor will inform all site personnel of any works involving
contaminated materials on site
8 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 8B ndash Unexpected Asbestos finds procedure
1 Introduction
The following Asbestos Management procedure will be adopted in the event that potential asbestos containing
material (ACM) or actual asbestos is uncovered during construction Implementation of this procedure will ensure
that asbestos is managed in such a way as to avoid harm to site personnel visitors and the community
2 Areas of known asbestos contamination
No asbestos was identified with the footprint of the proposed road construction works However there was one
Borehole (BH 415) from previous contamination assessments adjacent to the boundary that identified asbestos at
05m bgs The laboratory result was chrysotile detected below the reporting limit of 01 gkg (see location on map
below)
3 Identification of Asbestos
Asbestos has been used in the manufacturing of various products and these products can be found in either friable
or non-friable form All products are also known as asbestos-containing material Friable asbestos products are
generally quite loose and when dry can be crumbled into fine material or dust with light pressure such as
crushing with your hand
Non-friable asbestos products are made from a bonding compound (such as cement) mixed with a small proportion
(usually less than 15) of asbestos Non-friable asbestos products are solid rigid and non-friable and cannot be
crumbled pulverised or reduced to powder by hand pressure The asbestos fibres are tightly bound in the product
and are not normally released into the air When theyre in good condition non-friable asbestos products do not
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normally release any asbestos fibres into the air They are considered a very low risk for people who are in contact
with them as long as appropriate safety precautions are used when they are disturbed Non-friable asbestos
products that have been damaged or badly weathered may also become friable for example crushed asbestos
cement sheeting Examples of non-friable and friable asbestos are shown below
Photo 1 ndash example of non-friable asbestos in soil This is Asbestos cement sheeting that although broken it is solid rigid and cannot be crumbled or pulverised by hand pressure
Photo 2 ndash example of friable asbestos ndash this was a section of Asbestos cement sheeting that is weathered and crumbles under hand pressure
Photo 3 ndash example of non - friable asbestos ndash Asbestos cement water pipe in good condition
Photo 4 ndash example of friable asbestos ndash water pipe wrapped with friable woven ACM textile
4 Unexpected Asbestos ACM finds flow chart
In the event that a person on site identifies or disturbs asbestos ACM the unexpected asbestos management
procedure during Construction is summarised below
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Discovery of suspected asbestos containing materials
STOP EXCAVATION in the immediate affected area Demarcate and isolate area from workers
Notify the Supervisor
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next
step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No
Sample test and classify
in accordance with
Appendix 1A ndash Sydney
Metro Waste Classification
procedure
Yes
Friable Non Friable
Proceed with Licenced
Asbestos removal work in
accordance with section 6 -
11 Remove to stockpile for
reuse assessment by
Environmental Consultant
No
Greater than
10m2 of non-
friable asbestos
contamination
Less than 10m2 of
non-friable
asbestos
contamination
Proceed with non-
licenced asbestos
removal and
disposal in
accordance with
section 5
Trained and competent person to identify the asbestos
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5 Non Licence Asbestos removal work
Where small fragments of ACM or suspected ACM are found and provided that
the total number of fragments is lt 20 or
the total surface area of the fragmentpiece is lt 1 m2 or
the fragments are spread over an area of lt 10 m2 and
the fragments are non-friable
If the unexpected find meets the criteria above a trained and competent person will collect any fragments and
place it in a 200 mm polythene bag for later disposal at an appropriate waste facility A detailed visual inspection
of the area will be carried out by the Environmental consultant which will involve wet raking of the areas to a
depth of 10 cm for any further fragments If no further fragments are identified works can continue
If during the visual inspection the Environmental consultant determines that the criteria described above are
exceeded or if suspected asbestos ACM continues to be identified during excavation works andor if it is thought
that any uncovered material might be considered asbestos containing and friable works will cease and the
Environmental consultant will assess the situation and determine an appropriate course of action
6 Licenced Asbestos removal work
A licensed asbestos removalist will be required for removal works where there is friable asbestos or the
contaminated area is greater than 10 m2 There are two types of asbestos removal licences Class A and Class B
The type of licence required depends on the type and quantity of asbestos or ACM to be removed as outlined
below
Licence type What asbestos can be removed
Class A Can remove any amount or quantity of asbestos or ACM including any amount of friable asbestos or ACM any amount of asbestos-contaminated dust or debris (ACD) Any amount of non-friable asbestos or ACM
Class B Can remove
any amount of non-friable asbestos or ACM Note A Class B licence is required for removal of more than 10 m2
of non-friable asbestos or ACM but the licence holder can also remove up to 10 m2 of non-friable asbestos or ACM
ACD associated with the removal of non-friable asbestos or ACM Note A Class B licence is required for removal of ACD associated
with the removal of more than 10 msup2 of non-friable asbestos or ACM but the licence holder can also remove ACD associated with removal of up to 10msup2 of non-friable asbestos or ACM
No licence required Can remove
up to 10 m2 of non-friable asbestos or ACM ACD that is associated with the removal of less than 10 m2 of non-friable
asbestos or ACM Not associated with the removal of friable or non-friable asbestos
and is only a minor contamination
The licensed asbestos removalist will prepare an Asbestos Removal Control Plan prior to the removal of any
asbestos ACM The Asbestos Removal Control Plan documents the specific control measures to be implemented to
ensure site personnel and others are not at risk when asbestos removal work is being conducted It includes how
the asbestos removal will be carried out including temporary storage the method tools equipment and PPE to be
used and the asbestos ACM to be removed including the location type and condition of the asbestos ACM
The Client will be informed prior to excavation or removal of asbestos or ACM If the removal activity is to occur in
the vicinity of any occupied residence or business the project Community Advisor will notify the affected
residents or business owners
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7 Signage and demarcation
Georgiou will install warning signs and labels to clearly identify asbestos affected areas and where asbestos related
work is being carried out Flagging will be installed to delineate the asbestos related areas and restrict
unauthorised persons from entering the asbestos removal work Stockpiles will be covered and labelled Signage
and flagging will stay in place until all licensed asbestos removal work is complete and a clearance certificate is
provided
8 Notification
Prior to the commencement of licensed asbestos removal works notification to SafeWork NSW is required
SafeWork NSW requires a minimum of 5 daysrsquo notice prior to the removal of asbestos and the notification will be
made by the licensed asbestos removalist
9 Air Monitoring
All air monitoring requirements will be determined and conducted by a licensed asbestos assessor (LAA) The
location and layout of the air monitors will be detailed within the Asbestos Removal Control Plan
Air monitoring requirements will vary depending on the type of asbestos being removed the location and position
of the asbestos The following rules should be applied when determine if air monitoring is required (extract from
Safe Work Australia ndash Code of Practice on How to Safely Remove Asbestos (2016)
For friable asbestos removal ndash Air monitoring is mandatory for all friable asbestos removal This includes prior
to dismantling an enclosure and for the purposes of the clearance inspection
For more than 10 msup2 of non-friable asbestos removal ndash Air monitoring is not required but may be considered to
be carried out by a licensed asbestos assessor or competent person to ensure compliance with the duty to
eliminate or minimise exposure to airborne asbestos and to ensure the exposure standard is not exceeded
Public Location ndash Air monitoring should be considered where the asbestos removal work is being undertaken in
or next to a public location
Exposure air monitoring ndash Air monitoring should be carried out at other times to determine a workerrsquos exposure
to airborne asbestos if based on reasonable grounds there is uncertainty as to whether the exposure standard
may be exceeded and a risk assessment by a competent person indicates it is necessary Since most uses of
asbestos are prohibited exposure monitoring should not be required frequently
The results of air monitoring will be made available as soon as possible to all workers on site The asbestos
supervisor will be notified immediately if the fibre count exceeds the recommended level in the Exposure
Standards for Asbestos as set out in the National Code of Practice How to safely remove asbestos
10 Clearance
Following removal of asbestos ACM the licensed asbestos removalist will arrange for a clearance inspection of the
area to facilitate the issue of a clearance certificate and allow construction to recommence in the affected area
The clearance inspection is conducted by
an independent licensed asbestos assessor for work that was carried out by a Class A licensed asbestos
removalist
an independent competent person for asbestos work that is not required to be carried out by a Class A licensed
asbestos removalist
To be independent the licensed asbestos assessor must not be involved in the removal of asbestos for that specific
job and is not involved in a business or undertaking involved in the removal of the asbestos for that specific job
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A clearance certificate will be issued if the independent licensed asbestos assessor or competent person is satisfied
that the asbestos removal area and the immediate area are free from visible asbestos contamination Entry to the
area will be permitted following confirmation of certification
11 Decontamination
Decontamination of site personnel PPE and tools used in asbestos removal work will minimise exposure and spread
of asbestos outside of the removal area
Personal decontamination will occur every time a worker leaves the asbestos removal work area and involves
removal of all visible asbestos dustresidue from PPE and Respiratory Protective Equipment using an asbestos
vacuum cleaner and or wet wiping with a damp cloth Disposable PPE is considered asbestos waste and will be
disposed of at an appropriate waste facility Non-disposable protective clothing will be laundered in a suitable
laundering facility that is equipped to launder asbestos-contaminated clothing
Workers must be aware of personal hygiene and ensure that they carefully wash when leaving an asbestos removal
area paying particular attention to hands fingernails face and head
Tools will be dismantled (where appropriate) cleaned under controlled conditions and decontaminated prior to
removal from the area or disposed of at a suitable off site location
12 Stockpile Management
The following contingency measures will be put in place for any temporary stockpiling of asbestos contaminated
soils
All asbestos contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Any temporary stockpiles of asbestos contaminated soil will be maintained under moist conditions and remain
covered at all times
Sediment controls will be installed downslope of all contaminated soil stockpiles
In order to confirm that all contaminated soil has been removed validation sampling beneath stockpiles will
occur by an Environmental Consultant
13 Asbestos contaminated soil for reuse onsite
Stockpiled asbestos containing soils will be assessed for beneficial re-use with the Site (NEPC 2013) Any soils
identified to contain asbestos with concentrations of bonded ACM less than the NEPC (2013) Health Screening Level
(HSL)-D applicable for the future commercial industrial land use could be reused onsite providing the following
Placement in a designated location preferably beneath a road alignment or other suitably capped area (min
300 mm lsquocleanrsquo (ie ENMVENM soils) to eliminate any potential airborne exposure pathway
Occupational hygienist and asbestos removalists on-site supervising relocation and placement
Maintenance of an Site Asbestos Register to record the extent nature of the ACM materials retained or
identified on-site
Any other requirements by Sydney Metro such as adherence to the CEMP etc and or land conditions
A Long-term Environmental Management Plan to manage the presence of asbestos impacted materials remaining
on-site would be required if the proposed soils to be re-used are exceeding the HSL-D limits for non-friable or
friable asbestos
If stockpiled soils are identified to contain any detectable concentrations of Friable asbestos material is
recommended to be disposed off-site given its friable nature
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14 Waste disposal
Where the ACM is assessed as non-suitable for onsite reuse the licensed asbestos removalist will classify and dispose
of the ACM at a licensed asbestos waste disposal site in accordance with NSW EPA guidelines (including Waste
Classification Guidelines (EPA 2014)) and relevant industry codes of practice
Disposal of ACM will be to an approved asbestos waste facility listed on the NSW EPA website The transportation of
asbestos waste by trucks must comply with the following requirements
Transporter must have the appropriate EPA license to transport asbestos waste
Asbestos contaminated soils are wetted down
Any part of any vehicle in which a person transports asbestos waste is covered and leak proof during
transportation
Georgiou will notify the Client prior to removal of ACM from site and will provide details of the proposed method
and location of disposal Georgiou will maintain records of all asbestos ACM disposed off site the location of the
facility at which it was disposed and any receiptcertificate issued by the facilitydisposal authority
15 Materials Tracking
A Material tracking Register will be used to ensure information is collected for the movement of all asbestos
contaminated soils The material is carefully inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
and testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location of asbestos contaminated soil
stored onsite at the stockpile area The stockpile number on the map will correspond with the information in the
register
16 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential risks associated with asbestos management locations of asbestos as detailed in previous contamination
assessment reports and this unexpected finds procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works and include the unexpected asbestos finds procedure Prior to commencement of each shift the Supervisor
will inform all site personnel of any works involving contaminated materials on site
17 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure
Unclassified
Unclassified
Environmental Incident and Non-
compliance Reporting Procedure SM-17-00000096
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Manager Environment
System Owner Executive Director Safety Sustainability amp Environment
Status FINAL
Version 51
Date of issue 18 February 2019
Review date 11 February 2020
copy Sydney Metro 2019
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table of contents 1 Purpose and scope 4
2 Introduction 4
3 Definitions 4
4 Accountabilities 5
5 Environmental Events 5
51 Worked Example ndash Classifying Environmental Events 7
511 Soil and Water Issue 7
512 Soil and Water Non-compliance 7
513 Soil and Water Incident 7
52 Notifiable Events 8
53 Event Types 8
6 Environmental Incident Classification and Management 10
61 Incident Classification 11
611 Class 3 Incidents 11
612 Class 2 Incidents 11
613 Class 1 Incidents 12
62 Incident Notification 12
621 Principalrsquos Representative (PR) 12
622 Environmental Lead (EL) 13
63 Incident Notification Reports 14
64 Incident Investigations 14
65 Environmental Incidents with Health and Safety Impacts 14
66 Reporting Pollution Incidents to Relevant Authorities 15
661 Maritime Related Incident Notification and Reporting 16
67 Environmental Compliance Register 16
7 Environmental Non-compliance 17
71 Non-compliance Rate 17
8 Corrective and Preventative Actions 18
81 Action Status 18
9 Related Documents and References 19
10 Superseded Documents 19
11 Document History 19
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Figures Figure 1 Environmental Event Classification Process 6 Figure 2 Environment Incident notification process for Class 1 and 2 Incidents 13
Tables Table 1 Examples of Notifiable Events 8 Table 2 Environmental Event Types and their descriptions 9 Table 3 Examples of Environmental Incidents 10 Table 4 Classification System for Environmental Incidents 11 Table 5 Contact details for Relevant Authorities 15
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 19
Environmental Incident and Non-compliance Reporting Procedure
1 Purpose and scope
This procedure documents the process to be used when classifying and reporting Environmental Events
This procedure applies to Sydney Metro and any contractor Sydney Metro engages to carry out works Principal Contractors must ensure their processes for managing Environmental Events is consistent with this document The requirement for consistency is documented in the Construction Environmental Management Framework (Section 33(f)) and shall be allocated as a contractual requirement to each delivery partner
2 Introduction
Sydney Metro is committed to minimising risks to the environment the rapid identification and rectification of breaches to Environmental Requirements and efficient and effective responses to Environmental Incidents that grows our ability to minimise harm and prevent future re-occurrences
This procedure defines an approach to classifying Environmental Issues Incidents and Non-compliances and establishes the immediate interim and long term actions that are taken in response to Environmental Events
3 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition with the following exceptions
Term Definition
Environment
means components of the earth including
a) land air and water and
b) any layer of the atmosphere and
c) any organic or inorganic matter and any living organism and
d) human-made or modified structures and areas and includes interacting natural ecosystems that include components referred to in (a)-(c)
Environmental Event
An occurrence that identifies actual or potential environmental impacts or non-compliances Events cans include conversations inspections incidents or failures of process
Environmental Harm Includes any direct or indirect alteration of the environment that has the effect of degrading the environment and without limiting the generality of the above includes any act or omission that results in pollution
Environmental Incident
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Environmental Issue An occurrence or set of circumstances where Environmental Harm or Non-compliance could occur if not rectified
Environmental Non-compliance
A breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Term Definition
Material Harm to the Environment
harm to the environment is material if
a) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
b) it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding $10000 (or such other amount as is prescribed by the regulations) and
c) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent mitigate or make good harm to the environment
It does not matter that harm to the environment is caused only in the premises where the pollution incident occurs
Terms and jargon specific to this procedure are defined within the Sydney Metro Glossary
4 Accountabilities
The Executive Director Safety Sustainability amp Environment is accountable for this Procedure Accountability includes authorising the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
The Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document if specified in the relevant contracts
5 Environmental Events
Environmental surveillance data is relied upon to inform Sydney Metro of performance trends to provide assurance that legislative requirements are being met and indicate where surveillance activities should be directed In order to rely upon environmental data for this purpose there needs to be a high degree of consistency in the manner by which it is collected and interpreted Due to the need for consistency any incidentNon-compliance procedure produced by a delivery partner to Sydney Metro is required to be consistent with the requirements of this document
The concept of Environmental Events forms a common starting point for understanding what types of occurrences should be managed and reported as Incidents and what should be reported as Non-compliances or Issues When an Environmental Event occurs a series of questions can be asked to consistently determine what type of event it is Commonly Environmental Events lead to three different processes
1 Reporting of an Environmental Incident
2 Reporting of an Environmental Non-compliance or
3 Reporting of an Environmental Issue
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Incidents and Non-compliances are recorded using the Environmental Incident and Non-compliance Report Form (SM ES-FT-403) and Environmental Issues are recorded through environmental inspection reports using the Environmental Inspection Information amp Summary Form (SM ES-FT-406) These paper based records are subsequently entered into the Sydney Metro Compliance Register (Section 67) which is used to disseminate the data and facilities reporting internally and externally Note where a Principal Contractor has submitted alternative processes and these have been approved by Sydney Metro they may also be used
The figure below shows the process by which Environmental Events are classified (Figure 1)
Figure 1 Environmental Event Classification Process
Where Environmental Harm has been caused the event will always be classified as an Environmental Incident regardless of whether one or more Environmental Requirements have been breached Only when an event occurs without harm being caused to the environment will it be classified as a Non-compliance or Issue It should be noted that the Incident management process still captures any breaches of Environmental Requirements and these incidents contribute towards the calculation of the NC Rate (Section 71)
This flowchart above is intended to be a guide and there may be situations where it is unclear exactly how an Environmental Event should be classified In these situations a judgement call should be made in consultation with your Manager
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 19
Environmental Incident and Non-compliance Reporting Procedure
51 Worked Example ndash Classifying Environmental Events
This Section provides a fictitious example of Environmental Events which fall into each of the three different categories The situations outlined below are provided to explain how event classifications are made The background for these worked examples is as follows
Sydney Metro is carrying out works in a newly established site and substantial earthworks are occurring to construct piers for an elevated viaduct A nearby creek contains a variety of important fish species and the local community are known to use this creek for recreational fishing The Environmental Impact Statement identified the creek as being at risk of increased sedimentation from dirty water run-off and the Conditions of Approval include a requirement to have a Progressive Erosion and Sediment Control Plan in place This plan has been produced and indicates that sediment fences must be in place at specific locations to capture dirty water run-off Regular daily inspections of the sediment controls are carried out by the contractorrsquos Environment Manager and an Independent Environmental Representative has commenced a monthly inspection on this site at 7 am on Thursday morning
511 Soil and Water Issue
The Environmental Representative notices a sediment fence has been knocked over in one of the areas indicated as requiring fencing on the ERSED plan It appears to have occurred recently and there is no record of rainfall in the last few days During the course of the inspection all other ERSED controls appeared to be in good condition and erected in accordance with the requirements of the Blue Book In this example no harm has yet been caused and no environmental requirement has been breached so the event is classified as an Environmental Issue which is raised on the inspection report with an action to reinstall the fence
512 Soil and Water Non-compliance
Alternatively the Environmental Representative might have noticed many sediment fences had been knocked down and in some areas an absence of sediment fences where the plan indicates they are required Despite there being no rain in recent days the Environmental Representative concludes that the requirements of the plan are not being followed and have been breached The event is raised as non-compliance and actions are set in place to re-enforce the requirements of the ERSED plan for that sites workforce as well as the immediate reinstatement of controls
513 Soil and Water Incident
Finally in a third scenario the Environmental Representative notices many sediment fences are down and some are absent where required by the plan However significant rainfall has occurred in recent days and the Environmental Representative determines that it is likely dirty water has escaped through the area into the nearby creek potentially causing harm to the fish population This event is classified as an Incident by the inspector and immediate notification is undertaken Similar controls are implemented as described above
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 19
Environmental Incident and Non-compliance Reporting Procedure
52 Notifiable Events
There are a number of Acts and regulations that include a specific requirement to notify a Regulatory Authority When an Environmental Event triggers one of these notification requirements we then also refer to that event as a Notifiable Event (Table 1)
The Principal Contractorrsquos Environment Manager must determine whether an event is notifiable and may rely upon advice from Sydney Metro if it is provided
Table 1 Examples of Notifiable Events
Event type Legislation Trigger for Notification
Pollution Incident
1
POEO Act 1997 Part 57 Where Material Harm has occurred contact the EPA Pollution Line as soon as practicable POEO (General)
Regulation 2009 Section 101
Land contamination
Contaminated Land Management Act 1997
Section 60(1)
As soon as practicable after becoming aware of contamination that exceeds the relevant investigation levels in the National Environment Protection Measure where a person has or will be exposed to the contamination
Discovery of an Aboriginal relic
National Parks amp Wildlife Act 1974
Section 89A
Director General of EPA in writing within a reasonable time after becoming aware Note this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in the relevant Infrastructure Approval
Discover Aboriginal Remains
Commonwealth Aboriginal amp Torres Strait Islanders Heritage Protection Act 1984
Section 20 Commonwealth Minister of the Environment in writing as soon as practicable after becoming aware
Discovery of a relic
Heritage Act 1977 Section 146
Heritage Council in writing within a reasonable time after becoming aware
Note -this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in Infrastructure Approvals
53 Event Types
Each Environmental Event is assigned a secondary classification of an Event Type for the purpose of data analysis and general environmental management They are grouped by areas of environmental management so that targeted auditing training or awareness initiatives can be initiated in response to emergent trends Each Event Type is explained in Table 2
1 Further information on reporting pollution incidents to EPA is provided in Section 66 Environmental
IncidentNon-compliance Report
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table 2 Environmental Event Types and their descriptions
Event Type
Applies To
Description Issue Incident
Non-compliance
Soil and Water bull bull bull
Covers the physical location chemical composition and ecology of soils and waterways Any event which changes these compositions is a Soil and Water event Within this event type all instances of contamination erosion and sedimentation of waterways is covered
Flora and Fauna bull bull bull Covers vegetation and vegetation communities as well as animals and animal habitat Any event where vegetation is felled or damaged animals are killed or injured or habitat is harmed or destroyed is covered
Waste and Spoil bull bull bull
Covers the management of Excavated Natural Material (ENM) and Virgin Excavated Natural Material (VENM) including on-site management and disposal and also the classification and management of Waste materials
Note that the transportation of spoil is covered under Traffic Transport and Access
Heritage bull bull bull Covers the management of known heritage artefacts or sites and the treatment of unexpected finds archaeological investigations and other impacts
Air Quality bull bull bull Covers the management of emissions of particulate matter odours and gasses used as air quality parameters from worksites
Noise and Vibration bull bull bull
Covers the management of airborne and ground borne noise and vibration and includes hold points on the commencement of any work where Out of Hours Works permits or Construction Noise Impact Statements are required
Community Stakeholder and Business
bull bull bull Covers the management of Community and Stakeholder requirements and includes complaint response procedure community management protocols and the maintenance of information on websites
Traffic Transport and Access bull bull bull
Covers the management of traffic inside and outside of sites including access points and parking requirements This event type also covers any requirements in relation to vehicles and vehicle maintenance or the transportation of waste and spoil
Spills and Leaks bull bull bull
Covers all instances where environmentally sensitive substances are held within a container which has the potential to leak or spill and covers pipes hoses fuel tanks storage tanks and plastic containers
Note Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Management Systems bull bull bull
Covers procedural or administrate processes that are common across all areas It specifically does not cover procedural or administrate processes which are unique to any of the other event types For example not completing a vegetation removal form prior to vegetation clearing is still a Flora and Fauna event
Note A good example of a Management Systems NC would be not reporting an Environmental Incident within required timeframes
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 19
Environmental Incident and Non-compliance Reporting Procedure
6 Environmental Incident Classification and Management
Sydney Metro has defined an Environmental Incident as
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Adverse environmental impact includes contamination harm to flora and fauna (either individual species or communities) damage to heritage items or adverse community impacts
Planning Approvals and Environment Protection Licences permit some environmental impacts and these are not intended to be captured as Environmental Incidents
Table 3 Examples of Environmental Incidents
Type Example Incident
Air Quality Odour that travels beyond the site boundary
Air Quality Dust exceeding reasonable levels without active management measures in place
Air Quality Operation or maintenance of plant in a manner that causes or has likely caused excessive air pollution
Soil and Water Discharge of water on or off site in a manner that causes or has likely caused water pollution without required approvals
Noise and Vibration Noise that travels beyond the site boundary as a result of poorly maintained plant or operation of plant in an inefficient manner
Noise and Vibration Failure to comply with the approved hours of work
Soil and Water
Where the chemical composition of soil or water has been detrimentally modified by a contaminant leading to potential or actual environmental harm For example rainfall causes a flow of water across a site that erodes soil and enters a waterway increasing the total suspended solids of that water body
Spills and Leaks
Where a substance has leaked from or spilt from a container that is designed to prevent that substance from escaping into the environment (including bunds fuels tanks chemical bottles and other containers)
Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Soil and Water Dispose of waste in a manner that harms or is likely to harm the environment
Flora and Fauna Harm or ldquopickrdquo a threatened species endangered population or endangered ecological community without required approvals
Flora and Fauna Damage to vegetation fauna or habitat including watercourses without required approvals
Heritage Damage disturbance destruction or works to heritage itemsrelics without required approvals
Heritage Damage disturbance or destruction of Aboriginal objects or places without required approvals
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
61 Incident Classification
Environmental Incidents are classified into one of three Classes that are based upon the consequence descriptors for environmental risks in the Sydney Metro Risk Matrix (refer to Sydney Metro Risk Management Standard) Each of these classifications trigger a variety of management actions andor legislative requirements depending on the severity of the consequence described where Class 3 represents minor consequences and Class 1 represents major consequences
This matrix is further sub-divided into consequence ratings ranging from C6 (low impact) to C1 (high impact) An incident transitions between a Class 3 to a Class 2 incident once material harm has been caused and transitions into a Class 1 incident once it is determined that the Environmental Harm caused in large-scale and cannot be remediated (Table 4)
Table 4 Classification System for Environmental Incidents
Class 3 Class 2 Class 1
C6 C5 C4 C3 C2 C1
No appreciable changes to
environment andor highly
localised event
Change from normal conditions
within environmental
regulatory limits and environmental effects are within site boundaries
Short-term andor well-contained environmental effects Minor
remedial actions probably required
Impacts external ecosystem and considerable
remediation is required
Long-term environmental impairment in
neighbouring or valued
ecosystems
Extensive remediation
required
Irreversible large-scale
environmental impact with loss of
valued ecosystems
611 Class 3 Incidents
These Incidents are events which cause Environmental Harm but do not cause Material Harm to the environment Normally Class 3 Incidents are not Notifiable Events and therefore a simple notification protocol is adopted whereby Sydney Metro must be notified within 48 hours verbally and in writing
In some cases it will be unclear whether Material Harm has been caused in the early stages of Incident Management If this is the case then the process for Class 2 Incidents is followed (see Section Class 2 Incidents) until it is clear that Material Harm has not been caused
A formal Incident Investigation report is not required for Class 3 Incidents however it is expected that the person responsible for completing the Incident Notification Report makes appropriate enquiries to determine the likely causal factors involved and assigns effective corrective actions
612 Class 2 Incidents
These Incidents are events which cause Material Harm to the environment and they always trigger notification of Regulatory Authorities These Incidents represent events that are far more serious than Class 3 Incidents and therefore strict communication protocols are required to ensure that effective and informed decisions are made (Figure 2)
The Environmental Lead contract Environment Manager and the Independent Environmental Representative must be notified verbally as soon as possible after the observer becomes aware of a Class 2 Incident
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Class 2 Incidents must be investigated and the investigation must produce an investigation report containing corrective or preventative actions This investigation report must be provided to Sydney Metro within 7 days of the event unless another timeframe is agreed with the EL
Despite any arrangements for the submission of investigation reports an Incident Notification Report must be provided with all available information and submitted to Sydney Metro within 48 hours It is not expected that initial Incident Notification Reports for Incidents under investigation initially include actions as these will be informed by the findings of the investigation The report should be updated with actions resulting from the investigation when available
613 Class 1 Incidents
Class 1 Environmental Incidents are managed in the same manner as Class 2 Incidents expect where a determination is made by the Chief Executive (or delegate) that a Crisis Management Team should be activated In this situation the Sydney Metro Crisis Management Implementation Plan is followed
62 Incident Notification
When and Environmental Event occurs which causes Environmental Harm in all cases both verbal and written communication of the incident must be carried out immediately and within 48 hours respectively For Class 1 and 2 Incidents the notification process shown in Figure 2 must be followed Written communication of Environmental Incidents is via an Incident Notification Report (Section 63)
This process includes specific roles and responsibilities within Sydney Metro and our delivery Partners who are required to take notification actions in response to Incidents
This notification process has been developed to ensure that crucial information about Incidents is captured early and communicated to specific individuals who can ensure the Environmental Impacts are minimised and efficient and effective responses to the event are implemented
In particular the Principals Representative and the Environmental Lead for Sydney Metro play a crucial role in the communication of Incidents within Sydney Metro and these roles are explained in more detail below
621 Principalrsquos Representative (PR)
Each works package establishes a contractual interface for communication between the contracted party and Sydney Metro Generally this interface is between the Principal Contractors Project Director and an appointed representative of Sydney Metro called the Principals Representative
All formal written communications must pass between these two individuals electronically using TeamBinder The Principals Representative holds certain responsibilities in the Incident management Process outlined in Figure 2
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
622 Environmental Lead (EL)
Where this procedure is applied to a works package an Environmental Lead (EL) will be selected for the relevant works package The Environmental Lead must possess environmental experience and competency in managing Incidents and be a representative of Sydney Metro for those works This representative holds specific responsibilities outlined in Figure 2
Figure 2 Environment Incident notification process for Class 1 and 2 Incidents
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
63 Incident Notification Reports
For all Incidents an Incident Notification Report must be completed and submitted to Sydney Metro within 48 hours These reports satisfy the requirement for written communication to Sydney Metro and are completed using the Environmental Incident and Non-compliance Notification Report (SM ES-FT-403) or a similar and consistent form approved by Sydney Metro
64 Incident Investigations
Environmental Incident Investigations must be carried out for all Class 1 and Class 2 Incidents Investigations may also be requested for any other Environmental Event at the discretion of Sydney Metro This discretion is likely to be exercised where incidents of a similar nature are occurring repetitively
When conducting an Environmental Incident investigation they must
Be led by a lead investigator who is suitably independent investigator capable of arriving at objective findings and is experienced in conducting environmental incident investigations
Consider the need for legal privilege during the investigation process in consultation with legal counsel
Be informed by all available information that is relevant to the investigation
Analyse the timeline of events which led up to and followed the occurrence of Environmental Harm including the immediate incident response
Be conducted in a manner that is consistent with recognised investigation techniques such as ICAMS
Gather and record evidence
Seek the input of key stakeholders and
Identify Preventative and Corrective actions and document these in the Incident Notification Report
65 Environmental Incidents with Health and Safety Impacts
It is possible that where an Event occurs that causes Environmental Harm harm is also caused to the health safety or wellbeing of people In these situations there will also be a Health and Safety Incident process undertaken which is separate to the process outlined in this document
While the definition of the Environment covers people under the POEO Act the management of impacts upon them are carried out using the Health and Safety Incident Management protocols This is because Health Safety and Wellbeing requirements are governed by a range of legislation other than the POEO Act and this procedure is not comprehensive in that regard Sydney Metro has well established processes to manage impacts on people without the need for the Environmental Incident Process to intervene
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Furthermore where Environmental Events cause harm to both the lsquoenvironmentrsquo and people it is possible that the root causes for the respective impacts are different It is also possible that differences in the severity of the impacts trigger inconsistent notification requirements and investigation levels It is prudent to identify appropriate and effective corrective actions that reduce the risk of impacts to both people and the environment therefore separate Incident Management Processes are undertaken in these situations
For more detail on the management of Health and Safety Incidents please refer to the Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
66 Reporting Pollution Incidents to Relevant Authorities
If an Incident or Non-compliance is a Notifiable Event then a report must be provided to the relevant Regulatory Authority within the timeframe(s) specified by the relevant legislation Pollution Incidents which are causing or threatening Material Harm to the environment must be reported to each of the following authorities immediately after project personnel become aware of the Incident as required by Section 148 of the POEO Act 1997 The contact numbers for these authorities are listed in Table 5
Table 5 Contact details for Relevant Authorities
Type Example incident
EPA Environment Line 131 555
Local Authority Local Council (specific to area)
Ministry of Health Public Health Unit (refer to httpwwwhealthnswgovauPagesdefaultaspx to confirm local area contact details)
SafeWork NSW 131 050 or contactsafeworknswgovau
Fire and Rescue NSW 000
Relevant information required to be given to EPA when making a notification is specified in Section 150 of the POEO Act 1997 as follows
Time date nature duration and location of the incident
Location of the place where pollution is occurring or is likely to occur
Nature the estimated quantity or volume and the concentration of any pollutants involved
Circumstances in which the Incident occurred (including the cause of the Incident if known)
Action taken or proposed to be taken to deal with the Incident and any resulting pollution or threatened pollution and
Other information prescribed by the regulations
All relevant information known at the time of making the notification must be reported If the information required by (c) (d) or (e) above is not known at the time of initial notification but becomes known afterwards it must be reported to each authority immediately after it
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
becomes known Verbal notification must be followed by notification in writing within seven days of the date on which the Incident occurred
Pollution Incidents are not required to be reported if the Incident has already come to the attention of the EPA or the Incident involves only the emission of an odour
Failure to report a pollution Incident as required by the POEO Act 1997 is an offence
Where any work or activity is regulated by an Environment Protection License (EPL) notification of a pollution Incident to the EPA should be made by the licensee Thus where the contractor holds the EPL for the project notification to EPA shall be made by the contractor
For any work or activity that is not regulated by an EPL notification of pollution Incidents to EPA shall be made by Sydney Metro unless the contractor is instructed otherwise by Sydney Metro This includes pollution Incidents that occur as a result of pre-construction activities which may be undertaken prior to an EPL being required for a project Pre- construction activities are determined by the Planning Approval and may include for example geotechnical investigations or surveys
Where the Environmental Representative determines there to have been a significant off-site impact on people or the biophysical environment the program Director Sustainability Environment and Planning will notify the Secretary of the Department of Environment and Planning within 48 hours in accordance with Project Infrastructure Approval Conditions This notification will be followed by a full written report within seven days of the date on which the incident occurred
661 Maritime Related Incident Notification and Reporting
Marine Incidents involving vessels and personnel on board vessels must be reported to the Australian Maritime Safety Authority in accordance with the guidance published on their website at
Australian Maritime Safety Authority Incident Reporting and
Reporting obligations of owners and masters of domestic commercial vessels
67 Environmental Compliance Register
The Environmental Compliance Register is used to manage the information associated with reporting of Environmental Events This register is maintained by the Manager Environment and may be used by a variety of individuals to input data For access to the register or information on its use contact the Manager Environment
This register analyses the data it contains and produces environmental compliance statistics that are used to meet a range of reporting and environmental management requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
7 Environmental Non-compliance
An Environmental Non-compliance is a breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans It is important to note that regardless of whether an event is classified as a Non-compliance or an Incident the process behind managing the event remains the same with the following exceptions
Non-compliances are not notifiable to Regulatory Authorities under the POEO Act
Non-compliances are reported to have occurred on the day the breach was raised as opposed to the date when the requirement was breached (this is to preserve historical reporting and analysis ndash see Section 71)
Non-compliances are not divided into severity classes (Section 52)
Non-compliances do not have the potential to trigger crisis or emergency management processes and
There is an informal notification process in the immediate timeframe following a Non-compliance being raised
When an Environmental Event occurs that causes Environmental Harm and also breaches one or more Environmental Requirements then an Incident Notification Report will be created which records what requirements were breached
If a Non-compliance is identified then it must be raised using the Environmental Incident and Non-compliance Report Form within 48 hours by the party responsible for the breach
71 Non-compliance Rate
A key environmental performance statistic used by Sydney Metro is the Non-compliance Rate This statistic provides a standardised way of comparing the performance of different projects or contractors The NC Rate is calculated using the following formula
= (119873119862119904 + 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119903119886119894119904119890119889 119894119899 119898119900119899119905ℎ) + (119874119901119890119899 119873119862119904 + 119874119901119890119899 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119891119903119900119898 119901119903119890119907119894119900119906119904 119898119900119899119905ℎ119904)
119879119900119905119886119897 119873119906119898119887119890119903 119900119891 119874119899119892119900119894119899119892 119877119890119902119906119894119903119890119898119890119899119905119904) 119883 100
Each month a count of the number of NCs raised and Incident raised where Environmental Requirements have also been breached is counted Added to this number is the number of these events which were raised in previous months that still held an Open status in the current reporting period Non-compliance and incident Events are considered Open if any of the associated Actions are Open The total is divided by the number of Environmental Requirements which are actively being complied with (Ongoing Requirements) and a multiplying factor of 100 is applied
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
8 Corrective and Preventative Actions
Whenever an Environmental Event is raised actions will be assigned to the event irrespective of whether it is an Issue Incident or Non-compliance These actions will generally be Corrective Actions which are implemented to eliminate the cause of the Incident Non-compliance or Issue and can be thought of as reactive measures in response to the Environmental Event
Preventative Actions may also be assigned to prevent the occurrence of an Incident Non-compliance or Issue and can be considered pro-active measures which may be recommended following a detailed investigation of the event
Actions must
Limit impacts as far as is reasonably practicable
eliminate risk where practicable
where is it not practicable to eliminate the risk follow the hierarchy of controls
address root causes and contributing factors and
be prioritised based on risk
The Executive Director Safety Sustainability amp Environment must ensure there are systems in place to
monitor corrective action status
escalate issues to the executive where progress on a corrective action is inadequate and
retain all corrective action responses for recording purposes
81 Action Status
Actions are allocated to a person who will take accountability for ensuring it is carried out within a timely manner and completed by the due date
Actions are either closed immediately if the Action has already been carried out and verified by Sydney Metro or are created with an open status The Action will remain in an open state until such a time as Sydney Metro verifies that the responsible person has completed the Action in a satisfactory manner Until all actions associated with an Incident Non-compliance or Issue are closed the original Environmental Event is considered to be open as well This is relevant when calculating the NC Rate as open Non-compliances and Incidents contribute toward the calculation of this statistic
Verification is determined by the Environmental Lead by sighting evidence of the Actions implementation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
9 Related Documents and References
10 Superseded Documents
11 Document History
Related Documents and References
Environmental amp Sustainability Management Manual
Risk Management Standard
Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
Crisis Management Implementation Plan
Environmental Incident and Non-compliance Notification Report
Environmental Inspection Information amp Summary
Sydney Metro Glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
10 31 March 2015 New document
20 7 July 2016 IMS Review
30 7 April 2017 IMS Review
40 23 November 2018 IMS Review
50 11 February 2019 IMS Review
51 18 February 2019 Minor correction to formula
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Appendix 10 ndash Sydney Metro Environmental Inspection template
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2016 CEMP Appendix 10 - Sydney Metro Inspection template Page 1 of 1
Environmental Inspection Report Template
Contract
Contractor Date
Inspection Number Time
Location
Weather
Attendees
Site Activities
Item No
Key Issues Action Party
Priority
(L M H)
Inspection by
Name Title Signature
Date
Copy to
- All attendees
-
-
-
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Appendix 11 ndash Georgiou Environmental Policy
COMPANY POLICY
Rob Monaci Chief Executive Officer Georgiou Group September 2020
ENVIRONMENTAL
Georgiou is committed to minimising where reasonably practicable its impact on the natural environment and social surroundings for the benefit of current and future generations while enhancing Georgioursquos environmental performance
In order to achieve this commitment Georgiou will
set environmental objectives and targets applicable to the aspects and potential impacts of projects and facilities
establish positive relationships with community and stakeholders
comply with all applicable environmental laws regulations statutory obligations and client environmental requirements
identify significant environmental aspects and develop effective and appropriate mitigation measures to minimise environmental impacts
provide measures to protect heritage biodiversity land and waterways
manage potential community impacts related to air quality noise and vibration
practice responsible resource use and waste management including the promotion of efficient use reuse and recycling of resources
implement and maintain Georgioursquos management system and practices to meet its business needs ASNZS ISO 14001 client and other obligations and
hold employees and subcontractors accountable for proactively meeting their environmental responsibilities
Achieving these commitments is fundamental to demonstrate a positive impact on the environment and communities associated with Georgioursquos activities and developments All employees and persons who work with Georgiou have a personal responsibility for implementing this Policy
SAFE
TY |
PRO
FIT
| RE
LATI
ON
SHIP
S |
PEO
PLE
| IN
NO
VAT
ION
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TABLE OF CONTENTS
GLOSSARY ABBREVIATIONS 6
1 INTRODUCTION AND PURPOSE 8
Amendments and Authorisation 8
Communication of this Plan 8
Supporting Management Plans 8
2 SCOPE OF WORKS 9
3 LOCATION 9
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW 10
Environmental Management System 10
Policy 11
Environmental Management Plan 11
5 LEGAL AND OTHER OBLIGATIONS 12
General 12
Contractual Environmental Requirements 15
REF Determination Conditions of Approval 17
Environmental Licences and Permits 19
Infringement Improvement and Prohibition Notices 20
Availability of Statutory and Other Information 20
Objectives amp Targets 20
6 STRUCTURE AND RESPONSIBILITIES 21
Organisational Structure 21
Roles and Responsibilities and Authority 21
Communication and Acceptance of Accountabilities and Responsibilities 23
Field Leadership Visits 23
7 COMMUNICATION AND CONSULTATION 24
Internal Communication and Consultation 24
711 Inductions 24
712 HSE Notice Boards 25
713 HSE Alerts Bulletins 25
714 Site Meetings 25
Community and Stakeholder Involvement 25
721 Complaints Management 26
722 Urban Design of temporary works 26
723 Business and Property Impacts 27
8 HAZARD IDENTIFICATION AND RISK CONTROL 27
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Hierarchy of Control 27
Site Environmental Risk Analysis 28
Review of Risks 28
831 Change Management 28
Operational Control 28
841 Environmental Hazard Reporting 28
842 Take 5 29
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS) 29
844 Permit to Work 29
845 Environmental Control Maps 29
9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT 30
10 CLOSURE AND COMMISSIONING 30
11 TRAINING COMPETENCY AND RESOURCING 30
1111 Toolbox talks 30
1112 Recording of Training and Assessment 31
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE 31
EmergencyIncident Planning and Control 31
13 HSE REPORTING AND INVESTIGATION 31
Notifications and Reporting 31
1311 Internal 31
1312 Notification of Incidents to Sydney Metro 31
1313 Statutory Notifications 31
Investigations 32
Review and Communication of Incidents 32
14 ENVIRONMENTAL REPORTING 32
1411 Monthly Reports 32
Site Meetings 32
Project Performance Review 33
15 AUDITING REVIEWS AND INSPECTIONS 33
Inspections 33
1511 Environmental Inspections 33
Audits and Reviews 33
Monitoring 34
Corrective Actions 34
16 DOCUMENT AND RECORD CONTROL 34
17 APPENDICES 35
Appendix 1 - Waste Management Sub Plan 36
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Appendix 1A ndash Sydney Metro Waste Classification Procedure 42
Appendix 2- Soil and Water Management Sub Plan 43
Appendix 3- Hydrocarbon and Chemical Management Sub Plan 46
Appendix 4 - Flora amp Fauna Management Sub Plan 50
Appendix 5 - Cultural Heritage Management Sub Plan 53
Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure 55
Appendix 5B ndash Sydney Metro Exhumation Management Procedure 56
Appendix 6 - Air Quality amp Dust Management Sub Plan 57
Appendix 7- Noise Vibration and Light spill Management Sub Plan 59
Appendix 7A ndash Sydney Metro Out of Hours Application form 61
Appendix 8 ndash Contaminated Land Management Sub Plan 62
Appendix 8A ndash Unexpected Contamination finds procedure 67
Appendix 8B ndash Unexpected Asbestos finds procedure 71
Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure 78
Appendix 10 ndash Sydney Metro Environmental Inspection template 79
Appendix 11 ndash Georgiou Environmental Policy 80
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GLOSSARY ABBREVIATIONS
Term Expanded text
AFMP Ancillary Facilities Management Plan
BC Act Biodiversity Conservation Act 2016
CoA Condition of approval
Compliance audit Verification of how implementation is proceeding with respect to an CEMP (which incorporates the relevant approval conditions)
CPESC Certified practising erosion and sediment control professional
CRM Community Relations Manager
CPESC Certified practising erosion and sediment control professional
CSSI Critical State Significant Infrastructure
DEC Department of Environment and Conservation (NSW) (former)
DIPNR Department of Infrastructure Planning and Natural Resources (former)
DoEE Commonwealth Department of the Environment and Energy
DoI - Water NSW Department of Industry - Water
DPIE NSW Department of Planning Industry and Environment
Ecologically sustainable development (ESD)
Using conserving and enhancing the communityrsquos resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future can be increased (Council of Australian Governments 1992)
EIS Environmental Impact Statement
EMS Environmental Management System
Environmental aspect
Defined by ASNZS ISO 140012015 as an element of an organisationrsquos activities products or services that can interact with the environment
Environmental impact
Defined by ASNZS ISO 140012015 as any change to the environment whether adverse or beneficial wholly or partially resulting from an organisationrsquos environmental aspects
Environmental incident
An unexpected event that has or has the potential to cause harm to the environment and requires some action to minimise the impact or restore the environment
Environmental objective
Defined by ASNZS ISO 140012015 as an overall environmental goal consistent with the environmental policy that an organisation sets itself to achieve
Environmental policy
Statement by an organisation of its intention and principles for environmental performance
Environmental target
Defined by ASNZS ISO 140012015 as a detailed performance requirement applicable to the organisation or parts thereof that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives
EPA NSW Environment Protection Authority
EPampA Act NSW Environmental Planning and Assessment Act 1979
EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999
EPL NSW Environment Protection Licence under the Protection of the Environment Operations Act 1997
ERG Environmental Review Group
ESCP Erosion and Sediment Control Plan
EWMS Environmental Work Method Statement
Federal-CoA Condition of the Federal Department of the Environment and Energy Approval Decision
Hold point Is a verification point that prevents work from commencing prior to approval
GC-HSE-PLA-437 Uncontrolled when saved or printed
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LGA Local Government Area
MNES Matters of National Environmental Significance
Non-compliance Failure to comply with the requirements of the Project approval or any applicable licence permit or legal requirements
NSW-CoA Condition of the NSW DPampE Infrastructure Approval
OEH NSW Office of Environment and Heritage
OOHW Out of hours work
PIRMP Pollution Incident Response Management Plan
POEO Act Protection of the Environment Operations Act 1997 (NSW)
RAP Registered Aboriginal Party
RBL Rating background level
REF Review of Environmental Factors
ROL Road occupancy licence
SAP Sensitive Area Plan
SEPP State Environmental Planning Policy
UXO Unexploded Ordnance
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1 INTRODUCTION AND PURPOSE
The purpose of this Construction Environmental Management Plan (CEMP) is to describe how environmental aspects
are to be managed so that the site and those engaged onsite will
Comply with Georgiou Policy Client legal and other obligations
Minimise the impacts on the environment
Achieve the Company client and site objectives and targets
implement mitigation measures identified and assessed through Review of Environmental Factors (REF) under
Part 5 of the EPampA Act
Comply with the requirements of the Construction Environmental Management Framework (CEMF) February
2020 version 41 Managing Contractor Contract (MCC) Works Brief licencing and other relevant documents
This Management Plan is written in accordance with Georgioursquos health safety and environment management
system that is 3rd party certified to ASNZS ISO 14001 It has been written in accordance with the Transport for
New South Wales (TfNSW) Sydney Metro Construction Environmental Management Framework (CEMF) and the
project specific Sydney Metro General Specification ndash Plans and Reporting
Amendments and Authorisation
This Management Plan will be approved by the Project Manager their Line Manager and a Representative from the
HSE Department This Management Plan and other related documents will be reviewed annually or as a result of
Changes to Company procedures or processes
Changes to key personnel or resources
Changes in legal and other obligations
Findings from an audit or inspection
Findings from a significant incident or near miss
Significant changes to site conditions andor work methods
Instructions from Sydney Metro
Reviews will be undertaken in consultation with key stakeholders to ensure all locationsfunctions are considered
A record of the date and comments relating to any revisions of this document will be included in the revision table
The only Georgiou authorisation required to amend this document after initial approval is the Project Managerrsquos
Communication of this Plan
The Project Manager is accountable for ensuring
Location and access to the management plans is communicated at induction Management Plans have been communicated to subcontractor personnel prior to commencement of works
onsite Any changes made to the management plan are communicated to affected persons on the site
Supporting Management Plans
The following management plans have been developed to support this management plan
Emergency Response and Preparedness Plan
Georgiou Crisis Management Plan (controlled by Georgioursquos Perth Head Office and available on Company Intranet)
GC-HSE-PLA-437 Uncontrolled when saved or printed
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2 SCOPE OF WORKS
Sydney Metro is proposing to configure the internal port road network at Rozelle to facilitate the orderly urban
renewal of the Bays West area while maintaining access to the White Bay Cruise Terminal and other port operations
at Glebe Island and White Bay This includes long-term urban renewal initiatives for the Bays West area and works
for various future developments within the locality including critical works for the proposed Sydney Metro West
The proposal also provides the opportunity to improve road safety by reducing conflicting traffic movements in the
internal port road network
Georgioursquos scope of works is described as lsquoPhase 1rsquo works in the REF and it comprises of the following key
features
A reconfigured intersection at Port Access Road Solomons Way Sommerville Road including an interim
connection with the existing Port Access Road until it is relocated (as part of Phase 2)
Establishment of one-way traffic circulation along Solomons Way and Sommerville Road around the Glebe Island
Silos
Relocation of the Cement Australia Truck Parking Licenced Area to the north prior to the construction of the
reconfigured intersection due to the direct conflict with the reconfigured intersection
3 LOCATION
The proposal is located in an established industrial and port context at Rozelle within the Inner West Council local
government area
The lsquoproposal sitersquo refers to the area that would be directly impacted by the proposal as shown in Figure 1-1 The
proposal site is largely disused with the exception of the Port Access Road and port related lease areas including a
Cement Australia Truck Parking Licenced Area to service Cement Australiarsquos operations at the Glebe Island Silos
The proposal site is under the ownership of the Port Authority of NSW
To the north of the proposal site is the existing Port Access Road that supports access to the White Bay Cruise
Terminal and other port operations at White Bay To the east of the site is the existing Cement Australia and Sugar
Australia Glebe Island Silos and the Gypsum Resources Australia facility The south-eastern border of the site is
vegetated land adjoining Victoria Road Western Distributor The proposed location for the relocated Cement
Australia Truck Parking Licenced Area is currently a hardstand laydown area used by Port Authority of NSW
Beyond the proposal site the wider locality features a mix of land uses including retail commercial and urban
services along Robert Street to the north port and maritime uses to the east (Glebe Island and White Bay) and to
the south and City West Link Road and residential dwellings to the west in Rozelle
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CEMP Bays Road Relocation Works
Figure 3-1 Site location
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW
The following documents provide further information in regards to this topic
Management System Standard
Environmental Management System
The CEMP has been prepared in accordance with the overarching environmental management system (EMS) as
detailed below
Georgiou has a certified EMS consistent with ASNZS ISO 14001 Environmental Management Systems and will
prepare CEMPs in accordance with this EMS
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Policy
This Management Plan has been prepared in accordance with Georgioursquos Environmental Policy (appendix 11) All
relevant works including those conducted by subcontractors or by other companies on Georgioursquos behalf will
conform to this Policy
Georgioursquos Environmental Policy will be communicated to all workers at their site induction and displayed at the
site Georgioursquos policies will be made available to any interested party
Environmental Management Plan
This CEMP provides the system to manage and control the environmental aspects of the Project during pre-
construction and construction It identifies all the requirements applicable to manage the activities described in
Section 2 It also provides the overall framework for the system and procedures to ensure environmental impacts
are minimised and legislative and other requirements are fulfilled The strategies defined in this CEMP have been
developed with consideration of the Project approval requirements environmental management measures
presented in the approval documents This CEMP establishes the system for implementation monitoring and
continuous improvement to minimise impacts from the Project on the environment
This CEMP is consistent with
ASNZS ISO14001 2004 lsquoEnvironmental Management Systems - requirements with guidance for usersquo
Georgiou HSEQ Management System
Environmental Policy
Georgious Management is committed to regulatory
compliance pollution prevention and continous
improvement
Planning
Identify environmental interactions and signficant
aspects identify legal and other requirements and development
environmental objectives targets and the programs in
which to achieve them
Implementation and Operation
Define structure and responsibility identify and complete training
needs establish communication procedures document the EMS
through policies plans and procedures establish document
control establish operational control implement emergency
preparedness and response
Checking
Monitor and measure environmental interactions
evaluate compliance establish a non-conformance corrective
action and preventative action system maintain records and
perform periodic internal audits of the EMS
Management Review
Management to review environmental performance
EMS performance policy priorities and objectives and recommend improvements
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5 LEGAL AND OTHER OBLIGATIONS
The following documents provide further information in regards to this topic
Management System Standard
HSE Legal and Other Obligations Directory
General
The statutory requirements for this site have been identified within the Company HSE Legal and Obligations
Directories (available on Company Intranet) and have been incorporated into this management plan Legal and
other requirements specific to this contract which are not otherwise captured in the Company HSE Legal and
Obligations Directories are as follows
Legislation Other requirement
Requirement Comment
EPBC Act 1999
Under the EPBC Act a referral to the Commonwealth Department of Agriculture Water and the Environment is required for proposed lsquoactionsrsquo that have the potential to significantly impact on any matter of national environmental significance the environment in general or the environment of Commonwealth land (including leased land)
There are no matters of national environmental significance located within the general area of the proposal as confirmed in Appendix A of the REF Therefore an EPBC Act referral is not required
EPampA Act 1979
Clause 94 of the ISEPP outlines that development for the purpose of road and road infrastructure facilities which are permissible without the need for development consent under Part 4 of the EPampA Act when carried out by a public authority
Sydney Metro is a public authority and has prepared an REF and determination report to meet the assessment requirements under the EPampA Act
EPampA Regulation 1979 Under clause 228 of the factors to take into account concerning the impact on an activity on the environment
The REF and determination report prepared by Sydney Metro has considered factors under clause 228
ISEPP 2007
Division 1 of Part 2 of the ISEPP contains provisions for public authorities to consult with local councils and other public authorities prior to the commencement of certain types of development
Sydney Metro will conduct consultation with local councils and other authorities prior to commencement of construction
Biosecurity Act 2015
Under the Biosecurity Act 2015 all plants including weeds are regulated with a general biosecurity duty to prevent eliminate or minimise any biosecurity risk they may pose Any person who deals with any plant who knows (or ought to know) of any biosecurity risk has a duty to ensure the risk is prevented eliminated or minimised so far as is reasonably practicable
The State level priority weeds and associated legal requirements relevant to the region are outlined in the Greater Sydney Regional Strategic Weed Management Plan 2017-2022 (Greater Sydney Local Land Services 2017)
As such if present priority weeds on the site would be assessed and controlled to fulfil the General Biosecurity Duty and minimise biosecurity risks
Contaminated Land Section 60 of the Contaminated Land Management Act 1997 imposes a duty on
One site (former White Bay Power Station) that is currently regulated by
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Management Act 1997 landowners to notify the NSW EPA and potentially investigate and remediate land if contamination is above NSW EPA guideline levels
the NSW EPA is located within the proposal site
Given the proposed works are predominately surficial or up to one metre below existing site levels contamination risk is considered minor and manageable
Biodiversity
Conservation Act 2016
The Biodiversity Conservation Act 2016 provides for the protection of threatened species populations and ecological communities in NSW If a threatened species population or ecological community or its habitat is likely to occur in any area that may be affected by the proposal then an assessment of significance must be prepared to determine whether the proposal would have a significant impact
The site is unlikely to contain suitable habitat for any listed threatened species or community and is unlikely to have a significant impact on any threatened species or community
Heritage Act 1977
The NSW Heritage Act 1977 (Heritage Act) provides protection for items of lsquoEnvironmental heritagersquo in NSW Items considered to be significant to the State are listed on the State Heritage Register (SHR) and cannot be demolished altered moved or damaged or their significance altered without approval from the Heritage Council of NSW
Section 170 of the Heritage Act requires government agencies to maintain a heritage and conservation register (Section 170 register) These registers provide a list of government assets which may have State or local heritage significance
Sections 139 to 145 of the Heritage Act prevent the excavation or disturbance of land known or likely to contain relics unless in accordance with an excavation permit Excavation permits are issued under Section 140 of the Heritage Act or Section 60 for sites listed on the SHR Excavation Permit Applications must be supported by an Archaeological Research Design Section 146 of the Heritage Act requires that any discovery or location of a lsquorelicrsquo is reported to the Heritage Council
The road footprint for Georgioursquos scope of works is located outside of the heritage curtilage for the SHR-listed White Bay Power Station and does not extend north to the White Bay Power Station (Inlet) Canal (Port Authority of NSW s170 4560062)
The Glebe Island Silos (Port Authority of NSW s170 4560016) and the Glebe Island Dyke Exposures (Port Authority of NSW s170 4560056) are located immediately adjacent to the road footprint
As detailed in the REF it is unlikely that archaeological relics would be impacted by the works therefore a Section 139 exception or Section 140 permit are not required for the works
National Parks and
Wildlife Act 1974
Sections 86 87 and 90 of the National Parks and Wildlife Act 1974 require consent from the Environment Energy and Science Group of the Department of Planning Industry and Environment for the destruction or damage of Aboriginal objects
The proposal is unlikely to disturb any Aboriginal objects (refer Section 77)
However if unexpected archaeological items or items of Aboriginal heritage significance are discovered during the construction of the proposal the Sydney Metro Unexpected Finds procedure would be followed
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Protection of
the Environment
Operations Act 1997
The Protection of the Environment Operations Act 1997 (POEO Act) administers environment protection licences (EPLs) for specific activities relating to air water and noise pollution and waste management The Environment Protection Authority (EPA) and local government where relevant administer the POEO Act
Development activities require an EPL under the POEO Act if those activities meet the assessment criteria outlined in Schedule 1 of the Act
The proposal does not meet the definition of a scheduled activity under Schedule 1
In addition the POEO Act would require construction to be managed to prevent and avoid the potential to cause water noise andor air pollution The Act also includes requirements in relation to the management of waste
Notification to the EPA would also be required (as the administrators of this Act) in instances where any pollution incident has the potential to lsquocause or threaten material harm to the environmentrsquo (refer to Section 148 of the Act)
Roads Act 1993
In accordance with Section 138 of the Roads Act 1993 consent from NSW Transport for NSW would be required for the carrying out of work in on or over a classified road
For works on unclassified roads Clause 5 of Schedule 2 of the Act provides that a public authority is not required to obtain a road authorityrsquos consent
Ongoing consultation would be carried out with the relevant road authority (or authorities) in relation to the potential impacts that may occur to all of the roads and to identify any potential construction activities may be require consent
Waste avoidance and
Resource Recovery
Act 2001
The purpose of the Waste Avoidance and Resource Recovery Act 2001 is to develop and support the implementation of regional and local programs to meet the outcomes of a State-wide strategy for waste avoidance and resource recovery
It also aims to lsquominimise the consumption of natural resources and final disposal of waste by encouraging the avoidance of waste and the reuse and recycling of wastersquo
Waste generation and disposal reporting would be carried out during the construction and operation of the proposal Procedures would be implemented during construction in an attempt to promote the objectives of the Act
Water Act 1912 and
Water Management
Act 2000
The Water Act 1912 and the Water Management Act 2000 are the two key pieces of legislation for the management of water in NSW and contain provisions for the licensing of water access and use
The proposal would not involve any water use water management works drainage or food works controlled activities or aquifer interference
National Greenhouse and Energy Reporting Act 2007
The Act established a framework for reporting of greenhouse gas emissions abatement actions energy consumption and production data
The project will report on greenhouse gas and energy usage data as required by the Act
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Contractual Environmental Requirements
This Management Plan has been written to comply with the following Sydney Metro CEMF requirements
Requirement Reference
Scope of Applicability (Any Sections of the CEMF not addressed in the left hand column of
this table do not apply) Addressed by
CEMF Requirements
Section 1 full applicability This document
Section 4
Section 2 full applicability Section 5
Section 23
Standards and guidelines applicable to the works including o ISO14001 Environmental Management System ndash Requirements
with Guidelines for Use o Interim Construction Noise Guidelines (Department of
Environment and Climate Change 2009) o Managing Urban Stormwater Soil and Construction (Landcom
2008) o AS42821997 Control of the Obtrusive Effect of Outdoor Lighting o Waste Classification Guidelines (Department of Environment
Climate Change and Water 2008) o Australian and New Zealand Guidelines for Fresh and Marine
Water Quality
Section 41
Appendix 7
Appendix 2
Appendix 1
Section 32
Only applies with respect to Construction for o SMP1 o SMP2 o SMP5 o SMP6 o SMP7 o SMP14 o SMP18 o SMP19 o SMP30
Separate sustainability management plan
Section 34
34(d) (x) applies only to the extent of addressing environmental inspections
34(d) (xi) does not apply
Approval by DPIE is not required under 34(e)
34(f) Applies with respect to o Unexpected Finds Procedure (Heritage) o Environmental Incident and Non-compliance Reporting Procedure o Construction Noise and Vibration Standard o Out of Hours Work Application Form o Unexpected Finds Procedure (Contamination)
This document
Appendices 1-10
Section 36 36(b) only applies with respect to the drafting of a Waste Management Procedure and an Unexpected Finds Procedure for Contamination
Appendix 1
Appendix 8
Section 39 39(a) (iii) does not apply 39(b) does not apply
39(b) does not apply Section 11
Section 310 Applies except that a Pollution Incident Response Plan is not required Section 12
Section 312 312(a)(i) does not apply
312(a)(iv) does not apply Section 6
Section 313
313(b) does not apply
313(d) does not apply
313(e) does not apply
Section 15
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Section 314 Full Applicability Section 13
Appendix 9
Section 315 315(d) does not apply with respect to internal audits carried out by the Principal Contractor
Section 16
Section 316 316(d) does not apply where the Principal Contractors works last less than 1 year
Section 15
Section 4 42(a) does not apply
45(c) does not apply Section 72
Section 5 51(c) does not apply
54 does not apply Appendix 7
Section 6 Only 61 applies
Sustainability management plan
Section 7 71 does not apply
72 does not apply
Appendix 2
Section 8
81 full applicability
A Construction Noise and Vibration sub-plan is not required however the CEMP must address
82(a) (iii) and (b) for Site Establishment Activities
Appendix 7
Section 9
91 (a) (i) is not applicable
A Heritage Management plan is not required however the CEMP must address the following requirements
92 (iii)
92 (ix)
92 (c) (iii)
Appendix 5 5A 5B
Section 10
101 (ii) does not apply
102(a) (iii) applies with respect to the relocation of fauna only
102(b) (i) applies
102 (b) (ii) applies
All other sections are not applicable
Appendix 4
Section 11 111 (ii) does not apply
112 does not apply Section 72
Section 12
A Soil and Water Management Plan is not required however the CEMP must address the following requirements
122 (vi)
Appendix 2
Section 13 131 full applicability
132 does not apply Appendix 6
Section 14
141 full applicability
A Waste Management Plan is not required however the CEMP must address the following Requirements
142 (a) (iv)
142 (a) (v)
142 (b) (i)
142 (d)
Appendix 1
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REF Determination Conditions of Approval
The project is subject to compliance with the Conditions of Approval (CoA) identified below these are from the
REF Determination Report (August 2020) These Conditions of Approval are consistent with the management and
mitigation measures in the REF (April 2020) with some amendments due to the project changes identified in the
REF determination report
CoA Requirement Addressed by
REF Determination Conditions of Approval
NV1 Receivers that would potentially be affected by noise andor vibration from the works would be appropriately notified before the relevant works start
This would include details on the nature of works to be carried out the expected noise levels duration of noise generating construction works and contact details during construction
Appendix 7
NV2 Where vibration levels are predicted to exceed the screening criteria a more detailed assessment of the structure (in consultation with the relevant asset owner and a structural engineer) and attended vibration monitoring would be carried out to ensure vibration levels remain below appropriate limits for that structure
For heritage buildings and structures the more detailed assessment would specifically consider the heritage values of the structure in consultation with a heritage specialist to ensure sensitive heritage fabric is adequately monitored and managed
Appendix 7
NV3 Condition surveys of buildings and structures near to the proposal would be undertaken in consultation with the relevant owner prior to the commencement of vibration intensive works where appropriate For heritage buildings and structures the surveys would consider the heritage values of the structure in consultation with a heritage specialist
Sydney Metro
NV4 Alternative construction methodologies would be considered where vibration intensive works (typically site clearing ndash demolition) result in exceedances of cosmetic damage screening criteria and may include the following
The use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of rockbreakers for demolition of structures
Use of smaller capacity rockbreakers or lower vibration generating rockbreakers
Isolating the vibration sensitive structure from the vibration intensive work area by severing the vibration transmission path using non-vibration intensive means such a sawing
Appendix 7
NV5 The potential vibration impacts to underground utilities and services would be reviewed as the proposal progresses in consultation with the asset owners and the Port Authority of NSW
Appendix 7
T1 Clear wayfinding and safety signage would be provided to direct and guide vehicles not related to the proposal during road construction works This would be supplemented by Variable Message Signs to advise drivers of traffic diversions speed restrictions or alternative routes
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T2 The Port Authority of NSW and lease holders would be notified in advance of any proposed road changes within the port area and the potential for short term delays
Sydney Metro
Georgiou must provide written notifications to Sydney Metro on road changes in
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CEMP Bays Road Relocation Works
advance of each relevant road change within the port area
T3 Construction site traffic would be managed to minimise movements during peak periods
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T4 Access to Cement Australia and other leased areas would be maintained in consultation with Port Authority and lease holders
Sydney Metro
Georgiou will provide required information to SM
T5 All staff parking would be provided on-site and not on surrounding local streets
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
NAH1 An Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
(Transferred to Georgiou under VO-003)
C1 Sampling and testing of soils in areas of potential contamination concern would be conducted to characterise the soils (with respect to contamination) and determine the appropriate waste classification (which may include hazardous wastes or special wastes) and management response Waste classification would be carried out in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (NSW Environment Protection Authority 2014)
Appendix 1
Appendix 1A
C2 Soils would be managed in accordance with the Protection of the Environment Operations (Waste) Regulation 2014 and disposed of to an appropriately licensed waste management facility
Appendix 1
Appendix 1A
C3 Erosion and sediment measures would be implemented in accordance with the principles and requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Appendix 2
C4 All fuels chemicals and hazardous liquids would be stored in accordance with Australian standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Appendix 3
C5 Prior to ground disturbance in areas of potential acid sulfate soil occurrence testing would be carried out to determine the presence of actual andor potential acid sulfate soils If acid sulfate soils are encountered they would be managed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Appendix 2
LV1 The design and maintenance of construction site fencing would aim to minimise visual amenity impact where visible from public areas
Section 722
LV2 Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Appendix 7
WR1 All waste would be assessed classified managed transported and disposed of in accordance with the Waste Classification Guidelines and the Protection of the Environment Operations (Waste) Regulation 2014
Appendix 1
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The waste management hierarchy principles established under the Waste Avoidance and Resource Recovery Act 2001 of avoidreducereuserecycledispose would be applied to the construction of the proposal
AQ1 The following best-practice dust management measures would be implemented during all construction works
Regularly wet-down exposed and disturbed areas including stockpiles especially during dry weather
Adjust the intensity of activities based on measured and observed dust levels and weather forecasts
Minimise the amount of materials stockpiled and position stockpiles away from surrounding receivers
Regularly inspect dust emissions and apply additional controls as required
Appendix 6
AQ2 Plant and equipment would be maintained in a proper and efficient manner Visual inspections of emissions from plant would be carried out as part of pre-acceptance checks
Appendix 6
GHG1 Opportunities to reduce greenhouse gas emissions through the increased use of recycled materials would be investigated during detailed design
Sydney Metro
CI1 The likelihood of cumulative (ie concurrent and consecutive) construction impacts would be reviewed during detailed design when detailed construction schedules are available
Co-ordination and consultation with the following stakeholders would occur where required to manage the interface of projects under construction at the same time
Transport for NSW including Transport Coordination
Department of Planning Industry and Environment
Port Authority of NSW
Sydney Motorways Corporation
Construction contractors
Co-ordination would occur between potentially interacting projects to minimise concurrent or consecutive works in the same areas where possible
Sydney Metro
Georgiou must participate in any consultation as requested by the Principal and provide the Principal with all information and documentation the Principal requires to comply with condition
Environmental Licences and Permits
The Project Environmental Site Representative will be responsible for
Checking with the local government municipality to see if there are local environmental requirements Identifying the environmental licences and or permits under which the site will operate Obtaining a copy of any client held licences permitsapprovals to determine conditions of compliance or if not
available obtaining written verification that licences and permits are held Obtaining Georgiou held licences and or permits Monitoring compliance to the conditions of the licencepermit and report on the status in the Project HSEQ
Performance Report and to the client
Permits and licences relevant to the project are as follows
Permit licence Responsibility Status
Environmental protection licences (EPL) under the Protection of the Environment Operations Act 1997 for road construction
Georgiou Not required as this project does not trigger a scheduled activity under the POEO Act 1997
Road Occupancy Licences Georgiou To be applied for as required
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CEMP Bays Road Relocation Works
Infringement Improvement and Prohibition Notices
The Project Manager or delegate will ensure any infringement improvement or prohibition notice issued by a
regulatory authority recorded as a incident in Georgioursquos Incident reporting database (Beakon) and appropriate
actions taken in a timely manner A copy of the infringement improvement or prohibition will be added to the
incident report and forwarded to the HSE Business Unit Lead
The Project Manager will notify via email their General Manager Construction Manager Operations Manager
HSE Business Unit amp Environmental Site Representative Lead when the infringement improvement or prohibitions
notice has been closed out
Availability of Statutory and Other Information
Georgioursquos HSEQ Department maintains links to current statutory documents (Acts Regulations and Codes of
Practice) in the HSE Legal and Other Obligations Directories which are located on Georgioursquos Intranet
(GENIE)Georgiou subscribes to Environmental Essentials product Envirolaw which is available to all personnel
through the intranet link Envirolaw summarises environmental legal obligations provides links to legislation and
guidelines as well as providing search capabilities
Changes in legislation are monitored by the HSEQ Department and site management will be notified where a change
affects a site The Project Manager will be responsible for communicating changes in accordance with section 7
HSE will ensure the change is reflected in this Management Plan and other relevant plans and documents as
applicable
Objectives amp Targets
Objectives and targets have been set for the site taking into account the significant hazards and environmental
aspects of the job the group objectives and client and contractual requirements These are documented in the
table below
Item Description Measurement Target
1 Successful implementation of CEMP and contract requirements
Audits inspections reporting management reviews
0 NCRs associated with CEMP implementation
2 Compliance with all legal requirements Audits reporting management reviews
0 regulatory infringements (PINs or prosecutions)
3 Engage with the affected and broader community minimise complaints and respond to any complaints within a suitable timeframe
Review complaints register reporting audits
0 NCRs associated with CCS implementation
4 Environmental incidents with the potential to cause material harm to the environment
Number of material harm incidents 0
5 Continuously improve environmental performance
Regular environmental inspections
Regular Leadership visits
Share environmental best practice and innovations across projects
1 environmental inspection per week
1 Leadership visit per month
1 NSW Environmental meeting per month
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CEMP Bays Road Relocation Works
6 Environmental Awareness for all workers
Conduct all Toolboxes and training identified in this CEMP
1 environmental toolbox per month on relevant site issues
Additional objectives and targets may be set specifically for activities identified for upcoming works Performance
against all HSE objectives will be monitored as a minimum monthly at site meetings
6 STRUCTURE AND RESPONSIBILITIES
Organisational Structure
The site organisational structure has been documented in the Site Organisational Chart The Site Organisational
Chart identifies the roles that will support the site in fulfilling their HSE responsibilities
Roles and Responsibilities and Authority
The Project Manager is accountable for the environmental performance of the project and the implementation of
the projectrsquos management plans Key personnel and their site responsibilities are detailed below
Project Manager ndash Brad Collins
The environmental responsibilities of the Project Manager include (but are not limited to) the following
Ensure all works comply with relevant regulatory and Project requirements Ensure the requirements of this CEMP are fully implemented and in particular that environmental
requirements are not secondary to other construction requirements Endorse and support the environmental policy Be aware of their environmental responsibilities as detailed in the management plans Actively ensure that subcontractors and suppliers are complying with environmental requirements Liaise with the client and other government authorities as required Participate and provide guidance in the regular review of this CEMP and supporting documentation Provide adequate resources (personnel financial and technological) to ensure effective development
implementation and maintenance of this CEMP Ensure that all personnel receive appropriate induction training including details of the environmental and
community requirements Ensure that complaints are investigated to ensure effective resolution Stop work immediately if an unacceptable impact on the environment is likely to occur Hold monthly HSEQ management meetings to review environmental performance and monitor
implementation and effectiveness of the management system Ensure their direct reports fulfil their environmental responsibilities and achievement of KPIrsquos Support workers to immediately stop any lsquoat risk behaviourrsquo identified during their work activities
Project Site Engineer ndash Richard Kelly
The environmental responsibilities of the Project engineers include (but are not limited to) the following
Provide input into the preparation of environmental planning documents as required Ensure that instructions are issued and adequate information provided to employees that relate to
environmental risks on-site Ensure that the works are carried out in accordance with the requirements of the CEMP and supporting
documentation including the implementation of all environmental controls Identify any environmental risks Identify resource needs for implementation of CEMP requirements and related documents Ensure that complaints are investigated to ensure effective resolution
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CEMP Bays Road Relocation Works
Take action in the event of an emergency and allocate the required resources to minimise the environmental impact
Report any activity that has resulted or has the potential to result in an environmental incident immediately to the Supervisor and Environmental Site Representative
Supervisor ndash Eddie Storer
The Supervisor is responsible for creating an exemplary HSE culture and ensuring adherence to the Management System on their site The Supervisor is responsible for approving the commencement of works and to allocate necessary resources to complete a job safely in accordance with the Management Plan and will
Demonstrate commitment to the Environment by monitoring the workplace to ensure work practices are adhered to by way of routine checks of the workplace compliance to the Management Plan
Demonstrating through their actions and behaviour that safety and the environment are core values Hold Supervisors and leading hands (Georgiou amp subcontractors) accountable for the fulfilment of their
Environmental responsibilities including KPIrsquos Be given the authority and independence to require reasonable steps be taken to avoid or minimise
unintended or adverse environmental impacts Allocating work to ensure appropriate supervision for those with lesser experience Ensuring appropriate and necessary plant and equipment is provided for workers to carry out their work
safely and without undue harm to the environment Stopping rejecting or quarantining materials plant and equipment Supporting workers to immediately stop any lsquoAt Risk Behaviourrsquo identified during their work activities Participating in audits investigations and constructability reviews Management and HSE performance of the subcontractors utilised on site
Environmental Site Representative ndash Chloe Redman
The environmental responsibilities of the Environmental Site Representative include (but are not limited to)
overall responsibility for the implementation of environmental matters on the Project development implementation monitoring and updating of the EMP and sub-plans in accordance with
ISO14001 report to the Project Manager on the performance and implementation of the CEMP to ensure management
reviews of the CEMP are undertaken annually documented and actions implemented ensure environmental risks of the Project are identified and appropriate mitigation measures implemented identify where environmental measures are not meeting the targets set and where improvement can be
achieved ensure environmental protocols are in place and managed ensure environmental compliance obtain and update all environmental licences approvals and permits as required liaise with the approval authorities manage environmental document control reporting inductions and training manage environmental reporting within the Project team and to the Client and regulatory authorities prepare reports on a monthly basis outlining the Project works undertaken and the achievements that have
been met as well as identifying those areas where improvements were made oversee site monitoring inspections and audits manage all sub-contractors and consultants with regard to environmental matters including assessing their
environmental capabilities and overseeing the submission of their environmental documents develop and facilitate induction toolbox talks and other training programs regarding environmental
requirements for all site personnel notify the client and relevant authorities in the event of an environmental incident and manage close-out of
these stop activities where there is an actual or immediate risk of harm to the environment or to prevent
environmental non-conformities and advise the Project Manager and Supervisor assist the Community Relations Manager to resolve environment-related complaints
undertake site inspections carry out monitoring activities and complete site checklists ensure monitoring records are appropriately maintained reviewed and any non-compliance issues addressed assist in identifying environmental risks
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CEMP Bays Road Relocation Works
advise the Project Manager of the need to stop work immediately if an unacceptable impact on the environment is likely to occur or to require other reasonable steps to be taken by the site Construction staff to avoid or minimise impacts
Environmental Consultants
Georgiou has engaged consultancy contracts with the following companies
Ade Consulting - Contaminated land and hygienist services VMS ndash Noise and Vibration Management Services ARTEFACT ndash Archaeological and Heritage Consultants
Throughout the works there may be the requirement to engage other specialist environmental consultants or change the consultants listed above All Environmental consultants engaged to provide specialist advice on environmental matters are responsible to
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the Supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Adhering to all permit requirements Complying with all statutory and regulatory requirements
All Personnel
All personnel on site are responsible for
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident undertake remedial action as required to ensure environmental controls are maintained in good working
order Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Participating and adhering to SWIrsquos and JHArsquos Adhering to all permit requirements Immediately stopping any lsquoAt Risk Behaviourrsquo identified during daily work activities Complying with statutory and regulatory requirements
Communication and Acceptance of Accountabilities and Responsibilities
The Core Site Team will acknowledge their understanding and acceptance of the site accountabilities and
responsibilities by signing Appendix 1 in this plan
Field Leadership Visits
Senior Management with an operational role or functional support will demonstrate visible and proactive commitment by visiting site to engage in discussion with site management and workers in regard to HSE issues relevant to the business which may include any of the following
Active participation and contribution in Pre-start meetings Participation in Toolbox Talks Participation in the delivery of site safety and environmental messages on-site HSE programs or initiatives Participation in work inspections One-on-one discussions
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Behavioural observations Participation in monthly meetings discussing HSEQ performance
A record of the visit and the activity undertaken by the Senior Manager will be recorded and where appropriate feedback provided to the Site team A component of the Site Leadership visit will involve an environmental inspection of the site in accordance with section 151
7 COMMUNICATION AND CONSULTATION
The following documents provide further information in regards to this topic
HSEQ Communication and Consultation Standard
Community Relationship Management Guideline
Resolution of HSE Issues Procedure
Internal Communication and Consultation
Communication and consultative arrangements will be put in place to provide workers including subcontractors
with information and an opportunity to contribute to HSE and comply with applicable legislative requirements
The Site will use the methods detailed below to communicate to employees subcontractors and visitors
information in regard to the Georgiou Management System this management plan performance and environmental
issues
711 Inductions
All personnel (including sub-contractors) are required to attend a compulsory site induction that includes an
environmental component prior to commencement on-site This is undertaken to ensure all personnel involved in
the Project are aware of the requirements of the CEMP The environmental component of the induction must cover
all elements of the CEMP and will include as a minimum
relevant details of the CEMP including all sub-plans procedures and strategies their purpose and objectives
policies and KPIs
Requirements of due diligence and duty of care
relevant legislation and conditions of environmental licences permits and approvals
Potential environmental emergencies on-site and the emergency response procedures
Reporting and notification requirements for pollution and other environmental incidents
key environmental issues
Mitigation measures for the control of environmental issues
Complaints response and reporting
Communication protocols for interactions with community and stakeholders
site specific environmental management requirements and responsibilities
Incident and emergency response and reporting requirements
Environmentally sensitive locations and no-goexclusion zones
Erosion and sediment controls water quality controls and sediment basin management
Management of contaminated material (including asbestos impacted material)
Location of identified potential contaminated land sites
Signs of contaminated soil including visual asbestos identification protocols
Procedure for unexpected finds of contaminated land asbestos
Water quality management and protection measures
Location of identified Aboriginal and non-Aboriginal archaeological heritage sites areas of cultural sensitivity
and areas of archaeological potential and the kinds of historical relics structures or deposits which may be
encountered during the Construction works
Unexpected finds procedures for heritage
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noise vibration and air quality management controls
Standard Construction hours and the process for seeking approval for out of hours works including consultation
Road occupancy and other temporary and interim traffic arrangements
Specific responsibilities for the protection of flora and fauna
A record of all environment inductions will be maintained in a Project induction and training Register and kept on-
site The training register will identify who is trained when trained the trainer and what they were trained in
712 HSE Notice Boards
All worksites that have a crib room will set up a HSE notice board to display
Project HSEQ Performance Report
Environmental BulletinsAlerts
Site HSEQ Objectives and Targets
Organisational Chart
A Site Layout Plan and Emergency Evacuation Plan Emergency contacts and First Aiders list These will also be
posted in prominent locations throughout the site as described in the site Emergency Response Management
Plan
Risk Registers
713 HSE Alerts Bulletins
Incident Alerts will be used to communicate learningrsquos and actions required to assist in ensuring incidents that have
occurred in one workplace are not repeated in others HSE Bulletins will be used to communicate environmental
information to the workplace HSE Alerts and Bulletins will be developed by the Site Team using the approved
templates and approved by the HSE Business Unit Lead prior to communication
714 Site Meetings
The following meetings will be held on site to monitor implementation of the Georgiou Management System review
performance and communicate consult with workers in regards to HSE
Site Meetings (refer to section 142) Pre-Start Meetings Toolbox Meetings
Meeting agenda and minutes will be recorded maintained and be made available when required
Community and Stakeholder Involvement
A Community Communication Strategy will be developed for the project Key elements of the Community
Communication Strategy which will be implemented at appropriate times in the construction process will include
Notification (including targeted letterbox drops and email) of any works that may disturb local residents and businesses (such as noisy activities and night works) at least seven days prior to those works commencing
Notification (including targeted letterbox drops and email) of works that may affect transport (such as road closures changes to pedestrian routes and changes to bus stops)
Traffic alerts (via email) to all key traffic and transport stakeholders advising of any changes to access and local traffic arrangements (at least seven days prior to significant events)
Print and radio advertisements regarding major traffic changes 24-hour toll-free community project information phone line Complaints management Community information sessions as required Regular updates to the Sydney Metro website (sydneymetroinfo) including uploading of all relevant
documents and contact details for the stakeholder and community relations team
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Provision of information to the Sydney Metro Community Information Centre including community newsletters information brochures and fact sheets and interactive web-based activities
Clear signage at the construction sites Newspaper advertisements in local and metropolitan papers as required Regular inter-agency group meetings Community business and stakeholder satisfaction surveys and feedback forms Translator and interpreter services and The project team will liaise with the Sydney Metro Project Communications team as the point of contact for
the community
721 Complaints Management
Community liaison and complaints handling will be undertaken in accordance with the Construction Complaints
Management System and will include
dealing with complaints in a responsive manner so that stakeholdersrsquo concerns are managed effectively and promptly and
A verbal response will be provided to the complainant as soon as possible and within a maximum of two hours from the time of the complaint (unless the complainant requests otherwise) A detailed written response will then be provided if required to the complainant within one week
A complaints register will be maintained in Georgioursquos BEAKON database and in Sydney Metrorsquos Consultation
Manager TM which will contain
Date and time of complaint Method by which the complaint was made (telephone letter meeting etc) Name address and contact telephone number of complainant (if no such details were provided a note to that
effect) Nature of complaint Action taken in response including follow up contact with the complainant Any monitoring to confirm that the complaint has been satisfactorily resolved If no action was taken the reasons why no action was taken
The project will apply an adaptive approach to ensure that corrective actions are applied in consultation with the
appropriate construction staff to allow improvements in the management of issues resulting in community
complaints
722 Urban Design of temporary works
Temporary construction works will consider urban design and visual impacts including
Minimise impacts on existing landscape features as far as feasible and reasonable Artwork graphics and images to enhance the visual appearance of temporary works in high visibility locations Project information to raise awareness on benefits explain the proposed works at each site and provide
updates on construction progress Community information including contact numbers for enquiries complaints Signage and information to mitigate impacts on local businesses which may be obscured by the construction site Sydney Metro advertising public awareness campaigns Logos branding including Sydney Metro NSW Government and Contractor branding
The design of all temporary works will require Sydney Metro approval in relation to urban design and visual impacts
and Sydney Metro will stipulate the design of hording artwork including
Sydney Metro advertising public awareness campaigns and Logos branding including Sydney Metro NSW Government and Contractor branding
Construction hoardings scaffolding and acoustic sheds will be regularly inspected and kept clean and free of dust
build up Graffiti on construction hoardings scaffolding or acoustic sheds will be removed or painted over
promptly The principles of Crime Prevention Through Environmental Design will be applied to all works including
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temporary works that have a public interface
723 Business and Property Impacts
The project footprint is within any area managed by the Port Authority of NSW and several port related facilities
are adjacent to the work including Cement Australia Gypsum Resources Australia and Sugar Australia Georgiou will
undertake works to meet the following objectives
Minimise the potential impact of the project to businesses affected by construction works Ensure businesses are kept informed of the project and consulted in advance of major works or factors that are
likely to have a direct impact Ensure that business stakeholder enquiries and complaints regarding the project are managed and resolved
effectively
Consult with all business directly affected by changes to access arrangements regarding specific requirements at least two weeks prior to those changes coming into effect
8 HAZARD IDENTIFICATION AND RISK CONTROL
The following documents provide further information in regards to this topic
HSEQ Risk and Operational Control Standard Job Hazard Analysis (JHA) Procedure Permit to Work Procedure
Hierarchy of Control
The following hierarchy of control will be applied to controlling environmental risks and environmental aspects
within Georgiou This hierarchy recognises that the best controls act on the environment not on the people in it
HazardsAspects
Waste
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Site Environmental Risk Analysis
The Site Team has undertaken a construction risk assessment workshop (CRAW) and developed a HSEQ Risk
Register based on the Master Risk Register which incorporates the Companyrsquos mandatory controls and additional
site specific hazards and controls identified in the CRAW This Management Plan and the Emergency Response
Management Plan have been based upon this HSEQ Risk Register
Works on site will be undertaken in accordance with the HSEQ Risk Register The HSEQ Risk Register will be
made available to workers
Review of Risks
The aspects within the HSEQ Risk Register will be reviewed for adequacy
At site meetings Prior to the commencement of any new construction work that involves high impact risks After a significant incident
If there is a change made to the construction methodology and associated change in the risks and controls associated with the works the Risk register and Construction Environmental Management Plan will be updated as appropriate
831 Change Management
The following documents provide further information in regards to this topic
Change Management Procedure
Where there is a change to the planned scope design or construction methodology (including plant machinery
materials or sequence) the impact of the change must be assessed and a determination on whether the Change
Management Procedure applies If so then a formal analysis of the change will be undertaken using the
Management of Change Event Design Form
Changes to the project may require an assessment to determine consistency with the REF and Environmental
Documents The assessment will include
A description of the existing surrounding environment Details of the ancillary works and construction activities required to be carried out including the hours of works An assessment of the environmental impacts of the works including but not necessarily limited to traffic
noise and vibration air quality soil and water ecology and heritage Details of mitigation measures and monitoring specific to the works that would be implemented to minimise
environmental impacts Identification of the timing for completion of the construction works and how the sites would be reinstated
(including any necessary rehabilitation)
Operational Control
Operations and activities associated with significant environmental aspects will be planned to ensure they are
carried out under specific operating conditions An Environmental Control Map (ECM) Safe Work Method
Statements Job Hazard Analysis Take Five Hazard Report or a combination of these will be used to achieve this
requirement
841 Environmental Hazard Reporting
Environmental Hazard reporting will be conducted using the Hazard Report (contained within the Hazard
ReportTake 5 booklet)
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The Supervisor is responsible for ensuring environmental hazards are addressed in a timely manner using the
hierarchy of control and communicated to those who may be potentially affected Where hazards cannot be
addressed immediately and additional controls are required they are to be reported into the Beakon system for
follow-up and close-out
842 Take 5
Take 5 booklets will be available to all workers to perform risk assessments for work that is not high risk
construction Take 5 risk assessments include environmental aspects and the identified environmental controls for
these risks are to be documented on the Take 5 form and implemented for the works
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS)
JHASWMS will be completed for all high risk construction work JHASWMS developed will reflect the safety and
environmental risks and controls identified in the sites risk register and supporting work instructions
Subcontractors will be provided access to the sites HSEQ Risk Register and prior to undertaking the work will be
required to submit their JHArsquosSWMS to Georgiou for review and approval using the Subcontractor JHASWMS
Assessment (available in Beakon)
844 Permit to Work
The following high risk activities require written authority in the form of a ldquopermit to workrdquo from the Georgiou Site
Team
Vegetation Clearing Permit (Georgiou form) Dewatering Permit (Georgiou form) Out of Hours application (Sydney Metro form)
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices) will be included in the
environmental permits No work involving these activities will commence until the appropriate permit has been
completed Personrsquos issuing permits on the Site will be given training in the Georgiou Permit to Work system A
permit may be required for other high risk activities as determined by risk assessment the Sitersquos Manager andor
contractual requirements
845 Environmental Control Maps
To assist pre-construction planning and on-site construction management the environmental site constraints are
consolidated on a series of map-based sheets that extend the length of the Project Environmental Control maps
include information pertaining but not limited to
Noise and vibration sensitive receiverrsquos eg residential dwellings
Flora features including threatened species and endangered ecological communities
Aboriginal and non-Aboriginal heritage sites including items places objects and sites
Local waterways
Recorded threatened fauna sightings
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices)
The Environmental Control maps are a working element of the CEMP and will be revised throughout construction to
reflect true ground conditions and the most up-to-date information available on sensitive sites Sensitive area maps
will be used in conjunction with EWMS and ESCPs to help identify key risk areas and to promote ongoing
communication to construction personnel during the Project
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9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT
The following environment aspects have been identified as significant for this project Risks associated with these
significant aspects and appropriate controls have been identified during the construction risk assessment workshop
(CRAW) and included in the HSEQ Risk Register in accordance with section 82
In addition aspect specific sub-plans within this CEMP have been developed to detail how the environmental
aspects will be managed to comply with relevant legislation amp client requirements These aspect specific sub plans
include
Waste
Soil and Water
Hydrocarbon and Chemical
Cultural Heritage
Air Quality and Dust
Noise and Vibration
Contamination
10 CLOSURE AND COMMISSIONING
At completion of this project Georgiou will hand over the site in an environmentally responsible state) taking into
account the nature of the works in accordance with legislative amp contractual requirements
11 TRAINING COMPETENCY AND RESOURCING
All Georgiou personnel and contractors will undergo environmental training before commencing works on site
Training will be undertaken in the following forms
project site induction (section 711) and Environmental awareness training through regular tool box discussions Inductees will be required to sign-off that they have been informed of the environmental issues and that they
understand their responsibilities
1111 Toolbox talks
ldquoToolboxrdquo training will help to ensure that relevant information is communicated to the workforce and that
feedback can be provided on issues of interest or concern ldquoToolboxrdquo training will generally be prepared and
delivered by the Project Engineers Site Foreman or HSE Advisor Toolbox training topics are to be delivered to
provide refresher information on the environmental induction topics and associated environmental procedures In
the event of environmental near misses or incidents or changes to procedures that could result in changed levels of
environmental risks Toolbox talks may be used to deliver updates
Toolbox topics likely to be required include
work methods and efficient use of plant and materials waste management minimisation and recycling dust control protecting waterways spills and leaks emergency response procedures wet weather procedures and inspections and Legislation updates Please refer to the Toolbox schedule for a library of HSE toolboxes to deliver over the life of the project
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1112 Recording of Training and Assessment
Records of training and assessment will be maintained and will be readily available for verification Records of
induction and training will include the topic of the training carried out dates names and trainer details
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE
The following documents provide further information in regard to this topic
Emergency Preparedness and Response Standard
EmergencyIncident Planning and Control
The site has in place an Emergency Response Management Plan (ERMP) that addresses emergency response control
and recovery based upon credible emergency scenarios as identified in the Site Risk Register The Emergency
Response Management Plan has been developed in accordance with Emergency Preparedness and Standard
13 HSE REPORTING AND INVESTIGATION
The following documents provide further information in regard to this topic
Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
Notifications and Reporting
The Project Manager is accountable for ensuring all necessary reporting and notifications take place including
Client notification Statutory notification Scheme notification Community Complaints
Notifications and reporting regarding incidents will be done in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure
1311 Internal
The Environmental Site Representative or their delegate will be responsible for reporting all incidents into Beakon
database Incidents reported into Beakon will be reviewed by the Responsible Manager and approved within five
working days or before month end in which the incident occurred
1312 Notification of Incidents to Sydney Metro
Sydney Metro will be notified of any Georgiou environmental incident as soon as reasonably practicable Copies of
the incident reports and investigations incident will be made available to Sydney Metro within 48 hours in
accordance with the Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
1313 Statutory Notifications
An incident is an uncontrolled event or violation with serious or potentially serious negative consequences to
people property reputation or the environment Under Section 148 of the Protection of the Environment
Operations Act 1997 (POEO Act) Georgiou has a duty to immediately report pollution incidents causing or
threatening material harm to the environment Material harm is defined in Section 147 of the POEO Act as
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lsquoinvolves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding
$10000 and this loss includes the reasonable costs and expenses that would be incurred in taking all reasonable
and practicable measures to prevent mitigate or make good harm to the environmentrsquo
Investigations
Investigations regarding the incident will be completed in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure and commence as soon as practicable (preferably
immediately) but within 24 hours
All environmental incidents would be investigated in such a manner that the following basic elements can be
established
identifying the cause extent and responsibility of the incident
identifying and implementing the necessary corrective action
identifying the personnel responsible for carrying out the corrective action
implementing or modifying controls necessary to avoid a repeat occurrence of the incident
recording any changes in written procedures required and
Advising regulatory authorities in accordance with licence conditions
Review and Communication of Incidents
Incidents will be reviewed to check that causal factors and root causes were identified and that the findings have
been effectively addressed through assignment of actions at the
Site monthly meetings Business Unit meetings OHS Committee Meeting (if established)
Actual and potential class 1 incidents will be reviewed by senior management to ensure adequacy of closeout HSE
incidents and their preventative actionslearnings will be communicated at pre-start meetings toolbox meetings
and through HSE alertsbulletins as per section 7
14 ENVIRONMENTAL REPORTING
1411 Monthly Reports
Georgiou is required to submit an Environmental Monthly Report to the client including the information specified
below as evidence of implementation of the Environmental Management Plan
Implementation of environmental management including environmental monitoring implementation of environmental controls training inspections and testing
Implementation of incident management including emergency response - details of all environmental incidents or emergencies including non-compliance with environmental procedures and near misses complaints implementation of incident and emergency response management and implementation of corrective action
Implementation of reviews - details of internal reviews audits and inspections undertaken to verify that on-site environmental processes and practices conform to the Environmental Management Plan
Waste Statistics and NGERs reporting
Site Meetings
The Site will hold a monthly HSEQ Management Meeting in accordance with the Health amp Safety Management Plan
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Project Performance Review
At completion of the Project the Project Manager is responsible for arranging a review of project performance
which will include HSE management performance and lessons learnt for the purpose of continually improving
Georgiou Management Systems This review will be in accordance with the Project Close-Out Procedure
15 AUDITING REVIEWS AND INSPECTIONS
The following documents provide further information in regards to this topic
Auditing Reviews and Inspections Standard
Inspections
1511 Environmental Inspections
The following inspections will take place on site
Environmental Weekly Inspections Detailed Hazard Inspections considering timingavailability of activities Site leadership field visits These inspections will be used a process to monitor onsite environmental performance and they will cover all applied environmental mitigation measures including water quality erosion and sediment control structures fuel and chemical storage and waste management Attendees for the inspections can include Sydney Metro Environmental and project team members Georgiou Environmental and project team members and Georgiou Senior and Executive Management when conducting a Field Leadership Visit (section 64) The Environmental Site Representative will record inspection findings on the inspection report If any maintenance andor deficiencies in environmental controls or in the standard of environmental performance are observed they will be recorded on the inspection Records will also include details of any maintenance required the nature of the deficiency any actions required and an implementation priority Any Sydney Metro Environmental Inspections will occur on the Sydney Metro Inspection record template ndash Appendix 10
Audits and Reviews
The following audits are scheduled for this site
Internal
AuditReview
Purpose Commencement On-going requirement
Site HSE Mobilisation Audit
Review achievement towards site start-up activities
8 weeks after mobilisation NA
Internal HSEQ audit
Determine compliance to the management systems and an assessment as the effectiveness of those requirements to meet our legal and other obligations
Within 6 months of project start up
6 monthly
Sydney Metro (or an independent environmental auditor) Audit
EampSMS and compliance with the environmental aspects of contract documentation including Construction Environmental Management Framework
Construction Periodic
to be confirmed
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The Project Environmental Site Representative will be the principal contact for external auditors wishing to audit
the Sitersquos environmental management systems The Project Environmental Site Representative will be responsible
for responding to any external audits findings
Monitoring
Environment monitoring will be undertaken to validate the impacts predicted for the Project The monitoring
requirements for required aspects are included in the relevant environmental management sub-plans (Appendices)
All environmental monitoring equipment shall be maintained and calibrated according to manufacturerrsquos
specifications and appropriate records kept
Where monitoring results are outside of the expected range and are directly attributable to the Project (ie are
influenced by factors under the direct control of the Project eg noise from construction equipment) the process
described below will occur
An analysis of the results by the Environmental Site Representative in more detail with a view of determining possible causes for the non-conformance
A site inspection by the Environmental Site Representative or delegate Advising relevant personnel of the problem Identifying and agreeing on actions to resolve or mitigate the non-conformance Implementing actions to rectify or mitigate the non-conformance
Corrective Actions
Corrective actions identified through hazards inspections incidents auditing will be recorded in Beakon Close out of corrective actions are monitored through Site meetings and reported to senior management through the monthly and quarterly board reports
16 DOCUMENT AND RECORD CONTROL
Georgioursquos Health Safety and Environment Policies Standards Procedures Safe Work Instructions References
Guidelines Forms Templates are all accessible via the Companyrsquos Intranet - GENIE GENIE will maintain the
current and only authorised versions for use
Environment Management documentation that has been specifically developed for the site will be controlled on site
and recorded on the Site Document Register in accordance with the Site Quality Management Plan
The Project Manager is the owner of this plan and will apply change control to ensure the most recent plans are
approved and executed
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17 APPENDICES
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Appendix 1 - Waste Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise spoil generation where possible The project will mandate 100 reuse or recycling (on or off-site) of usable spoil Spoil will be managed with consideration to minimising adverse traffic and transport related issues Spoil will be managed to avoid contamination of land or water Spoil will be managed with consideration of the impacts on residents and other sensitive receivers Site contamination will be effectively managed to limit the potential risk to human health and the environment Minimise waste throughout the project life-cycle Avoidance of unnecessary resource consumption Resource recovery (including reuse reprocessing recycling and energy recovery) and Disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Project Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Training and Competency
As part of the Site Induction workers will be informed of
- The types of waste generated on site
- How the wastes are to be handled stored and disposed of Personnel responsible for clean-up of spills will be provided with instruction on how to use the sites
spill kits Personnel handling hazardous materials will be provided training to read and understand the SDS
Project Manager
Unidentified Waste Wastes that cannot be positively identified (ie unlabelled liquids potential asbestos) will be tested
before handling and disposal Any material that is unknown should be considered hazardous until positively identified
Project Engineer
Handling
Where practicable dust generating rubbish and debris will be removed to minimise dust release into the atmosphere
Handling of waste will be done in accordance with relevant state or local by-laws using suitable personal protective equipment
Project Engineer
Storage
Containers used for storage are not to be opened handled transported or stored in a manner that may rupture the container
All waste will be stored in waste receptacles and removed off site by a licensed contractor on a periodic basis
Dedicated recyclable and hazardous receptacles will be labelled Wastes stored on site will be stored in a manner to prevent the attraction of vermin and native
wildlife Waste is to be stored away from access and egress routes
All
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Appendix 1 - Waste Management Sub Plan Responsibility
The quantity and volume of wastes stored on site may be minimised where reasonably practical to reduce the risk to health safety and the Environment
Project Managers will be responsible for identifying and obtaining any required licenses andor permits to store wastes
Disposal
In deciding how to dispose of waste generated on site consideration will be given to reducing reusing or recycling waste where reasonably practical to minimize the volume sent to landfill Where reuse or recycling is not a feasible option the waste will be sent to a facility capable of accepting the waste
The burning of any type of wastes will not be permitted on any Georgiou site The use of stormwater drains for the disposal of waste is prohibited The disposal of waste will be done in a manner to prevent any damage to the environment
Project Engineer
Transportation
The removal and transportation of hazardous waste controlled waste (eg asbestos hydrocarbons and sewage) for disposal will only be conducted by licensed carriers Licensed operators will be engaged in accordance with the Procurement Procedure
Before a hazardous waste controlled waste is transported off site a waste tracking receipt will be collected from the operator as verification that the waste was correctly transported off site and to identify the proposed location for disposal The receipt will be scanned and filed into the DMS and linked to the Site Waste Register A copy of the receipt will be held for a minimum of 3 years
The transportation of other wastes for disposal will only be conducted if the load is covered or there is no risk of loaddebris falling and the load is disposed of at a registered landfill
Project Manager
Spoil
Although the Project would require the importation of fill material the excess spoil would be generated including from the following sources
Soils ndash This includes any topsoil and natural subsoils (ie soils between the topsoil and underlying bedrock)
Natural rock ndash This material would be generated from excavation of sandstone bed rock if required Road construction material ndash This would include material generated from the demolition of the
existing roads such as asphalt concrete geotechnically stabilised road sub-base and base material
Project Engineer
Spoil Classification
Spoil generated during the Construction of the Project will be firstly assessed for reuse in the project Should it not be suitable for onsite reuse it will be assessed in accordance with the Sydney Metro Classification Procedure (Appendix 1A) It will firstly be assessed against the requirements for Virgin Excavated Natural Material (VENM) detailed within the Protection of the Environment Operations Act 1997(POEO Act)
Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
If the material is not deemed to be VENM an assessment of the suitability of any current general resource recovery exemptions issued under the Protection of the Environment Operations (Waste) Regulation 2014 will be undertaken Current general resource recovery exemptions that may apply to the Project are
The excavated natural material exemption 2014 The excavated public road material exemption 2014 Spoil that cannot be re-used onsite or offsite under any of the exemptions stated above or classified as VENM will require waste classification in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (EPA 2014) prior to offsite disposal at an appropriately licensed facility
The management of spoil generated from the Project will be guided by the hierarchy detailed below
Rank Control Measure Implementation Example Potential to implement on Project
1 Avoid and reduce spoil
generation Reduce the amount of spoil being
generated through design and construction methodology
Limited
2 Prioritise reuse of contaminated
spoil onsite vs clean spoil Identify areas with lower risk of
contamination to spoil offsite as this will result in lower waste disposal costs for project
GSW and Contaminated Spoil is to
be utilised as fill on the project
prior to the use of excavated
sandstoneVENM The project will
produce excess spoil and the
priority is for this excess to be
sandstoneVENM
3 Reuse within Project Prioritise reuse of more contaminated
spoil onsite vs less contaminated spoil Reuse in the Project to fill
embankments and mounds within short haulage distance of source
Restoration of any pre-existing contaminated sites within the Project boundaries
Reuse as a feed product in Construction materials (eg concrete)
Preferred but dependant on area
available
Project Manager Project Engineer Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
4 Reuse for environmental works Reuse in revegetation and
rehabilitation projects Reuse in operational noise mitigation
works
Preferred as stockpiling on site is
restricted
5 Reuse on other development
projects Reuse for fill embankments and
mounds on projects within an economic transport distance from site
Preferred as stockpiling on site is
restricted
6 Reuse for land restoration Reuse for land reclamation or
remediation works Reuse to fill disused facilities eg
mines and quarries to enable ecological rehabilitation or other ecologically beneficial end use
Preferred as stockpiling on site is
restricted
7 Reuse for landfill management Reuse to cap completed landfill cells Reuse in daily covering of landfill
waste
Limited
8 Dispose offsite as waste Disposal of excess spoil as waste at an
approved facility licensed to receive that material
Potential but not preferred
Hazardous Waste - General
Hazardous wastes will be stored in sealed containers where practical and clearly labelled with waste type
Hazardous waste receptacles will be maintained in good condition to prevent leaks or spills Offensive odours should not be generated at any time when stored Hazardous wastes with a significant risk to human health and safety will be stored in containers that
comply with relevant legislation and guidelines Hazardous wastes will not be permitted to accumulate to a level that presents an unreasonable risk
to human health safety or the environment Controlled waste storage will be suitably contained to ensure debris does not travel beyond the boundary of the premise
Hazardous waste will be stored and segregated in accordance with their SDS Hazardous waste will be risk assessed to ensure they do not contaminate or interact with goods that are incompatible Where there may be a risk of fire hazardous waste will be segregated to prevent storage incompatibilities
Hazardous liquid waste will not be permitted to enter the environment
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 40 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
Design considerations for secondary containment will be given to the storage of liquid wastes to contain any potential spills Hazardous waste will be stored onin bunded palletsareas which will be compliant with AS1940-2004 443 (the bunded palletarea must have the capacity to contain 110 of the largest container
Hazardous waste such as batteries hydrocarbons sewage and asbestos will only be handled for final disposal recycling by certified waste removing contractors Sewage waste not plumbed directly into the main sewerage system will be contained within holding tanks on site compounds and emptied on a periodic basis or as required by a licenced contractor
Hazardous Waste - Batteries
Automotive and lead-based batteries will be stored in a manner that does not contaminate the natural surrounding environment This may include storage on bunded palletsareas on concrete hard stand or on any other sealed surface
All
Hazardous Waste - Asbestos
The disposal processes for asbestos will involve independent competent persons Identified ACM (Asbestos Contaminated Material) will be clearly marked out and controls put in place
to prevent contamination into surrounding areas
Project Manager
Hazardous Waste - Sanitary Sewage Waste
Sewage waste will either be plumbed directly into the main sewerage system or contained within holding tanks on site compounds and emptied as required
Sewage waste stored in bunded tanks underneath the toilets will be emptied by a licensed contractor on a periodic basis
Sanitary wastes will be stored in solid containers and clearly labelled for identification Sanitary wastes will not be re-handled after disposal to minimise the exposure and risk of double
handling Sanitary conveniences will be calculated based on the number of workers based on the site and meet
legislative requirements Sanitary waste will be stored away from food sources or where food is served Controls to prevent offensive odours to the public and workers will be implemented
Project Engineer
Recyclable Waste
On site paper and cardboard and scrap metal will be segregated to be collected and transported to a recycling facility
Green waste will be mulched and stockpiled with topsoil for use in revegetation Aggregate will be segregated during cut and fill operations for re-use
Project Engineer
Waste Water Any waste water or liquids must be disposed of to an approved receptacle and stored within an approved bunded location until they are removed from site
Project Engineer
Putrescible Waste Putrescibles waste will be stored into general waste containers that prevent the release of debris and leachate
Project Engineer
Clinical Waste In the event that clinical waste has been found the following control may be employed Project Engineer
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12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
Syringes and needles found on site will be stored in a clearly labelled solid sealed container to prevent access to contents They will be disposed of at a licenced provider
Clinical wastes will not be re-handled after disposal to minimise the exposure and risk of double handling
Concrete
Kibbles Concrete truck are to be washed out into a designated bunded area When the concrete is dried it will be disposed of with general waste
At no point will any Concrete truck or kibble be permitted to wash out at any point other than the designated area with all the associated controls in place
Project Engineer
Weekly (VisualDocumented)
DHI Environment to be completed via Beakon HSE Advisor
Reporting HSEQ Monthly Management Meeting Monitor and record the volumes of waste and the methods and locations of disposal Maintain records of all required waste dockets and receipts and provide to Sydney Metro monthly
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 42 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 1A ndash Sydney Metro Waste Classification Procedure
Unclassified
Unclassified
Waste Classification Procedure
SM-20-00040677
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Hugh Chapman Associate Director Environment Operations Customer amp Place-Making
System Owner Carolyn Riley Director Environment Sustainability amp Planning
Status Final
Version 30
Date of issue Pending
Review date Pending
copy Sydney Metro 2020
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 2 of 14
SM-20-00040677 Waste Classification Procedure V30
Table of contents
1 Introduction 3
11 Purpose and scope 3
12 Definitions 3
13 Spoil Management Decision Framework 5
14 Spoil Handling and Segregation 5
15 Typical Application of the Framework 6
16 Unexpected Finds Protocol 7
17 Accountabilities 14
2 Related documents and references 14
3 Superseded documents 14
4 Document history 14
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 3 of 14
SM-20-00040677 Waste Classification Procedure V30
1 Introduction
11 Purpose and scope
This framework describes the approach to classifying spoil and demolition materials generated during works in accordance with environmental legislation and guidelines
This framework considers the reuse of materials on site the beneficial reuse of materials transported off site as waste (for example as virgin excavated natural material [VENM]) the recycling of materials at offsite facilities and the offsite disposal of materials when reuserecycling is not achievable
The framework considers only the compliance and classification elements of the spoil management process and does not consider all of the practical issues associated with construction geotechnical properties of the spoil or market forces and costs that influence the reuse potential of spoil or other wastes
Section 16 of this framework outlines an Unexpected Find Protocol (UFP) to be implemented should unexpected potential contamination be found during works
12 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined within the SM-17-00000203 Sydney Metro glossary Acronyms specific to this document are listed below
Definitions
2014 Waste Regulation
Protection of the Environment Operations (Waste) Regulation 2014
CLM Act Contaminated Land Management Act 1997
Contamination
As defined in the CLM Act ldquomeans the presence in on or under the land of a substance at a concentration above the concentration at which the substance is normally presenthellipin the same localityhellipthat presents a risk of harm to human health or any other aspect of the environmentrdquo
Demolition materials
Materials such as concrete bricks and timber resulting from the demolition of buildings and structures Most demolition materials are pre-classified as General Solid Waste (non-putrescible) (see definition below) under the NSW EPA (2014) Waste Classification Guidelines However some demolition materials such as asbestos have other classifications as described below
EIS Environmental Impact Statement for the project which assesses potential environmental impacts and mitigation measures in accordance with the EPampA Act (see below)
ENM Excavated Natural Material as defined in The excavated natural material order 2014
being excavated material that is at least 98 (by weight) natural material that does not meet the definition of VENM (see below)
EPA NSW Environment Protection Authority
EPampA Act Environmental Planning amp Assessment Act 1979
EPL
Environment Protection Licence as may be held by an owner or operator of a premise licensed to receive process recover or store waste The EPL will contain a number of conditions that must be met by the holder These will specify the type(s) of waste the facility is permitted to receive process recover or store and include pollution prevention or monitoring requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 4 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Fill Soil and any associated extraneous materials (such as demolition wastes industrial by-products and refuse) imported to and placed at the location
GSW
General Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines GSW may be classified as putrescible or non-putrescible depending on the content of putrescible organic material Spoil and demolition materials are typically non-putrescible
HW
Hazardous Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines HW must be treated prior to disposal to landfill HW is typically
spoil that is contaminated with chemicals at concentrations that exceed all screening criteria specified in Step 5 of the Waste Classification Guidelines
Naturally Occurring Soil
Any soil which has not been significantly disturbed by human activities
NEPM National Environmental Protection (Assessment of Site Contamination) Measure 2013
POEO Act Protection of the Environment Operations Act 1997
Recycling Material that is removed from the project site (thereby becoming Waste) and is deposited at an appropriately licenced recycling facility for processing prior to reuse by others
REF Review of Environment Factors which addresses the likely environmental impacts and details protective measures to manage against any adverse effects in accordance with the EPampA Act
Remediation
As defined in the CLM Act remediation of contaminated land includes
(a) preparing a long-term management plan (if any) for the land and
(b) removing dispersing destroying reducing mitigating or containing the contamination of the land and
(c) eliminating or reducing any hazard arising from the contamination of the land (including by preventing the entry of persons or animals on the land)rdquo
Remediation is the act of mitigating exposure to contamination in its original location The process of remediation can generate spoil that may be subject to reuse within the project area (where that reuse is adequately controlled in order to mitigate exposure risks) or the removal of contaminated spoil for treatment andor disposal off site
Reuse offsite
Material to be reused by application to land at a location outside of the project site without the need for processing prior to reuse Material meeting the definition of VENM or ENM or material that is subject to an RRO and RRO are suitable (from an environmental perspective) for reuse at remote sites where all requirements of the POEO Act and CLM Act are met
Reuse onsite
Material that is excavated on the project site and reused on the project site Material to be reused onsite is not defined as Waste and does not require classification in accordance with NSW EPA (2014) Waste Classification Guidelines The material must be suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and must not cause pollution under the POEO Act If transport to another part of the project area requires material to be taken outside the site boundary temporarily this must be undertaken in accordance with the EIS or following consultation with relevant regulators
RRE Resource Recovery Exemption contains the conditions that must be met by consumers of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RRO Resource Recovery Order contains the conditions that must be met by generators and processors of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RSW Restricted Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines An example of RSW is spoil that is contaminated with chemicals above the criteria specified in Step 5 of the Waste Classification Guidelines
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 5 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Special Waste
As defined in the NSW EPA (2014) Waste Classification Guidelines a class of waste with
unique regulatory requirements Asbestos or any waste containing asbestos (eg spoil containing any fragments of asbestos cement sheeting) is Special Waste If Special Waste is mixed with RSW or HW (eg spoil classified as RSW that also contains asbestos) then the waste must be managed in accordance with both classifications
Spoil Soil or rock material generated from excavation activities
UFP Unexpected Find Protocol
VENM Virgin Excavated Natural Material as defined in Schedule 1 of the POEO Act being excavated natural material not mixed with any other waste and not from a contaminated area
WARR Act Waste Avoidance and Resource Recovery Act 2001
Waste Spoil or demolition material that has been taken off site which may be classified as Special Waste GSW RSW or HW
13 Spoil Management Decision Framework
Figure 1 provides a high-level flowchart for decisions regarding the fate of spoil generated on the site As reflected in Figure 1 the preferred spoil management hierarchy for the project listed from most preferred to least preferred is as follows
1 Spoil is reused within the project boundary
2 Spoil is beneficially reused at an appropriate offsite location
3 Spoil is recycled at an offsite licenced facility
4 Spoil is disposed to landfill
The approach to spoil classification is further detailed in Table 1 Table 1 describes the criteria information inputs and control measures required to be applied when reusing spoil on site reusing spoil offsite recycling spoil offsite or disposing of spoil
The framework does not account for the practical site based engineering or financial constraints associated with the hierarchy These must be addressed during delivery and the most appropriate efficient and sustainable method of spoil management adopted
14 Spoil Handling and Segregation
Careful excavation handling and segregation of spoil is critical to ensuring that materials with varying classifications are not mixed (cross-contaminated) and are not reused recycled or disposed in a manner inconsistent with their classifications
Appropriate segregation is also important in controlling the costs of spoil disposal to landfill noting that the inadvertent mixing of materials with low concentrations of contaminants with materials containing higher concentrations typically results in a higher classification and higher disposal rate (financial) being applied to all of the materials
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
The following processes are to be applied when excavating handling and segregating all spoil (for clarity a reference to a ldquogeological unitrdquo includes units or different layerstypes of Fill)
Spoil from each geological unit should be classified separately using sampling data that relates only to that unit Classification sampling may be performed in-situ (prior to excavation) or ex-situ (following excavation)
Spoil from each geological unit (as described in Part 4 below) should be excavated segregated and stored separately from spoil arising from other geological units
Excavations should be carefully monitored for visual indications of contamination such as stained soils odorous soils or the presence of anthropogenic waste materials Any spoil containing visual indicators of contamination will be excavated segregated and stored separately from other spoil Where unexpected contamination is identified an appropriate unexpected finds procedure must be implemented to manage potential human health or environmental risk (refer to Part 5)
Each spoil stockpile should be treated as a ldquobatchrdquo with its classification data clearly identifiable and will be handled stored transported and reusedrecycleddisposed as a batch Spoil stockpiles will not be managed in a ldquocontinuousrdquo manner with portions added taken away or mixed over a period of time and
Spoil should be tracked from cradle to grave to ensure a complete and accurate record of movement from the point of excavation to the final point of placement For clarity this includes tracking of spoil movement on the site as well as off the site
Tracking of spoil movement (whether the spoil is waste or not) requires must include written records of spoil excavation handling transport storage and placement via a centralised tracking system Personnel must be suitably trained in the use of the system and sufficient detail must be recorded and retained such that material typesclassifications volumes and location are tracked from the time the material is excavated until it is placed permanently (onsite or offsite) This includes accurate records of any interim handling or placement (such as stockpiling or treatment) Stockpiles onsite are to be clearly labelled at all times Tracking information is to be kept on-site and be available on request
15 Typical Application of the Framework
This section provides some practical guidance in implementing the spoil classification framework (further detailed in the attached Figure 1 and Table 1
An explanation of the likely classification of spoil excavated during works based on typical geological units is provided below
Fill ndash Fill is imported materials which have been placed on the site at some time in the past Fill generally exists at depths ranging up to 3m below ground surface on developed areas and brownfield sites Fill may exist to depths exceeding 20m in reclaimed lands landfill sites former brick pits footings and similar Fill cannot be classified as VENM Fill has an increased likelihood of being contaminated (compared to natural soils) and will predominantly be classifiable for offsite disposal as GSW Special Waste RSW or HW Some materials such as road base or crushed concrete may be recoverable under generic or specific RRERRO arrangements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Naturally Occuring Soils ndash Soil which has not been significantly disturbed by human activities Naturally occurring soils may be residual soil sediments aeolian or other In the majority of cases naturally occurring soils will be classifiable as VENM or ENM for offsite reuse However where overlying contamination in Fill has leached and caused contamination of underlying natural soils where point sources of contamination are present (such as industrial facilities or fuel storage facilities) or where significant groundwater contamination has migrated into the area offsite reuse may not be appropriate and other classifications such as GSW RSW or HW may be applicable Where evidence of potential contamination exists spoil is required to be sampled and classified in accordance with NSW EPA (2014) Waste Classification Guidelines
Rock ndash Rock in-situ will in the majority of scenarios be classifiable as VENM or ENM unless significant contamination is present in overlying soils or significant contamination has migrated to the rock within groundwater Where the excavation of rock involves the use of additives (for example to facilitate tunnel boring) the material would no longer be classifiable as VENM or ENM and would instead likely be classifiable as GSW A project specific RRERRO would then be required to allow for offsite reuse
The type of material (ie geological unit) excavated during works will provide guidance on implementing the spoil classification framework in regard to reuse opportunities
Reuse Onsite ndash Any of the material excavated which is Fill a Natural Occurring Soil or Rock may be suitable for reuse on the project site Wherever reuse onsite is to occur the material does not require classification in accordance with the NSW EPA (2014) Waste Classification Guidelines Instead the material must be validated as being suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and the material must not cause pollution under the POEO Act For clarity the classifications GSW RSW and HW have no direct relationship to the potential for reuse of materials on the project site
Reuse Offsite ndash With the exception of Fill it is likely that the majority of spoil will be suitable from an environmental perspective for reuse off-site Specifically all VENM ENM and material to which an RRERRO apply will be suitable (from a legislative and environmental perspective) for reuse at an offsite location
16 Unexpected Finds Protocol
This section provides guidance on implementing the Unexpected Finds Protocol (UFP) which is detailed in the attached Figure 2 The purpose of the UFP is to provide a clear procedure in the event of an unexpected find of contamination or potential contamination The UFP is only to be implemented following an unexpected find The handling of known contamination should already be addressed in construction and environmental management plans
Key indicators of potential contamination include (but are not limited to)
Fibrous cement or other asbestos containing materials
Discolouration of soil
Odours from soil andor groundwater
Buried drums or underground storage tanks and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Oily sheen on water
Should any of the above be discovered and is considered to be unexpected then the UFP in Figure 2 will need to be implemented
An explanation of key actions within the UFP is provided below
Notifying the Site Supervisor ndash Site Supervisor or an appropriate delegate are to be made aware of the find immediately
Securing the affected area ndash This includes restricting access to the area and implementing appropriate environmental controls around affected area in minimise risk to the environment and human health Examples of controls include barricading the affected area the diversion of water to minimise potential spread via surface water runoff covering the area re-burying andor wet-down Environmental controls are to be implemented appropriately in regard to the contamination source and site conditions
Emergency Response ndash In the event that the find presents andor creates health or environmental concerns which would require an emergency response call 000 andor implement the projects incident response and reporting process
Notify Principal or Sydney Metro ndash The Principalrsquos Representative and the Environmental Representative must be notified of the unexpected find
Recommence works ndash Works can be recommenced in an alternate area where practicable and where it is safe to do so
Assessment ndash The potential for any ongoing risk to the environment or human health during construction or operation of the site and whether or not the agreed scope appropriately manages the contamination will need to be assessed by a competent and qualified person (ie a contaminated land specialist or in the case of asbestos a hygienist or asbestos assessor)
Material Classification ndash Contaminated materials which are to be removed from the site are to be classified in accordance with the NSW EPA Waste Classification Guidelines and the Spoil Classification Framework detailed in this document See Figure 1 and Table 1
An unexpected find may result in additional works being required for the remediation of contaminated materials which fall outside of the current scope of the project Any such works will need to comply will all relevant legislation and guidelines and will require appropriately qualified persons to prepare the methodology and controls Any such works will require approval from Sydney Metro
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Spoil classification process flow
Syd
ne
y M
etr
oN
SW
EP
A W
aste
Gu
ide
line
s C
lassific
ation
ndash P
art
1 (
20
14)
Syd
ne
y M
etr
o
Additional inputs or information requirementsProcess
Is there an opportunity to re-use the spoil
on site
Is there an opportunity to use the spoil at
an offsite locat ion
Can the spoil be recycled
The spoil must be classif ied in accordance with the NSW Environmental Protection Authority (EPA) Waste Classification
Guidelines
1) Is the waste Special Waste ie does the waste contain asbestos Refer to the Protection of the Environment Operations
(POEO) Act and Waste Regulation Part 4 Management of Special Waste
2) Is the waste Liquid Waste
3) Is the waste pre-classified
4) Does the waste have hazardous
characteristics
5) Classify by chemical assessment Waste generators must chemically assess their waste in accordance with Step 5 of the Waste
Classification Guidelines to determine the waste s classification where it has not been classified under Steps 1 to 4 of the Guidelines
Re-use onsite Cost time and engineering requirements to be
considered as well as environmental risks before placement
Re-use offsite To allow offsite use the material mist be classifiable
VENM ENM or be subject to Resource Recovery Exemption and Order
No matter the classification the offsite location must conf irm it can legally
accept the spoil
Recycle offsite The spoil must go to a licenced treatment facility and
must meet the specific requirements of that facilities licence
Liquid waste The waste is not spadable andor becomes free-flowing
at or below 60 degrees Celsius or when it is transported
Pre-classified waste Refer to NSW EPA Waste Classif ication guidelines
for pre-classificat ions of Hazardous Wastes General Solid Waste
Dangerous goods Meets Dangerous Goods Classificat ion for classes 1
2 41 42 43 5 61 and 8
The waste has been classified in accordance with the Waste Guidelines and is ready to be transported offsite Prior to transport
the following must be confirmed and all relevant requirements met
Is the landfill or facility licenced to accept the type of waste
Is the waste subject to waste tracking requirements under the POEO Act or any other regulation
Is the transport contractor licenced to carry the waste as classified
6) Is the waste putrescible
Sampling under Step 5 must meet the requirements of the NSW Waste Classification Guidelines
Sampling can be in-situ (ie prior to excavat ion) or ex-situ (from stockpiles after excavation) but in both
scenarios
Sampling density is to as a minimum meet the sampling densities recommended in the Victorian
EPA soil sampling guidance
httpsrefepavicgovau~mediaPublicationsIWRG702pdf
Analytes must reflect the contaminants of concern likely to be present at the site and as a
minimum consider Asbestos Metals TPH BTEX PAHs and PFAS Other side specific
contaminants may include hexavalent chromium PCBs pesticides etc
If retained onsite the Waste Classif ications Guidelines do not apply BUT the material must be suitable
from a human health and environment perspective to remain This requires assessment against the
NEPM and may include visual inspections or sampling and analysis The input of an appropriately
qualified professional is required prior to the re-use of any fill or potentially contaminated spoil
Once the spoil is removed from the site it becomes Waste All waste must be transported to a facility
that is licenced to accept it VENM ENM andor Resource Recovery ExemptionsOrders impart specific
requirements regarding assessment sampling analysis classificat ion and use of these types of spoil
The requirements regarding sampling and record retention must be adhered to
Once spoil is removed from the site it becomes Waste All Waste must be classified in accordance with
the NSW EPA Waste Classification Guidelines and be transported to a facility licenced to accept it
Note that whether or not the asbestos is present further classif ication is required under Steps 2 to 6 of
the EPA Waste Classification Guidelines
Yes or No
General solid waste restricted waste or hazardous waste
No
Yes
Yes
Yes
Yes or No
Yes
Yes
Yes
No
No
No
No
No
Figure 1 Spoil Classification process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Table 1 Spoil Classification process flow
Decision Criteria InputsData ControlsReview
Reuse of the material on or within the approved project area
Most preferred option under WARR Act and Sydney Metro environment and sustainability policy
Suitable placement locations have been identified
The material is suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and will not cause pollution under the POEO Act
The spoil meets engineering requirements for placement locations
Where spoil or demolition materials require treatment or processing onsite to treat contaminants or to amend engineering properties the need for an EPL must be assessed and resulting conditions met
If transport to another project area is required and such transport requires material to be taken outside the site boundary temporarily this will need to be appropriately address in the projectrsquos environmental approvals (eg EIS or REF)
Appropriate risk-based assessment confirms the material is suitable for proposed final land use from a contamination perspective
Appropriate geotechnical assessment confirms the material is suitable for proposed final land use
EPL if required for onsite processing
Complete material tracking record including documentation of final placement location
Environmental controls to prevent cross-contamination of material prior to placement and pollution during placement
Training of relevant personnel in spoil reuse framework and underlying management plans
Audits of sampling data tracking and placement information and reuse locationssites
Long-term management plan and monitoring andor Environmental Protection Licence under the POEO Act (if required)
Reuse of the material off site
Spoil becomes waste under POEO Act once removed from site
Material meets VENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Assessment confirms material is VENM Sampling may be required depending on nature of material and source
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Material meets ENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Sampling conducted in accordance with ENM RRO prior to transport off site and results meet criteria
Statement of RRO compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
RRO records maintained for six years including details of sampling plan sampling results quantities supplied and receival sites
Material does not meet VENM or ENM definitions but has potential for reuse under a specific RRORRE An example is tunnel spoil containing additives
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Consult with the EPA prepare and submit application for specific RRORRE Characterisation data will be required for the application
Once specific RRORRE is granted obtain sampling data (and meet any other specific obligations) in accordance with conditions and confirm results meet criteria prior to transport off site
Statement of compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
As for reuse on site plus
Statement of compliance provided to each receival site
RRO records maintained for six years
Recycling off site
Material (spoil and demolition materials) becomes waste under POEO Act once removed from site
Material meets the EPL andor planning approval requirements for the receival facility and has value for recycling
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Assessmentsampling confirms the material meets the receival facility EPL conditions (typically GSW)
Appropriate EPL held by receival facility
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Disposal off site
Material does not fit one of the above categories andor suitable reuse or recycling locations could not be identified
Least preferred option
Waste is classified as GSW RSW or Special Waste
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by receival facilities
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Waste is classified as HW
Suitable treatment facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by treatment facilities
Treatment facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking treatment and disposal documentation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 13 of 14
SM-20-00040677 Waste Classification Procedure V30
Unexpected find process flow
Flo
w
Process Additional information
Unexpected potential
contamination find1 Immediate ly stop works
2 Notify the Site supervisor 3 Secure the affected area
Is an emergency
response required for any
health or environment
concerns
4b Notify Principal s Rep and
Environmenta l Rep
4a Trigger pro ject incident response and
reporting mechanism andor call 000
5b Inform the
Principal s Rep
Does the
contamination
present and ongoing risk to
environment or human
health dur ing
construction or
operation
Will the
agreed scope result in the
complete removal of the
contamination
Does the
disposal of the unexpected
find result in addi tional costs
to the Principa l
5a Materials to be classified in
accordance with the NSW EPA Waste
Classification Guidel ines (2014) (see
Figure 1 Spoil classification flow)
6a Inform the
Principal s Rep
6b Dispose of the material in
accordance with all relevant legislation
the project Spoil Classification amp
Management Framework and any
relevant directions from Sydney Metro
6c Develop
appropriate
methodology
plans to
manage the
contamination
and implement
Indicators of potentia l
contamination include
Fibre cement or other asbestos
containing materials
Discolouration of the so il
including staining andor
discolouration
Odours from soil or
groundwaterseepage
Bur ied drums and storage tanks
Oily sheen on water
Note this does not include on-
site contamination
Securing of the area should restrict
access to the affected area This
should include as a min imum
environmenta l controls around the
affected area to contain
contaminated material including
diversion of water to minimise
potential spread via surface water
runoff
Where contaminants are likely to
result in odours vapours or
airborne asbestos fibres immediate
action should be taken to prevent
their release (eg cover re-bury or
wet-down
Recommence works in alternate
area where practicable and safe
Assessment to be conducted by
suitably qualified and experienced
person
Methodology controls and p lans
are to be prepared by a sui tab ly
qualified and experienced person
and approved by Sydney Metro
prior to being actioned
Works may continue in the affected
area when it is safe and where
works will not exacerbate
contamination or hinder future
remediation works
Note Remediation of contaminated
materials may include (but not be
limited to) capping of
contaminating treatment andor off-
site disposal All associated
activities with the remediation of
contaminated materials such as
excavation handling stockpiling
and transport are to be addressed
an prepared methodology and
controls
Yes
No
Yes or unsure
No
No or unsure
Yes
Yes
No
Figure 2 Unexpected find process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 14 of 14
SM-20-00040677 Waste Classification Procedure V30
17 Accountabilities
The Director Program Sustainability Environment amp Planning is accountable for this document including approving the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document
2 Related documents and references
3 Superseded documents
4 Document history
Related documents and references
Entries should be formatted with IMSiCentral number followed by correct title and hyperlinked eg
SM-17-00000203 Sydney Metro glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
02 Pending New IMS document
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise pollution of surface water through appropriate erosion and sediment control Minimise leaks and spills from construction activities Maintain existing water quality of surrounding surface watercourses Source construction water from non-potable sources where feasible and reasonable
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp Targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Erosion and sediment measures would be implemented in accordance with the principles and
requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any significant water aspects and Site specific controls to minimise potential impacts
Emergency Management Team members will be provided training to respond to a discharge of contaminated water or hazardous substances into the environment
Project Manager
Notification The Site will not modify or remove any water utility assets without their approval Notification
of approval will be received by Sydney Water with a copy of authorisation Notification to the asset owner will be given as per their conditions of compliance
Project Engineer
ESCP
ESCPrsquos will be developed by construction staff with demonstrated skills and experience in preparing the ESCP in accordance with the Blue Book Guidelines ESCPrsquos plans will include but not be limited to
Title date and revision number Contours and clean and dirty water drainage paths Site layout including the location of access roads ancillary infrastructure Sediment basins and designated pump out locations Limit of disturbance Location and type of control measures Timing and order of control installation in sequence with work activities Specific construction details
Environmental Site Representative
Erosion and sediment control
The following key principals will apply to all areas and stages of construction on the Project
Minimise extent and duration of disturbance Control stormwater flows onto through and from the site
Project Engineer Supervisor
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Erosion control strategies to prevent on-site damage Sediment control strategies to prevent off-site damage Progressive stabilisation following completion of work areas Inspection Maintenance and Improvement of control measures throughout the site construction
until the site is successfully stabilised
Dewatering
Sediment laden water accumulated in trenches or excavations must not be discharged directly or indirectly to any stormwater natural watercourse or offsite
A suitable location to discharge will be identified considering site slope proximity to drainage lines soil permeability and ground cover ie well established existing vegetation
The water must be tested prior to any discharge by the Environmental Site Representative and may require treatment prior to discharge
Project Engineer Environmental Site Representative
Groundwater
Groundwater is unlikely to be intercepted during any excavation within the road footprint Deeper excavations for stormwater trenching may intercept groundwater however a method of pipe installation during low tide will removed the need for dewatering
If groundwater dewatering is required then a dewatering management plan should be developed
PlantVehicle Maintenance
The maintenance and cleaning of any vehicles plant or equipment must not be carried out in areas from which contaminants can be released into stormwater or natural watercourses
All
Acid Sulfate Soils
Prior to excavation for the Stormwater trench which will occur approximately 25m bgs testing would be carried out to determine the presence of actual andor potential acid sulfate soils
Testing for the presence of ASS shall be undertaken at proposed excavation locations and shall apply the following methodology Dig holes to the proposed depth of excavation conduct ASS pH field tests on material from the hole at 05m depth intervals and then conduct a SPOCAS plus or chromium suites on the most acidic ASS pH field test sample from the hole The testing and sampling to be undertaken in accordance with ASSMAC Laboratory method Guideline Aug 1998
If actual andor potential acid sulfate soils are present within the proposed area of excavation then an Acid Sulfate Management Plan will be developed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Project Engineer Environmental Site Representative
Water Discharge requirements
An Environmental Protection Licence (EPL) is not required for the project however Georgiou will test any water to be discharged offsite in accordance with the water quality parameters specified in the Blue Book (Landcom 2004) and ANZECCARMCANZ (2000) guidelines prior to discharge to ensure an incident of pollution to surrounding environment does not occur from the Project
Environmental Site Representative
Monitoring of Discharges
Waters released from site must be sampled prior to release The samples taken must be representative of the water being discharged
Project Engineer HSE Advisor
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Environmental Inspections amp Monitoring
The results of monitoring shall be recorded Environmental Site Representative
Daily (Visual) and weekly (documented)
Daily visual observation for evidence of water quality impacts including turbidity or hydrocarbon spills
Weekly inspections using Georgiou Beakon inspection form
Supervisor HSE Advisor
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report Dewatering records including all water quality test results
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Objectives and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise leaks and spills from construction activities All chemicals correctly stored and bunded in accordance with legislative requirements Any spills are controlled contained cleaned up and reported
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General All fuels chemicals and hazardous liquids would be stored in accordance with Australian
standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required to
manage hydrocarbon and chemical storage and use including
- Use and understanding of safety data sheets (SDS) - Use of personal protective equipment (PPE)
Emergency Management Team members will be provided training to respond to a hazardous substance spill
Project Manager
Register
All dangerous goods or hazardous substances must be approved by HSE Advisor prior to use on the site
ChemAlert will be used to register all site dangerous goods and hazardous substances manage electronic SDS and conduct and record product risk assessments
Consideration will be given to substitute products assessed as a high risk with a product of lesser risk
Project ManagerSupervisor
Transportation Containers holding hazardous substances or dangerous goods will be stored upright and secured
during transport Containers are not to be dropped tip or rolled sides The transportation of dangerous goods will be by licenced carriers
Project Engineer
Handling amp Use
Handling of products will be subject to the following requirements Hazardous substances and dangerous goods will be clearly labelled Current SDS (no older than 5 years) will be readily available when handling Controls stipulated in the SDS to be applied when handling and using Used oily rags oil filters and other left over hydrocarbon and chemical products hall be stored in
a designated area and removed by licensed carriers to either recycle or otherwise dispose of
All
Refuelling Refuelling of plant and vehicles must be monitored continually and conducted in designated areas
away from sensitive receptors
All in field refuelling must have a spill kits available to contain and clean up any spills
All
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Spill kits shall be stored in designated amp labelled containers and include a stock control register
All refuelling areas must be signed to prevent smoking or naked flame
Vehicles must be switched off when refuelling and the use of mobile phones prohibited
Fixed refuelling areas must have a plastic lined refuelling area
Fuel storage containers must be of a double bund construction
Site layout
Georgiou will develop a site plan (ie a diagram) showing the location of storage areas spill kit locations muster points firefighting equipment and 1st aid equipment including eye washflush locations
This site plan must be current and displayed at the work site at all times throughout construction
In the event of an emergency that involves the need for emergency services this site plan along with a product manifest must be provided to the emergency services
Project Manager
Storage of Hazardous Materials
Any Dangerous Goods andor Hazardous Substance must be stored in designated areas compliant
with statutory and industry codes of practice
Quantities of hazardous materials should be kept to a minimum commensurate with their usage
and shelf life
Safety Data Sheets of stored hazardous materials will be readily accessible at the place of
storagesite office
Permanent and temporary containers that hold hazardous materials must be labelled with the
appropriate signage
The volume and types of hazardous materials stored must be known current and documented and
must not exceed the design capacity of the storage area
Storage and containment areas (including secondary containment) must be inspected for signs of
loss or damage and any deficiencies must be addressed These areas must be inspected at least
monthly as part of the workplace inspection
Hazardous materials no longer in use must be identified and assessed to determine if they should
be removed from site
Hazardous materials storage areas must be kept clear of combustible material vegetation and refuse by a minimum of three metres
All
SpillEmergency Response
In the event of a spill the following generic procedure must be followed
1 Do not put yourself at risk 2 Notify personnel in the immediate area and remove yourself and others from danger 3 Report ALL SPILLS immediately to the Supervisor and Environmental Site Representative
(report location type and extent of incident)
All
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Once safety has been considered spills should be contained and cleaned up with material from the spill kit All contaminated soil caused by leaks or spills to be disposed of in accordance with legal requirements Any uncontrolled release of hazardous substances which cause actual or threatens potential serious or material environmental harm will be reported to the EPA pollution hotline
Workplace Inspections
Hazardous Materials storage and use will be inspected monthly as part of workplace inspections amp within the DHI Environmental Inspections checklist
Supervisors
Concrete
Designated concrete washout should be constructed and designated to be impermeable and securely fastened
Placed away from waterways drainage lines and stormwater inlets Sufficient storage to handle concrete works occurring onsite When the concrete is dried it will be disposed of with general waste mixed into fill layers (if
approved by client) or recycled At no point will any Concrete truck or kibble be permitted to wash out at any point other than the
designated area with all the associated controls in place (unless approved by the environmental site representative)
Excess concrete should be scraped off equipment prior to washing (allow excess to set and recycle offsite or reuse in fill if itrsquos not contaminated with black plastic)
Set concrete should be removed from the washout to restore storage capacity and prevent overflows
Use of a high pressure low volume water spray nozzle may reduce water use All wastewater must be disposed of in accordance with the project CEMP dewatering conditions
Maintenance of the washout Monitoring and maintenance of concrete washouts is essential to ensure the washout is functional no evidence of damage or wear and tear is evident and that adequate storage capacity remains In addition to daily inspections washout areas should be inspected
During dry weather and
Prior to during and after rainfall and storm events
SupervisorEnvironmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for evidence of spills or poor storage practice with potential to lead environmental incident
Hazardous goods storage area inspection for adequacy of bunding and product loss Weekly inspections using Georgiou Beakon inspection form
All staff
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Objectives
and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on flora and fauna Retain and enhance existing flora and fauna habitat wherever possible Appropriately manage the spread of weeds and plant pathogens
Project Manager
Performance
Criteria
100 compliance with Client amp legal requirements
100 achievement with Site Objectives amp Targets
100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation
Measures
General Vehicles equipment plant materials and personnel are to remain within the designated construction
area at all times and not breach established environmentally sensitive exclusion zones All
Training and
Competency
As part of the Site Induction workers will be informed of the Site specific controls required to minimise potential impacts and protect flora and fauna including - the requirement to work within the designated disturbance zones - requirement to recognise protected flora or fauna species identified to be found on the site - tree protection zones - Specific licence conditions applicable to the Site
Project Manager
Fauna habitat
Prior to clearing pre-clearance surveys are to occur to identify individual trees to be retained and any hollow bearing trees and logs
Where possible clearance should avoid hollow bearing trees Where unavoidable hollow bearing trees should be flagged and left standing at least 24 hours
after clearing all other vegetation Excavator operator to lsquotaprsquo tree prior to felling hollow bearing trees to allow for fauna to escape Ecologist (or similar) to be present onside during clearing of hollow bearing trees to handle any
displaced fauna In the event of injury to fauna WIRES or similar to be contacted and suitable arrangements made
NOTE Handling of any active animal breeding place is only permitted to be conducted by an authorised fauna handler operating under a current permit granted in accordance with legislative requirements
All
Authorisation amp Compliance
Georgiou will not clear vegetation without written permission from the Client local Shire or relevant Regulatory Authority All clearing works under a permit approval or licence will be compliant with the conditions of permit approvals or licence and within the predetermined area
In the event of any unauthorised clearing works will cease immediately and the Project Manager client will be notified Unauthorised clearing of areas will be investigated immediately
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Marking
The Project Engineer will ensure the area to be cleared is clearly marked (eg pegging) and areas of vegetation or trees nominated to be excluded from the clearing works are to be visually identifiable to all personnel involved in the works
The method of marking is to be communicated to all persons involved in the clearing process All control measures are to be communicated to personnel involved in the tasks
All
Flora
Flora that is to be protected will be clearly marked using a method that will not harm or damage A Tree protection Zone (TPZ) is to be established for any trees on a construction site that are to
be protected This is to be fenced off or barricaded to ensure construction activities do not cause damage to the root plate of the tree
Native vegetation should be protected where reasonably possible Large areas that are to be protected from Site works will be demarcated to prevent intrusion and disturbance This requirement is to be communicated to personnel involved within the site area
When the pruning of trees is to be undertaken that are to be protected it will be done by suitably qualified personnel only Where branches are trimmed an assessment of the trees ability to survive should be conducted by a suitably qualified person and adequate area around the tree in accordance with AS49702009 Protection of trees of development sites
Trees should be felled into the construction site or in slots between stands of trees where practical to minimise damage to other trees during the clearing process Machinery contact with standing trees on vegetated margins is to be avoided
The clearing of vegetation outside the construction area will not be permitted except in the event of an emergency or as directed by emergency services
All
Fauna
If fauna are confirmed to be present onsite during clearing clearing works should proceed with care to enable the fauna to relocate freely Clearing is to be conducted in a sequential manner and in a way that encourages escaping wildlife away from the activity into adjacent natural areas and not across roads or into other areas of threat (eg trench)
All
Trenches
All open excavations and trenches will be visually inspected on a daily basis for trapped fauna Surveillance must occur along the entire length of the trench or excavated area and not merely those areas described as fauna habitats or sensitive areas Open trenches are to be checked for fauna immediately prior to backfill and any trapped animals removed by authorised fauna handlers
All
Fauna Handling
Fauna will not be intentionally harmed or maimed under State wildlife protection legislation This includes aquatic and terrestrial fauna (land and air animals)
Workers are not authorised handleto be in possession of native fauna The trapping and handling of fauna in particular dangerous species will only be undertaken by a competent qualified fauna handler
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Fire Management
Georgiou will not set fire to bush or use spark generating machinery (eg graders) during a prohibited or restricted burning time
If safe to do so Georgiou will extinguish any bush fire within the site boundary and request help from authorities if necessary Fire breaks will be established as requested by authorities
Project Manager
Environmental
Inspections amp
Monitoring
Daily (Visual) and weekly
(documented)
General observation for clearing boundary demarcation Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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Appendix 5 - Cultural Heritage Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on items or places of heritage value Avoid accidental impacts on heritage items Maximise workerrsquos awareness of indigenous and non-indigenous heritage
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Maintain the integrity of the cultural (European amp Indigenous) aspects of the Site
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any identified cultural or heritage aspects on the Site and any specific controls to be adhered including - Management practices when working near protected areas - Respecting Heritage Sites - Reporting requirements
Georgiou personnel will participate in the Companyrsquos cross cultural awareness training for employees
Project Manager
Heritage Sites There are s170 heritage listed Glebe Island silos (Port Authority of NSW s170 4560056) that are approximately 5m from the edge of works
Project Engineer
Method statement
In accordance with the REF an Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
Unexpected heritage finds
In the event that an artefact or remains are found the Sydney Metro Unexpected Heritage Finds procedure (Appendix 5A) will be followed this includes - The works in that area will cease immediately - The Project Manager and Sydney Metro must be notified - The site must be made secure a buffer zone of ten meters is recommended - Sydney Metro to provide management recommendations
Georgiou will notify all site personnel of the object andor area and proposed treatment of that object andor area as soon as possible but prior to commencing work on the next working day
Works will not continue until written approval has been received from the client
All
discovery of human remains
In the event that human remains are found the Sydney Metro Exhumation Management procedure will be followed (Appendix 5B)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Environmental Inspections amp Monitoring
Building condition inspections Building condition inspections will be undertaken in accordance with REF condition NV3 Sydney Metro
Vibration Monitoring
Continuous vibration monitoring will occur during any vibratory works in close proximity to the Glebe Island silos in accordance with the Sydney Metro Construction Noise and Vibration Standard
Environmental Site Representative
Daily (Visual) and weekly (documented)
General observation for that protection measures and methods are being applied Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure
Sydney Metro Unexpected
Heritage Finds Procedure [SM-18-00105232]
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final
Version 33
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2018
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
copy Sydney Metro 2018 Page 2 of 34
Document history
Version Date of approval Notes
11 Incorporates ER comments 210617
12 Amends p13 step 8 reference to s146 added
13 Incorporates Planning Mods 1-4 including amended CoA E20
14 Incorporates ER comments 210318
20 Removes SSI 15-7400 COA reference
30 Revises definition
31 Revises flow chart
32 Revises roles and responsibilities
33 General edits and corrections
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
copy Sydney Metro 2018 Page 3 of 34
Table of contents
1 Purpose 3
11 Legislation that does not apply 3
2 Scope 4
3 Definitions 4
4 Types of unexpected heritage items and corresponding statutory protections 5
41 Aboriginal objects 5
42 Historic heritage items 6
43 Human skeletal remains 7
5 Legislative Requirements 7
6 Unexpected heritage finds protocol 9
7 Responsibilities 15
8 Seeking Advice 16
9 Related documents and references 16
10 List of appendices 16
11 Document history 17
Appendix 1 Examples of finds encountered during construction works 18
Appendix 2 - Unexpected heritage item recording form 24
Appendix 3 - Photographing unexpected heritage items 26
Appendix 4 - Uncovering bones 29
Appendix 5 - Archaeologicalheritage advice checklist 33
Appendix 6 - Template notification letter 34
Tables
Table 1 Legislation and guidelines for management of unexpected heritage finds 8 Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item 10 Table 3 Roles and Responsibilities 15
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
copy Sydney Metro 2018 Page 4 of 34
1 Purpose
This procedure is applicable to the Sydney Metro program of works including major projects delivered under Critical State Significant Infrastructure (CSSI) Planning Approvals early CSSI minor and enabling works and works that are subject to the NSW Heritage Act (1977) including s57139 and s60140 exemptions and permit approvals and the National Parks and Wildlife (NPW) Act 1974
This procedure has been prepared for Sydney Metro programs to provide a method for managing unexpected heritage items (both Aboriginal and non-Aboriginal) that are discovered during preconstruction (pre-Construction Heritage Management Plan approval) construction phases (post Construction Heritage Management Plan approval) and for works subject to the NSW Heritage Act (1977)
In NSW there are strict laws to protect and manage heritage objects and relics As a result appropriate heritage management measures need to be implemented to minimise impacts on heritage values ensure compliance with relevant heritage notification and other obligations and to minimise the risk of penalties to individuals Sydney Metro and its contractors This procedure includes Sydney Metrorsquos heritage notification obligations under the Heritage Act NPW Act and the Coronerrsquos Act 2009 and the requirements of the conditions of approval(CoA) issued by NSW Department of Planning Industry and Environment Note that a Contractor must not amend the Sydney Metro Unexpected Finds Procedure or use a different procedure without the prior approval of Sydney Metro
This procedure must be read in conjunction with the relevant CCSI conditions of approval (if applicable) the contract documents and other plans and procedures including the Sydney Metro Exhumation Procedure in addition to any other relevant documents as developed by the contractor during the delivery of the Sydney Metro works
2 Definitions and Abbreviations
An unexpected heritage find is
any unanticipated discovery of an actual or potential heritage item which Sydney Metro does not have approval to disturb andor does not have an existing management process in place
a find that has not been previously identified or assessed
a find that is not referenced in an Archaeological Research Design (ARD) Archaeological Method Statement (AMS) or other project document relating to heritage and archaeology
not covered by an existing approval under the Heritage Act 1977 (Heritage Act) or National Parks and Wildlife Act 1974 (NPW Act)
Note that locally significant areas of historical archaeological potential identified in an Archaeological Method Statement but not identified in an Archaeological Research Design would be managed as an ldquoexpectedrdquo find
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
copy Sydney Metro 2018 Page 5 of 34
All terminology in this procedure is taken to mean the generally accepted or dictionary definition with the exception of the following terms which have a specifically defined meaning
Definitions
AHIP Aboriginal Heritage Impact Permit
Aboriginal object An Aboriginal object is any deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remains An Aboriginal object may include a shell midden stone tools bones rock art Aboriginal-built fences and stockyards scarred trees and the remains of fringe camps
ARD Archaeological Research Design
AMS Archaeological Method Statement
CEMP Construction Environmental Management Plan
CoA Conditions of Approval
CSSD Critical State Significant Development
CSSI Critical State Significant Infrastructure
EPampA Act NSW Environmental Planning and Assessment Act 1979
Disturbance Disturbance is considered to be any physical interference to an item that results in it
being destroyed defaced damaged harmed impacted or altered in any way (this
includes archaeological investigation activities)
Excavation Director
A person that has been determined by the NSW Heritage Division to meet the Heritage Council of NSWrsquos Criteria for Assessment of Excavation Directors (4 September 2019 and as updated) and can therefore competently archaeologically investigate a site of either local andor state significance
Heritage Act NSW Heritage Act 1977
NPW Act NSW National Parks and Wildlife Act 1974
Heritage NSW Formerly Office of Environment and Heritage (OEH) Now Heritage NSW as part of PNSW Premier and Cabinet
SM Sydney Metro
Relic (non- Aboriginal heritage)
A relic means any deposit artefact object or material evidence that
a) relates to the settlement of the area that comprises NSW not being Aboriginal settlement and
b) is of State or local significance
A relic may include items such as bottles utensils remnants of clothing crockery
personal effects tools machinery and domestic or industrial refuse
TfNSW Transport for New South Wales
Work (non- Aboriginal heritage)
Archaeological features such as historic utilities or buried infrastructure that provide evidence of prior occupations such as former rail or tram tracks timber sleepers kerbing historic road pavement fences culverts historic pavement buried retaining walls cisterns conduits sheds or building foundations but are also subject to assessment by the Excavation Director to determine its classification
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
copy Sydney Metro 2018 Page 6 of 34
21 Legislation that does not apply
The following authorisations are not required for Sydney Metro approved Critical State Significant Infrastructure (and accordingly the provisions of any Act that prohibits an activity without such an authority do not apply)
Division 8 of Part 6 of the Heritage Act 1977 does not apply to prevent or interfere with the carrying out of approved State significant infrastructure
An approval under Part 4 or an excavation permit under section 139 of the Heritage Act 1977 and
An Aboriginal heritage impact permit under section 90 of the National Parks and Wildlife Act 1974
This document provides relevant background information in Section 4 followed by the technical procedure in Sections 6 and 7 Associated guidance referred to in the procedure can be found in Appendices 1-6
3 Scope
Even with early investigations unexpected finds may still occur during works on a Sydney Metro site When this happens this procedure must be followed This procedure provides direction on when to stop work where to seek technical advice how to notify the regulator if required and when works can recommence This procedure applies to the discovery of any unexpected heritage item relic or object where the find is not anticipated in an approved ARD or AMS or other project specific document related to archaeology
This procedure must be followed by all Sydney Metro staff contractors subcontractors or any person undertaking works for Sydney Metro It includes references to some of the relevant legislative and regulatory requirements but is not intended to replace them This procedure does not apply to
the discovery and disturbance of heritage items as a result of investigations being undertaken in accordance with the Code of Practice for Archaeological Investigations of Aboriginal Objects in NSW4376 20101 an Aboriginal Heritage Impact Permit (AHIP) issued under the NPW Act or a permit approval issued under the Heritage Act
the discovery and disturbance of heritage items as a result of construction related activities where the disturbance is permissible in accordance with an AHIP or an approval issued under the Heritage Act or CSSI CSSD planning approval or
locally significant non-Aboriginal archaeology identified in an AMS and not in an ARD
1 An act carried out in accordance with the Code of Practice for Archaeological Investigation of Aboriginal Objects
in NSW as published by the Department in the Gazette on 24 September 2010 is excluded from the definition of harm an object or place in section 5 (1) of the NPW Act
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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4 Types of unexpected heritage finds and corresponding statutory protections
Project field and environmental personnel (including construction contractors) are critical to the early identification and protection of unexpected finds
Appendix 1 illustrates the wide range of heritage items uncovered to date during Sydney Metro projects and gives an indicative guide to what unexpected finds may look like
These discoveries are categorised as either
(a) Aboriginal objects
(b) Historic (non-Aboriginal) heritage items or
(c) Human skeletal remains
The relevant legislation that applies to each of these categories is described below
41 Aboriginal objects
The NPW Act protects Aboriginal objects which are defined as
ldquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrdquo2
Examples of Aboriginal objects include stone tool artefacts shell middens axe grinding grooves pigment or engraved rock art burials and scarred trees
42 Historic heritage items
Historic (non-Aboriginal) heritage items may include
Archaeological lsquorelicsrsquo or
Other historic items (ie works structures buildings or movable objects)
2 Section 5(1) NPW Act 3 This is required under section 89(A) of the NPW Act and applies to all Sydney Metro projects
IMPORTANT
All Aboriginal objects regardless of significance are protected under law
If any impact is expected to an Aboriginal object an AHIP is usually required from Heritage NSW When a person becomes aware of an Aboriginal object they must notify the Director-
General of Heritage NSW about its location3 Assistance on how to do this is provided in Section 7 (Step 5)
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421 Archaeological relics
The Heritage Act protects relics which are defined as ldquoany deposit artefact object or material evidence that relates to the settlement of the area that comprises NSW not being Aboriginal settlement and is of State or local heritage significancerdquo4
Relics are archaeological items of local or state significance which may relate to past domestic industrial or agricultural activities in NSW and can include bottles remnants of clothing pottery building materials and general refuse
422 Other historic items
Some historic heritage items are not considered to be lsquorelicsrsquo but are instead referred to as works buildings structures or movable objects Examples of these items that may be encountered include culverts historic pavements retaining walls tramlines rail tracks turn tables timber sleepers cisterns fences sheds buildings and conduits Although an approval under the Heritage Act may not be required to disturb these items their discovery must be managed in accordance with this procedure
Usually archaeological relics are uncovered via a process of excavation or soil removal When an unexpected find is uncovered an archaeological excavation permit under section 140 or section 60 of the Heritage Act may be required to further investigate or remove it if investigation is not covered by an existing approval In contrast lsquoother historic itemsrsquo either exist above the ground surface (for example a shed) or they are designed to operate and exist beneath the ground surface (for example a culvert)They may also need a permit to alter disturb or remove them if there is not an approval already in place
4 Section 4(1) Heritage Act
5 This is required under section 146 of the Heritage Act and applies to all Sydney Metro projects
IMPORTANT
All relics are subject to statutory controls and protections
If a relic is likely to be disturbed a heritage approval is usually required from the NSW Heritage Council When a person discovers a relic they must notify the NSW Heritage
Council of its location5
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43 Human skeletal remains
The Sydney Metro Exhumation Procedure provides a more detailed explanation of the approval processes related to human remains
Human skeletal remains can be identified as either an Aboriginal object or non-Aboriginal relic depending on the ancestry of the individual (Aboriginal or non-Aboriginal) and the burial context (archaeological or non-archaeological) Remains are considered to be archaeological when the time elapsed since death is suspected of being 100 years or more Depending on ancestry and context different legislation applies
As a simple example a pre-European settlement archaeological Aboriginal burial would be protected under the NPW Act while a historic (non-Aboriginal) archaeological burial within a cemetery would be protected under the Heritage Act For a non-Aboriginal archaeological burial the relevant heritage approval and notification requirement described in Appendix 4 would apply In addition to the NPW Act finding Aboriginal human remains also triggers notification requirements to the Commonwealth Minister for the Environment under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
Where it is suspected that less than 100 years has elapsed since death the human skeletal remains come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such cases are lsquoreportable deathsrsquo and under legal notification obligations set out in section 35(2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (whether Aboriginal or non-Aboriginal remains) Public health controls may also apply6
Guidance on what to do when suspected human remains are found is provided in Appendix 5
IMPORTANT
All human skeletal remains are subject to statutory controls and protections
All bones must be treated as potential human skeletal remains and work around them must stop while they are appropriately protected and investigated the relevant authorities advised and approvals received This includes skeletal material found during any phase of work including
geotechnical works early works construction works and any other site works
6 Under section 19 of the Coroners Act 2009 the coroner has no jurisdiction to conduct an inquest into reportable
death unless it appears to the coroner that (or that there is reasonable cause to suspect that) the death or suspected death occurred within the last 100 years
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5 Legislative Requirements Table 1 identifies some of the relevant legislationregulations for the protection of heritage and the management of unexpected heritage finds in NSW It should be noted that significant penalties exist for breaches of the legislation which result in unauthorised impacts to heritage items
To avoid breaches of legislation it is important that Sydney Metro and its contractors are aware of their statutory obligations under relevant legislation and that appropriate control measures are in place to ensure that unexpected finds are appropriately managed during all project phases Contractors will need to ensure that they undertake their own due diligence to identify any other legislative requirements that may apply for a given project
Table 1 Legislation and guidelines for management of unexpected heritage finds
Relevant Requirement Objectives and offences
Environmental Planning and Assessment Act 1979 (EPampA Act)
Part 5 Division 52 Subdivision 2 Section 519
Requires heritage to be considered within the environmental impact assessment of projects
Heritage Act 1977 (Heritage Act)
The Heritage Act provides for the care protection and management of heritage items in NSW Under section 139 it is an offence to disturb or excavate any land knowing or having reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered exposed moved damaged or destroyed unless the disturbance or excavation is carried out in accordance with an excavation permit issued by the Heritage NSW under the Act a relic is defined as lsquoany deposit artefact object or material evidence that (a) relates to the settlement of the area that comprises New South Wales not being Aboriginal settlement and (b) is of State or local heritage significancersquo
A person must notify the Heritage NSW if a person is aware or believes that they have discovered or located a relic (section 146) Penalties for offences under the Heritage Act can include six months imprisonment andor a fine of up to $11million
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Relevant Requirement Objectives and offences
National Parks and Wildlife Act 1974 (NPW Act)
The NPW Act provides the basis for the care protection and management of Aboriginal objects and places in NSW
An Aboriginal object is defined as lsquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrsquo
An lsquoAboriginal placersquo is an area declared by the Minister administering the Act to be of special significance with respect to Aboriginal culture An Aboriginal place does not have to contain physical evidence of occupation (such as Aboriginal objects)
Under section 87 of the Act it is an offence to harm or desecrate an Aboriginal object or place There are strict liability offences An offence cannot be upheld where the harm or desecration was authorised by an AHIP and the permitrsquos conditions were not contravened Defences and exemptions to the offence of harming an Aboriginal object or Aboriginal place are provided in section 87 87A and 87B of the Act A person must notify Heritage NSW if a person is aware of the location of an Aboriginal object
Penalties for some of the offences can include two years imprisonment andor up to $550000 (for individuals) and a maximum penalty of $11 million (for corporations)
6 Unexpected heritage finds protocol
61 What is an unexpected heritage find
An lsquounexpected heritage findrsquo can be defined as any unanticipated archaeological discovery that has not been identified during a previous assessment or is not covered by an existing permit under the Heritage Act The find may have potential cultural heritage value which may require a heritage permit or notification if any interference of the heritage item is proposed or anticipated
The range of potential unexpected finds can include but is not limited to
remains of rail infrastructure including buildings footings stations signal boxes rail lines bridges and culverts
remains of other infrastructure including sandstone or brick buildings wells cisterns drainage services conduits old kerbing and pavement former road surfaces timber and stone culverts bridge footings and retaining walls
artefact scatters including clustering of broken and complete bottles glass ceramics animal bones and clay pipes and
archaeological human skeletal remains
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62 Managing unexpected finds
In the event that an unexpected find is encountered on a Sydney Metro site the steps detailed in Table 2 must be followed There are seven steps in the procedure
Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item
Step Task Responsibility Guidance and tools
1 Stop work and protect the item
11 Stop all work including geotechnical investigations in the immediate area of the item and notify the Project Manager
Contractor Supervisor
Appendix 1
Identifying Unexpected Heritage items
12 Establish a lsquono-go zonersquo around the item Use high visibility fencing where practical No work is to be undertaken within this zone until further investigations are completed and if required appropriate approvals are obtained
Inform all site personnel about the no-go zone
Project Manager Contractor Supervisor
2 Engage an Archaeologist
21 If you have Excavation Director or an archaeologist andor Aboriginal heritage consultant has been previously appointed for the project contact them to discuss the location and nature of the item and arrange a site inspection The project Construction Environmental Management Plan (CEMP) may contain contact details of the archaeologistAboriginal heritage consultant
Provide as much information as possible including photos and completed recording form
Inform the Sydney Metro Environmental Manager and keep them involved in the process The Environmental Manager will inform the Sydney Metro Senior Heritage Advisor
Contractors Project Manager
Appendix 2
Unexpected Heritage Item Recording Form
22 Where there is no project archaeologist engaged for the works engage a suitably qualified consultant to assess the find
If the find is a non-Aboriginal item engage a suitably qualified and experienced historical archaeological consultant
If the find is likely to be an Aboriginal object engage an Aboriginal heritage consultant
Contractorrsquos Project Manager
IMPORTANT
Sydney Metro may have approval to impact certain heritage items during construction If you think that you may have discovered a heritage item and you are unsure whether an
approval is in place or not STOP works and follow this procedure
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Step Task Responsibility Guidance and tools
23 ArchaeologistExcavation Director and Sydney Metro Environmental Manager to advise the Project Manager whether Sydney Metro has approval to impact the lsquoitemrsquo
If yes work may recommence in accordance with that approval or permit There is no further requirement to follow this procedure
If no continue to next step
Contractorrsquos Project Manager
3 Arrange site access
31 Arrange site access for the archaeologistAboriginal heritage consultant to inspect the item as soon as practicable In most cases a site inspection is required to conduct a preliminary assessment
Contractorrsquo s Project Manager Excavation Director
32 Subject to the archaeologistAboriginal heritage consultantrsquos assessment work may recommence at a set distance from the item This is to protect any other archaeological material that may exist in the vicinity which may have not yet been uncovered Existing protective fencing established in Step 12 may need to be adjusted to reflect the extent of the newly assessed protective area No works are to take place within this area once established
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
33 Occasionally the archaeologistAboriginal heritage consultant may determine from the photographs provided at Step 21 that no site inspection is required because no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo a lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Archaeologist Aboriginal heritage consultant Excavation Director
Proceed to Step 8
4 Undertake Preliminary assessment and recording of the find
41 Has the lsquofindrsquo been damaged or harmed
If yes record the incident in the Incident
Management System Implement any additional reporting requirements related to the planning approval and CEMP where relevant
Contractors Project Manager Archaeologist and or Excavation Director
42 Can the works avoid further disturbance to the item Project Manager to confirm with Sydney Metro Environment Manager
Complete the remaining tasks
Contractorrsquos Project Manager
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Step Task Responsibility Guidance and tools
43 Inspect document and photograph the item Archaeologist and or Excavation Director
Appendix 2
Unexpected Heritage Item Recording Form
Appendix 3
Photographing Unexpected Heritage items
44 Is the item likely to be bone
If yes follow the steps in Appendix 4 ndash lsquoUncovering bonesrsquo Where it is obvious that the bones are human remains you must notify the local police by telephone immediately They may take command of all or part of the site Also refer to the Sydney Metro Exhumation Procedure
If no proceed to next step
Archaeologist and or Excavation Director
Appendix 4
Uncovering Bones
45 The archaeologistAboriginal heritage consultant may provide advice after the site inspection and preliminary assessment that no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo or a lsquoheritage itemrsquo or an lsquoAboriginal itemrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Metro Project Manager
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
Proceed to Step 7
Refer to Appendix 1
Examples of finds encountered during construction worksrsquo
46 Where required seek additional specialist technical advice (such as a forensic or physical anthropologist to identify skeletal remains) The archaeologistAboriginal heritage consultant can provide contacts for such specialist consultants
Excavation Director Archaeologist
47 Where the item has been identified as a lsquorelicrsquo or lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo the archaeologist should formally record it
Archaeologist Aboriginal heritage consultant
48 NSW Heritage for non-Aboriginal relics and NSW Department of Planning Industry and Environment for Aboriginal objects can be notified informally by telephone at this stage by the Sydney Metro Senior Heritage Advisor Any verbal conversations with regulators must be noted on the project file for future reference
Contractors Project Manager Excavation Director
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Step Task Responsibility Guidance and tools
5 Notify the regulator if required
51 Based on the findings of the archaeological or heritage management plan and corresponding legislative requirements is notification of Heritage NSW and the Secretary required
If no proceed directly to Step 6
If yes proceed to next step
Sydney Metro Environmental Manager Contractorrsquos Excavation Director
52 If notification is required complete the template notification letter including the archaeological heritage management plan and other relevant supporting information and forward to the Sydney Metro Environmental Manager The Environmental Manager will seek the approval of the Sydney Metro Senior Heritage Advisor and the signature of the Principal Manager Sustainability Environment and Planning (Program)
Sydney Metro Environmental Manager Excavation Director
Appendix 6
Template Notification Letter
53 Forward the signed notification letter to Heritage NSW and the Secretary
Informal notification (via a phone call or email) to Heritage NSW prior to sending the letter is appropriate The archaeological or heritage management plan and the completed Unexpected Heritage Item Recording Form (Appendix 2) must be submitted with the notification letter (for both Aboriginal objects and non-Aboriginal relics)
The Department of Planning Industry and Environment may also need to be notified
54 A copy of the final signed notification letter archaeological or heritage management plan and the site recording form is to be kept on file and a copy sent to the Sydney Metro Project Manager
Contractorrsquos Project Manager Excavation Director
6 Implement archaeological or heritage management plan
61 Modify the archaeological or heritage management plan to take into account any additional advice resulting from notification and discussions with regulator
Contractorrsquos Project Manager Excavation Director
62 Implement the archaeological or heritage management plan Where impact is expected this may include a formal assessment of significance and heritage impact assessment preparation of excavation or recording methodologies consultation with Registered Aboriginal Parties obtaining heritage approvals etc if required
Contractorrsquos Project Manager Excavation Director
63 Where heritage approval is required contact the Sydney Metro Environment Manager for further advice and support material Please note there are time constraints associated with heritage approval preparation and processing
Contractorrsquos Project Manager Excavation Director
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64 Assess whether heritage impact is consistent with the project approval or if project approval modification is required from the Department of Planning Industry and Environment
Excavation Director Sydney Metro Environmental Manager
65 Where statutory approvals (or project approval modifications) are required impact upon relics andor Aboriginal objects must not occur until heritage approvals are issued by the appropriate regulator
Contractorrsquos Project Manager Excavation Director
66 Where statutory approval is not required but where recording is recommended by the archaeologistAboriginal heritage consultant sufficient time must be allowed for this to occur
Contractorrsquos Project Manager Excavation Director
67 Ensure short term and permanent storage locations are identified for archaeological material or other heritage material removed from site where required Interested third parties (for example museums local Aboriginal land councils or local councils) should be consulted on this issue Contact the archaeologist or Aboriginal heritage consultant for advice on this matter if required
Contractorrsquos Project Manager Excavation Director
7 Resume work
71 Seek written clearance to resume project work from the project Excavation Director Archaeologist Aboriginal heritage consultant
Clearance would only be given once all archaeological excavation andor heritage recommendations and approvals (where required) are complete Resumption of project work must be in accordance with the all relevant projectheritage approvalsdeterminations
Contractorrsquos Project Manager Excavation Director
72 If required ensure archaeological excavationheritage reporting and other heritage approval conditions are completed in the required timeframes This includes artefact retention repositories conservation andor disposal strategies
Contractorrsquos Project Manager Excavation Director
73 If additional unexpected items are discovered this procedure must begin again from Step 1
All
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7 Responsibilities
Table 3 Roles and Responsibilities
Role Responsibility or role under this guideline
Contractor Supervisor
Stop work immediately when an unexpected heritage find is encountered Cordon off area until Environmental Manager Excavation Director advises that work can recommence
Manage the process of identifying protecting and mitigating impacts on the lsquofindrsquo
Liaise with Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Assist the archaeologistAboriginal heritage consultant with mitigation and regulatory requirements
Complete Incident Report and review CEMP for any changes required Propose amendments to the CEMP if any changes are required
Contractors Project Manager
Ensures all aspects of this procedure are implemented Advise Contractor Supervisor to recommence work if all applicable requirements have been satisfied and the Excavation Director
Project Archaeologist has approved recommend of work
Contractorrsquos or Project Heritage Advisor or Consultant
Provide expert advice to the Sydney Metro Environment Manager on find identification significance mitigation legislative procedures and regulatory requirements
Environmental Representative
Ensure compliance with relevant approvals (new and existing)
Sydney Metro Environment Manager
Notify the Sydney Metro Principal Manager Environmental Management of find and manage Incident Reporting once completed by Environmental Manager
Sydney Metro Senior Heritage Advisor
Provide expert advice to Sydney Metro Environment Manager and project as required
8 Seeking Advice
Advice on this procedure should be sought from the Sydney Metro Environment Manager in the first instance Contractors and delivery partners should ensure their own project environment managers are aware of and understand this procedure
Technical archaeological or heritage advice regarding an unexpected heritage item should be sought from a suitably qualified and experienced archaeologistAboriginal heritage consultant
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9 Related documents and references
Sydney Metro Environmental Incident Classification and Reporting ndash SM-17-00000096
Transport for NSW Guide to Environmental Control Map ndash 3TP-SD-01570
NSW Heritage Office (1998) Skeletal remains guidelines for the management of human skeletal remains
Roads and Maritime Services (2015) Standard Management Procedure Unexpected Heritage Items
Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal remains
Sydney Metro Exhumation Procedure ndash SM ES-PW-31510
10 List of appendices
The following appendices are included to support this procedure
Appendix 1 Examples of finds encountered during construction works
Appendix 2 Unexpected Heritage Item Recording Form
Appendix 3 Photographing Unexpected Heritage Items
Appendix 4 Uncovering Bones
Appendix 5 Archaeological Advice Checklist
Appendix 6 Template Notification Letter
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Appendix 1 Examples of finds encountered during construction works
Photo 1 - Aboriginal artefacts found at the Wickham Transport Interchange 2015
Photo 2 ndash Aboriginal artefacts (shell material) found at the Wickham Transport Interchange 2015
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Sydney Metro ndash Integrated Management System (IMS)
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Photo 3 1840s seawall and 1880s retaining wall uncovered at Balmain East 2016
Photo 4 Sandstone pavers uncovered at Balmain East 2016
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Unclassified
Sydney Metro ndash Integrated Management System (IMS)
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Photo 5 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 6 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 7 - Sandstone flagging and cesspit - Wynyard Walk project 2014
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Sydney Metro ndash Integrated Management System (IMS)
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Photo 8 - Chinese Ming Dynasty pottery and English porcelainpottery dating back to early 19th century - Wynyard Walk project 2014
Photo 9 - Pottery made by convict potter Thomas Ball during the early settlement - Wynyard Walk project 2014
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Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The following images obtained from the Roads and Maritime Servicesrsquo Standard Management Procedure for Unexpected Heritage items 2015 can be used to assist in the preliminary identification of potential unexpected items during construction and maintenance works Photo 10 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones (Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights Newcastle area) (RMS 2015)
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Sydney Metro ndash Integrated Management System (IMS)
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Photo 11 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones
(Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork
recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights
Newcastle area) (RMS 2015)
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Sydney Metro ndash Integrated Management System (IMS)
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Appendix 2 - Unexpected Heritage Find Recording Form
Example of unexpected heritage item recording form
This form is to be completed Excavation Director on the discovery of an archaeological heritage find during construction or maintenance works
Date Recorded by
(include name and position)
Project name
Description of works
being undertaken
Description of exact
location of item
Description of item
found
(What type of item is it likely
to be Tick the relevant
boxes)
A A relic A lsquorelicrsquo is evidence of a past human activity
relating to the settlement of NSW with local
or state heritage significance A relic might
include bottle utensils plates cups
household items tools implements and
similar items
B A lsquoworkrsquo building or
structurersquo A lsquoworkrsquo can generally be defined as a form
infrastructure such as track or rail tracks
timber sleepers a culvert road base a
bridge pier kerbing and similar items
C An Aboriginal object An lsquoAboriginal objectrsquo may include stone
tools stone flakes shell middens rock art
scarred trees and human bones
D Bone Bones can either be human or animal
remains
Remember that you must contact the local
police immediately by telephone if you are
certain that the bone(s) are human
remains
E Other
Provide a short
description of the item
(Eg metal rail tracks
running parallel to the rail
corridor Good condition
Tracks set in concrete
approximately 10 cm below
the current ground surface)
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Sydney Metro ndash Integrated Management System (IMS)
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Sketch
(Provide a sketch of the
itemrsquos general location in
relation to other road
features so its approximate
location can be mapped
without having to re-
excavate it In addition
please include details of the
location and direction of any
photographs of the item
taken)
Action taken (Tick either
A or B)
A Unexpected item
would not be further
impacts on by the
works
Describe how works would avoid impact
on the item (Eg the rail tracks would be left in
situ and recovered with paving)
B Unexpected item
would be further
impacted by the works
Describe how works would impact on the
item (Eg milling is required to be continued to a
depth of 200 mm depth to ensure the pavement
requirements are met Rail tracks would need to
be removed)
Excavation Director Signature
Signature
It is a statutory offence to disturb Aboriginal objects and historic relics (including human
remains) without an approval All works affecting objects and relics must cease until an
approval is sought
Approvals may also be required to impact on certain works
Important
Unclassified
Appendix 3 - Photographing unexpected heritage finds
Photographs of unexpected finds in their current context (in situ) may assist archaeologistsAboriginal heritage consultants to better identify the heritage values of the item Emailing good quality photographs to specialists can allow for better quality and faster heritage advice The key elements that must be captured in photographs of the item include its position the item itself and any distinguishing features All photographs must have a scale (ruler scale bar mobile phone coin etc) and a note describing the direction of the photograph
Context and detailed photographs
It is important to take a general photograph (Figure 1) to convey the location and setting of the item This will add value to the subsequent detailed photographs also required (Figure 2)
Figure 1 Telford road uncovered on the Great Western Highway (Leura) in 2008 (RMS 2015)
Photographing distinguishing features
Where unexpected items have a distinguishing feature close up detailed photographs must be taken of these features where practicable In the case of a building or bridge this may include diagnostic details architectural or technical features See Figures 3 and 4 for examples
Unclassified
Removal of the item from its context (eg excavating from the ground) for
photographic purposes is not permitted
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Photographing bones
The majority of bones found on site will be animal bones often requiring no further assessment (unless they are in archaeological context) However if bones are human the police must be contacted immediately (see Appendix 5 for detailed guidance) Taking quality photographs of the bones can often resolve this issue quickly The project archaeologist can confirm if bones are human or non-human if provided with appropriate photographs
Ensure that photographs of bones are not concealed by foliage (Figure 5) as this makes it difficult to identify Minor hand removal of foliage can be undertaken as long as disturbance of the bone does not occur Excavation of the ground to remove bone(s) should not occur nor should they be pulled out of the ground if partially exposed
Where sediment (adhering to a bone found on the ground surface) conceals portions of a bone (Figure 6) ensure the photograph is taken of the bone (if any) that is not concealed by sediment
Ensure that all close up photographs include the whole bone and then specific details of the bone (especially the ends of long bones the epiphysis which is critical for species identification) Figures 7 and 8 are examples of good photographs of bones that can easily
Unclassified
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be identified from the photograph alone They show sufficient detail of the complete bone and the epiphysis
Unclassified
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Appendix 4 - Uncovering bones
This appendix provides advice regarding
what to do on first discovering bones
the range of human skeletal notification pathways and
additional considerations and requirements when managing the discovery of human remains
1 First uncovering bones
Refer to the Sydney Metro Exhumation Procedure
Stop all work in the vicinity of the find All bones uncovered during project works should be treated with care and urgency as they have the potential to be human remains The bones must be identified as either human or non-human as soon as possible by a qualified forensic or physical anthropologist
On the very rare occasion where it is immediately obvious from the remains that they are human the Project Manager (or a delegate) should inform the police by telephone prior to seeking specialist advice It will be obvious that it is human skeletal remains where there is no doubt as demonstrated by the example in Figure 17 Often skeletal elements in isolation (such as a skull) can also clearly be identified as human Note it may also be obvious that human remains have been uncovered when soft tissue andor clothing are present
7
After Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal
Remains 17
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This preliminary phone call is to let the police know that a specialist skeletal assessment to determine the approximate date of death which will inform legal jurisdiction The police may wish to take control of the site at this stage If not a forensic or physical anthropologist must be requested to make an on-site assessment of the skeletal remains
Where it is not immediately obvious that the bones are human (in the majority of cases illustrated by Figure 2) specialist assessment is required to identify the bones Photographs of the bones can assist this assessment if they are clear and taken in accordance with guidance provided in Appendix 3 Good photographs often result in the bones being identified by a specialist without requiring a site visit noting they are nearly always non-human In these cases non-human skeletal remains must be treated like any other unexpected archaeological find
If the bones are identified as human (either by photographs or an on-site inspection) a technical specialist must determine the likely ancestry (Aboriginal or non-Aboriginal) and burial context (archaeological or forensic) This assessment is required to identify the legal regulator of the human remains so urgent notification (as below) can occur
Preliminary telephone or verbal notification by the archaeologist to the Sydney Metro Senior Heritage Advisor is appropriate This must be followed up later by a formal letter notification to the relevant regulator when a management plan has been developed and agreed to by the relevant parties
2 Range of human skeletal notification pathways
The following is a summary of the different notification pathways required for human skeletal remains depending on the preliminary skeletal assessment of ancestry and burial context
A Human bones are from a recently deceased person (less than 100 years old)
B Human bones are archaeological in nature (more than 100 years old) and are likely to be Aboriginal remains
C Human bones are archaeological in nature (more than 100 years old) and likely to be non-Aboriginal remains
Figure 3 summarises the notification pathways on finding bones
Action
The Heritage NSW must be notified immediately
Action
The police must be notified immediately as per the obligations to report a death or suspected death under s35 of the Coroners Act 2009 (NSW) It should be assumed the police will then take command of the site until otherwise directed
Action
The Department of Planning Industry and Environment Aboriginal Heritage Section must be notified immediately The project Aboriginal Cultural Heritage Advisor must contact and inform the relevant Aboriginal community stakeholders who may request to be present on site
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Figure 3 Overview of steps to be undertaken on the discovery of bones
After the appropriate verbal notifications (as described in 2B and 2C above) the Project Manager must proceed through the Unexpected Heritage Items Exhumation Procedure (Step 4) It is noted that no Exhumation Procedure is required for forensic cases (2A) as all future management is a police matter Non-human skeletal remains must be treated like any other unexpected archaeological find and so must proceed to record the find
3 Additional considerations and requirements
Uncovering archaeological human remains must be managed intensively and needs to consider a number of additional specific issues These issues might include facilitating culturally appropriate processes when dealing with Aboriginal remains (such as repatriation and cultural ceremonies) Project Managers may need to consider overnight site security of any exposed remains and may need to manage the onsite attendance of a number of different external stakeholders during assessment andor investigation of remains
Project Managers may also be advised to liaise with local churchreligious groups and the media to manage community issues arising from the find Additional investigations may be required to identify living descendants particularly if the remains are to be removed and relocated
If exhumation of the remains (from a formal burial or a vault) is required Project Managers should also be aware of additional approval requirements under the NSW Public Health Act 1991 Specifically Sydney Metro may be required to apply to the Director General of NSW
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Department of Health for approval to exhume human remains as per Clause 26 of the NSW Public Health (Disposal of Bodies) Regulation 2002 8
Further the exhumation of such remains needs to consider health risks such as infectious disease control exhumation procedures and reburial approval and registration Further guidance on this matter can be found at the NSW Department of Health website
In addition due to the potential significant statutory and common law controls and prohibitions associated with interfering with a public cemetery project teams are advised when works uncover human remains adjacent to cemeteries to confirm the cemeteryrsquos exact boundaries where possible
8 This requirement is in addition to heritage approvals under the Heritage Act 1977
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Appendix 5 - Archaeologicalheritage advice checklist
The archaeologistAboriginal heritage consultant must advise the Sydney Metro Environment Manager and Senior Heritage Advisor of an appropriate archaeological or heritage management plan as soon as possible after an inspection of the site has been completed An archaeological or heritage management plan can include a range of activities and processes which differ depending on the find and its significance
In discussions with the archaeologistAboriginal heritage consultant the following checklist can be used as a prompt to ensure all relevant heritage issues are considered when developing this plan This will allow the project team to receive clear and full advice to move forward quickly Archaeological andor heritage advice on how to proceed can be received in a letter or email outlining all relevant archaeological andor heritage issues
Required Outcomenotes
Assessment and investigation
Assessment of significance YesNo
Assessment of heritage impact YesNo
Archaeological excavation YesNo
Archival photographic recording YesNo
Heritage approvals and notifications
AHIP section 140 section 139 exceptions section 60 exemptions etc
YesNo
Regulator relicsobjects notification YesNo
Notification to Sydney Trains for s170 heritage conservation register
YesNo
Compliance with CEMP or other project heritage approvals
YesNo
Stakeholder consultation
Aboriginal stakeholder consultation YesNo
Artefactheritage item management
Retention or conservation strategy (eg items may be subject to long conservation and interpretation)
YesNo
Disposal strategy YesNo
Short term and permanent storage locations (interested third parties should be consulted on this issue)
YesNo
Control Agreement for Aboriginal objects YesNo
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Appendix 6 - Template notification letter
Insert on Sydney Metro letterhead
Select and type date] [Select and type reference number]
XXX
Heritage NSW Department of Planning Industry and
Environment
xxx
Parramatta NSW 2124
[Select and type salutation and name]
Re Unexpected heritage item discovered during Sydney Metro activities
I write to inform you of an unexpected [select relic heritage item or Aboriginal object] found during Sydney Metro investigative and construction works at [insert location] on [insert date] in accordance with the notification requirement under select section 146 of the Heritage Act 1977 (NSW) [Where the regulator has been informally notified at an earlier date by telephone this should be referred to here]
[Provide a brief overview of the project background and project area Provide a summary of the description and location of the item including a map and image where possible Also include how the project was assessed under the Environmental Planning and Assessment Act 1979 (NSW) (eg Part 5) Also include any project approval number if available]
Sydney Metro [or contractor] has sought professional archaeological advice regarding the item A preliminary assessment indicates [provide a summary description and likely significance of the item] Please find additional information on the site recording form attached
Based on the preliminary findings Sydney Metro [or contractor] is proposing [provide a summary of the proposed archaeologicalheritage approach (eg develop archaeological research design (where relevant) seek heritage approvals undertake archaeological investigation or conservationinterpretation strategy) Also include preliminary justification of such heritage impact with regard to project design constraints and delivery program]
The proposed approach will be further developed in consultation with a nominated Office of Environment and Heritage staff member
Should you have any feedback on the proposed approach or if you require any further information please do not hesitate to contact [Environment and Planning Project Manager] on (02) XXXX XXXX
Yours sincerely
[Sender name]
Sydney Metro Director Environment Sustainability amp Planning [Attach the archaeologicalheritage management plan and site recording form]
NB On finding Aboriginal human skeletal remains this letter must also be sent to the Commonwealth Minister for the Environment in accordance with notification requirements under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 56 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 5B ndash Sydney Metro Exhumation Management Procedure
Unclassified
Exhumation Management
Procedure
SM ES-PW-31510
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final issued for Implementation
Version 40
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2017
Unclassified
Integrated
Management
System
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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Table of Contents
Contents 1 Introduction 3
2 Methodology 3 21 Overview of legislative requirements for dealing with human remains
4 22 Discovery of human remains and forensic cases NSW Coroners
Act 2009 (NSW) 4 23 Historic human remains Heritage Act 1977 and Guidelines for the
Management of Human Skeletal Remains under the Heritage Act 1977 5
24 Aboriginal human remains National Parks and Wildlife Act 1974 6 25 Exhumation of human remains Public Health Regulation 2012
(NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013) 7
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013) 7
27 Work Health and Safety Act 2011 7
3 Sydney Metro procedure for the discovery and management of human remains 8 31 Initial discovery of bones What do we do 8 32 Archaeological Exhumation Methodology 10
4 Excavation and post-excavation tasks 14 41 Research Questions 14 42 Process for DNA Testing Isotope Analysis and Environmental
Sampling 15 43 Reporting 16 44 Public Involvement 16 45 Temporary Storage and Permanent Repository or Resting Place for
Remains 17
5 Definitions 18
6 Related Documents and References 18
7 Superseded Documents 18
8 Document History 18
9 Schedule of Acronyms 18
Exhumation of Human Remains 20 EXHUMATION OF HUMAN REMAINS 1 MANDATORY REQUIREMENTS 1 IMPLEMENTATION 1 REVISION HISTORY 2 CONTENTS 4 APPENDIX 2 11 APPENDIX 3 12 APPENDIX 4 13 APPLICATION TO EXHUME REMAINS 16
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1 Introduction
This Exhumation Management Procedure (ExMP) has been developed to provide Sydney Metro and their contractors with guidance on managing the discovery of human skeletal remains during the course of the Sydney Metro program of works
Sydney Metro is Australiarsquos biggest public transport project From the northwest metro rail is being extended under Sydney Harbour through new underground city stations and beyond to the south west In 2024 Sydney will have 31 metro railway stations and a 66km standalone metro railway system revolutionising the way Australiarsquos biggest city travels (refer to Figure 1)
The purpose of this ExMP is to provide a clear and concise process to follow in the event of the discovery of potential human remains during Sydney Metro project works
This ExMP will be reviewed as required and prior to any future Sydney Metro project that has potential to impact on a known cemetery or burial ground A review may require amendment the ExMP to tailor additional controls or management procedures that are specific to the impacted cemetery or burial ground In addition the requirements of the relevant Planning Approval will be assessed during the review of this ExMP prior to its implementation
This procedure should be read in conjunction with the Sydney Metro Unexpected Finds Policy
2 Methodology
This ExMP outlines the procedure for the management of the discovery of human remains within the Sydney Metro program The ExMP addresses the following
Discussion of relevant legislation and guidelines (eg Coroners Act 2009 Heritage Act 1977 Guidelines for the Management of Human Skeletal Remains 1988 and the Public Health Regulations 2012)
Archaeological methodology for excavation of remains including processes for appropriately handling remains in accordance with the relevant guidelines
Preparation of a flow chart process to be used by contractors to respond to the discovery of suspected human remains
Post-exhumation management primarily around relocation processing and long- term arrangements
Process for nomination of a physical anthropologist and temporary storage location
Process for additional analysis including DNA testing isotope analysis and environmental sampling and discussion on requirements for public involvement
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Figure 1 2020 Sydney Metro Program Project overview and station locations
21 Overview of legislative requirements for dealing with human remains
The following section provides an overview of the legislation that would apply to the discovery management and relocation of human remains A discovery of suspected human remains may be subject to different Acts and requirements thereby triggering different notification pathways based on the specific circumstances involved
The first step will always be to notify the NSW Police Confirmation of the age (antiquity) and nature of the skeletal remains as well as the reasons for the disturbance will dictate which Act and provisions will be applicable
22 Discovery of human remains and forensic cases NSW Coroners Act 2009 (NSW)
For a discovery of suspected human remains less than 100 years old the remains would come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such a case would be considered a lsquoreportable deathrsquo and under legal notification obligations set out in s35 (2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (ie both Aboriginal and non-Aboriginal remains)
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35 Obligation to report death or suspected death
(1) This section applies to any person who has reasonable grounds to believe that a death or suspected death of another person
(a) is a reportable death or occurred in circumstances that would be examinable under Division 2 of Part 32 and
(b) has not been reported in accordance with subsection (2)
(2) A person to whom this section applies must report the death or suspected death concerned to a police officer a coroner or an assistant coroner as soon as possible after becoming aware of the grounds referred to in subsection (1)
Maximum penalty (subsection (2)) 10 penalty units
(3) A police officer to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner or assistant coroner as soon as possible after the report is made
(4) An assistant coroner to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner as soon as possible after the report is made
(5) A coroner to whom a death or suspected death is reported under this section is required to inform the State Coroner of the report as soon as practicable after the report is made
23 Historic human remains Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 19771 (the Guidelines) apply to historic burials in New South Wales It should be noted that the Guidelines are outdated in terms of the current statutory framework
A relic is defined as an archaeological deposit or artefact that has heritage significance at a local or State level The guidelines Assessing Significance for Historical Archaeological Sites and `Relics2 have been endorsed by the Heritage Council and should be used to assess the level of heritage or archaeological significance of the remains With reference to burial grounds objects such as headstones grave enclosures and grave goods as well as buried human remains may be a lsquorelicrsquo
1 NSW Heritage Office 1998
2 Heritage Branch of the Department of Planning 2009
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Approval under the Heritage Act 1977 and the National Parks and Wildlife Act 1974 is not required if human remains are uncovered during a Critical State Significant Infrastructure (CSSI) project However notification to the Heritage Council under s146 of the Heritage Act and notification of an Aboriginal object under the National Parks and Wildlife Act is required if archaeological human remains are uncovered
24 Aboriginal human remains National Parks and Wildlife Act 1974
The National Parks and Wildlife Act provides statutory protection for all Aboriginal lsquoobjectsrsquo (consisting of any material evidence of the Aboriginal occupation of NSW) under Section 90 of the Act and for lsquoAboriginal Placesrsquo (areas of cultural significance to the Aboriginal community) under Section 84
Discovery of Aboriginal burials andor human remains would be addressed in the projectrsquos Aboriginal Cultural Heritage Assessment Report (ACHAR) ACHARs would be prepared in accordance with the Heritage NSW
lsquoGuidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation3
Guide to investigating assessing and reporting on Aboriginal cultural heritage in NSW4
Aboriginal cultural heritage consultation requirements for proponents 20105
Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales6
If suspected human skeletal remains are uncovered at any time during the archaeological management program the process outlined in this ExMP and detailed in the flow chart is to be followed Management of the remains would be guided by consultation with the nominated Registered Aboriginal Parties (RAPs) for the project in adherence to the ACHAR
3 NSW Department of Environment and Conservation 2005
4 OEH 2011
5 Department of Environment Climate Change and Water 2010
6 OEH 2010
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25 Exhumation of human remains Public Health Regulation 2012 (NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013)
Public Health Regulation 2012 and the NSW Health Policy Statement ndash Exhumation of human remains of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies in NSW
Under Clause 70 of the Regulation an application for approval to exhume the remains of a dead person may be made to the Director-General via an approved form to the Director of the Local Public Health Unit that acts on behalf of the Director-General of NSW Health Exhumation is not to take place unless an authorised officer or a NSW Health member of staff is present at the exhumation (the grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer) (Clause 72) An authorised officer must be present at the exhumation to ensure the correct interment procedure is followed and that all of the remains are exhumed and to enforce the protection of public health should this be necessary
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013)
The NSW Ministry of Health Policy Statement on the exhumation of human remains provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation Under Clause 69 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General An application for permission to exhume the remains of a deceased person is to be made to the Public Health Unit on the approved form which is contained at the NSW Health website
The required form is appended to this ExMP for ease of reference
Note that the title of Director General of Health was replaced with the Secretary of Health when the Public Health Act and Public Health Regulation were amended However the Policy Directive PD2013-046 has not been amended to reflect this change
27 Work Health and Safety Act 2011
The Work Health and Safety Act 2011 provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices and are enforced by WorkCover NSW Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation More information on safe work practices is available at or by contacting SafeWork NSW via their website or directly
Health and safety aspects of working with human remains should be considered Generally working with archaeological human skeletal remains requires no extra precautions to be taken beyond normal health and safety regulations Once any necessary site health and safety precautions have been taken the exhumation of human remains can proceed
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3 Sydney Metro procedure for the discovery and management of human remains
This procedure provides project managers principal contractors and the project archaeologistExcavation Director with advice on the steps to follow upon uncovering suspected human remains Information on the potential for burials and human remains would be included in the general project induction for all personnel The induction would include the procedure to manage these finds as set out in this ExMP
31 Initial discovery of bones What do we do
To avoid doubt all suspected bone items must be treated as potential human skeletal remains and work around them must stop while they are protected and investigated as a matter of urgency
Stop Work and preliminary notification
On discovery of bone (suspected human remains) all work in the area of the find must stop and the remains must be confirmed as being human or not
The Project ArchaeologistExcavation Director must be notified
Preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 2009
What When bones are uncovered at a site all work in the area the find must stop immediately and the
site must be secured
Who The discoverer will immediately notify machinery operators so that no further disturbance of the
remains will occur as well as notify the foremansite supervisor principal contractor project archaeologistExcavation Director and Sydney Metro Environmental Manager
Preliminary notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager Notification should provide verbal description of the remains and inform the police that consultation with technical specialists is being undertaken to confirm that the remains are human as well as the burial context (archaeological or less than 100 years old refer Step 2)
How Inform all site personnel of restricted access to the area of the discovery until further notice Area must be fenced off (flagging or temporary exclusion fencing)
Actions Notify site supervisor principal contractor project archaeologist Excavation Director and Sydney Metro Environmental Manger of the find and protect the suspected remains until an initial assessment can be undertaken by a technical specialist
Preliminary notification to NSW Police by Sydney Metro Environmental Manager
Confirm the remains are human
Skeletal remains could either be articulated and in a recognisable form of burial such as a coffin or common burial position of the body (eg supine prone or flexed) or they could be disarticulated or fragmented remains Within the boundaries of a known historic burial ground there is a high probability of the remains being human In a suspected forensic case (less than 100 years old) the remains may have clothing andor human tissue Disarticulated or fragmented bones are often uncovered and these may require specialist assessment to determine legal jurisdiction
If suspected human remains are identified during the course of project works preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 1999 (refer Step 1) NSW Police would be contacted immediately upon receipt of confirmation of human provenance
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Sydney Metro Exhumation Procedure v40 (final)
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What Confirmation that the remains are human their burial context - whether they are forensic (less than 100 years) or archaeological (older than 100 years) and suspected ancestry (Aboriginal or non- Aboriginal)
Who Excavation Director and or Forensic or physical anthropologist or archaeologist with specialist skills such as an osteoarchaeologist
Notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager
How Consultation could be undertaken as either an on-site inspection or via good quality photos sent to the nominated technical specialist of 1) the remains and 2) the site general site location of the discovery
Actions Contact nominated technical specialists to confirm that the remains are a) human b) burial context (archaeological or forensic) and c) suspected ancestry (Aboriginal or non-Aboriginal)
For the duration of the Sydney Metro project the nominated technical specialists are
Forensic Anthropologist ndash TBC by contractor for project area
Nominated Excavation Director ndash TBC by contractor for project area
Sydney Metro Environmental Manager to conduct and or oversee liaison with NSW Police
The archaeologist may be able to identify the nature of remains without input from the Forensic Anthropologist The Forensic Anthropologist should be contacted as required
Notification based on jurisdiction (forensic or archaeological)
Once confirmation is received from the technical specialist that the remains are of human origin there are three possible statutory pathways to follow based on the assessment
What Forensic case remains are less than 100 years old
Who If it is determined by specialist assessment (Step 2) that the remains are forensic the remains come
under the jurisdiction of the State Coroner and the Coroners Act 2009
How The NSW Police would likely secure the site and will advise on the procedure to be followed
Actions Environmental Manager to liaise with NSW Police
What Archaeological ndash non-Aboriginal human remains -more than 100 years old
Who Follow the Archaeology Exhumation Methodology as set out in Step 4 below
How Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Actions Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
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Sydney Metro Exhumation Procedure v40 (final)
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What Archaeological ndash suspected Aboriginal human remains -more than 100 years old
Who Recording of Aboriginal ancestral remains must be undertaken by or conducted under the direct supervision of a specialist with RAPs present
How The RAPs must be present where it is reasonably suspected that Aboriginal burials or human remains have been encountered
Actions Notify RAPs and follow ACHAR Notification to Heritage NSW
Follow the Archaeology Exhumation Methodology as set out in Step 4
32 Archaeological Exhumation Methodology
The following section provides the archaeological methodology for exhumation and the appropriate handling of human remains
Securing the Site
The strategy for the excavation and removal of human remains must be sensitive to public opinion and ethical issues and exhumation activities should not be visible to the general public The site may need to be screened off from public areas not only with hoarding but also in some cases with a roof to screen the site off from overlooking buildings At all times human remains should be treated with respect and dignity The perimeter of the excavation site should be demarcated by plastic tape or flagging with only technical staff allowed within this area for the duration of exhumation activities
The site should be protected from the elements including flooding contamination with dust or debris and other disturbance These measures would be formulated by the Excavation Director in consultation with the contractor and Sydney Metro where required and may differ from site to site
Excavation Director
Archaeological investigations are to be managed by a suitably qualified Excavation Director with experience in the historical archaeology of Sydney and the excavation and management of human remains For sites with potential for locally significant remains the Excavation Director should meet the NSW Heritage Council criteria for locally significant archaeological sites For sites with potential for State significant archaeology the Excavation Director should meet the NSW Heritage Council criteria for State significant archaeological sites
Excavation and recording
Exhumation and recording is to be undertaken in accordance with best practice forensic and Heritage Council guidelines Prior to removal the remains should be fully recorded in situ to understand their surrounding archaeological context This will include recording any disturbances to the burial and the identification of bones present In some cases the deposit of bones may be a mixture of articulated and disarticulated remains Care should be taken to distinguish articulated remains and to assess if they represent commingled individuals or disturbed remains belonging to one individual and to record them accordingly
Recording
A standard context recording system would be employed
Unclassified
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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Detailed survey andor measured drawings would be prepared and include location of remains within the overall site (position of the body the direction of the burial noting any stratigraphic relationships with other archaeological features)
Any associated artefacts (potential grave goods burial furniture) would be recorded and collected by context for later analysis
Digital photography in RAW format using photographic scales and photo boards where appropriate A photographic record of all phases of the work on site would be undertaken
Registers of contexts photos samples and drawings would be kept
Excavation
Detection of the extent of the graveremains (if disarticulated)
Surface soils removed in excavation units of 100mm (site dependent) using small hand tools
Expose remains with soft paint brushes and pedestal the remains
Record position and depth of remains
Soil removed would be sieved through 3mm mesh to examine for teeth and bone fragments
Soil samples may be taken from the abdominal andor chest areas of the body (articulated remains) to retrieve further evidence
Exhumation must be under the control of the Excavation Director with the assistance of a Forensic Anthropologist if required Exhumation permits provided by NSW Ministry of Health may also require the presence of an authorised officer or a member of staff of the Ministry of Health
Further excavation of the bottom of the pit (grave) following removal to confirm the absence of further remains
Relocation of bones
Removal and collection of skeletal remains to follow standard forensic practice of labelling
Remove remains from the ground systematically and place in plastic bags according to anatomical areas of the body
Bags should not be air-tight and should have ventilation holes to prevent deterioration of fragile skeletal material Each bag should contain labels and the separate bags should then be placed in a large plastic bag crate or box labelled with the context information
The remains should be placed in a sturdy large cardboard box (approximately 600 x 300 x 200 mm) for relocation to off-site processing location
Resume work
Construction work may only recommence upon receipt of clearance certificate from the Excavation Director and may require additional NSW Ministry of Health approval If a forensic case written authorisation from the NSW Police is required
Reporting
A report would be prepared following the completion of the program of exhumation works separate to the archaeological excavation report for the project This report would include skeletal analysis catalogue comprehensively describe the process of exhumation detail
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the recording of the remains and synthesise the results of any further laboratory testing An assessment of significance for the remains would be provided and interpreted within the context of the archaeological research design (response to research questions)
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Sydney Metro Exhumation Procedure v4 (Final)
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Figure 2 Exhumation Procedure Flow chart
Page 13 of 24
Discovery of bone
Non-human remains
Archaeologist to investigate and work not
to recommence until instrcuted by ED
Work only to recommence when clearance given by Excavation Director
Human Remains
Forensic
Sydney Metro Environmental
Manager to advise NSW POlice
Archaoelogical work not to recommence until clearance given
by NSW Police or Coroner
Aboriginal
Sydney Metro Environmental Manager to advise NSW Policye notify RAPs and follow
ACHAR
Archaoelogical work not to
recommence until clearance firven by
NSW Police or Coroner
Non Aboriginal
Sydney Metro Environmental Manager to notifiy NSW Policce Heritage NSW and DPIE
Sydney Metrocontractor to apply to Secretary of
Health to exhume
Exhumation of human remains by nominated ED Construction work not to commence until
ED issues Clearance Certificate
Sydney Metro ndash Integrated Management System (IMS)
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4 Excavation and post-excavation tasks
The following tasks relate to responses to the identification of human remains on site All management should be in accordance with the AARD and relevant Archaeological Method Statement (AMS) and be overseen by the Excavation Director The Excavation Director would nominate a Forensic Anthropologist where required
41 Research Questions
The following research questions should be used guide exhumations should intact burials disarticulated remain burial cuttings or associated material culture be uncovered during works
The research questions are a guide only and could be added to or amended by the Excavation Director depending on the nature of the find
Social History and Burial Practices
Does the location of the burialburial cutting correspond with historic plansdescriptions Are these sources reliable
Is there evidence of exhumation
Do graves cut into older ones What can this tell us about nineteenth century burial practices and how does this compare to other excavated cemetery sites in the region
What is the distance between burials (if multiple burials uncovered) Does this conform to known nineteenth century burial practices
What type of fill was used within grave cuttings What can this tell us about the surrounding environment and burial practices at the time
What materialstree species were used to produce coffins Can coffin manufacturing techniques or fastening methods (use of mortar screws nails tacks) be identified Does this match known burial practices of the time If alternative methods are identified what can this tell us about the manufacturer or economicsocial landscape
Can the class or rank of the individual be identified via coffin materials grave goods or clothingshrouds
Which direction is the burial orientated How does this correspond with the knownhypothesised location of denomination areas
If the burial is associated with additional individuals can a familial relationship be assessed through DNA or other genetic markers identifiable within the skeletal remains (eg impacted third molar)
Can an exchange between burial practices in Britain and colonial Sydney be identified through the burial remains Is there evidence for alternative burial practices associated with additional cultures
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
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Environmental Factors and Scientific Analysis
What is the condition of the bones How does their condition compare to known or nearby burials of the same age What environmental or human factors may have influenced the decomposition process
Can the health nutrition sex race stature or age be identified through the skeletal remains Is there evidence of trauma on the bones Is there evidence of pathology on the bones (eg syphilis tuberculosis tumours)
If archaeobotanical analysis is carried out what can it tell us about the surrounding environment and nearby plant species Can prepost-European landscapes be determined within the archaeobotanical record
Can stable isotope analysis address any questions regarding diet country of origin and nutrition
Can DNA testing address any questions not answerable by the skeletal remains themselves such as sex familial relationships (if buried with another individuals) or race
Is there potential for DNA to be tested against any individuals who may come forward as a descendant of the deceased
42 Process for DNA Testing Isotope Analysis and Environmental Sampling
Pre-Excavation
The Excavation Director in consultation with the Forensic Anthropologist will nominate a suitable laboratory prior to works commencing Approval for the analysis of skeletal remains soil samples and material samples from the laboratory would also be sought prior to works commencing
Excavation
In order to prevent cross-contamination the following sample collection and excavation process should be followed
The location quantity and material (bone teeth hair soil wood) of samples will be determined by the Excavation Director or Forensic Anthropologist prior to its collection
Samples would be stored in a safe secure and climate controlled location while excavations are in progress This would be chosen by the Excavation Director or Forensic Anthropologist on site
Each collected sample would be given a unique catalogue number and a sample register would be recorded throughout the excavation
ldquoClean Excavationrsquo procedures would be followed during the excavation of burials and during the sample collection process7 This would include
7 Guidelines for lsquoclean excavationrsquo are based on procedures outlined in Yang D Y amp Watt K 2005
Contamination controls when preparing archaeological remains for ancient DNA analysis Journal of Archaeological Science vol 32 pp 331ndash336 and Society for Historical Archaeology 2015-2017 Research and Analysis of Artefacts Accessed online at httpsshaorgconservation- factsfaqanalysisC on 2552017
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Latex gloves would be worn by individuals excavating andor handling bone or soil samples Gloves would be changed for each bone andor individual to prevent cross-contamination
Excavation toolsbrushes would be cleaned prior to and after the collection of each sample to prevent cross-contamination
In some cases a face mask would be worn when samples for DNA analysis are being collected
Bone samples for DNA testing would be collected with surrounding in situ soil and should not be cleaned prior to bagging
It may be necessary for individuals involved in sample collection to submit DNA for comparison in the event of cross-contamination and
All bags containing samples for analysis would be bagged and labelled appropriately to prevent cross contamination and ensure they are handled and stored correctly
Post-Excavation
On completion of excavations samples will be transported to nominated laboratories for analysis A record of their location will be kept
43 Reporting
The results of the investigation of human remains and the exhumation will be included in the archaeological reporting for the project in accordance with the project AARD
Once finalised all archaeological excavation and data analysis reports will be submitted to
The relevant local Council and Library
The Heritage Office Library
The State Library of NSW and
Made available online for public access and educational purposes
Further if significant remains are identified during excavations the results and findings would be published in academic journals and conference papers where feasible
44 Public Involvement
Archaeological excavations may uncover remains directly associated with early settlement and burial practices Such remains are likely to generate public interest
Public involvement may include
Media releases
Public Open Days
Preparation of brochures detailing the archaeological excavations
Interpretive signage and online blog posts or site diaries while excavations are taking place and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The preparation of a Heritage Interpretation Plan designed to provide interpretation of the site within the new development upon the completion of works
Due to sensitive nature of human skeletal remains these recommendations would be adapted and modified as appropriate under the direction of Sydney Metro and the Excavation Director
Such recommendations would also be considered and require approval from relevant Stakeholder Groups such as known or potential descendants of the deceased NSW Heritage Heritage Council local Council and interest groups
45 Temporary Storage and Permanent Repository or Resting Place for Remains
Temporary Storage
Upon the completion of archaeological excavations skeletal remains should be boxed separately and temporarily stored within a safe secure and temperature controlled environment to allow for further analysis of the remains This location would be chosen by the Excavation Director and the Forensic Anthropologist and comply with NSW legislative requirements
Permanent Repository or Resting Place for Remains
A permanent repository or resting place for remains is dependent on the nature and volume of skeletal remains As this cannot be determined prior to excavations taking place the following recommendations should act as guidelines only Final arrangements would be dictated by Sydney Metro the Excavation Director Forensic Anthropologist identified descendants of the deceased andor Stakeholder Groups upon the completion of excavations and subsequent analysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
5 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined inhttpsicentraltdocstransportnswgovauotcscsexeappnodes3574566
6 Related Documents and References
Related Documents and References
na
7 Superseded Documents
Superseded Documents
Exhumation Management Plan Version 22
Exhumation Management Plan Version 30
8 Document History
Version Date of approval Notes
11 May 2017 New IMS document
20 July 2017 Incorporates Stage 2 (Section 3)
21
February 2019
Extended for Metro Program wide application includes changes specific Central Station management incorporates comments received from the State Coronerrsquos Office NSW Police NSW Health Sydney Metro Environmental Environmental Representatives engaged on the Central site and the Office of Environment and Heritage
22 February 2019 Incorporates comments received from Artefact Heritage and Denise Donlan issued to Health and OEH HD for consultation
30 May 2019 Incorporates Health Coroner and OEH comments
40 April 2020 Updates to remove specific references to City and South West and Central Station
Change of title to ldquoProcedurerdquo
Update to references
9 Schedule of Acronyms
Acronym Meaning
AARD Archaeological Assessment and Research Design
ACHAR Aboriginal Cultural Heritage Assessment Report
AMS Archaeological Method Statement
CSSI Critical State Significant Infrastructure
ER Environmental Representative (Independent)
ExMP Exhumation Management Plan (this plan)
OEH Office of Environment and Heritage
PHU Public Health Unit
RAPs Registered Aboriginal Parties
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Appendix 1
NSW Heath Policy Directive for Exhumation of Human Remains
Policy Directive
Ministry of Health NSW 73 Miller Street North Sydney NSW 2060
Locked Mail Bag 961 North Sydney NSW 2059 Telephone (02) 9391 9000 Fax (02) 9391 9101
httpwwwhealthnswgovaupolicies
Exhumation of Human Remains
Document Number PD2013_046
Publication date 05-Dec-2013
Functional Sub group Population Health - Environmental
Summary This document provides the policy to be observed by NSW Health in receipt of an application to seek permission for approval of the exhumation of human remains under clauses 69-72 of the Public Health Regulation 2012 This Policy Directive will provide the conditions on which approvals may be granted for exhumation of human remains
Replaces Doc No Burials - Exhumation of Human Remains [PD2008_022]
Author Branch Environmental Health
Branch contact Environmental Health 94245823
Applies to Local Health Districts Environmental Health Officers of Local Councils Ministry of Health Public Health Units Public Hospitals
Audience Authorised officers from Public Health Units and local councils
Distributed to Public Health System Environmental Health Officers of Local Councils NSW Ambulance Service Ministry of Health Public Health Units Public Hospitals
Review date 05-Dec-2018
Policy Manual Patient Matters
File No 081292
Status Active
Director-General
This Policy Directive may be varied withdrawn or replaced at any time Compliance with this directive is mandatory for NSW Health and is a condition of subsidy for public health organisations
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 1 of 2
EXHUMATION OF HUMAN REMAINS
PURPOSE
This document provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Common reasons for exhuming bodies include to repatriate the remains overseas or to relocate the body to another cemetery plot or vault
MANDATORY REQUIREMENTS
Under Clause 69 of the Public Health Regulation 2012 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General
An application for approval to exhume the remains of the body of a dead person may be made to the Director General by
An executor of the estate of the dead person
The nearest surviving relative of the dead person
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person may make the application
An application is to be made in the approved form and it is to be accompanied by
A certified copy of the death certificate relating to the dead person
A statutory declaration as to the relationship of the applicant to the dead person and the dead persons wishes if any regarding the disposal of his or her body
An application fee
Under Clause 71 of the Public Health Regulation 2012 the Director-General may
Grant an approval to exhume the remains of a body
Refuse the application
Under Clause 72 an exhumation cannot take place without an authorised officer or a Ministry of Health staff member present A person must not proceed with an exhumation if the authorised officer or Ministry of Health staff member who is present at the exhumation orders the exhumation to stop
Under Clause 78 if the applicant seeks to have the exhumed body cremated a separate application can be made for an exemption from providing the required cremation documentation provided the body has been buried for longer than 10 years The minimum 10 year period is strictly enforced An application under this clause is to be accompanied by a fee of $100
IMPLEMENTATION
Authorised officers in Public Health Units of Local Health Districts are responsible for assessing applications for exhumation of human remains and either approving with a set of conditions or rejecting the application Authorised officers should ensure that all of the required document has been submitted with the application fee and that an appropriate person has applied for the application The approval granted is valid for a period of three months after the approval is granted
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 2 of 2
REVISION HISTORY
Version Approved by Amendment notes
December 2013 PD2013_046
Deputy Director- General Population and Public Health
This document is an updating of the original document due to legal changes under the Public Health Regulation 2012
23 April 2008 PD2008_022
Director-General This document provided the policy to be observed by NSW Health in receipt of an application to seek permission for approval of exhumation of human remains under clauses 25 ndash 28 of the Public Health (Disposal of Bodies) Regulation 2002 It provided the conditions upon which approvals could be granted for the exhumation of human remains
ATTACHMENTS
1 Exhumation of Human Remains Procedures
Exhumation of Human Remains PROCEDURES
Issue date December-2013
PD2013_046
Exhumation of Human Remains
Issue date December-2013 PD2013_046 Contents Page
PROCEDURES
CONTENTS
1 BACKGROUND 2
11 Introduction 2
12 Key definitions 2
13 Legal and legislative framework 3
2 APPLICATION REQUIREMENTS 6
3 APPROVAL BY PUBLIC HEALTH UNITS 7
31 Delegation 7
32 Special Considerations on Exhumation Approval 7
33 Conditions of Approval 8
34 Approval Instrument 8
35 Notification of Approval 8
36 Refusals 8
37 Cremation of Remains 8
APPENDIX 1 10
APPENDIX 2 11
APPENDIX 3 12
APPENDIX 4 13
APPENDIX 5 14
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 2 of 14
1 BACKGROUND
11 Introduction
Exhumation of human remains may occur for a number of reasons including
To satisfy family wishes where the family of the deceased person may want the remains to be moved to another burial ground to another part of the state or country or abroad or even to have the remains cremated
To obey Coronial orders requiring exhumation for forensic (criminal) investigation
To enable the use of closed cemeteries for redevelopment or for the construction of new infrastructure such as a road or airport
A variety of people including authorised officers cemetery authorities and funeral directors are involved at different stages of exhumation procedures
Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation however there is no obligation to proceed with an exhumation once it has been approved
The objectives of this document are
To assist authorised officers with processing applications to exhume
To standardise the management of an exhumation so as to prevent a public health risk and protect community amenity in the handling of remains
12 Key definitions
These definitions are repeated from the Public Health Act 2010 and Public Health Regulation 2012 for clarity
Body Means the body of a dead person but does not include
the cremated remains of the person
Burial Includes putting the body in a vault
Cemetery Authority Means the person or body that directs the operations of a cemetery
Coroner Means a person who exercises or performs the functions of a coroner in accordance with the Coroners Act 2009
Dead person Includes a still-born child (see definition of Still birth)
Exhumation Means the removal of a dead personrsquos remains (not being cremated remains) from a grave or vault but does not include their removal from one vault for immediate transfer to another vault in the same cemetery or their temporary removal for the purposes of reburial in the same grave or vault
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 3 of 14
Funeral director Means a person (other than the operator of a mortuary transport service) who in the conduct of the personrsquos business engages for the purpose of burial cremation or transport in the collection transport storage preparation or embalming of bodies or engages in the conduct of exhumations
Prescribed infectious diseases
Means any one of the following diseases avian influenza in humans diphtheria plague respiratory anthrax smallpox severe acute respiratory syndrome tuberculosis and any viral haemorrhagic fever (including Lassa Marburg Ebola and Congo-Crimean fevers)
Proper person The Director General has the power to decide whether a person is a lsquoproper personrsquo to make an application to exhume the remains of a dead person
Nearest surviving relative
Means (a) In relation to a still-born child a parent or sibling at or above the age of 16 years of the child (b) In relation to a dead person who is not a still-born child ndash the spouse or de facto partner of the dead person immediately before death a parent of the dead person a child at or above the age of 16 years of the dead person or any relative of the dead person who was residing with the dead person when he or she died
Still-birth Consistent with the Births Deaths amp Marriages Act 1995 means the birth of a child that exhibits no sign of respiration or heartbeat or other sign of life after birth and that (a) Is of at least 20 weeksrsquo gestation (b) If it cannot be reliably established whether the period of gestation is more or less than 20 weeks has a body mass of at least 400 grams at birth
13 Legal and legislative framework
Public Health Regulation 2012
Division 4 of Part 8 of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies
Clause 69 Exhumation without approval prohibited
(1) A person must not exhume the remains of a body unless the exhumation of those remains has been
(a) Ordered by a coroner
(b) Approved by the Director-General
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 4 of 14
(2) However a funeral director may without a coronerrsquos order or Director-Generalrsquos approval transfer a coffin from a vault in a cemetery to a mortuary for the purpose of the coffin being immediately repaired and returned to the vault
(3) A funeral director must return the coffin to the cemetery within 24 hours of its transfer
Clause 70 Application to exhume remains
(1) An application for approval to exhume the remains of the body of a dead person may be made to the Director-General by
(a) An executor of the estate of the dead person
(b) The nearest surviving relative of the dead person
(c) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances may make the application
(2) An application is to be made in the approved form and is to be accompanied by
(a) A certified copy of the death certificate relating to the dead person
(b) A statutory declaration as to the relationship of the applicant to the dead person and the dead personrsquos wishes if any regarding the disposal of his or her body (so far as any such wishes are known to the applicant)
(c) An application fee (please check with the PHU for the current fee)
(3) In this clause death certificate means a certificate given by a medical practitioner as to the cause of death or issued under the Births Deaths and Marriages Registration Act 1995
All applications to exhume remains must be made in writing using an approved form to the Director of the local Public Health Unit that acts on behalf of the Director-General of the NSW Ministry of Health The application fee may increase periodically in line with the Consumer Price Index
Clause 71 Approval to exhume remains
(1) The Director-General may
(a) Grant an approval to exhume the remains of a body subject to any conditions specified in the approval
(b) Refuse the application
(2) An approval granted under this clause remains valid for three months from the date of the approval or for a period agreed to by the Director-General
The PHU is not bound to approve the application The PHU may approve subject to conditions or refuse the application An approval is normally given for 3 calendar months and this date will be specified in a schedule of conditions attached to the approval document Any further extension of time may require re-application and re-approval An approval initially for longer than three calendar months should be negotiated with the PHU
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 5 of 14
Clause 72 Exhumation not to take place without authorised officer present
(1) A person must not proceed with an exhumation unless an authorised officer or a member of staff of the Ministry of Health is present at the exhumation
(2) A person must not proceed with an exhumation if the authorised officer or Ministry staff member who is present at the exhumation orders the exhumation to stop
The grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer An authorised officer must be present at the exhumation to ensure that the correct interment is opened to ensure that all of the remains are exhumed and to enforce the protection of public health should this be necessary The authorised officer has the power to order that the exhumation be stopped immediately under adverse circumstances An example of where this may occur is where the weather is very poor with heavy rain The initial order to stop is to be given verbally and then confirmed in writing to all parties involved within 24 hours
Division 5 of Part 8 of the Public Health Regulation 2012 provides for cremation of deceased persons
Clause 78 No cremation without documentation
Clause 78 does not apply to a cremation of the body of a dead person that has been buried for at least 10 years if the cremation is carried out in accordance with an exemption granted by the Director-General following an application by
1) An executor of the estate of the dead person
2) The nearest surviving relative of the dead person
3) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
This is a new addition to the Exhumation section of the Regulation that may be used where a person makes a separate application to have the exhumed body cremated following the exhumation
Note The Director-Generalrsquos authority under Clause 78 (4) of the Public Health Regulation 2012 (Delegations Manual page 866 delegation (PH590)) is the power to decide whether a person is a ldquoproper personrdquo to make an application in the absence of an executor or surviving relative
Work Health and Safety Act 2011
The Work Health and Safety Act 2011 and Code of Practice for Excavation provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation The Work Health and Safety Act 2011 makes reference to working in confined spaces
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 6 of 14
WHampS matters are enforced by WorkCover NSW More information on safe work practices is available at httpwwwworkcovernswgovaudefault or by contacting Workcover NSW direct on 13 10 50
Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977 applies to relic burials Any burial site over 50 years old is considered to be relic under the Heritage Act If the site is listed on the State Heritage Register then approval is required from the Heritage Council of NSW
An application must be made to the Heritage Office before any disturbance removal or work commences on the site Approval for an exhumation under the Public Health Regulation 2012 does not obviate the necessity to obtain approval under the Heritage Act 1977 For further information contact the Heritage Office of NSW or visit httpwwwheritagenswgovau
Coronerrsquos Act 2009
A coroner may order an exhumation for the purposes of forensic investigation or a criminal investigation Such an order is outside the ambit of the Public Health Regulation 2012 The Police may request that an authorised officer from the Ministry of Health or the local Public Health Unit be present at the coronial exhumation
Births Deaths and Marriages Registration Act 1995
Section 41(2) of the Births Deaths and Marriages Registration Act 1995 requires that if human remains (other than cremated remains) are removed from NSW the funeral director or other person who arranges for the removal of the remains from NSW must within 28 days of disposal of the remains outside NSW give the Registrar notice of the new location of interment The act is available at httpwwwaustliieduauaulegisnswconsol_actbdamra1995383 The Registry of Births Deaths and Marriages may be contacted via httpwwwbdmnswgovau
2 APPLICATION REQUIREMENTS
An application for permission to exhume the remains of a deceased person is to be made to the PHU on the approved form which is contained at the NSW Ministry of Health website at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c70- application-to-exhumepdf
The application must be made by either
An executor of the estate of the deceased
The nearest surviving relative
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 7 of 14
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
The application must be accompanied by
A certified copy of the death certificate (death certificate issued by the Registry of Births Deaths and Marriages)
A statutory declaration that states
The relationship between the applicant and the deceased or the reason the applicant is the proper person to make the application
If the deceased left any instructions regarding the disposal of their bodyremains if known
In addition to the above an applicant should declare that he or she has consulted each nearest surviving relative and that they have no objection to the proposed exhumation
An application fee (please check with the PHU for the current fee)
Note If there is no agreement amongst nearest surviving relatives the applicant should seek independent legal advice regarding this issue The applicant should advise if there is an intention to cremate the body following the body being exhumed and the appropriate form completed
3 APPROVAL BY PUBLIC HEALTH UNITS
Approval by PHUs for an exhumation must be given by formal correspondence
31 Delegation
The Director-Generalrsquos authority under clauses 69(1) 70(1)(c) and 71 of the Public Health Regulation 2012 has been delegated to the Chief Health Officer Director Health Protection Public Health Officer or Public Health Unit Director as appointed under Section 121 of the Act (delegation PH308 PH309)
32 Special Considerations on Exhumation Approval
Special consideration should be given to the approval of an exhumation if the deceased was infected with a prescribed infectious disease For example if the deceased was infected with diphtheria or tuberculosis exhumation should not permitted in the first year of interment
Although not prohibited an exhumation of the remains of a body that was buried without a coffin will be approved only where the cemetery authority and funeral director have agreed to proceed with the exhumation especially during the first three years of interment
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 8 of 14
33 Conditions of Approval
After due consideration of the application and the statutory declaration(s) the PHU should then consider applying appropriate conditions to facilitate an approval
There are two standard sets of approval conditions which can be applied as appropriate
Appendix 2 ndash Schedule A - Conditions of Approval for Exhumation from a Grave
Appendix 3 ndash Schedule B - Conditions of Approval for Exhumation from an Above Ground Structure
Any other additional conditions that are deemed necessary to permit the exhumation may be added to schedule A or B based on the individual circumstances of the exhumation If some conditions are unwarranted they may be removed from the relevant schedule
34 Approval Instrument
An approval must be in writing and must be signed the Director General or their delegate A template to assist in the approval process can be found at Appendix 4 This template is to be completed by the Authorised Officer in order to facilitate approval by the delegate
35 Notification of Approval
The approval instrument is retained on file as a record that approval was granted by the Director General or their delegate Therefore it is necessary to advise the applicant the cemetery authority and the funeral director of the approval
The attached letter templates may be used for approval notification of the exhumation to the applicant funeral director and Cemetery Authority
Appendix 5 ndash Sample Letter to Applicant
Appendix 6 ndash Sample Letter to the Cemetery Authority and Funeral Director
36 Refusals
If after due consideration the application is to be refused then the applicant should be notified in writing specifying the reasons for refusal Ideally the applicant should consult the PHU in the first instance to discuss the requirements and possible restrictions on an application to exhume
37 Cremation of Remains
Division 5 of Part 8 of the Public Health Regulation 2012 sets out the requirements for documentation for cremations in NSW and includes the requirement for a cremation application form a cremation certificate and the cremation permit The documentation confirms the identity of the body to be cremated and the cause of death and ensures that a coronerrsquos investigation has been conducted where necessary
After the body is exhumed the next of kin may wish to have the body cremated However there may be cases whereby the body does not have the required paperwork necessary for cremation Clause 78 of the Public Health Regulation 2012 provides an exemption for
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 9 of 14
the required documentation for cremation where the body has been buried for longer than 10 years An application under this clause is to be accompanied by a fee
The Director General has the power to approve an exemption and the executor or the nearest surviving relative or another proper person may make application on form lsquoApplication for Exemption by the Director ndash General to the Requirement for Documentation for Cremation to Proceed Permission for Cremation of Exhumed Remains of a Body Buried more than 10 years ago with statutory declarationrsquo The minimum 10 year period will be strictly enforced and this matter should be clarified prior to any exhumation approval where it is planned for the remains to be subsequently cremated The application form is available at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c78-application-for- exemptionpdf
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 10 of 14
APPENDIX 1
Schedule A
CONDITIONS OF APPROVAL FOR EXHUMATION FROM GRAVE
1 The exhumation is to be carried out in the presence of a Public Health Unitrsquos authorised
officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Day and time of the exhumation shall be arranged by the participating parties and agreed
to by the Public Health Unit
4 The approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The presence of any relative of the deceased at the exhumation is strictly prohibited
6 No animals are to be permitted within the exhumation site
7 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
8 If during the course of the exhumation it is determined necessary to stop the exhumation
by either the exhumation supervisor cemetery manager or authorised Officer for any valid reason eg work health and or public health risk then the exhumation must cease
9 The remains of the deceased shall be enclosed in a body bag and placed into a new coffin
with a name plate attached inscribed with the name of the deceased
10 The remains of the original coffin are to be placed in the new coffin where possible Where there is an excess of remains of the original coffin these remains should be disposed in a sanitary and agreed manner
11 Excavated soil should be back filled The soil that was removed from immediately above
and around the coffin should be replaced first
12 If the exhumed remains are to be transferred to another cemetery a funeral director shall be contracted to transfer the remains from the cemetery grounds or carry out preparatory work for the safe reinterment of the remains
13 The exhumation will not proceed during or following a period of heavy rainfall within the preceding 24 hours of the appointed time of exhumation The cemetery manager is to confirm that satisfactory conditions exist for the exhumation to proceed two hours prior to the commencement of the exhumation
14 Used disposable protective equipment and materials are to be placed in a sealed plastic
bag and disposed of in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 11 of 14
APPENDIX 2
Schedule B
CONDITIONS OF APPROVAL FOR EXHUMATION FROM ABOVE GROUND STRUCTURE
1 The exhumation is to be carried out in presence of a Public Health Unit authorised officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Date and time of the exhumation shall be arranged by the participating parties and agreed to
by the Public Health Unit
4 An approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
6 If during the course of the exhumation it is determined necessary to stop the exhumation by
either the exhumation supervisor Cemetery Manager or authorised officer if for any valid reason eg worker health andor public health risks then the exhumation must cease
7 Used disposable protective equipment and materials are to be placed in a sealed plastic bag
and disposed in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 12 of 14
APPENDIX 3
LETTERHEAD
APPROVAL INSTRUMENT TEMPLATE
Public Health Unit Environmental Health Section
File Number [XXXXX]
PURPOSE To approve of the exhumation of the late
RECOMMENDATION
Approval is granted by the Director General pursuant to clause 71(1)(a) Public Health Regulation
2012 to [NAME OF APPLICANT] to exhume the remains of the late [NAME OF DECEASED]
KEY ISSUES
[DETAILS OF THE APPLICATION STATUTORY DECLARATION RELEVANT ISSUES
MANAGEMENT PLAN AND JUSTIFICATION OF SUGGESTED CONDITIONS ARE TO BE
INCLUDED HERE]
BACKGROUND (TO BE COMPLETED BY PHU)
CONSULTATION (TO BE COMPLETED BY PHU WHERE APPROPRIATE)
The approval be subject to compliance with the conditions specified in Schedule A Schedule B
and to expire on
Signature Authorised officer
Author Telephone Date
1 Authorised officer
2 Public Health Unit Director Public Health Officer [SIGN AND DATE]
Approved via delegation from the Director-General PH308 PH309 page 863 Public
Health Delegations Manual under clause 69(1) and 70(1) (C) Public Health Regulation
2012
3 Authorised officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 13 of 14
APPENDIX 4
LETTERHEAD
SAMPLE LETTER TO APPLICANT
[APPLICANTrsquoS NAME] [ADDRESS]
Dear [APPLICANTrsquoS NAME]
Reference is made to your application of [DATE] requesting approval to exhume the remains of
late [NAME OF DECEASED] from grave vault crypt No Section [NAME OF
PLACE OF INTERMENT OR CEMETERY] for the purpose of re-interment to [NAME OF PLACE
FOR RE-INTERMENT]
Approval has been granted by the Director-General pursuant to clause 71 (1) (a) Public Health
Regulation 2012 subject to compliance with the conditions specified in Schedule A Schedule B
attached
The funeral director and cemetery authority have been advised of the approval
Should you have any inquiries please contact the authorised officer [EHO] on [TELEPHONE] or (EMAIL ADDRESS)
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 14 of 14
APPENDIX 5
LETTERHEAD
SAMPLE LETTER TO CEMETERY AUTHORITY AND FUNERAL DIRECTORS
[NAME] [ADDRESS]
[DATE]
Dear [NAME]
EXHUMATION OF THE REMAINS OF THE LATE [NAME OF DECEASED]
Approval has been granted for the exhumation of the late [NAME OF DECEASED] from grave
vault crypt No Section [NAME OF PLACE OF INTERMENT OR
CEMETERY] in accordance with clause 71(1) (a) of the Public Health Regulation 2012 and
subject to compliance with the conditions specified in Schedule A Schedule B attached
A copy of the approval letter is attached for your information
Should you have any inquiries please contact [Authorised Officer) on [TELEPHONE] or email address
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
Unclassified
Addendum 2
NSW Heath Permit Application form
copy Sydney Metro 2017 Page 23 of 24
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
APPLICATION TO EXHUME REMAINS PUBLIC HEALTH REGULATION 2012 Clause 70(2)
In accordance with the requirements of Clause 70 (2) of the Public Health Regulation 2012 I helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Full name of applicant)
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip hereby (Address)
apply for permission to exhume the remains of the late helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Name of deceased)
from Grave Nohelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Section helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip being a single
interment within the helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipCemetery for the purpose of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
I seek permission to exhume for the following reasons
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
The deceased (cross out which is not applicable)
was not known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012 or
was known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012
I am entitled to make this application because I am (tick one)
1 [ ] The executor of the estate of the deceased or
2 [ ] The nearest surviving relative of the deceased or
3 [ ] If there is no such executor or relative available to make the application another the proper person to make the application for the reasons set out below
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Full reasons for proper person to make application) Attached is
1 A certified copy of the death certificate of the deceased
2 A statutory declaration as to
My relationship to the deceased and
the wishes of the deceased regarding the disposal of the body (if known)
the reasons why the Director-General may consider me the proper person in all the circumstances to make the application (if applicable)
3 The application fee of $helliphelliphelliphelliphelliphelliphellip
Signature helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Date helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Applicant)
The exhumation is to be supervised in strict accordance with the attached Plan of Management
by helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
employed with helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip(Funeral DirectorCemetery)
in the capacity of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
Form C70
Unclassified
copy Sydney Metro 2017 Unclassified Page 24 of 24
ExMP v30 (final)
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
bttp wwwshd nsw gay auQQpulat onhealthPubtic Healthhtml
NSW
Public Health Unit ll iI I
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 57 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise gaseous and particulate pollutant emissions from construction activities as far as feasible and reasonable Identify and control potential dust and air pollutant sources
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Site related dust identifiable fumes odours and vapours will not infringe beyond site boundaries where practical
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required for air quality and dust management including - Correct use of PPE - Use of monitoring equipment - Methods to control dust
Project Manager
Greenhouse Gases
Regular maintenance of plant and equipment for optimum performance will be undertaken to keep emissions to a minimum and increase plant productivity
Vehicles and equipment must be fitted with appropriate emission control equipment and routinely maintained Plant should be switched off when not in use wherever practicable
All plant equipment and vehicles are to be regularly monitored and maintained and records kept of maintenance Engine tampering to increase power output is prohibited
Air emissions from plant vehicles and equipment should be visually monitored throughout construction
Comply with National Greenhouse Emission Reporting Scheme (NGERS) reporting requirements
Project Manager
Dark Smoke
All internal combustion engines will be regularly serviced to ensure optimum operation and minimise the volume of visible smoke emitted Any Plant or light vehicles emitting unreasonable smoke (concentrations higher than normal operation) will cease operation and be serviced by a trained and qualified technician
Materials on site will not be burned intentionally without consulting and obtaining the authorisation of the relevant Local Shire Fire Authority and Client The burning of any material on site should be a last option after alternative methods have been considered
All
Dust Monitoring
The following dust monitoring methods will be applied on the Site
Obtaining weather reports from the Bureau of Meteorology (BOM) website Visual inspection
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 58 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Dust Control
Dust control methods to be applied on the site to keep dust generated within the site boundaries as reasonably practicable will be
- Wind fencing around the site or between the site and local residences - Application of waterdust suppressant via water carts - Hydro mulching to stabilise soils - Physical application of ground cover - Cessation of works in adverse weather conditions - Restricted speed limits on site - Reschedule dust generating activities to avoid adverse weather conditions - Communicate dust risk and mitigation measures to staff prior to commencing work
All
Fumes Odours and Vapours
The Site will endeavour to keep the generation of emission of unreasonable levels of fumes odours and vapours to a minimum Refer to the Waste Management Sub Plan and Hydrocarbon and Chemical Environmental Management Sub Plan which detail storage and handling controls that minimise fumes odours and vapours
All
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for dust mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 59 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise unreasonable noise and vibration impacts on residents and businesses Avoid structural damage to buildings or heritage items as a result of construction vibration Undertake active community consultation Reduce visual impact of construction to surrounding community Maintain positive cooperative relationships with schools childcare centres local residents and building owners
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Community
The nearest noise and vibration sensitive receivers will be notified of future works and expected levels of noise and vibration well in advance of the works occurring Notifications will be in accordance with the Community Communications Strategy
Information will be provided to the affected community before and during construction through media such as letterbox drops meetings or individual contact A website will also be established for the project to provide information
A toll-free 24hour project hotline will be provided for enquiries and complaints during the works
Sydney Metro and Georgiou Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the site specific management required
for noise and vibration including
- Sensitive receivers - Hours of works - Correct use of plant and equipment - Monitoring requirements
Standard hours of construction
Approved standard hours of construction are Monday to Friday
7 am to 6 pm Saturday 8 am to 1 pm No work on Sundays or public holidays
Project Manager
Out of Hours works Any out of hourrsquos works will require a noise assessment and approval by Sydney Metro through the out of hourrsquos application (Appendix 7A)
Project Engineer Environmental Site Representative
Plant Equipment amp Vehicles
All operators of plant will comply with requirements of the Construction Traffic Management Plan in relation to parking and laydown access and egress to site haulage routes and general site traffic movements
Plant will be fitted with appropriate noise emissionvibration control equipment Plant will be fitted with adequate seat suspension
Plant Department
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 60 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Plant should be switched off when not in use wherever practicable Tasks using equipment that causes vibration to hands will be rotated at intervals to reduce
exposure Consideration may be given to the use of anti-vibration PPE All plant equipment and vehicles are to be regularly monitored and maintained and records kept
of maintenance Any abnormalities in expected noise or vibration emissions will be recorded in the plantrsquos log
book and reported to the plant department Prioritise the use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of
rockbreakers for demolition of structures Use of smaller capacity rockbreakers or lower vibration generating rockbreakers Consider methods of isolating the vibration sensitive structure from the vibration intensive work
area by severing the vibration transmission path using non-vibration intensive means such a sawing
Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Monitoring
Continuous vibration monitoring will be undertaken whenever vibration generating plant will be working close to or within the recommended minimum working distances
When conducting vibration monitoring within or near the minimum working distances a warning system will be implemented including one or both of an audible andor visual warning alarm andor SMS andor email alerts to site staff
Attended noise monitoring will occur at the nearest noise sensitive receiver when - Requested by Sydney Metro - When noise levels are predicted to exceed the NML by more than 10dBA - When out of hours works continue past midnight - When noise complaints are received
Noise monitoring will determine if the predictions in the noise assessment were accurate
Project Engineer Environmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for noise and vibration mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 61 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7A ndash Sydney Metro Out of Hours Application form
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 1 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Out of hours work application form
This form is to be used for formal review and approval of out of hours (OOH) work as it may affect Residential and non-residential receivers This form can be used in accordance with the SM-17-00005396 City amp Southwest out of hours work protocol Each OOH application and all applicable appendices must be submitted to Sydney Metro as one PDF file at least 15 business days prior to the commencement of the proposed OOH work
1 OOH Application
Sydney Metro Project
Eg City amp Southwest Greater West West etc
Contract
Contractor
Application Title
Eg lsquoSmith St service relocation worksrsquo
Application Number
Eg 1 2 3 etc
Application Date
Original submission date (resubmission date in parentheses if applicable)
Relevant Planning Approval
Environment Protection Licence (EPL)
If subject to an EPL state title and number
2 Proposed OOH Work Details
Description of works including
Work methodologies
List of plantequipment to be used (worst case scenario)
Location Map (andor Environmental Control Map) attached as Appendix 1 indicating location of works plantequipment locations and receivers (including distance to nearest receiver for noisiest plantequipment)
Traffic Management Plan andor Traffic Control Plan if applicable as Appendix 2
Timing of works
Including proposed datestimes works are planned to be undertaken outside standard hours
Worst-case number of consecutive occasions affecting the same receiver
Refer to Section 4 for definition of lsquooccasionrsquo
Justification
Demonstrate how the proposed OOH work has been scheduled in accordance with the OOH work period prioritisation list Program acceleration is generally not accepted as a justification
Unless specified otherwise in project-specific documentation the prioritisation of work time periods is as follows
Standard Hours 7am to 6pm weekdays and 8am to 1pm Saturdays (note that Standard Hours for works subject to the City amp Southwest Sydenham to Bankstown planning approval also include 1pm to 6pm Saturdays)
Daytime OOH 1pm to 6pm Saturdays and 8am to 6pm Sundays and Public Holidays
Evening OOH 6pm to 9pm every day
Night Time OOH 9pm to 7am weekday mornings and 9pm to 8am weekend and Public Holiday mornings
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Assessed Noise and Vibration Impacts and Standard Mitigation Measures
Are the proposed works consistent with a prepared Construction Noise amp Vibration Impact Statement (CNVIS) (YN)
If lsquoNrsquo skip this section and move to Section 4
State the title of the CNVIS and attach the section(s) describing the noise and vibration impacts of the proposed works as Appendix 3
Quantitatively summarise the worst-case predicted noise and vibration impacts specific to the proposed OOH work for each OOH period on the nearest receivers and compare these against the respective management levels
For Night Time OOH Period works include a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Worst-case predicted noise impact summary
Worst-case predicted vibration impact summary
Potential sleep disturbance summary (for night time OOH periods only)
Using Table 4 and Table 5 indicate in Table 6
Which Additional Mitigation Measures (AMMs) are applicable for consideration
Which of those applicable for consideration are planned to be implemented
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered respite alternative accommodation etc)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
4 Non-Assessed Noise and Vibration Impacts
Skip this section if Section 3 has been completed in full
A quantitative noise assessment for OOH work is to be carried out in accordance with the Interim Construction Noise Guideline (DECC 2009) This section allows applicants to address these requirements through the following steps
1) Establishing Rating Background Levels (RBLs) and Noise Management Levels (NMLs)
2) Predicting the anticipated noise levels using a quantitative noise assessment
a Works that are not likely to generate high noise impacts for a significant duration may use a preliminary quantitative noise assessment (facilitated within this form) This ensures that all applications as a minimum include a preliminary quantitative noise assessment in accordance with the Interim Construction Noise Guideline (ICNG)
b Works that are likely to generate high noise impacts for a significant duration may require a detailed quantitative noise assessment (eg Construction Noise and Vibration Impact Statement) to be undertaken
c Works that are likely to generate ground-borne or structure-borne vibration andor noise require specialist advice and assessment
3) Comparing predicted noise levels against RBLsNMLs and applying standard mitigation measures as appropriate (ie implementing lsquoall feasible and reasonablersquo mitigation measures in accordance with the ICNG)
4) Considering additional mitigation measures when predicted noise levels exceed RBLsNMLs
The need for a detailed quantitative noise and vibration assessment will be considered by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable) collectively when the predicted noise levels are anticipated to
Exceed an RBL at a residential receiver or an NML at a non-residential receiver by more than 10dBA AND
Affect the same receiver on 10 or more consecutive occasions An occasion is anytime works are carried out
o Between 6pm on a weekday and the start of standard hours the next day OR
o Between 1pm on a Saturday and 8am on a Sunday (or between 6pm on a Saturday and 8am on a Sunday for works subject to the Sydenham to Bankstown planning approval) OR
o Between 8am on a Sunday or public holiday and the start of standard hours the next day
A detailed quantitative noise and vibration assessment should generally include
Derivation of RBLs for residential receivers andor derivation of NMLs for non-residential receivers based on noise monitoring at representative locations and local sensitivities
Detailed noise predictions for daytime evening and night time OOH periods (as applicable) in accordance with Section 45 of the ICNG (including an outline of timing duration and predicted noise levels for each OOH period)
For Night Time OOH Period works a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Detailed predictions of vibration levels for sensitive receivers
Please complete the following Steps 1 to 4
Step 1
RBLsNMLs
If RBLs for residential receivers or NMLs for non-residential receivers have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment or Construction Noise and Vibration Impact Statement for other work activities) enter into Table 3 and attach the supporting evidence as Appendix 3
If no RBLsNMLs have been established use Table 1 to estimate and enter into Table 3
Step 2
Predicted Anticipated Noise Levels
If predicted anticipated noise levels have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment) enter the predicted anticipated noise levels into Table 3 and attach the supporting evidence as Appendix 3
If predicted anticipated noise levels have not already been established use Table 2 to estimate anticipated noise aspects for the noisiest plantequipment and enter into Table 3 In Table 3 use these values to calculate the anticipated predicted noise levels
Step 3
Exceedances and Mitigation Measures
Compare the anticipated predicted noise levels to the applicable RBLsNMLs calculate the exceedances and enter into Table 3 In Section 5 provide a description of the standard mitigation measures that are planned to be implemented in order to mitigate the noise impacts (and vibration impacts if relevant) as much as lsquofeasible and reasonablersquo in accordance with the ICNG
Step 4
Consideration of Additional Mitigation Measures
Use Table 4 and the exceedances in Table 3 to determine the applicable Additional Mitigation Measures for consideration Use
Table 6 to indicate which of these measures are applicable for consideration which will be implemented and provide justificationdetails accordingly
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
5 Standard Mitigation Measures
Outline the standard noise mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Outline the standard vibration mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Table 1 Noise RBLs and NMLs
Skip this section RBLs and NMLs have already been established in other documentation
Sensitive Receiver Category Estimated RBLs (dBA)
Residential Daytime OOH Evening OOH Night Time OOH
Urban (eg city hubs near busy roads near industrial activity) 55 50 45
Suburban 45 40 35
Quiet rural or isolated 40 35 30
Non-Residential ICNG NMLs (dBA)
Industrial facilities 75 (only applicable when in use)
Offices or retail 70 (only applicable when in use)
Health and educational facilities 55 (only applicable when in use)
Table 2 Predicted Noise Level Aspects
Skip this section if predicted noise levels have already been established in other documentation
Noise Aspect Select the most applicable value for each noise aspect below and enter into Table 3 dBA
1 PlantEquipment Noise Level at 10m
Including non-continuous use reduction (-5dBA) and annoying activity penalty (+5dBA) for as per ICNG (refer to ICNG Appendix B for predicted noise level data)
Underline indicates vibratory generating plantequipment
Impact sheet piling rig 100
Hand-held tamper excavator with hammer rock-breaker drivenvibratory piling concrete saw diamond saw air track drill large dozer hand-held rail grinder
95
Jackhammer rock crusher angle grinder pneumatic hammer medium dozer tracked loader impact wrench
90
Mainline tamper ballast regulator dynamic track stabiliser vibratory roller mainline rail grinder ballast train (pourfill ballast) chainsaw tub grinderlarge mulcher scraper grader super-suckervacuum truck large backhoewheeled front-end loader bored piling pavement profiler fixed crane tracked excavator
85
Small bulldozer small excavator tower crane truck-mounted crane forklift bobcat skid-steer front-end loader road trucktruck and dog dump truck concrete truckpumpmixer compressor non-vibratorylarge pad foot roller whacker packercompactor water cart pavement laying machine asphalt truck and sprayer line marking truck standard penetration testing welder pin puller
80
Concrete vibrator cherry-picker scissor liftelevated work platformFranna crane small backhoe front end loader fence post driver electric drill rig hand held rattle gun generator (dieselpetrol) spreader
75
Lighting tower medium-rigid trucksemi-trailer welding equipment small front end loader 70
Light vehicle hand-tools (no impact) small cement mixer attenuated generator (inside housing)
65
2 Multiple Plant More than one of the noisiest plant being used simultaneously at roughly the same location +5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Local Screening
Existing screening between site and receiver (buildings cuttings canopies etc) - 5
Temporary screening to be implemented near work site - 10
Acoustic shed or enclosure - 25
4 Distance Attenuation
lt 10 metres 0
10 to 20 metres - 5
20 to 35 metres - 10
35 to 60 metres - 15
60 to 100 metres - 20
100 to 180 metres - 25
180 to 350 metres - 30
350 to 1000 metres - 40
Table 3 Predicted Noise Levels and Exceedances of RBLs andor NMLs (dBA)
Skip this section if Section 3 has been completed in full
Period
(only complete as applicable for each period)
Noisiest PlantEquipm
ent
(state the noisiest
plantequipment to be used during each applicable
OOH period)
Receiver Type
(state lsquoResrsquo or lsquoNon-Resrsquo as applicable for
closest receiver to noisiest
plantequipment)
Enter the most applicable values from Table 2 then add to determine
the Predicted Noise Level
Pre
dic
ted
No
ise L
evel
(1 +
2 +
3 +
4)
RB
L (
for
Res)
NM
L (
for
Non-R
es)
Exceedance
(Predicted Noise Level minus RBL for Res or NML for
Non-Res) 1
Pla
nt
Eq
uip
me
nt
No
ise L
evel
2
Mu
ltip
le
Pla
nt
Eq
uip
me
nt
3
Lo
cal
Scre
en
ing
4
Dis
tan
ce
Att
en
ua
tio
n
Daytime OOH
Evening OOH
Night Time OOH
Refer to OOH period timings under Section 2 of this form
Table 4 Additional Mitigation Measures (AMM) requiring Consideration for Implementation
OOH Period
AMMs that must be considered for implementation
(apply the exceedances from Table 3 to the two OOH period categories below as applicable)
lt= 10 dBA Exceedance
10 to lt= 20 dBA Exceedance
20 to lt= 30 dBA Exceedance
gt 30 dBA Exceedance
Daytime OOH Period ndash LB M LB M IB LB PC RO SN
Evening and Night Time OOH Periods
ndash M LB M IB LB PC SN RO M IB LB PC SN RO AA
AA is only applicable to Night Time OOH periods
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 5 List of Additional Mitigation Measures (AMM)
AMM Abbrev
AMM AMM Descriptions and Guidance
LB
Letterbox-drop
(generic to the project)
A newsletter is generally produced and distributed to the local community via letterbox-drop and the project mailing list These newsletters provide an overview of current and upcoming works across the project and other topics of interest The objective is to engage inform and provide project-specific messages The geographic extent of letterbox-drops is generally centred on the immediate surrounding community within 200 metres from the works site
For works that are subject to the Sydenham to Bankstown planning approval these will include an indicative schedule of likely OOH work for at least the upcoming two month period
M Monitoring
Where it has been identified that specific construction activities are likely to exceed the relevant Rating Background Levels (RBL) andor Noise Management Levels (NMLs) monitoring may be conducted at the affected receiver(s) or a nominated representative location (typically the nearest receiver where more than one receiver have been identified) Monitoring can be in the form of either unattended logging or operator attended surveys The purpose of monitoring is to inform the relevant personnel when the RBLNML has been exceeded so that additional management measures may be implemented
IB Individual Briefings
Individual briefings are used to inform stakeholders about the impacts of high noise activities and mitigation measures that will be implemented Communications representatives would visit identified stakeholders at least 48 hours ahead of potentially disturbing construction activities Individual briefings provide affected stakeholders with personalised contact and tailored advice with the opportunity to comment on the project
PC Phone calls
(andor emails)
Phone calls andor emails (with specific notifications attached) detailing relevant information would be made to identifiedaffected stakeholders within seven days of proposed work The objective of the phone calls andor emails is to support letterbox-drop and specific notifications Phone calls andor emails provide affected stakeholders with personalised contact and tailored advice with the opportunity to provide comments on the proposed work and specific needs
SN
Specific Notifications
(specific to the OOH work)
Specific notifications are letterbox-dropped to identified stakeholders no later than 7 days prior to out of hour construction activities commencing that are likely to exceed the RBLsNMLs Specific notifications may be produced by Sydney Trains or by Sydney Metro (or on behalf of Sydney Metro by a contractor as approved by Sydney Metro)
- Sydney Trains specific notifications cover all works being undertaken by various parties (including Sydney Metro) during designated rail possession periods These specific notifications are delivered 14 days prior to works commencing and are delivered to all properties located within 250m of the proposed works
- Sydney Metro specific notifications focus on proposed Sydney Metro works being undertaken outside of designated rail possession periods and are only produced in the absence of any Sydney Trains notifications covering the proposed works These notifications are delivered 7 days prior to works commencing and are delivered to all properties located within 100m of day works and within 200m of night works
All notifications are emailed to all registered stakeholders on site-specific email distribution lists
For works that are subject to the Sydenham to Bankstown planning approval these will include indicative information on the type of OOH work location duration expected noise characteristics expected noise level and likely mitigation and management measures
RO Respite Offer
The purpose of a project specific respite offer is to provide residents subjected to lengthy periods of noise andor vibration impacts respite during OOH periods Respite offers are offers made to affected receivers to provide a period of either no or limited noise impacts This can be in the form of stopping or limiting works onsite or offering affected receivers dinnermovie vouchers The first priority is to implement a period of no or limited noise impacts If this cannot be achieved dinnermovie vouchers may be offered on a case-by-case basis
AA Alternative
Accommodation (residential only)
Alternative accommodation options may be provided for residents living in close proximity to construction works that are likely to incur unreasonably high impacts during night time OOH periods Alternative accommodation will be considered on a case-by-case basis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 6 Consideration of Additional Mitigation Measures (AMM)
Additional Mitigation Measures
Applicable for Consideration
YN
(refer to Table 4)
To be Implemented
YN
JustificationDetails
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered RO AA etc)
LB
M
IB
PC
SN
RO
AA
For OOH work that is subject to the Sydenham to Bankstown approval and RO is required for consideration include in the lsquoJustificationCommentsrsquo column how community consultation influenced the decision to implement or not implement RO in accordance with Condition E23 If RO is being implemented include how community consultation influenced the manner in which RO is being implemented
6 Consideration Against Relevant Vibration Criteria
Using Table 2 indicate whether any vibratory plantequipment is planned to be used for the proposed works (YN)
If lsquoNrsquo skip this section and move to Section 7
lsquoPeoplersquo Criterion
Are the proposed works anticipated to have any perceptible sleep disturbance impacts (YN)
lsquoStructuresrsquo Criterion
Are the proposed works anticipated to generate greater than 75mms vibration impacts on surrounding structures (generally within 25 metres of works) (YN)
lsquoSensitive Equipmentrsquo Criterion
Are the proposed works anticipated to impact sensitive equipment located in surrounding non-residential receivers (YN)
If lsquoYrsquo is answered to ANY of the above criteria AND the impacts affect the same receiver for more than one consecutive occasion (refer to Section 4 for lsquooccasionrsquo definition) the need to prepare a detailed quantitative assessment will be considered collectively by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
7 City amp Southwest Construction Noise amp Vibration Strategy Addendum Mitigation Measures
If the proposed OOH work is part of the City amp Southwest project identify any mitigation measures to be implemented that have arisen from the City amp Southwest Construction Noise amp Vibration Strategy Addendum
8 Cumulative Impacts
Document the relevant details of any other OOH work (Sydney Metro or otherwise) that will impact the same receivers as those being impacted by these proposed works either concurrently or within 3 days of the start or end of these proposed works
If other works have been identified in the row above how have the proposed works been coordinated to ensure appropriate respite is provided
9 Community Consultation
What community consultation has been undertaken already
What community consultation is planned to be undertaken
If drafted already attach applicable Community Notification as Appendix 4
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
10 Contractorrsquos Signature
Contractorrsquos Identification of Risk Level
If subject to the Chatswood to Sydenham (C2S) or Sydenham to Bankstown (S2B) planning approval and not subject to an EPL provide Contractorrsquos Identification of Risk Level (refer to the City amp Southwest OOH Works StrategyProtocol for guidance)
Circle LOW or HIGH
Contractorrsquos Signature
Name
Title
Contact Number
Date
11 Contractorrsquos Contact Details
Contractor Personnel Name Mobile
Manager Environment
Manager Communications
Contractorrsquos Representative
Contractorrsquos 24hr contact person
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
C2SS2B Planning Approval Determination Page
Step 1 ndash Endorsement from Sydney Metro Director Public
Communications or Contractorrsquos Communications Manager
Step 2 ndash Risk IdentificationEndorsement from the AA under the C2S Planning Approval or from the
ER under the S2B Planning Approval
Step 3 ndash If works are under Sydney Trains EPL approval from Sydney Metro Director of Planning Environment and Sustainability
If works are not under an EPL approval from either the ER or the Secretary of the NSW Department of Planning amp Environment
Risk Level NA
If not subject to an EPL circle Risk Level as LOW or HIGH
If works are HIGH Risk Level and after 9pm Sydney Metro submits application to the Secretary of the
NSW Department of Planning amp Environment for approval
NA
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Role
Date
Comments
(including AAER Risk Level comments if applicable)
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Generic Determination Page (ie not subject to C2S or S2B planning approvals)
Step 1 ndash Sydney Metro Director of
Project Communications
Step 2 ndash Acoustic Advisor
(may be optional depending on planning approval or contract requirements)
Step 3 ndash Environmental Representative
(may be optional depending on planning approval or contract requirements)
Step 4 ndashSydney Metro Director of Planning Environment amp Sustainability
(only required if not approved already)
Action Endorsement Circle Endorsement or Approval Circle Endorsement or Approval Approval
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Date
Comments
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 12 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 1 Location Map (andor Environmental Control Map)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 13 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 2 Traffic Management Plan andor Traffic Control Plan
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 3 Supporting Evidence for Noise amp Vibration Impacts (eg Construction Noise amp Vibration Impact Statement noise assessment etc)
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 15 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 4 Community Notification
(if applicable and already drafted)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Any site contamination will be effectively managed to limit the potential risk to human health and the environment Spoil will be managed to avoid contamination of land or water Prioritise reuse of contaminated spoil into the project rather than offsite reuse or disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Planning and assessment
Planning
The Golders Douglas Partners contamination assessment report (June 2020) considered investigation results and data from previous relevant Sydney Metro West (SMW) investigations in the general area The physical characteristics of the soil on site as determined by the above report is described as ldquofill material described as containing evidence of anthropogenic materials including ash gravels terracotta tile fragments bricks and glass In addition to this sandstone bedrock was regularly encounteredsuspected to be present (eg drilling method refusal) during the pavement investigation This evidence implies that there is a wide variety of soil types and materials across the Site associated with natural and historical anthropogenic related activities The findings included elevated concentrations of heavy metals (copper nickel zinc) encountered at one location on the Site and several within close proximity to the Site However the exceedances were considered to pose a low risk to ecological receptors given that the majority of the Site is covered in asphalt hardstand with very low potential for exposure to subsurface soils Elevated concentrations of BaP were encountered in several boreholes within close proximity to the Site Once again the risks to ecological receptors from these were considered low due to the presence of asphalt hardstand at the Site Asbestos was identified at one borehole SMW_BH415 at a depth of 05 m The laboratory reported that chrysotile was detected below the reporting limit of 01 gkg The report considered due to the location access nature of the ACM (bonded) that there is a low risk of exposure to potential receptors Should the soil not be able to be reused on site further sampling assessment and waste classification must occur for any soil that is to be disposed offsite in accordance with the Sydney Metro Waste Classification Procedure (Appendix 1A)
Project Manager HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Unexpected finds of contamination onsite
In the event that contamination is identified on site Appendix 8A will be followed for soil contamination excluding Asbestos material For unexpected Asbestos Finds Appendix 8B will be followed
Supervisors All workers
Assessment
If any potential contamination is discovered during construction the soil will be excavated and transported to the stockpile area for assessment which may include sampling by a suitably qualified environmental consultant
The assessment must consider whether the material is suitable to return to site for reuse with consideration to the final land use and pathways and receptors for the contaminants
Laboratory testing associated with the assessment will be prioritised to 24 hour turnaround to mitigate any delay where required
The assessment detailing the type extent and management options for the contaminated soil must be provided to Sydney Metro before proceeding to either reuse or dispose of material
For unexpected Asbestos finds the controls listed in the section below must be followed before any excavation and transport to stockpile or offsite
Project Manager Supervisor Environmental scientist
Asbestos management measures
Access Restrictions
Signs and barriers will be erected to warn of the danger and to prevent unauthorised people entering areas where asbestos contaminated fill material is being excavated handled
The location and extent of any access control areas will be agreed in discussion between the Project Manager Project Engineer HSE Advisor and the Environmental Coordinator and will be established in accordance with NOHSC2002 (2005) Code of Practice for the Safe Removal of Asbestos (2nd Ed) guidelines
Potential entry points to the asbestos work area should be signposted or labelled in accordance with AS 1319 (1994) Safety Signs for the Occupational Environment and NOHSC 2002 (2005b)
Earthworks Engineers Licenced removal contractor Supervisors
Asbestos Removal
For unexpected Asbestos finds the Certified Occupational Hygienist will conduct a risk assessment to demine Air monitoring requirements and any other PPE and management controls prior to removal (see air monitoring section)
All removal procedures for asbestos should be undertaken under the supervision of an appropriately licensed contractor which is either ASA or ASB depending on the material being removed The removal of material shall be monitored by a relevantly trained supervisor in accordance with the Code of Practice for the Safe Removal of Asbestos [NOHSC 2002 (2011)]
You must be licensed to remove asbestos except if removing 10 square metres or less of non-friable asbestos
Engineers Certified Occupational Hygienist Licenced removal contractor
Workcover notification Permit to Work
A permit to work authority will need to be issued to and signed by the contractor Workers engaged in the removal of asbestos on site will not be issued with a permit to work unless
Engineers Licenced removal contractor
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
they are employed by a company holding a removal licence issued by WorkCover NSW appropriate for the type of asbestos materials concerned
Workcover must be notified at least five days prior to commencement of asbestos removal work
Safe Work Method Statement and Asbestos Removal Plan
All notification and permit applications for removal of asbestos in soils must be accompanied by a site risk assessment (Asbestos Removal Plan) carried out by a competent or licensed person who determines If the asbestos is bonded or friable The extent of contamination A safe work procedure for the remediation of the site
Engineers Licenced removal contractor
Dust Control
In order to remove the asbestos safely we shall be using the ldquowet methodrdquo to carry out these works The wet method includes continuously keeping the soil with asbestos fragments watered so as to eliminate the asbestos dustfibres becoming airborne An exclusion zone of 10m (or whatrsquos appropriate ndash depending on limitations) will be isolated from the rest of the site using fencing or bunting Any personnel that do not have the correct PPE or relevant training will not be allowed in this area
Supervisors Earthworks Engineers
Clearance
Following the excavation and removal of asbestos contaminated material a licenced asbestos assessor will conduct inspections and sampling (where required) in the excavation to confirm that no asbestos remains A clearance report will be issued and works can recommence in the area
Licenced Asbestos Assessor
All potential contaminated finds
Training
A toolbox must occur for all worker for unexpected contamination finds procedure They will also be informed of the Site specific controls required for management of contamination in soil Site access restrictions Correct use of PPE Decontamination procedures Use of monitoring equipment Waste handling procedures Dust control measures and performance measures
all workers
Stockpile Contingency Measures
The following contingency measures will be put in place should stockpiling of potential contaminated soils be required All potential contaminated stockpiles will be separated by lot numbers and sign posted to
avoid any cross contamination Any temporary stockpiles of asbestos contaminated soil will be maintained under moist
conditions and remain covered at all times Sediment controls will be installed downslope of all contaminated soil stockpiles In order to confirm that all contaminated soil has been removed an Environmental
Consultant (ADE) will conduct a visual inspection or sampling of the material below the
Supervisors Earthworks Engineers
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
stockpile and provide a clearance certificate or the like as legislated The Environmental Consultant will advise of the validation criteria dependant on the contamination of the soil
Material tracking for contaminated finds assessed as suitable for onsite reuse
Where suspected contaminated material is identified the material will be tracked from the area in which the material was identified to its location in stockpile (lot number)
For all material assessed as suitable for reuse onsite the material will be tracked from its stockpile location to final destination for reuse onsite Survey will determine the m3 and the location of the final destination
All materials movements associated with unexpected contamination finds will be recorded on the materials tracking register
Supervisors Earthworks Engineers
Waste classification for materials assessed unsuitable for onsite reuse
Waste classifications are required for any excavated soil or fill material which is to be disposed off-site Soil or fill material to be taken off-site for disposal shall be assessed in accordance with the waste classification guidelines (NSW EPA 2014) Materials excavated from the site should be tracked from lsquocradle to graversquo in order to provide detailed and accurate information about the location and quantity of all materials from the time of their excavation until their disposal For any truck or bin leaving the site the following information would be recorded origin of material material type waste classification report approximate volume truck andor bin registration number Receiving licenced facility For all soils known or having the potential to contain asbestos the following applies The POEO Act defines lsquoasbestos wastersquo as any waste that contains asbestos including
fragments or fibres It is understood that as a result the NSW EPA considers asbestos contaminated soil to be an asbestos waste In addition the Protection of the Environment Operations (Waste) Regulation 2014 provides certain requirements for the transportation of asbestos It is understood that the NSW EPA requires any management of soil containing asbestos waste on or off the site to be at least equal to controls set out by the Regulation
All asbestos contaminated soil or fill leaving site will be transported in a leak proof covered vehicle and disposed of at a licensed facility in accordance with waste classification guidelines (NSW EPA 2014)
Earthworks Engineers Licenced removal contractor ESR
Environmental Monitoring amp records
Air Monitoring
If asbestos removal work that requires a Class A licence that means it is friable then you must get the licensed asbestos assessor occupational Hygienist to undertake air monitoring of the asbestos removal area Monitoring for airborne asbestos in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres
Earthworks Engineers Licenced removal contractor Hygienist
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
[NOHSC 3003(2005)] the analysis should be carried out by a NATA accredited laboratory during the removal operations Refer to Clause 50 and 51 for the WorkCover 2011 Safety Regulation for requirements
For other contaminated soil the occupational hygienist may determine that the risks associated with their disturbance and handling requires air monitoring
Record Keeping
The records associated with management of contaminated land that should be kept include Material tracking register including lots volume and type Asbestos Removal Plan (ARP) Asbestos Register Airborne Monitoring Reports Calibration certificates for air monitors Clearance Inspection Reports or Certificates Waste classification reports Laboratory sampling results Landfill disposal dockets
Earthworks Engineers ESR HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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Appendix 8A ndash Unexpected Contamination finds procedure
1 Introduction
The following unexpected contaminated finds procedure will be adopted in the event that potential contamination
is discovered during construction Implementation of this procedure will ensure that contamination is managed in
such a way as to avoid harm to the environment workers community and comply with relevant legislation
2 Identification of Contamination
An unexpected find of contamination is likely to comprise of any soil characteristic which is not a typical soil
material identified in previous contamination assessment reports The Golders Douglas Partners contamination
assessment report (June 2020) section 102 makes note of indicators of contamination as
Significant staining
Odours from Soils
Oily sheen on water leaving soils
Anthropogenic waste materials other than those identified in the report (ie Ash Gravels Terracotta Tile
Bricks and Glass)
Where the soil characteristics are consistent with the reports and the above indicators are not present then no
further assessment is required for onsite reuse
Examples of these indicators are shown below
Photo 1 - Significant Staining or odorous soils
Discoloured soil (soil with non-natural colouring) Pungent smelling soils - petroleum compost
putrefied sulphurous septic sweet aromatic odours
Photo 2 ndash Oily Sheen on water
Rainbow sheen on water surfaces in soil
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CEMP Bays Road Relocation Works
Photo 3 ndash Buried wastes
Buried oil drums chemical container
Photo 3 ndash Buried wastes
Buried demolition wastes (eg concrete tiles bricks asphalt timber metal
3 Potential risk areas of unexpected finds
The higher risk activities for encountering unexpected finds during construction activities are considered to be
excavation works that extend below road pavement layers and into general fill
Higher risk areas for encountering unexpected finds construction are considered to be
Areas of excavation that extend through general fill layers and into natural soils eg Stormwater trench
locations
Locations of excavation near previous Boreholes with identified contamination (see map below)
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CEMP Bays Road Relocation Works
4 Unexpected finds flow chart
If potentially contaminated soils are encountered the following steps must be followed
During excavationif visual indications of contamination are present such as significant stained soils
odorous soils sheen tarry or ashy material or unexpected anthropogenic material (other than what is
expected to be encountered on site) then
STOP EXCAVATION in the immediate affected area
Notify the Supervisor Environmental Site Rep and Client
Environmental consultant to conduct assessment on material to determine suitability for reuse onsite This
step may require sampling and lab analysis ndash undertake with quick 24hr turnaround
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No Yes
Sample test and classify in
accordance with Appendix
1A ndash Sydney Metro Waste
Classification procedure
Contact environmental consultant and hygienist and provide details of the find Depending on the nature and type
of the find they may be required to attend site before any further excavation disturbance
Excavate the material to the extent of the potential contamination in 200mm thick layers and in 500mm
horizontal increments (Do not exceed design excavation extents) and move to stockpile area (Where it will be
allocated a lot number and signposted to avoid any cross contamination) For Asbestos follow specific
requirements in the unexpected Asbestos Finds Procedure Cover the stockpile and install controls around the
stockpile
Offsite disposal at licenced
landfill facility Maintain all
waste tracking and disposal
records
No
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CEMP Bays Road Relocation Works
5 Materials Tracking
A Material tracking Register will be used to ensure information is collected for unexpected finds materials
identification and traceability This register records all unexpected finds materials The material is carefully
inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location and type of soil stored onsite
at the stockpile area The material class and stockpile number on the map will correspond with the information in
the register
6 Stockpile Management
The following contingency measures will be put in place should stockpiling of suspected contaminated soils be
required
All suspected contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Sediment controls will be installed downslope of all suspected contaminated soil stockpiles
7 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential contamination onsite as detailed in previous contamination assessment reports and this unexpected finds
procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works
Prior to commencement of each shift the Supervisor will inform all site personnel of any works involving
contaminated materials on site
8 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 8B ndash Unexpected Asbestos finds procedure
1 Introduction
The following Asbestos Management procedure will be adopted in the event that potential asbestos containing
material (ACM) or actual asbestos is uncovered during construction Implementation of this procedure will ensure
that asbestos is managed in such a way as to avoid harm to site personnel visitors and the community
2 Areas of known asbestos contamination
No asbestos was identified with the footprint of the proposed road construction works However there was one
Borehole (BH 415) from previous contamination assessments adjacent to the boundary that identified asbestos at
05m bgs The laboratory result was chrysotile detected below the reporting limit of 01 gkg (see location on map
below)
3 Identification of Asbestos
Asbestos has been used in the manufacturing of various products and these products can be found in either friable
or non-friable form All products are also known as asbestos-containing material Friable asbestos products are
generally quite loose and when dry can be crumbled into fine material or dust with light pressure such as
crushing with your hand
Non-friable asbestos products are made from a bonding compound (such as cement) mixed with a small proportion
(usually less than 15) of asbestos Non-friable asbestos products are solid rigid and non-friable and cannot be
crumbled pulverised or reduced to powder by hand pressure The asbestos fibres are tightly bound in the product
and are not normally released into the air When theyre in good condition non-friable asbestos products do not
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
normally release any asbestos fibres into the air They are considered a very low risk for people who are in contact
with them as long as appropriate safety precautions are used when they are disturbed Non-friable asbestos
products that have been damaged or badly weathered may also become friable for example crushed asbestos
cement sheeting Examples of non-friable and friable asbestos are shown below
Photo 1 ndash example of non-friable asbestos in soil This is Asbestos cement sheeting that although broken it is solid rigid and cannot be crumbled or pulverised by hand pressure
Photo 2 ndash example of friable asbestos ndash this was a section of Asbestos cement sheeting that is weathered and crumbles under hand pressure
Photo 3 ndash example of non - friable asbestos ndash Asbestos cement water pipe in good condition
Photo 4 ndash example of friable asbestos ndash water pipe wrapped with friable woven ACM textile
4 Unexpected Asbestos ACM finds flow chart
In the event that a person on site identifies or disturbs asbestos ACM the unexpected asbestos management
procedure during Construction is summarised below
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Discovery of suspected asbestos containing materials
STOP EXCAVATION in the immediate affected area Demarcate and isolate area from workers
Notify the Supervisor
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next
step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No
Sample test and classify
in accordance with
Appendix 1A ndash Sydney
Metro Waste Classification
procedure
Yes
Friable Non Friable
Proceed with Licenced
Asbestos removal work in
accordance with section 6 -
11 Remove to stockpile for
reuse assessment by
Environmental Consultant
No
Greater than
10m2 of non-
friable asbestos
contamination
Less than 10m2 of
non-friable
asbestos
contamination
Proceed with non-
licenced asbestos
removal and
disposal in
accordance with
section 5
Trained and competent person to identify the asbestos
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CEMP Bays Road Relocation Works
5 Non Licence Asbestos removal work
Where small fragments of ACM or suspected ACM are found and provided that
the total number of fragments is lt 20 or
the total surface area of the fragmentpiece is lt 1 m2 or
the fragments are spread over an area of lt 10 m2 and
the fragments are non-friable
If the unexpected find meets the criteria above a trained and competent person will collect any fragments and
place it in a 200 mm polythene bag for later disposal at an appropriate waste facility A detailed visual inspection
of the area will be carried out by the Environmental consultant which will involve wet raking of the areas to a
depth of 10 cm for any further fragments If no further fragments are identified works can continue
If during the visual inspection the Environmental consultant determines that the criteria described above are
exceeded or if suspected asbestos ACM continues to be identified during excavation works andor if it is thought
that any uncovered material might be considered asbestos containing and friable works will cease and the
Environmental consultant will assess the situation and determine an appropriate course of action
6 Licenced Asbestos removal work
A licensed asbestos removalist will be required for removal works where there is friable asbestos or the
contaminated area is greater than 10 m2 There are two types of asbestos removal licences Class A and Class B
The type of licence required depends on the type and quantity of asbestos or ACM to be removed as outlined
below
Licence type What asbestos can be removed
Class A Can remove any amount or quantity of asbestos or ACM including any amount of friable asbestos or ACM any amount of asbestos-contaminated dust or debris (ACD) Any amount of non-friable asbestos or ACM
Class B Can remove
any amount of non-friable asbestos or ACM Note A Class B licence is required for removal of more than 10 m2
of non-friable asbestos or ACM but the licence holder can also remove up to 10 m2 of non-friable asbestos or ACM
ACD associated with the removal of non-friable asbestos or ACM Note A Class B licence is required for removal of ACD associated
with the removal of more than 10 msup2 of non-friable asbestos or ACM but the licence holder can also remove ACD associated with removal of up to 10msup2 of non-friable asbestos or ACM
No licence required Can remove
up to 10 m2 of non-friable asbestos or ACM ACD that is associated with the removal of less than 10 m2 of non-friable
asbestos or ACM Not associated with the removal of friable or non-friable asbestos
and is only a minor contamination
The licensed asbestos removalist will prepare an Asbestos Removal Control Plan prior to the removal of any
asbestos ACM The Asbestos Removal Control Plan documents the specific control measures to be implemented to
ensure site personnel and others are not at risk when asbestos removal work is being conducted It includes how
the asbestos removal will be carried out including temporary storage the method tools equipment and PPE to be
used and the asbestos ACM to be removed including the location type and condition of the asbestos ACM
The Client will be informed prior to excavation or removal of asbestos or ACM If the removal activity is to occur in
the vicinity of any occupied residence or business the project Community Advisor will notify the affected
residents or business owners
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7 Signage and demarcation
Georgiou will install warning signs and labels to clearly identify asbestos affected areas and where asbestos related
work is being carried out Flagging will be installed to delineate the asbestos related areas and restrict
unauthorised persons from entering the asbestos removal work Stockpiles will be covered and labelled Signage
and flagging will stay in place until all licensed asbestos removal work is complete and a clearance certificate is
provided
8 Notification
Prior to the commencement of licensed asbestos removal works notification to SafeWork NSW is required
SafeWork NSW requires a minimum of 5 daysrsquo notice prior to the removal of asbestos and the notification will be
made by the licensed asbestos removalist
9 Air Monitoring
All air monitoring requirements will be determined and conducted by a licensed asbestos assessor (LAA) The
location and layout of the air monitors will be detailed within the Asbestos Removal Control Plan
Air monitoring requirements will vary depending on the type of asbestos being removed the location and position
of the asbestos The following rules should be applied when determine if air monitoring is required (extract from
Safe Work Australia ndash Code of Practice on How to Safely Remove Asbestos (2016)
For friable asbestos removal ndash Air monitoring is mandatory for all friable asbestos removal This includes prior
to dismantling an enclosure and for the purposes of the clearance inspection
For more than 10 msup2 of non-friable asbestos removal ndash Air monitoring is not required but may be considered to
be carried out by a licensed asbestos assessor or competent person to ensure compliance with the duty to
eliminate or minimise exposure to airborne asbestos and to ensure the exposure standard is not exceeded
Public Location ndash Air monitoring should be considered where the asbestos removal work is being undertaken in
or next to a public location
Exposure air monitoring ndash Air monitoring should be carried out at other times to determine a workerrsquos exposure
to airborne asbestos if based on reasonable grounds there is uncertainty as to whether the exposure standard
may be exceeded and a risk assessment by a competent person indicates it is necessary Since most uses of
asbestos are prohibited exposure monitoring should not be required frequently
The results of air monitoring will be made available as soon as possible to all workers on site The asbestos
supervisor will be notified immediately if the fibre count exceeds the recommended level in the Exposure
Standards for Asbestos as set out in the National Code of Practice How to safely remove asbestos
10 Clearance
Following removal of asbestos ACM the licensed asbestos removalist will arrange for a clearance inspection of the
area to facilitate the issue of a clearance certificate and allow construction to recommence in the affected area
The clearance inspection is conducted by
an independent licensed asbestos assessor for work that was carried out by a Class A licensed asbestos
removalist
an independent competent person for asbestos work that is not required to be carried out by a Class A licensed
asbestos removalist
To be independent the licensed asbestos assessor must not be involved in the removal of asbestos for that specific
job and is not involved in a business or undertaking involved in the removal of the asbestos for that specific job
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A clearance certificate will be issued if the independent licensed asbestos assessor or competent person is satisfied
that the asbestos removal area and the immediate area are free from visible asbestos contamination Entry to the
area will be permitted following confirmation of certification
11 Decontamination
Decontamination of site personnel PPE and tools used in asbestos removal work will minimise exposure and spread
of asbestos outside of the removal area
Personal decontamination will occur every time a worker leaves the asbestos removal work area and involves
removal of all visible asbestos dustresidue from PPE and Respiratory Protective Equipment using an asbestos
vacuum cleaner and or wet wiping with a damp cloth Disposable PPE is considered asbestos waste and will be
disposed of at an appropriate waste facility Non-disposable protective clothing will be laundered in a suitable
laundering facility that is equipped to launder asbestos-contaminated clothing
Workers must be aware of personal hygiene and ensure that they carefully wash when leaving an asbestos removal
area paying particular attention to hands fingernails face and head
Tools will be dismantled (where appropriate) cleaned under controlled conditions and decontaminated prior to
removal from the area or disposed of at a suitable off site location
12 Stockpile Management
The following contingency measures will be put in place for any temporary stockpiling of asbestos contaminated
soils
All asbestos contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Any temporary stockpiles of asbestos contaminated soil will be maintained under moist conditions and remain
covered at all times
Sediment controls will be installed downslope of all contaminated soil stockpiles
In order to confirm that all contaminated soil has been removed validation sampling beneath stockpiles will
occur by an Environmental Consultant
13 Asbestos contaminated soil for reuse onsite
Stockpiled asbestos containing soils will be assessed for beneficial re-use with the Site (NEPC 2013) Any soils
identified to contain asbestos with concentrations of bonded ACM less than the NEPC (2013) Health Screening Level
(HSL)-D applicable for the future commercial industrial land use could be reused onsite providing the following
Placement in a designated location preferably beneath a road alignment or other suitably capped area (min
300 mm lsquocleanrsquo (ie ENMVENM soils) to eliminate any potential airborne exposure pathway
Occupational hygienist and asbestos removalists on-site supervising relocation and placement
Maintenance of an Site Asbestos Register to record the extent nature of the ACM materials retained or
identified on-site
Any other requirements by Sydney Metro such as adherence to the CEMP etc and or land conditions
A Long-term Environmental Management Plan to manage the presence of asbestos impacted materials remaining
on-site would be required if the proposed soils to be re-used are exceeding the HSL-D limits for non-friable or
friable asbestos
If stockpiled soils are identified to contain any detectable concentrations of Friable asbestos material is
recommended to be disposed off-site given its friable nature
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14 Waste disposal
Where the ACM is assessed as non-suitable for onsite reuse the licensed asbestos removalist will classify and dispose
of the ACM at a licensed asbestos waste disposal site in accordance with NSW EPA guidelines (including Waste
Classification Guidelines (EPA 2014)) and relevant industry codes of practice
Disposal of ACM will be to an approved asbestos waste facility listed on the NSW EPA website The transportation of
asbestos waste by trucks must comply with the following requirements
Transporter must have the appropriate EPA license to transport asbestos waste
Asbestos contaminated soils are wetted down
Any part of any vehicle in which a person transports asbestos waste is covered and leak proof during
transportation
Georgiou will notify the Client prior to removal of ACM from site and will provide details of the proposed method
and location of disposal Georgiou will maintain records of all asbestos ACM disposed off site the location of the
facility at which it was disposed and any receiptcertificate issued by the facilitydisposal authority
15 Materials Tracking
A Material tracking Register will be used to ensure information is collected for the movement of all asbestos
contaminated soils The material is carefully inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
and testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location of asbestos contaminated soil
stored onsite at the stockpile area The stockpile number on the map will correspond with the information in the
register
16 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential risks associated with asbestos management locations of asbestos as detailed in previous contamination
assessment reports and this unexpected finds procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works and include the unexpected asbestos finds procedure Prior to commencement of each shift the Supervisor
will inform all site personnel of any works involving contaminated materials on site
17 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure
Unclassified
Unclassified
Environmental Incident and Non-
compliance Reporting Procedure SM-17-00000096
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Manager Environment
System Owner Executive Director Safety Sustainability amp Environment
Status FINAL
Version 51
Date of issue 18 February 2019
Review date 11 February 2020
copy Sydney Metro 2019
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table of contents 1 Purpose and scope 4
2 Introduction 4
3 Definitions 4
4 Accountabilities 5
5 Environmental Events 5
51 Worked Example ndash Classifying Environmental Events 7
511 Soil and Water Issue 7
512 Soil and Water Non-compliance 7
513 Soil and Water Incident 7
52 Notifiable Events 8
53 Event Types 8
6 Environmental Incident Classification and Management 10
61 Incident Classification 11
611 Class 3 Incidents 11
612 Class 2 Incidents 11
613 Class 1 Incidents 12
62 Incident Notification 12
621 Principalrsquos Representative (PR) 12
622 Environmental Lead (EL) 13
63 Incident Notification Reports 14
64 Incident Investigations 14
65 Environmental Incidents with Health and Safety Impacts 14
66 Reporting Pollution Incidents to Relevant Authorities 15
661 Maritime Related Incident Notification and Reporting 16
67 Environmental Compliance Register 16
7 Environmental Non-compliance 17
71 Non-compliance Rate 17
8 Corrective and Preventative Actions 18
81 Action Status 18
9 Related Documents and References 19
10 Superseded Documents 19
11 Document History 19
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Figures Figure 1 Environmental Event Classification Process 6 Figure 2 Environment Incident notification process for Class 1 and 2 Incidents 13
Tables Table 1 Examples of Notifiable Events 8 Table 2 Environmental Event Types and their descriptions 9 Table 3 Examples of Environmental Incidents 10 Table 4 Classification System for Environmental Incidents 11 Table 5 Contact details for Relevant Authorities 15
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Environmental Incident and Non-compliance Reporting Procedure
1 Purpose and scope
This procedure documents the process to be used when classifying and reporting Environmental Events
This procedure applies to Sydney Metro and any contractor Sydney Metro engages to carry out works Principal Contractors must ensure their processes for managing Environmental Events is consistent with this document The requirement for consistency is documented in the Construction Environmental Management Framework (Section 33(f)) and shall be allocated as a contractual requirement to each delivery partner
2 Introduction
Sydney Metro is committed to minimising risks to the environment the rapid identification and rectification of breaches to Environmental Requirements and efficient and effective responses to Environmental Incidents that grows our ability to minimise harm and prevent future re-occurrences
This procedure defines an approach to classifying Environmental Issues Incidents and Non-compliances and establishes the immediate interim and long term actions that are taken in response to Environmental Events
3 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition with the following exceptions
Term Definition
Environment
means components of the earth including
a) land air and water and
b) any layer of the atmosphere and
c) any organic or inorganic matter and any living organism and
d) human-made or modified structures and areas and includes interacting natural ecosystems that include components referred to in (a)-(c)
Environmental Event
An occurrence that identifies actual or potential environmental impacts or non-compliances Events cans include conversations inspections incidents or failures of process
Environmental Harm Includes any direct or indirect alteration of the environment that has the effect of degrading the environment and without limiting the generality of the above includes any act or omission that results in pollution
Environmental Incident
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Environmental Issue An occurrence or set of circumstances where Environmental Harm or Non-compliance could occur if not rectified
Environmental Non-compliance
A breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Term Definition
Material Harm to the Environment
harm to the environment is material if
a) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
b) it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding $10000 (or such other amount as is prescribed by the regulations) and
c) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent mitigate or make good harm to the environment
It does not matter that harm to the environment is caused only in the premises where the pollution incident occurs
Terms and jargon specific to this procedure are defined within the Sydney Metro Glossary
4 Accountabilities
The Executive Director Safety Sustainability amp Environment is accountable for this Procedure Accountability includes authorising the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
The Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document if specified in the relevant contracts
5 Environmental Events
Environmental surveillance data is relied upon to inform Sydney Metro of performance trends to provide assurance that legislative requirements are being met and indicate where surveillance activities should be directed In order to rely upon environmental data for this purpose there needs to be a high degree of consistency in the manner by which it is collected and interpreted Due to the need for consistency any incidentNon-compliance procedure produced by a delivery partner to Sydney Metro is required to be consistent with the requirements of this document
The concept of Environmental Events forms a common starting point for understanding what types of occurrences should be managed and reported as Incidents and what should be reported as Non-compliances or Issues When an Environmental Event occurs a series of questions can be asked to consistently determine what type of event it is Commonly Environmental Events lead to three different processes
1 Reporting of an Environmental Incident
2 Reporting of an Environmental Non-compliance or
3 Reporting of an Environmental Issue
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Incidents and Non-compliances are recorded using the Environmental Incident and Non-compliance Report Form (SM ES-FT-403) and Environmental Issues are recorded through environmental inspection reports using the Environmental Inspection Information amp Summary Form (SM ES-FT-406) These paper based records are subsequently entered into the Sydney Metro Compliance Register (Section 67) which is used to disseminate the data and facilities reporting internally and externally Note where a Principal Contractor has submitted alternative processes and these have been approved by Sydney Metro they may also be used
The figure below shows the process by which Environmental Events are classified (Figure 1)
Figure 1 Environmental Event Classification Process
Where Environmental Harm has been caused the event will always be classified as an Environmental Incident regardless of whether one or more Environmental Requirements have been breached Only when an event occurs without harm being caused to the environment will it be classified as a Non-compliance or Issue It should be noted that the Incident management process still captures any breaches of Environmental Requirements and these incidents contribute towards the calculation of the NC Rate (Section 71)
This flowchart above is intended to be a guide and there may be situations where it is unclear exactly how an Environmental Event should be classified In these situations a judgement call should be made in consultation with your Manager
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
51 Worked Example ndash Classifying Environmental Events
This Section provides a fictitious example of Environmental Events which fall into each of the three different categories The situations outlined below are provided to explain how event classifications are made The background for these worked examples is as follows
Sydney Metro is carrying out works in a newly established site and substantial earthworks are occurring to construct piers for an elevated viaduct A nearby creek contains a variety of important fish species and the local community are known to use this creek for recreational fishing The Environmental Impact Statement identified the creek as being at risk of increased sedimentation from dirty water run-off and the Conditions of Approval include a requirement to have a Progressive Erosion and Sediment Control Plan in place This plan has been produced and indicates that sediment fences must be in place at specific locations to capture dirty water run-off Regular daily inspections of the sediment controls are carried out by the contractorrsquos Environment Manager and an Independent Environmental Representative has commenced a monthly inspection on this site at 7 am on Thursday morning
511 Soil and Water Issue
The Environmental Representative notices a sediment fence has been knocked over in one of the areas indicated as requiring fencing on the ERSED plan It appears to have occurred recently and there is no record of rainfall in the last few days During the course of the inspection all other ERSED controls appeared to be in good condition and erected in accordance with the requirements of the Blue Book In this example no harm has yet been caused and no environmental requirement has been breached so the event is classified as an Environmental Issue which is raised on the inspection report with an action to reinstall the fence
512 Soil and Water Non-compliance
Alternatively the Environmental Representative might have noticed many sediment fences had been knocked down and in some areas an absence of sediment fences where the plan indicates they are required Despite there being no rain in recent days the Environmental Representative concludes that the requirements of the plan are not being followed and have been breached The event is raised as non-compliance and actions are set in place to re-enforce the requirements of the ERSED plan for that sites workforce as well as the immediate reinstatement of controls
513 Soil and Water Incident
Finally in a third scenario the Environmental Representative notices many sediment fences are down and some are absent where required by the plan However significant rainfall has occurred in recent days and the Environmental Representative determines that it is likely dirty water has escaped through the area into the nearby creek potentially causing harm to the fish population This event is classified as an Incident by the inspector and immediate notification is undertaken Similar controls are implemented as described above
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
52 Notifiable Events
There are a number of Acts and regulations that include a specific requirement to notify a Regulatory Authority When an Environmental Event triggers one of these notification requirements we then also refer to that event as a Notifiable Event (Table 1)
The Principal Contractorrsquos Environment Manager must determine whether an event is notifiable and may rely upon advice from Sydney Metro if it is provided
Table 1 Examples of Notifiable Events
Event type Legislation Trigger for Notification
Pollution Incident
1
POEO Act 1997 Part 57 Where Material Harm has occurred contact the EPA Pollution Line as soon as practicable POEO (General)
Regulation 2009 Section 101
Land contamination
Contaminated Land Management Act 1997
Section 60(1)
As soon as practicable after becoming aware of contamination that exceeds the relevant investigation levels in the National Environment Protection Measure where a person has or will be exposed to the contamination
Discovery of an Aboriginal relic
National Parks amp Wildlife Act 1974
Section 89A
Director General of EPA in writing within a reasonable time after becoming aware Note this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in the relevant Infrastructure Approval
Discover Aboriginal Remains
Commonwealth Aboriginal amp Torres Strait Islanders Heritage Protection Act 1984
Section 20 Commonwealth Minister of the Environment in writing as soon as practicable after becoming aware
Discovery of a relic
Heritage Act 1977 Section 146
Heritage Council in writing within a reasonable time after becoming aware
Note -this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in Infrastructure Approvals
53 Event Types
Each Environmental Event is assigned a secondary classification of an Event Type for the purpose of data analysis and general environmental management They are grouped by areas of environmental management so that targeted auditing training or awareness initiatives can be initiated in response to emergent trends Each Event Type is explained in Table 2
1 Further information on reporting pollution incidents to EPA is provided in Section 66 Environmental
IncidentNon-compliance Report
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Table 2 Environmental Event Types and their descriptions
Event Type
Applies To
Description Issue Incident
Non-compliance
Soil and Water bull bull bull
Covers the physical location chemical composition and ecology of soils and waterways Any event which changes these compositions is a Soil and Water event Within this event type all instances of contamination erosion and sedimentation of waterways is covered
Flora and Fauna bull bull bull Covers vegetation and vegetation communities as well as animals and animal habitat Any event where vegetation is felled or damaged animals are killed or injured or habitat is harmed or destroyed is covered
Waste and Spoil bull bull bull
Covers the management of Excavated Natural Material (ENM) and Virgin Excavated Natural Material (VENM) including on-site management and disposal and also the classification and management of Waste materials
Note that the transportation of spoil is covered under Traffic Transport and Access
Heritage bull bull bull Covers the management of known heritage artefacts or sites and the treatment of unexpected finds archaeological investigations and other impacts
Air Quality bull bull bull Covers the management of emissions of particulate matter odours and gasses used as air quality parameters from worksites
Noise and Vibration bull bull bull
Covers the management of airborne and ground borne noise and vibration and includes hold points on the commencement of any work where Out of Hours Works permits or Construction Noise Impact Statements are required
Community Stakeholder and Business
bull bull bull Covers the management of Community and Stakeholder requirements and includes complaint response procedure community management protocols and the maintenance of information on websites
Traffic Transport and Access bull bull bull
Covers the management of traffic inside and outside of sites including access points and parking requirements This event type also covers any requirements in relation to vehicles and vehicle maintenance or the transportation of waste and spoil
Spills and Leaks bull bull bull
Covers all instances where environmentally sensitive substances are held within a container which has the potential to leak or spill and covers pipes hoses fuel tanks storage tanks and plastic containers
Note Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Management Systems bull bull bull
Covers procedural or administrate processes that are common across all areas It specifically does not cover procedural or administrate processes which are unique to any of the other event types For example not completing a vegetation removal form prior to vegetation clearing is still a Flora and Fauna event
Note A good example of a Management Systems NC would be not reporting an Environmental Incident within required timeframes
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
6 Environmental Incident Classification and Management
Sydney Metro has defined an Environmental Incident as
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Adverse environmental impact includes contamination harm to flora and fauna (either individual species or communities) damage to heritage items or adverse community impacts
Planning Approvals and Environment Protection Licences permit some environmental impacts and these are not intended to be captured as Environmental Incidents
Table 3 Examples of Environmental Incidents
Type Example Incident
Air Quality Odour that travels beyond the site boundary
Air Quality Dust exceeding reasonable levels without active management measures in place
Air Quality Operation or maintenance of plant in a manner that causes or has likely caused excessive air pollution
Soil and Water Discharge of water on or off site in a manner that causes or has likely caused water pollution without required approvals
Noise and Vibration Noise that travels beyond the site boundary as a result of poorly maintained plant or operation of plant in an inefficient manner
Noise and Vibration Failure to comply with the approved hours of work
Soil and Water
Where the chemical composition of soil or water has been detrimentally modified by a contaminant leading to potential or actual environmental harm For example rainfall causes a flow of water across a site that erodes soil and enters a waterway increasing the total suspended solids of that water body
Spills and Leaks
Where a substance has leaked from or spilt from a container that is designed to prevent that substance from escaping into the environment (including bunds fuels tanks chemical bottles and other containers)
Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Soil and Water Dispose of waste in a manner that harms or is likely to harm the environment
Flora and Fauna Harm or ldquopickrdquo a threatened species endangered population or endangered ecological community without required approvals
Flora and Fauna Damage to vegetation fauna or habitat including watercourses without required approvals
Heritage Damage disturbance destruction or works to heritage itemsrelics without required approvals
Heritage Damage disturbance or destruction of Aboriginal objects or places without required approvals
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
61 Incident Classification
Environmental Incidents are classified into one of three Classes that are based upon the consequence descriptors for environmental risks in the Sydney Metro Risk Matrix (refer to Sydney Metro Risk Management Standard) Each of these classifications trigger a variety of management actions andor legislative requirements depending on the severity of the consequence described where Class 3 represents minor consequences and Class 1 represents major consequences
This matrix is further sub-divided into consequence ratings ranging from C6 (low impact) to C1 (high impact) An incident transitions between a Class 3 to a Class 2 incident once material harm has been caused and transitions into a Class 1 incident once it is determined that the Environmental Harm caused in large-scale and cannot be remediated (Table 4)
Table 4 Classification System for Environmental Incidents
Class 3 Class 2 Class 1
C6 C5 C4 C3 C2 C1
No appreciable changes to
environment andor highly
localised event
Change from normal conditions
within environmental
regulatory limits and environmental effects are within site boundaries
Short-term andor well-contained environmental effects Minor
remedial actions probably required
Impacts external ecosystem and considerable
remediation is required
Long-term environmental impairment in
neighbouring or valued
ecosystems
Extensive remediation
required
Irreversible large-scale
environmental impact with loss of
valued ecosystems
611 Class 3 Incidents
These Incidents are events which cause Environmental Harm but do not cause Material Harm to the environment Normally Class 3 Incidents are not Notifiable Events and therefore a simple notification protocol is adopted whereby Sydney Metro must be notified within 48 hours verbally and in writing
In some cases it will be unclear whether Material Harm has been caused in the early stages of Incident Management If this is the case then the process for Class 2 Incidents is followed (see Section Class 2 Incidents) until it is clear that Material Harm has not been caused
A formal Incident Investigation report is not required for Class 3 Incidents however it is expected that the person responsible for completing the Incident Notification Report makes appropriate enquiries to determine the likely causal factors involved and assigns effective corrective actions
612 Class 2 Incidents
These Incidents are events which cause Material Harm to the environment and they always trigger notification of Regulatory Authorities These Incidents represent events that are far more serious than Class 3 Incidents and therefore strict communication protocols are required to ensure that effective and informed decisions are made (Figure 2)
The Environmental Lead contract Environment Manager and the Independent Environmental Representative must be notified verbally as soon as possible after the observer becomes aware of a Class 2 Incident
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(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Class 2 Incidents must be investigated and the investigation must produce an investigation report containing corrective or preventative actions This investigation report must be provided to Sydney Metro within 7 days of the event unless another timeframe is agreed with the EL
Despite any arrangements for the submission of investigation reports an Incident Notification Report must be provided with all available information and submitted to Sydney Metro within 48 hours It is not expected that initial Incident Notification Reports for Incidents under investigation initially include actions as these will be informed by the findings of the investigation The report should be updated with actions resulting from the investigation when available
613 Class 1 Incidents
Class 1 Environmental Incidents are managed in the same manner as Class 2 Incidents expect where a determination is made by the Chief Executive (or delegate) that a Crisis Management Team should be activated In this situation the Sydney Metro Crisis Management Implementation Plan is followed
62 Incident Notification
When and Environmental Event occurs which causes Environmental Harm in all cases both verbal and written communication of the incident must be carried out immediately and within 48 hours respectively For Class 1 and 2 Incidents the notification process shown in Figure 2 must be followed Written communication of Environmental Incidents is via an Incident Notification Report (Section 63)
This process includes specific roles and responsibilities within Sydney Metro and our delivery Partners who are required to take notification actions in response to Incidents
This notification process has been developed to ensure that crucial information about Incidents is captured early and communicated to specific individuals who can ensure the Environmental Impacts are minimised and efficient and effective responses to the event are implemented
In particular the Principals Representative and the Environmental Lead for Sydney Metro play a crucial role in the communication of Incidents within Sydney Metro and these roles are explained in more detail below
621 Principalrsquos Representative (PR)
Each works package establishes a contractual interface for communication between the contracted party and Sydney Metro Generally this interface is between the Principal Contractors Project Director and an appointed representative of Sydney Metro called the Principals Representative
All formal written communications must pass between these two individuals electronically using TeamBinder The Principals Representative holds certain responsibilities in the Incident management Process outlined in Figure 2
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
622 Environmental Lead (EL)
Where this procedure is applied to a works package an Environmental Lead (EL) will be selected for the relevant works package The Environmental Lead must possess environmental experience and competency in managing Incidents and be a representative of Sydney Metro for those works This representative holds specific responsibilities outlined in Figure 2
Figure 2 Environment Incident notification process for Class 1 and 2 Incidents
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
63 Incident Notification Reports
For all Incidents an Incident Notification Report must be completed and submitted to Sydney Metro within 48 hours These reports satisfy the requirement for written communication to Sydney Metro and are completed using the Environmental Incident and Non-compliance Notification Report (SM ES-FT-403) or a similar and consistent form approved by Sydney Metro
64 Incident Investigations
Environmental Incident Investigations must be carried out for all Class 1 and Class 2 Incidents Investigations may also be requested for any other Environmental Event at the discretion of Sydney Metro This discretion is likely to be exercised where incidents of a similar nature are occurring repetitively
When conducting an Environmental Incident investigation they must
Be led by a lead investigator who is suitably independent investigator capable of arriving at objective findings and is experienced in conducting environmental incident investigations
Consider the need for legal privilege during the investigation process in consultation with legal counsel
Be informed by all available information that is relevant to the investigation
Analyse the timeline of events which led up to and followed the occurrence of Environmental Harm including the immediate incident response
Be conducted in a manner that is consistent with recognised investigation techniques such as ICAMS
Gather and record evidence
Seek the input of key stakeholders and
Identify Preventative and Corrective actions and document these in the Incident Notification Report
65 Environmental Incidents with Health and Safety Impacts
It is possible that where an Event occurs that causes Environmental Harm harm is also caused to the health safety or wellbeing of people In these situations there will also be a Health and Safety Incident process undertaken which is separate to the process outlined in this document
While the definition of the Environment covers people under the POEO Act the management of impacts upon them are carried out using the Health and Safety Incident Management protocols This is because Health Safety and Wellbeing requirements are governed by a range of legislation other than the POEO Act and this procedure is not comprehensive in that regard Sydney Metro has well established processes to manage impacts on people without the need for the Environmental Incident Process to intervene
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Furthermore where Environmental Events cause harm to both the lsquoenvironmentrsquo and people it is possible that the root causes for the respective impacts are different It is also possible that differences in the severity of the impacts trigger inconsistent notification requirements and investigation levels It is prudent to identify appropriate and effective corrective actions that reduce the risk of impacts to both people and the environment therefore separate Incident Management Processes are undertaken in these situations
For more detail on the management of Health and Safety Incidents please refer to the Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
66 Reporting Pollution Incidents to Relevant Authorities
If an Incident or Non-compliance is a Notifiable Event then a report must be provided to the relevant Regulatory Authority within the timeframe(s) specified by the relevant legislation Pollution Incidents which are causing or threatening Material Harm to the environment must be reported to each of the following authorities immediately after project personnel become aware of the Incident as required by Section 148 of the POEO Act 1997 The contact numbers for these authorities are listed in Table 5
Table 5 Contact details for Relevant Authorities
Type Example incident
EPA Environment Line 131 555
Local Authority Local Council (specific to area)
Ministry of Health Public Health Unit (refer to httpwwwhealthnswgovauPagesdefaultaspx to confirm local area contact details)
SafeWork NSW 131 050 or contactsafeworknswgovau
Fire and Rescue NSW 000
Relevant information required to be given to EPA when making a notification is specified in Section 150 of the POEO Act 1997 as follows
Time date nature duration and location of the incident
Location of the place where pollution is occurring or is likely to occur
Nature the estimated quantity or volume and the concentration of any pollutants involved
Circumstances in which the Incident occurred (including the cause of the Incident if known)
Action taken or proposed to be taken to deal with the Incident and any resulting pollution or threatened pollution and
Other information prescribed by the regulations
All relevant information known at the time of making the notification must be reported If the information required by (c) (d) or (e) above is not known at the time of initial notification but becomes known afterwards it must be reported to each authority immediately after it
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 16 of 19
Environmental Incident and Non-compliance Reporting Procedure
becomes known Verbal notification must be followed by notification in writing within seven days of the date on which the Incident occurred
Pollution Incidents are not required to be reported if the Incident has already come to the attention of the EPA or the Incident involves only the emission of an odour
Failure to report a pollution Incident as required by the POEO Act 1997 is an offence
Where any work or activity is regulated by an Environment Protection License (EPL) notification of a pollution Incident to the EPA should be made by the licensee Thus where the contractor holds the EPL for the project notification to EPA shall be made by the contractor
For any work or activity that is not regulated by an EPL notification of pollution Incidents to EPA shall be made by Sydney Metro unless the contractor is instructed otherwise by Sydney Metro This includes pollution Incidents that occur as a result of pre-construction activities which may be undertaken prior to an EPL being required for a project Pre- construction activities are determined by the Planning Approval and may include for example geotechnical investigations or surveys
Where the Environmental Representative determines there to have been a significant off-site impact on people or the biophysical environment the program Director Sustainability Environment and Planning will notify the Secretary of the Department of Environment and Planning within 48 hours in accordance with Project Infrastructure Approval Conditions This notification will be followed by a full written report within seven days of the date on which the incident occurred
661 Maritime Related Incident Notification and Reporting
Marine Incidents involving vessels and personnel on board vessels must be reported to the Australian Maritime Safety Authority in accordance with the guidance published on their website at
Australian Maritime Safety Authority Incident Reporting and
Reporting obligations of owners and masters of domestic commercial vessels
67 Environmental Compliance Register
The Environmental Compliance Register is used to manage the information associated with reporting of Environmental Events This register is maintained by the Manager Environment and may be used by a variety of individuals to input data For access to the register or information on its use contact the Manager Environment
This register analyses the data it contains and produces environmental compliance statistics that are used to meet a range of reporting and environmental management requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 17 of 19
Environmental Incident and Non-compliance Reporting Procedure
7 Environmental Non-compliance
An Environmental Non-compliance is a breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans It is important to note that regardless of whether an event is classified as a Non-compliance or an Incident the process behind managing the event remains the same with the following exceptions
Non-compliances are not notifiable to Regulatory Authorities under the POEO Act
Non-compliances are reported to have occurred on the day the breach was raised as opposed to the date when the requirement was breached (this is to preserve historical reporting and analysis ndash see Section 71)
Non-compliances are not divided into severity classes (Section 52)
Non-compliances do not have the potential to trigger crisis or emergency management processes and
There is an informal notification process in the immediate timeframe following a Non-compliance being raised
When an Environmental Event occurs that causes Environmental Harm and also breaches one or more Environmental Requirements then an Incident Notification Report will be created which records what requirements were breached
If a Non-compliance is identified then it must be raised using the Environmental Incident and Non-compliance Report Form within 48 hours by the party responsible for the breach
71 Non-compliance Rate
A key environmental performance statistic used by Sydney Metro is the Non-compliance Rate This statistic provides a standardised way of comparing the performance of different projects or contractors The NC Rate is calculated using the following formula
= (119873119862119904 + 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119903119886119894119904119890119889 119894119899 119898119900119899119905ℎ) + (119874119901119890119899 119873119862119904 + 119874119901119890119899 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119891119903119900119898 119901119903119890119907119894119900119906119904 119898119900119899119905ℎ119904)
119879119900119905119886119897 119873119906119898119887119890119903 119900119891 119874119899119892119900119894119899119892 119877119890119902119906119894119903119890119898119890119899119905119904) 119883 100
Each month a count of the number of NCs raised and Incident raised where Environmental Requirements have also been breached is counted Added to this number is the number of these events which were raised in previous months that still held an Open status in the current reporting period Non-compliance and incident Events are considered Open if any of the associated Actions are Open The total is divided by the number of Environmental Requirements which are actively being complied with (Ongoing Requirements) and a multiplying factor of 100 is applied
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 18 of 19
Environmental Incident and Non-compliance Reporting Procedure
8 Corrective and Preventative Actions
Whenever an Environmental Event is raised actions will be assigned to the event irrespective of whether it is an Issue Incident or Non-compliance These actions will generally be Corrective Actions which are implemented to eliminate the cause of the Incident Non-compliance or Issue and can be thought of as reactive measures in response to the Environmental Event
Preventative Actions may also be assigned to prevent the occurrence of an Incident Non-compliance or Issue and can be considered pro-active measures which may be recommended following a detailed investigation of the event
Actions must
Limit impacts as far as is reasonably practicable
eliminate risk where practicable
where is it not practicable to eliminate the risk follow the hierarchy of controls
address root causes and contributing factors and
be prioritised based on risk
The Executive Director Safety Sustainability amp Environment must ensure there are systems in place to
monitor corrective action status
escalate issues to the executive where progress on a corrective action is inadequate and
retain all corrective action responses for recording purposes
81 Action Status
Actions are allocated to a person who will take accountability for ensuring it is carried out within a timely manner and completed by the due date
Actions are either closed immediately if the Action has already been carried out and verified by Sydney Metro or are created with an open status The Action will remain in an open state until such a time as Sydney Metro verifies that the responsible person has completed the Action in a satisfactory manner Until all actions associated with an Incident Non-compliance or Issue are closed the original Environmental Event is considered to be open as well This is relevant when calculating the NC Rate as open Non-compliances and Incidents contribute toward the calculation of this statistic
Verification is determined by the Environmental Lead by sighting evidence of the Actions implementation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 19 of 19
Environmental Incident and Non-compliance Reporting Procedure
9 Related Documents and References
10 Superseded Documents
11 Document History
Related Documents and References
Environmental amp Sustainability Management Manual
Risk Management Standard
Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
Crisis Management Implementation Plan
Environmental Incident and Non-compliance Notification Report
Environmental Inspection Information amp Summary
Sydney Metro Glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
10 31 March 2015 New document
20 7 July 2016 IMS Review
30 7 April 2017 IMS Review
40 23 November 2018 IMS Review
50 11 February 2019 IMS Review
51 18 February 2019 Minor correction to formula
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Appendix 10 ndash Sydney Metro Environmental Inspection template
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2016 CEMP Appendix 10 - Sydney Metro Inspection template Page 1 of 1
Environmental Inspection Report Template
Contract
Contractor Date
Inspection Number Time
Location
Weather
Attendees
Site Activities
Item No
Key Issues Action Party
Priority
(L M H)
Inspection by
Name Title Signature
Date
Copy to
- All attendees
-
-
-
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Appendix 11 ndash Georgiou Environmental Policy
COMPANY POLICY
Rob Monaci Chief Executive Officer Georgiou Group September 2020
ENVIRONMENTAL
Georgiou is committed to minimising where reasonably practicable its impact on the natural environment and social surroundings for the benefit of current and future generations while enhancing Georgioursquos environmental performance
In order to achieve this commitment Georgiou will
set environmental objectives and targets applicable to the aspects and potential impacts of projects and facilities
establish positive relationships with community and stakeholders
comply with all applicable environmental laws regulations statutory obligations and client environmental requirements
identify significant environmental aspects and develop effective and appropriate mitigation measures to minimise environmental impacts
provide measures to protect heritage biodiversity land and waterways
manage potential community impacts related to air quality noise and vibration
practice responsible resource use and waste management including the promotion of efficient use reuse and recycling of resources
implement and maintain Georgioursquos management system and practices to meet its business needs ASNZS ISO 14001 client and other obligations and
hold employees and subcontractors accountable for proactively meeting their environmental responsibilities
Achieving these commitments is fundamental to demonstrate a positive impact on the environment and communities associated with Georgioursquos activities and developments All employees and persons who work with Georgiou have a personal responsibility for implementing this Policy
SAFE
TY |
PRO
FIT
| RE
LATI
ON
SHIP
S |
PEO
PLE
| IN
NO
VAT
ION
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Hierarchy of Control 27
Site Environmental Risk Analysis 28
Review of Risks 28
831 Change Management 28
Operational Control 28
841 Environmental Hazard Reporting 28
842 Take 5 29
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS) 29
844 Permit to Work 29
845 Environmental Control Maps 29
9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT 30
10 CLOSURE AND COMMISSIONING 30
11 TRAINING COMPETENCY AND RESOURCING 30
1111 Toolbox talks 30
1112 Recording of Training and Assessment 31
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE 31
EmergencyIncident Planning and Control 31
13 HSE REPORTING AND INVESTIGATION 31
Notifications and Reporting 31
1311 Internal 31
1312 Notification of Incidents to Sydney Metro 31
1313 Statutory Notifications 31
Investigations 32
Review and Communication of Incidents 32
14 ENVIRONMENTAL REPORTING 32
1411 Monthly Reports 32
Site Meetings 32
Project Performance Review 33
15 AUDITING REVIEWS AND INSPECTIONS 33
Inspections 33
1511 Environmental Inspections 33
Audits and Reviews 33
Monitoring 34
Corrective Actions 34
16 DOCUMENT AND RECORD CONTROL 34
17 APPENDICES 35
Appendix 1 - Waste Management Sub Plan 36
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Appendix 1A ndash Sydney Metro Waste Classification Procedure 42
Appendix 2- Soil and Water Management Sub Plan 43
Appendix 3- Hydrocarbon and Chemical Management Sub Plan 46
Appendix 4 - Flora amp Fauna Management Sub Plan 50
Appendix 5 - Cultural Heritage Management Sub Plan 53
Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure 55
Appendix 5B ndash Sydney Metro Exhumation Management Procedure 56
Appendix 6 - Air Quality amp Dust Management Sub Plan 57
Appendix 7- Noise Vibration and Light spill Management Sub Plan 59
Appendix 7A ndash Sydney Metro Out of Hours Application form 61
Appendix 8 ndash Contaminated Land Management Sub Plan 62
Appendix 8A ndash Unexpected Contamination finds procedure 67
Appendix 8B ndash Unexpected Asbestos finds procedure 71
Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure 78
Appendix 10 ndash Sydney Metro Environmental Inspection template 79
Appendix 11 ndash Georgiou Environmental Policy 80
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GLOSSARY ABBREVIATIONS
Term Expanded text
AFMP Ancillary Facilities Management Plan
BC Act Biodiversity Conservation Act 2016
CoA Condition of approval
Compliance audit Verification of how implementation is proceeding with respect to an CEMP (which incorporates the relevant approval conditions)
CPESC Certified practising erosion and sediment control professional
CRM Community Relations Manager
CPESC Certified practising erosion and sediment control professional
CSSI Critical State Significant Infrastructure
DEC Department of Environment and Conservation (NSW) (former)
DIPNR Department of Infrastructure Planning and Natural Resources (former)
DoEE Commonwealth Department of the Environment and Energy
DoI - Water NSW Department of Industry - Water
DPIE NSW Department of Planning Industry and Environment
Ecologically sustainable development (ESD)
Using conserving and enhancing the communityrsquos resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future can be increased (Council of Australian Governments 1992)
EIS Environmental Impact Statement
EMS Environmental Management System
Environmental aspect
Defined by ASNZS ISO 140012015 as an element of an organisationrsquos activities products or services that can interact with the environment
Environmental impact
Defined by ASNZS ISO 140012015 as any change to the environment whether adverse or beneficial wholly or partially resulting from an organisationrsquos environmental aspects
Environmental incident
An unexpected event that has or has the potential to cause harm to the environment and requires some action to minimise the impact or restore the environment
Environmental objective
Defined by ASNZS ISO 140012015 as an overall environmental goal consistent with the environmental policy that an organisation sets itself to achieve
Environmental policy
Statement by an organisation of its intention and principles for environmental performance
Environmental target
Defined by ASNZS ISO 140012015 as a detailed performance requirement applicable to the organisation or parts thereof that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives
EPA NSW Environment Protection Authority
EPampA Act NSW Environmental Planning and Assessment Act 1979
EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999
EPL NSW Environment Protection Licence under the Protection of the Environment Operations Act 1997
ERG Environmental Review Group
ESCP Erosion and Sediment Control Plan
EWMS Environmental Work Method Statement
Federal-CoA Condition of the Federal Department of the Environment and Energy Approval Decision
Hold point Is a verification point that prevents work from commencing prior to approval
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LGA Local Government Area
MNES Matters of National Environmental Significance
Non-compliance Failure to comply with the requirements of the Project approval or any applicable licence permit or legal requirements
NSW-CoA Condition of the NSW DPampE Infrastructure Approval
OEH NSW Office of Environment and Heritage
OOHW Out of hours work
PIRMP Pollution Incident Response Management Plan
POEO Act Protection of the Environment Operations Act 1997 (NSW)
RAP Registered Aboriginal Party
RBL Rating background level
REF Review of Environmental Factors
ROL Road occupancy licence
SAP Sensitive Area Plan
SEPP State Environmental Planning Policy
UXO Unexploded Ordnance
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1 INTRODUCTION AND PURPOSE
The purpose of this Construction Environmental Management Plan (CEMP) is to describe how environmental aspects
are to be managed so that the site and those engaged onsite will
Comply with Georgiou Policy Client legal and other obligations
Minimise the impacts on the environment
Achieve the Company client and site objectives and targets
implement mitigation measures identified and assessed through Review of Environmental Factors (REF) under
Part 5 of the EPampA Act
Comply with the requirements of the Construction Environmental Management Framework (CEMF) February
2020 version 41 Managing Contractor Contract (MCC) Works Brief licencing and other relevant documents
This Management Plan is written in accordance with Georgioursquos health safety and environment management
system that is 3rd party certified to ASNZS ISO 14001 It has been written in accordance with the Transport for
New South Wales (TfNSW) Sydney Metro Construction Environmental Management Framework (CEMF) and the
project specific Sydney Metro General Specification ndash Plans and Reporting
Amendments and Authorisation
This Management Plan will be approved by the Project Manager their Line Manager and a Representative from the
HSE Department This Management Plan and other related documents will be reviewed annually or as a result of
Changes to Company procedures or processes
Changes to key personnel or resources
Changes in legal and other obligations
Findings from an audit or inspection
Findings from a significant incident or near miss
Significant changes to site conditions andor work methods
Instructions from Sydney Metro
Reviews will be undertaken in consultation with key stakeholders to ensure all locationsfunctions are considered
A record of the date and comments relating to any revisions of this document will be included in the revision table
The only Georgiou authorisation required to amend this document after initial approval is the Project Managerrsquos
Communication of this Plan
The Project Manager is accountable for ensuring
Location and access to the management plans is communicated at induction Management Plans have been communicated to subcontractor personnel prior to commencement of works
onsite Any changes made to the management plan are communicated to affected persons on the site
Supporting Management Plans
The following management plans have been developed to support this management plan
Emergency Response and Preparedness Plan
Georgiou Crisis Management Plan (controlled by Georgioursquos Perth Head Office and available on Company Intranet)
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2 SCOPE OF WORKS
Sydney Metro is proposing to configure the internal port road network at Rozelle to facilitate the orderly urban
renewal of the Bays West area while maintaining access to the White Bay Cruise Terminal and other port operations
at Glebe Island and White Bay This includes long-term urban renewal initiatives for the Bays West area and works
for various future developments within the locality including critical works for the proposed Sydney Metro West
The proposal also provides the opportunity to improve road safety by reducing conflicting traffic movements in the
internal port road network
Georgioursquos scope of works is described as lsquoPhase 1rsquo works in the REF and it comprises of the following key
features
A reconfigured intersection at Port Access Road Solomons Way Sommerville Road including an interim
connection with the existing Port Access Road until it is relocated (as part of Phase 2)
Establishment of one-way traffic circulation along Solomons Way and Sommerville Road around the Glebe Island
Silos
Relocation of the Cement Australia Truck Parking Licenced Area to the north prior to the construction of the
reconfigured intersection due to the direct conflict with the reconfigured intersection
3 LOCATION
The proposal is located in an established industrial and port context at Rozelle within the Inner West Council local
government area
The lsquoproposal sitersquo refers to the area that would be directly impacted by the proposal as shown in Figure 1-1 The
proposal site is largely disused with the exception of the Port Access Road and port related lease areas including a
Cement Australia Truck Parking Licenced Area to service Cement Australiarsquos operations at the Glebe Island Silos
The proposal site is under the ownership of the Port Authority of NSW
To the north of the proposal site is the existing Port Access Road that supports access to the White Bay Cruise
Terminal and other port operations at White Bay To the east of the site is the existing Cement Australia and Sugar
Australia Glebe Island Silos and the Gypsum Resources Australia facility The south-eastern border of the site is
vegetated land adjoining Victoria Road Western Distributor The proposed location for the relocated Cement
Australia Truck Parking Licenced Area is currently a hardstand laydown area used by Port Authority of NSW
Beyond the proposal site the wider locality features a mix of land uses including retail commercial and urban
services along Robert Street to the north port and maritime uses to the east (Glebe Island and White Bay) and to
the south and City West Link Road and residential dwellings to the west in Rozelle
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CEMP Bays Road Relocation Works
Figure 3-1 Site location
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW
The following documents provide further information in regards to this topic
Management System Standard
Environmental Management System
The CEMP has been prepared in accordance with the overarching environmental management system (EMS) as
detailed below
Georgiou has a certified EMS consistent with ASNZS ISO 14001 Environmental Management Systems and will
prepare CEMPs in accordance with this EMS
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Policy
This Management Plan has been prepared in accordance with Georgioursquos Environmental Policy (appendix 11) All
relevant works including those conducted by subcontractors or by other companies on Georgioursquos behalf will
conform to this Policy
Georgioursquos Environmental Policy will be communicated to all workers at their site induction and displayed at the
site Georgioursquos policies will be made available to any interested party
Environmental Management Plan
This CEMP provides the system to manage and control the environmental aspects of the Project during pre-
construction and construction It identifies all the requirements applicable to manage the activities described in
Section 2 It also provides the overall framework for the system and procedures to ensure environmental impacts
are minimised and legislative and other requirements are fulfilled The strategies defined in this CEMP have been
developed with consideration of the Project approval requirements environmental management measures
presented in the approval documents This CEMP establishes the system for implementation monitoring and
continuous improvement to minimise impacts from the Project on the environment
This CEMP is consistent with
ASNZS ISO14001 2004 lsquoEnvironmental Management Systems - requirements with guidance for usersquo
Georgiou HSEQ Management System
Environmental Policy
Georgious Management is committed to regulatory
compliance pollution prevention and continous
improvement
Planning
Identify environmental interactions and signficant
aspects identify legal and other requirements and development
environmental objectives targets and the programs in
which to achieve them
Implementation and Operation
Define structure and responsibility identify and complete training
needs establish communication procedures document the EMS
through policies plans and procedures establish document
control establish operational control implement emergency
preparedness and response
Checking
Monitor and measure environmental interactions
evaluate compliance establish a non-conformance corrective
action and preventative action system maintain records and
perform periodic internal audits of the EMS
Management Review
Management to review environmental performance
EMS performance policy priorities and objectives and recommend improvements
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5 LEGAL AND OTHER OBLIGATIONS
The following documents provide further information in regards to this topic
Management System Standard
HSE Legal and Other Obligations Directory
General
The statutory requirements for this site have been identified within the Company HSE Legal and Obligations
Directories (available on Company Intranet) and have been incorporated into this management plan Legal and
other requirements specific to this contract which are not otherwise captured in the Company HSE Legal and
Obligations Directories are as follows
Legislation Other requirement
Requirement Comment
EPBC Act 1999
Under the EPBC Act a referral to the Commonwealth Department of Agriculture Water and the Environment is required for proposed lsquoactionsrsquo that have the potential to significantly impact on any matter of national environmental significance the environment in general or the environment of Commonwealth land (including leased land)
There are no matters of national environmental significance located within the general area of the proposal as confirmed in Appendix A of the REF Therefore an EPBC Act referral is not required
EPampA Act 1979
Clause 94 of the ISEPP outlines that development for the purpose of road and road infrastructure facilities which are permissible without the need for development consent under Part 4 of the EPampA Act when carried out by a public authority
Sydney Metro is a public authority and has prepared an REF and determination report to meet the assessment requirements under the EPampA Act
EPampA Regulation 1979 Under clause 228 of the factors to take into account concerning the impact on an activity on the environment
The REF and determination report prepared by Sydney Metro has considered factors under clause 228
ISEPP 2007
Division 1 of Part 2 of the ISEPP contains provisions for public authorities to consult with local councils and other public authorities prior to the commencement of certain types of development
Sydney Metro will conduct consultation with local councils and other authorities prior to commencement of construction
Biosecurity Act 2015
Under the Biosecurity Act 2015 all plants including weeds are regulated with a general biosecurity duty to prevent eliminate or minimise any biosecurity risk they may pose Any person who deals with any plant who knows (or ought to know) of any biosecurity risk has a duty to ensure the risk is prevented eliminated or minimised so far as is reasonably practicable
The State level priority weeds and associated legal requirements relevant to the region are outlined in the Greater Sydney Regional Strategic Weed Management Plan 2017-2022 (Greater Sydney Local Land Services 2017)
As such if present priority weeds on the site would be assessed and controlled to fulfil the General Biosecurity Duty and minimise biosecurity risks
Contaminated Land Section 60 of the Contaminated Land Management Act 1997 imposes a duty on
One site (former White Bay Power Station) that is currently regulated by
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Management Act 1997 landowners to notify the NSW EPA and potentially investigate and remediate land if contamination is above NSW EPA guideline levels
the NSW EPA is located within the proposal site
Given the proposed works are predominately surficial or up to one metre below existing site levels contamination risk is considered minor and manageable
Biodiversity
Conservation Act 2016
The Biodiversity Conservation Act 2016 provides for the protection of threatened species populations and ecological communities in NSW If a threatened species population or ecological community or its habitat is likely to occur in any area that may be affected by the proposal then an assessment of significance must be prepared to determine whether the proposal would have a significant impact
The site is unlikely to contain suitable habitat for any listed threatened species or community and is unlikely to have a significant impact on any threatened species or community
Heritage Act 1977
The NSW Heritage Act 1977 (Heritage Act) provides protection for items of lsquoEnvironmental heritagersquo in NSW Items considered to be significant to the State are listed on the State Heritage Register (SHR) and cannot be demolished altered moved or damaged or their significance altered without approval from the Heritage Council of NSW
Section 170 of the Heritage Act requires government agencies to maintain a heritage and conservation register (Section 170 register) These registers provide a list of government assets which may have State or local heritage significance
Sections 139 to 145 of the Heritage Act prevent the excavation or disturbance of land known or likely to contain relics unless in accordance with an excavation permit Excavation permits are issued under Section 140 of the Heritage Act or Section 60 for sites listed on the SHR Excavation Permit Applications must be supported by an Archaeological Research Design Section 146 of the Heritage Act requires that any discovery or location of a lsquorelicrsquo is reported to the Heritage Council
The road footprint for Georgioursquos scope of works is located outside of the heritage curtilage for the SHR-listed White Bay Power Station and does not extend north to the White Bay Power Station (Inlet) Canal (Port Authority of NSW s170 4560062)
The Glebe Island Silos (Port Authority of NSW s170 4560016) and the Glebe Island Dyke Exposures (Port Authority of NSW s170 4560056) are located immediately adjacent to the road footprint
As detailed in the REF it is unlikely that archaeological relics would be impacted by the works therefore a Section 139 exception or Section 140 permit are not required for the works
National Parks and
Wildlife Act 1974
Sections 86 87 and 90 of the National Parks and Wildlife Act 1974 require consent from the Environment Energy and Science Group of the Department of Planning Industry and Environment for the destruction or damage of Aboriginal objects
The proposal is unlikely to disturb any Aboriginal objects (refer Section 77)
However if unexpected archaeological items or items of Aboriginal heritage significance are discovered during the construction of the proposal the Sydney Metro Unexpected Finds procedure would be followed
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Protection of
the Environment
Operations Act 1997
The Protection of the Environment Operations Act 1997 (POEO Act) administers environment protection licences (EPLs) for specific activities relating to air water and noise pollution and waste management The Environment Protection Authority (EPA) and local government where relevant administer the POEO Act
Development activities require an EPL under the POEO Act if those activities meet the assessment criteria outlined in Schedule 1 of the Act
The proposal does not meet the definition of a scheduled activity under Schedule 1
In addition the POEO Act would require construction to be managed to prevent and avoid the potential to cause water noise andor air pollution The Act also includes requirements in relation to the management of waste
Notification to the EPA would also be required (as the administrators of this Act) in instances where any pollution incident has the potential to lsquocause or threaten material harm to the environmentrsquo (refer to Section 148 of the Act)
Roads Act 1993
In accordance with Section 138 of the Roads Act 1993 consent from NSW Transport for NSW would be required for the carrying out of work in on or over a classified road
For works on unclassified roads Clause 5 of Schedule 2 of the Act provides that a public authority is not required to obtain a road authorityrsquos consent
Ongoing consultation would be carried out with the relevant road authority (or authorities) in relation to the potential impacts that may occur to all of the roads and to identify any potential construction activities may be require consent
Waste avoidance and
Resource Recovery
Act 2001
The purpose of the Waste Avoidance and Resource Recovery Act 2001 is to develop and support the implementation of regional and local programs to meet the outcomes of a State-wide strategy for waste avoidance and resource recovery
It also aims to lsquominimise the consumption of natural resources and final disposal of waste by encouraging the avoidance of waste and the reuse and recycling of wastersquo
Waste generation and disposal reporting would be carried out during the construction and operation of the proposal Procedures would be implemented during construction in an attempt to promote the objectives of the Act
Water Act 1912 and
Water Management
Act 2000
The Water Act 1912 and the Water Management Act 2000 are the two key pieces of legislation for the management of water in NSW and contain provisions for the licensing of water access and use
The proposal would not involve any water use water management works drainage or food works controlled activities or aquifer interference
National Greenhouse and Energy Reporting Act 2007
The Act established a framework for reporting of greenhouse gas emissions abatement actions energy consumption and production data
The project will report on greenhouse gas and energy usage data as required by the Act
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Contractual Environmental Requirements
This Management Plan has been written to comply with the following Sydney Metro CEMF requirements
Requirement Reference
Scope of Applicability (Any Sections of the CEMF not addressed in the left hand column of
this table do not apply) Addressed by
CEMF Requirements
Section 1 full applicability This document
Section 4
Section 2 full applicability Section 5
Section 23
Standards and guidelines applicable to the works including o ISO14001 Environmental Management System ndash Requirements
with Guidelines for Use o Interim Construction Noise Guidelines (Department of
Environment and Climate Change 2009) o Managing Urban Stormwater Soil and Construction (Landcom
2008) o AS42821997 Control of the Obtrusive Effect of Outdoor Lighting o Waste Classification Guidelines (Department of Environment
Climate Change and Water 2008) o Australian and New Zealand Guidelines for Fresh and Marine
Water Quality
Section 41
Appendix 7
Appendix 2
Appendix 1
Section 32
Only applies with respect to Construction for o SMP1 o SMP2 o SMP5 o SMP6 o SMP7 o SMP14 o SMP18 o SMP19 o SMP30
Separate sustainability management plan
Section 34
34(d) (x) applies only to the extent of addressing environmental inspections
34(d) (xi) does not apply
Approval by DPIE is not required under 34(e)
34(f) Applies with respect to o Unexpected Finds Procedure (Heritage) o Environmental Incident and Non-compliance Reporting Procedure o Construction Noise and Vibration Standard o Out of Hours Work Application Form o Unexpected Finds Procedure (Contamination)
This document
Appendices 1-10
Section 36 36(b) only applies with respect to the drafting of a Waste Management Procedure and an Unexpected Finds Procedure for Contamination
Appendix 1
Appendix 8
Section 39 39(a) (iii) does not apply 39(b) does not apply
39(b) does not apply Section 11
Section 310 Applies except that a Pollution Incident Response Plan is not required Section 12
Section 312 312(a)(i) does not apply
312(a)(iv) does not apply Section 6
Section 313
313(b) does not apply
313(d) does not apply
313(e) does not apply
Section 15
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Section 314 Full Applicability Section 13
Appendix 9
Section 315 315(d) does not apply with respect to internal audits carried out by the Principal Contractor
Section 16
Section 316 316(d) does not apply where the Principal Contractors works last less than 1 year
Section 15
Section 4 42(a) does not apply
45(c) does not apply Section 72
Section 5 51(c) does not apply
54 does not apply Appendix 7
Section 6 Only 61 applies
Sustainability management plan
Section 7 71 does not apply
72 does not apply
Appendix 2
Section 8
81 full applicability
A Construction Noise and Vibration sub-plan is not required however the CEMP must address
82(a) (iii) and (b) for Site Establishment Activities
Appendix 7
Section 9
91 (a) (i) is not applicable
A Heritage Management plan is not required however the CEMP must address the following requirements
92 (iii)
92 (ix)
92 (c) (iii)
Appendix 5 5A 5B
Section 10
101 (ii) does not apply
102(a) (iii) applies with respect to the relocation of fauna only
102(b) (i) applies
102 (b) (ii) applies
All other sections are not applicable
Appendix 4
Section 11 111 (ii) does not apply
112 does not apply Section 72
Section 12
A Soil and Water Management Plan is not required however the CEMP must address the following requirements
122 (vi)
Appendix 2
Section 13 131 full applicability
132 does not apply Appendix 6
Section 14
141 full applicability
A Waste Management Plan is not required however the CEMP must address the following Requirements
142 (a) (iv)
142 (a) (v)
142 (b) (i)
142 (d)
Appendix 1
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REF Determination Conditions of Approval
The project is subject to compliance with the Conditions of Approval (CoA) identified below these are from the
REF Determination Report (August 2020) These Conditions of Approval are consistent with the management and
mitigation measures in the REF (April 2020) with some amendments due to the project changes identified in the
REF determination report
CoA Requirement Addressed by
REF Determination Conditions of Approval
NV1 Receivers that would potentially be affected by noise andor vibration from the works would be appropriately notified before the relevant works start
This would include details on the nature of works to be carried out the expected noise levels duration of noise generating construction works and contact details during construction
Appendix 7
NV2 Where vibration levels are predicted to exceed the screening criteria a more detailed assessment of the structure (in consultation with the relevant asset owner and a structural engineer) and attended vibration monitoring would be carried out to ensure vibration levels remain below appropriate limits for that structure
For heritage buildings and structures the more detailed assessment would specifically consider the heritage values of the structure in consultation with a heritage specialist to ensure sensitive heritage fabric is adequately monitored and managed
Appendix 7
NV3 Condition surveys of buildings and structures near to the proposal would be undertaken in consultation with the relevant owner prior to the commencement of vibration intensive works where appropriate For heritage buildings and structures the surveys would consider the heritage values of the structure in consultation with a heritage specialist
Sydney Metro
NV4 Alternative construction methodologies would be considered where vibration intensive works (typically site clearing ndash demolition) result in exceedances of cosmetic damage screening criteria and may include the following
The use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of rockbreakers for demolition of structures
Use of smaller capacity rockbreakers or lower vibration generating rockbreakers
Isolating the vibration sensitive structure from the vibration intensive work area by severing the vibration transmission path using non-vibration intensive means such a sawing
Appendix 7
NV5 The potential vibration impacts to underground utilities and services would be reviewed as the proposal progresses in consultation with the asset owners and the Port Authority of NSW
Appendix 7
T1 Clear wayfinding and safety signage would be provided to direct and guide vehicles not related to the proposal during road construction works This would be supplemented by Variable Message Signs to advise drivers of traffic diversions speed restrictions or alternative routes
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T2 The Port Authority of NSW and lease holders would be notified in advance of any proposed road changes within the port area and the potential for short term delays
Sydney Metro
Georgiou must provide written notifications to Sydney Metro on road changes in
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advance of each relevant road change within the port area
T3 Construction site traffic would be managed to minimise movements during peak periods
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T4 Access to Cement Australia and other leased areas would be maintained in consultation with Port Authority and lease holders
Sydney Metro
Georgiou will provide required information to SM
T5 All staff parking would be provided on-site and not on surrounding local streets
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
NAH1 An Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
(Transferred to Georgiou under VO-003)
C1 Sampling and testing of soils in areas of potential contamination concern would be conducted to characterise the soils (with respect to contamination) and determine the appropriate waste classification (which may include hazardous wastes or special wastes) and management response Waste classification would be carried out in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (NSW Environment Protection Authority 2014)
Appendix 1
Appendix 1A
C2 Soils would be managed in accordance with the Protection of the Environment Operations (Waste) Regulation 2014 and disposed of to an appropriately licensed waste management facility
Appendix 1
Appendix 1A
C3 Erosion and sediment measures would be implemented in accordance with the principles and requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Appendix 2
C4 All fuels chemicals and hazardous liquids would be stored in accordance with Australian standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Appendix 3
C5 Prior to ground disturbance in areas of potential acid sulfate soil occurrence testing would be carried out to determine the presence of actual andor potential acid sulfate soils If acid sulfate soils are encountered they would be managed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Appendix 2
LV1 The design and maintenance of construction site fencing would aim to minimise visual amenity impact where visible from public areas
Section 722
LV2 Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Appendix 7
WR1 All waste would be assessed classified managed transported and disposed of in accordance with the Waste Classification Guidelines and the Protection of the Environment Operations (Waste) Regulation 2014
Appendix 1
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The waste management hierarchy principles established under the Waste Avoidance and Resource Recovery Act 2001 of avoidreducereuserecycledispose would be applied to the construction of the proposal
AQ1 The following best-practice dust management measures would be implemented during all construction works
Regularly wet-down exposed and disturbed areas including stockpiles especially during dry weather
Adjust the intensity of activities based on measured and observed dust levels and weather forecasts
Minimise the amount of materials stockpiled and position stockpiles away from surrounding receivers
Regularly inspect dust emissions and apply additional controls as required
Appendix 6
AQ2 Plant and equipment would be maintained in a proper and efficient manner Visual inspections of emissions from plant would be carried out as part of pre-acceptance checks
Appendix 6
GHG1 Opportunities to reduce greenhouse gas emissions through the increased use of recycled materials would be investigated during detailed design
Sydney Metro
CI1 The likelihood of cumulative (ie concurrent and consecutive) construction impacts would be reviewed during detailed design when detailed construction schedules are available
Co-ordination and consultation with the following stakeholders would occur where required to manage the interface of projects under construction at the same time
Transport for NSW including Transport Coordination
Department of Planning Industry and Environment
Port Authority of NSW
Sydney Motorways Corporation
Construction contractors
Co-ordination would occur between potentially interacting projects to minimise concurrent or consecutive works in the same areas where possible
Sydney Metro
Georgiou must participate in any consultation as requested by the Principal and provide the Principal with all information and documentation the Principal requires to comply with condition
Environmental Licences and Permits
The Project Environmental Site Representative will be responsible for
Checking with the local government municipality to see if there are local environmental requirements Identifying the environmental licences and or permits under which the site will operate Obtaining a copy of any client held licences permitsapprovals to determine conditions of compliance or if not
available obtaining written verification that licences and permits are held Obtaining Georgiou held licences and or permits Monitoring compliance to the conditions of the licencepermit and report on the status in the Project HSEQ
Performance Report and to the client
Permits and licences relevant to the project are as follows
Permit licence Responsibility Status
Environmental protection licences (EPL) under the Protection of the Environment Operations Act 1997 for road construction
Georgiou Not required as this project does not trigger a scheduled activity under the POEO Act 1997
Road Occupancy Licences Georgiou To be applied for as required
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Infringement Improvement and Prohibition Notices
The Project Manager or delegate will ensure any infringement improvement or prohibition notice issued by a
regulatory authority recorded as a incident in Georgioursquos Incident reporting database (Beakon) and appropriate
actions taken in a timely manner A copy of the infringement improvement or prohibition will be added to the
incident report and forwarded to the HSE Business Unit Lead
The Project Manager will notify via email their General Manager Construction Manager Operations Manager
HSE Business Unit amp Environmental Site Representative Lead when the infringement improvement or prohibitions
notice has been closed out
Availability of Statutory and Other Information
Georgioursquos HSEQ Department maintains links to current statutory documents (Acts Regulations and Codes of
Practice) in the HSE Legal and Other Obligations Directories which are located on Georgioursquos Intranet
(GENIE)Georgiou subscribes to Environmental Essentials product Envirolaw which is available to all personnel
through the intranet link Envirolaw summarises environmental legal obligations provides links to legislation and
guidelines as well as providing search capabilities
Changes in legislation are monitored by the HSEQ Department and site management will be notified where a change
affects a site The Project Manager will be responsible for communicating changes in accordance with section 7
HSE will ensure the change is reflected in this Management Plan and other relevant plans and documents as
applicable
Objectives amp Targets
Objectives and targets have been set for the site taking into account the significant hazards and environmental
aspects of the job the group objectives and client and contractual requirements These are documented in the
table below
Item Description Measurement Target
1 Successful implementation of CEMP and contract requirements
Audits inspections reporting management reviews
0 NCRs associated with CEMP implementation
2 Compliance with all legal requirements Audits reporting management reviews
0 regulatory infringements (PINs or prosecutions)
3 Engage with the affected and broader community minimise complaints and respond to any complaints within a suitable timeframe
Review complaints register reporting audits
0 NCRs associated with CCS implementation
4 Environmental incidents with the potential to cause material harm to the environment
Number of material harm incidents 0
5 Continuously improve environmental performance
Regular environmental inspections
Regular Leadership visits
Share environmental best practice and innovations across projects
1 environmental inspection per week
1 Leadership visit per month
1 NSW Environmental meeting per month
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6 Environmental Awareness for all workers
Conduct all Toolboxes and training identified in this CEMP
1 environmental toolbox per month on relevant site issues
Additional objectives and targets may be set specifically for activities identified for upcoming works Performance
against all HSE objectives will be monitored as a minimum monthly at site meetings
6 STRUCTURE AND RESPONSIBILITIES
Organisational Structure
The site organisational structure has been documented in the Site Organisational Chart The Site Organisational
Chart identifies the roles that will support the site in fulfilling their HSE responsibilities
Roles and Responsibilities and Authority
The Project Manager is accountable for the environmental performance of the project and the implementation of
the projectrsquos management plans Key personnel and their site responsibilities are detailed below
Project Manager ndash Brad Collins
The environmental responsibilities of the Project Manager include (but are not limited to) the following
Ensure all works comply with relevant regulatory and Project requirements Ensure the requirements of this CEMP are fully implemented and in particular that environmental
requirements are not secondary to other construction requirements Endorse and support the environmental policy Be aware of their environmental responsibilities as detailed in the management plans Actively ensure that subcontractors and suppliers are complying with environmental requirements Liaise with the client and other government authorities as required Participate and provide guidance in the regular review of this CEMP and supporting documentation Provide adequate resources (personnel financial and technological) to ensure effective development
implementation and maintenance of this CEMP Ensure that all personnel receive appropriate induction training including details of the environmental and
community requirements Ensure that complaints are investigated to ensure effective resolution Stop work immediately if an unacceptable impact on the environment is likely to occur Hold monthly HSEQ management meetings to review environmental performance and monitor
implementation and effectiveness of the management system Ensure their direct reports fulfil their environmental responsibilities and achievement of KPIrsquos Support workers to immediately stop any lsquoat risk behaviourrsquo identified during their work activities
Project Site Engineer ndash Richard Kelly
The environmental responsibilities of the Project engineers include (but are not limited to) the following
Provide input into the preparation of environmental planning documents as required Ensure that instructions are issued and adequate information provided to employees that relate to
environmental risks on-site Ensure that the works are carried out in accordance with the requirements of the CEMP and supporting
documentation including the implementation of all environmental controls Identify any environmental risks Identify resource needs for implementation of CEMP requirements and related documents Ensure that complaints are investigated to ensure effective resolution
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Take action in the event of an emergency and allocate the required resources to minimise the environmental impact
Report any activity that has resulted or has the potential to result in an environmental incident immediately to the Supervisor and Environmental Site Representative
Supervisor ndash Eddie Storer
The Supervisor is responsible for creating an exemplary HSE culture and ensuring adherence to the Management System on their site The Supervisor is responsible for approving the commencement of works and to allocate necessary resources to complete a job safely in accordance with the Management Plan and will
Demonstrate commitment to the Environment by monitoring the workplace to ensure work practices are adhered to by way of routine checks of the workplace compliance to the Management Plan
Demonstrating through their actions and behaviour that safety and the environment are core values Hold Supervisors and leading hands (Georgiou amp subcontractors) accountable for the fulfilment of their
Environmental responsibilities including KPIrsquos Be given the authority and independence to require reasonable steps be taken to avoid or minimise
unintended or adverse environmental impacts Allocating work to ensure appropriate supervision for those with lesser experience Ensuring appropriate and necessary plant and equipment is provided for workers to carry out their work
safely and without undue harm to the environment Stopping rejecting or quarantining materials plant and equipment Supporting workers to immediately stop any lsquoAt Risk Behaviourrsquo identified during their work activities Participating in audits investigations and constructability reviews Management and HSE performance of the subcontractors utilised on site
Environmental Site Representative ndash Chloe Redman
The environmental responsibilities of the Environmental Site Representative include (but are not limited to)
overall responsibility for the implementation of environmental matters on the Project development implementation monitoring and updating of the EMP and sub-plans in accordance with
ISO14001 report to the Project Manager on the performance and implementation of the CEMP to ensure management
reviews of the CEMP are undertaken annually documented and actions implemented ensure environmental risks of the Project are identified and appropriate mitigation measures implemented identify where environmental measures are not meeting the targets set and where improvement can be
achieved ensure environmental protocols are in place and managed ensure environmental compliance obtain and update all environmental licences approvals and permits as required liaise with the approval authorities manage environmental document control reporting inductions and training manage environmental reporting within the Project team and to the Client and regulatory authorities prepare reports on a monthly basis outlining the Project works undertaken and the achievements that have
been met as well as identifying those areas where improvements were made oversee site monitoring inspections and audits manage all sub-contractors and consultants with regard to environmental matters including assessing their
environmental capabilities and overseeing the submission of their environmental documents develop and facilitate induction toolbox talks and other training programs regarding environmental
requirements for all site personnel notify the client and relevant authorities in the event of an environmental incident and manage close-out of
these stop activities where there is an actual or immediate risk of harm to the environment or to prevent
environmental non-conformities and advise the Project Manager and Supervisor assist the Community Relations Manager to resolve environment-related complaints
undertake site inspections carry out monitoring activities and complete site checklists ensure monitoring records are appropriately maintained reviewed and any non-compliance issues addressed assist in identifying environmental risks
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advise the Project Manager of the need to stop work immediately if an unacceptable impact on the environment is likely to occur or to require other reasonable steps to be taken by the site Construction staff to avoid or minimise impacts
Environmental Consultants
Georgiou has engaged consultancy contracts with the following companies
Ade Consulting - Contaminated land and hygienist services VMS ndash Noise and Vibration Management Services ARTEFACT ndash Archaeological and Heritage Consultants
Throughout the works there may be the requirement to engage other specialist environmental consultants or change the consultants listed above All Environmental consultants engaged to provide specialist advice on environmental matters are responsible to
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the Supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Adhering to all permit requirements Complying with all statutory and regulatory requirements
All Personnel
All personnel on site are responsible for
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident undertake remedial action as required to ensure environmental controls are maintained in good working
order Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Participating and adhering to SWIrsquos and JHArsquos Adhering to all permit requirements Immediately stopping any lsquoAt Risk Behaviourrsquo identified during daily work activities Complying with statutory and regulatory requirements
Communication and Acceptance of Accountabilities and Responsibilities
The Core Site Team will acknowledge their understanding and acceptance of the site accountabilities and
responsibilities by signing Appendix 1 in this plan
Field Leadership Visits
Senior Management with an operational role or functional support will demonstrate visible and proactive commitment by visiting site to engage in discussion with site management and workers in regard to HSE issues relevant to the business which may include any of the following
Active participation and contribution in Pre-start meetings Participation in Toolbox Talks Participation in the delivery of site safety and environmental messages on-site HSE programs or initiatives Participation in work inspections One-on-one discussions
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Behavioural observations Participation in monthly meetings discussing HSEQ performance
A record of the visit and the activity undertaken by the Senior Manager will be recorded and where appropriate feedback provided to the Site team A component of the Site Leadership visit will involve an environmental inspection of the site in accordance with section 151
7 COMMUNICATION AND CONSULTATION
The following documents provide further information in regards to this topic
HSEQ Communication and Consultation Standard
Community Relationship Management Guideline
Resolution of HSE Issues Procedure
Internal Communication and Consultation
Communication and consultative arrangements will be put in place to provide workers including subcontractors
with information and an opportunity to contribute to HSE and comply with applicable legislative requirements
The Site will use the methods detailed below to communicate to employees subcontractors and visitors
information in regard to the Georgiou Management System this management plan performance and environmental
issues
711 Inductions
All personnel (including sub-contractors) are required to attend a compulsory site induction that includes an
environmental component prior to commencement on-site This is undertaken to ensure all personnel involved in
the Project are aware of the requirements of the CEMP The environmental component of the induction must cover
all elements of the CEMP and will include as a minimum
relevant details of the CEMP including all sub-plans procedures and strategies their purpose and objectives
policies and KPIs
Requirements of due diligence and duty of care
relevant legislation and conditions of environmental licences permits and approvals
Potential environmental emergencies on-site and the emergency response procedures
Reporting and notification requirements for pollution and other environmental incidents
key environmental issues
Mitigation measures for the control of environmental issues
Complaints response and reporting
Communication protocols for interactions with community and stakeholders
site specific environmental management requirements and responsibilities
Incident and emergency response and reporting requirements
Environmentally sensitive locations and no-goexclusion zones
Erosion and sediment controls water quality controls and sediment basin management
Management of contaminated material (including asbestos impacted material)
Location of identified potential contaminated land sites
Signs of contaminated soil including visual asbestos identification protocols
Procedure for unexpected finds of contaminated land asbestos
Water quality management and protection measures
Location of identified Aboriginal and non-Aboriginal archaeological heritage sites areas of cultural sensitivity
and areas of archaeological potential and the kinds of historical relics structures or deposits which may be
encountered during the Construction works
Unexpected finds procedures for heritage
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noise vibration and air quality management controls
Standard Construction hours and the process for seeking approval for out of hours works including consultation
Road occupancy and other temporary and interim traffic arrangements
Specific responsibilities for the protection of flora and fauna
A record of all environment inductions will be maintained in a Project induction and training Register and kept on-
site The training register will identify who is trained when trained the trainer and what they were trained in
712 HSE Notice Boards
All worksites that have a crib room will set up a HSE notice board to display
Project HSEQ Performance Report
Environmental BulletinsAlerts
Site HSEQ Objectives and Targets
Organisational Chart
A Site Layout Plan and Emergency Evacuation Plan Emergency contacts and First Aiders list These will also be
posted in prominent locations throughout the site as described in the site Emergency Response Management
Plan
Risk Registers
713 HSE Alerts Bulletins
Incident Alerts will be used to communicate learningrsquos and actions required to assist in ensuring incidents that have
occurred in one workplace are not repeated in others HSE Bulletins will be used to communicate environmental
information to the workplace HSE Alerts and Bulletins will be developed by the Site Team using the approved
templates and approved by the HSE Business Unit Lead prior to communication
714 Site Meetings
The following meetings will be held on site to monitor implementation of the Georgiou Management System review
performance and communicate consult with workers in regards to HSE
Site Meetings (refer to section 142) Pre-Start Meetings Toolbox Meetings
Meeting agenda and minutes will be recorded maintained and be made available when required
Community and Stakeholder Involvement
A Community Communication Strategy will be developed for the project Key elements of the Community
Communication Strategy which will be implemented at appropriate times in the construction process will include
Notification (including targeted letterbox drops and email) of any works that may disturb local residents and businesses (such as noisy activities and night works) at least seven days prior to those works commencing
Notification (including targeted letterbox drops and email) of works that may affect transport (such as road closures changes to pedestrian routes and changes to bus stops)
Traffic alerts (via email) to all key traffic and transport stakeholders advising of any changes to access and local traffic arrangements (at least seven days prior to significant events)
Print and radio advertisements regarding major traffic changes 24-hour toll-free community project information phone line Complaints management Community information sessions as required Regular updates to the Sydney Metro website (sydneymetroinfo) including uploading of all relevant
documents and contact details for the stakeholder and community relations team
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Provision of information to the Sydney Metro Community Information Centre including community newsletters information brochures and fact sheets and interactive web-based activities
Clear signage at the construction sites Newspaper advertisements in local and metropolitan papers as required Regular inter-agency group meetings Community business and stakeholder satisfaction surveys and feedback forms Translator and interpreter services and The project team will liaise with the Sydney Metro Project Communications team as the point of contact for
the community
721 Complaints Management
Community liaison and complaints handling will be undertaken in accordance with the Construction Complaints
Management System and will include
dealing with complaints in a responsive manner so that stakeholdersrsquo concerns are managed effectively and promptly and
A verbal response will be provided to the complainant as soon as possible and within a maximum of two hours from the time of the complaint (unless the complainant requests otherwise) A detailed written response will then be provided if required to the complainant within one week
A complaints register will be maintained in Georgioursquos BEAKON database and in Sydney Metrorsquos Consultation
Manager TM which will contain
Date and time of complaint Method by which the complaint was made (telephone letter meeting etc) Name address and contact telephone number of complainant (if no such details were provided a note to that
effect) Nature of complaint Action taken in response including follow up contact with the complainant Any monitoring to confirm that the complaint has been satisfactorily resolved If no action was taken the reasons why no action was taken
The project will apply an adaptive approach to ensure that corrective actions are applied in consultation with the
appropriate construction staff to allow improvements in the management of issues resulting in community
complaints
722 Urban Design of temporary works
Temporary construction works will consider urban design and visual impacts including
Minimise impacts on existing landscape features as far as feasible and reasonable Artwork graphics and images to enhance the visual appearance of temporary works in high visibility locations Project information to raise awareness on benefits explain the proposed works at each site and provide
updates on construction progress Community information including contact numbers for enquiries complaints Signage and information to mitigate impacts on local businesses which may be obscured by the construction site Sydney Metro advertising public awareness campaigns Logos branding including Sydney Metro NSW Government and Contractor branding
The design of all temporary works will require Sydney Metro approval in relation to urban design and visual impacts
and Sydney Metro will stipulate the design of hording artwork including
Sydney Metro advertising public awareness campaigns and Logos branding including Sydney Metro NSW Government and Contractor branding
Construction hoardings scaffolding and acoustic sheds will be regularly inspected and kept clean and free of dust
build up Graffiti on construction hoardings scaffolding or acoustic sheds will be removed or painted over
promptly The principles of Crime Prevention Through Environmental Design will be applied to all works including
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CEMP Bays Road Relocation Works
temporary works that have a public interface
723 Business and Property Impacts
The project footprint is within any area managed by the Port Authority of NSW and several port related facilities
are adjacent to the work including Cement Australia Gypsum Resources Australia and Sugar Australia Georgiou will
undertake works to meet the following objectives
Minimise the potential impact of the project to businesses affected by construction works Ensure businesses are kept informed of the project and consulted in advance of major works or factors that are
likely to have a direct impact Ensure that business stakeholder enquiries and complaints regarding the project are managed and resolved
effectively
Consult with all business directly affected by changes to access arrangements regarding specific requirements at least two weeks prior to those changes coming into effect
8 HAZARD IDENTIFICATION AND RISK CONTROL
The following documents provide further information in regards to this topic
HSEQ Risk and Operational Control Standard Job Hazard Analysis (JHA) Procedure Permit to Work Procedure
Hierarchy of Control
The following hierarchy of control will be applied to controlling environmental risks and environmental aspects
within Georgiou This hierarchy recognises that the best controls act on the environment not on the people in it
HazardsAspects
Waste
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Site Environmental Risk Analysis
The Site Team has undertaken a construction risk assessment workshop (CRAW) and developed a HSEQ Risk
Register based on the Master Risk Register which incorporates the Companyrsquos mandatory controls and additional
site specific hazards and controls identified in the CRAW This Management Plan and the Emergency Response
Management Plan have been based upon this HSEQ Risk Register
Works on site will be undertaken in accordance with the HSEQ Risk Register The HSEQ Risk Register will be
made available to workers
Review of Risks
The aspects within the HSEQ Risk Register will be reviewed for adequacy
At site meetings Prior to the commencement of any new construction work that involves high impact risks After a significant incident
If there is a change made to the construction methodology and associated change in the risks and controls associated with the works the Risk register and Construction Environmental Management Plan will be updated as appropriate
831 Change Management
The following documents provide further information in regards to this topic
Change Management Procedure
Where there is a change to the planned scope design or construction methodology (including plant machinery
materials or sequence) the impact of the change must be assessed and a determination on whether the Change
Management Procedure applies If so then a formal analysis of the change will be undertaken using the
Management of Change Event Design Form
Changes to the project may require an assessment to determine consistency with the REF and Environmental
Documents The assessment will include
A description of the existing surrounding environment Details of the ancillary works and construction activities required to be carried out including the hours of works An assessment of the environmental impacts of the works including but not necessarily limited to traffic
noise and vibration air quality soil and water ecology and heritage Details of mitigation measures and monitoring specific to the works that would be implemented to minimise
environmental impacts Identification of the timing for completion of the construction works and how the sites would be reinstated
(including any necessary rehabilitation)
Operational Control
Operations and activities associated with significant environmental aspects will be planned to ensure they are
carried out under specific operating conditions An Environmental Control Map (ECM) Safe Work Method
Statements Job Hazard Analysis Take Five Hazard Report or a combination of these will be used to achieve this
requirement
841 Environmental Hazard Reporting
Environmental Hazard reporting will be conducted using the Hazard Report (contained within the Hazard
ReportTake 5 booklet)
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The Supervisor is responsible for ensuring environmental hazards are addressed in a timely manner using the
hierarchy of control and communicated to those who may be potentially affected Where hazards cannot be
addressed immediately and additional controls are required they are to be reported into the Beakon system for
follow-up and close-out
842 Take 5
Take 5 booklets will be available to all workers to perform risk assessments for work that is not high risk
construction Take 5 risk assessments include environmental aspects and the identified environmental controls for
these risks are to be documented on the Take 5 form and implemented for the works
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS)
JHASWMS will be completed for all high risk construction work JHASWMS developed will reflect the safety and
environmental risks and controls identified in the sites risk register and supporting work instructions
Subcontractors will be provided access to the sites HSEQ Risk Register and prior to undertaking the work will be
required to submit their JHArsquosSWMS to Georgiou for review and approval using the Subcontractor JHASWMS
Assessment (available in Beakon)
844 Permit to Work
The following high risk activities require written authority in the form of a ldquopermit to workrdquo from the Georgiou Site
Team
Vegetation Clearing Permit (Georgiou form) Dewatering Permit (Georgiou form) Out of Hours application (Sydney Metro form)
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices) will be included in the
environmental permits No work involving these activities will commence until the appropriate permit has been
completed Personrsquos issuing permits on the Site will be given training in the Georgiou Permit to Work system A
permit may be required for other high risk activities as determined by risk assessment the Sitersquos Manager andor
contractual requirements
845 Environmental Control Maps
To assist pre-construction planning and on-site construction management the environmental site constraints are
consolidated on a series of map-based sheets that extend the length of the Project Environmental Control maps
include information pertaining but not limited to
Noise and vibration sensitive receiverrsquos eg residential dwellings
Flora features including threatened species and endangered ecological communities
Aboriginal and non-Aboriginal heritage sites including items places objects and sites
Local waterways
Recorded threatened fauna sightings
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices)
The Environmental Control maps are a working element of the CEMP and will be revised throughout construction to
reflect true ground conditions and the most up-to-date information available on sensitive sites Sensitive area maps
will be used in conjunction with EWMS and ESCPs to help identify key risk areas and to promote ongoing
communication to construction personnel during the Project
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9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT
The following environment aspects have been identified as significant for this project Risks associated with these
significant aspects and appropriate controls have been identified during the construction risk assessment workshop
(CRAW) and included in the HSEQ Risk Register in accordance with section 82
In addition aspect specific sub-plans within this CEMP have been developed to detail how the environmental
aspects will be managed to comply with relevant legislation amp client requirements These aspect specific sub plans
include
Waste
Soil and Water
Hydrocarbon and Chemical
Cultural Heritage
Air Quality and Dust
Noise and Vibration
Contamination
10 CLOSURE AND COMMISSIONING
At completion of this project Georgiou will hand over the site in an environmentally responsible state) taking into
account the nature of the works in accordance with legislative amp contractual requirements
11 TRAINING COMPETENCY AND RESOURCING
All Georgiou personnel and contractors will undergo environmental training before commencing works on site
Training will be undertaken in the following forms
project site induction (section 711) and Environmental awareness training through regular tool box discussions Inductees will be required to sign-off that they have been informed of the environmental issues and that they
understand their responsibilities
1111 Toolbox talks
ldquoToolboxrdquo training will help to ensure that relevant information is communicated to the workforce and that
feedback can be provided on issues of interest or concern ldquoToolboxrdquo training will generally be prepared and
delivered by the Project Engineers Site Foreman or HSE Advisor Toolbox training topics are to be delivered to
provide refresher information on the environmental induction topics and associated environmental procedures In
the event of environmental near misses or incidents or changes to procedures that could result in changed levels of
environmental risks Toolbox talks may be used to deliver updates
Toolbox topics likely to be required include
work methods and efficient use of plant and materials waste management minimisation and recycling dust control protecting waterways spills and leaks emergency response procedures wet weather procedures and inspections and Legislation updates Please refer to the Toolbox schedule for a library of HSE toolboxes to deliver over the life of the project
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1112 Recording of Training and Assessment
Records of training and assessment will be maintained and will be readily available for verification Records of
induction and training will include the topic of the training carried out dates names and trainer details
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE
The following documents provide further information in regard to this topic
Emergency Preparedness and Response Standard
EmergencyIncident Planning and Control
The site has in place an Emergency Response Management Plan (ERMP) that addresses emergency response control
and recovery based upon credible emergency scenarios as identified in the Site Risk Register The Emergency
Response Management Plan has been developed in accordance with Emergency Preparedness and Standard
13 HSE REPORTING AND INVESTIGATION
The following documents provide further information in regard to this topic
Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
Notifications and Reporting
The Project Manager is accountable for ensuring all necessary reporting and notifications take place including
Client notification Statutory notification Scheme notification Community Complaints
Notifications and reporting regarding incidents will be done in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure
1311 Internal
The Environmental Site Representative or their delegate will be responsible for reporting all incidents into Beakon
database Incidents reported into Beakon will be reviewed by the Responsible Manager and approved within five
working days or before month end in which the incident occurred
1312 Notification of Incidents to Sydney Metro
Sydney Metro will be notified of any Georgiou environmental incident as soon as reasonably practicable Copies of
the incident reports and investigations incident will be made available to Sydney Metro within 48 hours in
accordance with the Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
1313 Statutory Notifications
An incident is an uncontrolled event or violation with serious or potentially serious negative consequences to
people property reputation or the environment Under Section 148 of the Protection of the Environment
Operations Act 1997 (POEO Act) Georgiou has a duty to immediately report pollution incidents causing or
threatening material harm to the environment Material harm is defined in Section 147 of the POEO Act as
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lsquoinvolves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding
$10000 and this loss includes the reasonable costs and expenses that would be incurred in taking all reasonable
and practicable measures to prevent mitigate or make good harm to the environmentrsquo
Investigations
Investigations regarding the incident will be completed in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure and commence as soon as practicable (preferably
immediately) but within 24 hours
All environmental incidents would be investigated in such a manner that the following basic elements can be
established
identifying the cause extent and responsibility of the incident
identifying and implementing the necessary corrective action
identifying the personnel responsible for carrying out the corrective action
implementing or modifying controls necessary to avoid a repeat occurrence of the incident
recording any changes in written procedures required and
Advising regulatory authorities in accordance with licence conditions
Review and Communication of Incidents
Incidents will be reviewed to check that causal factors and root causes were identified and that the findings have
been effectively addressed through assignment of actions at the
Site monthly meetings Business Unit meetings OHS Committee Meeting (if established)
Actual and potential class 1 incidents will be reviewed by senior management to ensure adequacy of closeout HSE
incidents and their preventative actionslearnings will be communicated at pre-start meetings toolbox meetings
and through HSE alertsbulletins as per section 7
14 ENVIRONMENTAL REPORTING
1411 Monthly Reports
Georgiou is required to submit an Environmental Monthly Report to the client including the information specified
below as evidence of implementation of the Environmental Management Plan
Implementation of environmental management including environmental monitoring implementation of environmental controls training inspections and testing
Implementation of incident management including emergency response - details of all environmental incidents or emergencies including non-compliance with environmental procedures and near misses complaints implementation of incident and emergency response management and implementation of corrective action
Implementation of reviews - details of internal reviews audits and inspections undertaken to verify that on-site environmental processes and practices conform to the Environmental Management Plan
Waste Statistics and NGERs reporting
Site Meetings
The Site will hold a monthly HSEQ Management Meeting in accordance with the Health amp Safety Management Plan
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Project Performance Review
At completion of the Project the Project Manager is responsible for arranging a review of project performance
which will include HSE management performance and lessons learnt for the purpose of continually improving
Georgiou Management Systems This review will be in accordance with the Project Close-Out Procedure
15 AUDITING REVIEWS AND INSPECTIONS
The following documents provide further information in regards to this topic
Auditing Reviews and Inspections Standard
Inspections
1511 Environmental Inspections
The following inspections will take place on site
Environmental Weekly Inspections Detailed Hazard Inspections considering timingavailability of activities Site leadership field visits These inspections will be used a process to monitor onsite environmental performance and they will cover all applied environmental mitigation measures including water quality erosion and sediment control structures fuel and chemical storage and waste management Attendees for the inspections can include Sydney Metro Environmental and project team members Georgiou Environmental and project team members and Georgiou Senior and Executive Management when conducting a Field Leadership Visit (section 64) The Environmental Site Representative will record inspection findings on the inspection report If any maintenance andor deficiencies in environmental controls or in the standard of environmental performance are observed they will be recorded on the inspection Records will also include details of any maintenance required the nature of the deficiency any actions required and an implementation priority Any Sydney Metro Environmental Inspections will occur on the Sydney Metro Inspection record template ndash Appendix 10
Audits and Reviews
The following audits are scheduled for this site
Internal
AuditReview
Purpose Commencement On-going requirement
Site HSE Mobilisation Audit
Review achievement towards site start-up activities
8 weeks after mobilisation NA
Internal HSEQ audit
Determine compliance to the management systems and an assessment as the effectiveness of those requirements to meet our legal and other obligations
Within 6 months of project start up
6 monthly
Sydney Metro (or an independent environmental auditor) Audit
EampSMS and compliance with the environmental aspects of contract documentation including Construction Environmental Management Framework
Construction Periodic
to be confirmed
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The Project Environmental Site Representative will be the principal contact for external auditors wishing to audit
the Sitersquos environmental management systems The Project Environmental Site Representative will be responsible
for responding to any external audits findings
Monitoring
Environment monitoring will be undertaken to validate the impacts predicted for the Project The monitoring
requirements for required aspects are included in the relevant environmental management sub-plans (Appendices)
All environmental monitoring equipment shall be maintained and calibrated according to manufacturerrsquos
specifications and appropriate records kept
Where monitoring results are outside of the expected range and are directly attributable to the Project (ie are
influenced by factors under the direct control of the Project eg noise from construction equipment) the process
described below will occur
An analysis of the results by the Environmental Site Representative in more detail with a view of determining possible causes for the non-conformance
A site inspection by the Environmental Site Representative or delegate Advising relevant personnel of the problem Identifying and agreeing on actions to resolve or mitigate the non-conformance Implementing actions to rectify or mitigate the non-conformance
Corrective Actions
Corrective actions identified through hazards inspections incidents auditing will be recorded in Beakon Close out of corrective actions are monitored through Site meetings and reported to senior management through the monthly and quarterly board reports
16 DOCUMENT AND RECORD CONTROL
Georgioursquos Health Safety and Environment Policies Standards Procedures Safe Work Instructions References
Guidelines Forms Templates are all accessible via the Companyrsquos Intranet - GENIE GENIE will maintain the
current and only authorised versions for use
Environment Management documentation that has been specifically developed for the site will be controlled on site
and recorded on the Site Document Register in accordance with the Site Quality Management Plan
The Project Manager is the owner of this plan and will apply change control to ensure the most recent plans are
approved and executed
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17 APPENDICES
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Appendix 1 - Waste Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise spoil generation where possible The project will mandate 100 reuse or recycling (on or off-site) of usable spoil Spoil will be managed with consideration to minimising adverse traffic and transport related issues Spoil will be managed to avoid contamination of land or water Spoil will be managed with consideration of the impacts on residents and other sensitive receivers Site contamination will be effectively managed to limit the potential risk to human health and the environment Minimise waste throughout the project life-cycle Avoidance of unnecessary resource consumption Resource recovery (including reuse reprocessing recycling and energy recovery) and Disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Project Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Training and Competency
As part of the Site Induction workers will be informed of
- The types of waste generated on site
- How the wastes are to be handled stored and disposed of Personnel responsible for clean-up of spills will be provided with instruction on how to use the sites
spill kits Personnel handling hazardous materials will be provided training to read and understand the SDS
Project Manager
Unidentified Waste Wastes that cannot be positively identified (ie unlabelled liquids potential asbestos) will be tested
before handling and disposal Any material that is unknown should be considered hazardous until positively identified
Project Engineer
Handling
Where practicable dust generating rubbish and debris will be removed to minimise dust release into the atmosphere
Handling of waste will be done in accordance with relevant state or local by-laws using suitable personal protective equipment
Project Engineer
Storage
Containers used for storage are not to be opened handled transported or stored in a manner that may rupture the container
All waste will be stored in waste receptacles and removed off site by a licensed contractor on a periodic basis
Dedicated recyclable and hazardous receptacles will be labelled Wastes stored on site will be stored in a manner to prevent the attraction of vermin and native
wildlife Waste is to be stored away from access and egress routes
All
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CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
The quantity and volume of wastes stored on site may be minimised where reasonably practical to reduce the risk to health safety and the Environment
Project Managers will be responsible for identifying and obtaining any required licenses andor permits to store wastes
Disposal
In deciding how to dispose of waste generated on site consideration will be given to reducing reusing or recycling waste where reasonably practical to minimize the volume sent to landfill Where reuse or recycling is not a feasible option the waste will be sent to a facility capable of accepting the waste
The burning of any type of wastes will not be permitted on any Georgiou site The use of stormwater drains for the disposal of waste is prohibited The disposal of waste will be done in a manner to prevent any damage to the environment
Project Engineer
Transportation
The removal and transportation of hazardous waste controlled waste (eg asbestos hydrocarbons and sewage) for disposal will only be conducted by licensed carriers Licensed operators will be engaged in accordance with the Procurement Procedure
Before a hazardous waste controlled waste is transported off site a waste tracking receipt will be collected from the operator as verification that the waste was correctly transported off site and to identify the proposed location for disposal The receipt will be scanned and filed into the DMS and linked to the Site Waste Register A copy of the receipt will be held for a minimum of 3 years
The transportation of other wastes for disposal will only be conducted if the load is covered or there is no risk of loaddebris falling and the load is disposed of at a registered landfill
Project Manager
Spoil
Although the Project would require the importation of fill material the excess spoil would be generated including from the following sources
Soils ndash This includes any topsoil and natural subsoils (ie soils between the topsoil and underlying bedrock)
Natural rock ndash This material would be generated from excavation of sandstone bed rock if required Road construction material ndash This would include material generated from the demolition of the
existing roads such as asphalt concrete geotechnically stabilised road sub-base and base material
Project Engineer
Spoil Classification
Spoil generated during the Construction of the Project will be firstly assessed for reuse in the project Should it not be suitable for onsite reuse it will be assessed in accordance with the Sydney Metro Classification Procedure (Appendix 1A) It will firstly be assessed against the requirements for Virgin Excavated Natural Material (VENM) detailed within the Protection of the Environment Operations Act 1997(POEO Act)
Project Engineer
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CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
If the material is not deemed to be VENM an assessment of the suitability of any current general resource recovery exemptions issued under the Protection of the Environment Operations (Waste) Regulation 2014 will be undertaken Current general resource recovery exemptions that may apply to the Project are
The excavated natural material exemption 2014 The excavated public road material exemption 2014 Spoil that cannot be re-used onsite or offsite under any of the exemptions stated above or classified as VENM will require waste classification in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (EPA 2014) prior to offsite disposal at an appropriately licensed facility
The management of spoil generated from the Project will be guided by the hierarchy detailed below
Rank Control Measure Implementation Example Potential to implement on Project
1 Avoid and reduce spoil
generation Reduce the amount of spoil being
generated through design and construction methodology
Limited
2 Prioritise reuse of contaminated
spoil onsite vs clean spoil Identify areas with lower risk of
contamination to spoil offsite as this will result in lower waste disposal costs for project
GSW and Contaminated Spoil is to
be utilised as fill on the project
prior to the use of excavated
sandstoneVENM The project will
produce excess spoil and the
priority is for this excess to be
sandstoneVENM
3 Reuse within Project Prioritise reuse of more contaminated
spoil onsite vs less contaminated spoil Reuse in the Project to fill
embankments and mounds within short haulage distance of source
Restoration of any pre-existing contaminated sites within the Project boundaries
Reuse as a feed product in Construction materials (eg concrete)
Preferred but dependant on area
available
Project Manager Project Engineer Project Engineer
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CEMP Bays Road Relocation Works
Appendix 1 - Waste Management Sub Plan Responsibility
4 Reuse for environmental works Reuse in revegetation and
rehabilitation projects Reuse in operational noise mitigation
works
Preferred as stockpiling on site is
restricted
5 Reuse on other development
projects Reuse for fill embankments and
mounds on projects within an economic transport distance from site
Preferred as stockpiling on site is
restricted
6 Reuse for land restoration Reuse for land reclamation or
remediation works Reuse to fill disused facilities eg
mines and quarries to enable ecological rehabilitation or other ecologically beneficial end use
Preferred as stockpiling on site is
restricted
7 Reuse for landfill management Reuse to cap completed landfill cells Reuse in daily covering of landfill
waste
Limited
8 Dispose offsite as waste Disposal of excess spoil as waste at an
approved facility licensed to receive that material
Potential but not preferred
Hazardous Waste - General
Hazardous wastes will be stored in sealed containers where practical and clearly labelled with waste type
Hazardous waste receptacles will be maintained in good condition to prevent leaks or spills Offensive odours should not be generated at any time when stored Hazardous wastes with a significant risk to human health and safety will be stored in containers that
comply with relevant legislation and guidelines Hazardous wastes will not be permitted to accumulate to a level that presents an unreasonable risk
to human health safety or the environment Controlled waste storage will be suitably contained to ensure debris does not travel beyond the boundary of the premise
Hazardous waste will be stored and segregated in accordance with their SDS Hazardous waste will be risk assessed to ensure they do not contaminate or interact with goods that are incompatible Where there may be a risk of fire hazardous waste will be segregated to prevent storage incompatibilities
Hazardous liquid waste will not be permitted to enter the environment
All
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Appendix 1 - Waste Management Sub Plan Responsibility
Design considerations for secondary containment will be given to the storage of liquid wastes to contain any potential spills Hazardous waste will be stored onin bunded palletsareas which will be compliant with AS1940-2004 443 (the bunded palletarea must have the capacity to contain 110 of the largest container
Hazardous waste such as batteries hydrocarbons sewage and asbestos will only be handled for final disposal recycling by certified waste removing contractors Sewage waste not plumbed directly into the main sewerage system will be contained within holding tanks on site compounds and emptied on a periodic basis or as required by a licenced contractor
Hazardous Waste - Batteries
Automotive and lead-based batteries will be stored in a manner that does not contaminate the natural surrounding environment This may include storage on bunded palletsareas on concrete hard stand or on any other sealed surface
All
Hazardous Waste - Asbestos
The disposal processes for asbestos will involve independent competent persons Identified ACM (Asbestos Contaminated Material) will be clearly marked out and controls put in place
to prevent contamination into surrounding areas
Project Manager
Hazardous Waste - Sanitary Sewage Waste
Sewage waste will either be plumbed directly into the main sewerage system or contained within holding tanks on site compounds and emptied as required
Sewage waste stored in bunded tanks underneath the toilets will be emptied by a licensed contractor on a periodic basis
Sanitary wastes will be stored in solid containers and clearly labelled for identification Sanitary wastes will not be re-handled after disposal to minimise the exposure and risk of double
handling Sanitary conveniences will be calculated based on the number of workers based on the site and meet
legislative requirements Sanitary waste will be stored away from food sources or where food is served Controls to prevent offensive odours to the public and workers will be implemented
Project Engineer
Recyclable Waste
On site paper and cardboard and scrap metal will be segregated to be collected and transported to a recycling facility
Green waste will be mulched and stockpiled with topsoil for use in revegetation Aggregate will be segregated during cut and fill operations for re-use
Project Engineer
Waste Water Any waste water or liquids must be disposed of to an approved receptacle and stored within an approved bunded location until they are removed from site
Project Engineer
Putrescible Waste Putrescibles waste will be stored into general waste containers that prevent the release of debris and leachate
Project Engineer
Clinical Waste In the event that clinical waste has been found the following control may be employed Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
Syringes and needles found on site will be stored in a clearly labelled solid sealed container to prevent access to contents They will be disposed of at a licenced provider
Clinical wastes will not be re-handled after disposal to minimise the exposure and risk of double handling
Concrete
Kibbles Concrete truck are to be washed out into a designated bunded area When the concrete is dried it will be disposed of with general waste
At no point will any Concrete truck or kibble be permitted to wash out at any point other than the designated area with all the associated controls in place
Project Engineer
Weekly (VisualDocumented)
DHI Environment to be completed via Beakon HSE Advisor
Reporting HSEQ Monthly Management Meeting Monitor and record the volumes of waste and the methods and locations of disposal Maintain records of all required waste dockets and receipts and provide to Sydney Metro monthly
Project Manager
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Appendix 1A ndash Sydney Metro Waste Classification Procedure
Unclassified
Unclassified
Waste Classification Procedure
SM-20-00040677
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Hugh Chapman Associate Director Environment Operations Customer amp Place-Making
System Owner Carolyn Riley Director Environment Sustainability amp Planning
Status Final
Version 30
Date of issue Pending
Review date Pending
copy Sydney Metro 2020
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 2 of 14
SM-20-00040677 Waste Classification Procedure V30
Table of contents
1 Introduction 3
11 Purpose and scope 3
12 Definitions 3
13 Spoil Management Decision Framework 5
14 Spoil Handling and Segregation 5
15 Typical Application of the Framework 6
16 Unexpected Finds Protocol 7
17 Accountabilities 14
2 Related documents and references 14
3 Superseded documents 14
4 Document history 14
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 3 of 14
SM-20-00040677 Waste Classification Procedure V30
1 Introduction
11 Purpose and scope
This framework describes the approach to classifying spoil and demolition materials generated during works in accordance with environmental legislation and guidelines
This framework considers the reuse of materials on site the beneficial reuse of materials transported off site as waste (for example as virgin excavated natural material [VENM]) the recycling of materials at offsite facilities and the offsite disposal of materials when reuserecycling is not achievable
The framework considers only the compliance and classification elements of the spoil management process and does not consider all of the practical issues associated with construction geotechnical properties of the spoil or market forces and costs that influence the reuse potential of spoil or other wastes
Section 16 of this framework outlines an Unexpected Find Protocol (UFP) to be implemented should unexpected potential contamination be found during works
12 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined within the SM-17-00000203 Sydney Metro glossary Acronyms specific to this document are listed below
Definitions
2014 Waste Regulation
Protection of the Environment Operations (Waste) Regulation 2014
CLM Act Contaminated Land Management Act 1997
Contamination
As defined in the CLM Act ldquomeans the presence in on or under the land of a substance at a concentration above the concentration at which the substance is normally presenthellipin the same localityhellipthat presents a risk of harm to human health or any other aspect of the environmentrdquo
Demolition materials
Materials such as concrete bricks and timber resulting from the demolition of buildings and structures Most demolition materials are pre-classified as General Solid Waste (non-putrescible) (see definition below) under the NSW EPA (2014) Waste Classification Guidelines However some demolition materials such as asbestos have other classifications as described below
EIS Environmental Impact Statement for the project which assesses potential environmental impacts and mitigation measures in accordance with the EPampA Act (see below)
ENM Excavated Natural Material as defined in The excavated natural material order 2014
being excavated material that is at least 98 (by weight) natural material that does not meet the definition of VENM (see below)
EPA NSW Environment Protection Authority
EPampA Act Environmental Planning amp Assessment Act 1979
EPL
Environment Protection Licence as may be held by an owner or operator of a premise licensed to receive process recover or store waste The EPL will contain a number of conditions that must be met by the holder These will specify the type(s) of waste the facility is permitted to receive process recover or store and include pollution prevention or monitoring requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 4 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Fill Soil and any associated extraneous materials (such as demolition wastes industrial by-products and refuse) imported to and placed at the location
GSW
General Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines GSW may be classified as putrescible or non-putrescible depending on the content of putrescible organic material Spoil and demolition materials are typically non-putrescible
HW
Hazardous Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines HW must be treated prior to disposal to landfill HW is typically
spoil that is contaminated with chemicals at concentrations that exceed all screening criteria specified in Step 5 of the Waste Classification Guidelines
Naturally Occurring Soil
Any soil which has not been significantly disturbed by human activities
NEPM National Environmental Protection (Assessment of Site Contamination) Measure 2013
POEO Act Protection of the Environment Operations Act 1997
Recycling Material that is removed from the project site (thereby becoming Waste) and is deposited at an appropriately licenced recycling facility for processing prior to reuse by others
REF Review of Environment Factors which addresses the likely environmental impacts and details protective measures to manage against any adverse effects in accordance with the EPampA Act
Remediation
As defined in the CLM Act remediation of contaminated land includes
(a) preparing a long-term management plan (if any) for the land and
(b) removing dispersing destroying reducing mitigating or containing the contamination of the land and
(c) eliminating or reducing any hazard arising from the contamination of the land (including by preventing the entry of persons or animals on the land)rdquo
Remediation is the act of mitigating exposure to contamination in its original location The process of remediation can generate spoil that may be subject to reuse within the project area (where that reuse is adequately controlled in order to mitigate exposure risks) or the removal of contaminated spoil for treatment andor disposal off site
Reuse offsite
Material to be reused by application to land at a location outside of the project site without the need for processing prior to reuse Material meeting the definition of VENM or ENM or material that is subject to an RRO and RRO are suitable (from an environmental perspective) for reuse at remote sites where all requirements of the POEO Act and CLM Act are met
Reuse onsite
Material that is excavated on the project site and reused on the project site Material to be reused onsite is not defined as Waste and does not require classification in accordance with NSW EPA (2014) Waste Classification Guidelines The material must be suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and must not cause pollution under the POEO Act If transport to another part of the project area requires material to be taken outside the site boundary temporarily this must be undertaken in accordance with the EIS or following consultation with relevant regulators
RRE Resource Recovery Exemption contains the conditions that must be met by consumers of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RRO Resource Recovery Order contains the conditions that must be met by generators and processors of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RSW Restricted Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines An example of RSW is spoil that is contaminated with chemicals above the criteria specified in Step 5 of the Waste Classification Guidelines
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 5 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Special Waste
As defined in the NSW EPA (2014) Waste Classification Guidelines a class of waste with
unique regulatory requirements Asbestos or any waste containing asbestos (eg spoil containing any fragments of asbestos cement sheeting) is Special Waste If Special Waste is mixed with RSW or HW (eg spoil classified as RSW that also contains asbestos) then the waste must be managed in accordance with both classifications
Spoil Soil or rock material generated from excavation activities
UFP Unexpected Find Protocol
VENM Virgin Excavated Natural Material as defined in Schedule 1 of the POEO Act being excavated natural material not mixed with any other waste and not from a contaminated area
WARR Act Waste Avoidance and Resource Recovery Act 2001
Waste Spoil or demolition material that has been taken off site which may be classified as Special Waste GSW RSW or HW
13 Spoil Management Decision Framework
Figure 1 provides a high-level flowchart for decisions regarding the fate of spoil generated on the site As reflected in Figure 1 the preferred spoil management hierarchy for the project listed from most preferred to least preferred is as follows
1 Spoil is reused within the project boundary
2 Spoil is beneficially reused at an appropriate offsite location
3 Spoil is recycled at an offsite licenced facility
4 Spoil is disposed to landfill
The approach to spoil classification is further detailed in Table 1 Table 1 describes the criteria information inputs and control measures required to be applied when reusing spoil on site reusing spoil offsite recycling spoil offsite or disposing of spoil
The framework does not account for the practical site based engineering or financial constraints associated with the hierarchy These must be addressed during delivery and the most appropriate efficient and sustainable method of spoil management adopted
14 Spoil Handling and Segregation
Careful excavation handling and segregation of spoil is critical to ensuring that materials with varying classifications are not mixed (cross-contaminated) and are not reused recycled or disposed in a manner inconsistent with their classifications
Appropriate segregation is also important in controlling the costs of spoil disposal to landfill noting that the inadvertent mixing of materials with low concentrations of contaminants with materials containing higher concentrations typically results in a higher classification and higher disposal rate (financial) being applied to all of the materials
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 6 of 14
SM-20-00040677 Waste Classification Procedure V30
The following processes are to be applied when excavating handling and segregating all spoil (for clarity a reference to a ldquogeological unitrdquo includes units or different layerstypes of Fill)
Spoil from each geological unit should be classified separately using sampling data that relates only to that unit Classification sampling may be performed in-situ (prior to excavation) or ex-situ (following excavation)
Spoil from each geological unit (as described in Part 4 below) should be excavated segregated and stored separately from spoil arising from other geological units
Excavations should be carefully monitored for visual indications of contamination such as stained soils odorous soils or the presence of anthropogenic waste materials Any spoil containing visual indicators of contamination will be excavated segregated and stored separately from other spoil Where unexpected contamination is identified an appropriate unexpected finds procedure must be implemented to manage potential human health or environmental risk (refer to Part 5)
Each spoil stockpile should be treated as a ldquobatchrdquo with its classification data clearly identifiable and will be handled stored transported and reusedrecycleddisposed as a batch Spoil stockpiles will not be managed in a ldquocontinuousrdquo manner with portions added taken away or mixed over a period of time and
Spoil should be tracked from cradle to grave to ensure a complete and accurate record of movement from the point of excavation to the final point of placement For clarity this includes tracking of spoil movement on the site as well as off the site
Tracking of spoil movement (whether the spoil is waste or not) requires must include written records of spoil excavation handling transport storage and placement via a centralised tracking system Personnel must be suitably trained in the use of the system and sufficient detail must be recorded and retained such that material typesclassifications volumes and location are tracked from the time the material is excavated until it is placed permanently (onsite or offsite) This includes accurate records of any interim handling or placement (such as stockpiling or treatment) Stockpiles onsite are to be clearly labelled at all times Tracking information is to be kept on-site and be available on request
15 Typical Application of the Framework
This section provides some practical guidance in implementing the spoil classification framework (further detailed in the attached Figure 1 and Table 1
An explanation of the likely classification of spoil excavated during works based on typical geological units is provided below
Fill ndash Fill is imported materials which have been placed on the site at some time in the past Fill generally exists at depths ranging up to 3m below ground surface on developed areas and brownfield sites Fill may exist to depths exceeding 20m in reclaimed lands landfill sites former brick pits footings and similar Fill cannot be classified as VENM Fill has an increased likelihood of being contaminated (compared to natural soils) and will predominantly be classifiable for offsite disposal as GSW Special Waste RSW or HW Some materials such as road base or crushed concrete may be recoverable under generic or specific RRERRO arrangements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 7 of 14
SM-20-00040677 Waste Classification Procedure V30
Naturally Occuring Soils ndash Soil which has not been significantly disturbed by human activities Naturally occurring soils may be residual soil sediments aeolian or other In the majority of cases naturally occurring soils will be classifiable as VENM or ENM for offsite reuse However where overlying contamination in Fill has leached and caused contamination of underlying natural soils where point sources of contamination are present (such as industrial facilities or fuel storage facilities) or where significant groundwater contamination has migrated into the area offsite reuse may not be appropriate and other classifications such as GSW RSW or HW may be applicable Where evidence of potential contamination exists spoil is required to be sampled and classified in accordance with NSW EPA (2014) Waste Classification Guidelines
Rock ndash Rock in-situ will in the majority of scenarios be classifiable as VENM or ENM unless significant contamination is present in overlying soils or significant contamination has migrated to the rock within groundwater Where the excavation of rock involves the use of additives (for example to facilitate tunnel boring) the material would no longer be classifiable as VENM or ENM and would instead likely be classifiable as GSW A project specific RRERRO would then be required to allow for offsite reuse
The type of material (ie geological unit) excavated during works will provide guidance on implementing the spoil classification framework in regard to reuse opportunities
Reuse Onsite ndash Any of the material excavated which is Fill a Natural Occurring Soil or Rock may be suitable for reuse on the project site Wherever reuse onsite is to occur the material does not require classification in accordance with the NSW EPA (2014) Waste Classification Guidelines Instead the material must be validated as being suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and the material must not cause pollution under the POEO Act For clarity the classifications GSW RSW and HW have no direct relationship to the potential for reuse of materials on the project site
Reuse Offsite ndash With the exception of Fill it is likely that the majority of spoil will be suitable from an environmental perspective for reuse off-site Specifically all VENM ENM and material to which an RRERRO apply will be suitable (from a legislative and environmental perspective) for reuse at an offsite location
16 Unexpected Finds Protocol
This section provides guidance on implementing the Unexpected Finds Protocol (UFP) which is detailed in the attached Figure 2 The purpose of the UFP is to provide a clear procedure in the event of an unexpected find of contamination or potential contamination The UFP is only to be implemented following an unexpected find The handling of known contamination should already be addressed in construction and environmental management plans
Key indicators of potential contamination include (but are not limited to)
Fibrous cement or other asbestos containing materials
Discolouration of soil
Odours from soil andor groundwater
Buried drums or underground storage tanks and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 8 of 14
SM-20-00040677 Waste Classification Procedure V30
Oily sheen on water
Should any of the above be discovered and is considered to be unexpected then the UFP in Figure 2 will need to be implemented
An explanation of key actions within the UFP is provided below
Notifying the Site Supervisor ndash Site Supervisor or an appropriate delegate are to be made aware of the find immediately
Securing the affected area ndash This includes restricting access to the area and implementing appropriate environmental controls around affected area in minimise risk to the environment and human health Examples of controls include barricading the affected area the diversion of water to minimise potential spread via surface water runoff covering the area re-burying andor wet-down Environmental controls are to be implemented appropriately in regard to the contamination source and site conditions
Emergency Response ndash In the event that the find presents andor creates health or environmental concerns which would require an emergency response call 000 andor implement the projects incident response and reporting process
Notify Principal or Sydney Metro ndash The Principalrsquos Representative and the Environmental Representative must be notified of the unexpected find
Recommence works ndash Works can be recommenced in an alternate area where practicable and where it is safe to do so
Assessment ndash The potential for any ongoing risk to the environment or human health during construction or operation of the site and whether or not the agreed scope appropriately manages the contamination will need to be assessed by a competent and qualified person (ie a contaminated land specialist or in the case of asbestos a hygienist or asbestos assessor)
Material Classification ndash Contaminated materials which are to be removed from the site are to be classified in accordance with the NSW EPA Waste Classification Guidelines and the Spoil Classification Framework detailed in this document See Figure 1 and Table 1
An unexpected find may result in additional works being required for the remediation of contaminated materials which fall outside of the current scope of the project Any such works will need to comply will all relevant legislation and guidelines and will require appropriately qualified persons to prepare the methodology and controls Any such works will require approval from Sydney Metro
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 9 of 14
SM-20-00040677 Waste Classification Procedure V30
Spoil classification process flow
Syd
ne
y M
etr
oN
SW
EP
A W
aste
Gu
ide
line
s C
lassific
ation
ndash P
art
1 (
20
14)
Syd
ne
y M
etr
o
Additional inputs or information requirementsProcess
Is there an opportunity to re-use the spoil
on site
Is there an opportunity to use the spoil at
an offsite locat ion
Can the spoil be recycled
The spoil must be classif ied in accordance with the NSW Environmental Protection Authority (EPA) Waste Classification
Guidelines
1) Is the waste Special Waste ie does the waste contain asbestos Refer to the Protection of the Environment Operations
(POEO) Act and Waste Regulation Part 4 Management of Special Waste
2) Is the waste Liquid Waste
3) Is the waste pre-classified
4) Does the waste have hazardous
characteristics
5) Classify by chemical assessment Waste generators must chemically assess their waste in accordance with Step 5 of the Waste
Classification Guidelines to determine the waste s classification where it has not been classified under Steps 1 to 4 of the Guidelines
Re-use onsite Cost time and engineering requirements to be
considered as well as environmental risks before placement
Re-use offsite To allow offsite use the material mist be classifiable
VENM ENM or be subject to Resource Recovery Exemption and Order
No matter the classification the offsite location must conf irm it can legally
accept the spoil
Recycle offsite The spoil must go to a licenced treatment facility and
must meet the specific requirements of that facilities licence
Liquid waste The waste is not spadable andor becomes free-flowing
at or below 60 degrees Celsius or when it is transported
Pre-classified waste Refer to NSW EPA Waste Classif ication guidelines
for pre-classificat ions of Hazardous Wastes General Solid Waste
Dangerous goods Meets Dangerous Goods Classificat ion for classes 1
2 41 42 43 5 61 and 8
The waste has been classified in accordance with the Waste Guidelines and is ready to be transported offsite Prior to transport
the following must be confirmed and all relevant requirements met
Is the landfill or facility licenced to accept the type of waste
Is the waste subject to waste tracking requirements under the POEO Act or any other regulation
Is the transport contractor licenced to carry the waste as classified
6) Is the waste putrescible
Sampling under Step 5 must meet the requirements of the NSW Waste Classification Guidelines
Sampling can be in-situ (ie prior to excavat ion) or ex-situ (from stockpiles after excavation) but in both
scenarios
Sampling density is to as a minimum meet the sampling densities recommended in the Victorian
EPA soil sampling guidance
httpsrefepavicgovau~mediaPublicationsIWRG702pdf
Analytes must reflect the contaminants of concern likely to be present at the site and as a
minimum consider Asbestos Metals TPH BTEX PAHs and PFAS Other side specific
contaminants may include hexavalent chromium PCBs pesticides etc
If retained onsite the Waste Classif ications Guidelines do not apply BUT the material must be suitable
from a human health and environment perspective to remain This requires assessment against the
NEPM and may include visual inspections or sampling and analysis The input of an appropriately
qualified professional is required prior to the re-use of any fill or potentially contaminated spoil
Once the spoil is removed from the site it becomes Waste All waste must be transported to a facility
that is licenced to accept it VENM ENM andor Resource Recovery ExemptionsOrders impart specific
requirements regarding assessment sampling analysis classificat ion and use of these types of spoil
The requirements regarding sampling and record retention must be adhered to
Once spoil is removed from the site it becomes Waste All Waste must be classified in accordance with
the NSW EPA Waste Classification Guidelines and be transported to a facility licenced to accept it
Note that whether or not the asbestos is present further classif ication is required under Steps 2 to 6 of
the EPA Waste Classification Guidelines
Yes or No
General solid waste restricted waste or hazardous waste
No
Yes
Yes
Yes
Yes or No
Yes
Yes
Yes
No
No
No
No
No
Figure 1 Spoil Classification process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 10 of 14
SM-20-00040677 Waste Classification Procedure V30
Table 1 Spoil Classification process flow
Decision Criteria InputsData ControlsReview
Reuse of the material on or within the approved project area
Most preferred option under WARR Act and Sydney Metro environment and sustainability policy
Suitable placement locations have been identified
The material is suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and will not cause pollution under the POEO Act
The spoil meets engineering requirements for placement locations
Where spoil or demolition materials require treatment or processing onsite to treat contaminants or to amend engineering properties the need for an EPL must be assessed and resulting conditions met
If transport to another project area is required and such transport requires material to be taken outside the site boundary temporarily this will need to be appropriately address in the projectrsquos environmental approvals (eg EIS or REF)
Appropriate risk-based assessment confirms the material is suitable for proposed final land use from a contamination perspective
Appropriate geotechnical assessment confirms the material is suitable for proposed final land use
EPL if required for onsite processing
Complete material tracking record including documentation of final placement location
Environmental controls to prevent cross-contamination of material prior to placement and pollution during placement
Training of relevant personnel in spoil reuse framework and underlying management plans
Audits of sampling data tracking and placement information and reuse locationssites
Long-term management plan and monitoring andor Environmental Protection Licence under the POEO Act (if required)
Reuse of the material off site
Spoil becomes waste under POEO Act once removed from site
Material meets VENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Assessment confirms material is VENM Sampling may be required depending on nature of material and source
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 11 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Material meets ENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Sampling conducted in accordance with ENM RRO prior to transport off site and results meet criteria
Statement of RRO compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
RRO records maintained for six years including details of sampling plan sampling results quantities supplied and receival sites
Material does not meet VENM or ENM definitions but has potential for reuse under a specific RRORRE An example is tunnel spoil containing additives
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Consult with the EPA prepare and submit application for specific RRORRE Characterisation data will be required for the application
Once specific RRORRE is granted obtain sampling data (and meet any other specific obligations) in accordance with conditions and confirm results meet criteria prior to transport off site
Statement of compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
As for reuse on site plus
Statement of compliance provided to each receival site
RRO records maintained for six years
Recycling off site
Material (spoil and demolition materials) becomes waste under POEO Act once removed from site
Material meets the EPL andor planning approval requirements for the receival facility and has value for recycling
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Assessmentsampling confirms the material meets the receival facility EPL conditions (typically GSW)
Appropriate EPL held by receival facility
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 12 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Disposal off site
Material does not fit one of the above categories andor suitable reuse or recycling locations could not be identified
Least preferred option
Waste is classified as GSW RSW or Special Waste
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by receival facilities
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Waste is classified as HW
Suitable treatment facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by treatment facilities
Treatment facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking treatment and disposal documentation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 13 of 14
SM-20-00040677 Waste Classification Procedure V30
Unexpected find process flow
Flo
w
Process Additional information
Unexpected potential
contamination find1 Immediate ly stop works
2 Notify the Site supervisor 3 Secure the affected area
Is an emergency
response required for any
health or environment
concerns
4b Notify Principal s Rep and
Environmenta l Rep
4a Trigger pro ject incident response and
reporting mechanism andor call 000
5b Inform the
Principal s Rep
Does the
contamination
present and ongoing risk to
environment or human
health dur ing
construction or
operation
Will the
agreed scope result in the
complete removal of the
contamination
Does the
disposal of the unexpected
find result in addi tional costs
to the Principa l
5a Materials to be classified in
accordance with the NSW EPA Waste
Classification Guidel ines (2014) (see
Figure 1 Spoil classification flow)
6a Inform the
Principal s Rep
6b Dispose of the material in
accordance with all relevant legislation
the project Spoil Classification amp
Management Framework and any
relevant directions from Sydney Metro
6c Develop
appropriate
methodology
plans to
manage the
contamination
and implement
Indicators of potentia l
contamination include
Fibre cement or other asbestos
containing materials
Discolouration of the so il
including staining andor
discolouration
Odours from soil or
groundwaterseepage
Bur ied drums and storage tanks
Oily sheen on water
Note this does not include on-
site contamination
Securing of the area should restrict
access to the affected area This
should include as a min imum
environmenta l controls around the
affected area to contain
contaminated material including
diversion of water to minimise
potential spread via surface water
runoff
Where contaminants are likely to
result in odours vapours or
airborne asbestos fibres immediate
action should be taken to prevent
their release (eg cover re-bury or
wet-down
Recommence works in alternate
area where practicable and safe
Assessment to be conducted by
suitably qualified and experienced
person
Methodology controls and p lans
are to be prepared by a sui tab ly
qualified and experienced person
and approved by Sydney Metro
prior to being actioned
Works may continue in the affected
area when it is safe and where
works will not exacerbate
contamination or hinder future
remediation works
Note Remediation of contaminated
materials may include (but not be
limited to) capping of
contaminating treatment andor off-
site disposal All associated
activities with the remediation of
contaminated materials such as
excavation handling stockpiling
and transport are to be addressed
an prepared methodology and
controls
Yes
No
Yes or unsure
No
No or unsure
Yes
Yes
No
Figure 2 Unexpected find process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 14 of 14
SM-20-00040677 Waste Classification Procedure V30
17 Accountabilities
The Director Program Sustainability Environment amp Planning is accountable for this document including approving the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document
2 Related documents and references
3 Superseded documents
4 Document history
Related documents and references
Entries should be formatted with IMSiCentral number followed by correct title and hyperlinked eg
SM-17-00000203 Sydney Metro glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
02 Pending New IMS document
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 43 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise pollution of surface water through appropriate erosion and sediment control Minimise leaks and spills from construction activities Maintain existing water quality of surrounding surface watercourses Source construction water from non-potable sources where feasible and reasonable
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp Targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Erosion and sediment measures would be implemented in accordance with the principles and
requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any significant water aspects and Site specific controls to minimise potential impacts
Emergency Management Team members will be provided training to respond to a discharge of contaminated water or hazardous substances into the environment
Project Manager
Notification The Site will not modify or remove any water utility assets without their approval Notification
of approval will be received by Sydney Water with a copy of authorisation Notification to the asset owner will be given as per their conditions of compliance
Project Engineer
ESCP
ESCPrsquos will be developed by construction staff with demonstrated skills and experience in preparing the ESCP in accordance with the Blue Book Guidelines ESCPrsquos plans will include but not be limited to
Title date and revision number Contours and clean and dirty water drainage paths Site layout including the location of access roads ancillary infrastructure Sediment basins and designated pump out locations Limit of disturbance Location and type of control measures Timing and order of control installation in sequence with work activities Specific construction details
Environmental Site Representative
Erosion and sediment control
The following key principals will apply to all areas and stages of construction on the Project
Minimise extent and duration of disturbance Control stormwater flows onto through and from the site
Project Engineer Supervisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 44 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Erosion control strategies to prevent on-site damage Sediment control strategies to prevent off-site damage Progressive stabilisation following completion of work areas Inspection Maintenance and Improvement of control measures throughout the site construction
until the site is successfully stabilised
Dewatering
Sediment laden water accumulated in trenches or excavations must not be discharged directly or indirectly to any stormwater natural watercourse or offsite
A suitable location to discharge will be identified considering site slope proximity to drainage lines soil permeability and ground cover ie well established existing vegetation
The water must be tested prior to any discharge by the Environmental Site Representative and may require treatment prior to discharge
Project Engineer Environmental Site Representative
Groundwater
Groundwater is unlikely to be intercepted during any excavation within the road footprint Deeper excavations for stormwater trenching may intercept groundwater however a method of pipe installation during low tide will removed the need for dewatering
If groundwater dewatering is required then a dewatering management plan should be developed
PlantVehicle Maintenance
The maintenance and cleaning of any vehicles plant or equipment must not be carried out in areas from which contaminants can be released into stormwater or natural watercourses
All
Acid Sulfate Soils
Prior to excavation for the Stormwater trench which will occur approximately 25m bgs testing would be carried out to determine the presence of actual andor potential acid sulfate soils
Testing for the presence of ASS shall be undertaken at proposed excavation locations and shall apply the following methodology Dig holes to the proposed depth of excavation conduct ASS pH field tests on material from the hole at 05m depth intervals and then conduct a SPOCAS plus or chromium suites on the most acidic ASS pH field test sample from the hole The testing and sampling to be undertaken in accordance with ASSMAC Laboratory method Guideline Aug 1998
If actual andor potential acid sulfate soils are present within the proposed area of excavation then an Acid Sulfate Management Plan will be developed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Project Engineer Environmental Site Representative
Water Discharge requirements
An Environmental Protection Licence (EPL) is not required for the project however Georgiou will test any water to be discharged offsite in accordance with the water quality parameters specified in the Blue Book (Landcom 2004) and ANZECCARMCANZ (2000) guidelines prior to discharge to ensure an incident of pollution to surrounding environment does not occur from the Project
Environmental Site Representative
Monitoring of Discharges
Waters released from site must be sampled prior to release The samples taken must be representative of the water being discharged
Project Engineer HSE Advisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 45 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Environmental Inspections amp Monitoring
The results of monitoring shall be recorded Environmental Site Representative
Daily (Visual) and weekly (documented)
Daily visual observation for evidence of water quality impacts including turbidity or hydrocarbon spills
Weekly inspections using Georgiou Beakon inspection form
Supervisor HSE Advisor
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report Dewatering records including all water quality test results
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 46 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Objectives and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise leaks and spills from construction activities All chemicals correctly stored and bunded in accordance with legislative requirements Any spills are controlled contained cleaned up and reported
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General All fuels chemicals and hazardous liquids would be stored in accordance with Australian
standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required to
manage hydrocarbon and chemical storage and use including
- Use and understanding of safety data sheets (SDS) - Use of personal protective equipment (PPE)
Emergency Management Team members will be provided training to respond to a hazardous substance spill
Project Manager
Register
All dangerous goods or hazardous substances must be approved by HSE Advisor prior to use on the site
ChemAlert will be used to register all site dangerous goods and hazardous substances manage electronic SDS and conduct and record product risk assessments
Consideration will be given to substitute products assessed as a high risk with a product of lesser risk
Project ManagerSupervisor
Transportation Containers holding hazardous substances or dangerous goods will be stored upright and secured
during transport Containers are not to be dropped tip or rolled sides The transportation of dangerous goods will be by licenced carriers
Project Engineer
Handling amp Use
Handling of products will be subject to the following requirements Hazardous substances and dangerous goods will be clearly labelled Current SDS (no older than 5 years) will be readily available when handling Controls stipulated in the SDS to be applied when handling and using Used oily rags oil filters and other left over hydrocarbon and chemical products hall be stored in
a designated area and removed by licensed carriers to either recycle or otherwise dispose of
All
Refuelling Refuelling of plant and vehicles must be monitored continually and conducted in designated areas
away from sensitive receptors
All in field refuelling must have a spill kits available to contain and clean up any spills
All
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Spill kits shall be stored in designated amp labelled containers and include a stock control register
All refuelling areas must be signed to prevent smoking or naked flame
Vehicles must be switched off when refuelling and the use of mobile phones prohibited
Fixed refuelling areas must have a plastic lined refuelling area
Fuel storage containers must be of a double bund construction
Site layout
Georgiou will develop a site plan (ie a diagram) showing the location of storage areas spill kit locations muster points firefighting equipment and 1st aid equipment including eye washflush locations
This site plan must be current and displayed at the work site at all times throughout construction
In the event of an emergency that involves the need for emergency services this site plan along with a product manifest must be provided to the emergency services
Project Manager
Storage of Hazardous Materials
Any Dangerous Goods andor Hazardous Substance must be stored in designated areas compliant
with statutory and industry codes of practice
Quantities of hazardous materials should be kept to a minimum commensurate with their usage
and shelf life
Safety Data Sheets of stored hazardous materials will be readily accessible at the place of
storagesite office
Permanent and temporary containers that hold hazardous materials must be labelled with the
appropriate signage
The volume and types of hazardous materials stored must be known current and documented and
must not exceed the design capacity of the storage area
Storage and containment areas (including secondary containment) must be inspected for signs of
loss or damage and any deficiencies must be addressed These areas must be inspected at least
monthly as part of the workplace inspection
Hazardous materials no longer in use must be identified and assessed to determine if they should
be removed from site
Hazardous materials storage areas must be kept clear of combustible material vegetation and refuse by a minimum of three metres
All
SpillEmergency Response
In the event of a spill the following generic procedure must be followed
1 Do not put yourself at risk 2 Notify personnel in the immediate area and remove yourself and others from danger 3 Report ALL SPILLS immediately to the Supervisor and Environmental Site Representative
(report location type and extent of incident)
All
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Once safety has been considered spills should be contained and cleaned up with material from the spill kit All contaminated soil caused by leaks or spills to be disposed of in accordance with legal requirements Any uncontrolled release of hazardous substances which cause actual or threatens potential serious or material environmental harm will be reported to the EPA pollution hotline
Workplace Inspections
Hazardous Materials storage and use will be inspected monthly as part of workplace inspections amp within the DHI Environmental Inspections checklist
Supervisors
Concrete
Designated concrete washout should be constructed and designated to be impermeable and securely fastened
Placed away from waterways drainage lines and stormwater inlets Sufficient storage to handle concrete works occurring onsite When the concrete is dried it will be disposed of with general waste mixed into fill layers (if
approved by client) or recycled At no point will any Concrete truck or kibble be permitted to wash out at any point other than the
designated area with all the associated controls in place (unless approved by the environmental site representative)
Excess concrete should be scraped off equipment prior to washing (allow excess to set and recycle offsite or reuse in fill if itrsquos not contaminated with black plastic)
Set concrete should be removed from the washout to restore storage capacity and prevent overflows
Use of a high pressure low volume water spray nozzle may reduce water use All wastewater must be disposed of in accordance with the project CEMP dewatering conditions
Maintenance of the washout Monitoring and maintenance of concrete washouts is essential to ensure the washout is functional no evidence of damage or wear and tear is evident and that adequate storage capacity remains In addition to daily inspections washout areas should be inspected
During dry weather and
Prior to during and after rainfall and storm events
SupervisorEnvironmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for evidence of spills or poor storage practice with potential to lead environmental incident
Hazardous goods storage area inspection for adequacy of bunding and product loss Weekly inspections using Georgiou Beakon inspection form
All staff
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Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Objectives
and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on flora and fauna Retain and enhance existing flora and fauna habitat wherever possible Appropriately manage the spread of weeds and plant pathogens
Project Manager
Performance
Criteria
100 compliance with Client amp legal requirements
100 achievement with Site Objectives amp Targets
100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation
Measures
General Vehicles equipment plant materials and personnel are to remain within the designated construction
area at all times and not breach established environmentally sensitive exclusion zones All
Training and
Competency
As part of the Site Induction workers will be informed of the Site specific controls required to minimise potential impacts and protect flora and fauna including - the requirement to work within the designated disturbance zones - requirement to recognise protected flora or fauna species identified to be found on the site - tree protection zones - Specific licence conditions applicable to the Site
Project Manager
Fauna habitat
Prior to clearing pre-clearance surveys are to occur to identify individual trees to be retained and any hollow bearing trees and logs
Where possible clearance should avoid hollow bearing trees Where unavoidable hollow bearing trees should be flagged and left standing at least 24 hours
after clearing all other vegetation Excavator operator to lsquotaprsquo tree prior to felling hollow bearing trees to allow for fauna to escape Ecologist (or similar) to be present onside during clearing of hollow bearing trees to handle any
displaced fauna In the event of injury to fauna WIRES or similar to be contacted and suitable arrangements made
NOTE Handling of any active animal breeding place is only permitted to be conducted by an authorised fauna handler operating under a current permit granted in accordance with legislative requirements
All
Authorisation amp Compliance
Georgiou will not clear vegetation without written permission from the Client local Shire or relevant Regulatory Authority All clearing works under a permit approval or licence will be compliant with the conditions of permit approvals or licence and within the predetermined area
In the event of any unauthorised clearing works will cease immediately and the Project Manager client will be notified Unauthorised clearing of areas will be investigated immediately
Project Engineer
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Marking
The Project Engineer will ensure the area to be cleared is clearly marked (eg pegging) and areas of vegetation or trees nominated to be excluded from the clearing works are to be visually identifiable to all personnel involved in the works
The method of marking is to be communicated to all persons involved in the clearing process All control measures are to be communicated to personnel involved in the tasks
All
Flora
Flora that is to be protected will be clearly marked using a method that will not harm or damage A Tree protection Zone (TPZ) is to be established for any trees on a construction site that are to
be protected This is to be fenced off or barricaded to ensure construction activities do not cause damage to the root plate of the tree
Native vegetation should be protected where reasonably possible Large areas that are to be protected from Site works will be demarcated to prevent intrusion and disturbance This requirement is to be communicated to personnel involved within the site area
When the pruning of trees is to be undertaken that are to be protected it will be done by suitably qualified personnel only Where branches are trimmed an assessment of the trees ability to survive should be conducted by a suitably qualified person and adequate area around the tree in accordance with AS49702009 Protection of trees of development sites
Trees should be felled into the construction site or in slots between stands of trees where practical to minimise damage to other trees during the clearing process Machinery contact with standing trees on vegetated margins is to be avoided
The clearing of vegetation outside the construction area will not be permitted except in the event of an emergency or as directed by emergency services
All
Fauna
If fauna are confirmed to be present onsite during clearing clearing works should proceed with care to enable the fauna to relocate freely Clearing is to be conducted in a sequential manner and in a way that encourages escaping wildlife away from the activity into adjacent natural areas and not across roads or into other areas of threat (eg trench)
All
Trenches
All open excavations and trenches will be visually inspected on a daily basis for trapped fauna Surveillance must occur along the entire length of the trench or excavated area and not merely those areas described as fauna habitats or sensitive areas Open trenches are to be checked for fauna immediately prior to backfill and any trapped animals removed by authorised fauna handlers
All
Fauna Handling
Fauna will not be intentionally harmed or maimed under State wildlife protection legislation This includes aquatic and terrestrial fauna (land and air animals)
Workers are not authorised handleto be in possession of native fauna The trapping and handling of fauna in particular dangerous species will only be undertaken by a competent qualified fauna handler
All
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Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Fire Management
Georgiou will not set fire to bush or use spark generating machinery (eg graders) during a prohibited or restricted burning time
If safe to do so Georgiou will extinguish any bush fire within the site boundary and request help from authorities if necessary Fire breaks will be established as requested by authorities
Project Manager
Environmental
Inspections amp
Monitoring
Daily (Visual) and weekly
(documented)
General observation for clearing boundary demarcation Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 5 - Cultural Heritage Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on items or places of heritage value Avoid accidental impacts on heritage items Maximise workerrsquos awareness of indigenous and non-indigenous heritage
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Maintain the integrity of the cultural (European amp Indigenous) aspects of the Site
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any identified cultural or heritage aspects on the Site and any specific controls to be adhered including - Management practices when working near protected areas - Respecting Heritage Sites - Reporting requirements
Georgiou personnel will participate in the Companyrsquos cross cultural awareness training for employees
Project Manager
Heritage Sites There are s170 heritage listed Glebe Island silos (Port Authority of NSW s170 4560056) that are approximately 5m from the edge of works
Project Engineer
Method statement
In accordance with the REF an Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
Unexpected heritage finds
In the event that an artefact or remains are found the Sydney Metro Unexpected Heritage Finds procedure (Appendix 5A) will be followed this includes - The works in that area will cease immediately - The Project Manager and Sydney Metro must be notified - The site must be made secure a buffer zone of ten meters is recommended - Sydney Metro to provide management recommendations
Georgiou will notify all site personnel of the object andor area and proposed treatment of that object andor area as soon as possible but prior to commencing work on the next working day
Works will not continue until written approval has been received from the client
All
discovery of human remains
In the event that human remains are found the Sydney Metro Exhumation Management procedure will be followed (Appendix 5B)
All
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Environmental Inspections amp Monitoring
Building condition inspections Building condition inspections will be undertaken in accordance with REF condition NV3 Sydney Metro
Vibration Monitoring
Continuous vibration monitoring will occur during any vibratory works in close proximity to the Glebe Island silos in accordance with the Sydney Metro Construction Noise and Vibration Standard
Environmental Site Representative
Daily (Visual) and weekly (documented)
General observation for that protection measures and methods are being applied Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure
Sydney Metro Unexpected
Heritage Finds Procedure [SM-18-00105232]
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final
Version 33
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2018
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Document history
Version Date of approval Notes
11 Incorporates ER comments 210617
12 Amends p13 step 8 reference to s146 added
13 Incorporates Planning Mods 1-4 including amended CoA E20
14 Incorporates ER comments 210318
20 Removes SSI 15-7400 COA reference
30 Revises definition
31 Revises flow chart
32 Revises roles and responsibilities
33 General edits and corrections
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Table of contents
1 Purpose 3
11 Legislation that does not apply 3
2 Scope 4
3 Definitions 4
4 Types of unexpected heritage items and corresponding statutory protections 5
41 Aboriginal objects 5
42 Historic heritage items 6
43 Human skeletal remains 7
5 Legislative Requirements 7
6 Unexpected heritage finds protocol 9
7 Responsibilities 15
8 Seeking Advice 16
9 Related documents and references 16
10 List of appendices 16
11 Document history 17
Appendix 1 Examples of finds encountered during construction works 18
Appendix 2 - Unexpected heritage item recording form 24
Appendix 3 - Photographing unexpected heritage items 26
Appendix 4 - Uncovering bones 29
Appendix 5 - Archaeologicalheritage advice checklist 33
Appendix 6 - Template notification letter 34
Tables
Table 1 Legislation and guidelines for management of unexpected heritage finds 8 Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item 10 Table 3 Roles and Responsibilities 15
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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1 Purpose
This procedure is applicable to the Sydney Metro program of works including major projects delivered under Critical State Significant Infrastructure (CSSI) Planning Approvals early CSSI minor and enabling works and works that are subject to the NSW Heritage Act (1977) including s57139 and s60140 exemptions and permit approvals and the National Parks and Wildlife (NPW) Act 1974
This procedure has been prepared for Sydney Metro programs to provide a method for managing unexpected heritage items (both Aboriginal and non-Aboriginal) that are discovered during preconstruction (pre-Construction Heritage Management Plan approval) construction phases (post Construction Heritage Management Plan approval) and for works subject to the NSW Heritage Act (1977)
In NSW there are strict laws to protect and manage heritage objects and relics As a result appropriate heritage management measures need to be implemented to minimise impacts on heritage values ensure compliance with relevant heritage notification and other obligations and to minimise the risk of penalties to individuals Sydney Metro and its contractors This procedure includes Sydney Metrorsquos heritage notification obligations under the Heritage Act NPW Act and the Coronerrsquos Act 2009 and the requirements of the conditions of approval(CoA) issued by NSW Department of Planning Industry and Environment Note that a Contractor must not amend the Sydney Metro Unexpected Finds Procedure or use a different procedure without the prior approval of Sydney Metro
This procedure must be read in conjunction with the relevant CCSI conditions of approval (if applicable) the contract documents and other plans and procedures including the Sydney Metro Exhumation Procedure in addition to any other relevant documents as developed by the contractor during the delivery of the Sydney Metro works
2 Definitions and Abbreviations
An unexpected heritage find is
any unanticipated discovery of an actual or potential heritage item which Sydney Metro does not have approval to disturb andor does not have an existing management process in place
a find that has not been previously identified or assessed
a find that is not referenced in an Archaeological Research Design (ARD) Archaeological Method Statement (AMS) or other project document relating to heritage and archaeology
not covered by an existing approval under the Heritage Act 1977 (Heritage Act) or National Parks and Wildlife Act 1974 (NPW Act)
Note that locally significant areas of historical archaeological potential identified in an Archaeological Method Statement but not identified in an Archaeological Research Design would be managed as an ldquoexpectedrdquo find
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(Uncontrolled when printed)
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All terminology in this procedure is taken to mean the generally accepted or dictionary definition with the exception of the following terms which have a specifically defined meaning
Definitions
AHIP Aboriginal Heritage Impact Permit
Aboriginal object An Aboriginal object is any deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remains An Aboriginal object may include a shell midden stone tools bones rock art Aboriginal-built fences and stockyards scarred trees and the remains of fringe camps
ARD Archaeological Research Design
AMS Archaeological Method Statement
CEMP Construction Environmental Management Plan
CoA Conditions of Approval
CSSD Critical State Significant Development
CSSI Critical State Significant Infrastructure
EPampA Act NSW Environmental Planning and Assessment Act 1979
Disturbance Disturbance is considered to be any physical interference to an item that results in it
being destroyed defaced damaged harmed impacted or altered in any way (this
includes archaeological investigation activities)
Excavation Director
A person that has been determined by the NSW Heritage Division to meet the Heritage Council of NSWrsquos Criteria for Assessment of Excavation Directors (4 September 2019 and as updated) and can therefore competently archaeologically investigate a site of either local andor state significance
Heritage Act NSW Heritage Act 1977
NPW Act NSW National Parks and Wildlife Act 1974
Heritage NSW Formerly Office of Environment and Heritage (OEH) Now Heritage NSW as part of PNSW Premier and Cabinet
SM Sydney Metro
Relic (non- Aboriginal heritage)
A relic means any deposit artefact object or material evidence that
a) relates to the settlement of the area that comprises NSW not being Aboriginal settlement and
b) is of State or local significance
A relic may include items such as bottles utensils remnants of clothing crockery
personal effects tools machinery and domestic or industrial refuse
TfNSW Transport for New South Wales
Work (non- Aboriginal heritage)
Archaeological features such as historic utilities or buried infrastructure that provide evidence of prior occupations such as former rail or tram tracks timber sleepers kerbing historic road pavement fences culverts historic pavement buried retaining walls cisterns conduits sheds or building foundations but are also subject to assessment by the Excavation Director to determine its classification
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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21 Legislation that does not apply
The following authorisations are not required for Sydney Metro approved Critical State Significant Infrastructure (and accordingly the provisions of any Act that prohibits an activity without such an authority do not apply)
Division 8 of Part 6 of the Heritage Act 1977 does not apply to prevent or interfere with the carrying out of approved State significant infrastructure
An approval under Part 4 or an excavation permit under section 139 of the Heritage Act 1977 and
An Aboriginal heritage impact permit under section 90 of the National Parks and Wildlife Act 1974
This document provides relevant background information in Section 4 followed by the technical procedure in Sections 6 and 7 Associated guidance referred to in the procedure can be found in Appendices 1-6
3 Scope
Even with early investigations unexpected finds may still occur during works on a Sydney Metro site When this happens this procedure must be followed This procedure provides direction on when to stop work where to seek technical advice how to notify the regulator if required and when works can recommence This procedure applies to the discovery of any unexpected heritage item relic or object where the find is not anticipated in an approved ARD or AMS or other project specific document related to archaeology
This procedure must be followed by all Sydney Metro staff contractors subcontractors or any person undertaking works for Sydney Metro It includes references to some of the relevant legislative and regulatory requirements but is not intended to replace them This procedure does not apply to
the discovery and disturbance of heritage items as a result of investigations being undertaken in accordance with the Code of Practice for Archaeological Investigations of Aboriginal Objects in NSW4376 20101 an Aboriginal Heritage Impact Permit (AHIP) issued under the NPW Act or a permit approval issued under the Heritage Act
the discovery and disturbance of heritage items as a result of construction related activities where the disturbance is permissible in accordance with an AHIP or an approval issued under the Heritage Act or CSSI CSSD planning approval or
locally significant non-Aboriginal archaeology identified in an AMS and not in an ARD
1 An act carried out in accordance with the Code of Practice for Archaeological Investigation of Aboriginal Objects
in NSW as published by the Department in the Gazette on 24 September 2010 is excluded from the definition of harm an object or place in section 5 (1) of the NPW Act
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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4 Types of unexpected heritage finds and corresponding statutory protections
Project field and environmental personnel (including construction contractors) are critical to the early identification and protection of unexpected finds
Appendix 1 illustrates the wide range of heritage items uncovered to date during Sydney Metro projects and gives an indicative guide to what unexpected finds may look like
These discoveries are categorised as either
(a) Aboriginal objects
(b) Historic (non-Aboriginal) heritage items or
(c) Human skeletal remains
The relevant legislation that applies to each of these categories is described below
41 Aboriginal objects
The NPW Act protects Aboriginal objects which are defined as
ldquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrdquo2
Examples of Aboriginal objects include stone tool artefacts shell middens axe grinding grooves pigment or engraved rock art burials and scarred trees
42 Historic heritage items
Historic (non-Aboriginal) heritage items may include
Archaeological lsquorelicsrsquo or
Other historic items (ie works structures buildings or movable objects)
2 Section 5(1) NPW Act 3 This is required under section 89(A) of the NPW Act and applies to all Sydney Metro projects
IMPORTANT
All Aboriginal objects regardless of significance are protected under law
If any impact is expected to an Aboriginal object an AHIP is usually required from Heritage NSW When a person becomes aware of an Aboriginal object they must notify the Director-
General of Heritage NSW about its location3 Assistance on how to do this is provided in Section 7 (Step 5)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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421 Archaeological relics
The Heritage Act protects relics which are defined as ldquoany deposit artefact object or material evidence that relates to the settlement of the area that comprises NSW not being Aboriginal settlement and is of State or local heritage significancerdquo4
Relics are archaeological items of local or state significance which may relate to past domestic industrial or agricultural activities in NSW and can include bottles remnants of clothing pottery building materials and general refuse
422 Other historic items
Some historic heritage items are not considered to be lsquorelicsrsquo but are instead referred to as works buildings structures or movable objects Examples of these items that may be encountered include culverts historic pavements retaining walls tramlines rail tracks turn tables timber sleepers cisterns fences sheds buildings and conduits Although an approval under the Heritage Act may not be required to disturb these items their discovery must be managed in accordance with this procedure
Usually archaeological relics are uncovered via a process of excavation or soil removal When an unexpected find is uncovered an archaeological excavation permit under section 140 or section 60 of the Heritage Act may be required to further investigate or remove it if investigation is not covered by an existing approval In contrast lsquoother historic itemsrsquo either exist above the ground surface (for example a shed) or they are designed to operate and exist beneath the ground surface (for example a culvert)They may also need a permit to alter disturb or remove them if there is not an approval already in place
4 Section 4(1) Heritage Act
5 This is required under section 146 of the Heritage Act and applies to all Sydney Metro projects
IMPORTANT
All relics are subject to statutory controls and protections
If a relic is likely to be disturbed a heritage approval is usually required from the NSW Heritage Council When a person discovers a relic they must notify the NSW Heritage
Council of its location5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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43 Human skeletal remains
The Sydney Metro Exhumation Procedure provides a more detailed explanation of the approval processes related to human remains
Human skeletal remains can be identified as either an Aboriginal object or non-Aboriginal relic depending on the ancestry of the individual (Aboriginal or non-Aboriginal) and the burial context (archaeological or non-archaeological) Remains are considered to be archaeological when the time elapsed since death is suspected of being 100 years or more Depending on ancestry and context different legislation applies
As a simple example a pre-European settlement archaeological Aboriginal burial would be protected under the NPW Act while a historic (non-Aboriginal) archaeological burial within a cemetery would be protected under the Heritage Act For a non-Aboriginal archaeological burial the relevant heritage approval and notification requirement described in Appendix 4 would apply In addition to the NPW Act finding Aboriginal human remains also triggers notification requirements to the Commonwealth Minister for the Environment under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
Where it is suspected that less than 100 years has elapsed since death the human skeletal remains come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such cases are lsquoreportable deathsrsquo and under legal notification obligations set out in section 35(2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (whether Aboriginal or non-Aboriginal remains) Public health controls may also apply6
Guidance on what to do when suspected human remains are found is provided in Appendix 5
IMPORTANT
All human skeletal remains are subject to statutory controls and protections
All bones must be treated as potential human skeletal remains and work around them must stop while they are appropriately protected and investigated the relevant authorities advised and approvals received This includes skeletal material found during any phase of work including
geotechnical works early works construction works and any other site works
6 Under section 19 of the Coroners Act 2009 the coroner has no jurisdiction to conduct an inquest into reportable
death unless it appears to the coroner that (or that there is reasonable cause to suspect that) the death or suspected death occurred within the last 100 years
Unclassified
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(Uncontrolled when printed)
Unclassified
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5 Legislative Requirements Table 1 identifies some of the relevant legislationregulations for the protection of heritage and the management of unexpected heritage finds in NSW It should be noted that significant penalties exist for breaches of the legislation which result in unauthorised impacts to heritage items
To avoid breaches of legislation it is important that Sydney Metro and its contractors are aware of their statutory obligations under relevant legislation and that appropriate control measures are in place to ensure that unexpected finds are appropriately managed during all project phases Contractors will need to ensure that they undertake their own due diligence to identify any other legislative requirements that may apply for a given project
Table 1 Legislation and guidelines for management of unexpected heritage finds
Relevant Requirement Objectives and offences
Environmental Planning and Assessment Act 1979 (EPampA Act)
Part 5 Division 52 Subdivision 2 Section 519
Requires heritage to be considered within the environmental impact assessment of projects
Heritage Act 1977 (Heritage Act)
The Heritage Act provides for the care protection and management of heritage items in NSW Under section 139 it is an offence to disturb or excavate any land knowing or having reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered exposed moved damaged or destroyed unless the disturbance or excavation is carried out in accordance with an excavation permit issued by the Heritage NSW under the Act a relic is defined as lsquoany deposit artefact object or material evidence that (a) relates to the settlement of the area that comprises New South Wales not being Aboriginal settlement and (b) is of State or local heritage significancersquo
A person must notify the Heritage NSW if a person is aware or believes that they have discovered or located a relic (section 146) Penalties for offences under the Heritage Act can include six months imprisonment andor a fine of up to $11million
Unclassified
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Relevant Requirement Objectives and offences
National Parks and Wildlife Act 1974 (NPW Act)
The NPW Act provides the basis for the care protection and management of Aboriginal objects and places in NSW
An Aboriginal object is defined as lsquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrsquo
An lsquoAboriginal placersquo is an area declared by the Minister administering the Act to be of special significance with respect to Aboriginal culture An Aboriginal place does not have to contain physical evidence of occupation (such as Aboriginal objects)
Under section 87 of the Act it is an offence to harm or desecrate an Aboriginal object or place There are strict liability offences An offence cannot be upheld where the harm or desecration was authorised by an AHIP and the permitrsquos conditions were not contravened Defences and exemptions to the offence of harming an Aboriginal object or Aboriginal place are provided in section 87 87A and 87B of the Act A person must notify Heritage NSW if a person is aware of the location of an Aboriginal object
Penalties for some of the offences can include two years imprisonment andor up to $550000 (for individuals) and a maximum penalty of $11 million (for corporations)
6 Unexpected heritage finds protocol
61 What is an unexpected heritage find
An lsquounexpected heritage findrsquo can be defined as any unanticipated archaeological discovery that has not been identified during a previous assessment or is not covered by an existing permit under the Heritage Act The find may have potential cultural heritage value which may require a heritage permit or notification if any interference of the heritage item is proposed or anticipated
The range of potential unexpected finds can include but is not limited to
remains of rail infrastructure including buildings footings stations signal boxes rail lines bridges and culverts
remains of other infrastructure including sandstone or brick buildings wells cisterns drainage services conduits old kerbing and pavement former road surfaces timber and stone culverts bridge footings and retaining walls
artefact scatters including clustering of broken and complete bottles glass ceramics animal bones and clay pipes and
archaeological human skeletal remains
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(Uncontrolled when printed)
62 Managing unexpected finds
In the event that an unexpected find is encountered on a Sydney Metro site the steps detailed in Table 2 must be followed There are seven steps in the procedure
Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item
Step Task Responsibility Guidance and tools
1 Stop work and protect the item
11 Stop all work including geotechnical investigations in the immediate area of the item and notify the Project Manager
Contractor Supervisor
Appendix 1
Identifying Unexpected Heritage items
12 Establish a lsquono-go zonersquo around the item Use high visibility fencing where practical No work is to be undertaken within this zone until further investigations are completed and if required appropriate approvals are obtained
Inform all site personnel about the no-go zone
Project Manager Contractor Supervisor
2 Engage an Archaeologist
21 If you have Excavation Director or an archaeologist andor Aboriginal heritage consultant has been previously appointed for the project contact them to discuss the location and nature of the item and arrange a site inspection The project Construction Environmental Management Plan (CEMP) may contain contact details of the archaeologistAboriginal heritage consultant
Provide as much information as possible including photos and completed recording form
Inform the Sydney Metro Environmental Manager and keep them involved in the process The Environmental Manager will inform the Sydney Metro Senior Heritage Advisor
Contractors Project Manager
Appendix 2
Unexpected Heritage Item Recording Form
22 Where there is no project archaeologist engaged for the works engage a suitably qualified consultant to assess the find
If the find is a non-Aboriginal item engage a suitably qualified and experienced historical archaeological consultant
If the find is likely to be an Aboriginal object engage an Aboriginal heritage consultant
Contractorrsquos Project Manager
IMPORTANT
Sydney Metro may have approval to impact certain heritage items during construction If you think that you may have discovered a heritage item and you are unsure whether an
approval is in place or not STOP works and follow this procedure
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Step Task Responsibility Guidance and tools
23 ArchaeologistExcavation Director and Sydney Metro Environmental Manager to advise the Project Manager whether Sydney Metro has approval to impact the lsquoitemrsquo
If yes work may recommence in accordance with that approval or permit There is no further requirement to follow this procedure
If no continue to next step
Contractorrsquos Project Manager
3 Arrange site access
31 Arrange site access for the archaeologistAboriginal heritage consultant to inspect the item as soon as practicable In most cases a site inspection is required to conduct a preliminary assessment
Contractorrsquo s Project Manager Excavation Director
32 Subject to the archaeologistAboriginal heritage consultantrsquos assessment work may recommence at a set distance from the item This is to protect any other archaeological material that may exist in the vicinity which may have not yet been uncovered Existing protective fencing established in Step 12 may need to be adjusted to reflect the extent of the newly assessed protective area No works are to take place within this area once established
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
33 Occasionally the archaeologistAboriginal heritage consultant may determine from the photographs provided at Step 21 that no site inspection is required because no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo a lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Archaeologist Aboriginal heritage consultant Excavation Director
Proceed to Step 8
4 Undertake Preliminary assessment and recording of the find
41 Has the lsquofindrsquo been damaged or harmed
If yes record the incident in the Incident
Management System Implement any additional reporting requirements related to the planning approval and CEMP where relevant
Contractors Project Manager Archaeologist and or Excavation Director
42 Can the works avoid further disturbance to the item Project Manager to confirm with Sydney Metro Environment Manager
Complete the remaining tasks
Contractorrsquos Project Manager
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Step Task Responsibility Guidance and tools
43 Inspect document and photograph the item Archaeologist and or Excavation Director
Appendix 2
Unexpected Heritage Item Recording Form
Appendix 3
Photographing Unexpected Heritage items
44 Is the item likely to be bone
If yes follow the steps in Appendix 4 ndash lsquoUncovering bonesrsquo Where it is obvious that the bones are human remains you must notify the local police by telephone immediately They may take command of all or part of the site Also refer to the Sydney Metro Exhumation Procedure
If no proceed to next step
Archaeologist and or Excavation Director
Appendix 4
Uncovering Bones
45 The archaeologistAboriginal heritage consultant may provide advice after the site inspection and preliminary assessment that no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo or a lsquoheritage itemrsquo or an lsquoAboriginal itemrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Metro Project Manager
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
Proceed to Step 7
Refer to Appendix 1
Examples of finds encountered during construction worksrsquo
46 Where required seek additional specialist technical advice (such as a forensic or physical anthropologist to identify skeletal remains) The archaeologistAboriginal heritage consultant can provide contacts for such specialist consultants
Excavation Director Archaeologist
47 Where the item has been identified as a lsquorelicrsquo or lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo the archaeologist should formally record it
Archaeologist Aboriginal heritage consultant
48 NSW Heritage for non-Aboriginal relics and NSW Department of Planning Industry and Environment for Aboriginal objects can be notified informally by telephone at this stage by the Sydney Metro Senior Heritage Advisor Any verbal conversations with regulators must be noted on the project file for future reference
Contractors Project Manager Excavation Director
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Step Task Responsibility Guidance and tools
5 Notify the regulator if required
51 Based on the findings of the archaeological or heritage management plan and corresponding legislative requirements is notification of Heritage NSW and the Secretary required
If no proceed directly to Step 6
If yes proceed to next step
Sydney Metro Environmental Manager Contractorrsquos Excavation Director
52 If notification is required complete the template notification letter including the archaeological heritage management plan and other relevant supporting information and forward to the Sydney Metro Environmental Manager The Environmental Manager will seek the approval of the Sydney Metro Senior Heritage Advisor and the signature of the Principal Manager Sustainability Environment and Planning (Program)
Sydney Metro Environmental Manager Excavation Director
Appendix 6
Template Notification Letter
53 Forward the signed notification letter to Heritage NSW and the Secretary
Informal notification (via a phone call or email) to Heritage NSW prior to sending the letter is appropriate The archaeological or heritage management plan and the completed Unexpected Heritage Item Recording Form (Appendix 2) must be submitted with the notification letter (for both Aboriginal objects and non-Aboriginal relics)
The Department of Planning Industry and Environment may also need to be notified
54 A copy of the final signed notification letter archaeological or heritage management plan and the site recording form is to be kept on file and a copy sent to the Sydney Metro Project Manager
Contractorrsquos Project Manager Excavation Director
6 Implement archaeological or heritage management plan
61 Modify the archaeological or heritage management plan to take into account any additional advice resulting from notification and discussions with regulator
Contractorrsquos Project Manager Excavation Director
62 Implement the archaeological or heritage management plan Where impact is expected this may include a formal assessment of significance and heritage impact assessment preparation of excavation or recording methodologies consultation with Registered Aboriginal Parties obtaining heritage approvals etc if required
Contractorrsquos Project Manager Excavation Director
63 Where heritage approval is required contact the Sydney Metro Environment Manager for further advice and support material Please note there are time constraints associated with heritage approval preparation and processing
Contractorrsquos Project Manager Excavation Director
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64 Assess whether heritage impact is consistent with the project approval or if project approval modification is required from the Department of Planning Industry and Environment
Excavation Director Sydney Metro Environmental Manager
65 Where statutory approvals (or project approval modifications) are required impact upon relics andor Aboriginal objects must not occur until heritage approvals are issued by the appropriate regulator
Contractorrsquos Project Manager Excavation Director
66 Where statutory approval is not required but where recording is recommended by the archaeologistAboriginal heritage consultant sufficient time must be allowed for this to occur
Contractorrsquos Project Manager Excavation Director
67 Ensure short term and permanent storage locations are identified for archaeological material or other heritage material removed from site where required Interested third parties (for example museums local Aboriginal land councils or local councils) should be consulted on this issue Contact the archaeologist or Aboriginal heritage consultant for advice on this matter if required
Contractorrsquos Project Manager Excavation Director
7 Resume work
71 Seek written clearance to resume project work from the project Excavation Director Archaeologist Aboriginal heritage consultant
Clearance would only be given once all archaeological excavation andor heritage recommendations and approvals (where required) are complete Resumption of project work must be in accordance with the all relevant projectheritage approvalsdeterminations
Contractorrsquos Project Manager Excavation Director
72 If required ensure archaeological excavationheritage reporting and other heritage approval conditions are completed in the required timeframes This includes artefact retention repositories conservation andor disposal strategies
Contractorrsquos Project Manager Excavation Director
73 If additional unexpected items are discovered this procedure must begin again from Step 1
All
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7 Responsibilities
Table 3 Roles and Responsibilities
Role Responsibility or role under this guideline
Contractor Supervisor
Stop work immediately when an unexpected heritage find is encountered Cordon off area until Environmental Manager Excavation Director advises that work can recommence
Manage the process of identifying protecting and mitigating impacts on the lsquofindrsquo
Liaise with Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Assist the archaeologistAboriginal heritage consultant with mitigation and regulatory requirements
Complete Incident Report and review CEMP for any changes required Propose amendments to the CEMP if any changes are required
Contractors Project Manager
Ensures all aspects of this procedure are implemented Advise Contractor Supervisor to recommence work if all applicable requirements have been satisfied and the Excavation Director
Project Archaeologist has approved recommend of work
Contractorrsquos or Project Heritage Advisor or Consultant
Provide expert advice to the Sydney Metro Environment Manager on find identification significance mitigation legislative procedures and regulatory requirements
Environmental Representative
Ensure compliance with relevant approvals (new and existing)
Sydney Metro Environment Manager
Notify the Sydney Metro Principal Manager Environmental Management of find and manage Incident Reporting once completed by Environmental Manager
Sydney Metro Senior Heritage Advisor
Provide expert advice to Sydney Metro Environment Manager and project as required
8 Seeking Advice
Advice on this procedure should be sought from the Sydney Metro Environment Manager in the first instance Contractors and delivery partners should ensure their own project environment managers are aware of and understand this procedure
Technical archaeological or heritage advice regarding an unexpected heritage item should be sought from a suitably qualified and experienced archaeologistAboriginal heritage consultant
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9 Related documents and references
Sydney Metro Environmental Incident Classification and Reporting ndash SM-17-00000096
Transport for NSW Guide to Environmental Control Map ndash 3TP-SD-01570
NSW Heritage Office (1998) Skeletal remains guidelines for the management of human skeletal remains
Roads and Maritime Services (2015) Standard Management Procedure Unexpected Heritage Items
Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal remains
Sydney Metro Exhumation Procedure ndash SM ES-PW-31510
10 List of appendices
The following appendices are included to support this procedure
Appendix 1 Examples of finds encountered during construction works
Appendix 2 Unexpected Heritage Item Recording Form
Appendix 3 Photographing Unexpected Heritage Items
Appendix 4 Uncovering Bones
Appendix 5 Archaeological Advice Checklist
Appendix 6 Template Notification Letter
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Sydney Metro ndash Integrated Management System (IMS)
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Appendix 1 Examples of finds encountered during construction works
Photo 1 - Aboriginal artefacts found at the Wickham Transport Interchange 2015
Photo 2 ndash Aboriginal artefacts (shell material) found at the Wickham Transport Interchange 2015
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Photo 3 1840s seawall and 1880s retaining wall uncovered at Balmain East 2016
Photo 4 Sandstone pavers uncovered at Balmain East 2016
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Photo 5 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 6 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 7 - Sandstone flagging and cesspit - Wynyard Walk project 2014
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Sydney Metro ndash Integrated Management System (IMS)
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Photo 8 - Chinese Ming Dynasty pottery and English porcelainpottery dating back to early 19th century - Wynyard Walk project 2014
Photo 9 - Pottery made by convict potter Thomas Ball during the early settlement - Wynyard Walk project 2014
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The following images obtained from the Roads and Maritime Servicesrsquo Standard Management Procedure for Unexpected Heritage items 2015 can be used to assist in the preliminary identification of potential unexpected items during construction and maintenance works Photo 10 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones (Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights Newcastle area) (RMS 2015)
Unclassified
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Photo 11 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones
(Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork
recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights
Newcastle area) (RMS 2015)
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Sydney Metro ndash Integrated Management System (IMS)
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Appendix 2 - Unexpected Heritage Find Recording Form
Example of unexpected heritage item recording form
This form is to be completed Excavation Director on the discovery of an archaeological heritage find during construction or maintenance works
Date Recorded by
(include name and position)
Project name
Description of works
being undertaken
Description of exact
location of item
Description of item
found
(What type of item is it likely
to be Tick the relevant
boxes)
A A relic A lsquorelicrsquo is evidence of a past human activity
relating to the settlement of NSW with local
or state heritage significance A relic might
include bottle utensils plates cups
household items tools implements and
similar items
B A lsquoworkrsquo building or
structurersquo A lsquoworkrsquo can generally be defined as a form
infrastructure such as track or rail tracks
timber sleepers a culvert road base a
bridge pier kerbing and similar items
C An Aboriginal object An lsquoAboriginal objectrsquo may include stone
tools stone flakes shell middens rock art
scarred trees and human bones
D Bone Bones can either be human or animal
remains
Remember that you must contact the local
police immediately by telephone if you are
certain that the bone(s) are human
remains
E Other
Provide a short
description of the item
(Eg metal rail tracks
running parallel to the rail
corridor Good condition
Tracks set in concrete
approximately 10 cm below
the current ground surface)
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Sydney Metro ndash Integrated Management System (IMS)
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Sketch
(Provide a sketch of the
itemrsquos general location in
relation to other road
features so its approximate
location can be mapped
without having to re-
excavate it In addition
please include details of the
location and direction of any
photographs of the item
taken)
Action taken (Tick either
A or B)
A Unexpected item
would not be further
impacts on by the
works
Describe how works would avoid impact
on the item (Eg the rail tracks would be left in
situ and recovered with paving)
B Unexpected item
would be further
impacted by the works
Describe how works would impact on the
item (Eg milling is required to be continued to a
depth of 200 mm depth to ensure the pavement
requirements are met Rail tracks would need to
be removed)
Excavation Director Signature
Signature
It is a statutory offence to disturb Aboriginal objects and historic relics (including human
remains) without an approval All works affecting objects and relics must cease until an
approval is sought
Approvals may also be required to impact on certain works
Important
Unclassified
Appendix 3 - Photographing unexpected heritage finds
Photographs of unexpected finds in their current context (in situ) may assist archaeologistsAboriginal heritage consultants to better identify the heritage values of the item Emailing good quality photographs to specialists can allow for better quality and faster heritage advice The key elements that must be captured in photographs of the item include its position the item itself and any distinguishing features All photographs must have a scale (ruler scale bar mobile phone coin etc) and a note describing the direction of the photograph
Context and detailed photographs
It is important to take a general photograph (Figure 1) to convey the location and setting of the item This will add value to the subsequent detailed photographs also required (Figure 2)
Figure 1 Telford road uncovered on the Great Western Highway (Leura) in 2008 (RMS 2015)
Photographing distinguishing features
Where unexpected items have a distinguishing feature close up detailed photographs must be taken of these features where practicable In the case of a building or bridge this may include diagnostic details architectural or technical features See Figures 3 and 4 for examples
Unclassified
Removal of the item from its context (eg excavating from the ground) for
photographic purposes is not permitted
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Unexpected Finds Procedure V20
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Photographing bones
The majority of bones found on site will be animal bones often requiring no further assessment (unless they are in archaeological context) However if bones are human the police must be contacted immediately (see Appendix 5 for detailed guidance) Taking quality photographs of the bones can often resolve this issue quickly The project archaeologist can confirm if bones are human or non-human if provided with appropriate photographs
Ensure that photographs of bones are not concealed by foliage (Figure 5) as this makes it difficult to identify Minor hand removal of foliage can be undertaken as long as disturbance of the bone does not occur Excavation of the ground to remove bone(s) should not occur nor should they be pulled out of the ground if partially exposed
Where sediment (adhering to a bone found on the ground surface) conceals portions of a bone (Figure 6) ensure the photograph is taken of the bone (if any) that is not concealed by sediment
Ensure that all close up photographs include the whole bone and then specific details of the bone (especially the ends of long bones the epiphysis which is critical for species identification) Figures 7 and 8 are examples of good photographs of bones that can easily
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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be identified from the photograph alone They show sufficient detail of the complete bone and the epiphysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Unexpected Finds Procedure V20
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Appendix 4 - Uncovering bones
This appendix provides advice regarding
what to do on first discovering bones
the range of human skeletal notification pathways and
additional considerations and requirements when managing the discovery of human remains
1 First uncovering bones
Refer to the Sydney Metro Exhumation Procedure
Stop all work in the vicinity of the find All bones uncovered during project works should be treated with care and urgency as they have the potential to be human remains The bones must be identified as either human or non-human as soon as possible by a qualified forensic or physical anthropologist
On the very rare occasion where it is immediately obvious from the remains that they are human the Project Manager (or a delegate) should inform the police by telephone prior to seeking specialist advice It will be obvious that it is human skeletal remains where there is no doubt as demonstrated by the example in Figure 17 Often skeletal elements in isolation (such as a skull) can also clearly be identified as human Note it may also be obvious that human remains have been uncovered when soft tissue andor clothing are present
7
After Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal
Remains 17
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Unexpected Finds Procedure V20
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This preliminary phone call is to let the police know that a specialist skeletal assessment to determine the approximate date of death which will inform legal jurisdiction The police may wish to take control of the site at this stage If not a forensic or physical anthropologist must be requested to make an on-site assessment of the skeletal remains
Where it is not immediately obvious that the bones are human (in the majority of cases illustrated by Figure 2) specialist assessment is required to identify the bones Photographs of the bones can assist this assessment if they are clear and taken in accordance with guidance provided in Appendix 3 Good photographs often result in the bones being identified by a specialist without requiring a site visit noting they are nearly always non-human In these cases non-human skeletal remains must be treated like any other unexpected archaeological find
If the bones are identified as human (either by photographs or an on-site inspection) a technical specialist must determine the likely ancestry (Aboriginal or non-Aboriginal) and burial context (archaeological or forensic) This assessment is required to identify the legal regulator of the human remains so urgent notification (as below) can occur
Preliminary telephone or verbal notification by the archaeologist to the Sydney Metro Senior Heritage Advisor is appropriate This must be followed up later by a formal letter notification to the relevant regulator when a management plan has been developed and agreed to by the relevant parties
2 Range of human skeletal notification pathways
The following is a summary of the different notification pathways required for human skeletal remains depending on the preliminary skeletal assessment of ancestry and burial context
A Human bones are from a recently deceased person (less than 100 years old)
B Human bones are archaeological in nature (more than 100 years old) and are likely to be Aboriginal remains
C Human bones are archaeological in nature (more than 100 years old) and likely to be non-Aboriginal remains
Figure 3 summarises the notification pathways on finding bones
Action
The Heritage NSW must be notified immediately
Action
The police must be notified immediately as per the obligations to report a death or suspected death under s35 of the Coroners Act 2009 (NSW) It should be assumed the police will then take command of the site until otherwise directed
Action
The Department of Planning Industry and Environment Aboriginal Heritage Section must be notified immediately The project Aboriginal Cultural Heritage Advisor must contact and inform the relevant Aboriginal community stakeholders who may request to be present on site
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Sydney Metro Unexpected Finds Procedure V20
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Figure 3 Overview of steps to be undertaken on the discovery of bones
After the appropriate verbal notifications (as described in 2B and 2C above) the Project Manager must proceed through the Unexpected Heritage Items Exhumation Procedure (Step 4) It is noted that no Exhumation Procedure is required for forensic cases (2A) as all future management is a police matter Non-human skeletal remains must be treated like any other unexpected archaeological find and so must proceed to record the find
3 Additional considerations and requirements
Uncovering archaeological human remains must be managed intensively and needs to consider a number of additional specific issues These issues might include facilitating culturally appropriate processes when dealing with Aboriginal remains (such as repatriation and cultural ceremonies) Project Managers may need to consider overnight site security of any exposed remains and may need to manage the onsite attendance of a number of different external stakeholders during assessment andor investigation of remains
Project Managers may also be advised to liaise with local churchreligious groups and the media to manage community issues arising from the find Additional investigations may be required to identify living descendants particularly if the remains are to be removed and relocated
If exhumation of the remains (from a formal burial or a vault) is required Project Managers should also be aware of additional approval requirements under the NSW Public Health Act 1991 Specifically Sydney Metro may be required to apply to the Director General of NSW
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Department of Health for approval to exhume human remains as per Clause 26 of the NSW Public Health (Disposal of Bodies) Regulation 2002 8
Further the exhumation of such remains needs to consider health risks such as infectious disease control exhumation procedures and reburial approval and registration Further guidance on this matter can be found at the NSW Department of Health website
In addition due to the potential significant statutory and common law controls and prohibitions associated with interfering with a public cemetery project teams are advised when works uncover human remains adjacent to cemeteries to confirm the cemeteryrsquos exact boundaries where possible
8 This requirement is in addition to heritage approvals under the Heritage Act 1977
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Appendix 5 - Archaeologicalheritage advice checklist
The archaeologistAboriginal heritage consultant must advise the Sydney Metro Environment Manager and Senior Heritage Advisor of an appropriate archaeological or heritage management plan as soon as possible after an inspection of the site has been completed An archaeological or heritage management plan can include a range of activities and processes which differ depending on the find and its significance
In discussions with the archaeologistAboriginal heritage consultant the following checklist can be used as a prompt to ensure all relevant heritage issues are considered when developing this plan This will allow the project team to receive clear and full advice to move forward quickly Archaeological andor heritage advice on how to proceed can be received in a letter or email outlining all relevant archaeological andor heritage issues
Required Outcomenotes
Assessment and investigation
Assessment of significance YesNo
Assessment of heritage impact YesNo
Archaeological excavation YesNo
Archival photographic recording YesNo
Heritage approvals and notifications
AHIP section 140 section 139 exceptions section 60 exemptions etc
YesNo
Regulator relicsobjects notification YesNo
Notification to Sydney Trains for s170 heritage conservation register
YesNo
Compliance with CEMP or other project heritage approvals
YesNo
Stakeholder consultation
Aboriginal stakeholder consultation YesNo
Artefactheritage item management
Retention or conservation strategy (eg items may be subject to long conservation and interpretation)
YesNo
Disposal strategy YesNo
Short term and permanent storage locations (interested third parties should be consulted on this issue)
YesNo
Control Agreement for Aboriginal objects YesNo
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Unexpected Finds Procedure V20
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Appendix 6 - Template notification letter
Insert on Sydney Metro letterhead
Select and type date] [Select and type reference number]
XXX
Heritage NSW Department of Planning Industry and
Environment
xxx
Parramatta NSW 2124
[Select and type salutation and name]
Re Unexpected heritage item discovered during Sydney Metro activities
I write to inform you of an unexpected [select relic heritage item or Aboriginal object] found during Sydney Metro investigative and construction works at [insert location] on [insert date] in accordance with the notification requirement under select section 146 of the Heritage Act 1977 (NSW) [Where the regulator has been informally notified at an earlier date by telephone this should be referred to here]
[Provide a brief overview of the project background and project area Provide a summary of the description and location of the item including a map and image where possible Also include how the project was assessed under the Environmental Planning and Assessment Act 1979 (NSW) (eg Part 5) Also include any project approval number if available]
Sydney Metro [or contractor] has sought professional archaeological advice regarding the item A preliminary assessment indicates [provide a summary description and likely significance of the item] Please find additional information on the site recording form attached
Based on the preliminary findings Sydney Metro [or contractor] is proposing [provide a summary of the proposed archaeologicalheritage approach (eg develop archaeological research design (where relevant) seek heritage approvals undertake archaeological investigation or conservationinterpretation strategy) Also include preliminary justification of such heritage impact with regard to project design constraints and delivery program]
The proposed approach will be further developed in consultation with a nominated Office of Environment and Heritage staff member
Should you have any feedback on the proposed approach or if you require any further information please do not hesitate to contact [Environment and Planning Project Manager] on (02) XXXX XXXX
Yours sincerely
[Sender name]
Sydney Metro Director Environment Sustainability amp Planning [Attach the archaeologicalheritage management plan and site recording form]
NB On finding Aboriginal human skeletal remains this letter must also be sent to the Commonwealth Minister for the Environment in accordance with notification requirements under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 56 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 5B ndash Sydney Metro Exhumation Management Procedure
Unclassified
Exhumation Management
Procedure
SM ES-PW-31510
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final issued for Implementation
Version 40
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2017
Unclassified
Integrated
Management
System
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 2 of 24
Table of Contents
Contents 1 Introduction 3
2 Methodology 3 21 Overview of legislative requirements for dealing with human remains
4 22 Discovery of human remains and forensic cases NSW Coroners
Act 2009 (NSW) 4 23 Historic human remains Heritage Act 1977 and Guidelines for the
Management of Human Skeletal Remains under the Heritage Act 1977 5
24 Aboriginal human remains National Parks and Wildlife Act 1974 6 25 Exhumation of human remains Public Health Regulation 2012
(NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013) 7
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013) 7
27 Work Health and Safety Act 2011 7
3 Sydney Metro procedure for the discovery and management of human remains 8 31 Initial discovery of bones What do we do 8 32 Archaeological Exhumation Methodology 10
4 Excavation and post-excavation tasks 14 41 Research Questions 14 42 Process for DNA Testing Isotope Analysis and Environmental
Sampling 15 43 Reporting 16 44 Public Involvement 16 45 Temporary Storage and Permanent Repository or Resting Place for
Remains 17
5 Definitions 18
6 Related Documents and References 18
7 Superseded Documents 18
8 Document History 18
9 Schedule of Acronyms 18
Exhumation of Human Remains 20 EXHUMATION OF HUMAN REMAINS 1 MANDATORY REQUIREMENTS 1 IMPLEMENTATION 1 REVISION HISTORY 2 CONTENTS 4 APPENDIX 2 11 APPENDIX 3 12 APPENDIX 4 13 APPLICATION TO EXHUME REMAINS 16
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1 Introduction
This Exhumation Management Procedure (ExMP) has been developed to provide Sydney Metro and their contractors with guidance on managing the discovery of human skeletal remains during the course of the Sydney Metro program of works
Sydney Metro is Australiarsquos biggest public transport project From the northwest metro rail is being extended under Sydney Harbour through new underground city stations and beyond to the south west In 2024 Sydney will have 31 metro railway stations and a 66km standalone metro railway system revolutionising the way Australiarsquos biggest city travels (refer to Figure 1)
The purpose of this ExMP is to provide a clear and concise process to follow in the event of the discovery of potential human remains during Sydney Metro project works
This ExMP will be reviewed as required and prior to any future Sydney Metro project that has potential to impact on a known cemetery or burial ground A review may require amendment the ExMP to tailor additional controls or management procedures that are specific to the impacted cemetery or burial ground In addition the requirements of the relevant Planning Approval will be assessed during the review of this ExMP prior to its implementation
This procedure should be read in conjunction with the Sydney Metro Unexpected Finds Policy
2 Methodology
This ExMP outlines the procedure for the management of the discovery of human remains within the Sydney Metro program The ExMP addresses the following
Discussion of relevant legislation and guidelines (eg Coroners Act 2009 Heritage Act 1977 Guidelines for the Management of Human Skeletal Remains 1988 and the Public Health Regulations 2012)
Archaeological methodology for excavation of remains including processes for appropriately handling remains in accordance with the relevant guidelines
Preparation of a flow chart process to be used by contractors to respond to the discovery of suspected human remains
Post-exhumation management primarily around relocation processing and long- term arrangements
Process for nomination of a physical anthropologist and temporary storage location
Process for additional analysis including DNA testing isotope analysis and environmental sampling and discussion on requirements for public involvement
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Figure 1 2020 Sydney Metro Program Project overview and station locations
21 Overview of legislative requirements for dealing with human remains
The following section provides an overview of the legislation that would apply to the discovery management and relocation of human remains A discovery of suspected human remains may be subject to different Acts and requirements thereby triggering different notification pathways based on the specific circumstances involved
The first step will always be to notify the NSW Police Confirmation of the age (antiquity) and nature of the skeletal remains as well as the reasons for the disturbance will dictate which Act and provisions will be applicable
22 Discovery of human remains and forensic cases NSW Coroners Act 2009 (NSW)
For a discovery of suspected human remains less than 100 years old the remains would come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such a case would be considered a lsquoreportable deathrsquo and under legal notification obligations set out in s35 (2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (ie both Aboriginal and non-Aboriginal remains)
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35 Obligation to report death or suspected death
(1) This section applies to any person who has reasonable grounds to believe that a death or suspected death of another person
(a) is a reportable death or occurred in circumstances that would be examinable under Division 2 of Part 32 and
(b) has not been reported in accordance with subsection (2)
(2) A person to whom this section applies must report the death or suspected death concerned to a police officer a coroner or an assistant coroner as soon as possible after becoming aware of the grounds referred to in subsection (1)
Maximum penalty (subsection (2)) 10 penalty units
(3) A police officer to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner or assistant coroner as soon as possible after the report is made
(4) An assistant coroner to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner as soon as possible after the report is made
(5) A coroner to whom a death or suspected death is reported under this section is required to inform the State Coroner of the report as soon as practicable after the report is made
23 Historic human remains Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 19771 (the Guidelines) apply to historic burials in New South Wales It should be noted that the Guidelines are outdated in terms of the current statutory framework
A relic is defined as an archaeological deposit or artefact that has heritage significance at a local or State level The guidelines Assessing Significance for Historical Archaeological Sites and `Relics2 have been endorsed by the Heritage Council and should be used to assess the level of heritage or archaeological significance of the remains With reference to burial grounds objects such as headstones grave enclosures and grave goods as well as buried human remains may be a lsquorelicrsquo
1 NSW Heritage Office 1998
2 Heritage Branch of the Department of Planning 2009
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(Uncontrolled when printed)
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Approval under the Heritage Act 1977 and the National Parks and Wildlife Act 1974 is not required if human remains are uncovered during a Critical State Significant Infrastructure (CSSI) project However notification to the Heritage Council under s146 of the Heritage Act and notification of an Aboriginal object under the National Parks and Wildlife Act is required if archaeological human remains are uncovered
24 Aboriginal human remains National Parks and Wildlife Act 1974
The National Parks and Wildlife Act provides statutory protection for all Aboriginal lsquoobjectsrsquo (consisting of any material evidence of the Aboriginal occupation of NSW) under Section 90 of the Act and for lsquoAboriginal Placesrsquo (areas of cultural significance to the Aboriginal community) under Section 84
Discovery of Aboriginal burials andor human remains would be addressed in the projectrsquos Aboriginal Cultural Heritage Assessment Report (ACHAR) ACHARs would be prepared in accordance with the Heritage NSW
lsquoGuidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation3
Guide to investigating assessing and reporting on Aboriginal cultural heritage in NSW4
Aboriginal cultural heritage consultation requirements for proponents 20105
Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales6
If suspected human skeletal remains are uncovered at any time during the archaeological management program the process outlined in this ExMP and detailed in the flow chart is to be followed Management of the remains would be guided by consultation with the nominated Registered Aboriginal Parties (RAPs) for the project in adherence to the ACHAR
3 NSW Department of Environment and Conservation 2005
4 OEH 2011
5 Department of Environment Climate Change and Water 2010
6 OEH 2010
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25 Exhumation of human remains Public Health Regulation 2012 (NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013)
Public Health Regulation 2012 and the NSW Health Policy Statement ndash Exhumation of human remains of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies in NSW
Under Clause 70 of the Regulation an application for approval to exhume the remains of a dead person may be made to the Director-General via an approved form to the Director of the Local Public Health Unit that acts on behalf of the Director-General of NSW Health Exhumation is not to take place unless an authorised officer or a NSW Health member of staff is present at the exhumation (the grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer) (Clause 72) An authorised officer must be present at the exhumation to ensure the correct interment procedure is followed and that all of the remains are exhumed and to enforce the protection of public health should this be necessary
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013)
The NSW Ministry of Health Policy Statement on the exhumation of human remains provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation Under Clause 69 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General An application for permission to exhume the remains of a deceased person is to be made to the Public Health Unit on the approved form which is contained at the NSW Health website
The required form is appended to this ExMP for ease of reference
Note that the title of Director General of Health was replaced with the Secretary of Health when the Public Health Act and Public Health Regulation were amended However the Policy Directive PD2013-046 has not been amended to reflect this change
27 Work Health and Safety Act 2011
The Work Health and Safety Act 2011 provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices and are enforced by WorkCover NSW Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation More information on safe work practices is available at or by contacting SafeWork NSW via their website or directly
Health and safety aspects of working with human remains should be considered Generally working with archaeological human skeletal remains requires no extra precautions to be taken beyond normal health and safety regulations Once any necessary site health and safety precautions have been taken the exhumation of human remains can proceed
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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3 Sydney Metro procedure for the discovery and management of human remains
This procedure provides project managers principal contractors and the project archaeologistExcavation Director with advice on the steps to follow upon uncovering suspected human remains Information on the potential for burials and human remains would be included in the general project induction for all personnel The induction would include the procedure to manage these finds as set out in this ExMP
31 Initial discovery of bones What do we do
To avoid doubt all suspected bone items must be treated as potential human skeletal remains and work around them must stop while they are protected and investigated as a matter of urgency
Stop Work and preliminary notification
On discovery of bone (suspected human remains) all work in the area of the find must stop and the remains must be confirmed as being human or not
The Project ArchaeologistExcavation Director must be notified
Preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 2009
What When bones are uncovered at a site all work in the area the find must stop immediately and the
site must be secured
Who The discoverer will immediately notify machinery operators so that no further disturbance of the
remains will occur as well as notify the foremansite supervisor principal contractor project archaeologistExcavation Director and Sydney Metro Environmental Manager
Preliminary notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager Notification should provide verbal description of the remains and inform the police that consultation with technical specialists is being undertaken to confirm that the remains are human as well as the burial context (archaeological or less than 100 years old refer Step 2)
How Inform all site personnel of restricted access to the area of the discovery until further notice Area must be fenced off (flagging or temporary exclusion fencing)
Actions Notify site supervisor principal contractor project archaeologist Excavation Director and Sydney Metro Environmental Manger of the find and protect the suspected remains until an initial assessment can be undertaken by a technical specialist
Preliminary notification to NSW Police by Sydney Metro Environmental Manager
Confirm the remains are human
Skeletal remains could either be articulated and in a recognisable form of burial such as a coffin or common burial position of the body (eg supine prone or flexed) or they could be disarticulated or fragmented remains Within the boundaries of a known historic burial ground there is a high probability of the remains being human In a suspected forensic case (less than 100 years old) the remains may have clothing andor human tissue Disarticulated or fragmented bones are often uncovered and these may require specialist assessment to determine legal jurisdiction
If suspected human remains are identified during the course of project works preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 1999 (refer Step 1) NSW Police would be contacted immediately upon receipt of confirmation of human provenance
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Sydney Metro Exhumation Procedure v40 (final)
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What Confirmation that the remains are human their burial context - whether they are forensic (less than 100 years) or archaeological (older than 100 years) and suspected ancestry (Aboriginal or non- Aboriginal)
Who Excavation Director and or Forensic or physical anthropologist or archaeologist with specialist skills such as an osteoarchaeologist
Notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager
How Consultation could be undertaken as either an on-site inspection or via good quality photos sent to the nominated technical specialist of 1) the remains and 2) the site general site location of the discovery
Actions Contact nominated technical specialists to confirm that the remains are a) human b) burial context (archaeological or forensic) and c) suspected ancestry (Aboriginal or non-Aboriginal)
For the duration of the Sydney Metro project the nominated technical specialists are
Forensic Anthropologist ndash TBC by contractor for project area
Nominated Excavation Director ndash TBC by contractor for project area
Sydney Metro Environmental Manager to conduct and or oversee liaison with NSW Police
The archaeologist may be able to identify the nature of remains without input from the Forensic Anthropologist The Forensic Anthropologist should be contacted as required
Notification based on jurisdiction (forensic or archaeological)
Once confirmation is received from the technical specialist that the remains are of human origin there are three possible statutory pathways to follow based on the assessment
What Forensic case remains are less than 100 years old
Who If it is determined by specialist assessment (Step 2) that the remains are forensic the remains come
under the jurisdiction of the State Coroner and the Coroners Act 2009
How The NSW Police would likely secure the site and will advise on the procedure to be followed
Actions Environmental Manager to liaise with NSW Police
What Archaeological ndash non-Aboriginal human remains -more than 100 years old
Who Follow the Archaeology Exhumation Methodology as set out in Step 4 below
How Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Actions Follow the Archaeology Exhumation Methodology as set out in Step 4 below
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What Archaeological ndash suspected Aboriginal human remains -more than 100 years old
Who Recording of Aboriginal ancestral remains must be undertaken by or conducted under the direct supervision of a specialist with RAPs present
How The RAPs must be present where it is reasonably suspected that Aboriginal burials or human remains have been encountered
Actions Notify RAPs and follow ACHAR Notification to Heritage NSW
Follow the Archaeology Exhumation Methodology as set out in Step 4
32 Archaeological Exhumation Methodology
The following section provides the archaeological methodology for exhumation and the appropriate handling of human remains
Securing the Site
The strategy for the excavation and removal of human remains must be sensitive to public opinion and ethical issues and exhumation activities should not be visible to the general public The site may need to be screened off from public areas not only with hoarding but also in some cases with a roof to screen the site off from overlooking buildings At all times human remains should be treated with respect and dignity The perimeter of the excavation site should be demarcated by plastic tape or flagging with only technical staff allowed within this area for the duration of exhumation activities
The site should be protected from the elements including flooding contamination with dust or debris and other disturbance These measures would be formulated by the Excavation Director in consultation with the contractor and Sydney Metro where required and may differ from site to site
Excavation Director
Archaeological investigations are to be managed by a suitably qualified Excavation Director with experience in the historical archaeology of Sydney and the excavation and management of human remains For sites with potential for locally significant remains the Excavation Director should meet the NSW Heritage Council criteria for locally significant archaeological sites For sites with potential for State significant archaeology the Excavation Director should meet the NSW Heritage Council criteria for State significant archaeological sites
Excavation and recording
Exhumation and recording is to be undertaken in accordance with best practice forensic and Heritage Council guidelines Prior to removal the remains should be fully recorded in situ to understand their surrounding archaeological context This will include recording any disturbances to the burial and the identification of bones present In some cases the deposit of bones may be a mixture of articulated and disarticulated remains Care should be taken to distinguish articulated remains and to assess if they represent commingled individuals or disturbed remains belonging to one individual and to record them accordingly
Recording
A standard context recording system would be employed
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Detailed survey andor measured drawings would be prepared and include location of remains within the overall site (position of the body the direction of the burial noting any stratigraphic relationships with other archaeological features)
Any associated artefacts (potential grave goods burial furniture) would be recorded and collected by context for later analysis
Digital photography in RAW format using photographic scales and photo boards where appropriate A photographic record of all phases of the work on site would be undertaken
Registers of contexts photos samples and drawings would be kept
Excavation
Detection of the extent of the graveremains (if disarticulated)
Surface soils removed in excavation units of 100mm (site dependent) using small hand tools
Expose remains with soft paint brushes and pedestal the remains
Record position and depth of remains
Soil removed would be sieved through 3mm mesh to examine for teeth and bone fragments
Soil samples may be taken from the abdominal andor chest areas of the body (articulated remains) to retrieve further evidence
Exhumation must be under the control of the Excavation Director with the assistance of a Forensic Anthropologist if required Exhumation permits provided by NSW Ministry of Health may also require the presence of an authorised officer or a member of staff of the Ministry of Health
Further excavation of the bottom of the pit (grave) following removal to confirm the absence of further remains
Relocation of bones
Removal and collection of skeletal remains to follow standard forensic practice of labelling
Remove remains from the ground systematically and place in plastic bags according to anatomical areas of the body
Bags should not be air-tight and should have ventilation holes to prevent deterioration of fragile skeletal material Each bag should contain labels and the separate bags should then be placed in a large plastic bag crate or box labelled with the context information
The remains should be placed in a sturdy large cardboard box (approximately 600 x 300 x 200 mm) for relocation to off-site processing location
Resume work
Construction work may only recommence upon receipt of clearance certificate from the Excavation Director and may require additional NSW Ministry of Health approval If a forensic case written authorisation from the NSW Police is required
Reporting
A report would be prepared following the completion of the program of exhumation works separate to the archaeological excavation report for the project This report would include skeletal analysis catalogue comprehensively describe the process of exhumation detail
Unclassified
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(Uncontrolled when printed)
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the recording of the remains and synthesise the results of any further laboratory testing An assessment of significance for the remains would be provided and interpreted within the context of the archaeological research design (response to research questions)
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Figure 2 Exhumation Procedure Flow chart
Page 13 of 24
Discovery of bone
Non-human remains
Archaeologist to investigate and work not
to recommence until instrcuted by ED
Work only to recommence when clearance given by Excavation Director
Human Remains
Forensic
Sydney Metro Environmental
Manager to advise NSW POlice
Archaoelogical work not to recommence until clearance given
by NSW Police or Coroner
Aboriginal
Sydney Metro Environmental Manager to advise NSW Policye notify RAPs and follow
ACHAR
Archaoelogical work not to
recommence until clearance firven by
NSW Police or Coroner
Non Aboriginal
Sydney Metro Environmental Manager to notifiy NSW Policce Heritage NSW and DPIE
Sydney Metrocontractor to apply to Secretary of
Health to exhume
Exhumation of human remains by nominated ED Construction work not to commence until
ED issues Clearance Certificate
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
4 Excavation and post-excavation tasks
The following tasks relate to responses to the identification of human remains on site All management should be in accordance with the AARD and relevant Archaeological Method Statement (AMS) and be overseen by the Excavation Director The Excavation Director would nominate a Forensic Anthropologist where required
41 Research Questions
The following research questions should be used guide exhumations should intact burials disarticulated remain burial cuttings or associated material culture be uncovered during works
The research questions are a guide only and could be added to or amended by the Excavation Director depending on the nature of the find
Social History and Burial Practices
Does the location of the burialburial cutting correspond with historic plansdescriptions Are these sources reliable
Is there evidence of exhumation
Do graves cut into older ones What can this tell us about nineteenth century burial practices and how does this compare to other excavated cemetery sites in the region
What is the distance between burials (if multiple burials uncovered) Does this conform to known nineteenth century burial practices
What type of fill was used within grave cuttings What can this tell us about the surrounding environment and burial practices at the time
What materialstree species were used to produce coffins Can coffin manufacturing techniques or fastening methods (use of mortar screws nails tacks) be identified Does this match known burial practices of the time If alternative methods are identified what can this tell us about the manufacturer or economicsocial landscape
Can the class or rank of the individual be identified via coffin materials grave goods or clothingshrouds
Which direction is the burial orientated How does this correspond with the knownhypothesised location of denomination areas
If the burial is associated with additional individuals can a familial relationship be assessed through DNA or other genetic markers identifiable within the skeletal remains (eg impacted third molar)
Can an exchange between burial practices in Britain and colonial Sydney be identified through the burial remains Is there evidence for alternative burial practices associated with additional cultures
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Environmental Factors and Scientific Analysis
What is the condition of the bones How does their condition compare to known or nearby burials of the same age What environmental or human factors may have influenced the decomposition process
Can the health nutrition sex race stature or age be identified through the skeletal remains Is there evidence of trauma on the bones Is there evidence of pathology on the bones (eg syphilis tuberculosis tumours)
If archaeobotanical analysis is carried out what can it tell us about the surrounding environment and nearby plant species Can prepost-European landscapes be determined within the archaeobotanical record
Can stable isotope analysis address any questions regarding diet country of origin and nutrition
Can DNA testing address any questions not answerable by the skeletal remains themselves such as sex familial relationships (if buried with another individuals) or race
Is there potential for DNA to be tested against any individuals who may come forward as a descendant of the deceased
42 Process for DNA Testing Isotope Analysis and Environmental Sampling
Pre-Excavation
The Excavation Director in consultation with the Forensic Anthropologist will nominate a suitable laboratory prior to works commencing Approval for the analysis of skeletal remains soil samples and material samples from the laboratory would also be sought prior to works commencing
Excavation
In order to prevent cross-contamination the following sample collection and excavation process should be followed
The location quantity and material (bone teeth hair soil wood) of samples will be determined by the Excavation Director or Forensic Anthropologist prior to its collection
Samples would be stored in a safe secure and climate controlled location while excavations are in progress This would be chosen by the Excavation Director or Forensic Anthropologist on site
Each collected sample would be given a unique catalogue number and a sample register would be recorded throughout the excavation
ldquoClean Excavationrsquo procedures would be followed during the excavation of burials and during the sample collection process7 This would include
7 Guidelines for lsquoclean excavationrsquo are based on procedures outlined in Yang D Y amp Watt K 2005
Contamination controls when preparing archaeological remains for ancient DNA analysis Journal of Archaeological Science vol 32 pp 331ndash336 and Society for Historical Archaeology 2015-2017 Research and Analysis of Artefacts Accessed online at httpsshaorgconservation- factsfaqanalysisC on 2552017
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Latex gloves would be worn by individuals excavating andor handling bone or soil samples Gloves would be changed for each bone andor individual to prevent cross-contamination
Excavation toolsbrushes would be cleaned prior to and after the collection of each sample to prevent cross-contamination
In some cases a face mask would be worn when samples for DNA analysis are being collected
Bone samples for DNA testing would be collected with surrounding in situ soil and should not be cleaned prior to bagging
It may be necessary for individuals involved in sample collection to submit DNA for comparison in the event of cross-contamination and
All bags containing samples for analysis would be bagged and labelled appropriately to prevent cross contamination and ensure they are handled and stored correctly
Post-Excavation
On completion of excavations samples will be transported to nominated laboratories for analysis A record of their location will be kept
43 Reporting
The results of the investigation of human remains and the exhumation will be included in the archaeological reporting for the project in accordance with the project AARD
Once finalised all archaeological excavation and data analysis reports will be submitted to
The relevant local Council and Library
The Heritage Office Library
The State Library of NSW and
Made available online for public access and educational purposes
Further if significant remains are identified during excavations the results and findings would be published in academic journals and conference papers where feasible
44 Public Involvement
Archaeological excavations may uncover remains directly associated with early settlement and burial practices Such remains are likely to generate public interest
Public involvement may include
Media releases
Public Open Days
Preparation of brochures detailing the archaeological excavations
Interpretive signage and online blog posts or site diaries while excavations are taking place and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The preparation of a Heritage Interpretation Plan designed to provide interpretation of the site within the new development upon the completion of works
Due to sensitive nature of human skeletal remains these recommendations would be adapted and modified as appropriate under the direction of Sydney Metro and the Excavation Director
Such recommendations would also be considered and require approval from relevant Stakeholder Groups such as known or potential descendants of the deceased NSW Heritage Heritage Council local Council and interest groups
45 Temporary Storage and Permanent Repository or Resting Place for Remains
Temporary Storage
Upon the completion of archaeological excavations skeletal remains should be boxed separately and temporarily stored within a safe secure and temperature controlled environment to allow for further analysis of the remains This location would be chosen by the Excavation Director and the Forensic Anthropologist and comply with NSW legislative requirements
Permanent Repository or Resting Place for Remains
A permanent repository or resting place for remains is dependent on the nature and volume of skeletal remains As this cannot be determined prior to excavations taking place the following recommendations should act as guidelines only Final arrangements would be dictated by Sydney Metro the Excavation Director Forensic Anthropologist identified descendants of the deceased andor Stakeholder Groups upon the completion of excavations and subsequent analysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
5 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined inhttpsicentraltdocstransportnswgovauotcscsexeappnodes3574566
6 Related Documents and References
Related Documents and References
na
7 Superseded Documents
Superseded Documents
Exhumation Management Plan Version 22
Exhumation Management Plan Version 30
8 Document History
Version Date of approval Notes
11 May 2017 New IMS document
20 July 2017 Incorporates Stage 2 (Section 3)
21
February 2019
Extended for Metro Program wide application includes changes specific Central Station management incorporates comments received from the State Coronerrsquos Office NSW Police NSW Health Sydney Metro Environmental Environmental Representatives engaged on the Central site and the Office of Environment and Heritage
22 February 2019 Incorporates comments received from Artefact Heritage and Denise Donlan issued to Health and OEH HD for consultation
30 May 2019 Incorporates Health Coroner and OEH comments
40 April 2020 Updates to remove specific references to City and South West and Central Station
Change of title to ldquoProcedurerdquo
Update to references
9 Schedule of Acronyms
Acronym Meaning
AARD Archaeological Assessment and Research Design
ACHAR Aboriginal Cultural Heritage Assessment Report
AMS Archaeological Method Statement
CSSI Critical State Significant Infrastructure
ER Environmental Representative (Independent)
ExMP Exhumation Management Plan (this plan)
OEH Office of Environment and Heritage
PHU Public Health Unit
RAPs Registered Aboriginal Parties
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Appendix 1
NSW Heath Policy Directive for Exhumation of Human Remains
Policy Directive
Ministry of Health NSW 73 Miller Street North Sydney NSW 2060
Locked Mail Bag 961 North Sydney NSW 2059 Telephone (02) 9391 9000 Fax (02) 9391 9101
httpwwwhealthnswgovaupolicies
Exhumation of Human Remains
Document Number PD2013_046
Publication date 05-Dec-2013
Functional Sub group Population Health - Environmental
Summary This document provides the policy to be observed by NSW Health in receipt of an application to seek permission for approval of the exhumation of human remains under clauses 69-72 of the Public Health Regulation 2012 This Policy Directive will provide the conditions on which approvals may be granted for exhumation of human remains
Replaces Doc No Burials - Exhumation of Human Remains [PD2008_022]
Author Branch Environmental Health
Branch contact Environmental Health 94245823
Applies to Local Health Districts Environmental Health Officers of Local Councils Ministry of Health Public Health Units Public Hospitals
Audience Authorised officers from Public Health Units and local councils
Distributed to Public Health System Environmental Health Officers of Local Councils NSW Ambulance Service Ministry of Health Public Health Units Public Hospitals
Review date 05-Dec-2018
Policy Manual Patient Matters
File No 081292
Status Active
Director-General
This Policy Directive may be varied withdrawn or replaced at any time Compliance with this directive is mandatory for NSW Health and is a condition of subsidy for public health organisations
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 1 of 2
EXHUMATION OF HUMAN REMAINS
PURPOSE
This document provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Common reasons for exhuming bodies include to repatriate the remains overseas or to relocate the body to another cemetery plot or vault
MANDATORY REQUIREMENTS
Under Clause 69 of the Public Health Regulation 2012 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General
An application for approval to exhume the remains of the body of a dead person may be made to the Director General by
An executor of the estate of the dead person
The nearest surviving relative of the dead person
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person may make the application
An application is to be made in the approved form and it is to be accompanied by
A certified copy of the death certificate relating to the dead person
A statutory declaration as to the relationship of the applicant to the dead person and the dead persons wishes if any regarding the disposal of his or her body
An application fee
Under Clause 71 of the Public Health Regulation 2012 the Director-General may
Grant an approval to exhume the remains of a body
Refuse the application
Under Clause 72 an exhumation cannot take place without an authorised officer or a Ministry of Health staff member present A person must not proceed with an exhumation if the authorised officer or Ministry of Health staff member who is present at the exhumation orders the exhumation to stop
Under Clause 78 if the applicant seeks to have the exhumed body cremated a separate application can be made for an exemption from providing the required cremation documentation provided the body has been buried for longer than 10 years The minimum 10 year period is strictly enforced An application under this clause is to be accompanied by a fee of $100
IMPLEMENTATION
Authorised officers in Public Health Units of Local Health Districts are responsible for assessing applications for exhumation of human remains and either approving with a set of conditions or rejecting the application Authorised officers should ensure that all of the required document has been submitted with the application fee and that an appropriate person has applied for the application The approval granted is valid for a period of three months after the approval is granted
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 2 of 2
REVISION HISTORY
Version Approved by Amendment notes
December 2013 PD2013_046
Deputy Director- General Population and Public Health
This document is an updating of the original document due to legal changes under the Public Health Regulation 2012
23 April 2008 PD2008_022
Director-General This document provided the policy to be observed by NSW Health in receipt of an application to seek permission for approval of exhumation of human remains under clauses 25 ndash 28 of the Public Health (Disposal of Bodies) Regulation 2002 It provided the conditions upon which approvals could be granted for the exhumation of human remains
ATTACHMENTS
1 Exhumation of Human Remains Procedures
Exhumation of Human Remains PROCEDURES
Issue date December-2013
PD2013_046
Exhumation of Human Remains
Issue date December-2013 PD2013_046 Contents Page
PROCEDURES
CONTENTS
1 BACKGROUND 2
11 Introduction 2
12 Key definitions 2
13 Legal and legislative framework 3
2 APPLICATION REQUIREMENTS 6
3 APPROVAL BY PUBLIC HEALTH UNITS 7
31 Delegation 7
32 Special Considerations on Exhumation Approval 7
33 Conditions of Approval 8
34 Approval Instrument 8
35 Notification of Approval 8
36 Refusals 8
37 Cremation of Remains 8
APPENDIX 1 10
APPENDIX 2 11
APPENDIX 3 12
APPENDIX 4 13
APPENDIX 5 14
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 2 of 14
1 BACKGROUND
11 Introduction
Exhumation of human remains may occur for a number of reasons including
To satisfy family wishes where the family of the deceased person may want the remains to be moved to another burial ground to another part of the state or country or abroad or even to have the remains cremated
To obey Coronial orders requiring exhumation for forensic (criminal) investigation
To enable the use of closed cemeteries for redevelopment or for the construction of new infrastructure such as a road or airport
A variety of people including authorised officers cemetery authorities and funeral directors are involved at different stages of exhumation procedures
Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation however there is no obligation to proceed with an exhumation once it has been approved
The objectives of this document are
To assist authorised officers with processing applications to exhume
To standardise the management of an exhumation so as to prevent a public health risk and protect community amenity in the handling of remains
12 Key definitions
These definitions are repeated from the Public Health Act 2010 and Public Health Regulation 2012 for clarity
Body Means the body of a dead person but does not include
the cremated remains of the person
Burial Includes putting the body in a vault
Cemetery Authority Means the person or body that directs the operations of a cemetery
Coroner Means a person who exercises or performs the functions of a coroner in accordance with the Coroners Act 2009
Dead person Includes a still-born child (see definition of Still birth)
Exhumation Means the removal of a dead personrsquos remains (not being cremated remains) from a grave or vault but does not include their removal from one vault for immediate transfer to another vault in the same cemetery or their temporary removal for the purposes of reburial in the same grave or vault
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 3 of 14
Funeral director Means a person (other than the operator of a mortuary transport service) who in the conduct of the personrsquos business engages for the purpose of burial cremation or transport in the collection transport storage preparation or embalming of bodies or engages in the conduct of exhumations
Prescribed infectious diseases
Means any one of the following diseases avian influenza in humans diphtheria plague respiratory anthrax smallpox severe acute respiratory syndrome tuberculosis and any viral haemorrhagic fever (including Lassa Marburg Ebola and Congo-Crimean fevers)
Proper person The Director General has the power to decide whether a person is a lsquoproper personrsquo to make an application to exhume the remains of a dead person
Nearest surviving relative
Means (a) In relation to a still-born child a parent or sibling at or above the age of 16 years of the child (b) In relation to a dead person who is not a still-born child ndash the spouse or de facto partner of the dead person immediately before death a parent of the dead person a child at or above the age of 16 years of the dead person or any relative of the dead person who was residing with the dead person when he or she died
Still-birth Consistent with the Births Deaths amp Marriages Act 1995 means the birth of a child that exhibits no sign of respiration or heartbeat or other sign of life after birth and that (a) Is of at least 20 weeksrsquo gestation (b) If it cannot be reliably established whether the period of gestation is more or less than 20 weeks has a body mass of at least 400 grams at birth
13 Legal and legislative framework
Public Health Regulation 2012
Division 4 of Part 8 of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies
Clause 69 Exhumation without approval prohibited
(1) A person must not exhume the remains of a body unless the exhumation of those remains has been
(a) Ordered by a coroner
(b) Approved by the Director-General
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 4 of 14
(2) However a funeral director may without a coronerrsquos order or Director-Generalrsquos approval transfer a coffin from a vault in a cemetery to a mortuary for the purpose of the coffin being immediately repaired and returned to the vault
(3) A funeral director must return the coffin to the cemetery within 24 hours of its transfer
Clause 70 Application to exhume remains
(1) An application for approval to exhume the remains of the body of a dead person may be made to the Director-General by
(a) An executor of the estate of the dead person
(b) The nearest surviving relative of the dead person
(c) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances may make the application
(2) An application is to be made in the approved form and is to be accompanied by
(a) A certified copy of the death certificate relating to the dead person
(b) A statutory declaration as to the relationship of the applicant to the dead person and the dead personrsquos wishes if any regarding the disposal of his or her body (so far as any such wishes are known to the applicant)
(c) An application fee (please check with the PHU for the current fee)
(3) In this clause death certificate means a certificate given by a medical practitioner as to the cause of death or issued under the Births Deaths and Marriages Registration Act 1995
All applications to exhume remains must be made in writing using an approved form to the Director of the local Public Health Unit that acts on behalf of the Director-General of the NSW Ministry of Health The application fee may increase periodically in line with the Consumer Price Index
Clause 71 Approval to exhume remains
(1) The Director-General may
(a) Grant an approval to exhume the remains of a body subject to any conditions specified in the approval
(b) Refuse the application
(2) An approval granted under this clause remains valid for three months from the date of the approval or for a period agreed to by the Director-General
The PHU is not bound to approve the application The PHU may approve subject to conditions or refuse the application An approval is normally given for 3 calendar months and this date will be specified in a schedule of conditions attached to the approval document Any further extension of time may require re-application and re-approval An approval initially for longer than three calendar months should be negotiated with the PHU
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 5 of 14
Clause 72 Exhumation not to take place without authorised officer present
(1) A person must not proceed with an exhumation unless an authorised officer or a member of staff of the Ministry of Health is present at the exhumation
(2) A person must not proceed with an exhumation if the authorised officer or Ministry staff member who is present at the exhumation orders the exhumation to stop
The grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer An authorised officer must be present at the exhumation to ensure that the correct interment is opened to ensure that all of the remains are exhumed and to enforce the protection of public health should this be necessary The authorised officer has the power to order that the exhumation be stopped immediately under adverse circumstances An example of where this may occur is where the weather is very poor with heavy rain The initial order to stop is to be given verbally and then confirmed in writing to all parties involved within 24 hours
Division 5 of Part 8 of the Public Health Regulation 2012 provides for cremation of deceased persons
Clause 78 No cremation without documentation
Clause 78 does not apply to a cremation of the body of a dead person that has been buried for at least 10 years if the cremation is carried out in accordance with an exemption granted by the Director-General following an application by
1) An executor of the estate of the dead person
2) The nearest surviving relative of the dead person
3) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
This is a new addition to the Exhumation section of the Regulation that may be used where a person makes a separate application to have the exhumed body cremated following the exhumation
Note The Director-Generalrsquos authority under Clause 78 (4) of the Public Health Regulation 2012 (Delegations Manual page 866 delegation (PH590)) is the power to decide whether a person is a ldquoproper personrdquo to make an application in the absence of an executor or surviving relative
Work Health and Safety Act 2011
The Work Health and Safety Act 2011 and Code of Practice for Excavation provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation The Work Health and Safety Act 2011 makes reference to working in confined spaces
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 6 of 14
WHampS matters are enforced by WorkCover NSW More information on safe work practices is available at httpwwwworkcovernswgovaudefault or by contacting Workcover NSW direct on 13 10 50
Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977 applies to relic burials Any burial site over 50 years old is considered to be relic under the Heritage Act If the site is listed on the State Heritage Register then approval is required from the Heritage Council of NSW
An application must be made to the Heritage Office before any disturbance removal or work commences on the site Approval for an exhumation under the Public Health Regulation 2012 does not obviate the necessity to obtain approval under the Heritage Act 1977 For further information contact the Heritage Office of NSW or visit httpwwwheritagenswgovau
Coronerrsquos Act 2009
A coroner may order an exhumation for the purposes of forensic investigation or a criminal investigation Such an order is outside the ambit of the Public Health Regulation 2012 The Police may request that an authorised officer from the Ministry of Health or the local Public Health Unit be present at the coronial exhumation
Births Deaths and Marriages Registration Act 1995
Section 41(2) of the Births Deaths and Marriages Registration Act 1995 requires that if human remains (other than cremated remains) are removed from NSW the funeral director or other person who arranges for the removal of the remains from NSW must within 28 days of disposal of the remains outside NSW give the Registrar notice of the new location of interment The act is available at httpwwwaustliieduauaulegisnswconsol_actbdamra1995383 The Registry of Births Deaths and Marriages may be contacted via httpwwwbdmnswgovau
2 APPLICATION REQUIREMENTS
An application for permission to exhume the remains of a deceased person is to be made to the PHU on the approved form which is contained at the NSW Ministry of Health website at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c70- application-to-exhumepdf
The application must be made by either
An executor of the estate of the deceased
The nearest surviving relative
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 7 of 14
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
The application must be accompanied by
A certified copy of the death certificate (death certificate issued by the Registry of Births Deaths and Marriages)
A statutory declaration that states
The relationship between the applicant and the deceased or the reason the applicant is the proper person to make the application
If the deceased left any instructions regarding the disposal of their bodyremains if known
In addition to the above an applicant should declare that he or she has consulted each nearest surviving relative and that they have no objection to the proposed exhumation
An application fee (please check with the PHU for the current fee)
Note If there is no agreement amongst nearest surviving relatives the applicant should seek independent legal advice regarding this issue The applicant should advise if there is an intention to cremate the body following the body being exhumed and the appropriate form completed
3 APPROVAL BY PUBLIC HEALTH UNITS
Approval by PHUs for an exhumation must be given by formal correspondence
31 Delegation
The Director-Generalrsquos authority under clauses 69(1) 70(1)(c) and 71 of the Public Health Regulation 2012 has been delegated to the Chief Health Officer Director Health Protection Public Health Officer or Public Health Unit Director as appointed under Section 121 of the Act (delegation PH308 PH309)
32 Special Considerations on Exhumation Approval
Special consideration should be given to the approval of an exhumation if the deceased was infected with a prescribed infectious disease For example if the deceased was infected with diphtheria or tuberculosis exhumation should not permitted in the first year of interment
Although not prohibited an exhumation of the remains of a body that was buried without a coffin will be approved only where the cemetery authority and funeral director have agreed to proceed with the exhumation especially during the first three years of interment
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 8 of 14
33 Conditions of Approval
After due consideration of the application and the statutory declaration(s) the PHU should then consider applying appropriate conditions to facilitate an approval
There are two standard sets of approval conditions which can be applied as appropriate
Appendix 2 ndash Schedule A - Conditions of Approval for Exhumation from a Grave
Appendix 3 ndash Schedule B - Conditions of Approval for Exhumation from an Above Ground Structure
Any other additional conditions that are deemed necessary to permit the exhumation may be added to schedule A or B based on the individual circumstances of the exhumation If some conditions are unwarranted they may be removed from the relevant schedule
34 Approval Instrument
An approval must be in writing and must be signed the Director General or their delegate A template to assist in the approval process can be found at Appendix 4 This template is to be completed by the Authorised Officer in order to facilitate approval by the delegate
35 Notification of Approval
The approval instrument is retained on file as a record that approval was granted by the Director General or their delegate Therefore it is necessary to advise the applicant the cemetery authority and the funeral director of the approval
The attached letter templates may be used for approval notification of the exhumation to the applicant funeral director and Cemetery Authority
Appendix 5 ndash Sample Letter to Applicant
Appendix 6 ndash Sample Letter to the Cemetery Authority and Funeral Director
36 Refusals
If after due consideration the application is to be refused then the applicant should be notified in writing specifying the reasons for refusal Ideally the applicant should consult the PHU in the first instance to discuss the requirements and possible restrictions on an application to exhume
37 Cremation of Remains
Division 5 of Part 8 of the Public Health Regulation 2012 sets out the requirements for documentation for cremations in NSW and includes the requirement for a cremation application form a cremation certificate and the cremation permit The documentation confirms the identity of the body to be cremated and the cause of death and ensures that a coronerrsquos investigation has been conducted where necessary
After the body is exhumed the next of kin may wish to have the body cremated However there may be cases whereby the body does not have the required paperwork necessary for cremation Clause 78 of the Public Health Regulation 2012 provides an exemption for
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 9 of 14
the required documentation for cremation where the body has been buried for longer than 10 years An application under this clause is to be accompanied by a fee
The Director General has the power to approve an exemption and the executor or the nearest surviving relative or another proper person may make application on form lsquoApplication for Exemption by the Director ndash General to the Requirement for Documentation for Cremation to Proceed Permission for Cremation of Exhumed Remains of a Body Buried more than 10 years ago with statutory declarationrsquo The minimum 10 year period will be strictly enforced and this matter should be clarified prior to any exhumation approval where it is planned for the remains to be subsequently cremated The application form is available at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c78-application-for- exemptionpdf
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 10 of 14
APPENDIX 1
Schedule A
CONDITIONS OF APPROVAL FOR EXHUMATION FROM GRAVE
1 The exhumation is to be carried out in the presence of a Public Health Unitrsquos authorised
officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Day and time of the exhumation shall be arranged by the participating parties and agreed
to by the Public Health Unit
4 The approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The presence of any relative of the deceased at the exhumation is strictly prohibited
6 No animals are to be permitted within the exhumation site
7 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
8 If during the course of the exhumation it is determined necessary to stop the exhumation
by either the exhumation supervisor cemetery manager or authorised Officer for any valid reason eg work health and or public health risk then the exhumation must cease
9 The remains of the deceased shall be enclosed in a body bag and placed into a new coffin
with a name plate attached inscribed with the name of the deceased
10 The remains of the original coffin are to be placed in the new coffin where possible Where there is an excess of remains of the original coffin these remains should be disposed in a sanitary and agreed manner
11 Excavated soil should be back filled The soil that was removed from immediately above
and around the coffin should be replaced first
12 If the exhumed remains are to be transferred to another cemetery a funeral director shall be contracted to transfer the remains from the cemetery grounds or carry out preparatory work for the safe reinterment of the remains
13 The exhumation will not proceed during or following a period of heavy rainfall within the preceding 24 hours of the appointed time of exhumation The cemetery manager is to confirm that satisfactory conditions exist for the exhumation to proceed two hours prior to the commencement of the exhumation
14 Used disposable protective equipment and materials are to be placed in a sealed plastic
bag and disposed of in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 11 of 14
APPENDIX 2
Schedule B
CONDITIONS OF APPROVAL FOR EXHUMATION FROM ABOVE GROUND STRUCTURE
1 The exhumation is to be carried out in presence of a Public Health Unit authorised officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Date and time of the exhumation shall be arranged by the participating parties and agreed to
by the Public Health Unit
4 An approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
6 If during the course of the exhumation it is determined necessary to stop the exhumation by
either the exhumation supervisor Cemetery Manager or authorised officer if for any valid reason eg worker health andor public health risks then the exhumation must cease
7 Used disposable protective equipment and materials are to be placed in a sealed plastic bag
and disposed in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 12 of 14
APPENDIX 3
LETTERHEAD
APPROVAL INSTRUMENT TEMPLATE
Public Health Unit Environmental Health Section
File Number [XXXXX]
PURPOSE To approve of the exhumation of the late
RECOMMENDATION
Approval is granted by the Director General pursuant to clause 71(1)(a) Public Health Regulation
2012 to [NAME OF APPLICANT] to exhume the remains of the late [NAME OF DECEASED]
KEY ISSUES
[DETAILS OF THE APPLICATION STATUTORY DECLARATION RELEVANT ISSUES
MANAGEMENT PLAN AND JUSTIFICATION OF SUGGESTED CONDITIONS ARE TO BE
INCLUDED HERE]
BACKGROUND (TO BE COMPLETED BY PHU)
CONSULTATION (TO BE COMPLETED BY PHU WHERE APPROPRIATE)
The approval be subject to compliance with the conditions specified in Schedule A Schedule B
and to expire on
Signature Authorised officer
Author Telephone Date
1 Authorised officer
2 Public Health Unit Director Public Health Officer [SIGN AND DATE]
Approved via delegation from the Director-General PH308 PH309 page 863 Public
Health Delegations Manual under clause 69(1) and 70(1) (C) Public Health Regulation
2012
3 Authorised officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 13 of 14
APPENDIX 4
LETTERHEAD
SAMPLE LETTER TO APPLICANT
[APPLICANTrsquoS NAME] [ADDRESS]
Dear [APPLICANTrsquoS NAME]
Reference is made to your application of [DATE] requesting approval to exhume the remains of
late [NAME OF DECEASED] from grave vault crypt No Section [NAME OF
PLACE OF INTERMENT OR CEMETERY] for the purpose of re-interment to [NAME OF PLACE
FOR RE-INTERMENT]
Approval has been granted by the Director-General pursuant to clause 71 (1) (a) Public Health
Regulation 2012 subject to compliance with the conditions specified in Schedule A Schedule B
attached
The funeral director and cemetery authority have been advised of the approval
Should you have any inquiries please contact the authorised officer [EHO] on [TELEPHONE] or (EMAIL ADDRESS)
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 14 of 14
APPENDIX 5
LETTERHEAD
SAMPLE LETTER TO CEMETERY AUTHORITY AND FUNERAL DIRECTORS
[NAME] [ADDRESS]
[DATE]
Dear [NAME]
EXHUMATION OF THE REMAINS OF THE LATE [NAME OF DECEASED]
Approval has been granted for the exhumation of the late [NAME OF DECEASED] from grave
vault crypt No Section [NAME OF PLACE OF INTERMENT OR
CEMETERY] in accordance with clause 71(1) (a) of the Public Health Regulation 2012 and
subject to compliance with the conditions specified in Schedule A Schedule B attached
A copy of the approval letter is attached for your information
Should you have any inquiries please contact [Authorised Officer) on [TELEPHONE] or email address
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
Unclassified
Addendum 2
NSW Heath Permit Application form
copy Sydney Metro 2017 Page 23 of 24
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
APPLICATION TO EXHUME REMAINS PUBLIC HEALTH REGULATION 2012 Clause 70(2)
In accordance with the requirements of Clause 70 (2) of the Public Health Regulation 2012 I helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Full name of applicant)
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip hereby (Address)
apply for permission to exhume the remains of the late helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Name of deceased)
from Grave Nohelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Section helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip being a single
interment within the helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipCemetery for the purpose of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
I seek permission to exhume for the following reasons
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
The deceased (cross out which is not applicable)
was not known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012 or
was known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012
I am entitled to make this application because I am (tick one)
1 [ ] The executor of the estate of the deceased or
2 [ ] The nearest surviving relative of the deceased or
3 [ ] If there is no such executor or relative available to make the application another the proper person to make the application for the reasons set out below
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Full reasons for proper person to make application) Attached is
1 A certified copy of the death certificate of the deceased
2 A statutory declaration as to
My relationship to the deceased and
the wishes of the deceased regarding the disposal of the body (if known)
the reasons why the Director-General may consider me the proper person in all the circumstances to make the application (if applicable)
3 The application fee of $helliphelliphelliphelliphelliphelliphellip
Signature helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Date helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Applicant)
The exhumation is to be supervised in strict accordance with the attached Plan of Management
by helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
employed with helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip(Funeral DirectorCemetery)
in the capacity of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
Form C70
Unclassified
copy Sydney Metro 2017 Unclassified Page 24 of 24
ExMP v30 (final)
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
bttp wwwshd nsw gay auQQpulat onhealthPubtic Healthhtml
NSW
Public Health Unit ll iI I
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 57 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise gaseous and particulate pollutant emissions from construction activities as far as feasible and reasonable Identify and control potential dust and air pollutant sources
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Site related dust identifiable fumes odours and vapours will not infringe beyond site boundaries where practical
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required for air quality and dust management including - Correct use of PPE - Use of monitoring equipment - Methods to control dust
Project Manager
Greenhouse Gases
Regular maintenance of plant and equipment for optimum performance will be undertaken to keep emissions to a minimum and increase plant productivity
Vehicles and equipment must be fitted with appropriate emission control equipment and routinely maintained Plant should be switched off when not in use wherever practicable
All plant equipment and vehicles are to be regularly monitored and maintained and records kept of maintenance Engine tampering to increase power output is prohibited
Air emissions from plant vehicles and equipment should be visually monitored throughout construction
Comply with National Greenhouse Emission Reporting Scheme (NGERS) reporting requirements
Project Manager
Dark Smoke
All internal combustion engines will be regularly serviced to ensure optimum operation and minimise the volume of visible smoke emitted Any Plant or light vehicles emitting unreasonable smoke (concentrations higher than normal operation) will cease operation and be serviced by a trained and qualified technician
Materials on site will not be burned intentionally without consulting and obtaining the authorisation of the relevant Local Shire Fire Authority and Client The burning of any material on site should be a last option after alternative methods have been considered
All
Dust Monitoring
The following dust monitoring methods will be applied on the Site
Obtaining weather reports from the Bureau of Meteorology (BOM) website Visual inspection
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 58 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Dust Control
Dust control methods to be applied on the site to keep dust generated within the site boundaries as reasonably practicable will be
- Wind fencing around the site or between the site and local residences - Application of waterdust suppressant via water carts - Hydro mulching to stabilise soils - Physical application of ground cover - Cessation of works in adverse weather conditions - Restricted speed limits on site - Reschedule dust generating activities to avoid adverse weather conditions - Communicate dust risk and mitigation measures to staff prior to commencing work
All
Fumes Odours and Vapours
The Site will endeavour to keep the generation of emission of unreasonable levels of fumes odours and vapours to a minimum Refer to the Waste Management Sub Plan and Hydrocarbon and Chemical Environmental Management Sub Plan which detail storage and handling controls that minimise fumes odours and vapours
All
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for dust mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 59 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise unreasonable noise and vibration impacts on residents and businesses Avoid structural damage to buildings or heritage items as a result of construction vibration Undertake active community consultation Reduce visual impact of construction to surrounding community Maintain positive cooperative relationships with schools childcare centres local residents and building owners
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Community
The nearest noise and vibration sensitive receivers will be notified of future works and expected levels of noise and vibration well in advance of the works occurring Notifications will be in accordance with the Community Communications Strategy
Information will be provided to the affected community before and during construction through media such as letterbox drops meetings or individual contact A website will also be established for the project to provide information
A toll-free 24hour project hotline will be provided for enquiries and complaints during the works
Sydney Metro and Georgiou Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the site specific management required
for noise and vibration including
- Sensitive receivers - Hours of works - Correct use of plant and equipment - Monitoring requirements
Standard hours of construction
Approved standard hours of construction are Monday to Friday
7 am to 6 pm Saturday 8 am to 1 pm No work on Sundays or public holidays
Project Manager
Out of Hours works Any out of hourrsquos works will require a noise assessment and approval by Sydney Metro through the out of hourrsquos application (Appendix 7A)
Project Engineer Environmental Site Representative
Plant Equipment amp Vehicles
All operators of plant will comply with requirements of the Construction Traffic Management Plan in relation to parking and laydown access and egress to site haulage routes and general site traffic movements
Plant will be fitted with appropriate noise emissionvibration control equipment Plant will be fitted with adequate seat suspension
Plant Department
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 60 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Plant should be switched off when not in use wherever practicable Tasks using equipment that causes vibration to hands will be rotated at intervals to reduce
exposure Consideration may be given to the use of anti-vibration PPE All plant equipment and vehicles are to be regularly monitored and maintained and records kept
of maintenance Any abnormalities in expected noise or vibration emissions will be recorded in the plantrsquos log
book and reported to the plant department Prioritise the use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of
rockbreakers for demolition of structures Use of smaller capacity rockbreakers or lower vibration generating rockbreakers Consider methods of isolating the vibration sensitive structure from the vibration intensive work
area by severing the vibration transmission path using non-vibration intensive means such a sawing
Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Monitoring
Continuous vibration monitoring will be undertaken whenever vibration generating plant will be working close to or within the recommended minimum working distances
When conducting vibration monitoring within or near the minimum working distances a warning system will be implemented including one or both of an audible andor visual warning alarm andor SMS andor email alerts to site staff
Attended noise monitoring will occur at the nearest noise sensitive receiver when - Requested by Sydney Metro - When noise levels are predicted to exceed the NML by more than 10dBA - When out of hours works continue past midnight - When noise complaints are received
Noise monitoring will determine if the predictions in the noise assessment were accurate
Project Engineer Environmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for noise and vibration mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 61 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7A ndash Sydney Metro Out of Hours Application form
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 1 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Out of hours work application form
This form is to be used for formal review and approval of out of hours (OOH) work as it may affect Residential and non-residential receivers This form can be used in accordance with the SM-17-00005396 City amp Southwest out of hours work protocol Each OOH application and all applicable appendices must be submitted to Sydney Metro as one PDF file at least 15 business days prior to the commencement of the proposed OOH work
1 OOH Application
Sydney Metro Project
Eg City amp Southwest Greater West West etc
Contract
Contractor
Application Title
Eg lsquoSmith St service relocation worksrsquo
Application Number
Eg 1 2 3 etc
Application Date
Original submission date (resubmission date in parentheses if applicable)
Relevant Planning Approval
Environment Protection Licence (EPL)
If subject to an EPL state title and number
2 Proposed OOH Work Details
Description of works including
Work methodologies
List of plantequipment to be used (worst case scenario)
Location Map (andor Environmental Control Map) attached as Appendix 1 indicating location of works plantequipment locations and receivers (including distance to nearest receiver for noisiest plantequipment)
Traffic Management Plan andor Traffic Control Plan if applicable as Appendix 2
Timing of works
Including proposed datestimes works are planned to be undertaken outside standard hours
Worst-case number of consecutive occasions affecting the same receiver
Refer to Section 4 for definition of lsquooccasionrsquo
Justification
Demonstrate how the proposed OOH work has been scheduled in accordance with the OOH work period prioritisation list Program acceleration is generally not accepted as a justification
Unless specified otherwise in project-specific documentation the prioritisation of work time periods is as follows
Standard Hours 7am to 6pm weekdays and 8am to 1pm Saturdays (note that Standard Hours for works subject to the City amp Southwest Sydenham to Bankstown planning approval also include 1pm to 6pm Saturdays)
Daytime OOH 1pm to 6pm Saturdays and 8am to 6pm Sundays and Public Holidays
Evening OOH 6pm to 9pm every day
Night Time OOH 9pm to 7am weekday mornings and 9pm to 8am weekend and Public Holiday mornings
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Assessed Noise and Vibration Impacts and Standard Mitigation Measures
Are the proposed works consistent with a prepared Construction Noise amp Vibration Impact Statement (CNVIS) (YN)
If lsquoNrsquo skip this section and move to Section 4
State the title of the CNVIS and attach the section(s) describing the noise and vibration impacts of the proposed works as Appendix 3
Quantitatively summarise the worst-case predicted noise and vibration impacts specific to the proposed OOH work for each OOH period on the nearest receivers and compare these against the respective management levels
For Night Time OOH Period works include a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Worst-case predicted noise impact summary
Worst-case predicted vibration impact summary
Potential sleep disturbance summary (for night time OOH periods only)
Using Table 4 and Table 5 indicate in Table 6
Which Additional Mitigation Measures (AMMs) are applicable for consideration
Which of those applicable for consideration are planned to be implemented
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered respite alternative accommodation etc)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
4 Non-Assessed Noise and Vibration Impacts
Skip this section if Section 3 has been completed in full
A quantitative noise assessment for OOH work is to be carried out in accordance with the Interim Construction Noise Guideline (DECC 2009) This section allows applicants to address these requirements through the following steps
1) Establishing Rating Background Levels (RBLs) and Noise Management Levels (NMLs)
2) Predicting the anticipated noise levels using a quantitative noise assessment
a Works that are not likely to generate high noise impacts for a significant duration may use a preliminary quantitative noise assessment (facilitated within this form) This ensures that all applications as a minimum include a preliminary quantitative noise assessment in accordance with the Interim Construction Noise Guideline (ICNG)
b Works that are likely to generate high noise impacts for a significant duration may require a detailed quantitative noise assessment (eg Construction Noise and Vibration Impact Statement) to be undertaken
c Works that are likely to generate ground-borne or structure-borne vibration andor noise require specialist advice and assessment
3) Comparing predicted noise levels against RBLsNMLs and applying standard mitigation measures as appropriate (ie implementing lsquoall feasible and reasonablersquo mitigation measures in accordance with the ICNG)
4) Considering additional mitigation measures when predicted noise levels exceed RBLsNMLs
The need for a detailed quantitative noise and vibration assessment will be considered by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable) collectively when the predicted noise levels are anticipated to
Exceed an RBL at a residential receiver or an NML at a non-residential receiver by more than 10dBA AND
Affect the same receiver on 10 or more consecutive occasions An occasion is anytime works are carried out
o Between 6pm on a weekday and the start of standard hours the next day OR
o Between 1pm on a Saturday and 8am on a Sunday (or between 6pm on a Saturday and 8am on a Sunday for works subject to the Sydenham to Bankstown planning approval) OR
o Between 8am on a Sunday or public holiday and the start of standard hours the next day
A detailed quantitative noise and vibration assessment should generally include
Derivation of RBLs for residential receivers andor derivation of NMLs for non-residential receivers based on noise monitoring at representative locations and local sensitivities
Detailed noise predictions for daytime evening and night time OOH periods (as applicable) in accordance with Section 45 of the ICNG (including an outline of timing duration and predicted noise levels for each OOH period)
For Night Time OOH Period works a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Detailed predictions of vibration levels for sensitive receivers
Please complete the following Steps 1 to 4
Step 1
RBLsNMLs
If RBLs for residential receivers or NMLs for non-residential receivers have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment or Construction Noise and Vibration Impact Statement for other work activities) enter into Table 3 and attach the supporting evidence as Appendix 3
If no RBLsNMLs have been established use Table 1 to estimate and enter into Table 3
Step 2
Predicted Anticipated Noise Levels
If predicted anticipated noise levels have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment) enter the predicted anticipated noise levels into Table 3 and attach the supporting evidence as Appendix 3
If predicted anticipated noise levels have not already been established use Table 2 to estimate anticipated noise aspects for the noisiest plantequipment and enter into Table 3 In Table 3 use these values to calculate the anticipated predicted noise levels
Step 3
Exceedances and Mitigation Measures
Compare the anticipated predicted noise levels to the applicable RBLsNMLs calculate the exceedances and enter into Table 3 In Section 5 provide a description of the standard mitigation measures that are planned to be implemented in order to mitigate the noise impacts (and vibration impacts if relevant) as much as lsquofeasible and reasonablersquo in accordance with the ICNG
Step 4
Consideration of Additional Mitigation Measures
Use Table 4 and the exceedances in Table 3 to determine the applicable Additional Mitigation Measures for consideration Use
Table 6 to indicate which of these measures are applicable for consideration which will be implemented and provide justificationdetails accordingly
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
5 Standard Mitigation Measures
Outline the standard noise mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Outline the standard vibration mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Table 1 Noise RBLs and NMLs
Skip this section RBLs and NMLs have already been established in other documentation
Sensitive Receiver Category Estimated RBLs (dBA)
Residential Daytime OOH Evening OOH Night Time OOH
Urban (eg city hubs near busy roads near industrial activity) 55 50 45
Suburban 45 40 35
Quiet rural or isolated 40 35 30
Non-Residential ICNG NMLs (dBA)
Industrial facilities 75 (only applicable when in use)
Offices or retail 70 (only applicable when in use)
Health and educational facilities 55 (only applicable when in use)
Table 2 Predicted Noise Level Aspects
Skip this section if predicted noise levels have already been established in other documentation
Noise Aspect Select the most applicable value for each noise aspect below and enter into Table 3 dBA
1 PlantEquipment Noise Level at 10m
Including non-continuous use reduction (-5dBA) and annoying activity penalty (+5dBA) for as per ICNG (refer to ICNG Appendix B for predicted noise level data)
Underline indicates vibratory generating plantequipment
Impact sheet piling rig 100
Hand-held tamper excavator with hammer rock-breaker drivenvibratory piling concrete saw diamond saw air track drill large dozer hand-held rail grinder
95
Jackhammer rock crusher angle grinder pneumatic hammer medium dozer tracked loader impact wrench
90
Mainline tamper ballast regulator dynamic track stabiliser vibratory roller mainline rail grinder ballast train (pourfill ballast) chainsaw tub grinderlarge mulcher scraper grader super-suckervacuum truck large backhoewheeled front-end loader bored piling pavement profiler fixed crane tracked excavator
85
Small bulldozer small excavator tower crane truck-mounted crane forklift bobcat skid-steer front-end loader road trucktruck and dog dump truck concrete truckpumpmixer compressor non-vibratorylarge pad foot roller whacker packercompactor water cart pavement laying machine asphalt truck and sprayer line marking truck standard penetration testing welder pin puller
80
Concrete vibrator cherry-picker scissor liftelevated work platformFranna crane small backhoe front end loader fence post driver electric drill rig hand held rattle gun generator (dieselpetrol) spreader
75
Lighting tower medium-rigid trucksemi-trailer welding equipment small front end loader 70
Light vehicle hand-tools (no impact) small cement mixer attenuated generator (inside housing)
65
2 Multiple Plant More than one of the noisiest plant being used simultaneously at roughly the same location +5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Local Screening
Existing screening between site and receiver (buildings cuttings canopies etc) - 5
Temporary screening to be implemented near work site - 10
Acoustic shed or enclosure - 25
4 Distance Attenuation
lt 10 metres 0
10 to 20 metres - 5
20 to 35 metres - 10
35 to 60 metres - 15
60 to 100 metres - 20
100 to 180 metres - 25
180 to 350 metres - 30
350 to 1000 metres - 40
Table 3 Predicted Noise Levels and Exceedances of RBLs andor NMLs (dBA)
Skip this section if Section 3 has been completed in full
Period
(only complete as applicable for each period)
Noisiest PlantEquipm
ent
(state the noisiest
plantequipment to be used during each applicable
OOH period)
Receiver Type
(state lsquoResrsquo or lsquoNon-Resrsquo as applicable for
closest receiver to noisiest
plantequipment)
Enter the most applicable values from Table 2 then add to determine
the Predicted Noise Level
Pre
dic
ted
No
ise L
evel
(1 +
2 +
3 +
4)
RB
L (
for
Res)
NM
L (
for
Non-R
es)
Exceedance
(Predicted Noise Level minus RBL for Res or NML for
Non-Res) 1
Pla
nt
Eq
uip
me
nt
No
ise L
evel
2
Mu
ltip
le
Pla
nt
Eq
uip
me
nt
3
Lo
cal
Scre
en
ing
4
Dis
tan
ce
Att
en
ua
tio
n
Daytime OOH
Evening OOH
Night Time OOH
Refer to OOH period timings under Section 2 of this form
Table 4 Additional Mitigation Measures (AMM) requiring Consideration for Implementation
OOH Period
AMMs that must be considered for implementation
(apply the exceedances from Table 3 to the two OOH period categories below as applicable)
lt= 10 dBA Exceedance
10 to lt= 20 dBA Exceedance
20 to lt= 30 dBA Exceedance
gt 30 dBA Exceedance
Daytime OOH Period ndash LB M LB M IB LB PC RO SN
Evening and Night Time OOH Periods
ndash M LB M IB LB PC SN RO M IB LB PC SN RO AA
AA is only applicable to Night Time OOH periods
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 5 List of Additional Mitigation Measures (AMM)
AMM Abbrev
AMM AMM Descriptions and Guidance
LB
Letterbox-drop
(generic to the project)
A newsletter is generally produced and distributed to the local community via letterbox-drop and the project mailing list These newsletters provide an overview of current and upcoming works across the project and other topics of interest The objective is to engage inform and provide project-specific messages The geographic extent of letterbox-drops is generally centred on the immediate surrounding community within 200 metres from the works site
For works that are subject to the Sydenham to Bankstown planning approval these will include an indicative schedule of likely OOH work for at least the upcoming two month period
M Monitoring
Where it has been identified that specific construction activities are likely to exceed the relevant Rating Background Levels (RBL) andor Noise Management Levels (NMLs) monitoring may be conducted at the affected receiver(s) or a nominated representative location (typically the nearest receiver where more than one receiver have been identified) Monitoring can be in the form of either unattended logging or operator attended surveys The purpose of monitoring is to inform the relevant personnel when the RBLNML has been exceeded so that additional management measures may be implemented
IB Individual Briefings
Individual briefings are used to inform stakeholders about the impacts of high noise activities and mitigation measures that will be implemented Communications representatives would visit identified stakeholders at least 48 hours ahead of potentially disturbing construction activities Individual briefings provide affected stakeholders with personalised contact and tailored advice with the opportunity to comment on the project
PC Phone calls
(andor emails)
Phone calls andor emails (with specific notifications attached) detailing relevant information would be made to identifiedaffected stakeholders within seven days of proposed work The objective of the phone calls andor emails is to support letterbox-drop and specific notifications Phone calls andor emails provide affected stakeholders with personalised contact and tailored advice with the opportunity to provide comments on the proposed work and specific needs
SN
Specific Notifications
(specific to the OOH work)
Specific notifications are letterbox-dropped to identified stakeholders no later than 7 days prior to out of hour construction activities commencing that are likely to exceed the RBLsNMLs Specific notifications may be produced by Sydney Trains or by Sydney Metro (or on behalf of Sydney Metro by a contractor as approved by Sydney Metro)
- Sydney Trains specific notifications cover all works being undertaken by various parties (including Sydney Metro) during designated rail possession periods These specific notifications are delivered 14 days prior to works commencing and are delivered to all properties located within 250m of the proposed works
- Sydney Metro specific notifications focus on proposed Sydney Metro works being undertaken outside of designated rail possession periods and are only produced in the absence of any Sydney Trains notifications covering the proposed works These notifications are delivered 7 days prior to works commencing and are delivered to all properties located within 100m of day works and within 200m of night works
All notifications are emailed to all registered stakeholders on site-specific email distribution lists
For works that are subject to the Sydenham to Bankstown planning approval these will include indicative information on the type of OOH work location duration expected noise characteristics expected noise level and likely mitigation and management measures
RO Respite Offer
The purpose of a project specific respite offer is to provide residents subjected to lengthy periods of noise andor vibration impacts respite during OOH periods Respite offers are offers made to affected receivers to provide a period of either no or limited noise impacts This can be in the form of stopping or limiting works onsite or offering affected receivers dinnermovie vouchers The first priority is to implement a period of no or limited noise impacts If this cannot be achieved dinnermovie vouchers may be offered on a case-by-case basis
AA Alternative
Accommodation (residential only)
Alternative accommodation options may be provided for residents living in close proximity to construction works that are likely to incur unreasonably high impacts during night time OOH periods Alternative accommodation will be considered on a case-by-case basis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 6 Consideration of Additional Mitigation Measures (AMM)
Additional Mitigation Measures
Applicable for Consideration
YN
(refer to Table 4)
To be Implemented
YN
JustificationDetails
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered RO AA etc)
LB
M
IB
PC
SN
RO
AA
For OOH work that is subject to the Sydenham to Bankstown approval and RO is required for consideration include in the lsquoJustificationCommentsrsquo column how community consultation influenced the decision to implement or not implement RO in accordance with Condition E23 If RO is being implemented include how community consultation influenced the manner in which RO is being implemented
6 Consideration Against Relevant Vibration Criteria
Using Table 2 indicate whether any vibratory plantequipment is planned to be used for the proposed works (YN)
If lsquoNrsquo skip this section and move to Section 7
lsquoPeoplersquo Criterion
Are the proposed works anticipated to have any perceptible sleep disturbance impacts (YN)
lsquoStructuresrsquo Criterion
Are the proposed works anticipated to generate greater than 75mms vibration impacts on surrounding structures (generally within 25 metres of works) (YN)
lsquoSensitive Equipmentrsquo Criterion
Are the proposed works anticipated to impact sensitive equipment located in surrounding non-residential receivers (YN)
If lsquoYrsquo is answered to ANY of the above criteria AND the impacts affect the same receiver for more than one consecutive occasion (refer to Section 4 for lsquooccasionrsquo definition) the need to prepare a detailed quantitative assessment will be considered collectively by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
7 City amp Southwest Construction Noise amp Vibration Strategy Addendum Mitigation Measures
If the proposed OOH work is part of the City amp Southwest project identify any mitigation measures to be implemented that have arisen from the City amp Southwest Construction Noise amp Vibration Strategy Addendum
8 Cumulative Impacts
Document the relevant details of any other OOH work (Sydney Metro or otherwise) that will impact the same receivers as those being impacted by these proposed works either concurrently or within 3 days of the start or end of these proposed works
If other works have been identified in the row above how have the proposed works been coordinated to ensure appropriate respite is provided
9 Community Consultation
What community consultation has been undertaken already
What community consultation is planned to be undertaken
If drafted already attach applicable Community Notification as Appendix 4
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
10 Contractorrsquos Signature
Contractorrsquos Identification of Risk Level
If subject to the Chatswood to Sydenham (C2S) or Sydenham to Bankstown (S2B) planning approval and not subject to an EPL provide Contractorrsquos Identification of Risk Level (refer to the City amp Southwest OOH Works StrategyProtocol for guidance)
Circle LOW or HIGH
Contractorrsquos Signature
Name
Title
Contact Number
Date
11 Contractorrsquos Contact Details
Contractor Personnel Name Mobile
Manager Environment
Manager Communications
Contractorrsquos Representative
Contractorrsquos 24hr contact person
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
C2SS2B Planning Approval Determination Page
Step 1 ndash Endorsement from Sydney Metro Director Public
Communications or Contractorrsquos Communications Manager
Step 2 ndash Risk IdentificationEndorsement from the AA under the C2S Planning Approval or from the
ER under the S2B Planning Approval
Step 3 ndash If works are under Sydney Trains EPL approval from Sydney Metro Director of Planning Environment and Sustainability
If works are not under an EPL approval from either the ER or the Secretary of the NSW Department of Planning amp Environment
Risk Level NA
If not subject to an EPL circle Risk Level as LOW or HIGH
If works are HIGH Risk Level and after 9pm Sydney Metro submits application to the Secretary of the
NSW Department of Planning amp Environment for approval
NA
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Role
Date
Comments
(including AAER Risk Level comments if applicable)
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Generic Determination Page (ie not subject to C2S or S2B planning approvals)
Step 1 ndash Sydney Metro Director of
Project Communications
Step 2 ndash Acoustic Advisor
(may be optional depending on planning approval or contract requirements)
Step 3 ndash Environmental Representative
(may be optional depending on planning approval or contract requirements)
Step 4 ndashSydney Metro Director of Planning Environment amp Sustainability
(only required if not approved already)
Action Endorsement Circle Endorsement or Approval Circle Endorsement or Approval Approval
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Date
Comments
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 12 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 1 Location Map (andor Environmental Control Map)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 13 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 2 Traffic Management Plan andor Traffic Control Plan
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 3 Supporting Evidence for Noise amp Vibration Impacts (eg Construction Noise amp Vibration Impact Statement noise assessment etc)
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 15 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 4 Community Notification
(if applicable and already drafted)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 62 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Any site contamination will be effectively managed to limit the potential risk to human health and the environment Spoil will be managed to avoid contamination of land or water Prioritise reuse of contaminated spoil into the project rather than offsite reuse or disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Planning and assessment
Planning
The Golders Douglas Partners contamination assessment report (June 2020) considered investigation results and data from previous relevant Sydney Metro West (SMW) investigations in the general area The physical characteristics of the soil on site as determined by the above report is described as ldquofill material described as containing evidence of anthropogenic materials including ash gravels terracotta tile fragments bricks and glass In addition to this sandstone bedrock was regularly encounteredsuspected to be present (eg drilling method refusal) during the pavement investigation This evidence implies that there is a wide variety of soil types and materials across the Site associated with natural and historical anthropogenic related activities The findings included elevated concentrations of heavy metals (copper nickel zinc) encountered at one location on the Site and several within close proximity to the Site However the exceedances were considered to pose a low risk to ecological receptors given that the majority of the Site is covered in asphalt hardstand with very low potential for exposure to subsurface soils Elevated concentrations of BaP were encountered in several boreholes within close proximity to the Site Once again the risks to ecological receptors from these were considered low due to the presence of asphalt hardstand at the Site Asbestos was identified at one borehole SMW_BH415 at a depth of 05 m The laboratory reported that chrysotile was detected below the reporting limit of 01 gkg The report considered due to the location access nature of the ACM (bonded) that there is a low risk of exposure to potential receptors Should the soil not be able to be reused on site further sampling assessment and waste classification must occur for any soil that is to be disposed offsite in accordance with the Sydney Metro Waste Classification Procedure (Appendix 1A)
Project Manager HampS Manager
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Unexpected finds of contamination onsite
In the event that contamination is identified on site Appendix 8A will be followed for soil contamination excluding Asbestos material For unexpected Asbestos Finds Appendix 8B will be followed
Supervisors All workers
Assessment
If any potential contamination is discovered during construction the soil will be excavated and transported to the stockpile area for assessment which may include sampling by a suitably qualified environmental consultant
The assessment must consider whether the material is suitable to return to site for reuse with consideration to the final land use and pathways and receptors for the contaminants
Laboratory testing associated with the assessment will be prioritised to 24 hour turnaround to mitigate any delay where required
The assessment detailing the type extent and management options for the contaminated soil must be provided to Sydney Metro before proceeding to either reuse or dispose of material
For unexpected Asbestos finds the controls listed in the section below must be followed before any excavation and transport to stockpile or offsite
Project Manager Supervisor Environmental scientist
Asbestos management measures
Access Restrictions
Signs and barriers will be erected to warn of the danger and to prevent unauthorised people entering areas where asbestos contaminated fill material is being excavated handled
The location and extent of any access control areas will be agreed in discussion between the Project Manager Project Engineer HSE Advisor and the Environmental Coordinator and will be established in accordance with NOHSC2002 (2005) Code of Practice for the Safe Removal of Asbestos (2nd Ed) guidelines
Potential entry points to the asbestos work area should be signposted or labelled in accordance with AS 1319 (1994) Safety Signs for the Occupational Environment and NOHSC 2002 (2005b)
Earthworks Engineers Licenced removal contractor Supervisors
Asbestos Removal
For unexpected Asbestos finds the Certified Occupational Hygienist will conduct a risk assessment to demine Air monitoring requirements and any other PPE and management controls prior to removal (see air monitoring section)
All removal procedures for asbestos should be undertaken under the supervision of an appropriately licensed contractor which is either ASA or ASB depending on the material being removed The removal of material shall be monitored by a relevantly trained supervisor in accordance with the Code of Practice for the Safe Removal of Asbestos [NOHSC 2002 (2011)]
You must be licensed to remove asbestos except if removing 10 square metres or less of non-friable asbestos
Engineers Certified Occupational Hygienist Licenced removal contractor
Workcover notification Permit to Work
A permit to work authority will need to be issued to and signed by the contractor Workers engaged in the removal of asbestos on site will not be issued with a permit to work unless
Engineers Licenced removal contractor
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
they are employed by a company holding a removal licence issued by WorkCover NSW appropriate for the type of asbestos materials concerned
Workcover must be notified at least five days prior to commencement of asbestos removal work
Safe Work Method Statement and Asbestos Removal Plan
All notification and permit applications for removal of asbestos in soils must be accompanied by a site risk assessment (Asbestos Removal Plan) carried out by a competent or licensed person who determines If the asbestos is bonded or friable The extent of contamination A safe work procedure for the remediation of the site
Engineers Licenced removal contractor
Dust Control
In order to remove the asbestos safely we shall be using the ldquowet methodrdquo to carry out these works The wet method includes continuously keeping the soil with asbestos fragments watered so as to eliminate the asbestos dustfibres becoming airborne An exclusion zone of 10m (or whatrsquos appropriate ndash depending on limitations) will be isolated from the rest of the site using fencing or bunting Any personnel that do not have the correct PPE or relevant training will not be allowed in this area
Supervisors Earthworks Engineers
Clearance
Following the excavation and removal of asbestos contaminated material a licenced asbestos assessor will conduct inspections and sampling (where required) in the excavation to confirm that no asbestos remains A clearance report will be issued and works can recommence in the area
Licenced Asbestos Assessor
All potential contaminated finds
Training
A toolbox must occur for all worker for unexpected contamination finds procedure They will also be informed of the Site specific controls required for management of contamination in soil Site access restrictions Correct use of PPE Decontamination procedures Use of monitoring equipment Waste handling procedures Dust control measures and performance measures
all workers
Stockpile Contingency Measures
The following contingency measures will be put in place should stockpiling of potential contaminated soils be required All potential contaminated stockpiles will be separated by lot numbers and sign posted to
avoid any cross contamination Any temporary stockpiles of asbestos contaminated soil will be maintained under moist
conditions and remain covered at all times Sediment controls will be installed downslope of all contaminated soil stockpiles In order to confirm that all contaminated soil has been removed an Environmental
Consultant (ADE) will conduct a visual inspection or sampling of the material below the
Supervisors Earthworks Engineers
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
stockpile and provide a clearance certificate or the like as legislated The Environmental Consultant will advise of the validation criteria dependant on the contamination of the soil
Material tracking for contaminated finds assessed as suitable for onsite reuse
Where suspected contaminated material is identified the material will be tracked from the area in which the material was identified to its location in stockpile (lot number)
For all material assessed as suitable for reuse onsite the material will be tracked from its stockpile location to final destination for reuse onsite Survey will determine the m3 and the location of the final destination
All materials movements associated with unexpected contamination finds will be recorded on the materials tracking register
Supervisors Earthworks Engineers
Waste classification for materials assessed unsuitable for onsite reuse
Waste classifications are required for any excavated soil or fill material which is to be disposed off-site Soil or fill material to be taken off-site for disposal shall be assessed in accordance with the waste classification guidelines (NSW EPA 2014) Materials excavated from the site should be tracked from lsquocradle to graversquo in order to provide detailed and accurate information about the location and quantity of all materials from the time of their excavation until their disposal For any truck or bin leaving the site the following information would be recorded origin of material material type waste classification report approximate volume truck andor bin registration number Receiving licenced facility For all soils known or having the potential to contain asbestos the following applies The POEO Act defines lsquoasbestos wastersquo as any waste that contains asbestos including
fragments or fibres It is understood that as a result the NSW EPA considers asbestos contaminated soil to be an asbestos waste In addition the Protection of the Environment Operations (Waste) Regulation 2014 provides certain requirements for the transportation of asbestos It is understood that the NSW EPA requires any management of soil containing asbestos waste on or off the site to be at least equal to controls set out by the Regulation
All asbestos contaminated soil or fill leaving site will be transported in a leak proof covered vehicle and disposed of at a licensed facility in accordance with waste classification guidelines (NSW EPA 2014)
Earthworks Engineers Licenced removal contractor ESR
Environmental Monitoring amp records
Air Monitoring
If asbestos removal work that requires a Class A licence that means it is friable then you must get the licensed asbestos assessor occupational Hygienist to undertake air monitoring of the asbestos removal area Monitoring for airborne asbestos in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres
Earthworks Engineers Licenced removal contractor Hygienist
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Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
[NOHSC 3003(2005)] the analysis should be carried out by a NATA accredited laboratory during the removal operations Refer to Clause 50 and 51 for the WorkCover 2011 Safety Regulation for requirements
For other contaminated soil the occupational hygienist may determine that the risks associated with their disturbance and handling requires air monitoring
Record Keeping
The records associated with management of contaminated land that should be kept include Material tracking register including lots volume and type Asbestos Removal Plan (ARP) Asbestos Register Airborne Monitoring Reports Calibration certificates for air monitors Clearance Inspection Reports or Certificates Waste classification reports Laboratory sampling results Landfill disposal dockets
Earthworks Engineers ESR HampS Manager
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Appendix 8A ndash Unexpected Contamination finds procedure
1 Introduction
The following unexpected contaminated finds procedure will be adopted in the event that potential contamination
is discovered during construction Implementation of this procedure will ensure that contamination is managed in
such a way as to avoid harm to the environment workers community and comply with relevant legislation
2 Identification of Contamination
An unexpected find of contamination is likely to comprise of any soil characteristic which is not a typical soil
material identified in previous contamination assessment reports The Golders Douglas Partners contamination
assessment report (June 2020) section 102 makes note of indicators of contamination as
Significant staining
Odours from Soils
Oily sheen on water leaving soils
Anthropogenic waste materials other than those identified in the report (ie Ash Gravels Terracotta Tile
Bricks and Glass)
Where the soil characteristics are consistent with the reports and the above indicators are not present then no
further assessment is required for onsite reuse
Examples of these indicators are shown below
Photo 1 - Significant Staining or odorous soils
Discoloured soil (soil with non-natural colouring) Pungent smelling soils - petroleum compost
putrefied sulphurous septic sweet aromatic odours
Photo 2 ndash Oily Sheen on water
Rainbow sheen on water surfaces in soil
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Photo 3 ndash Buried wastes
Buried oil drums chemical container
Photo 3 ndash Buried wastes
Buried demolition wastes (eg concrete tiles bricks asphalt timber metal
3 Potential risk areas of unexpected finds
The higher risk activities for encountering unexpected finds during construction activities are considered to be
excavation works that extend below road pavement layers and into general fill
Higher risk areas for encountering unexpected finds construction are considered to be
Areas of excavation that extend through general fill layers and into natural soils eg Stormwater trench
locations
Locations of excavation near previous Boreholes with identified contamination (see map below)
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4 Unexpected finds flow chart
If potentially contaminated soils are encountered the following steps must be followed
During excavationif visual indications of contamination are present such as significant stained soils
odorous soils sheen tarry or ashy material or unexpected anthropogenic material (other than what is
expected to be encountered on site) then
STOP EXCAVATION in the immediate affected area
Notify the Supervisor Environmental Site Rep and Client
Environmental consultant to conduct assessment on material to determine suitability for reuse onsite This
step may require sampling and lab analysis ndash undertake with quick 24hr turnaround
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No Yes
Sample test and classify in
accordance with Appendix
1A ndash Sydney Metro Waste
Classification procedure
Contact environmental consultant and hygienist and provide details of the find Depending on the nature and type
of the find they may be required to attend site before any further excavation disturbance
Excavate the material to the extent of the potential contamination in 200mm thick layers and in 500mm
horizontal increments (Do not exceed design excavation extents) and move to stockpile area (Where it will be
allocated a lot number and signposted to avoid any cross contamination) For Asbestos follow specific
requirements in the unexpected Asbestos Finds Procedure Cover the stockpile and install controls around the
stockpile
Offsite disposal at licenced
landfill facility Maintain all
waste tracking and disposal
records
No
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5 Materials Tracking
A Material tracking Register will be used to ensure information is collected for unexpected finds materials
identification and traceability This register records all unexpected finds materials The material is carefully
inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location and type of soil stored onsite
at the stockpile area The material class and stockpile number on the map will correspond with the information in
the register
6 Stockpile Management
The following contingency measures will be put in place should stockpiling of suspected contaminated soils be
required
All suspected contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Sediment controls will be installed downslope of all suspected contaminated soil stockpiles
7 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential contamination onsite as detailed in previous contamination assessment reports and this unexpected finds
procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works
Prior to commencement of each shift the Supervisor will inform all site personnel of any works involving
contaminated materials on site
8 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 8B ndash Unexpected Asbestos finds procedure
1 Introduction
The following Asbestos Management procedure will be adopted in the event that potential asbestos containing
material (ACM) or actual asbestos is uncovered during construction Implementation of this procedure will ensure
that asbestos is managed in such a way as to avoid harm to site personnel visitors and the community
2 Areas of known asbestos contamination
No asbestos was identified with the footprint of the proposed road construction works However there was one
Borehole (BH 415) from previous contamination assessments adjacent to the boundary that identified asbestos at
05m bgs The laboratory result was chrysotile detected below the reporting limit of 01 gkg (see location on map
below)
3 Identification of Asbestos
Asbestos has been used in the manufacturing of various products and these products can be found in either friable
or non-friable form All products are also known as asbestos-containing material Friable asbestos products are
generally quite loose and when dry can be crumbled into fine material or dust with light pressure such as
crushing with your hand
Non-friable asbestos products are made from a bonding compound (such as cement) mixed with a small proportion
(usually less than 15) of asbestos Non-friable asbestos products are solid rigid and non-friable and cannot be
crumbled pulverised or reduced to powder by hand pressure The asbestos fibres are tightly bound in the product
and are not normally released into the air When theyre in good condition non-friable asbestos products do not
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normally release any asbestos fibres into the air They are considered a very low risk for people who are in contact
with them as long as appropriate safety precautions are used when they are disturbed Non-friable asbestos
products that have been damaged or badly weathered may also become friable for example crushed asbestos
cement sheeting Examples of non-friable and friable asbestos are shown below
Photo 1 ndash example of non-friable asbestos in soil This is Asbestos cement sheeting that although broken it is solid rigid and cannot be crumbled or pulverised by hand pressure
Photo 2 ndash example of friable asbestos ndash this was a section of Asbestos cement sheeting that is weathered and crumbles under hand pressure
Photo 3 ndash example of non - friable asbestos ndash Asbestos cement water pipe in good condition
Photo 4 ndash example of friable asbestos ndash water pipe wrapped with friable woven ACM textile
4 Unexpected Asbestos ACM finds flow chart
In the event that a person on site identifies or disturbs asbestos ACM the unexpected asbestos management
procedure during Construction is summarised below
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Discovery of suspected asbestos containing materials
STOP EXCAVATION in the immediate affected area Demarcate and isolate area from workers
Notify the Supervisor
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next
step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No
Sample test and classify
in accordance with
Appendix 1A ndash Sydney
Metro Waste Classification
procedure
Yes
Friable Non Friable
Proceed with Licenced
Asbestos removal work in
accordance with section 6 -
11 Remove to stockpile for
reuse assessment by
Environmental Consultant
No
Greater than
10m2 of non-
friable asbestos
contamination
Less than 10m2 of
non-friable
asbestos
contamination
Proceed with non-
licenced asbestos
removal and
disposal in
accordance with
section 5
Trained and competent person to identify the asbestos
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5 Non Licence Asbestos removal work
Where small fragments of ACM or suspected ACM are found and provided that
the total number of fragments is lt 20 or
the total surface area of the fragmentpiece is lt 1 m2 or
the fragments are spread over an area of lt 10 m2 and
the fragments are non-friable
If the unexpected find meets the criteria above a trained and competent person will collect any fragments and
place it in a 200 mm polythene bag for later disposal at an appropriate waste facility A detailed visual inspection
of the area will be carried out by the Environmental consultant which will involve wet raking of the areas to a
depth of 10 cm for any further fragments If no further fragments are identified works can continue
If during the visual inspection the Environmental consultant determines that the criteria described above are
exceeded or if suspected asbestos ACM continues to be identified during excavation works andor if it is thought
that any uncovered material might be considered asbestos containing and friable works will cease and the
Environmental consultant will assess the situation and determine an appropriate course of action
6 Licenced Asbestos removal work
A licensed asbestos removalist will be required for removal works where there is friable asbestos or the
contaminated area is greater than 10 m2 There are two types of asbestos removal licences Class A and Class B
The type of licence required depends on the type and quantity of asbestos or ACM to be removed as outlined
below
Licence type What asbestos can be removed
Class A Can remove any amount or quantity of asbestos or ACM including any amount of friable asbestos or ACM any amount of asbestos-contaminated dust or debris (ACD) Any amount of non-friable asbestos or ACM
Class B Can remove
any amount of non-friable asbestos or ACM Note A Class B licence is required for removal of more than 10 m2
of non-friable asbestos or ACM but the licence holder can also remove up to 10 m2 of non-friable asbestos or ACM
ACD associated with the removal of non-friable asbestos or ACM Note A Class B licence is required for removal of ACD associated
with the removal of more than 10 msup2 of non-friable asbestos or ACM but the licence holder can also remove ACD associated with removal of up to 10msup2 of non-friable asbestos or ACM
No licence required Can remove
up to 10 m2 of non-friable asbestos or ACM ACD that is associated with the removal of less than 10 m2 of non-friable
asbestos or ACM Not associated with the removal of friable or non-friable asbestos
and is only a minor contamination
The licensed asbestos removalist will prepare an Asbestos Removal Control Plan prior to the removal of any
asbestos ACM The Asbestos Removal Control Plan documents the specific control measures to be implemented to
ensure site personnel and others are not at risk when asbestos removal work is being conducted It includes how
the asbestos removal will be carried out including temporary storage the method tools equipment and PPE to be
used and the asbestos ACM to be removed including the location type and condition of the asbestos ACM
The Client will be informed prior to excavation or removal of asbestos or ACM If the removal activity is to occur in
the vicinity of any occupied residence or business the project Community Advisor will notify the affected
residents or business owners
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7 Signage and demarcation
Georgiou will install warning signs and labels to clearly identify asbestos affected areas and where asbestos related
work is being carried out Flagging will be installed to delineate the asbestos related areas and restrict
unauthorised persons from entering the asbestos removal work Stockpiles will be covered and labelled Signage
and flagging will stay in place until all licensed asbestos removal work is complete and a clearance certificate is
provided
8 Notification
Prior to the commencement of licensed asbestos removal works notification to SafeWork NSW is required
SafeWork NSW requires a minimum of 5 daysrsquo notice prior to the removal of asbestos and the notification will be
made by the licensed asbestos removalist
9 Air Monitoring
All air monitoring requirements will be determined and conducted by a licensed asbestos assessor (LAA) The
location and layout of the air monitors will be detailed within the Asbestos Removal Control Plan
Air monitoring requirements will vary depending on the type of asbestos being removed the location and position
of the asbestos The following rules should be applied when determine if air monitoring is required (extract from
Safe Work Australia ndash Code of Practice on How to Safely Remove Asbestos (2016)
For friable asbestos removal ndash Air monitoring is mandatory for all friable asbestos removal This includes prior
to dismantling an enclosure and for the purposes of the clearance inspection
For more than 10 msup2 of non-friable asbestos removal ndash Air monitoring is not required but may be considered to
be carried out by a licensed asbestos assessor or competent person to ensure compliance with the duty to
eliminate or minimise exposure to airborne asbestos and to ensure the exposure standard is not exceeded
Public Location ndash Air monitoring should be considered where the asbestos removal work is being undertaken in
or next to a public location
Exposure air monitoring ndash Air monitoring should be carried out at other times to determine a workerrsquos exposure
to airborne asbestos if based on reasonable grounds there is uncertainty as to whether the exposure standard
may be exceeded and a risk assessment by a competent person indicates it is necessary Since most uses of
asbestos are prohibited exposure monitoring should not be required frequently
The results of air monitoring will be made available as soon as possible to all workers on site The asbestos
supervisor will be notified immediately if the fibre count exceeds the recommended level in the Exposure
Standards for Asbestos as set out in the National Code of Practice How to safely remove asbestos
10 Clearance
Following removal of asbestos ACM the licensed asbestos removalist will arrange for a clearance inspection of the
area to facilitate the issue of a clearance certificate and allow construction to recommence in the affected area
The clearance inspection is conducted by
an independent licensed asbestos assessor for work that was carried out by a Class A licensed asbestos
removalist
an independent competent person for asbestos work that is not required to be carried out by a Class A licensed
asbestos removalist
To be independent the licensed asbestos assessor must not be involved in the removal of asbestos for that specific
job and is not involved in a business or undertaking involved in the removal of the asbestos for that specific job
GC-HSE-PLA-437 Uncontrolled when saved or printed
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A clearance certificate will be issued if the independent licensed asbestos assessor or competent person is satisfied
that the asbestos removal area and the immediate area are free from visible asbestos contamination Entry to the
area will be permitted following confirmation of certification
11 Decontamination
Decontamination of site personnel PPE and tools used in asbestos removal work will minimise exposure and spread
of asbestos outside of the removal area
Personal decontamination will occur every time a worker leaves the asbestos removal work area and involves
removal of all visible asbestos dustresidue from PPE and Respiratory Protective Equipment using an asbestos
vacuum cleaner and or wet wiping with a damp cloth Disposable PPE is considered asbestos waste and will be
disposed of at an appropriate waste facility Non-disposable protective clothing will be laundered in a suitable
laundering facility that is equipped to launder asbestos-contaminated clothing
Workers must be aware of personal hygiene and ensure that they carefully wash when leaving an asbestos removal
area paying particular attention to hands fingernails face and head
Tools will be dismantled (where appropriate) cleaned under controlled conditions and decontaminated prior to
removal from the area or disposed of at a suitable off site location
12 Stockpile Management
The following contingency measures will be put in place for any temporary stockpiling of asbestos contaminated
soils
All asbestos contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Any temporary stockpiles of asbestos contaminated soil will be maintained under moist conditions and remain
covered at all times
Sediment controls will be installed downslope of all contaminated soil stockpiles
In order to confirm that all contaminated soil has been removed validation sampling beneath stockpiles will
occur by an Environmental Consultant
13 Asbestos contaminated soil for reuse onsite
Stockpiled asbestos containing soils will be assessed for beneficial re-use with the Site (NEPC 2013) Any soils
identified to contain asbestos with concentrations of bonded ACM less than the NEPC (2013) Health Screening Level
(HSL)-D applicable for the future commercial industrial land use could be reused onsite providing the following
Placement in a designated location preferably beneath a road alignment or other suitably capped area (min
300 mm lsquocleanrsquo (ie ENMVENM soils) to eliminate any potential airborne exposure pathway
Occupational hygienist and asbestos removalists on-site supervising relocation and placement
Maintenance of an Site Asbestos Register to record the extent nature of the ACM materials retained or
identified on-site
Any other requirements by Sydney Metro such as adherence to the CEMP etc and or land conditions
A Long-term Environmental Management Plan to manage the presence of asbestos impacted materials remaining
on-site would be required if the proposed soils to be re-used are exceeding the HSL-D limits for non-friable or
friable asbestos
If stockpiled soils are identified to contain any detectable concentrations of Friable asbestos material is
recommended to be disposed off-site given its friable nature
GC-HSE-PLA-437 Uncontrolled when saved or printed
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14 Waste disposal
Where the ACM is assessed as non-suitable for onsite reuse the licensed asbestos removalist will classify and dispose
of the ACM at a licensed asbestos waste disposal site in accordance with NSW EPA guidelines (including Waste
Classification Guidelines (EPA 2014)) and relevant industry codes of practice
Disposal of ACM will be to an approved asbestos waste facility listed on the NSW EPA website The transportation of
asbestos waste by trucks must comply with the following requirements
Transporter must have the appropriate EPA license to transport asbestos waste
Asbestos contaminated soils are wetted down
Any part of any vehicle in which a person transports asbestos waste is covered and leak proof during
transportation
Georgiou will notify the Client prior to removal of ACM from site and will provide details of the proposed method
and location of disposal Georgiou will maintain records of all asbestos ACM disposed off site the location of the
facility at which it was disposed and any receiptcertificate issued by the facilitydisposal authority
15 Materials Tracking
A Material tracking Register will be used to ensure information is collected for the movement of all asbestos
contaminated soils The material is carefully inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
and testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location of asbestos contaminated soil
stored onsite at the stockpile area The stockpile number on the map will correspond with the information in the
register
16 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential risks associated with asbestos management locations of asbestos as detailed in previous contamination
assessment reports and this unexpected finds procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works and include the unexpected asbestos finds procedure Prior to commencement of each shift the Supervisor
will inform all site personnel of any works involving contaminated materials on site
17 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure
Unclassified
Unclassified
Environmental Incident and Non-
compliance Reporting Procedure SM-17-00000096
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Manager Environment
System Owner Executive Director Safety Sustainability amp Environment
Status FINAL
Version 51
Date of issue 18 February 2019
Review date 11 February 2020
copy Sydney Metro 2019
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table of contents 1 Purpose and scope 4
2 Introduction 4
3 Definitions 4
4 Accountabilities 5
5 Environmental Events 5
51 Worked Example ndash Classifying Environmental Events 7
511 Soil and Water Issue 7
512 Soil and Water Non-compliance 7
513 Soil and Water Incident 7
52 Notifiable Events 8
53 Event Types 8
6 Environmental Incident Classification and Management 10
61 Incident Classification 11
611 Class 3 Incidents 11
612 Class 2 Incidents 11
613 Class 1 Incidents 12
62 Incident Notification 12
621 Principalrsquos Representative (PR) 12
622 Environmental Lead (EL) 13
63 Incident Notification Reports 14
64 Incident Investigations 14
65 Environmental Incidents with Health and Safety Impacts 14
66 Reporting Pollution Incidents to Relevant Authorities 15
661 Maritime Related Incident Notification and Reporting 16
67 Environmental Compliance Register 16
7 Environmental Non-compliance 17
71 Non-compliance Rate 17
8 Corrective and Preventative Actions 18
81 Action Status 18
9 Related Documents and References 19
10 Superseded Documents 19
11 Document History 19
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Figures Figure 1 Environmental Event Classification Process 6 Figure 2 Environment Incident notification process for Class 1 and 2 Incidents 13
Tables Table 1 Examples of Notifiable Events 8 Table 2 Environmental Event Types and their descriptions 9 Table 3 Examples of Environmental Incidents 10 Table 4 Classification System for Environmental Incidents 11 Table 5 Contact details for Relevant Authorities 15
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Environmental Incident and Non-compliance Reporting Procedure
1 Purpose and scope
This procedure documents the process to be used when classifying and reporting Environmental Events
This procedure applies to Sydney Metro and any contractor Sydney Metro engages to carry out works Principal Contractors must ensure their processes for managing Environmental Events is consistent with this document The requirement for consistency is documented in the Construction Environmental Management Framework (Section 33(f)) and shall be allocated as a contractual requirement to each delivery partner
2 Introduction
Sydney Metro is committed to minimising risks to the environment the rapid identification and rectification of breaches to Environmental Requirements and efficient and effective responses to Environmental Incidents that grows our ability to minimise harm and prevent future re-occurrences
This procedure defines an approach to classifying Environmental Issues Incidents and Non-compliances and establishes the immediate interim and long term actions that are taken in response to Environmental Events
3 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition with the following exceptions
Term Definition
Environment
means components of the earth including
a) land air and water and
b) any layer of the atmosphere and
c) any organic or inorganic matter and any living organism and
d) human-made or modified structures and areas and includes interacting natural ecosystems that include components referred to in (a)-(c)
Environmental Event
An occurrence that identifies actual or potential environmental impacts or non-compliances Events cans include conversations inspections incidents or failures of process
Environmental Harm Includes any direct or indirect alteration of the environment that has the effect of degrading the environment and without limiting the generality of the above includes any act or omission that results in pollution
Environmental Incident
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Environmental Issue An occurrence or set of circumstances where Environmental Harm or Non-compliance could occur if not rectified
Environmental Non-compliance
A breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans
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Environmental Incident and Non-compliance Reporting Procedure
Term Definition
Material Harm to the Environment
harm to the environment is material if
a) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
b) it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding $10000 (or such other amount as is prescribed by the regulations) and
c) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent mitigate or make good harm to the environment
It does not matter that harm to the environment is caused only in the premises where the pollution incident occurs
Terms and jargon specific to this procedure are defined within the Sydney Metro Glossary
4 Accountabilities
The Executive Director Safety Sustainability amp Environment is accountable for this Procedure Accountability includes authorising the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
The Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document if specified in the relevant contracts
5 Environmental Events
Environmental surveillance data is relied upon to inform Sydney Metro of performance trends to provide assurance that legislative requirements are being met and indicate where surveillance activities should be directed In order to rely upon environmental data for this purpose there needs to be a high degree of consistency in the manner by which it is collected and interpreted Due to the need for consistency any incidentNon-compliance procedure produced by a delivery partner to Sydney Metro is required to be consistent with the requirements of this document
The concept of Environmental Events forms a common starting point for understanding what types of occurrences should be managed and reported as Incidents and what should be reported as Non-compliances or Issues When an Environmental Event occurs a series of questions can be asked to consistently determine what type of event it is Commonly Environmental Events lead to three different processes
1 Reporting of an Environmental Incident
2 Reporting of an Environmental Non-compliance or
3 Reporting of an Environmental Issue
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Environmental Incident and Non-compliance Reporting Procedure
Incidents and Non-compliances are recorded using the Environmental Incident and Non-compliance Report Form (SM ES-FT-403) and Environmental Issues are recorded through environmental inspection reports using the Environmental Inspection Information amp Summary Form (SM ES-FT-406) These paper based records are subsequently entered into the Sydney Metro Compliance Register (Section 67) which is used to disseminate the data and facilities reporting internally and externally Note where a Principal Contractor has submitted alternative processes and these have been approved by Sydney Metro they may also be used
The figure below shows the process by which Environmental Events are classified (Figure 1)
Figure 1 Environmental Event Classification Process
Where Environmental Harm has been caused the event will always be classified as an Environmental Incident regardless of whether one or more Environmental Requirements have been breached Only when an event occurs without harm being caused to the environment will it be classified as a Non-compliance or Issue It should be noted that the Incident management process still captures any breaches of Environmental Requirements and these incidents contribute towards the calculation of the NC Rate (Section 71)
This flowchart above is intended to be a guide and there may be situations where it is unclear exactly how an Environmental Event should be classified In these situations a judgement call should be made in consultation with your Manager
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Environmental Incident and Non-compliance Reporting Procedure
51 Worked Example ndash Classifying Environmental Events
This Section provides a fictitious example of Environmental Events which fall into each of the three different categories The situations outlined below are provided to explain how event classifications are made The background for these worked examples is as follows
Sydney Metro is carrying out works in a newly established site and substantial earthworks are occurring to construct piers for an elevated viaduct A nearby creek contains a variety of important fish species and the local community are known to use this creek for recreational fishing The Environmental Impact Statement identified the creek as being at risk of increased sedimentation from dirty water run-off and the Conditions of Approval include a requirement to have a Progressive Erosion and Sediment Control Plan in place This plan has been produced and indicates that sediment fences must be in place at specific locations to capture dirty water run-off Regular daily inspections of the sediment controls are carried out by the contractorrsquos Environment Manager and an Independent Environmental Representative has commenced a monthly inspection on this site at 7 am on Thursday morning
511 Soil and Water Issue
The Environmental Representative notices a sediment fence has been knocked over in one of the areas indicated as requiring fencing on the ERSED plan It appears to have occurred recently and there is no record of rainfall in the last few days During the course of the inspection all other ERSED controls appeared to be in good condition and erected in accordance with the requirements of the Blue Book In this example no harm has yet been caused and no environmental requirement has been breached so the event is classified as an Environmental Issue which is raised on the inspection report with an action to reinstall the fence
512 Soil and Water Non-compliance
Alternatively the Environmental Representative might have noticed many sediment fences had been knocked down and in some areas an absence of sediment fences where the plan indicates they are required Despite there being no rain in recent days the Environmental Representative concludes that the requirements of the plan are not being followed and have been breached The event is raised as non-compliance and actions are set in place to re-enforce the requirements of the ERSED plan for that sites workforce as well as the immediate reinstatement of controls
513 Soil and Water Incident
Finally in a third scenario the Environmental Representative notices many sediment fences are down and some are absent where required by the plan However significant rainfall has occurred in recent days and the Environmental Representative determines that it is likely dirty water has escaped through the area into the nearby creek potentially causing harm to the fish population This event is classified as an Incident by the inspector and immediate notification is undertaken Similar controls are implemented as described above
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Environmental Incident and Non-compliance Reporting Procedure
52 Notifiable Events
There are a number of Acts and regulations that include a specific requirement to notify a Regulatory Authority When an Environmental Event triggers one of these notification requirements we then also refer to that event as a Notifiable Event (Table 1)
The Principal Contractorrsquos Environment Manager must determine whether an event is notifiable and may rely upon advice from Sydney Metro if it is provided
Table 1 Examples of Notifiable Events
Event type Legislation Trigger for Notification
Pollution Incident
1
POEO Act 1997 Part 57 Where Material Harm has occurred contact the EPA Pollution Line as soon as practicable POEO (General)
Regulation 2009 Section 101
Land contamination
Contaminated Land Management Act 1997
Section 60(1)
As soon as practicable after becoming aware of contamination that exceeds the relevant investigation levels in the National Environment Protection Measure where a person has or will be exposed to the contamination
Discovery of an Aboriginal relic
National Parks amp Wildlife Act 1974
Section 89A
Director General of EPA in writing within a reasonable time after becoming aware Note this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in the relevant Infrastructure Approval
Discover Aboriginal Remains
Commonwealth Aboriginal amp Torres Strait Islanders Heritage Protection Act 1984
Section 20 Commonwealth Minister of the Environment in writing as soon as practicable after becoming aware
Discovery of a relic
Heritage Act 1977 Section 146
Heritage Council in writing within a reasonable time after becoming aware
Note -this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in Infrastructure Approvals
53 Event Types
Each Environmental Event is assigned a secondary classification of an Event Type for the purpose of data analysis and general environmental management They are grouped by areas of environmental management so that targeted auditing training or awareness initiatives can be initiated in response to emergent trends Each Event Type is explained in Table 2
1 Further information on reporting pollution incidents to EPA is provided in Section 66 Environmental
IncidentNon-compliance Report
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Environmental Incident and Non-compliance Reporting Procedure
Table 2 Environmental Event Types and their descriptions
Event Type
Applies To
Description Issue Incident
Non-compliance
Soil and Water bull bull bull
Covers the physical location chemical composition and ecology of soils and waterways Any event which changes these compositions is a Soil and Water event Within this event type all instances of contamination erosion and sedimentation of waterways is covered
Flora and Fauna bull bull bull Covers vegetation and vegetation communities as well as animals and animal habitat Any event where vegetation is felled or damaged animals are killed or injured or habitat is harmed or destroyed is covered
Waste and Spoil bull bull bull
Covers the management of Excavated Natural Material (ENM) and Virgin Excavated Natural Material (VENM) including on-site management and disposal and also the classification and management of Waste materials
Note that the transportation of spoil is covered under Traffic Transport and Access
Heritage bull bull bull Covers the management of known heritage artefacts or sites and the treatment of unexpected finds archaeological investigations and other impacts
Air Quality bull bull bull Covers the management of emissions of particulate matter odours and gasses used as air quality parameters from worksites
Noise and Vibration bull bull bull
Covers the management of airborne and ground borne noise and vibration and includes hold points on the commencement of any work where Out of Hours Works permits or Construction Noise Impact Statements are required
Community Stakeholder and Business
bull bull bull Covers the management of Community and Stakeholder requirements and includes complaint response procedure community management protocols and the maintenance of information on websites
Traffic Transport and Access bull bull bull
Covers the management of traffic inside and outside of sites including access points and parking requirements This event type also covers any requirements in relation to vehicles and vehicle maintenance or the transportation of waste and spoil
Spills and Leaks bull bull bull
Covers all instances where environmentally sensitive substances are held within a container which has the potential to leak or spill and covers pipes hoses fuel tanks storage tanks and plastic containers
Note Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Management Systems bull bull bull
Covers procedural or administrate processes that are common across all areas It specifically does not cover procedural or administrate processes which are unique to any of the other event types For example not completing a vegetation removal form prior to vegetation clearing is still a Flora and Fauna event
Note A good example of a Management Systems NC would be not reporting an Environmental Incident within required timeframes
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Environmental Incident and Non-compliance Reporting Procedure
6 Environmental Incident Classification and Management
Sydney Metro has defined an Environmental Incident as
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Adverse environmental impact includes contamination harm to flora and fauna (either individual species or communities) damage to heritage items or adverse community impacts
Planning Approvals and Environment Protection Licences permit some environmental impacts and these are not intended to be captured as Environmental Incidents
Table 3 Examples of Environmental Incidents
Type Example Incident
Air Quality Odour that travels beyond the site boundary
Air Quality Dust exceeding reasonable levels without active management measures in place
Air Quality Operation or maintenance of plant in a manner that causes or has likely caused excessive air pollution
Soil and Water Discharge of water on or off site in a manner that causes or has likely caused water pollution without required approvals
Noise and Vibration Noise that travels beyond the site boundary as a result of poorly maintained plant or operation of plant in an inefficient manner
Noise and Vibration Failure to comply with the approved hours of work
Soil and Water
Where the chemical composition of soil or water has been detrimentally modified by a contaminant leading to potential or actual environmental harm For example rainfall causes a flow of water across a site that erodes soil and enters a waterway increasing the total suspended solids of that water body
Spills and Leaks
Where a substance has leaked from or spilt from a container that is designed to prevent that substance from escaping into the environment (including bunds fuels tanks chemical bottles and other containers)
Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Soil and Water Dispose of waste in a manner that harms or is likely to harm the environment
Flora and Fauna Harm or ldquopickrdquo a threatened species endangered population or endangered ecological community without required approvals
Flora and Fauna Damage to vegetation fauna or habitat including watercourses without required approvals
Heritage Damage disturbance destruction or works to heritage itemsrelics without required approvals
Heritage Damage disturbance or destruction of Aboriginal objects or places without required approvals
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
61 Incident Classification
Environmental Incidents are classified into one of three Classes that are based upon the consequence descriptors for environmental risks in the Sydney Metro Risk Matrix (refer to Sydney Metro Risk Management Standard) Each of these classifications trigger a variety of management actions andor legislative requirements depending on the severity of the consequence described where Class 3 represents minor consequences and Class 1 represents major consequences
This matrix is further sub-divided into consequence ratings ranging from C6 (low impact) to C1 (high impact) An incident transitions between a Class 3 to a Class 2 incident once material harm has been caused and transitions into a Class 1 incident once it is determined that the Environmental Harm caused in large-scale and cannot be remediated (Table 4)
Table 4 Classification System for Environmental Incidents
Class 3 Class 2 Class 1
C6 C5 C4 C3 C2 C1
No appreciable changes to
environment andor highly
localised event
Change from normal conditions
within environmental
regulatory limits and environmental effects are within site boundaries
Short-term andor well-contained environmental effects Minor
remedial actions probably required
Impacts external ecosystem and considerable
remediation is required
Long-term environmental impairment in
neighbouring or valued
ecosystems
Extensive remediation
required
Irreversible large-scale
environmental impact with loss of
valued ecosystems
611 Class 3 Incidents
These Incidents are events which cause Environmental Harm but do not cause Material Harm to the environment Normally Class 3 Incidents are not Notifiable Events and therefore a simple notification protocol is adopted whereby Sydney Metro must be notified within 48 hours verbally and in writing
In some cases it will be unclear whether Material Harm has been caused in the early stages of Incident Management If this is the case then the process for Class 2 Incidents is followed (see Section Class 2 Incidents) until it is clear that Material Harm has not been caused
A formal Incident Investigation report is not required for Class 3 Incidents however it is expected that the person responsible for completing the Incident Notification Report makes appropriate enquiries to determine the likely causal factors involved and assigns effective corrective actions
612 Class 2 Incidents
These Incidents are events which cause Material Harm to the environment and they always trigger notification of Regulatory Authorities These Incidents represent events that are far more serious than Class 3 Incidents and therefore strict communication protocols are required to ensure that effective and informed decisions are made (Figure 2)
The Environmental Lead contract Environment Manager and the Independent Environmental Representative must be notified verbally as soon as possible after the observer becomes aware of a Class 2 Incident
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Environmental Incident and Non-compliance Reporting Procedure
Class 2 Incidents must be investigated and the investigation must produce an investigation report containing corrective or preventative actions This investigation report must be provided to Sydney Metro within 7 days of the event unless another timeframe is agreed with the EL
Despite any arrangements for the submission of investigation reports an Incident Notification Report must be provided with all available information and submitted to Sydney Metro within 48 hours It is not expected that initial Incident Notification Reports for Incidents under investigation initially include actions as these will be informed by the findings of the investigation The report should be updated with actions resulting from the investigation when available
613 Class 1 Incidents
Class 1 Environmental Incidents are managed in the same manner as Class 2 Incidents expect where a determination is made by the Chief Executive (or delegate) that a Crisis Management Team should be activated In this situation the Sydney Metro Crisis Management Implementation Plan is followed
62 Incident Notification
When and Environmental Event occurs which causes Environmental Harm in all cases both verbal and written communication of the incident must be carried out immediately and within 48 hours respectively For Class 1 and 2 Incidents the notification process shown in Figure 2 must be followed Written communication of Environmental Incidents is via an Incident Notification Report (Section 63)
This process includes specific roles and responsibilities within Sydney Metro and our delivery Partners who are required to take notification actions in response to Incidents
This notification process has been developed to ensure that crucial information about Incidents is captured early and communicated to specific individuals who can ensure the Environmental Impacts are minimised and efficient and effective responses to the event are implemented
In particular the Principals Representative and the Environmental Lead for Sydney Metro play a crucial role in the communication of Incidents within Sydney Metro and these roles are explained in more detail below
621 Principalrsquos Representative (PR)
Each works package establishes a contractual interface for communication between the contracted party and Sydney Metro Generally this interface is between the Principal Contractors Project Director and an appointed representative of Sydney Metro called the Principals Representative
All formal written communications must pass between these two individuals electronically using TeamBinder The Principals Representative holds certain responsibilities in the Incident management Process outlined in Figure 2
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Environmental Incident and Non-compliance Reporting Procedure
622 Environmental Lead (EL)
Where this procedure is applied to a works package an Environmental Lead (EL) will be selected for the relevant works package The Environmental Lead must possess environmental experience and competency in managing Incidents and be a representative of Sydney Metro for those works This representative holds specific responsibilities outlined in Figure 2
Figure 2 Environment Incident notification process for Class 1 and 2 Incidents
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(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
63 Incident Notification Reports
For all Incidents an Incident Notification Report must be completed and submitted to Sydney Metro within 48 hours These reports satisfy the requirement for written communication to Sydney Metro and are completed using the Environmental Incident and Non-compliance Notification Report (SM ES-FT-403) or a similar and consistent form approved by Sydney Metro
64 Incident Investigations
Environmental Incident Investigations must be carried out for all Class 1 and Class 2 Incidents Investigations may also be requested for any other Environmental Event at the discretion of Sydney Metro This discretion is likely to be exercised where incidents of a similar nature are occurring repetitively
When conducting an Environmental Incident investigation they must
Be led by a lead investigator who is suitably independent investigator capable of arriving at objective findings and is experienced in conducting environmental incident investigations
Consider the need for legal privilege during the investigation process in consultation with legal counsel
Be informed by all available information that is relevant to the investigation
Analyse the timeline of events which led up to and followed the occurrence of Environmental Harm including the immediate incident response
Be conducted in a manner that is consistent with recognised investigation techniques such as ICAMS
Gather and record evidence
Seek the input of key stakeholders and
Identify Preventative and Corrective actions and document these in the Incident Notification Report
65 Environmental Incidents with Health and Safety Impacts
It is possible that where an Event occurs that causes Environmental Harm harm is also caused to the health safety or wellbeing of people In these situations there will also be a Health and Safety Incident process undertaken which is separate to the process outlined in this document
While the definition of the Environment covers people under the POEO Act the management of impacts upon them are carried out using the Health and Safety Incident Management protocols This is because Health Safety and Wellbeing requirements are governed by a range of legislation other than the POEO Act and this procedure is not comprehensive in that regard Sydney Metro has well established processes to manage impacts on people without the need for the Environmental Incident Process to intervene
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Furthermore where Environmental Events cause harm to both the lsquoenvironmentrsquo and people it is possible that the root causes for the respective impacts are different It is also possible that differences in the severity of the impacts trigger inconsistent notification requirements and investigation levels It is prudent to identify appropriate and effective corrective actions that reduce the risk of impacts to both people and the environment therefore separate Incident Management Processes are undertaken in these situations
For more detail on the management of Health and Safety Incidents please refer to the Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
66 Reporting Pollution Incidents to Relevant Authorities
If an Incident or Non-compliance is a Notifiable Event then a report must be provided to the relevant Regulatory Authority within the timeframe(s) specified by the relevant legislation Pollution Incidents which are causing or threatening Material Harm to the environment must be reported to each of the following authorities immediately after project personnel become aware of the Incident as required by Section 148 of the POEO Act 1997 The contact numbers for these authorities are listed in Table 5
Table 5 Contact details for Relevant Authorities
Type Example incident
EPA Environment Line 131 555
Local Authority Local Council (specific to area)
Ministry of Health Public Health Unit (refer to httpwwwhealthnswgovauPagesdefaultaspx to confirm local area contact details)
SafeWork NSW 131 050 or contactsafeworknswgovau
Fire and Rescue NSW 000
Relevant information required to be given to EPA when making a notification is specified in Section 150 of the POEO Act 1997 as follows
Time date nature duration and location of the incident
Location of the place where pollution is occurring or is likely to occur
Nature the estimated quantity or volume and the concentration of any pollutants involved
Circumstances in which the Incident occurred (including the cause of the Incident if known)
Action taken or proposed to be taken to deal with the Incident and any resulting pollution or threatened pollution and
Other information prescribed by the regulations
All relevant information known at the time of making the notification must be reported If the information required by (c) (d) or (e) above is not known at the time of initial notification but becomes known afterwards it must be reported to each authority immediately after it
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
becomes known Verbal notification must be followed by notification in writing within seven days of the date on which the Incident occurred
Pollution Incidents are not required to be reported if the Incident has already come to the attention of the EPA or the Incident involves only the emission of an odour
Failure to report a pollution Incident as required by the POEO Act 1997 is an offence
Where any work or activity is regulated by an Environment Protection License (EPL) notification of a pollution Incident to the EPA should be made by the licensee Thus where the contractor holds the EPL for the project notification to EPA shall be made by the contractor
For any work or activity that is not regulated by an EPL notification of pollution Incidents to EPA shall be made by Sydney Metro unless the contractor is instructed otherwise by Sydney Metro This includes pollution Incidents that occur as a result of pre-construction activities which may be undertaken prior to an EPL being required for a project Pre- construction activities are determined by the Planning Approval and may include for example geotechnical investigations or surveys
Where the Environmental Representative determines there to have been a significant off-site impact on people or the biophysical environment the program Director Sustainability Environment and Planning will notify the Secretary of the Department of Environment and Planning within 48 hours in accordance with Project Infrastructure Approval Conditions This notification will be followed by a full written report within seven days of the date on which the incident occurred
661 Maritime Related Incident Notification and Reporting
Marine Incidents involving vessels and personnel on board vessels must be reported to the Australian Maritime Safety Authority in accordance with the guidance published on their website at
Australian Maritime Safety Authority Incident Reporting and
Reporting obligations of owners and masters of domestic commercial vessels
67 Environmental Compliance Register
The Environmental Compliance Register is used to manage the information associated with reporting of Environmental Events This register is maintained by the Manager Environment and may be used by a variety of individuals to input data For access to the register or information on its use contact the Manager Environment
This register analyses the data it contains and produces environmental compliance statistics that are used to meet a range of reporting and environmental management requirements
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
7 Environmental Non-compliance
An Environmental Non-compliance is a breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans It is important to note that regardless of whether an event is classified as a Non-compliance or an Incident the process behind managing the event remains the same with the following exceptions
Non-compliances are not notifiable to Regulatory Authorities under the POEO Act
Non-compliances are reported to have occurred on the day the breach was raised as opposed to the date when the requirement was breached (this is to preserve historical reporting and analysis ndash see Section 71)
Non-compliances are not divided into severity classes (Section 52)
Non-compliances do not have the potential to trigger crisis or emergency management processes and
There is an informal notification process in the immediate timeframe following a Non-compliance being raised
When an Environmental Event occurs that causes Environmental Harm and also breaches one or more Environmental Requirements then an Incident Notification Report will be created which records what requirements were breached
If a Non-compliance is identified then it must be raised using the Environmental Incident and Non-compliance Report Form within 48 hours by the party responsible for the breach
71 Non-compliance Rate
A key environmental performance statistic used by Sydney Metro is the Non-compliance Rate This statistic provides a standardised way of comparing the performance of different projects or contractors The NC Rate is calculated using the following formula
= (119873119862119904 + 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119903119886119894119904119890119889 119894119899 119898119900119899119905ℎ) + (119874119901119890119899 119873119862119904 + 119874119901119890119899 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119891119903119900119898 119901119903119890119907119894119900119906119904 119898119900119899119905ℎ119904)
119879119900119905119886119897 119873119906119898119887119890119903 119900119891 119874119899119892119900119894119899119892 119877119890119902119906119894119903119890119898119890119899119905119904) 119883 100
Each month a count of the number of NCs raised and Incident raised where Environmental Requirements have also been breached is counted Added to this number is the number of these events which were raised in previous months that still held an Open status in the current reporting period Non-compliance and incident Events are considered Open if any of the associated Actions are Open The total is divided by the number of Environmental Requirements which are actively being complied with (Ongoing Requirements) and a multiplying factor of 100 is applied
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
8 Corrective and Preventative Actions
Whenever an Environmental Event is raised actions will be assigned to the event irrespective of whether it is an Issue Incident or Non-compliance These actions will generally be Corrective Actions which are implemented to eliminate the cause of the Incident Non-compliance or Issue and can be thought of as reactive measures in response to the Environmental Event
Preventative Actions may also be assigned to prevent the occurrence of an Incident Non-compliance or Issue and can be considered pro-active measures which may be recommended following a detailed investigation of the event
Actions must
Limit impacts as far as is reasonably practicable
eliminate risk where practicable
where is it not practicable to eliminate the risk follow the hierarchy of controls
address root causes and contributing factors and
be prioritised based on risk
The Executive Director Safety Sustainability amp Environment must ensure there are systems in place to
monitor corrective action status
escalate issues to the executive where progress on a corrective action is inadequate and
retain all corrective action responses for recording purposes
81 Action Status
Actions are allocated to a person who will take accountability for ensuring it is carried out within a timely manner and completed by the due date
Actions are either closed immediately if the Action has already been carried out and verified by Sydney Metro or are created with an open status The Action will remain in an open state until such a time as Sydney Metro verifies that the responsible person has completed the Action in a satisfactory manner Until all actions associated with an Incident Non-compliance or Issue are closed the original Environmental Event is considered to be open as well This is relevant when calculating the NC Rate as open Non-compliances and Incidents contribute toward the calculation of this statistic
Verification is determined by the Environmental Lead by sighting evidence of the Actions implementation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
9 Related Documents and References
10 Superseded Documents
11 Document History
Related Documents and References
Environmental amp Sustainability Management Manual
Risk Management Standard
Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
Crisis Management Implementation Plan
Environmental Incident and Non-compliance Notification Report
Environmental Inspection Information amp Summary
Sydney Metro Glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
10 31 March 2015 New document
20 7 July 2016 IMS Review
30 7 April 2017 IMS Review
40 23 November 2018 IMS Review
50 11 February 2019 IMS Review
51 18 February 2019 Minor correction to formula
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 79 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 10 ndash Sydney Metro Environmental Inspection template
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2016 CEMP Appendix 10 - Sydney Metro Inspection template Page 1 of 1
Environmental Inspection Report Template
Contract
Contractor Date
Inspection Number Time
Location
Weather
Attendees
Site Activities
Item No
Key Issues Action Party
Priority
(L M H)
Inspection by
Name Title Signature
Date
Copy to
- All attendees
-
-
-
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Appendix 11 ndash Georgiou Environmental Policy
COMPANY POLICY
Rob Monaci Chief Executive Officer Georgiou Group September 2020
ENVIRONMENTAL
Georgiou is committed to minimising where reasonably practicable its impact on the natural environment and social surroundings for the benefit of current and future generations while enhancing Georgioursquos environmental performance
In order to achieve this commitment Georgiou will
set environmental objectives and targets applicable to the aspects and potential impacts of projects and facilities
establish positive relationships with community and stakeholders
comply with all applicable environmental laws regulations statutory obligations and client environmental requirements
identify significant environmental aspects and develop effective and appropriate mitigation measures to minimise environmental impacts
provide measures to protect heritage biodiversity land and waterways
manage potential community impacts related to air quality noise and vibration
practice responsible resource use and waste management including the promotion of efficient use reuse and recycling of resources
implement and maintain Georgioursquos management system and practices to meet its business needs ASNZS ISO 14001 client and other obligations and
hold employees and subcontractors accountable for proactively meeting their environmental responsibilities
Achieving these commitments is fundamental to demonstrate a positive impact on the environment and communities associated with Georgioursquos activities and developments All employees and persons who work with Georgiou have a personal responsibility for implementing this Policy
SAFE
TY |
PRO
FIT
| RE
LATI
ON
SHIP
S |
PEO
PLE
| IN
NO
VAT
ION
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Appendix 1A ndash Sydney Metro Waste Classification Procedure 42
Appendix 2- Soil and Water Management Sub Plan 43
Appendix 3- Hydrocarbon and Chemical Management Sub Plan 46
Appendix 4 - Flora amp Fauna Management Sub Plan 50
Appendix 5 - Cultural Heritage Management Sub Plan 53
Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure 55
Appendix 5B ndash Sydney Metro Exhumation Management Procedure 56
Appendix 6 - Air Quality amp Dust Management Sub Plan 57
Appendix 7- Noise Vibration and Light spill Management Sub Plan 59
Appendix 7A ndash Sydney Metro Out of Hours Application form 61
Appendix 8 ndash Contaminated Land Management Sub Plan 62
Appendix 8A ndash Unexpected Contamination finds procedure 67
Appendix 8B ndash Unexpected Asbestos finds procedure 71
Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure 78
Appendix 10 ndash Sydney Metro Environmental Inspection template 79
Appendix 11 ndash Georgiou Environmental Policy 80
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GLOSSARY ABBREVIATIONS
Term Expanded text
AFMP Ancillary Facilities Management Plan
BC Act Biodiversity Conservation Act 2016
CoA Condition of approval
Compliance audit Verification of how implementation is proceeding with respect to an CEMP (which incorporates the relevant approval conditions)
CPESC Certified practising erosion and sediment control professional
CRM Community Relations Manager
CPESC Certified practising erosion and sediment control professional
CSSI Critical State Significant Infrastructure
DEC Department of Environment and Conservation (NSW) (former)
DIPNR Department of Infrastructure Planning and Natural Resources (former)
DoEE Commonwealth Department of the Environment and Energy
DoI - Water NSW Department of Industry - Water
DPIE NSW Department of Planning Industry and Environment
Ecologically sustainable development (ESD)
Using conserving and enhancing the communityrsquos resources so that the ecological processes on which life depends are maintained and the total quality of life now and in the future can be increased (Council of Australian Governments 1992)
EIS Environmental Impact Statement
EMS Environmental Management System
Environmental aspect
Defined by ASNZS ISO 140012015 as an element of an organisationrsquos activities products or services that can interact with the environment
Environmental impact
Defined by ASNZS ISO 140012015 as any change to the environment whether adverse or beneficial wholly or partially resulting from an organisationrsquos environmental aspects
Environmental incident
An unexpected event that has or has the potential to cause harm to the environment and requires some action to minimise the impact or restore the environment
Environmental objective
Defined by ASNZS ISO 140012015 as an overall environmental goal consistent with the environmental policy that an organisation sets itself to achieve
Environmental policy
Statement by an organisation of its intention and principles for environmental performance
Environmental target
Defined by ASNZS ISO 140012015 as a detailed performance requirement applicable to the organisation or parts thereof that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives
EPA NSW Environment Protection Authority
EPampA Act NSW Environmental Planning and Assessment Act 1979
EPBC Act Commonwealth Environment Protection and Biodiversity Conservation Act 1999
EPL NSW Environment Protection Licence under the Protection of the Environment Operations Act 1997
ERG Environmental Review Group
ESCP Erosion and Sediment Control Plan
EWMS Environmental Work Method Statement
Federal-CoA Condition of the Federal Department of the Environment and Energy Approval Decision
Hold point Is a verification point that prevents work from commencing prior to approval
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LGA Local Government Area
MNES Matters of National Environmental Significance
Non-compliance Failure to comply with the requirements of the Project approval or any applicable licence permit or legal requirements
NSW-CoA Condition of the NSW DPampE Infrastructure Approval
OEH NSW Office of Environment and Heritage
OOHW Out of hours work
PIRMP Pollution Incident Response Management Plan
POEO Act Protection of the Environment Operations Act 1997 (NSW)
RAP Registered Aboriginal Party
RBL Rating background level
REF Review of Environmental Factors
ROL Road occupancy licence
SAP Sensitive Area Plan
SEPP State Environmental Planning Policy
UXO Unexploded Ordnance
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CEMP Bays Road Relocation Works
1 INTRODUCTION AND PURPOSE
The purpose of this Construction Environmental Management Plan (CEMP) is to describe how environmental aspects
are to be managed so that the site and those engaged onsite will
Comply with Georgiou Policy Client legal and other obligations
Minimise the impacts on the environment
Achieve the Company client and site objectives and targets
implement mitigation measures identified and assessed through Review of Environmental Factors (REF) under
Part 5 of the EPampA Act
Comply with the requirements of the Construction Environmental Management Framework (CEMF) February
2020 version 41 Managing Contractor Contract (MCC) Works Brief licencing and other relevant documents
This Management Plan is written in accordance with Georgioursquos health safety and environment management
system that is 3rd party certified to ASNZS ISO 14001 It has been written in accordance with the Transport for
New South Wales (TfNSW) Sydney Metro Construction Environmental Management Framework (CEMF) and the
project specific Sydney Metro General Specification ndash Plans and Reporting
Amendments and Authorisation
This Management Plan will be approved by the Project Manager their Line Manager and a Representative from the
HSE Department This Management Plan and other related documents will be reviewed annually or as a result of
Changes to Company procedures or processes
Changes to key personnel or resources
Changes in legal and other obligations
Findings from an audit or inspection
Findings from a significant incident or near miss
Significant changes to site conditions andor work methods
Instructions from Sydney Metro
Reviews will be undertaken in consultation with key stakeholders to ensure all locationsfunctions are considered
A record of the date and comments relating to any revisions of this document will be included in the revision table
The only Georgiou authorisation required to amend this document after initial approval is the Project Managerrsquos
Communication of this Plan
The Project Manager is accountable for ensuring
Location and access to the management plans is communicated at induction Management Plans have been communicated to subcontractor personnel prior to commencement of works
onsite Any changes made to the management plan are communicated to affected persons on the site
Supporting Management Plans
The following management plans have been developed to support this management plan
Emergency Response and Preparedness Plan
Georgiou Crisis Management Plan (controlled by Georgioursquos Perth Head Office and available on Company Intranet)
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2 SCOPE OF WORKS
Sydney Metro is proposing to configure the internal port road network at Rozelle to facilitate the orderly urban
renewal of the Bays West area while maintaining access to the White Bay Cruise Terminal and other port operations
at Glebe Island and White Bay This includes long-term urban renewal initiatives for the Bays West area and works
for various future developments within the locality including critical works for the proposed Sydney Metro West
The proposal also provides the opportunity to improve road safety by reducing conflicting traffic movements in the
internal port road network
Georgioursquos scope of works is described as lsquoPhase 1rsquo works in the REF and it comprises of the following key
features
A reconfigured intersection at Port Access Road Solomons Way Sommerville Road including an interim
connection with the existing Port Access Road until it is relocated (as part of Phase 2)
Establishment of one-way traffic circulation along Solomons Way and Sommerville Road around the Glebe Island
Silos
Relocation of the Cement Australia Truck Parking Licenced Area to the north prior to the construction of the
reconfigured intersection due to the direct conflict with the reconfigured intersection
3 LOCATION
The proposal is located in an established industrial and port context at Rozelle within the Inner West Council local
government area
The lsquoproposal sitersquo refers to the area that would be directly impacted by the proposal as shown in Figure 1-1 The
proposal site is largely disused with the exception of the Port Access Road and port related lease areas including a
Cement Australia Truck Parking Licenced Area to service Cement Australiarsquos operations at the Glebe Island Silos
The proposal site is under the ownership of the Port Authority of NSW
To the north of the proposal site is the existing Port Access Road that supports access to the White Bay Cruise
Terminal and other port operations at White Bay To the east of the site is the existing Cement Australia and Sugar
Australia Glebe Island Silos and the Gypsum Resources Australia facility The south-eastern border of the site is
vegetated land adjoining Victoria Road Western Distributor The proposed location for the relocated Cement
Australia Truck Parking Licenced Area is currently a hardstand laydown area used by Port Authority of NSW
Beyond the proposal site the wider locality features a mix of land uses including retail commercial and urban
services along Robert Street to the north port and maritime uses to the east (Glebe Island and White Bay) and to
the south and City West Link Road and residential dwellings to the west in Rozelle
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CEMP Bays Road Relocation Works
Figure 3-1 Site location
4 ENVIRONMENTAL MANAGEMENT SYSTEM OVERVIEW
The following documents provide further information in regards to this topic
Management System Standard
Environmental Management System
The CEMP has been prepared in accordance with the overarching environmental management system (EMS) as
detailed below
Georgiou has a certified EMS consistent with ASNZS ISO 14001 Environmental Management Systems and will
prepare CEMPs in accordance with this EMS
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CEMP Bays Road Relocation Works
Policy
This Management Plan has been prepared in accordance with Georgioursquos Environmental Policy (appendix 11) All
relevant works including those conducted by subcontractors or by other companies on Georgioursquos behalf will
conform to this Policy
Georgioursquos Environmental Policy will be communicated to all workers at their site induction and displayed at the
site Georgioursquos policies will be made available to any interested party
Environmental Management Plan
This CEMP provides the system to manage and control the environmental aspects of the Project during pre-
construction and construction It identifies all the requirements applicable to manage the activities described in
Section 2 It also provides the overall framework for the system and procedures to ensure environmental impacts
are minimised and legislative and other requirements are fulfilled The strategies defined in this CEMP have been
developed with consideration of the Project approval requirements environmental management measures
presented in the approval documents This CEMP establishes the system for implementation monitoring and
continuous improvement to minimise impacts from the Project on the environment
This CEMP is consistent with
ASNZS ISO14001 2004 lsquoEnvironmental Management Systems - requirements with guidance for usersquo
Georgiou HSEQ Management System
Environmental Policy
Georgious Management is committed to regulatory
compliance pollution prevention and continous
improvement
Planning
Identify environmental interactions and signficant
aspects identify legal and other requirements and development
environmental objectives targets and the programs in
which to achieve them
Implementation and Operation
Define structure and responsibility identify and complete training
needs establish communication procedures document the EMS
through policies plans and procedures establish document
control establish operational control implement emergency
preparedness and response
Checking
Monitor and measure environmental interactions
evaluate compliance establish a non-conformance corrective
action and preventative action system maintain records and
perform periodic internal audits of the EMS
Management Review
Management to review environmental performance
EMS performance policy priorities and objectives and recommend improvements
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5 LEGAL AND OTHER OBLIGATIONS
The following documents provide further information in regards to this topic
Management System Standard
HSE Legal and Other Obligations Directory
General
The statutory requirements for this site have been identified within the Company HSE Legal and Obligations
Directories (available on Company Intranet) and have been incorporated into this management plan Legal and
other requirements specific to this contract which are not otherwise captured in the Company HSE Legal and
Obligations Directories are as follows
Legislation Other requirement
Requirement Comment
EPBC Act 1999
Under the EPBC Act a referral to the Commonwealth Department of Agriculture Water and the Environment is required for proposed lsquoactionsrsquo that have the potential to significantly impact on any matter of national environmental significance the environment in general or the environment of Commonwealth land (including leased land)
There are no matters of national environmental significance located within the general area of the proposal as confirmed in Appendix A of the REF Therefore an EPBC Act referral is not required
EPampA Act 1979
Clause 94 of the ISEPP outlines that development for the purpose of road and road infrastructure facilities which are permissible without the need for development consent under Part 4 of the EPampA Act when carried out by a public authority
Sydney Metro is a public authority and has prepared an REF and determination report to meet the assessment requirements under the EPampA Act
EPampA Regulation 1979 Under clause 228 of the factors to take into account concerning the impact on an activity on the environment
The REF and determination report prepared by Sydney Metro has considered factors under clause 228
ISEPP 2007
Division 1 of Part 2 of the ISEPP contains provisions for public authorities to consult with local councils and other public authorities prior to the commencement of certain types of development
Sydney Metro will conduct consultation with local councils and other authorities prior to commencement of construction
Biosecurity Act 2015
Under the Biosecurity Act 2015 all plants including weeds are regulated with a general biosecurity duty to prevent eliminate or minimise any biosecurity risk they may pose Any person who deals with any plant who knows (or ought to know) of any biosecurity risk has a duty to ensure the risk is prevented eliminated or minimised so far as is reasonably practicable
The State level priority weeds and associated legal requirements relevant to the region are outlined in the Greater Sydney Regional Strategic Weed Management Plan 2017-2022 (Greater Sydney Local Land Services 2017)
As such if present priority weeds on the site would be assessed and controlled to fulfil the General Biosecurity Duty and minimise biosecurity risks
Contaminated Land Section 60 of the Contaminated Land Management Act 1997 imposes a duty on
One site (former White Bay Power Station) that is currently regulated by
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Management Act 1997 landowners to notify the NSW EPA and potentially investigate and remediate land if contamination is above NSW EPA guideline levels
the NSW EPA is located within the proposal site
Given the proposed works are predominately surficial or up to one metre below existing site levels contamination risk is considered minor and manageable
Biodiversity
Conservation Act 2016
The Biodiversity Conservation Act 2016 provides for the protection of threatened species populations and ecological communities in NSW If a threatened species population or ecological community or its habitat is likely to occur in any area that may be affected by the proposal then an assessment of significance must be prepared to determine whether the proposal would have a significant impact
The site is unlikely to contain suitable habitat for any listed threatened species or community and is unlikely to have a significant impact on any threatened species or community
Heritage Act 1977
The NSW Heritage Act 1977 (Heritage Act) provides protection for items of lsquoEnvironmental heritagersquo in NSW Items considered to be significant to the State are listed on the State Heritage Register (SHR) and cannot be demolished altered moved or damaged or their significance altered without approval from the Heritage Council of NSW
Section 170 of the Heritage Act requires government agencies to maintain a heritage and conservation register (Section 170 register) These registers provide a list of government assets which may have State or local heritage significance
Sections 139 to 145 of the Heritage Act prevent the excavation or disturbance of land known or likely to contain relics unless in accordance with an excavation permit Excavation permits are issued under Section 140 of the Heritage Act or Section 60 for sites listed on the SHR Excavation Permit Applications must be supported by an Archaeological Research Design Section 146 of the Heritage Act requires that any discovery or location of a lsquorelicrsquo is reported to the Heritage Council
The road footprint for Georgioursquos scope of works is located outside of the heritage curtilage for the SHR-listed White Bay Power Station and does not extend north to the White Bay Power Station (Inlet) Canal (Port Authority of NSW s170 4560062)
The Glebe Island Silos (Port Authority of NSW s170 4560016) and the Glebe Island Dyke Exposures (Port Authority of NSW s170 4560056) are located immediately adjacent to the road footprint
As detailed in the REF it is unlikely that archaeological relics would be impacted by the works therefore a Section 139 exception or Section 140 permit are not required for the works
National Parks and
Wildlife Act 1974
Sections 86 87 and 90 of the National Parks and Wildlife Act 1974 require consent from the Environment Energy and Science Group of the Department of Planning Industry and Environment for the destruction or damage of Aboriginal objects
The proposal is unlikely to disturb any Aboriginal objects (refer Section 77)
However if unexpected archaeological items or items of Aboriginal heritage significance are discovered during the construction of the proposal the Sydney Metro Unexpected Finds procedure would be followed
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Protection of
the Environment
Operations Act 1997
The Protection of the Environment Operations Act 1997 (POEO Act) administers environment protection licences (EPLs) for specific activities relating to air water and noise pollution and waste management The Environment Protection Authority (EPA) and local government where relevant administer the POEO Act
Development activities require an EPL under the POEO Act if those activities meet the assessment criteria outlined in Schedule 1 of the Act
The proposal does not meet the definition of a scheduled activity under Schedule 1
In addition the POEO Act would require construction to be managed to prevent and avoid the potential to cause water noise andor air pollution The Act also includes requirements in relation to the management of waste
Notification to the EPA would also be required (as the administrators of this Act) in instances where any pollution incident has the potential to lsquocause or threaten material harm to the environmentrsquo (refer to Section 148 of the Act)
Roads Act 1993
In accordance with Section 138 of the Roads Act 1993 consent from NSW Transport for NSW would be required for the carrying out of work in on or over a classified road
For works on unclassified roads Clause 5 of Schedule 2 of the Act provides that a public authority is not required to obtain a road authorityrsquos consent
Ongoing consultation would be carried out with the relevant road authority (or authorities) in relation to the potential impacts that may occur to all of the roads and to identify any potential construction activities may be require consent
Waste avoidance and
Resource Recovery
Act 2001
The purpose of the Waste Avoidance and Resource Recovery Act 2001 is to develop and support the implementation of regional and local programs to meet the outcomes of a State-wide strategy for waste avoidance and resource recovery
It also aims to lsquominimise the consumption of natural resources and final disposal of waste by encouraging the avoidance of waste and the reuse and recycling of wastersquo
Waste generation and disposal reporting would be carried out during the construction and operation of the proposal Procedures would be implemented during construction in an attempt to promote the objectives of the Act
Water Act 1912 and
Water Management
Act 2000
The Water Act 1912 and the Water Management Act 2000 are the two key pieces of legislation for the management of water in NSW and contain provisions for the licensing of water access and use
The proposal would not involve any water use water management works drainage or food works controlled activities or aquifer interference
National Greenhouse and Energy Reporting Act 2007
The Act established a framework for reporting of greenhouse gas emissions abatement actions energy consumption and production data
The project will report on greenhouse gas and energy usage data as required by the Act
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Contractual Environmental Requirements
This Management Plan has been written to comply with the following Sydney Metro CEMF requirements
Requirement Reference
Scope of Applicability (Any Sections of the CEMF not addressed in the left hand column of
this table do not apply) Addressed by
CEMF Requirements
Section 1 full applicability This document
Section 4
Section 2 full applicability Section 5
Section 23
Standards and guidelines applicable to the works including o ISO14001 Environmental Management System ndash Requirements
with Guidelines for Use o Interim Construction Noise Guidelines (Department of
Environment and Climate Change 2009) o Managing Urban Stormwater Soil and Construction (Landcom
2008) o AS42821997 Control of the Obtrusive Effect of Outdoor Lighting o Waste Classification Guidelines (Department of Environment
Climate Change and Water 2008) o Australian and New Zealand Guidelines for Fresh and Marine
Water Quality
Section 41
Appendix 7
Appendix 2
Appendix 1
Section 32
Only applies with respect to Construction for o SMP1 o SMP2 o SMP5 o SMP6 o SMP7 o SMP14 o SMP18 o SMP19 o SMP30
Separate sustainability management plan
Section 34
34(d) (x) applies only to the extent of addressing environmental inspections
34(d) (xi) does not apply
Approval by DPIE is not required under 34(e)
34(f) Applies with respect to o Unexpected Finds Procedure (Heritage) o Environmental Incident and Non-compliance Reporting Procedure o Construction Noise and Vibration Standard o Out of Hours Work Application Form o Unexpected Finds Procedure (Contamination)
This document
Appendices 1-10
Section 36 36(b) only applies with respect to the drafting of a Waste Management Procedure and an Unexpected Finds Procedure for Contamination
Appendix 1
Appendix 8
Section 39 39(a) (iii) does not apply 39(b) does not apply
39(b) does not apply Section 11
Section 310 Applies except that a Pollution Incident Response Plan is not required Section 12
Section 312 312(a)(i) does not apply
312(a)(iv) does not apply Section 6
Section 313
313(b) does not apply
313(d) does not apply
313(e) does not apply
Section 15
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CEMP Bays Road Relocation Works
Section 314 Full Applicability Section 13
Appendix 9
Section 315 315(d) does not apply with respect to internal audits carried out by the Principal Contractor
Section 16
Section 316 316(d) does not apply where the Principal Contractors works last less than 1 year
Section 15
Section 4 42(a) does not apply
45(c) does not apply Section 72
Section 5 51(c) does not apply
54 does not apply Appendix 7
Section 6 Only 61 applies
Sustainability management plan
Section 7 71 does not apply
72 does not apply
Appendix 2
Section 8
81 full applicability
A Construction Noise and Vibration sub-plan is not required however the CEMP must address
82(a) (iii) and (b) for Site Establishment Activities
Appendix 7
Section 9
91 (a) (i) is not applicable
A Heritage Management plan is not required however the CEMP must address the following requirements
92 (iii)
92 (ix)
92 (c) (iii)
Appendix 5 5A 5B
Section 10
101 (ii) does not apply
102(a) (iii) applies with respect to the relocation of fauna only
102(b) (i) applies
102 (b) (ii) applies
All other sections are not applicable
Appendix 4
Section 11 111 (ii) does not apply
112 does not apply Section 72
Section 12
A Soil and Water Management Plan is not required however the CEMP must address the following requirements
122 (vi)
Appendix 2
Section 13 131 full applicability
132 does not apply Appendix 6
Section 14
141 full applicability
A Waste Management Plan is not required however the CEMP must address the following Requirements
142 (a) (iv)
142 (a) (v)
142 (b) (i)
142 (d)
Appendix 1
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CEMP Bays Road Relocation Works
REF Determination Conditions of Approval
The project is subject to compliance with the Conditions of Approval (CoA) identified below these are from the
REF Determination Report (August 2020) These Conditions of Approval are consistent with the management and
mitigation measures in the REF (April 2020) with some amendments due to the project changes identified in the
REF determination report
CoA Requirement Addressed by
REF Determination Conditions of Approval
NV1 Receivers that would potentially be affected by noise andor vibration from the works would be appropriately notified before the relevant works start
This would include details on the nature of works to be carried out the expected noise levels duration of noise generating construction works and contact details during construction
Appendix 7
NV2 Where vibration levels are predicted to exceed the screening criteria a more detailed assessment of the structure (in consultation with the relevant asset owner and a structural engineer) and attended vibration monitoring would be carried out to ensure vibration levels remain below appropriate limits for that structure
For heritage buildings and structures the more detailed assessment would specifically consider the heritage values of the structure in consultation with a heritage specialist to ensure sensitive heritage fabric is adequately monitored and managed
Appendix 7
NV3 Condition surveys of buildings and structures near to the proposal would be undertaken in consultation with the relevant owner prior to the commencement of vibration intensive works where appropriate For heritage buildings and structures the surveys would consider the heritage values of the structure in consultation with a heritage specialist
Sydney Metro
NV4 Alternative construction methodologies would be considered where vibration intensive works (typically site clearing ndash demolition) result in exceedances of cosmetic damage screening criteria and may include the following
The use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of rockbreakers for demolition of structures
Use of smaller capacity rockbreakers or lower vibration generating rockbreakers
Isolating the vibration sensitive structure from the vibration intensive work area by severing the vibration transmission path using non-vibration intensive means such a sawing
Appendix 7
NV5 The potential vibration impacts to underground utilities and services would be reviewed as the proposal progresses in consultation with the asset owners and the Port Authority of NSW
Appendix 7
T1 Clear wayfinding and safety signage would be provided to direct and guide vehicles not related to the proposal during road construction works This would be supplemented by Variable Message Signs to advise drivers of traffic diversions speed restrictions or alternative routes
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T2 The Port Authority of NSW and lease holders would be notified in advance of any proposed road changes within the port area and the potential for short term delays
Sydney Metro
Georgiou must provide written notifications to Sydney Metro on road changes in
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CEMP Bays Road Relocation Works
advance of each relevant road change within the port area
T3 Construction site traffic would be managed to minimise movements during peak periods
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
T4 Access to Cement Australia and other leased areas would be maintained in consultation with Port Authority and lease holders
Sydney Metro
Georgiou will provide required information to SM
T5 All staff parking would be provided on-site and not on surrounding local streets
Traffic management plan (TMP) and Traffic control plans (TCPs) will address
NAH1 An Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
(Transferred to Georgiou under VO-003)
C1 Sampling and testing of soils in areas of potential contamination concern would be conducted to characterise the soils (with respect to contamination) and determine the appropriate waste classification (which may include hazardous wastes or special wastes) and management response Waste classification would be carried out in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (NSW Environment Protection Authority 2014)
Appendix 1
Appendix 1A
C2 Soils would be managed in accordance with the Protection of the Environment Operations (Waste) Regulation 2014 and disposed of to an appropriately licensed waste management facility
Appendix 1
Appendix 1A
C3 Erosion and sediment measures would be implemented in accordance with the principles and requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Appendix 2
C4 All fuels chemicals and hazardous liquids would be stored in accordance with Australian standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Appendix 3
C5 Prior to ground disturbance in areas of potential acid sulfate soil occurrence testing would be carried out to determine the presence of actual andor potential acid sulfate soils If acid sulfate soils are encountered they would be managed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Appendix 2
LV1 The design and maintenance of construction site fencing would aim to minimise visual amenity impact where visible from public areas
Section 722
LV2 Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Appendix 7
WR1 All waste would be assessed classified managed transported and disposed of in accordance with the Waste Classification Guidelines and the Protection of the Environment Operations (Waste) Regulation 2014
Appendix 1
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CEMP Bays Road Relocation Works
The waste management hierarchy principles established under the Waste Avoidance and Resource Recovery Act 2001 of avoidreducereuserecycledispose would be applied to the construction of the proposal
AQ1 The following best-practice dust management measures would be implemented during all construction works
Regularly wet-down exposed and disturbed areas including stockpiles especially during dry weather
Adjust the intensity of activities based on measured and observed dust levels and weather forecasts
Minimise the amount of materials stockpiled and position stockpiles away from surrounding receivers
Regularly inspect dust emissions and apply additional controls as required
Appendix 6
AQ2 Plant and equipment would be maintained in a proper and efficient manner Visual inspections of emissions from plant would be carried out as part of pre-acceptance checks
Appendix 6
GHG1 Opportunities to reduce greenhouse gas emissions through the increased use of recycled materials would be investigated during detailed design
Sydney Metro
CI1 The likelihood of cumulative (ie concurrent and consecutive) construction impacts would be reviewed during detailed design when detailed construction schedules are available
Co-ordination and consultation with the following stakeholders would occur where required to manage the interface of projects under construction at the same time
Transport for NSW including Transport Coordination
Department of Planning Industry and Environment
Port Authority of NSW
Sydney Motorways Corporation
Construction contractors
Co-ordination would occur between potentially interacting projects to minimise concurrent or consecutive works in the same areas where possible
Sydney Metro
Georgiou must participate in any consultation as requested by the Principal and provide the Principal with all information and documentation the Principal requires to comply with condition
Environmental Licences and Permits
The Project Environmental Site Representative will be responsible for
Checking with the local government municipality to see if there are local environmental requirements Identifying the environmental licences and or permits under which the site will operate Obtaining a copy of any client held licences permitsapprovals to determine conditions of compliance or if not
available obtaining written verification that licences and permits are held Obtaining Georgiou held licences and or permits Monitoring compliance to the conditions of the licencepermit and report on the status in the Project HSEQ
Performance Report and to the client
Permits and licences relevant to the project are as follows
Permit licence Responsibility Status
Environmental protection licences (EPL) under the Protection of the Environment Operations Act 1997 for road construction
Georgiou Not required as this project does not trigger a scheduled activity under the POEO Act 1997
Road Occupancy Licences Georgiou To be applied for as required
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Infringement Improvement and Prohibition Notices
The Project Manager or delegate will ensure any infringement improvement or prohibition notice issued by a
regulatory authority recorded as a incident in Georgioursquos Incident reporting database (Beakon) and appropriate
actions taken in a timely manner A copy of the infringement improvement or prohibition will be added to the
incident report and forwarded to the HSE Business Unit Lead
The Project Manager will notify via email their General Manager Construction Manager Operations Manager
HSE Business Unit amp Environmental Site Representative Lead when the infringement improvement or prohibitions
notice has been closed out
Availability of Statutory and Other Information
Georgioursquos HSEQ Department maintains links to current statutory documents (Acts Regulations and Codes of
Practice) in the HSE Legal and Other Obligations Directories which are located on Georgioursquos Intranet
(GENIE)Georgiou subscribes to Environmental Essentials product Envirolaw which is available to all personnel
through the intranet link Envirolaw summarises environmental legal obligations provides links to legislation and
guidelines as well as providing search capabilities
Changes in legislation are monitored by the HSEQ Department and site management will be notified where a change
affects a site The Project Manager will be responsible for communicating changes in accordance with section 7
HSE will ensure the change is reflected in this Management Plan and other relevant plans and documents as
applicable
Objectives amp Targets
Objectives and targets have been set for the site taking into account the significant hazards and environmental
aspects of the job the group objectives and client and contractual requirements These are documented in the
table below
Item Description Measurement Target
1 Successful implementation of CEMP and contract requirements
Audits inspections reporting management reviews
0 NCRs associated with CEMP implementation
2 Compliance with all legal requirements Audits reporting management reviews
0 regulatory infringements (PINs or prosecutions)
3 Engage with the affected and broader community minimise complaints and respond to any complaints within a suitable timeframe
Review complaints register reporting audits
0 NCRs associated with CCS implementation
4 Environmental incidents with the potential to cause material harm to the environment
Number of material harm incidents 0
5 Continuously improve environmental performance
Regular environmental inspections
Regular Leadership visits
Share environmental best practice and innovations across projects
1 environmental inspection per week
1 Leadership visit per month
1 NSW Environmental meeting per month
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6 Environmental Awareness for all workers
Conduct all Toolboxes and training identified in this CEMP
1 environmental toolbox per month on relevant site issues
Additional objectives and targets may be set specifically for activities identified for upcoming works Performance
against all HSE objectives will be monitored as a minimum monthly at site meetings
6 STRUCTURE AND RESPONSIBILITIES
Organisational Structure
The site organisational structure has been documented in the Site Organisational Chart The Site Organisational
Chart identifies the roles that will support the site in fulfilling their HSE responsibilities
Roles and Responsibilities and Authority
The Project Manager is accountable for the environmental performance of the project and the implementation of
the projectrsquos management plans Key personnel and their site responsibilities are detailed below
Project Manager ndash Brad Collins
The environmental responsibilities of the Project Manager include (but are not limited to) the following
Ensure all works comply with relevant regulatory and Project requirements Ensure the requirements of this CEMP are fully implemented and in particular that environmental
requirements are not secondary to other construction requirements Endorse and support the environmental policy Be aware of their environmental responsibilities as detailed in the management plans Actively ensure that subcontractors and suppliers are complying with environmental requirements Liaise with the client and other government authorities as required Participate and provide guidance in the regular review of this CEMP and supporting documentation Provide adequate resources (personnel financial and technological) to ensure effective development
implementation and maintenance of this CEMP Ensure that all personnel receive appropriate induction training including details of the environmental and
community requirements Ensure that complaints are investigated to ensure effective resolution Stop work immediately if an unacceptable impact on the environment is likely to occur Hold monthly HSEQ management meetings to review environmental performance and monitor
implementation and effectiveness of the management system Ensure their direct reports fulfil their environmental responsibilities and achievement of KPIrsquos Support workers to immediately stop any lsquoat risk behaviourrsquo identified during their work activities
Project Site Engineer ndash Richard Kelly
The environmental responsibilities of the Project engineers include (but are not limited to) the following
Provide input into the preparation of environmental planning documents as required Ensure that instructions are issued and adequate information provided to employees that relate to
environmental risks on-site Ensure that the works are carried out in accordance with the requirements of the CEMP and supporting
documentation including the implementation of all environmental controls Identify any environmental risks Identify resource needs for implementation of CEMP requirements and related documents Ensure that complaints are investigated to ensure effective resolution
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Take action in the event of an emergency and allocate the required resources to minimise the environmental impact
Report any activity that has resulted or has the potential to result in an environmental incident immediately to the Supervisor and Environmental Site Representative
Supervisor ndash Eddie Storer
The Supervisor is responsible for creating an exemplary HSE culture and ensuring adherence to the Management System on their site The Supervisor is responsible for approving the commencement of works and to allocate necessary resources to complete a job safely in accordance with the Management Plan and will
Demonstrate commitment to the Environment by monitoring the workplace to ensure work practices are adhered to by way of routine checks of the workplace compliance to the Management Plan
Demonstrating through their actions and behaviour that safety and the environment are core values Hold Supervisors and leading hands (Georgiou amp subcontractors) accountable for the fulfilment of their
Environmental responsibilities including KPIrsquos Be given the authority and independence to require reasonable steps be taken to avoid or minimise
unintended or adverse environmental impacts Allocating work to ensure appropriate supervision for those with lesser experience Ensuring appropriate and necessary plant and equipment is provided for workers to carry out their work
safely and without undue harm to the environment Stopping rejecting or quarantining materials plant and equipment Supporting workers to immediately stop any lsquoAt Risk Behaviourrsquo identified during their work activities Participating in audits investigations and constructability reviews Management and HSE performance of the subcontractors utilised on site
Environmental Site Representative ndash Chloe Redman
The environmental responsibilities of the Environmental Site Representative include (but are not limited to)
overall responsibility for the implementation of environmental matters on the Project development implementation monitoring and updating of the EMP and sub-plans in accordance with
ISO14001 report to the Project Manager on the performance and implementation of the CEMP to ensure management
reviews of the CEMP are undertaken annually documented and actions implemented ensure environmental risks of the Project are identified and appropriate mitigation measures implemented identify where environmental measures are not meeting the targets set and where improvement can be
achieved ensure environmental protocols are in place and managed ensure environmental compliance obtain and update all environmental licences approvals and permits as required liaise with the approval authorities manage environmental document control reporting inductions and training manage environmental reporting within the Project team and to the Client and regulatory authorities prepare reports on a monthly basis outlining the Project works undertaken and the achievements that have
been met as well as identifying those areas where improvements were made oversee site monitoring inspections and audits manage all sub-contractors and consultants with regard to environmental matters including assessing their
environmental capabilities and overseeing the submission of their environmental documents develop and facilitate induction toolbox talks and other training programs regarding environmental
requirements for all site personnel notify the client and relevant authorities in the event of an environmental incident and manage close-out of
these stop activities where there is an actual or immediate risk of harm to the environment or to prevent
environmental non-conformities and advise the Project Manager and Supervisor assist the Community Relations Manager to resolve environment-related complaints
undertake site inspections carry out monitoring activities and complete site checklists ensure monitoring records are appropriately maintained reviewed and any non-compliance issues addressed assist in identifying environmental risks
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advise the Project Manager of the need to stop work immediately if an unacceptable impact on the environment is likely to occur or to require other reasonable steps to be taken by the site Construction staff to avoid or minimise impacts
Environmental Consultants
Georgiou has engaged consultancy contracts with the following companies
Ade Consulting - Contaminated land and hygienist services VMS ndash Noise and Vibration Management Services ARTEFACT ndash Archaeological and Heritage Consultants
Throughout the works there may be the requirement to engage other specialist environmental consultants or change the consultants listed above All Environmental consultants engaged to provide specialist advice on environmental matters are responsible to
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the Supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Adhering to all permit requirements Complying with all statutory and regulatory requirements
All Personnel
All personnel on site are responsible for
comply with the relevant requirements of the CEMP or other environmental management guidance as instructed by a member of the Projectrsquos management
participate in the mandatory Projectsite induction program report any environmental incidents to the supervisor immediately or as soon as practicable if reasonable
steps can be adopted to control the incident undertake remedial action as required to ensure environmental controls are maintained in good working
order Stop activities where there is an actual or immediate risk of harm to the environment and advise the
Supervisor Ensuring compliance with the requirements of the HSE management system Participating and adhering to SWIrsquos and JHArsquos Adhering to all permit requirements Immediately stopping any lsquoAt Risk Behaviourrsquo identified during daily work activities Complying with statutory and regulatory requirements
Communication and Acceptance of Accountabilities and Responsibilities
The Core Site Team will acknowledge their understanding and acceptance of the site accountabilities and
responsibilities by signing Appendix 1 in this plan
Field Leadership Visits
Senior Management with an operational role or functional support will demonstrate visible and proactive commitment by visiting site to engage in discussion with site management and workers in regard to HSE issues relevant to the business which may include any of the following
Active participation and contribution in Pre-start meetings Participation in Toolbox Talks Participation in the delivery of site safety and environmental messages on-site HSE programs or initiatives Participation in work inspections One-on-one discussions
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Behavioural observations Participation in monthly meetings discussing HSEQ performance
A record of the visit and the activity undertaken by the Senior Manager will be recorded and where appropriate feedback provided to the Site team A component of the Site Leadership visit will involve an environmental inspection of the site in accordance with section 151
7 COMMUNICATION AND CONSULTATION
The following documents provide further information in regards to this topic
HSEQ Communication and Consultation Standard
Community Relationship Management Guideline
Resolution of HSE Issues Procedure
Internal Communication and Consultation
Communication and consultative arrangements will be put in place to provide workers including subcontractors
with information and an opportunity to contribute to HSE and comply with applicable legislative requirements
The Site will use the methods detailed below to communicate to employees subcontractors and visitors
information in regard to the Georgiou Management System this management plan performance and environmental
issues
711 Inductions
All personnel (including sub-contractors) are required to attend a compulsory site induction that includes an
environmental component prior to commencement on-site This is undertaken to ensure all personnel involved in
the Project are aware of the requirements of the CEMP The environmental component of the induction must cover
all elements of the CEMP and will include as a minimum
relevant details of the CEMP including all sub-plans procedures and strategies their purpose and objectives
policies and KPIs
Requirements of due diligence and duty of care
relevant legislation and conditions of environmental licences permits and approvals
Potential environmental emergencies on-site and the emergency response procedures
Reporting and notification requirements for pollution and other environmental incidents
key environmental issues
Mitigation measures for the control of environmental issues
Complaints response and reporting
Communication protocols for interactions with community and stakeholders
site specific environmental management requirements and responsibilities
Incident and emergency response and reporting requirements
Environmentally sensitive locations and no-goexclusion zones
Erosion and sediment controls water quality controls and sediment basin management
Management of contaminated material (including asbestos impacted material)
Location of identified potential contaminated land sites
Signs of contaminated soil including visual asbestos identification protocols
Procedure for unexpected finds of contaminated land asbestos
Water quality management and protection measures
Location of identified Aboriginal and non-Aboriginal archaeological heritage sites areas of cultural sensitivity
and areas of archaeological potential and the kinds of historical relics structures or deposits which may be
encountered during the Construction works
Unexpected finds procedures for heritage
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noise vibration and air quality management controls
Standard Construction hours and the process for seeking approval for out of hours works including consultation
Road occupancy and other temporary and interim traffic arrangements
Specific responsibilities for the protection of flora and fauna
A record of all environment inductions will be maintained in a Project induction and training Register and kept on-
site The training register will identify who is trained when trained the trainer and what they were trained in
712 HSE Notice Boards
All worksites that have a crib room will set up a HSE notice board to display
Project HSEQ Performance Report
Environmental BulletinsAlerts
Site HSEQ Objectives and Targets
Organisational Chart
A Site Layout Plan and Emergency Evacuation Plan Emergency contacts and First Aiders list These will also be
posted in prominent locations throughout the site as described in the site Emergency Response Management
Plan
Risk Registers
713 HSE Alerts Bulletins
Incident Alerts will be used to communicate learningrsquos and actions required to assist in ensuring incidents that have
occurred in one workplace are not repeated in others HSE Bulletins will be used to communicate environmental
information to the workplace HSE Alerts and Bulletins will be developed by the Site Team using the approved
templates and approved by the HSE Business Unit Lead prior to communication
714 Site Meetings
The following meetings will be held on site to monitor implementation of the Georgiou Management System review
performance and communicate consult with workers in regards to HSE
Site Meetings (refer to section 142) Pre-Start Meetings Toolbox Meetings
Meeting agenda and minutes will be recorded maintained and be made available when required
Community and Stakeholder Involvement
A Community Communication Strategy will be developed for the project Key elements of the Community
Communication Strategy which will be implemented at appropriate times in the construction process will include
Notification (including targeted letterbox drops and email) of any works that may disturb local residents and businesses (such as noisy activities and night works) at least seven days prior to those works commencing
Notification (including targeted letterbox drops and email) of works that may affect transport (such as road closures changes to pedestrian routes and changes to bus stops)
Traffic alerts (via email) to all key traffic and transport stakeholders advising of any changes to access and local traffic arrangements (at least seven days prior to significant events)
Print and radio advertisements regarding major traffic changes 24-hour toll-free community project information phone line Complaints management Community information sessions as required Regular updates to the Sydney Metro website (sydneymetroinfo) including uploading of all relevant
documents and contact details for the stakeholder and community relations team
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Provision of information to the Sydney Metro Community Information Centre including community newsletters information brochures and fact sheets and interactive web-based activities
Clear signage at the construction sites Newspaper advertisements in local and metropolitan papers as required Regular inter-agency group meetings Community business and stakeholder satisfaction surveys and feedback forms Translator and interpreter services and The project team will liaise with the Sydney Metro Project Communications team as the point of contact for
the community
721 Complaints Management
Community liaison and complaints handling will be undertaken in accordance with the Construction Complaints
Management System and will include
dealing with complaints in a responsive manner so that stakeholdersrsquo concerns are managed effectively and promptly and
A verbal response will be provided to the complainant as soon as possible and within a maximum of two hours from the time of the complaint (unless the complainant requests otherwise) A detailed written response will then be provided if required to the complainant within one week
A complaints register will be maintained in Georgioursquos BEAKON database and in Sydney Metrorsquos Consultation
Manager TM which will contain
Date and time of complaint Method by which the complaint was made (telephone letter meeting etc) Name address and contact telephone number of complainant (if no such details were provided a note to that
effect) Nature of complaint Action taken in response including follow up contact with the complainant Any monitoring to confirm that the complaint has been satisfactorily resolved If no action was taken the reasons why no action was taken
The project will apply an adaptive approach to ensure that corrective actions are applied in consultation with the
appropriate construction staff to allow improvements in the management of issues resulting in community
complaints
722 Urban Design of temporary works
Temporary construction works will consider urban design and visual impacts including
Minimise impacts on existing landscape features as far as feasible and reasonable Artwork graphics and images to enhance the visual appearance of temporary works in high visibility locations Project information to raise awareness on benefits explain the proposed works at each site and provide
updates on construction progress Community information including contact numbers for enquiries complaints Signage and information to mitigate impacts on local businesses which may be obscured by the construction site Sydney Metro advertising public awareness campaigns Logos branding including Sydney Metro NSW Government and Contractor branding
The design of all temporary works will require Sydney Metro approval in relation to urban design and visual impacts
and Sydney Metro will stipulate the design of hording artwork including
Sydney Metro advertising public awareness campaigns and Logos branding including Sydney Metro NSW Government and Contractor branding
Construction hoardings scaffolding and acoustic sheds will be regularly inspected and kept clean and free of dust
build up Graffiti on construction hoardings scaffolding or acoustic sheds will be removed or painted over
promptly The principles of Crime Prevention Through Environmental Design will be applied to all works including
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temporary works that have a public interface
723 Business and Property Impacts
The project footprint is within any area managed by the Port Authority of NSW and several port related facilities
are adjacent to the work including Cement Australia Gypsum Resources Australia and Sugar Australia Georgiou will
undertake works to meet the following objectives
Minimise the potential impact of the project to businesses affected by construction works Ensure businesses are kept informed of the project and consulted in advance of major works or factors that are
likely to have a direct impact Ensure that business stakeholder enquiries and complaints regarding the project are managed and resolved
effectively
Consult with all business directly affected by changes to access arrangements regarding specific requirements at least two weeks prior to those changes coming into effect
8 HAZARD IDENTIFICATION AND RISK CONTROL
The following documents provide further information in regards to this topic
HSEQ Risk and Operational Control Standard Job Hazard Analysis (JHA) Procedure Permit to Work Procedure
Hierarchy of Control
The following hierarchy of control will be applied to controlling environmental risks and environmental aspects
within Georgiou This hierarchy recognises that the best controls act on the environment not on the people in it
HazardsAspects
Waste
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Site Environmental Risk Analysis
The Site Team has undertaken a construction risk assessment workshop (CRAW) and developed a HSEQ Risk
Register based on the Master Risk Register which incorporates the Companyrsquos mandatory controls and additional
site specific hazards and controls identified in the CRAW This Management Plan and the Emergency Response
Management Plan have been based upon this HSEQ Risk Register
Works on site will be undertaken in accordance with the HSEQ Risk Register The HSEQ Risk Register will be
made available to workers
Review of Risks
The aspects within the HSEQ Risk Register will be reviewed for adequacy
At site meetings Prior to the commencement of any new construction work that involves high impact risks After a significant incident
If there is a change made to the construction methodology and associated change in the risks and controls associated with the works the Risk register and Construction Environmental Management Plan will be updated as appropriate
831 Change Management
The following documents provide further information in regards to this topic
Change Management Procedure
Where there is a change to the planned scope design or construction methodology (including plant machinery
materials or sequence) the impact of the change must be assessed and a determination on whether the Change
Management Procedure applies If so then a formal analysis of the change will be undertaken using the
Management of Change Event Design Form
Changes to the project may require an assessment to determine consistency with the REF and Environmental
Documents The assessment will include
A description of the existing surrounding environment Details of the ancillary works and construction activities required to be carried out including the hours of works An assessment of the environmental impacts of the works including but not necessarily limited to traffic
noise and vibration air quality soil and water ecology and heritage Details of mitigation measures and monitoring specific to the works that would be implemented to minimise
environmental impacts Identification of the timing for completion of the construction works and how the sites would be reinstated
(including any necessary rehabilitation)
Operational Control
Operations and activities associated with significant environmental aspects will be planned to ensure they are
carried out under specific operating conditions An Environmental Control Map (ECM) Safe Work Method
Statements Job Hazard Analysis Take Five Hazard Report or a combination of these will be used to achieve this
requirement
841 Environmental Hazard Reporting
Environmental Hazard reporting will be conducted using the Hazard Report (contained within the Hazard
ReportTake 5 booklet)
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The Supervisor is responsible for ensuring environmental hazards are addressed in a timely manner using the
hierarchy of control and communicated to those who may be potentially affected Where hazards cannot be
addressed immediately and additional controls are required they are to be reported into the Beakon system for
follow-up and close-out
842 Take 5
Take 5 booklets will be available to all workers to perform risk assessments for work that is not high risk
construction Take 5 risk assessments include environmental aspects and the identified environmental controls for
these risks are to be documented on the Take 5 form and implemented for the works
843 Job Hazard Analysis (JHA)Safe Work Method Statement (SWMS)
JHASWMS will be completed for all high risk construction work JHASWMS developed will reflect the safety and
environmental risks and controls identified in the sites risk register and supporting work instructions
Subcontractors will be provided access to the sites HSEQ Risk Register and prior to undertaking the work will be
required to submit their JHArsquosSWMS to Georgiou for review and approval using the Subcontractor JHASWMS
Assessment (available in Beakon)
844 Permit to Work
The following high risk activities require written authority in the form of a ldquopermit to workrdquo from the Georgiou Site
Team
Vegetation Clearing Permit (Georgiou form) Dewatering Permit (Georgiou form) Out of Hours application (Sydney Metro form)
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices) will be included in the
environmental permits No work involving these activities will commence until the appropriate permit has been
completed Personrsquos issuing permits on the Site will be given training in the Georgiou Permit to Work system A
permit may be required for other high risk activities as determined by risk assessment the Sitersquos Manager andor
contractual requirements
845 Environmental Control Maps
To assist pre-construction planning and on-site construction management the environmental site constraints are
consolidated on a series of map-based sheets that extend the length of the Project Environmental Control maps
include information pertaining but not limited to
Noise and vibration sensitive receiverrsquos eg residential dwellings
Flora features including threatened species and endangered ecological communities
Aboriginal and non-Aboriginal heritage sites including items places objects and sites
Local waterways
Recorded threatened fauna sightings
Relevant environmental controls detailed in this CEMP and associated sub plans (appendices)
The Environmental Control maps are a working element of the CEMP and will be revised throughout construction to
reflect true ground conditions and the most up-to-date information available on sensitive sites Sensitive area maps
will be used in conjunction with EWMS and ESCPs to help identify key risk areas and to promote ongoing
communication to construction personnel during the Project
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9 SIGNIFICANT ENVIRONMENTAL ASPECTS MANAGEMENT
The following environment aspects have been identified as significant for this project Risks associated with these
significant aspects and appropriate controls have been identified during the construction risk assessment workshop
(CRAW) and included in the HSEQ Risk Register in accordance with section 82
In addition aspect specific sub-plans within this CEMP have been developed to detail how the environmental
aspects will be managed to comply with relevant legislation amp client requirements These aspect specific sub plans
include
Waste
Soil and Water
Hydrocarbon and Chemical
Cultural Heritage
Air Quality and Dust
Noise and Vibration
Contamination
10 CLOSURE AND COMMISSIONING
At completion of this project Georgiou will hand over the site in an environmentally responsible state) taking into
account the nature of the works in accordance with legislative amp contractual requirements
11 TRAINING COMPETENCY AND RESOURCING
All Georgiou personnel and contractors will undergo environmental training before commencing works on site
Training will be undertaken in the following forms
project site induction (section 711) and Environmental awareness training through regular tool box discussions Inductees will be required to sign-off that they have been informed of the environmental issues and that they
understand their responsibilities
1111 Toolbox talks
ldquoToolboxrdquo training will help to ensure that relevant information is communicated to the workforce and that
feedback can be provided on issues of interest or concern ldquoToolboxrdquo training will generally be prepared and
delivered by the Project Engineers Site Foreman or HSE Advisor Toolbox training topics are to be delivered to
provide refresher information on the environmental induction topics and associated environmental procedures In
the event of environmental near misses or incidents or changes to procedures that could result in changed levels of
environmental risks Toolbox talks may be used to deliver updates
Toolbox topics likely to be required include
work methods and efficient use of plant and materials waste management minimisation and recycling dust control protecting waterways spills and leaks emergency response procedures wet weather procedures and inspections and Legislation updates Please refer to the Toolbox schedule for a library of HSE toolboxes to deliver over the life of the project
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1112 Recording of Training and Assessment
Records of training and assessment will be maintained and will be readily available for verification Records of
induction and training will include the topic of the training carried out dates names and trainer details
12 INCIDENT EMERGENCY PREPAREDNESS AND RESPONSE
The following documents provide further information in regard to this topic
Emergency Preparedness and Response Standard
EmergencyIncident Planning and Control
The site has in place an Emergency Response Management Plan (ERMP) that addresses emergency response control
and recovery based upon credible emergency scenarios as identified in the Site Risk Register The Emergency
Response Management Plan has been developed in accordance with Emergency Preparedness and Standard
13 HSE REPORTING AND INVESTIGATION
The following documents provide further information in regard to this topic
Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
Notifications and Reporting
The Project Manager is accountable for ensuring all necessary reporting and notifications take place including
Client notification Statutory notification Scheme notification Community Complaints
Notifications and reporting regarding incidents will be done in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure
1311 Internal
The Environmental Site Representative or their delegate will be responsible for reporting all incidents into Beakon
database Incidents reported into Beakon will be reviewed by the Responsible Manager and approved within five
working days or before month end in which the incident occurred
1312 Notification of Incidents to Sydney Metro
Sydney Metro will be notified of any Georgiou environmental incident as soon as reasonably practicable Copies of
the incident reports and investigations incident will be made available to Sydney Metro within 48 hours in
accordance with the Sydney Metro Environmental Incident and Non Compliance Reporting Procedure
1313 Statutory Notifications
An incident is an uncontrolled event or violation with serious or potentially serious negative consequences to
people property reputation or the environment Under Section 148 of the Protection of the Environment
Operations Act 1997 (POEO Act) Georgiou has a duty to immediately report pollution incidents causing or
threatening material harm to the environment Material harm is defined in Section 147 of the POEO Act as
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lsquoinvolves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding
$10000 and this loss includes the reasonable costs and expenses that would be incurred in taking all reasonable
and practicable measures to prevent mitigate or make good harm to the environmentrsquo
Investigations
Investigations regarding the incident will be completed in accordance with the Sydney Metro Environmental
Incident and Non Compliance Reporting Procedure and commence as soon as practicable (preferably
immediately) but within 24 hours
All environmental incidents would be investigated in such a manner that the following basic elements can be
established
identifying the cause extent and responsibility of the incident
identifying and implementing the necessary corrective action
identifying the personnel responsible for carrying out the corrective action
implementing or modifying controls necessary to avoid a repeat occurrence of the incident
recording any changes in written procedures required and
Advising regulatory authorities in accordance with licence conditions
Review and Communication of Incidents
Incidents will be reviewed to check that causal factors and root causes were identified and that the findings have
been effectively addressed through assignment of actions at the
Site monthly meetings Business Unit meetings OHS Committee Meeting (if established)
Actual and potential class 1 incidents will be reviewed by senior management to ensure adequacy of closeout HSE
incidents and their preventative actionslearnings will be communicated at pre-start meetings toolbox meetings
and through HSE alertsbulletins as per section 7
14 ENVIRONMENTAL REPORTING
1411 Monthly Reports
Georgiou is required to submit an Environmental Monthly Report to the client including the information specified
below as evidence of implementation of the Environmental Management Plan
Implementation of environmental management including environmental monitoring implementation of environmental controls training inspections and testing
Implementation of incident management including emergency response - details of all environmental incidents or emergencies including non-compliance with environmental procedures and near misses complaints implementation of incident and emergency response management and implementation of corrective action
Implementation of reviews - details of internal reviews audits and inspections undertaken to verify that on-site environmental processes and practices conform to the Environmental Management Plan
Waste Statistics and NGERs reporting
Site Meetings
The Site will hold a monthly HSEQ Management Meeting in accordance with the Health amp Safety Management Plan
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Project Performance Review
At completion of the Project the Project Manager is responsible for arranging a review of project performance
which will include HSE management performance and lessons learnt for the purpose of continually improving
Georgiou Management Systems This review will be in accordance with the Project Close-Out Procedure
15 AUDITING REVIEWS AND INSPECTIONS
The following documents provide further information in regards to this topic
Auditing Reviews and Inspections Standard
Inspections
1511 Environmental Inspections
The following inspections will take place on site
Environmental Weekly Inspections Detailed Hazard Inspections considering timingavailability of activities Site leadership field visits These inspections will be used a process to monitor onsite environmental performance and they will cover all applied environmental mitigation measures including water quality erosion and sediment control structures fuel and chemical storage and waste management Attendees for the inspections can include Sydney Metro Environmental and project team members Georgiou Environmental and project team members and Georgiou Senior and Executive Management when conducting a Field Leadership Visit (section 64) The Environmental Site Representative will record inspection findings on the inspection report If any maintenance andor deficiencies in environmental controls or in the standard of environmental performance are observed they will be recorded on the inspection Records will also include details of any maintenance required the nature of the deficiency any actions required and an implementation priority Any Sydney Metro Environmental Inspections will occur on the Sydney Metro Inspection record template ndash Appendix 10
Audits and Reviews
The following audits are scheduled for this site
Internal
AuditReview
Purpose Commencement On-going requirement
Site HSE Mobilisation Audit
Review achievement towards site start-up activities
8 weeks after mobilisation NA
Internal HSEQ audit
Determine compliance to the management systems and an assessment as the effectiveness of those requirements to meet our legal and other obligations
Within 6 months of project start up
6 monthly
Sydney Metro (or an independent environmental auditor) Audit
EampSMS and compliance with the environmental aspects of contract documentation including Construction Environmental Management Framework
Construction Periodic
to be confirmed
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The Project Environmental Site Representative will be the principal contact for external auditors wishing to audit
the Sitersquos environmental management systems The Project Environmental Site Representative will be responsible
for responding to any external audits findings
Monitoring
Environment monitoring will be undertaken to validate the impacts predicted for the Project The monitoring
requirements for required aspects are included in the relevant environmental management sub-plans (Appendices)
All environmental monitoring equipment shall be maintained and calibrated according to manufacturerrsquos
specifications and appropriate records kept
Where monitoring results are outside of the expected range and are directly attributable to the Project (ie are
influenced by factors under the direct control of the Project eg noise from construction equipment) the process
described below will occur
An analysis of the results by the Environmental Site Representative in more detail with a view of determining possible causes for the non-conformance
A site inspection by the Environmental Site Representative or delegate Advising relevant personnel of the problem Identifying and agreeing on actions to resolve or mitigate the non-conformance Implementing actions to rectify or mitigate the non-conformance
Corrective Actions
Corrective actions identified through hazards inspections incidents auditing will be recorded in Beakon Close out of corrective actions are monitored through Site meetings and reported to senior management through the monthly and quarterly board reports
16 DOCUMENT AND RECORD CONTROL
Georgioursquos Health Safety and Environment Policies Standards Procedures Safe Work Instructions References
Guidelines Forms Templates are all accessible via the Companyrsquos Intranet - GENIE GENIE will maintain the
current and only authorised versions for use
Environment Management documentation that has been specifically developed for the site will be controlled on site
and recorded on the Site Document Register in accordance with the Site Quality Management Plan
The Project Manager is the owner of this plan and will apply change control to ensure the most recent plans are
approved and executed
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17 APPENDICES
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Appendix 1 - Waste Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise spoil generation where possible The project will mandate 100 reuse or recycling (on or off-site) of usable spoil Spoil will be managed with consideration to minimising adverse traffic and transport related issues Spoil will be managed to avoid contamination of land or water Spoil will be managed with consideration of the impacts on residents and other sensitive receivers Site contamination will be effectively managed to limit the potential risk to human health and the environment Minimise waste throughout the project life-cycle Avoidance of unnecessary resource consumption Resource recovery (including reuse reprocessing recycling and energy recovery) and Disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Project Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Training and Competency
As part of the Site Induction workers will be informed of
- The types of waste generated on site
- How the wastes are to be handled stored and disposed of Personnel responsible for clean-up of spills will be provided with instruction on how to use the sites
spill kits Personnel handling hazardous materials will be provided training to read and understand the SDS
Project Manager
Unidentified Waste Wastes that cannot be positively identified (ie unlabelled liquids potential asbestos) will be tested
before handling and disposal Any material that is unknown should be considered hazardous until positively identified
Project Engineer
Handling
Where practicable dust generating rubbish and debris will be removed to minimise dust release into the atmosphere
Handling of waste will be done in accordance with relevant state or local by-laws using suitable personal protective equipment
Project Engineer
Storage
Containers used for storage are not to be opened handled transported or stored in a manner that may rupture the container
All waste will be stored in waste receptacles and removed off site by a licensed contractor on a periodic basis
Dedicated recyclable and hazardous receptacles will be labelled Wastes stored on site will be stored in a manner to prevent the attraction of vermin and native
wildlife Waste is to be stored away from access and egress routes
All
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Appendix 1 - Waste Management Sub Plan Responsibility
The quantity and volume of wastes stored on site may be minimised where reasonably practical to reduce the risk to health safety and the Environment
Project Managers will be responsible for identifying and obtaining any required licenses andor permits to store wastes
Disposal
In deciding how to dispose of waste generated on site consideration will be given to reducing reusing or recycling waste where reasonably practical to minimize the volume sent to landfill Where reuse or recycling is not a feasible option the waste will be sent to a facility capable of accepting the waste
The burning of any type of wastes will not be permitted on any Georgiou site The use of stormwater drains for the disposal of waste is prohibited The disposal of waste will be done in a manner to prevent any damage to the environment
Project Engineer
Transportation
The removal and transportation of hazardous waste controlled waste (eg asbestos hydrocarbons and sewage) for disposal will only be conducted by licensed carriers Licensed operators will be engaged in accordance with the Procurement Procedure
Before a hazardous waste controlled waste is transported off site a waste tracking receipt will be collected from the operator as verification that the waste was correctly transported off site and to identify the proposed location for disposal The receipt will be scanned and filed into the DMS and linked to the Site Waste Register A copy of the receipt will be held for a minimum of 3 years
The transportation of other wastes for disposal will only be conducted if the load is covered or there is no risk of loaddebris falling and the load is disposed of at a registered landfill
Project Manager
Spoil
Although the Project would require the importation of fill material the excess spoil would be generated including from the following sources
Soils ndash This includes any topsoil and natural subsoils (ie soils between the topsoil and underlying bedrock)
Natural rock ndash This material would be generated from excavation of sandstone bed rock if required Road construction material ndash This would include material generated from the demolition of the
existing roads such as asphalt concrete geotechnically stabilised road sub-base and base material
Project Engineer
Spoil Classification
Spoil generated during the Construction of the Project will be firstly assessed for reuse in the project Should it not be suitable for onsite reuse it will be assessed in accordance with the Sydney Metro Classification Procedure (Appendix 1A) It will firstly be assessed against the requirements for Virgin Excavated Natural Material (VENM) detailed within the Protection of the Environment Operations Act 1997(POEO Act)
Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
If the material is not deemed to be VENM an assessment of the suitability of any current general resource recovery exemptions issued under the Protection of the Environment Operations (Waste) Regulation 2014 will be undertaken Current general resource recovery exemptions that may apply to the Project are
The excavated natural material exemption 2014 The excavated public road material exemption 2014 Spoil that cannot be re-used onsite or offsite under any of the exemptions stated above or classified as VENM will require waste classification in accordance with the Waste Classification Guidelines Part 1 Classifying Waste (EPA 2014) prior to offsite disposal at an appropriately licensed facility
The management of spoil generated from the Project will be guided by the hierarchy detailed below
Rank Control Measure Implementation Example Potential to implement on Project
1 Avoid and reduce spoil
generation Reduce the amount of spoil being
generated through design and construction methodology
Limited
2 Prioritise reuse of contaminated
spoil onsite vs clean spoil Identify areas with lower risk of
contamination to spoil offsite as this will result in lower waste disposal costs for project
GSW and Contaminated Spoil is to
be utilised as fill on the project
prior to the use of excavated
sandstoneVENM The project will
produce excess spoil and the
priority is for this excess to be
sandstoneVENM
3 Reuse within Project Prioritise reuse of more contaminated
spoil onsite vs less contaminated spoil Reuse in the Project to fill
embankments and mounds within short haulage distance of source
Restoration of any pre-existing contaminated sites within the Project boundaries
Reuse as a feed product in Construction materials (eg concrete)
Preferred but dependant on area
available
Project Manager Project Engineer Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
4 Reuse for environmental works Reuse in revegetation and
rehabilitation projects Reuse in operational noise mitigation
works
Preferred as stockpiling on site is
restricted
5 Reuse on other development
projects Reuse for fill embankments and
mounds on projects within an economic transport distance from site
Preferred as stockpiling on site is
restricted
6 Reuse for land restoration Reuse for land reclamation or
remediation works Reuse to fill disused facilities eg
mines and quarries to enable ecological rehabilitation or other ecologically beneficial end use
Preferred as stockpiling on site is
restricted
7 Reuse for landfill management Reuse to cap completed landfill cells Reuse in daily covering of landfill
waste
Limited
8 Dispose offsite as waste Disposal of excess spoil as waste at an
approved facility licensed to receive that material
Potential but not preferred
Hazardous Waste - General
Hazardous wastes will be stored in sealed containers where practical and clearly labelled with waste type
Hazardous waste receptacles will be maintained in good condition to prevent leaks or spills Offensive odours should not be generated at any time when stored Hazardous wastes with a significant risk to human health and safety will be stored in containers that
comply with relevant legislation and guidelines Hazardous wastes will not be permitted to accumulate to a level that presents an unreasonable risk
to human health safety or the environment Controlled waste storage will be suitably contained to ensure debris does not travel beyond the boundary of the premise
Hazardous waste will be stored and segregated in accordance with their SDS Hazardous waste will be risk assessed to ensure they do not contaminate or interact with goods that are incompatible Where there may be a risk of fire hazardous waste will be segregated to prevent storage incompatibilities
Hazardous liquid waste will not be permitted to enter the environment
All
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Appendix 1 - Waste Management Sub Plan Responsibility
Design considerations for secondary containment will be given to the storage of liquid wastes to contain any potential spills Hazardous waste will be stored onin bunded palletsareas which will be compliant with AS1940-2004 443 (the bunded palletarea must have the capacity to contain 110 of the largest container
Hazardous waste such as batteries hydrocarbons sewage and asbestos will only be handled for final disposal recycling by certified waste removing contractors Sewage waste not plumbed directly into the main sewerage system will be contained within holding tanks on site compounds and emptied on a periodic basis or as required by a licenced contractor
Hazardous Waste - Batteries
Automotive and lead-based batteries will be stored in a manner that does not contaminate the natural surrounding environment This may include storage on bunded palletsareas on concrete hard stand or on any other sealed surface
All
Hazardous Waste - Asbestos
The disposal processes for asbestos will involve independent competent persons Identified ACM (Asbestos Contaminated Material) will be clearly marked out and controls put in place
to prevent contamination into surrounding areas
Project Manager
Hazardous Waste - Sanitary Sewage Waste
Sewage waste will either be plumbed directly into the main sewerage system or contained within holding tanks on site compounds and emptied as required
Sewage waste stored in bunded tanks underneath the toilets will be emptied by a licensed contractor on a periodic basis
Sanitary wastes will be stored in solid containers and clearly labelled for identification Sanitary wastes will not be re-handled after disposal to minimise the exposure and risk of double
handling Sanitary conveniences will be calculated based on the number of workers based on the site and meet
legislative requirements Sanitary waste will be stored away from food sources or where food is served Controls to prevent offensive odours to the public and workers will be implemented
Project Engineer
Recyclable Waste
On site paper and cardboard and scrap metal will be segregated to be collected and transported to a recycling facility
Green waste will be mulched and stockpiled with topsoil for use in revegetation Aggregate will be segregated during cut and fill operations for re-use
Project Engineer
Waste Water Any waste water or liquids must be disposed of to an approved receptacle and stored within an approved bunded location until they are removed from site
Project Engineer
Putrescible Waste Putrescibles waste will be stored into general waste containers that prevent the release of debris and leachate
Project Engineer
Clinical Waste In the event that clinical waste has been found the following control may be employed Project Engineer
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Appendix 1 - Waste Management Sub Plan Responsibility
Syringes and needles found on site will be stored in a clearly labelled solid sealed container to prevent access to contents They will be disposed of at a licenced provider
Clinical wastes will not be re-handled after disposal to minimise the exposure and risk of double handling
Concrete
Kibbles Concrete truck are to be washed out into a designated bunded area When the concrete is dried it will be disposed of with general waste
At no point will any Concrete truck or kibble be permitted to wash out at any point other than the designated area with all the associated controls in place
Project Engineer
Weekly (VisualDocumented)
DHI Environment to be completed via Beakon HSE Advisor
Reporting HSEQ Monthly Management Meeting Monitor and record the volumes of waste and the methods and locations of disposal Maintain records of all required waste dockets and receipts and provide to Sydney Metro monthly
Project Manager
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Appendix 1A ndash Sydney Metro Waste Classification Procedure
Unclassified
Unclassified
Waste Classification Procedure
SM-20-00040677
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Hugh Chapman Associate Director Environment Operations Customer amp Place-Making
System Owner Carolyn Riley Director Environment Sustainability amp Planning
Status Final
Version 30
Date of issue Pending
Review date Pending
copy Sydney Metro 2020
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 2 of 14
SM-20-00040677 Waste Classification Procedure V30
Table of contents
1 Introduction 3
11 Purpose and scope 3
12 Definitions 3
13 Spoil Management Decision Framework 5
14 Spoil Handling and Segregation 5
15 Typical Application of the Framework 6
16 Unexpected Finds Protocol 7
17 Accountabilities 14
2 Related documents and references 14
3 Superseded documents 14
4 Document history 14
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 3 of 14
SM-20-00040677 Waste Classification Procedure V30
1 Introduction
11 Purpose and scope
This framework describes the approach to classifying spoil and demolition materials generated during works in accordance with environmental legislation and guidelines
This framework considers the reuse of materials on site the beneficial reuse of materials transported off site as waste (for example as virgin excavated natural material [VENM]) the recycling of materials at offsite facilities and the offsite disposal of materials when reuserecycling is not achievable
The framework considers only the compliance and classification elements of the spoil management process and does not consider all of the practical issues associated with construction geotechnical properties of the spoil or market forces and costs that influence the reuse potential of spoil or other wastes
Section 16 of this framework outlines an Unexpected Find Protocol (UFP) to be implemented should unexpected potential contamination be found during works
12 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined within the SM-17-00000203 Sydney Metro glossary Acronyms specific to this document are listed below
Definitions
2014 Waste Regulation
Protection of the Environment Operations (Waste) Regulation 2014
CLM Act Contaminated Land Management Act 1997
Contamination
As defined in the CLM Act ldquomeans the presence in on or under the land of a substance at a concentration above the concentration at which the substance is normally presenthellipin the same localityhellipthat presents a risk of harm to human health or any other aspect of the environmentrdquo
Demolition materials
Materials such as concrete bricks and timber resulting from the demolition of buildings and structures Most demolition materials are pre-classified as General Solid Waste (non-putrescible) (see definition below) under the NSW EPA (2014) Waste Classification Guidelines However some demolition materials such as asbestos have other classifications as described below
EIS Environmental Impact Statement for the project which assesses potential environmental impacts and mitigation measures in accordance with the EPampA Act (see below)
ENM Excavated Natural Material as defined in The excavated natural material order 2014
being excavated material that is at least 98 (by weight) natural material that does not meet the definition of VENM (see below)
EPA NSW Environment Protection Authority
EPampA Act Environmental Planning amp Assessment Act 1979
EPL
Environment Protection Licence as may be held by an owner or operator of a premise licensed to receive process recover or store waste The EPL will contain a number of conditions that must be met by the holder These will specify the type(s) of waste the facility is permitted to receive process recover or store and include pollution prevention or monitoring requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 4 of 14
SM-20-00040677 Waste Classification Procedure V30
Definitions
Fill Soil and any associated extraneous materials (such as demolition wastes industrial by-products and refuse) imported to and placed at the location
GSW
General Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines GSW may be classified as putrescible or non-putrescible depending on the content of putrescible organic material Spoil and demolition materials are typically non-putrescible
HW
Hazardous Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines HW must be treated prior to disposal to landfill HW is typically
spoil that is contaminated with chemicals at concentrations that exceed all screening criteria specified in Step 5 of the Waste Classification Guidelines
Naturally Occurring Soil
Any soil which has not been significantly disturbed by human activities
NEPM National Environmental Protection (Assessment of Site Contamination) Measure 2013
POEO Act Protection of the Environment Operations Act 1997
Recycling Material that is removed from the project site (thereby becoming Waste) and is deposited at an appropriately licenced recycling facility for processing prior to reuse by others
REF Review of Environment Factors which addresses the likely environmental impacts and details protective measures to manage against any adverse effects in accordance with the EPampA Act
Remediation
As defined in the CLM Act remediation of contaminated land includes
(a) preparing a long-term management plan (if any) for the land and
(b) removing dispersing destroying reducing mitigating or containing the contamination of the land and
(c) eliminating or reducing any hazard arising from the contamination of the land (including by preventing the entry of persons or animals on the land)rdquo
Remediation is the act of mitigating exposure to contamination in its original location The process of remediation can generate spoil that may be subject to reuse within the project area (where that reuse is adequately controlled in order to mitigate exposure risks) or the removal of contaminated spoil for treatment andor disposal off site
Reuse offsite
Material to be reused by application to land at a location outside of the project site without the need for processing prior to reuse Material meeting the definition of VENM or ENM or material that is subject to an RRO and RRO are suitable (from an environmental perspective) for reuse at remote sites where all requirements of the POEO Act and CLM Act are met
Reuse onsite
Material that is excavated on the project site and reused on the project site Material to be reused onsite is not defined as Waste and does not require classification in accordance with NSW EPA (2014) Waste Classification Guidelines The material must be suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and must not cause pollution under the POEO Act If transport to another part of the project area requires material to be taken outside the site boundary temporarily this must be undertaken in accordance with the EIS or following consultation with relevant regulators
RRE Resource Recovery Exemption contains the conditions that must be met by consumers of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RRO Resource Recovery Order contains the conditions that must be met by generators and processors of a waste type to allow its exempt reuse as granted by the EPA under the 2014 Waste Regulation
RSW Restricted Solid Waste classified in accordance with the NSW EPA (2014) Waste Classification Guidelines An example of RSW is spoil that is contaminated with chemicals above the criteria specified in Step 5 of the Waste Classification Guidelines
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Definitions
Special Waste
As defined in the NSW EPA (2014) Waste Classification Guidelines a class of waste with
unique regulatory requirements Asbestos or any waste containing asbestos (eg spoil containing any fragments of asbestos cement sheeting) is Special Waste If Special Waste is mixed with RSW or HW (eg spoil classified as RSW that also contains asbestos) then the waste must be managed in accordance with both classifications
Spoil Soil or rock material generated from excavation activities
UFP Unexpected Find Protocol
VENM Virgin Excavated Natural Material as defined in Schedule 1 of the POEO Act being excavated natural material not mixed with any other waste and not from a contaminated area
WARR Act Waste Avoidance and Resource Recovery Act 2001
Waste Spoil or demolition material that has been taken off site which may be classified as Special Waste GSW RSW or HW
13 Spoil Management Decision Framework
Figure 1 provides a high-level flowchart for decisions regarding the fate of spoil generated on the site As reflected in Figure 1 the preferred spoil management hierarchy for the project listed from most preferred to least preferred is as follows
1 Spoil is reused within the project boundary
2 Spoil is beneficially reused at an appropriate offsite location
3 Spoil is recycled at an offsite licenced facility
4 Spoil is disposed to landfill
The approach to spoil classification is further detailed in Table 1 Table 1 describes the criteria information inputs and control measures required to be applied when reusing spoil on site reusing spoil offsite recycling spoil offsite or disposing of spoil
The framework does not account for the practical site based engineering or financial constraints associated with the hierarchy These must be addressed during delivery and the most appropriate efficient and sustainable method of spoil management adopted
14 Spoil Handling and Segregation
Careful excavation handling and segregation of spoil is critical to ensuring that materials with varying classifications are not mixed (cross-contaminated) and are not reused recycled or disposed in a manner inconsistent with their classifications
Appropriate segregation is also important in controlling the costs of spoil disposal to landfill noting that the inadvertent mixing of materials with low concentrations of contaminants with materials containing higher concentrations typically results in a higher classification and higher disposal rate (financial) being applied to all of the materials
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
The following processes are to be applied when excavating handling and segregating all spoil (for clarity a reference to a ldquogeological unitrdquo includes units or different layerstypes of Fill)
Spoil from each geological unit should be classified separately using sampling data that relates only to that unit Classification sampling may be performed in-situ (prior to excavation) or ex-situ (following excavation)
Spoil from each geological unit (as described in Part 4 below) should be excavated segregated and stored separately from spoil arising from other geological units
Excavations should be carefully monitored for visual indications of contamination such as stained soils odorous soils or the presence of anthropogenic waste materials Any spoil containing visual indicators of contamination will be excavated segregated and stored separately from other spoil Where unexpected contamination is identified an appropriate unexpected finds procedure must be implemented to manage potential human health or environmental risk (refer to Part 5)
Each spoil stockpile should be treated as a ldquobatchrdquo with its classification data clearly identifiable and will be handled stored transported and reusedrecycleddisposed as a batch Spoil stockpiles will not be managed in a ldquocontinuousrdquo manner with portions added taken away or mixed over a period of time and
Spoil should be tracked from cradle to grave to ensure a complete and accurate record of movement from the point of excavation to the final point of placement For clarity this includes tracking of spoil movement on the site as well as off the site
Tracking of spoil movement (whether the spoil is waste or not) requires must include written records of spoil excavation handling transport storage and placement via a centralised tracking system Personnel must be suitably trained in the use of the system and sufficient detail must be recorded and retained such that material typesclassifications volumes and location are tracked from the time the material is excavated until it is placed permanently (onsite or offsite) This includes accurate records of any interim handling or placement (such as stockpiling or treatment) Stockpiles onsite are to be clearly labelled at all times Tracking information is to be kept on-site and be available on request
15 Typical Application of the Framework
This section provides some practical guidance in implementing the spoil classification framework (further detailed in the attached Figure 1 and Table 1
An explanation of the likely classification of spoil excavated during works based on typical geological units is provided below
Fill ndash Fill is imported materials which have been placed on the site at some time in the past Fill generally exists at depths ranging up to 3m below ground surface on developed areas and brownfield sites Fill may exist to depths exceeding 20m in reclaimed lands landfill sites former brick pits footings and similar Fill cannot be classified as VENM Fill has an increased likelihood of being contaminated (compared to natural soils) and will predominantly be classifiable for offsite disposal as GSW Special Waste RSW or HW Some materials such as road base or crushed concrete may be recoverable under generic or specific RRERRO arrangements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 7 of 14
SM-20-00040677 Waste Classification Procedure V30
Naturally Occuring Soils ndash Soil which has not been significantly disturbed by human activities Naturally occurring soils may be residual soil sediments aeolian or other In the majority of cases naturally occurring soils will be classifiable as VENM or ENM for offsite reuse However where overlying contamination in Fill has leached and caused contamination of underlying natural soils where point sources of contamination are present (such as industrial facilities or fuel storage facilities) or where significant groundwater contamination has migrated into the area offsite reuse may not be appropriate and other classifications such as GSW RSW or HW may be applicable Where evidence of potential contamination exists spoil is required to be sampled and classified in accordance with NSW EPA (2014) Waste Classification Guidelines
Rock ndash Rock in-situ will in the majority of scenarios be classifiable as VENM or ENM unless significant contamination is present in overlying soils or significant contamination has migrated to the rock within groundwater Where the excavation of rock involves the use of additives (for example to facilitate tunnel boring) the material would no longer be classifiable as VENM or ENM and would instead likely be classifiable as GSW A project specific RRERRO would then be required to allow for offsite reuse
The type of material (ie geological unit) excavated during works will provide guidance on implementing the spoil classification framework in regard to reuse opportunities
Reuse Onsite ndash Any of the material excavated which is Fill a Natural Occurring Soil or Rock may be suitable for reuse on the project site Wherever reuse onsite is to occur the material does not require classification in accordance with the NSW EPA (2014) Waste Classification Guidelines Instead the material must be validated as being suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and the material must not cause pollution under the POEO Act For clarity the classifications GSW RSW and HW have no direct relationship to the potential for reuse of materials on the project site
Reuse Offsite ndash With the exception of Fill it is likely that the majority of spoil will be suitable from an environmental perspective for reuse off-site Specifically all VENM ENM and material to which an RRERRO apply will be suitable (from a legislative and environmental perspective) for reuse at an offsite location
16 Unexpected Finds Protocol
This section provides guidance on implementing the Unexpected Finds Protocol (UFP) which is detailed in the attached Figure 2 The purpose of the UFP is to provide a clear procedure in the event of an unexpected find of contamination or potential contamination The UFP is only to be implemented following an unexpected find The handling of known contamination should already be addressed in construction and environmental management plans
Key indicators of potential contamination include (but are not limited to)
Fibrous cement or other asbestos containing materials
Discolouration of soil
Odours from soil andor groundwater
Buried drums or underground storage tanks and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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SM-20-00040677 Waste Classification Procedure V30
Oily sheen on water
Should any of the above be discovered and is considered to be unexpected then the UFP in Figure 2 will need to be implemented
An explanation of key actions within the UFP is provided below
Notifying the Site Supervisor ndash Site Supervisor or an appropriate delegate are to be made aware of the find immediately
Securing the affected area ndash This includes restricting access to the area and implementing appropriate environmental controls around affected area in minimise risk to the environment and human health Examples of controls include barricading the affected area the diversion of water to minimise potential spread via surface water runoff covering the area re-burying andor wet-down Environmental controls are to be implemented appropriately in regard to the contamination source and site conditions
Emergency Response ndash In the event that the find presents andor creates health or environmental concerns which would require an emergency response call 000 andor implement the projects incident response and reporting process
Notify Principal or Sydney Metro ndash The Principalrsquos Representative and the Environmental Representative must be notified of the unexpected find
Recommence works ndash Works can be recommenced in an alternate area where practicable and where it is safe to do so
Assessment ndash The potential for any ongoing risk to the environment or human health during construction or operation of the site and whether or not the agreed scope appropriately manages the contamination will need to be assessed by a competent and qualified person (ie a contaminated land specialist or in the case of asbestos a hygienist or asbestos assessor)
Material Classification ndash Contaminated materials which are to be removed from the site are to be classified in accordance with the NSW EPA Waste Classification Guidelines and the Spoil Classification Framework detailed in this document See Figure 1 and Table 1
An unexpected find may result in additional works being required for the remediation of contaminated materials which fall outside of the current scope of the project Any such works will need to comply will all relevant legislation and guidelines and will require appropriately qualified persons to prepare the methodology and controls Any such works will require approval from Sydney Metro
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 9 of 14
SM-20-00040677 Waste Classification Procedure V30
Spoil classification process flow
Syd
ne
y M
etr
oN
SW
EP
A W
aste
Gu
ide
line
s C
lassific
ation
ndash P
art
1 (
20
14)
Syd
ne
y M
etr
o
Additional inputs or information requirementsProcess
Is there an opportunity to re-use the spoil
on site
Is there an opportunity to use the spoil at
an offsite locat ion
Can the spoil be recycled
The spoil must be classif ied in accordance with the NSW Environmental Protection Authority (EPA) Waste Classification
Guidelines
1) Is the waste Special Waste ie does the waste contain asbestos Refer to the Protection of the Environment Operations
(POEO) Act and Waste Regulation Part 4 Management of Special Waste
2) Is the waste Liquid Waste
3) Is the waste pre-classified
4) Does the waste have hazardous
characteristics
5) Classify by chemical assessment Waste generators must chemically assess their waste in accordance with Step 5 of the Waste
Classification Guidelines to determine the waste s classification where it has not been classified under Steps 1 to 4 of the Guidelines
Re-use onsite Cost time and engineering requirements to be
considered as well as environmental risks before placement
Re-use offsite To allow offsite use the material mist be classifiable
VENM ENM or be subject to Resource Recovery Exemption and Order
No matter the classification the offsite location must conf irm it can legally
accept the spoil
Recycle offsite The spoil must go to a licenced treatment facility and
must meet the specific requirements of that facilities licence
Liquid waste The waste is not spadable andor becomes free-flowing
at or below 60 degrees Celsius or when it is transported
Pre-classified waste Refer to NSW EPA Waste Classif ication guidelines
for pre-classificat ions of Hazardous Wastes General Solid Waste
Dangerous goods Meets Dangerous Goods Classificat ion for classes 1
2 41 42 43 5 61 and 8
The waste has been classified in accordance with the Waste Guidelines and is ready to be transported offsite Prior to transport
the following must be confirmed and all relevant requirements met
Is the landfill or facility licenced to accept the type of waste
Is the waste subject to waste tracking requirements under the POEO Act or any other regulation
Is the transport contractor licenced to carry the waste as classified
6) Is the waste putrescible
Sampling under Step 5 must meet the requirements of the NSW Waste Classification Guidelines
Sampling can be in-situ (ie prior to excavat ion) or ex-situ (from stockpiles after excavation) but in both
scenarios
Sampling density is to as a minimum meet the sampling densities recommended in the Victorian
EPA soil sampling guidance
httpsrefepavicgovau~mediaPublicationsIWRG702pdf
Analytes must reflect the contaminants of concern likely to be present at the site and as a
minimum consider Asbestos Metals TPH BTEX PAHs and PFAS Other side specific
contaminants may include hexavalent chromium PCBs pesticides etc
If retained onsite the Waste Classif ications Guidelines do not apply BUT the material must be suitable
from a human health and environment perspective to remain This requires assessment against the
NEPM and may include visual inspections or sampling and analysis The input of an appropriately
qualified professional is required prior to the re-use of any fill or potentially contaminated spoil
Once the spoil is removed from the site it becomes Waste All waste must be transported to a facility
that is licenced to accept it VENM ENM andor Resource Recovery ExemptionsOrders impart specific
requirements regarding assessment sampling analysis classificat ion and use of these types of spoil
The requirements regarding sampling and record retention must be adhered to
Once spoil is removed from the site it becomes Waste All Waste must be classified in accordance with
the NSW EPA Waste Classification Guidelines and be transported to a facility licenced to accept it
Note that whether or not the asbestos is present further classif ication is required under Steps 2 to 6 of
the EPA Waste Classification Guidelines
Yes or No
General solid waste restricted waste or hazardous waste
No
Yes
Yes
Yes
Yes or No
Yes
Yes
Yes
No
No
No
No
No
Figure 1 Spoil Classification process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 10 of 14
SM-20-00040677 Waste Classification Procedure V30
Table 1 Spoil Classification process flow
Decision Criteria InputsData ControlsReview
Reuse of the material on or within the approved project area
Most preferred option under WARR Act and Sydney Metro environment and sustainability policy
Suitable placement locations have been identified
The material is suitable for the final land use at the placement location in accordance with EPA guidelines made or approved under the CLM Act and will not cause pollution under the POEO Act
The spoil meets engineering requirements for placement locations
Where spoil or demolition materials require treatment or processing onsite to treat contaminants or to amend engineering properties the need for an EPL must be assessed and resulting conditions met
If transport to another project area is required and such transport requires material to be taken outside the site boundary temporarily this will need to be appropriately address in the projectrsquos environmental approvals (eg EIS or REF)
Appropriate risk-based assessment confirms the material is suitable for proposed final land use from a contamination perspective
Appropriate geotechnical assessment confirms the material is suitable for proposed final land use
EPL if required for onsite processing
Complete material tracking record including documentation of final placement location
Environmental controls to prevent cross-contamination of material prior to placement and pollution during placement
Training of relevant personnel in spoil reuse framework and underlying management plans
Audits of sampling data tracking and placement information and reuse locationssites
Long-term management plan and monitoring andor Environmental Protection Licence under the POEO Act (if required)
Reuse of the material off site
Spoil becomes waste under POEO Act once removed from site
Material meets VENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Assessment confirms material is VENM Sampling may be required depending on nature of material and source
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 11 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Material meets ENM definition
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Sampling conducted in accordance with ENM RRO prior to transport off site and results meet criteria
Statement of RRO compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
Material tracking record from the Metro site to the receival site
Environmental controls to prevent pollution during transport
RRO records maintained for six years including details of sampling plan sampling results quantities supplied and receival sites
Material does not meet VENM or ENM definitions but has potential for reuse under a specific RRORRE An example is tunnel spoil containing additives
Suitable off site reuse locations have been identified and sites have the necessary approvals to accept the material
Consult with the EPA prepare and submit application for specific RRORRE Characterisation data will be required for the application
Once specific RRORRE is granted obtain sampling data (and meet any other specific obligations) in accordance with conditions and confirm results meet criteria prior to transport off site
Statement of compliance provided to each receival site
Receival site provides confirmation that waste can be accepted
Approval under EPampA Act or EPL
Section 143 certificate
Meets RRE conditions
As for reuse on site plus
Statement of compliance provided to each receival site
RRO records maintained for six years
Recycling off site
Material (spoil and demolition materials) becomes waste under POEO Act once removed from site
Material meets the EPL andor planning approval requirements for the receival facility and has value for recycling
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Assessmentsampling confirms the material meets the receival facility EPL conditions (typically GSW)
Appropriate EPL held by receival facility
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 12 of 14
SM-20-00040677 Waste Classification Procedure V30
Decision Criteria InputsData ControlsReview
Disposal off site
Material does not fit one of the above categories andor suitable reuse or recycling locations could not be identified
Least preferred option
Waste is classified as GSW RSW or Special Waste
Suitable receival facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by receival facilities
Receival facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking documentation depending on waste type
Waste is classified as HW
Suitable treatment facilities have been identified and sites have the necessary approvals to accept the material
Pre-classification or sampling results to classify material in accordance with NSW EPA (2014) Waste Classification Guidelines
Appropriate EPL held by treatment facilities
Treatment facility has confirmed waste can be accepted
As for reuse on site plus
Waste tracking treatment and disposal documentation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 13 of 14
SM-20-00040677 Waste Classification Procedure V30
Unexpected find process flow
Flo
w
Process Additional information
Unexpected potential
contamination find1 Immediate ly stop works
2 Notify the Site supervisor 3 Secure the affected area
Is an emergency
response required for any
health or environment
concerns
4b Notify Principal s Rep and
Environmenta l Rep
4a Trigger pro ject incident response and
reporting mechanism andor call 000
5b Inform the
Principal s Rep
Does the
contamination
present and ongoing risk to
environment or human
health dur ing
construction or
operation
Will the
agreed scope result in the
complete removal of the
contamination
Does the
disposal of the unexpected
find result in addi tional costs
to the Principa l
5a Materials to be classified in
accordance with the NSW EPA Waste
Classification Guidel ines (2014) (see
Figure 1 Spoil classification flow)
6a Inform the
Principal s Rep
6b Dispose of the material in
accordance with all relevant legislation
the project Spoil Classification amp
Management Framework and any
relevant directions from Sydney Metro
6c Develop
appropriate
methodology
plans to
manage the
contamination
and implement
Indicators of potentia l
contamination include
Fibre cement or other asbestos
containing materials
Discolouration of the so il
including staining andor
discolouration
Odours from soil or
groundwaterseepage
Bur ied drums and storage tanks
Oily sheen on water
Note this does not include on-
site contamination
Securing of the area should restrict
access to the affected area This
should include as a min imum
environmenta l controls around the
affected area to contain
contaminated material including
diversion of water to minimise
potential spread via surface water
runoff
Where contaminants are likely to
result in odours vapours or
airborne asbestos fibres immediate
action should be taken to prevent
their release (eg cover re-bury or
wet-down
Recommence works in alternate
area where practicable and safe
Assessment to be conducted by
suitably qualified and experienced
person
Methodology controls and p lans
are to be prepared by a sui tab ly
qualified and experienced person
and approved by Sydney Metro
prior to being actioned
Works may continue in the affected
area when it is safe and where
works will not exacerbate
contamination or hinder future
remediation works
Note Remediation of contaminated
materials may include (but not be
limited to) capping of
contaminating treatment andor off-
site disposal All associated
activities with the remediation of
contaminated materials such as
excavation handling stockpiling
and transport are to be addressed
an prepared methodology and
controls
Yes
No
Yes or unsure
No
No or unsure
Yes
Yes
No
Figure 2 Unexpected find process flow
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2020 Unclassified Page 14 of 14
SM-20-00040677 Waste Classification Procedure V30
17 Accountabilities
The Director Program Sustainability Environment amp Planning is accountable for this document including approving the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document
2 Related documents and references
3 Superseded documents
4 Document history
Related documents and references
Entries should be formatted with IMSiCentral number followed by correct title and hyperlinked eg
SM-17-00000203 Sydney Metro glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
02 Pending New IMS document
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Appendix 2- Soil and Water Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise pollution of surface water through appropriate erosion and sediment control Minimise leaks and spills from construction activities Maintain existing water quality of surrounding surface watercourses Source construction water from non-potable sources where feasible and reasonable
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp Targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Erosion and sediment measures would be implemented in accordance with the principles and
requirements in Managing Urban Stormwater ndash Soils and Construction Volume 1 (Landcom 2004) and Volume 2D (NSW Department of Environment Climate Change and Water 2008)
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any significant water aspects and Site specific controls to minimise potential impacts
Emergency Management Team members will be provided training to respond to a discharge of contaminated water or hazardous substances into the environment
Project Manager
Notification The Site will not modify or remove any water utility assets without their approval Notification
of approval will be received by Sydney Water with a copy of authorisation Notification to the asset owner will be given as per their conditions of compliance
Project Engineer
ESCP
ESCPrsquos will be developed by construction staff with demonstrated skills and experience in preparing the ESCP in accordance with the Blue Book Guidelines ESCPrsquos plans will include but not be limited to
Title date and revision number Contours and clean and dirty water drainage paths Site layout including the location of access roads ancillary infrastructure Sediment basins and designated pump out locations Limit of disturbance Location and type of control measures Timing and order of control installation in sequence with work activities Specific construction details
Environmental Site Representative
Erosion and sediment control
The following key principals will apply to all areas and stages of construction on the Project
Minimise extent and duration of disturbance Control stormwater flows onto through and from the site
Project Engineer Supervisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Erosion control strategies to prevent on-site damage Sediment control strategies to prevent off-site damage Progressive stabilisation following completion of work areas Inspection Maintenance and Improvement of control measures throughout the site construction
until the site is successfully stabilised
Dewatering
Sediment laden water accumulated in trenches or excavations must not be discharged directly or indirectly to any stormwater natural watercourse or offsite
A suitable location to discharge will be identified considering site slope proximity to drainage lines soil permeability and ground cover ie well established existing vegetation
The water must be tested prior to any discharge by the Environmental Site Representative and may require treatment prior to discharge
Project Engineer Environmental Site Representative
Groundwater
Groundwater is unlikely to be intercepted during any excavation within the road footprint Deeper excavations for stormwater trenching may intercept groundwater however a method of pipe installation during low tide will removed the need for dewatering
If groundwater dewatering is required then a dewatering management plan should be developed
PlantVehicle Maintenance
The maintenance and cleaning of any vehicles plant or equipment must not be carried out in areas from which contaminants can be released into stormwater or natural watercourses
All
Acid Sulfate Soils
Prior to excavation for the Stormwater trench which will occur approximately 25m bgs testing would be carried out to determine the presence of actual andor potential acid sulfate soils
Testing for the presence of ASS shall be undertaken at proposed excavation locations and shall apply the following methodology Dig holes to the proposed depth of excavation conduct ASS pH field tests on material from the hole at 05m depth intervals and then conduct a SPOCAS plus or chromium suites on the most acidic ASS pH field test sample from the hole The testing and sampling to be undertaken in accordance with ASSMAC Laboratory method Guideline Aug 1998
If actual andor potential acid sulfate soils are present within the proposed area of excavation then an Acid Sulfate Management Plan will be developed in accordance with the Acid Sulfate Soil Manual (Acid Sulfate Soil Management Advisory Committee 1998)
Project Engineer Environmental Site Representative
Water Discharge requirements
An Environmental Protection Licence (EPL) is not required for the project however Georgiou will test any water to be discharged offsite in accordance with the water quality parameters specified in the Blue Book (Landcom 2004) and ANZECCARMCANZ (2000) guidelines prior to discharge to ensure an incident of pollution to surrounding environment does not occur from the Project
Environmental Site Representative
Monitoring of Discharges
Waters released from site must be sampled prior to release The samples taken must be representative of the water being discharged
Project Engineer HSE Advisor
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 2- Soil and Water Management Sub Plan Responsibility
Environmental Inspections amp Monitoring
The results of monitoring shall be recorded Environmental Site Representative
Daily (Visual) and weekly (documented)
Daily visual observation for evidence of water quality impacts including turbidity or hydrocarbon spills
Weekly inspections using Georgiou Beakon inspection form
Supervisor HSE Advisor
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report Dewatering records including all water quality test results
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 46 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Objectives and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise leaks and spills from construction activities All chemicals correctly stored and bunded in accordance with legislative requirements Any spills are controlled contained cleaned up and reported
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General All fuels chemicals and hazardous liquids would be stored in accordance with Australian
standards and EPA Guidelines Any refuelling carried out on-site would be carried out in designated areas only and spill kits would be available as part of any worksite
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required to
manage hydrocarbon and chemical storage and use including
- Use and understanding of safety data sheets (SDS) - Use of personal protective equipment (PPE)
Emergency Management Team members will be provided training to respond to a hazardous substance spill
Project Manager
Register
All dangerous goods or hazardous substances must be approved by HSE Advisor prior to use on the site
ChemAlert will be used to register all site dangerous goods and hazardous substances manage electronic SDS and conduct and record product risk assessments
Consideration will be given to substitute products assessed as a high risk with a product of lesser risk
Project ManagerSupervisor
Transportation Containers holding hazardous substances or dangerous goods will be stored upright and secured
during transport Containers are not to be dropped tip or rolled sides The transportation of dangerous goods will be by licenced carriers
Project Engineer
Handling amp Use
Handling of products will be subject to the following requirements Hazardous substances and dangerous goods will be clearly labelled Current SDS (no older than 5 years) will be readily available when handling Controls stipulated in the SDS to be applied when handling and using Used oily rags oil filters and other left over hydrocarbon and chemical products hall be stored in
a designated area and removed by licensed carriers to either recycle or otherwise dispose of
All
Refuelling Refuelling of plant and vehicles must be monitored continually and conducted in designated areas
away from sensitive receptors
All in field refuelling must have a spill kits available to contain and clean up any spills
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Page 47 of 80
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Spill kits shall be stored in designated amp labelled containers and include a stock control register
All refuelling areas must be signed to prevent smoking or naked flame
Vehicles must be switched off when refuelling and the use of mobile phones prohibited
Fixed refuelling areas must have a plastic lined refuelling area
Fuel storage containers must be of a double bund construction
Site layout
Georgiou will develop a site plan (ie a diagram) showing the location of storage areas spill kit locations muster points firefighting equipment and 1st aid equipment including eye washflush locations
This site plan must be current and displayed at the work site at all times throughout construction
In the event of an emergency that involves the need for emergency services this site plan along with a product manifest must be provided to the emergency services
Project Manager
Storage of Hazardous Materials
Any Dangerous Goods andor Hazardous Substance must be stored in designated areas compliant
with statutory and industry codes of practice
Quantities of hazardous materials should be kept to a minimum commensurate with their usage
and shelf life
Safety Data Sheets of stored hazardous materials will be readily accessible at the place of
storagesite office
Permanent and temporary containers that hold hazardous materials must be labelled with the
appropriate signage
The volume and types of hazardous materials stored must be known current and documented and
must not exceed the design capacity of the storage area
Storage and containment areas (including secondary containment) must be inspected for signs of
loss or damage and any deficiencies must be addressed These areas must be inspected at least
monthly as part of the workplace inspection
Hazardous materials no longer in use must be identified and assessed to determine if they should
be removed from site
Hazardous materials storage areas must be kept clear of combustible material vegetation and refuse by a minimum of three metres
All
SpillEmergency Response
In the event of a spill the following generic procedure must be followed
1 Do not put yourself at risk 2 Notify personnel in the immediate area and remove yourself and others from danger 3 Report ALL SPILLS immediately to the Supervisor and Environmental Site Representative
(report location type and extent of incident)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Once safety has been considered spills should be contained and cleaned up with material from the spill kit All contaminated soil caused by leaks or spills to be disposed of in accordance with legal requirements Any uncontrolled release of hazardous substances which cause actual or threatens potential serious or material environmental harm will be reported to the EPA pollution hotline
Workplace Inspections
Hazardous Materials storage and use will be inspected monthly as part of workplace inspections amp within the DHI Environmental Inspections checklist
Supervisors
Concrete
Designated concrete washout should be constructed and designated to be impermeable and securely fastened
Placed away from waterways drainage lines and stormwater inlets Sufficient storage to handle concrete works occurring onsite When the concrete is dried it will be disposed of with general waste mixed into fill layers (if
approved by client) or recycled At no point will any Concrete truck or kibble be permitted to wash out at any point other than the
designated area with all the associated controls in place (unless approved by the environmental site representative)
Excess concrete should be scraped off equipment prior to washing (allow excess to set and recycle offsite or reuse in fill if itrsquos not contaminated with black plastic)
Set concrete should be removed from the washout to restore storage capacity and prevent overflows
Use of a high pressure low volume water spray nozzle may reduce water use All wastewater must be disposed of in accordance with the project CEMP dewatering conditions
Maintenance of the washout Monitoring and maintenance of concrete washouts is essential to ensure the washout is functional no evidence of damage or wear and tear is evident and that adequate storage capacity remains In addition to daily inspections washout areas should be inspected
During dry weather and
Prior to during and after rainfall and storm events
SupervisorEnvironmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for evidence of spills or poor storage practice with potential to lead environmental incident
Hazardous goods storage area inspection for adequacy of bunding and product loss Weekly inspections using Georgiou Beakon inspection form
All staff
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Page 49 of 80
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CEMP Bays Road Relocation Works
Appendix 3- Hydrocarbon and Chemical Management Sub Plan Responsibility
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 50 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Objectives
and Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on flora and fauna Retain and enhance existing flora and fauna habitat wherever possible Appropriately manage the spread of weeds and plant pathogens
Project Manager
Performance
Criteria
100 compliance with Client amp legal requirements
100 achievement with Site Objectives amp Targets
100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation
Measures
General Vehicles equipment plant materials and personnel are to remain within the designated construction
area at all times and not breach established environmentally sensitive exclusion zones All
Training and
Competency
As part of the Site Induction workers will be informed of the Site specific controls required to minimise potential impacts and protect flora and fauna including - the requirement to work within the designated disturbance zones - requirement to recognise protected flora or fauna species identified to be found on the site - tree protection zones - Specific licence conditions applicable to the Site
Project Manager
Fauna habitat
Prior to clearing pre-clearance surveys are to occur to identify individual trees to be retained and any hollow bearing trees and logs
Where possible clearance should avoid hollow bearing trees Where unavoidable hollow bearing trees should be flagged and left standing at least 24 hours
after clearing all other vegetation Excavator operator to lsquotaprsquo tree prior to felling hollow bearing trees to allow for fauna to escape Ecologist (or similar) to be present onside during clearing of hollow bearing trees to handle any
displaced fauna In the event of injury to fauna WIRES or similar to be contacted and suitable arrangements made
NOTE Handling of any active animal breeding place is only permitted to be conducted by an authorised fauna handler operating under a current permit granted in accordance with legislative requirements
All
Authorisation amp Compliance
Georgiou will not clear vegetation without written permission from the Client local Shire or relevant Regulatory Authority All clearing works under a permit approval or licence will be compliant with the conditions of permit approvals or licence and within the predetermined area
In the event of any unauthorised clearing works will cease immediately and the Project Manager client will be notified Unauthorised clearing of areas will be investigated immediately
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Marking
The Project Engineer will ensure the area to be cleared is clearly marked (eg pegging) and areas of vegetation or trees nominated to be excluded from the clearing works are to be visually identifiable to all personnel involved in the works
The method of marking is to be communicated to all persons involved in the clearing process All control measures are to be communicated to personnel involved in the tasks
All
Flora
Flora that is to be protected will be clearly marked using a method that will not harm or damage A Tree protection Zone (TPZ) is to be established for any trees on a construction site that are to
be protected This is to be fenced off or barricaded to ensure construction activities do not cause damage to the root plate of the tree
Native vegetation should be protected where reasonably possible Large areas that are to be protected from Site works will be demarcated to prevent intrusion and disturbance This requirement is to be communicated to personnel involved within the site area
When the pruning of trees is to be undertaken that are to be protected it will be done by suitably qualified personnel only Where branches are trimmed an assessment of the trees ability to survive should be conducted by a suitably qualified person and adequate area around the tree in accordance with AS49702009 Protection of trees of development sites
Trees should be felled into the construction site or in slots between stands of trees where practical to minimise damage to other trees during the clearing process Machinery contact with standing trees on vegetated margins is to be avoided
The clearing of vegetation outside the construction area will not be permitted except in the event of an emergency or as directed by emergency services
All
Fauna
If fauna are confirmed to be present onsite during clearing clearing works should proceed with care to enable the fauna to relocate freely Clearing is to be conducted in a sequential manner and in a way that encourages escaping wildlife away from the activity into adjacent natural areas and not across roads or into other areas of threat (eg trench)
All
Trenches
All open excavations and trenches will be visually inspected on a daily basis for trapped fauna Surveillance must occur along the entire length of the trench or excavated area and not merely those areas described as fauna habitats or sensitive areas Open trenches are to be checked for fauna immediately prior to backfill and any trapped animals removed by authorised fauna handlers
All
Fauna Handling
Fauna will not be intentionally harmed or maimed under State wildlife protection legislation This includes aquatic and terrestrial fauna (land and air animals)
Workers are not authorised handleto be in possession of native fauna The trapping and handling of fauna in particular dangerous species will only be undertaken by a competent qualified fauna handler
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
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CEMP Bays Road Relocation Works
Appendix 4 - Flora amp Fauna Management Sub Plan Responsibility
Fire Management
Georgiou will not set fire to bush or use spark generating machinery (eg graders) during a prohibited or restricted burning time
If safe to do so Georgiou will extinguish any bush fire within the site boundary and request help from authorities if necessary Fire breaks will be established as requested by authorities
Project Manager
Environmental
Inspections amp
Monitoring
Daily (Visual) and weekly
(documented)
General observation for clearing boundary demarcation Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
Appendix 5 - Cultural Heritage Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise impacts on items or places of heritage value Avoid accidental impacts on heritage items Maximise workerrsquos awareness of indigenous and non-indigenous heritage
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Maintain the integrity of the cultural (European amp Indigenous) aspects of the Site
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of any identified cultural or heritage aspects on the Site and any specific controls to be adhered including - Management practices when working near protected areas - Respecting Heritage Sites - Reporting requirements
Georgiou personnel will participate in the Companyrsquos cross cultural awareness training for employees
Project Manager
Heritage Sites There are s170 heritage listed Glebe Island silos (Port Authority of NSW s170 4560056) that are approximately 5m from the edge of works
Project Engineer
Method statement
In accordance with the REF an Archaeological Work Method Statement would be prepared and implemented where excavation is required The Archaeological Work Method Statement would outline the requirements of archaeological monitoring and recording where archaeological remains of potential local significance may be impacted
Sydney Metro
Unexpected heritage finds
In the event that an artefact or remains are found the Sydney Metro Unexpected Heritage Finds procedure (Appendix 5A) will be followed this includes - The works in that area will cease immediately - The Project Manager and Sydney Metro must be notified - The site must be made secure a buffer zone of ten meters is recommended - Sydney Metro to provide management recommendations
Georgiou will notify all site personnel of the object andor area and proposed treatment of that object andor area as soon as possible but prior to commencing work on the next working day
Works will not continue until written approval has been received from the client
All
discovery of human remains
In the event that human remains are found the Sydney Metro Exhumation Management procedure will be followed (Appendix 5B)
All
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
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CEMP Bays Road Relocation Works
Environmental Inspections amp Monitoring
Building condition inspections Building condition inspections will be undertaken in accordance with REF condition NV3 Sydney Metro
Vibration Monitoring
Continuous vibration monitoring will occur during any vibratory works in close proximity to the Glebe Island silos in accordance with the Sydney Metro Construction Noise and Vibration Standard
Environmental Site Representative
Daily (Visual) and weekly (documented)
General observation for that protection measures and methods are being applied Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
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Appendix 5A ndash Sydney Metro Unexpected Heritage Finds Procedure
Sydney Metro Unexpected
Heritage Finds Procedure [SM-18-00105232]
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final
Version 33
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2018
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Document history
Version Date of approval Notes
11 Incorporates ER comments 210617
12 Amends p13 step 8 reference to s146 added
13 Incorporates Planning Mods 1-4 including amended CoA E20
14 Incorporates ER comments 210318
20 Removes SSI 15-7400 COA reference
30 Revises definition
31 Revises flow chart
32 Revises roles and responsibilities
33 General edits and corrections
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Table of contents
1 Purpose 3
11 Legislation that does not apply 3
2 Scope 4
3 Definitions 4
4 Types of unexpected heritage items and corresponding statutory protections 5
41 Aboriginal objects 5
42 Historic heritage items 6
43 Human skeletal remains 7
5 Legislative Requirements 7
6 Unexpected heritage finds protocol 9
7 Responsibilities 15
8 Seeking Advice 16
9 Related documents and references 16
10 List of appendices 16
11 Document history 17
Appendix 1 Examples of finds encountered during construction works 18
Appendix 2 - Unexpected heritage item recording form 24
Appendix 3 - Photographing unexpected heritage items 26
Appendix 4 - Uncovering bones 29
Appendix 5 - Archaeologicalheritage advice checklist 33
Appendix 6 - Template notification letter 34
Tables
Table 1 Legislation and guidelines for management of unexpected heritage finds 8 Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item 10 Table 3 Roles and Responsibilities 15
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1 Purpose
This procedure is applicable to the Sydney Metro program of works including major projects delivered under Critical State Significant Infrastructure (CSSI) Planning Approvals early CSSI minor and enabling works and works that are subject to the NSW Heritage Act (1977) including s57139 and s60140 exemptions and permit approvals and the National Parks and Wildlife (NPW) Act 1974
This procedure has been prepared for Sydney Metro programs to provide a method for managing unexpected heritage items (both Aboriginal and non-Aboriginal) that are discovered during preconstruction (pre-Construction Heritage Management Plan approval) construction phases (post Construction Heritage Management Plan approval) and for works subject to the NSW Heritage Act (1977)
In NSW there are strict laws to protect and manage heritage objects and relics As a result appropriate heritage management measures need to be implemented to minimise impacts on heritage values ensure compliance with relevant heritage notification and other obligations and to minimise the risk of penalties to individuals Sydney Metro and its contractors This procedure includes Sydney Metrorsquos heritage notification obligations under the Heritage Act NPW Act and the Coronerrsquos Act 2009 and the requirements of the conditions of approval(CoA) issued by NSW Department of Planning Industry and Environment Note that a Contractor must not amend the Sydney Metro Unexpected Finds Procedure or use a different procedure without the prior approval of Sydney Metro
This procedure must be read in conjunction with the relevant CCSI conditions of approval (if applicable) the contract documents and other plans and procedures including the Sydney Metro Exhumation Procedure in addition to any other relevant documents as developed by the contractor during the delivery of the Sydney Metro works
2 Definitions and Abbreviations
An unexpected heritage find is
any unanticipated discovery of an actual or potential heritage item which Sydney Metro does not have approval to disturb andor does not have an existing management process in place
a find that has not been previously identified or assessed
a find that is not referenced in an Archaeological Research Design (ARD) Archaeological Method Statement (AMS) or other project document relating to heritage and archaeology
not covered by an existing approval under the Heritage Act 1977 (Heritage Act) or National Parks and Wildlife Act 1974 (NPW Act)
Note that locally significant areas of historical archaeological potential identified in an Archaeological Method Statement but not identified in an Archaeological Research Design would be managed as an ldquoexpectedrdquo find
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All terminology in this procedure is taken to mean the generally accepted or dictionary definition with the exception of the following terms which have a specifically defined meaning
Definitions
AHIP Aboriginal Heritage Impact Permit
Aboriginal object An Aboriginal object is any deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remains An Aboriginal object may include a shell midden stone tools bones rock art Aboriginal-built fences and stockyards scarred trees and the remains of fringe camps
ARD Archaeological Research Design
AMS Archaeological Method Statement
CEMP Construction Environmental Management Plan
CoA Conditions of Approval
CSSD Critical State Significant Development
CSSI Critical State Significant Infrastructure
EPampA Act NSW Environmental Planning and Assessment Act 1979
Disturbance Disturbance is considered to be any physical interference to an item that results in it
being destroyed defaced damaged harmed impacted or altered in any way (this
includes archaeological investigation activities)
Excavation Director
A person that has been determined by the NSW Heritage Division to meet the Heritage Council of NSWrsquos Criteria for Assessment of Excavation Directors (4 September 2019 and as updated) and can therefore competently archaeologically investigate a site of either local andor state significance
Heritage Act NSW Heritage Act 1977
NPW Act NSW National Parks and Wildlife Act 1974
Heritage NSW Formerly Office of Environment and Heritage (OEH) Now Heritage NSW as part of PNSW Premier and Cabinet
SM Sydney Metro
Relic (non- Aboriginal heritage)
A relic means any deposit artefact object or material evidence that
a) relates to the settlement of the area that comprises NSW not being Aboriginal settlement and
b) is of State or local significance
A relic may include items such as bottles utensils remnants of clothing crockery
personal effects tools machinery and domestic or industrial refuse
TfNSW Transport for New South Wales
Work (non- Aboriginal heritage)
Archaeological features such as historic utilities or buried infrastructure that provide evidence of prior occupations such as former rail or tram tracks timber sleepers kerbing historic road pavement fences culverts historic pavement buried retaining walls cisterns conduits sheds or building foundations but are also subject to assessment by the Excavation Director to determine its classification
Unclassified
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21 Legislation that does not apply
The following authorisations are not required for Sydney Metro approved Critical State Significant Infrastructure (and accordingly the provisions of any Act that prohibits an activity without such an authority do not apply)
Division 8 of Part 6 of the Heritage Act 1977 does not apply to prevent or interfere with the carrying out of approved State significant infrastructure
An approval under Part 4 or an excavation permit under section 139 of the Heritage Act 1977 and
An Aboriginal heritage impact permit under section 90 of the National Parks and Wildlife Act 1974
This document provides relevant background information in Section 4 followed by the technical procedure in Sections 6 and 7 Associated guidance referred to in the procedure can be found in Appendices 1-6
3 Scope
Even with early investigations unexpected finds may still occur during works on a Sydney Metro site When this happens this procedure must be followed This procedure provides direction on when to stop work where to seek technical advice how to notify the regulator if required and when works can recommence This procedure applies to the discovery of any unexpected heritage item relic or object where the find is not anticipated in an approved ARD or AMS or other project specific document related to archaeology
This procedure must be followed by all Sydney Metro staff contractors subcontractors or any person undertaking works for Sydney Metro It includes references to some of the relevant legislative and regulatory requirements but is not intended to replace them This procedure does not apply to
the discovery and disturbance of heritage items as a result of investigations being undertaken in accordance with the Code of Practice for Archaeological Investigations of Aboriginal Objects in NSW4376 20101 an Aboriginal Heritage Impact Permit (AHIP) issued under the NPW Act or a permit approval issued under the Heritage Act
the discovery and disturbance of heritage items as a result of construction related activities where the disturbance is permissible in accordance with an AHIP or an approval issued under the Heritage Act or CSSI CSSD planning approval or
locally significant non-Aboriginal archaeology identified in an AMS and not in an ARD
1 An act carried out in accordance with the Code of Practice for Archaeological Investigation of Aboriginal Objects
in NSW as published by the Department in the Gazette on 24 September 2010 is excluded from the definition of harm an object or place in section 5 (1) of the NPW Act
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4 Types of unexpected heritage finds and corresponding statutory protections
Project field and environmental personnel (including construction contractors) are critical to the early identification and protection of unexpected finds
Appendix 1 illustrates the wide range of heritage items uncovered to date during Sydney Metro projects and gives an indicative guide to what unexpected finds may look like
These discoveries are categorised as either
(a) Aboriginal objects
(b) Historic (non-Aboriginal) heritage items or
(c) Human skeletal remains
The relevant legislation that applies to each of these categories is described below
41 Aboriginal objects
The NPW Act protects Aboriginal objects which are defined as
ldquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrdquo2
Examples of Aboriginal objects include stone tool artefacts shell middens axe grinding grooves pigment or engraved rock art burials and scarred trees
42 Historic heritage items
Historic (non-Aboriginal) heritage items may include
Archaeological lsquorelicsrsquo or
Other historic items (ie works structures buildings or movable objects)
2 Section 5(1) NPW Act 3 This is required under section 89(A) of the NPW Act and applies to all Sydney Metro projects
IMPORTANT
All Aboriginal objects regardless of significance are protected under law
If any impact is expected to an Aboriginal object an AHIP is usually required from Heritage NSW When a person becomes aware of an Aboriginal object they must notify the Director-
General of Heritage NSW about its location3 Assistance on how to do this is provided in Section 7 (Step 5)
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421 Archaeological relics
The Heritage Act protects relics which are defined as ldquoany deposit artefact object or material evidence that relates to the settlement of the area that comprises NSW not being Aboriginal settlement and is of State or local heritage significancerdquo4
Relics are archaeological items of local or state significance which may relate to past domestic industrial or agricultural activities in NSW and can include bottles remnants of clothing pottery building materials and general refuse
422 Other historic items
Some historic heritage items are not considered to be lsquorelicsrsquo but are instead referred to as works buildings structures or movable objects Examples of these items that may be encountered include culverts historic pavements retaining walls tramlines rail tracks turn tables timber sleepers cisterns fences sheds buildings and conduits Although an approval under the Heritage Act may not be required to disturb these items their discovery must be managed in accordance with this procedure
Usually archaeological relics are uncovered via a process of excavation or soil removal When an unexpected find is uncovered an archaeological excavation permit under section 140 or section 60 of the Heritage Act may be required to further investigate or remove it if investigation is not covered by an existing approval In contrast lsquoother historic itemsrsquo either exist above the ground surface (for example a shed) or they are designed to operate and exist beneath the ground surface (for example a culvert)They may also need a permit to alter disturb or remove them if there is not an approval already in place
4 Section 4(1) Heritage Act
5 This is required under section 146 of the Heritage Act and applies to all Sydney Metro projects
IMPORTANT
All relics are subject to statutory controls and protections
If a relic is likely to be disturbed a heritage approval is usually required from the NSW Heritage Council When a person discovers a relic they must notify the NSW Heritage
Council of its location5
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43 Human skeletal remains
The Sydney Metro Exhumation Procedure provides a more detailed explanation of the approval processes related to human remains
Human skeletal remains can be identified as either an Aboriginal object or non-Aboriginal relic depending on the ancestry of the individual (Aboriginal or non-Aboriginal) and the burial context (archaeological or non-archaeological) Remains are considered to be archaeological when the time elapsed since death is suspected of being 100 years or more Depending on ancestry and context different legislation applies
As a simple example a pre-European settlement archaeological Aboriginal burial would be protected under the NPW Act while a historic (non-Aboriginal) archaeological burial within a cemetery would be protected under the Heritage Act For a non-Aboriginal archaeological burial the relevant heritage approval and notification requirement described in Appendix 4 would apply In addition to the NPW Act finding Aboriginal human remains also triggers notification requirements to the Commonwealth Minister for the Environment under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
Where it is suspected that less than 100 years has elapsed since death the human skeletal remains come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such cases are lsquoreportable deathsrsquo and under legal notification obligations set out in section 35(2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (whether Aboriginal or non-Aboriginal remains) Public health controls may also apply6
Guidance on what to do when suspected human remains are found is provided in Appendix 5
IMPORTANT
All human skeletal remains are subject to statutory controls and protections
All bones must be treated as potential human skeletal remains and work around them must stop while they are appropriately protected and investigated the relevant authorities advised and approvals received This includes skeletal material found during any phase of work including
geotechnical works early works construction works and any other site works
6 Under section 19 of the Coroners Act 2009 the coroner has no jurisdiction to conduct an inquest into reportable
death unless it appears to the coroner that (or that there is reasonable cause to suspect that) the death or suspected death occurred within the last 100 years
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5 Legislative Requirements Table 1 identifies some of the relevant legislationregulations for the protection of heritage and the management of unexpected heritage finds in NSW It should be noted that significant penalties exist for breaches of the legislation which result in unauthorised impacts to heritage items
To avoid breaches of legislation it is important that Sydney Metro and its contractors are aware of their statutory obligations under relevant legislation and that appropriate control measures are in place to ensure that unexpected finds are appropriately managed during all project phases Contractors will need to ensure that they undertake their own due diligence to identify any other legislative requirements that may apply for a given project
Table 1 Legislation and guidelines for management of unexpected heritage finds
Relevant Requirement Objectives and offences
Environmental Planning and Assessment Act 1979 (EPampA Act)
Part 5 Division 52 Subdivision 2 Section 519
Requires heritage to be considered within the environmental impact assessment of projects
Heritage Act 1977 (Heritage Act)
The Heritage Act provides for the care protection and management of heritage items in NSW Under section 139 it is an offence to disturb or excavate any land knowing or having reasonable cause to suspect that the disturbance or excavation will or is likely to result in a relic being discovered exposed moved damaged or destroyed unless the disturbance or excavation is carried out in accordance with an excavation permit issued by the Heritage NSW under the Act a relic is defined as lsquoany deposit artefact object or material evidence that (a) relates to the settlement of the area that comprises New South Wales not being Aboriginal settlement and (b) is of State or local heritage significancersquo
A person must notify the Heritage NSW if a person is aware or believes that they have discovered or located a relic (section 146) Penalties for offences under the Heritage Act can include six months imprisonment andor a fine of up to $11million
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Relevant Requirement Objectives and offences
National Parks and Wildlife Act 1974 (NPW Act)
The NPW Act provides the basis for the care protection and management of Aboriginal objects and places in NSW
An Aboriginal object is defined as lsquoany deposit object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction and includes Aboriginal remainsrsquo
An lsquoAboriginal placersquo is an area declared by the Minister administering the Act to be of special significance with respect to Aboriginal culture An Aboriginal place does not have to contain physical evidence of occupation (such as Aboriginal objects)
Under section 87 of the Act it is an offence to harm or desecrate an Aboriginal object or place There are strict liability offences An offence cannot be upheld where the harm or desecration was authorised by an AHIP and the permitrsquos conditions were not contravened Defences and exemptions to the offence of harming an Aboriginal object or Aboriginal place are provided in section 87 87A and 87B of the Act A person must notify Heritage NSW if a person is aware of the location of an Aboriginal object
Penalties for some of the offences can include two years imprisonment andor up to $550000 (for individuals) and a maximum penalty of $11 million (for corporations)
6 Unexpected heritage finds protocol
61 What is an unexpected heritage find
An lsquounexpected heritage findrsquo can be defined as any unanticipated archaeological discovery that has not been identified during a previous assessment or is not covered by an existing permit under the Heritage Act The find may have potential cultural heritage value which may require a heritage permit or notification if any interference of the heritage item is proposed or anticipated
The range of potential unexpected finds can include but is not limited to
remains of rail infrastructure including buildings footings stations signal boxes rail lines bridges and culverts
remains of other infrastructure including sandstone or brick buildings wells cisterns drainage services conduits old kerbing and pavement former road surfaces timber and stone culverts bridge footings and retaining walls
artefact scatters including clustering of broken and complete bottles glass ceramics animal bones and clay pipes and
archaeological human skeletal remains
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62 Managing unexpected finds
In the event that an unexpected find is encountered on a Sydney Metro site the steps detailed in Table 2 must be followed There are seven steps in the procedure
Table 2 Specific tasks to be implemented following the discovery of an unexpected heritage item
Step Task Responsibility Guidance and tools
1 Stop work and protect the item
11 Stop all work including geotechnical investigations in the immediate area of the item and notify the Project Manager
Contractor Supervisor
Appendix 1
Identifying Unexpected Heritage items
12 Establish a lsquono-go zonersquo around the item Use high visibility fencing where practical No work is to be undertaken within this zone until further investigations are completed and if required appropriate approvals are obtained
Inform all site personnel about the no-go zone
Project Manager Contractor Supervisor
2 Engage an Archaeologist
21 If you have Excavation Director or an archaeologist andor Aboriginal heritage consultant has been previously appointed for the project contact them to discuss the location and nature of the item and arrange a site inspection The project Construction Environmental Management Plan (CEMP) may contain contact details of the archaeologistAboriginal heritage consultant
Provide as much information as possible including photos and completed recording form
Inform the Sydney Metro Environmental Manager and keep them involved in the process The Environmental Manager will inform the Sydney Metro Senior Heritage Advisor
Contractors Project Manager
Appendix 2
Unexpected Heritage Item Recording Form
22 Where there is no project archaeologist engaged for the works engage a suitably qualified consultant to assess the find
If the find is a non-Aboriginal item engage a suitably qualified and experienced historical archaeological consultant
If the find is likely to be an Aboriginal object engage an Aboriginal heritage consultant
Contractorrsquos Project Manager
IMPORTANT
Sydney Metro may have approval to impact certain heritage items during construction If you think that you may have discovered a heritage item and you are unsure whether an
approval is in place or not STOP works and follow this procedure
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Step Task Responsibility Guidance and tools
23 ArchaeologistExcavation Director and Sydney Metro Environmental Manager to advise the Project Manager whether Sydney Metro has approval to impact the lsquoitemrsquo
If yes work may recommence in accordance with that approval or permit There is no further requirement to follow this procedure
If no continue to next step
Contractorrsquos Project Manager
3 Arrange site access
31 Arrange site access for the archaeologistAboriginal heritage consultant to inspect the item as soon as practicable In most cases a site inspection is required to conduct a preliminary assessment
Contractorrsquo s Project Manager Excavation Director
32 Subject to the archaeologistAboriginal heritage consultantrsquos assessment work may recommence at a set distance from the item This is to protect any other archaeological material that may exist in the vicinity which may have not yet been uncovered Existing protective fencing established in Step 12 may need to be adjusted to reflect the extent of the newly assessed protective area No works are to take place within this area once established
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
33 Occasionally the archaeologistAboriginal heritage consultant may determine from the photographs provided at Step 21 that no site inspection is required because no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo a lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Archaeologist Aboriginal heritage consultant Excavation Director
Proceed to Step 8
4 Undertake Preliminary assessment and recording of the find
41 Has the lsquofindrsquo been damaged or harmed
If yes record the incident in the Incident
Management System Implement any additional reporting requirements related to the planning approval and CEMP where relevant
Contractors Project Manager Archaeologist and or Excavation Director
42 Can the works avoid further disturbance to the item Project Manager to confirm with Sydney Metro Environment Manager
Complete the remaining tasks
Contractorrsquos Project Manager
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Step Task Responsibility Guidance and tools
43 Inspect document and photograph the item Archaeologist and or Excavation Director
Appendix 2
Unexpected Heritage Item Recording Form
Appendix 3
Photographing Unexpected Heritage items
44 Is the item likely to be bone
If yes follow the steps in Appendix 4 ndash lsquoUncovering bonesrsquo Where it is obvious that the bones are human remains you must notify the local police by telephone immediately They may take command of all or part of the site Also refer to the Sydney Metro Exhumation Procedure
If no proceed to next step
Archaeologist and or Excavation Director
Appendix 4
Uncovering Bones
45 The archaeologistAboriginal heritage consultant may provide advice after the site inspection and preliminary assessment that no heritage constraint exists for the project (for example the item is not a lsquorelicrsquo or a lsquoheritage itemrsquo or an lsquoAboriginal itemrsquo) Any such advice should be provided in writing (for example via email or letter with the consultantrsquos name and company details clearly identifiable) to the Metro Project Manager
Archaeologist Aboriginal heritage consultant Contractorrsquos Project Manager Excavation Director
Proceed to Step 7
Refer to Appendix 1
Examples of finds encountered during construction worksrsquo
46 Where required seek additional specialist technical advice (such as a forensic or physical anthropologist to identify skeletal remains) The archaeologistAboriginal heritage consultant can provide contacts for such specialist consultants
Excavation Director Archaeologist
47 Where the item has been identified as a lsquorelicrsquo or lsquoheritage itemrsquo or an lsquoAboriginal objectrsquo the archaeologist should formally record it
Archaeologist Aboriginal heritage consultant
48 NSW Heritage for non-Aboriginal relics and NSW Department of Planning Industry and Environment for Aboriginal objects can be notified informally by telephone at this stage by the Sydney Metro Senior Heritage Advisor Any verbal conversations with regulators must be noted on the project file for future reference
Contractors Project Manager Excavation Director
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Unclassified
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Step Task Responsibility Guidance and tools
5 Notify the regulator if required
51 Based on the findings of the archaeological or heritage management plan and corresponding legislative requirements is notification of Heritage NSW and the Secretary required
If no proceed directly to Step 6
If yes proceed to next step
Sydney Metro Environmental Manager Contractorrsquos Excavation Director
52 If notification is required complete the template notification letter including the archaeological heritage management plan and other relevant supporting information and forward to the Sydney Metro Environmental Manager The Environmental Manager will seek the approval of the Sydney Metro Senior Heritage Advisor and the signature of the Principal Manager Sustainability Environment and Planning (Program)
Sydney Metro Environmental Manager Excavation Director
Appendix 6
Template Notification Letter
53 Forward the signed notification letter to Heritage NSW and the Secretary
Informal notification (via a phone call or email) to Heritage NSW prior to sending the letter is appropriate The archaeological or heritage management plan and the completed Unexpected Heritage Item Recording Form (Appendix 2) must be submitted with the notification letter (for both Aboriginal objects and non-Aboriginal relics)
The Department of Planning Industry and Environment may also need to be notified
54 A copy of the final signed notification letter archaeological or heritage management plan and the site recording form is to be kept on file and a copy sent to the Sydney Metro Project Manager
Contractorrsquos Project Manager Excavation Director
6 Implement archaeological or heritage management plan
61 Modify the archaeological or heritage management plan to take into account any additional advice resulting from notification and discussions with regulator
Contractorrsquos Project Manager Excavation Director
62 Implement the archaeological or heritage management plan Where impact is expected this may include a formal assessment of significance and heritage impact assessment preparation of excavation or recording methodologies consultation with Registered Aboriginal Parties obtaining heritage approvals etc if required
Contractorrsquos Project Manager Excavation Director
63 Where heritage approval is required contact the Sydney Metro Environment Manager for further advice and support material Please note there are time constraints associated with heritage approval preparation and processing
Contractorrsquos Project Manager Excavation Director
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Unclassified
Sydney Metro ndash Integrated Management System (IMS)
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64 Assess whether heritage impact is consistent with the project approval or if project approval modification is required from the Department of Planning Industry and Environment
Excavation Director Sydney Metro Environmental Manager
65 Where statutory approvals (or project approval modifications) are required impact upon relics andor Aboriginal objects must not occur until heritage approvals are issued by the appropriate regulator
Contractorrsquos Project Manager Excavation Director
66 Where statutory approval is not required but where recording is recommended by the archaeologistAboriginal heritage consultant sufficient time must be allowed for this to occur
Contractorrsquos Project Manager Excavation Director
67 Ensure short term and permanent storage locations are identified for archaeological material or other heritage material removed from site where required Interested third parties (for example museums local Aboriginal land councils or local councils) should be consulted on this issue Contact the archaeologist or Aboriginal heritage consultant for advice on this matter if required
Contractorrsquos Project Manager Excavation Director
7 Resume work
71 Seek written clearance to resume project work from the project Excavation Director Archaeologist Aboriginal heritage consultant
Clearance would only be given once all archaeological excavation andor heritage recommendations and approvals (where required) are complete Resumption of project work must be in accordance with the all relevant projectheritage approvalsdeterminations
Contractorrsquos Project Manager Excavation Director
72 If required ensure archaeological excavationheritage reporting and other heritage approval conditions are completed in the required timeframes This includes artefact retention repositories conservation andor disposal strategies
Contractorrsquos Project Manager Excavation Director
73 If additional unexpected items are discovered this procedure must begin again from Step 1
All
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Sydney Metro ndash Integrated Management System (IMS)
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7 Responsibilities
Table 3 Roles and Responsibilities
Role Responsibility or role under this guideline
Contractor Supervisor
Stop work immediately when an unexpected heritage find is encountered Cordon off area until Environmental Manager Excavation Director advises that work can recommence
Manage the process of identifying protecting and mitigating impacts on the lsquofindrsquo
Liaise with Sydney Metro Project Manager Environment Manager and Senior Heritage Advisor
Assist the archaeologistAboriginal heritage consultant with mitigation and regulatory requirements
Complete Incident Report and review CEMP for any changes required Propose amendments to the CEMP if any changes are required
Contractors Project Manager
Ensures all aspects of this procedure are implemented Advise Contractor Supervisor to recommence work if all applicable requirements have been satisfied and the Excavation Director
Project Archaeologist has approved recommend of work
Contractorrsquos or Project Heritage Advisor or Consultant
Provide expert advice to the Sydney Metro Environment Manager on find identification significance mitigation legislative procedures and regulatory requirements
Environmental Representative
Ensure compliance with relevant approvals (new and existing)
Sydney Metro Environment Manager
Notify the Sydney Metro Principal Manager Environmental Management of find and manage Incident Reporting once completed by Environmental Manager
Sydney Metro Senior Heritage Advisor
Provide expert advice to Sydney Metro Environment Manager and project as required
8 Seeking Advice
Advice on this procedure should be sought from the Sydney Metro Environment Manager in the first instance Contractors and delivery partners should ensure their own project environment managers are aware of and understand this procedure
Technical archaeological or heritage advice regarding an unexpected heritage item should be sought from a suitably qualified and experienced archaeologistAboriginal heritage consultant
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9 Related documents and references
Sydney Metro Environmental Incident Classification and Reporting ndash SM-17-00000096
Transport for NSW Guide to Environmental Control Map ndash 3TP-SD-01570
NSW Heritage Office (1998) Skeletal remains guidelines for the management of human skeletal remains
Roads and Maritime Services (2015) Standard Management Procedure Unexpected Heritage Items
Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal remains
Sydney Metro Exhumation Procedure ndash SM ES-PW-31510
10 List of appendices
The following appendices are included to support this procedure
Appendix 1 Examples of finds encountered during construction works
Appendix 2 Unexpected Heritage Item Recording Form
Appendix 3 Photographing Unexpected Heritage Items
Appendix 4 Uncovering Bones
Appendix 5 Archaeological Advice Checklist
Appendix 6 Template Notification Letter
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Appendix 1 Examples of finds encountered during construction works
Photo 1 - Aboriginal artefacts found at the Wickham Transport Interchange 2015
Photo 2 ndash Aboriginal artefacts (shell material) found at the Wickham Transport Interchange 2015
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Photo 3 1840s seawall and 1880s retaining wall uncovered at Balmain East 2016
Photo 4 Sandstone pavers uncovered at Balmain East 2016
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Photo 5 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 6 - Platform structure at Hamilton Railway Station classified as a lsquoworkrsquo by the project archaeologist - Wickham Transport Interchange project 2015
Photo 7 - Sandstone flagging and cesspit - Wynyard Walk project 2014
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Photo 8 - Chinese Ming Dynasty pottery and English porcelainpottery dating back to early 19th century - Wynyard Walk project 2014
Photo 9 - Pottery made by convict potter Thomas Ball during the early settlement - Wynyard Walk project 2014
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The following images obtained from the Roads and Maritime Servicesrsquo Standard Management Procedure for Unexpected Heritage items 2015 can be used to assist in the preliminary identification of potential unexpected items during construction and maintenance works Photo 10 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones (Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights Newcastle area) (RMS 2015)
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Photo 11 - Top left hand picture continuing clockwise Stock camp remnants (Hume Highway Bypass at
Tarcutta) Linear archaeological feature with post holes (Hume Highway Duplication) Animal bones
(Hume Highway Bypass at Woomargama) Cut wooden stake Glass jars bottles spoon and fork
recovered from refuse pit associated with a Newcastle Hotel (Pacific Highway Adamstown Heights
Newcastle area) (RMS 2015)
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Appendix 2 - Unexpected Heritage Find Recording Form
Example of unexpected heritage item recording form
This form is to be completed Excavation Director on the discovery of an archaeological heritage find during construction or maintenance works
Date Recorded by
(include name and position)
Project name
Description of works
being undertaken
Description of exact
location of item
Description of item
found
(What type of item is it likely
to be Tick the relevant
boxes)
A A relic A lsquorelicrsquo is evidence of a past human activity
relating to the settlement of NSW with local
or state heritage significance A relic might
include bottle utensils plates cups
household items tools implements and
similar items
B A lsquoworkrsquo building or
structurersquo A lsquoworkrsquo can generally be defined as a form
infrastructure such as track or rail tracks
timber sleepers a culvert road base a
bridge pier kerbing and similar items
C An Aboriginal object An lsquoAboriginal objectrsquo may include stone
tools stone flakes shell middens rock art
scarred trees and human bones
D Bone Bones can either be human or animal
remains
Remember that you must contact the local
police immediately by telephone if you are
certain that the bone(s) are human
remains
E Other
Provide a short
description of the item
(Eg metal rail tracks
running parallel to the rail
corridor Good condition
Tracks set in concrete
approximately 10 cm below
the current ground surface)
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Sketch
(Provide a sketch of the
itemrsquos general location in
relation to other road
features so its approximate
location can be mapped
without having to re-
excavate it In addition
please include details of the
location and direction of any
photographs of the item
taken)
Action taken (Tick either
A or B)
A Unexpected item
would not be further
impacts on by the
works
Describe how works would avoid impact
on the item (Eg the rail tracks would be left in
situ and recovered with paving)
B Unexpected item
would be further
impacted by the works
Describe how works would impact on the
item (Eg milling is required to be continued to a
depth of 200 mm depth to ensure the pavement
requirements are met Rail tracks would need to
be removed)
Excavation Director Signature
Signature
It is a statutory offence to disturb Aboriginal objects and historic relics (including human
remains) without an approval All works affecting objects and relics must cease until an
approval is sought
Approvals may also be required to impact on certain works
Important
Unclassified
Appendix 3 - Photographing unexpected heritage finds
Photographs of unexpected finds in their current context (in situ) may assist archaeologistsAboriginal heritage consultants to better identify the heritage values of the item Emailing good quality photographs to specialists can allow for better quality and faster heritage advice The key elements that must be captured in photographs of the item include its position the item itself and any distinguishing features All photographs must have a scale (ruler scale bar mobile phone coin etc) and a note describing the direction of the photograph
Context and detailed photographs
It is important to take a general photograph (Figure 1) to convey the location and setting of the item This will add value to the subsequent detailed photographs also required (Figure 2)
Figure 1 Telford road uncovered on the Great Western Highway (Leura) in 2008 (RMS 2015)
Photographing distinguishing features
Where unexpected items have a distinguishing feature close up detailed photographs must be taken of these features where practicable In the case of a building or bridge this may include diagnostic details architectural or technical features See Figures 3 and 4 for examples
Unclassified
Removal of the item from its context (eg excavating from the ground) for
photographic purposes is not permitted
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Photographing bones
The majority of bones found on site will be animal bones often requiring no further assessment (unless they are in archaeological context) However if bones are human the police must be contacted immediately (see Appendix 5 for detailed guidance) Taking quality photographs of the bones can often resolve this issue quickly The project archaeologist can confirm if bones are human or non-human if provided with appropriate photographs
Ensure that photographs of bones are not concealed by foliage (Figure 5) as this makes it difficult to identify Minor hand removal of foliage can be undertaken as long as disturbance of the bone does not occur Excavation of the ground to remove bone(s) should not occur nor should they be pulled out of the ground if partially exposed
Where sediment (adhering to a bone found on the ground surface) conceals portions of a bone (Figure 6) ensure the photograph is taken of the bone (if any) that is not concealed by sediment
Ensure that all close up photographs include the whole bone and then specific details of the bone (especially the ends of long bones the epiphysis which is critical for species identification) Figures 7 and 8 are examples of good photographs of bones that can easily
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be identified from the photograph alone They show sufficient detail of the complete bone and the epiphysis
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Appendix 4 - Uncovering bones
This appendix provides advice regarding
what to do on first discovering bones
the range of human skeletal notification pathways and
additional considerations and requirements when managing the discovery of human remains
1 First uncovering bones
Refer to the Sydney Metro Exhumation Procedure
Stop all work in the vicinity of the find All bones uncovered during project works should be treated with care and urgency as they have the potential to be human remains The bones must be identified as either human or non-human as soon as possible by a qualified forensic or physical anthropologist
On the very rare occasion where it is immediately obvious from the remains that they are human the Project Manager (or a delegate) should inform the police by telephone prior to seeking specialist advice It will be obvious that it is human skeletal remains where there is no doubt as demonstrated by the example in Figure 17 Often skeletal elements in isolation (such as a skull) can also clearly be identified as human Note it may also be obvious that human remains have been uncovered when soft tissue andor clothing are present
7
After Department of Environment and Conservation NSW (2006) Manual for the identification of Aboriginal
Remains 17
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This preliminary phone call is to let the police know that a specialist skeletal assessment to determine the approximate date of death which will inform legal jurisdiction The police may wish to take control of the site at this stage If not a forensic or physical anthropologist must be requested to make an on-site assessment of the skeletal remains
Where it is not immediately obvious that the bones are human (in the majority of cases illustrated by Figure 2) specialist assessment is required to identify the bones Photographs of the bones can assist this assessment if they are clear and taken in accordance with guidance provided in Appendix 3 Good photographs often result in the bones being identified by a specialist without requiring a site visit noting they are nearly always non-human In these cases non-human skeletal remains must be treated like any other unexpected archaeological find
If the bones are identified as human (either by photographs or an on-site inspection) a technical specialist must determine the likely ancestry (Aboriginal or non-Aboriginal) and burial context (archaeological or forensic) This assessment is required to identify the legal regulator of the human remains so urgent notification (as below) can occur
Preliminary telephone or verbal notification by the archaeologist to the Sydney Metro Senior Heritage Advisor is appropriate This must be followed up later by a formal letter notification to the relevant regulator when a management plan has been developed and agreed to by the relevant parties
2 Range of human skeletal notification pathways
The following is a summary of the different notification pathways required for human skeletal remains depending on the preliminary skeletal assessment of ancestry and burial context
A Human bones are from a recently deceased person (less than 100 years old)
B Human bones are archaeological in nature (more than 100 years old) and are likely to be Aboriginal remains
C Human bones are archaeological in nature (more than 100 years old) and likely to be non-Aboriginal remains
Figure 3 summarises the notification pathways on finding bones
Action
The Heritage NSW must be notified immediately
Action
The police must be notified immediately as per the obligations to report a death or suspected death under s35 of the Coroners Act 2009 (NSW) It should be assumed the police will then take command of the site until otherwise directed
Action
The Department of Planning Industry and Environment Aboriginal Heritage Section must be notified immediately The project Aboriginal Cultural Heritage Advisor must contact and inform the relevant Aboriginal community stakeholders who may request to be present on site
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Figure 3 Overview of steps to be undertaken on the discovery of bones
After the appropriate verbal notifications (as described in 2B and 2C above) the Project Manager must proceed through the Unexpected Heritage Items Exhumation Procedure (Step 4) It is noted that no Exhumation Procedure is required for forensic cases (2A) as all future management is a police matter Non-human skeletal remains must be treated like any other unexpected archaeological find and so must proceed to record the find
3 Additional considerations and requirements
Uncovering archaeological human remains must be managed intensively and needs to consider a number of additional specific issues These issues might include facilitating culturally appropriate processes when dealing with Aboriginal remains (such as repatriation and cultural ceremonies) Project Managers may need to consider overnight site security of any exposed remains and may need to manage the onsite attendance of a number of different external stakeholders during assessment andor investigation of remains
Project Managers may also be advised to liaise with local churchreligious groups and the media to manage community issues arising from the find Additional investigations may be required to identify living descendants particularly if the remains are to be removed and relocated
If exhumation of the remains (from a formal burial or a vault) is required Project Managers should also be aware of additional approval requirements under the NSW Public Health Act 1991 Specifically Sydney Metro may be required to apply to the Director General of NSW
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Department of Health for approval to exhume human remains as per Clause 26 of the NSW Public Health (Disposal of Bodies) Regulation 2002 8
Further the exhumation of such remains needs to consider health risks such as infectious disease control exhumation procedures and reburial approval and registration Further guidance on this matter can be found at the NSW Department of Health website
In addition due to the potential significant statutory and common law controls and prohibitions associated with interfering with a public cemetery project teams are advised when works uncover human remains adjacent to cemeteries to confirm the cemeteryrsquos exact boundaries where possible
8 This requirement is in addition to heritage approvals under the Heritage Act 1977
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Appendix 5 - Archaeologicalheritage advice checklist
The archaeologistAboriginal heritage consultant must advise the Sydney Metro Environment Manager and Senior Heritage Advisor of an appropriate archaeological or heritage management plan as soon as possible after an inspection of the site has been completed An archaeological or heritage management plan can include a range of activities and processes which differ depending on the find and its significance
In discussions with the archaeologistAboriginal heritage consultant the following checklist can be used as a prompt to ensure all relevant heritage issues are considered when developing this plan This will allow the project team to receive clear and full advice to move forward quickly Archaeological andor heritage advice on how to proceed can be received in a letter or email outlining all relevant archaeological andor heritage issues
Required Outcomenotes
Assessment and investigation
Assessment of significance YesNo
Assessment of heritage impact YesNo
Archaeological excavation YesNo
Archival photographic recording YesNo
Heritage approvals and notifications
AHIP section 140 section 139 exceptions section 60 exemptions etc
YesNo
Regulator relicsobjects notification YesNo
Notification to Sydney Trains for s170 heritage conservation register
YesNo
Compliance with CEMP or other project heritage approvals
YesNo
Stakeholder consultation
Aboriginal stakeholder consultation YesNo
Artefactheritage item management
Retention or conservation strategy (eg items may be subject to long conservation and interpretation)
YesNo
Disposal strategy YesNo
Short term and permanent storage locations (interested third parties should be consulted on this issue)
YesNo
Control Agreement for Aboriginal objects YesNo
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Appendix 6 - Template notification letter
Insert on Sydney Metro letterhead
Select and type date] [Select and type reference number]
XXX
Heritage NSW Department of Planning Industry and
Environment
xxx
Parramatta NSW 2124
[Select and type salutation and name]
Re Unexpected heritage item discovered during Sydney Metro activities
I write to inform you of an unexpected [select relic heritage item or Aboriginal object] found during Sydney Metro investigative and construction works at [insert location] on [insert date] in accordance with the notification requirement under select section 146 of the Heritage Act 1977 (NSW) [Where the regulator has been informally notified at an earlier date by telephone this should be referred to here]
[Provide a brief overview of the project background and project area Provide a summary of the description and location of the item including a map and image where possible Also include how the project was assessed under the Environmental Planning and Assessment Act 1979 (NSW) (eg Part 5) Also include any project approval number if available]
Sydney Metro [or contractor] has sought professional archaeological advice regarding the item A preliminary assessment indicates [provide a summary description and likely significance of the item] Please find additional information on the site recording form attached
Based on the preliminary findings Sydney Metro [or contractor] is proposing [provide a summary of the proposed archaeologicalheritage approach (eg develop archaeological research design (where relevant) seek heritage approvals undertake archaeological investigation or conservationinterpretation strategy) Also include preliminary justification of such heritage impact with regard to project design constraints and delivery program]
The proposed approach will be further developed in consultation with a nominated Office of Environment and Heritage staff member
Should you have any feedback on the proposed approach or if you require any further information please do not hesitate to contact [Environment and Planning Project Manager] on (02) XXXX XXXX
Yours sincerely
[Sender name]
Sydney Metro Director Environment Sustainability amp Planning [Attach the archaeologicalheritage management plan and site recording form]
NB On finding Aboriginal human skeletal remains this letter must also be sent to the Commonwealth Minister for the Environment in accordance with notification requirements under section 20(1) of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (Commonwealth)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 56 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 5B ndash Sydney Metro Exhumation Management Procedure
Unclassified
Exhumation Management
Procedure
SM ES-PW-31510
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Senior Heritage Advisor
System Owner Environment Sustainability and Planning
Status Final issued for Implementation
Version 40
Date of issue June 2020
Review date June 2021
copy Sydney Metro 2017
Unclassified
Integrated
Management
System
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 2 of 24
Table of Contents
Contents 1 Introduction 3
2 Methodology 3 21 Overview of legislative requirements for dealing with human remains
4 22 Discovery of human remains and forensic cases NSW Coroners
Act 2009 (NSW) 4 23 Historic human remains Heritage Act 1977 and Guidelines for the
Management of Human Skeletal Remains under the Heritage Act 1977 5
24 Aboriginal human remains National Parks and Wildlife Act 1974 6 25 Exhumation of human remains Public Health Regulation 2012
(NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013) 7
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013) 7
27 Work Health and Safety Act 2011 7
3 Sydney Metro procedure for the discovery and management of human remains 8 31 Initial discovery of bones What do we do 8 32 Archaeological Exhumation Methodology 10
4 Excavation and post-excavation tasks 14 41 Research Questions 14 42 Process for DNA Testing Isotope Analysis and Environmental
Sampling 15 43 Reporting 16 44 Public Involvement 16 45 Temporary Storage and Permanent Repository or Resting Place for
Remains 17
5 Definitions 18
6 Related Documents and References 18
7 Superseded Documents 18
8 Document History 18
9 Schedule of Acronyms 18
Exhumation of Human Remains 20 EXHUMATION OF HUMAN REMAINS 1 MANDATORY REQUIREMENTS 1 IMPLEMENTATION 1 REVISION HISTORY 2 CONTENTS 4 APPENDIX 2 11 APPENDIX 3 12 APPENDIX 4 13 APPLICATION TO EXHUME REMAINS 16
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1 Introduction
This Exhumation Management Procedure (ExMP) has been developed to provide Sydney Metro and their contractors with guidance on managing the discovery of human skeletal remains during the course of the Sydney Metro program of works
Sydney Metro is Australiarsquos biggest public transport project From the northwest metro rail is being extended under Sydney Harbour through new underground city stations and beyond to the south west In 2024 Sydney will have 31 metro railway stations and a 66km standalone metro railway system revolutionising the way Australiarsquos biggest city travels (refer to Figure 1)
The purpose of this ExMP is to provide a clear and concise process to follow in the event of the discovery of potential human remains during Sydney Metro project works
This ExMP will be reviewed as required and prior to any future Sydney Metro project that has potential to impact on a known cemetery or burial ground A review may require amendment the ExMP to tailor additional controls or management procedures that are specific to the impacted cemetery or burial ground In addition the requirements of the relevant Planning Approval will be assessed during the review of this ExMP prior to its implementation
This procedure should be read in conjunction with the Sydney Metro Unexpected Finds Policy
2 Methodology
This ExMP outlines the procedure for the management of the discovery of human remains within the Sydney Metro program The ExMP addresses the following
Discussion of relevant legislation and guidelines (eg Coroners Act 2009 Heritage Act 1977 Guidelines for the Management of Human Skeletal Remains 1988 and the Public Health Regulations 2012)
Archaeological methodology for excavation of remains including processes for appropriately handling remains in accordance with the relevant guidelines
Preparation of a flow chart process to be used by contractors to respond to the discovery of suspected human remains
Post-exhumation management primarily around relocation processing and long- term arrangements
Process for nomination of a physical anthropologist and temporary storage location
Process for additional analysis including DNA testing isotope analysis and environmental sampling and discussion on requirements for public involvement
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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Figure 1 2020 Sydney Metro Program Project overview and station locations
21 Overview of legislative requirements for dealing with human remains
The following section provides an overview of the legislation that would apply to the discovery management and relocation of human remains A discovery of suspected human remains may be subject to different Acts and requirements thereby triggering different notification pathways based on the specific circumstances involved
The first step will always be to notify the NSW Police Confirmation of the age (antiquity) and nature of the skeletal remains as well as the reasons for the disturbance will dictate which Act and provisions will be applicable
22 Discovery of human remains and forensic cases NSW Coroners Act 2009 (NSW)
For a discovery of suspected human remains less than 100 years old the remains would come under the jurisdiction of the State Coroner and the NSW Coroners Act 2009 Such a case would be considered a lsquoreportable deathrsquo and under legal notification obligations set out in s35 (2) a person must report the death to a police officer a coroner or an assistant coroner as soon as possible This applies to all human remains less than 100 years old regardless of ancestry (ie both Aboriginal and non-Aboriginal remains)
Unclassified
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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35 Obligation to report death or suspected death
(1) This section applies to any person who has reasonable grounds to believe that a death or suspected death of another person
(a) is a reportable death or occurred in circumstances that would be examinable under Division 2 of Part 32 and
(b) has not been reported in accordance with subsection (2)
(2) A person to whom this section applies must report the death or suspected death concerned to a police officer a coroner or an assistant coroner as soon as possible after becoming aware of the grounds referred to in subsection (1)
Maximum penalty (subsection (2)) 10 penalty units
(3) A police officer to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner or assistant coroner as soon as possible after the report is made
(4) An assistant coroner to whom a death or suspected death is reported under this section is required to report the death or suspected death to a coroner as soon as possible after the report is made
(5) A coroner to whom a death or suspected death is reported under this section is required to inform the State Coroner of the report as soon as practicable after the report is made
23 Historic human remains Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 19771 (the Guidelines) apply to historic burials in New South Wales It should be noted that the Guidelines are outdated in terms of the current statutory framework
A relic is defined as an archaeological deposit or artefact that has heritage significance at a local or State level The guidelines Assessing Significance for Historical Archaeological Sites and `Relics2 have been endorsed by the Heritage Council and should be used to assess the level of heritage or archaeological significance of the remains With reference to burial grounds objects such as headstones grave enclosures and grave goods as well as buried human remains may be a lsquorelicrsquo
1 NSW Heritage Office 1998
2 Heritage Branch of the Department of Planning 2009
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Approval under the Heritage Act 1977 and the National Parks and Wildlife Act 1974 is not required if human remains are uncovered during a Critical State Significant Infrastructure (CSSI) project However notification to the Heritage Council under s146 of the Heritage Act and notification of an Aboriginal object under the National Parks and Wildlife Act is required if archaeological human remains are uncovered
24 Aboriginal human remains National Parks and Wildlife Act 1974
The National Parks and Wildlife Act provides statutory protection for all Aboriginal lsquoobjectsrsquo (consisting of any material evidence of the Aboriginal occupation of NSW) under Section 90 of the Act and for lsquoAboriginal Placesrsquo (areas of cultural significance to the Aboriginal community) under Section 84
Discovery of Aboriginal burials andor human remains would be addressed in the projectrsquos Aboriginal Cultural Heritage Assessment Report (ACHAR) ACHARs would be prepared in accordance with the Heritage NSW
lsquoGuidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation3
Guide to investigating assessing and reporting on Aboriginal cultural heritage in NSW4
Aboriginal cultural heritage consultation requirements for proponents 20105
Code of Practice for Archaeological Investigation of Aboriginal Objects in New South Wales6
If suspected human skeletal remains are uncovered at any time during the archaeological management program the process outlined in this ExMP and detailed in the flow chart is to be followed Management of the remains would be guided by consultation with the nominated Registered Aboriginal Parties (RAPs) for the project in adherence to the ACHAR
3 NSW Department of Environment and Conservation 2005
4 OEH 2011
5 Department of Environment Climate Change and Water 2010
6 OEH 2010
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(Uncontrolled when printed)
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Sydney Metro Exhumation Procedure v40 (final)
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25 Exhumation of human remains Public Health Regulation 2012 (NSW) and the NSW Health Policy Statement ndash Exhumation of human remains (2013)
Public Health Regulation 2012 and the NSW Health Policy Statement ndash Exhumation of human remains of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies in NSW
Under Clause 70 of the Regulation an application for approval to exhume the remains of a dead person may be made to the Director-General via an approved form to the Director of the Local Public Health Unit that acts on behalf of the Director-General of NSW Health Exhumation is not to take place unless an authorised officer or a NSW Health member of staff is present at the exhumation (the grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer) (Clause 72) An authorised officer must be present at the exhumation to ensure the correct interment procedure is followed and that all of the remains are exhumed and to enforce the protection of public health should this be necessary
26 NSW Ministry of Health Policy Statement ndash Exhumation of human remains (2013)
The NSW Ministry of Health Policy Statement on the exhumation of human remains provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation Under Clause 69 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General An application for permission to exhume the remains of a deceased person is to be made to the Public Health Unit on the approved form which is contained at the NSW Health website
The required form is appended to this ExMP for ease of reference
Note that the title of Director General of Health was replaced with the Secretary of Health when the Public Health Act and Public Health Regulation were amended However the Policy Directive PD2013-046 has not been amended to reflect this change
27 Work Health and Safety Act 2011
The Work Health and Safety Act 2011 provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices and are enforced by WorkCover NSW Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation More information on safe work practices is available at or by contacting SafeWork NSW via their website or directly
Health and safety aspects of working with human remains should be considered Generally working with archaeological human skeletal remains requires no extra precautions to be taken beyond normal health and safety regulations Once any necessary site health and safety precautions have been taken the exhumation of human remains can proceed
Unclassified
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Sydney Metro Exhumation Procedure v40 (final)
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3 Sydney Metro procedure for the discovery and management of human remains
This procedure provides project managers principal contractors and the project archaeologistExcavation Director with advice on the steps to follow upon uncovering suspected human remains Information on the potential for burials and human remains would be included in the general project induction for all personnel The induction would include the procedure to manage these finds as set out in this ExMP
31 Initial discovery of bones What do we do
To avoid doubt all suspected bone items must be treated as potential human skeletal remains and work around them must stop while they are protected and investigated as a matter of urgency
Stop Work and preliminary notification
On discovery of bone (suspected human remains) all work in the area of the find must stop and the remains must be confirmed as being human or not
The Project ArchaeologistExcavation Director must be notified
Preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 2009
What When bones are uncovered at a site all work in the area the find must stop immediately and the
site must be secured
Who The discoverer will immediately notify machinery operators so that no further disturbance of the
remains will occur as well as notify the foremansite supervisor principal contractor project archaeologistExcavation Director and Sydney Metro Environmental Manager
Preliminary notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager Notification should provide verbal description of the remains and inform the police that consultation with technical specialists is being undertaken to confirm that the remains are human as well as the burial context (archaeological or less than 100 years old refer Step 2)
How Inform all site personnel of restricted access to the area of the discovery until further notice Area must be fenced off (flagging or temporary exclusion fencing)
Actions Notify site supervisor principal contractor project archaeologist Excavation Director and Sydney Metro Environmental Manger of the find and protect the suspected remains until an initial assessment can be undertaken by a technical specialist
Preliminary notification to NSW Police by Sydney Metro Environmental Manager
Confirm the remains are human
Skeletal remains could either be articulated and in a recognisable form of burial such as a coffin or common burial position of the body (eg supine prone or flexed) or they could be disarticulated or fragmented remains Within the boundaries of a known historic burial ground there is a high probability of the remains being human In a suspected forensic case (less than 100 years old) the remains may have clothing andor human tissue Disarticulated or fragmented bones are often uncovered and these may require specialist assessment to determine legal jurisdiction
If suspected human remains are identified during the course of project works preliminary notification must be made to the NSW Police in compliance with Section 35 of the Coroners Act 1999 (refer Step 1) NSW Police would be contacted immediately upon receipt of confirmation of human provenance
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 9 of 24
What Confirmation that the remains are human their burial context - whether they are forensic (less than 100 years) or archaeological (older than 100 years) and suspected ancestry (Aboriginal or non- Aboriginal)
Who Excavation Director and or Forensic or physical anthropologist or archaeologist with specialist skills such as an osteoarchaeologist
Notification to the NSW Police will be undertaken by the Sydney Metro Environmental Manager
How Consultation could be undertaken as either an on-site inspection or via good quality photos sent to the nominated technical specialist of 1) the remains and 2) the site general site location of the discovery
Actions Contact nominated technical specialists to confirm that the remains are a) human b) burial context (archaeological or forensic) and c) suspected ancestry (Aboriginal or non-Aboriginal)
For the duration of the Sydney Metro project the nominated technical specialists are
Forensic Anthropologist ndash TBC by contractor for project area
Nominated Excavation Director ndash TBC by contractor for project area
Sydney Metro Environmental Manager to conduct and or oversee liaison with NSW Police
The archaeologist may be able to identify the nature of remains without input from the Forensic Anthropologist The Forensic Anthropologist should be contacted as required
Notification based on jurisdiction (forensic or archaeological)
Once confirmation is received from the technical specialist that the remains are of human origin there are three possible statutory pathways to follow based on the assessment
What Forensic case remains are less than 100 years old
Who If it is determined by specialist assessment (Step 2) that the remains are forensic the remains come
under the jurisdiction of the State Coroner and the Coroners Act 2009
How The NSW Police would likely secure the site and will advise on the procedure to be followed
Actions Environmental Manager to liaise with NSW Police
What Archaeological ndash non-Aboriginal human remains -more than 100 years old
Who Follow the Archaeology Exhumation Methodology as set out in Step 4 below
How Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Actions Follow the Archaeology Exhumation Methodology as set out in Step 4 below
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 10 of 24
What Archaeological ndash suspected Aboriginal human remains -more than 100 years old
Who Recording of Aboriginal ancestral remains must be undertaken by or conducted under the direct supervision of a specialist with RAPs present
How The RAPs must be present where it is reasonably suspected that Aboriginal burials or human remains have been encountered
Actions Notify RAPs and follow ACHAR Notification to Heritage NSW
Follow the Archaeology Exhumation Methodology as set out in Step 4
32 Archaeological Exhumation Methodology
The following section provides the archaeological methodology for exhumation and the appropriate handling of human remains
Securing the Site
The strategy for the excavation and removal of human remains must be sensitive to public opinion and ethical issues and exhumation activities should not be visible to the general public The site may need to be screened off from public areas not only with hoarding but also in some cases with a roof to screen the site off from overlooking buildings At all times human remains should be treated with respect and dignity The perimeter of the excavation site should be demarcated by plastic tape or flagging with only technical staff allowed within this area for the duration of exhumation activities
The site should be protected from the elements including flooding contamination with dust or debris and other disturbance These measures would be formulated by the Excavation Director in consultation with the contractor and Sydney Metro where required and may differ from site to site
Excavation Director
Archaeological investigations are to be managed by a suitably qualified Excavation Director with experience in the historical archaeology of Sydney and the excavation and management of human remains For sites with potential for locally significant remains the Excavation Director should meet the NSW Heritage Council criteria for locally significant archaeological sites For sites with potential for State significant archaeology the Excavation Director should meet the NSW Heritage Council criteria for State significant archaeological sites
Excavation and recording
Exhumation and recording is to be undertaken in accordance with best practice forensic and Heritage Council guidelines Prior to removal the remains should be fully recorded in situ to understand their surrounding archaeological context This will include recording any disturbances to the burial and the identification of bones present In some cases the deposit of bones may be a mixture of articulated and disarticulated remains Care should be taken to distinguish articulated remains and to assess if they represent commingled individuals or disturbed remains belonging to one individual and to record them accordingly
Recording
A standard context recording system would be employed
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 11 of 24
Detailed survey andor measured drawings would be prepared and include location of remains within the overall site (position of the body the direction of the burial noting any stratigraphic relationships with other archaeological features)
Any associated artefacts (potential grave goods burial furniture) would be recorded and collected by context for later analysis
Digital photography in RAW format using photographic scales and photo boards where appropriate A photographic record of all phases of the work on site would be undertaken
Registers of contexts photos samples and drawings would be kept
Excavation
Detection of the extent of the graveremains (if disarticulated)
Surface soils removed in excavation units of 100mm (site dependent) using small hand tools
Expose remains with soft paint brushes and pedestal the remains
Record position and depth of remains
Soil removed would be sieved through 3mm mesh to examine for teeth and bone fragments
Soil samples may be taken from the abdominal andor chest areas of the body (articulated remains) to retrieve further evidence
Exhumation must be under the control of the Excavation Director with the assistance of a Forensic Anthropologist if required Exhumation permits provided by NSW Ministry of Health may also require the presence of an authorised officer or a member of staff of the Ministry of Health
Further excavation of the bottom of the pit (grave) following removal to confirm the absence of further remains
Relocation of bones
Removal and collection of skeletal remains to follow standard forensic practice of labelling
Remove remains from the ground systematically and place in plastic bags according to anatomical areas of the body
Bags should not be air-tight and should have ventilation holes to prevent deterioration of fragile skeletal material Each bag should contain labels and the separate bags should then be placed in a large plastic bag crate or box labelled with the context information
The remains should be placed in a sturdy large cardboard box (approximately 600 x 300 x 200 mm) for relocation to off-site processing location
Resume work
Construction work may only recommence upon receipt of clearance certificate from the Excavation Director and may require additional NSW Ministry of Health approval If a forensic case written authorisation from the NSW Police is required
Reporting
A report would be prepared following the completion of the program of exhumation works separate to the archaeological excavation report for the project This report would include skeletal analysis catalogue comprehensively describe the process of exhumation detail
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
copy Sydney Metro 2017 Page 12 of 24
the recording of the remains and synthesise the results of any further laboratory testing An assessment of significance for the remains would be provided and interpreted within the context of the archaeological research design (response to research questions)
Unclassified
Sydney Metro Exhumation Procedure v4 (Final)
Unclassified
Figure 2 Exhumation Procedure Flow chart
Page 13 of 24
Discovery of bone
Non-human remains
Archaeologist to investigate and work not
to recommence until instrcuted by ED
Work only to recommence when clearance given by Excavation Director
Human Remains
Forensic
Sydney Metro Environmental
Manager to advise NSW POlice
Archaoelogical work not to recommence until clearance given
by NSW Police or Coroner
Aboriginal
Sydney Metro Environmental Manager to advise NSW Policye notify RAPs and follow
ACHAR
Archaoelogical work not to
recommence until clearance firven by
NSW Police or Coroner
Non Aboriginal
Sydney Metro Environmental Manager to notifiy NSW Policce Heritage NSW and DPIE
Sydney Metrocontractor to apply to Secretary of
Health to exhume
Exhumation of human remains by nominated ED Construction work not to commence until
ED issues Clearance Certificate
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
4 Excavation and post-excavation tasks
The following tasks relate to responses to the identification of human remains on site All management should be in accordance with the AARD and relevant Archaeological Method Statement (AMS) and be overseen by the Excavation Director The Excavation Director would nominate a Forensic Anthropologist where required
41 Research Questions
The following research questions should be used guide exhumations should intact burials disarticulated remain burial cuttings or associated material culture be uncovered during works
The research questions are a guide only and could be added to or amended by the Excavation Director depending on the nature of the find
Social History and Burial Practices
Does the location of the burialburial cutting correspond with historic plansdescriptions Are these sources reliable
Is there evidence of exhumation
Do graves cut into older ones What can this tell us about nineteenth century burial practices and how does this compare to other excavated cemetery sites in the region
What is the distance between burials (if multiple burials uncovered) Does this conform to known nineteenth century burial practices
What type of fill was used within grave cuttings What can this tell us about the surrounding environment and burial practices at the time
What materialstree species were used to produce coffins Can coffin manufacturing techniques or fastening methods (use of mortar screws nails tacks) be identified Does this match known burial practices of the time If alternative methods are identified what can this tell us about the manufacturer or economicsocial landscape
Can the class or rank of the individual be identified via coffin materials grave goods or clothingshrouds
Which direction is the burial orientated How does this correspond with the knownhypothesised location of denomination areas
If the burial is associated with additional individuals can a familial relationship be assessed through DNA or other genetic markers identifiable within the skeletal remains (eg impacted third molar)
Can an exchange between burial practices in Britain and colonial Sydney be identified through the burial remains Is there evidence for alternative burial practices associated with additional cultures
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Environmental Factors and Scientific Analysis
What is the condition of the bones How does their condition compare to known or nearby burials of the same age What environmental or human factors may have influenced the decomposition process
Can the health nutrition sex race stature or age be identified through the skeletal remains Is there evidence of trauma on the bones Is there evidence of pathology on the bones (eg syphilis tuberculosis tumours)
If archaeobotanical analysis is carried out what can it tell us about the surrounding environment and nearby plant species Can prepost-European landscapes be determined within the archaeobotanical record
Can stable isotope analysis address any questions regarding diet country of origin and nutrition
Can DNA testing address any questions not answerable by the skeletal remains themselves such as sex familial relationships (if buried with another individuals) or race
Is there potential for DNA to be tested against any individuals who may come forward as a descendant of the deceased
42 Process for DNA Testing Isotope Analysis and Environmental Sampling
Pre-Excavation
The Excavation Director in consultation with the Forensic Anthropologist will nominate a suitable laboratory prior to works commencing Approval for the analysis of skeletal remains soil samples and material samples from the laboratory would also be sought prior to works commencing
Excavation
In order to prevent cross-contamination the following sample collection and excavation process should be followed
The location quantity and material (bone teeth hair soil wood) of samples will be determined by the Excavation Director or Forensic Anthropologist prior to its collection
Samples would be stored in a safe secure and climate controlled location while excavations are in progress This would be chosen by the Excavation Director or Forensic Anthropologist on site
Each collected sample would be given a unique catalogue number and a sample register would be recorded throughout the excavation
ldquoClean Excavationrsquo procedures would be followed during the excavation of burials and during the sample collection process7 This would include
7 Guidelines for lsquoclean excavationrsquo are based on procedures outlined in Yang D Y amp Watt K 2005
Contamination controls when preparing archaeological remains for ancient DNA analysis Journal of Archaeological Science vol 32 pp 331ndash336 and Society for Historical Archaeology 2015-2017 Research and Analysis of Artefacts Accessed online at httpsshaorgconservation- factsfaqanalysisC on 2552017
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Latex gloves would be worn by individuals excavating andor handling bone or soil samples Gloves would be changed for each bone andor individual to prevent cross-contamination
Excavation toolsbrushes would be cleaned prior to and after the collection of each sample to prevent cross-contamination
In some cases a face mask would be worn when samples for DNA analysis are being collected
Bone samples for DNA testing would be collected with surrounding in situ soil and should not be cleaned prior to bagging
It may be necessary for individuals involved in sample collection to submit DNA for comparison in the event of cross-contamination and
All bags containing samples for analysis would be bagged and labelled appropriately to prevent cross contamination and ensure they are handled and stored correctly
Post-Excavation
On completion of excavations samples will be transported to nominated laboratories for analysis A record of their location will be kept
43 Reporting
The results of the investigation of human remains and the exhumation will be included in the archaeological reporting for the project in accordance with the project AARD
Once finalised all archaeological excavation and data analysis reports will be submitted to
The relevant local Council and Library
The Heritage Office Library
The State Library of NSW and
Made available online for public access and educational purposes
Further if significant remains are identified during excavations the results and findings would be published in academic journals and conference papers where feasible
44 Public Involvement
Archaeological excavations may uncover remains directly associated with early settlement and burial practices Such remains are likely to generate public interest
Public involvement may include
Media releases
Public Open Days
Preparation of brochures detailing the archaeological excavations
Interpretive signage and online blog posts or site diaries while excavations are taking place and
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
The preparation of a Heritage Interpretation Plan designed to provide interpretation of the site within the new development upon the completion of works
Due to sensitive nature of human skeletal remains these recommendations would be adapted and modified as appropriate under the direction of Sydney Metro and the Excavation Director
Such recommendations would also be considered and require approval from relevant Stakeholder Groups such as known or potential descendants of the deceased NSW Heritage Heritage Council local Council and interest groups
45 Temporary Storage and Permanent Repository or Resting Place for Remains
Temporary Storage
Upon the completion of archaeological excavations skeletal remains should be boxed separately and temporarily stored within a safe secure and temperature controlled environment to allow for further analysis of the remains This location would be chosen by the Excavation Director and the Forensic Anthropologist and comply with NSW legislative requirements
Permanent Repository or Resting Place for Remains
A permanent repository or resting place for remains is dependent on the nature and volume of skeletal remains As this cannot be determined prior to excavations taking place the following recommendations should act as guidelines only Final arrangements would be dictated by Sydney Metro the Excavation Director Forensic Anthropologist identified descendants of the deceased andor Stakeholder Groups upon the completion of excavations and subsequent analysis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
5 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition Other terms and jargon specific to this Procedure are defined inhttpsicentraltdocstransportnswgovauotcscsexeappnodes3574566
6 Related Documents and References
Related Documents and References
na
7 Superseded Documents
Superseded Documents
Exhumation Management Plan Version 22
Exhumation Management Plan Version 30
8 Document History
Version Date of approval Notes
11 May 2017 New IMS document
20 July 2017 Incorporates Stage 2 (Section 3)
21
February 2019
Extended for Metro Program wide application includes changes specific Central Station management incorporates comments received from the State Coronerrsquos Office NSW Police NSW Health Sydney Metro Environmental Environmental Representatives engaged on the Central site and the Office of Environment and Heritage
22 February 2019 Incorporates comments received from Artefact Heritage and Denise Donlan issued to Health and OEH HD for consultation
30 May 2019 Incorporates Health Coroner and OEH comments
40 April 2020 Updates to remove specific references to City and South West and Central Station
Change of title to ldquoProcedurerdquo
Update to references
9 Schedule of Acronyms
Acronym Meaning
AARD Archaeological Assessment and Research Design
ACHAR Aboriginal Cultural Heritage Assessment Report
AMS Archaeological Method Statement
CSSI Critical State Significant Infrastructure
ER Environmental Representative (Independent)
ExMP Exhumation Management Plan (this plan)
OEH Office of Environment and Heritage
PHU Public Health Unit
RAPs Registered Aboriginal Parties
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
Appendix 1
NSW Heath Policy Directive for Exhumation of Human Remains
Policy Directive
Ministry of Health NSW 73 Miller Street North Sydney NSW 2060
Locked Mail Bag 961 North Sydney NSW 2059 Telephone (02) 9391 9000 Fax (02) 9391 9101
httpwwwhealthnswgovaupolicies
Exhumation of Human Remains
Document Number PD2013_046
Publication date 05-Dec-2013
Functional Sub group Population Health - Environmental
Summary This document provides the policy to be observed by NSW Health in receipt of an application to seek permission for approval of the exhumation of human remains under clauses 69-72 of the Public Health Regulation 2012 This Policy Directive will provide the conditions on which approvals may be granted for exhumation of human remains
Replaces Doc No Burials - Exhumation of Human Remains [PD2008_022]
Author Branch Environmental Health
Branch contact Environmental Health 94245823
Applies to Local Health Districts Environmental Health Officers of Local Councils Ministry of Health Public Health Units Public Hospitals
Audience Authorised officers from Public Health Units and local councils
Distributed to Public Health System Environmental Health Officers of Local Councils NSW Ambulance Service Ministry of Health Public Health Units Public Hospitals
Review date 05-Dec-2018
Policy Manual Patient Matters
File No 081292
Status Active
Director-General
This Policy Directive may be varied withdrawn or replaced at any time Compliance with this directive is mandatory for NSW Health and is a condition of subsidy for public health organisations
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 1 of 2
EXHUMATION OF HUMAN REMAINS
PURPOSE
This document provides the policy to be observed by Public Health Units located in Local Health Districts on receipt of an application to seek permission for approval of the exhumation of human remains under the Public Health Regulation 2012 Common reasons for exhuming bodies include to repatriate the remains overseas or to relocate the body to another cemetery plot or vault
MANDATORY REQUIREMENTS
Under Clause 69 of the Public Health Regulation 2012 a person must not exhume a body unless the exhumation of the remains has been approved by the Director-General
An application for approval to exhume the remains of the body of a dead person may be made to the Director General by
An executor of the estate of the dead person
The nearest surviving relative of the dead person
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person may make the application
An application is to be made in the approved form and it is to be accompanied by
A certified copy of the death certificate relating to the dead person
A statutory declaration as to the relationship of the applicant to the dead person and the dead persons wishes if any regarding the disposal of his or her body
An application fee
Under Clause 71 of the Public Health Regulation 2012 the Director-General may
Grant an approval to exhume the remains of a body
Refuse the application
Under Clause 72 an exhumation cannot take place without an authorised officer or a Ministry of Health staff member present A person must not proceed with an exhumation if the authorised officer or Ministry of Health staff member who is present at the exhumation orders the exhumation to stop
Under Clause 78 if the applicant seeks to have the exhumed body cremated a separate application can be made for an exemption from providing the required cremation documentation provided the body has been buried for longer than 10 years The minimum 10 year period is strictly enforced An application under this clause is to be accompanied by a fee of $100
IMPLEMENTATION
Authorised officers in Public Health Units of Local Health Districts are responsible for assessing applications for exhumation of human remains and either approving with a set of conditions or rejecting the application Authorised officers should ensure that all of the required document has been submitted with the application fee and that an appropriate person has applied for the application The approval granted is valid for a period of three months after the approval is granted
POLICY STATEMENT
Issue date December-2013 PD2013_046 Page 2 of 2
REVISION HISTORY
Version Approved by Amendment notes
December 2013 PD2013_046
Deputy Director- General Population and Public Health
This document is an updating of the original document due to legal changes under the Public Health Regulation 2012
23 April 2008 PD2008_022
Director-General This document provided the policy to be observed by NSW Health in receipt of an application to seek permission for approval of exhumation of human remains under clauses 25 ndash 28 of the Public Health (Disposal of Bodies) Regulation 2002 It provided the conditions upon which approvals could be granted for the exhumation of human remains
ATTACHMENTS
1 Exhumation of Human Remains Procedures
Exhumation of Human Remains PROCEDURES
Issue date December-2013
PD2013_046
Exhumation of Human Remains
Issue date December-2013 PD2013_046 Contents Page
PROCEDURES
CONTENTS
1 BACKGROUND 2
11 Introduction 2
12 Key definitions 2
13 Legal and legislative framework 3
2 APPLICATION REQUIREMENTS 6
3 APPROVAL BY PUBLIC HEALTH UNITS 7
31 Delegation 7
32 Special Considerations on Exhumation Approval 7
33 Conditions of Approval 8
34 Approval Instrument 8
35 Notification of Approval 8
36 Refusals 8
37 Cremation of Remains 8
APPENDIX 1 10
APPENDIX 2 11
APPENDIX 3 12
APPENDIX 4 13
APPENDIX 5 14
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 2 of 14
1 BACKGROUND
11 Introduction
Exhumation of human remains may occur for a number of reasons including
To satisfy family wishes where the family of the deceased person may want the remains to be moved to another burial ground to another part of the state or country or abroad or even to have the remains cremated
To obey Coronial orders requiring exhumation for forensic (criminal) investigation
To enable the use of closed cemeteries for redevelopment or for the construction of new infrastructure such as a road or airport
A variety of people including authorised officers cemetery authorities and funeral directors are involved at different stages of exhumation procedures
Public Health Units (PHUs) of Local Health Districts (LHDs) in NSW facilitate the approval for an exhumation however there is no obligation to proceed with an exhumation once it has been approved
The objectives of this document are
To assist authorised officers with processing applications to exhume
To standardise the management of an exhumation so as to prevent a public health risk and protect community amenity in the handling of remains
12 Key definitions
These definitions are repeated from the Public Health Act 2010 and Public Health Regulation 2012 for clarity
Body Means the body of a dead person but does not include
the cremated remains of the person
Burial Includes putting the body in a vault
Cemetery Authority Means the person or body that directs the operations of a cemetery
Coroner Means a person who exercises or performs the functions of a coroner in accordance with the Coroners Act 2009
Dead person Includes a still-born child (see definition of Still birth)
Exhumation Means the removal of a dead personrsquos remains (not being cremated remains) from a grave or vault but does not include their removal from one vault for immediate transfer to another vault in the same cemetery or their temporary removal for the purposes of reburial in the same grave or vault
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 3 of 14
Funeral director Means a person (other than the operator of a mortuary transport service) who in the conduct of the personrsquos business engages for the purpose of burial cremation or transport in the collection transport storage preparation or embalming of bodies or engages in the conduct of exhumations
Prescribed infectious diseases
Means any one of the following diseases avian influenza in humans diphtheria plague respiratory anthrax smallpox severe acute respiratory syndrome tuberculosis and any viral haemorrhagic fever (including Lassa Marburg Ebola and Congo-Crimean fevers)
Proper person The Director General has the power to decide whether a person is a lsquoproper personrsquo to make an application to exhume the remains of a dead person
Nearest surviving relative
Means (a) In relation to a still-born child a parent or sibling at or above the age of 16 years of the child (b) In relation to a dead person who is not a still-born child ndash the spouse or de facto partner of the dead person immediately before death a parent of the dead person a child at or above the age of 16 years of the dead person or any relative of the dead person who was residing with the dead person when he or she died
Still-birth Consistent with the Births Deaths amp Marriages Act 1995 means the birth of a child that exhibits no sign of respiration or heartbeat or other sign of life after birth and that (a) Is of at least 20 weeksrsquo gestation (b) If it cannot be reliably established whether the period of gestation is more or less than 20 weeks has a body mass of at least 400 grams at birth
13 Legal and legislative framework
Public Health Regulation 2012
Division 4 of Part 8 of the Public Health Regulation 2012 provides specific regulation for the exhumation of bodies
Clause 69 Exhumation without approval prohibited
(1) A person must not exhume the remains of a body unless the exhumation of those remains has been
(a) Ordered by a coroner
(b) Approved by the Director-General
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 4 of 14
(2) However a funeral director may without a coronerrsquos order or Director-Generalrsquos approval transfer a coffin from a vault in a cemetery to a mortuary for the purpose of the coffin being immediately repaired and returned to the vault
(3) A funeral director must return the coffin to the cemetery within 24 hours of its transfer
Clause 70 Application to exhume remains
(1) An application for approval to exhume the remains of the body of a dead person may be made to the Director-General by
(a) An executor of the estate of the dead person
(b) The nearest surviving relative of the dead person
(c) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances may make the application
(2) An application is to be made in the approved form and is to be accompanied by
(a) A certified copy of the death certificate relating to the dead person
(b) A statutory declaration as to the relationship of the applicant to the dead person and the dead personrsquos wishes if any regarding the disposal of his or her body (so far as any such wishes are known to the applicant)
(c) An application fee (please check with the PHU for the current fee)
(3) In this clause death certificate means a certificate given by a medical practitioner as to the cause of death or issued under the Births Deaths and Marriages Registration Act 1995
All applications to exhume remains must be made in writing using an approved form to the Director of the local Public Health Unit that acts on behalf of the Director-General of the NSW Ministry of Health The application fee may increase periodically in line with the Consumer Price Index
Clause 71 Approval to exhume remains
(1) The Director-General may
(a) Grant an approval to exhume the remains of a body subject to any conditions specified in the approval
(b) Refuse the application
(2) An approval granted under this clause remains valid for three months from the date of the approval or for a period agreed to by the Director-General
The PHU is not bound to approve the application The PHU may approve subject to conditions or refuse the application An approval is normally given for 3 calendar months and this date will be specified in a schedule of conditions attached to the approval document Any further extension of time may require re-application and re-approval An approval initially for longer than three calendar months should be negotiated with the PHU
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 5 of 14
Clause 72 Exhumation not to take place without authorised officer present
(1) A person must not proceed with an exhumation unless an authorised officer or a member of staff of the Ministry of Health is present at the exhumation
(2) A person must not proceed with an exhumation if the authorised officer or Ministry staff member who is present at the exhumation orders the exhumation to stop
The grave may be excavated to the lid of the coffin but nothing must be disturbed until the arrival of the authorised officer An authorised officer must be present at the exhumation to ensure that the correct interment is opened to ensure that all of the remains are exhumed and to enforce the protection of public health should this be necessary The authorised officer has the power to order that the exhumation be stopped immediately under adverse circumstances An example of where this may occur is where the weather is very poor with heavy rain The initial order to stop is to be given verbally and then confirmed in writing to all parties involved within 24 hours
Division 5 of Part 8 of the Public Health Regulation 2012 provides for cremation of deceased persons
Clause 78 No cremation without documentation
Clause 78 does not apply to a cremation of the body of a dead person that has been buried for at least 10 years if the cremation is carried out in accordance with an exemption granted by the Director-General following an application by
1) An executor of the estate of the dead person
2) The nearest surviving relative of the dead person
3) If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
This is a new addition to the Exhumation section of the Regulation that may be used where a person makes a separate application to have the exhumed body cremated following the exhumation
Note The Director-Generalrsquos authority under Clause 78 (4) of the Public Health Regulation 2012 (Delegations Manual page 866 delegation (PH590)) is the power to decide whether a person is a ldquoproper personrdquo to make an application in the absence of an executor or surviving relative
Work Health and Safety Act 2011
The Work Health and Safety Act 2011 and Code of Practice for Excavation provisions apply to protect personnel involved in the exhumation procedure by creating and maintaining safe and healthy work practices Graves crypts and vaults could be considered to be confined spaces in some circumstances under health and safety legislation The Work Health and Safety Act 2011 makes reference to working in confined spaces
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 6 of 14
WHampS matters are enforced by WorkCover NSW More information on safe work practices is available at httpwwwworkcovernswgovaudefault or by contacting Workcover NSW direct on 13 10 50
Heritage Act 1977
The Heritage Act 1977 and Guidelines for the Management of Human Skeletal Remains under the Heritage Act 1977 applies to relic burials Any burial site over 50 years old is considered to be relic under the Heritage Act If the site is listed on the State Heritage Register then approval is required from the Heritage Council of NSW
An application must be made to the Heritage Office before any disturbance removal or work commences on the site Approval for an exhumation under the Public Health Regulation 2012 does not obviate the necessity to obtain approval under the Heritage Act 1977 For further information contact the Heritage Office of NSW or visit httpwwwheritagenswgovau
Coronerrsquos Act 2009
A coroner may order an exhumation for the purposes of forensic investigation or a criminal investigation Such an order is outside the ambit of the Public Health Regulation 2012 The Police may request that an authorised officer from the Ministry of Health or the local Public Health Unit be present at the coronial exhumation
Births Deaths and Marriages Registration Act 1995
Section 41(2) of the Births Deaths and Marriages Registration Act 1995 requires that if human remains (other than cremated remains) are removed from NSW the funeral director or other person who arranges for the removal of the remains from NSW must within 28 days of disposal of the remains outside NSW give the Registrar notice of the new location of interment The act is available at httpwwwaustliieduauaulegisnswconsol_actbdamra1995383 The Registry of Births Deaths and Marriages may be contacted via httpwwwbdmnswgovau
2 APPLICATION REQUIREMENTS
An application for permission to exhume the remains of a deceased person is to be made to the PHU on the approved form which is contained at the NSW Ministry of Health website at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c70- application-to-exhumepdf
The application must be made by either
An executor of the estate of the deceased
The nearest surviving relative
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 7 of 14
If there is no such executor or relative available to make the application a person who in the opinion of the Director-General is a proper person in all the circumstances to make the application
The application must be accompanied by
A certified copy of the death certificate (death certificate issued by the Registry of Births Deaths and Marriages)
A statutory declaration that states
The relationship between the applicant and the deceased or the reason the applicant is the proper person to make the application
If the deceased left any instructions regarding the disposal of their bodyremains if known
In addition to the above an applicant should declare that he or she has consulted each nearest surviving relative and that they have no objection to the proposed exhumation
An application fee (please check with the PHU for the current fee)
Note If there is no agreement amongst nearest surviving relatives the applicant should seek independent legal advice regarding this issue The applicant should advise if there is an intention to cremate the body following the body being exhumed and the appropriate form completed
3 APPROVAL BY PUBLIC HEALTH UNITS
Approval by PHUs for an exhumation must be given by formal correspondence
31 Delegation
The Director-Generalrsquos authority under clauses 69(1) 70(1)(c) and 71 of the Public Health Regulation 2012 has been delegated to the Chief Health Officer Director Health Protection Public Health Officer or Public Health Unit Director as appointed under Section 121 of the Act (delegation PH308 PH309)
32 Special Considerations on Exhumation Approval
Special consideration should be given to the approval of an exhumation if the deceased was infected with a prescribed infectious disease For example if the deceased was infected with diphtheria or tuberculosis exhumation should not permitted in the first year of interment
Although not prohibited an exhumation of the remains of a body that was buried without a coffin will be approved only where the cemetery authority and funeral director have agreed to proceed with the exhumation especially during the first three years of interment
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 8 of 14
33 Conditions of Approval
After due consideration of the application and the statutory declaration(s) the PHU should then consider applying appropriate conditions to facilitate an approval
There are two standard sets of approval conditions which can be applied as appropriate
Appendix 2 ndash Schedule A - Conditions of Approval for Exhumation from a Grave
Appendix 3 ndash Schedule B - Conditions of Approval for Exhumation from an Above Ground Structure
Any other additional conditions that are deemed necessary to permit the exhumation may be added to schedule A or B based on the individual circumstances of the exhumation If some conditions are unwarranted they may be removed from the relevant schedule
34 Approval Instrument
An approval must be in writing and must be signed the Director General or their delegate A template to assist in the approval process can be found at Appendix 4 This template is to be completed by the Authorised Officer in order to facilitate approval by the delegate
35 Notification of Approval
The approval instrument is retained on file as a record that approval was granted by the Director General or their delegate Therefore it is necessary to advise the applicant the cemetery authority and the funeral director of the approval
The attached letter templates may be used for approval notification of the exhumation to the applicant funeral director and Cemetery Authority
Appendix 5 ndash Sample Letter to Applicant
Appendix 6 ndash Sample Letter to the Cemetery Authority and Funeral Director
36 Refusals
If after due consideration the application is to be refused then the applicant should be notified in writing specifying the reasons for refusal Ideally the applicant should consult the PHU in the first instance to discuss the requirements and possible restrictions on an application to exhume
37 Cremation of Remains
Division 5 of Part 8 of the Public Health Regulation 2012 sets out the requirements for documentation for cremations in NSW and includes the requirement for a cremation application form a cremation certificate and the cremation permit The documentation confirms the identity of the body to be cremated and the cause of death and ensures that a coronerrsquos investigation has been conducted where necessary
After the body is exhumed the next of kin may wish to have the body cremated However there may be cases whereby the body does not have the required paperwork necessary for cremation Clause 78 of the Public Health Regulation 2012 provides an exemption for
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 9 of 14
the required documentation for cremation where the body has been buried for longer than 10 years An application under this clause is to be accompanied by a fee
The Director General has the power to approve an exemption and the executor or the nearest surviving relative or another proper person may make application on form lsquoApplication for Exemption by the Director ndash General to the Requirement for Documentation for Cremation to Proceed Permission for Cremation of Exhumed Remains of a Body Buried more than 10 years ago with statutory declarationrsquo The minimum 10 year period will be strictly enforced and this matter should be clarified prior to any exhumation approval where it is planned for the remains to be subsequently cremated The application form is available at httpwwwhealthnswgovauenvironmentdotdDocumentsform-c78-application-for- exemptionpdf
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 10 of 14
APPENDIX 1
Schedule A
CONDITIONS OF APPROVAL FOR EXHUMATION FROM GRAVE
1 The exhumation is to be carried out in the presence of a Public Health Unitrsquos authorised
officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Day and time of the exhumation shall be arranged by the participating parties and agreed
to by the Public Health Unit
4 The approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The presence of any relative of the deceased at the exhumation is strictly prohibited
6 No animals are to be permitted within the exhumation site
7 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
8 If during the course of the exhumation it is determined necessary to stop the exhumation
by either the exhumation supervisor cemetery manager or authorised Officer for any valid reason eg work health and or public health risk then the exhumation must cease
9 The remains of the deceased shall be enclosed in a body bag and placed into a new coffin
with a name plate attached inscribed with the name of the deceased
10 The remains of the original coffin are to be placed in the new coffin where possible Where there is an excess of remains of the original coffin these remains should be disposed in a sanitary and agreed manner
11 Excavated soil should be back filled The soil that was removed from immediately above
and around the coffin should be replaced first
12 If the exhumed remains are to be transferred to another cemetery a funeral director shall be contracted to transfer the remains from the cemetery grounds or carry out preparatory work for the safe reinterment of the remains
13 The exhumation will not proceed during or following a period of heavy rainfall within the preceding 24 hours of the appointed time of exhumation The cemetery manager is to confirm that satisfactory conditions exist for the exhumation to proceed two hours prior to the commencement of the exhumation
14 Used disposable protective equipment and materials are to be placed in a sealed plastic
bag and disposed of in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 11 of 14
APPENDIX 2
Schedule B
CONDITIONS OF APPROVAL FOR EXHUMATION FROM ABOVE GROUND STRUCTURE
1 The exhumation is to be carried out in presence of a Public Health Unit authorised officer or other authorised officer of the NSW Ministry of Health or Local Council authorised Officer and person appointed by Cemetery Authority
2 At least 48 hoursrsquo notice of the exhumation arrangements shall be given to the Public Health Unit
3 Date and time of the exhumation shall be arranged by the participating parties and agreed to
by the Public Health Unit
4 An approval granted is valid for a period of three months and shall lapse on unless a further approval is granted
5 The cemetery authority and funeral director shall be responsible for the work health and safety of all persons involved in the exhumation and shall ensure that all NSW WorkCover requirements are complied with
6 If during the course of the exhumation it is determined necessary to stop the exhumation by
either the exhumation supervisor Cemetery Manager or authorised officer if for any valid reason eg worker health andor public health risks then the exhumation must cease
7 Used disposable protective equipment and materials are to be placed in a sealed plastic bag
and disposed in a sanitary manner
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 12 of 14
APPENDIX 3
LETTERHEAD
APPROVAL INSTRUMENT TEMPLATE
Public Health Unit Environmental Health Section
File Number [XXXXX]
PURPOSE To approve of the exhumation of the late
RECOMMENDATION
Approval is granted by the Director General pursuant to clause 71(1)(a) Public Health Regulation
2012 to [NAME OF APPLICANT] to exhume the remains of the late [NAME OF DECEASED]
KEY ISSUES
[DETAILS OF THE APPLICATION STATUTORY DECLARATION RELEVANT ISSUES
MANAGEMENT PLAN AND JUSTIFICATION OF SUGGESTED CONDITIONS ARE TO BE
INCLUDED HERE]
BACKGROUND (TO BE COMPLETED BY PHU)
CONSULTATION (TO BE COMPLETED BY PHU WHERE APPROPRIATE)
The approval be subject to compliance with the conditions specified in Schedule A Schedule B
and to expire on
Signature Authorised officer
Author Telephone Date
1 Authorised officer
2 Public Health Unit Director Public Health Officer [SIGN AND DATE]
Approved via delegation from the Director-General PH308 PH309 page 863 Public
Health Delegations Manual under clause 69(1) and 70(1) (C) Public Health Regulation
2012
3 Authorised officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 13 of 14
APPENDIX 4
LETTERHEAD
SAMPLE LETTER TO APPLICANT
[APPLICANTrsquoS NAME] [ADDRESS]
Dear [APPLICANTrsquoS NAME]
Reference is made to your application of [DATE] requesting approval to exhume the remains of
late [NAME OF DECEASED] from grave vault crypt No Section [NAME OF
PLACE OF INTERMENT OR CEMETERY] for the purpose of re-interment to [NAME OF PLACE
FOR RE-INTERMENT]
Approval has been granted by the Director-General pursuant to clause 71 (1) (a) Public Health
Regulation 2012 subject to compliance with the conditions specified in Schedule A Schedule B
attached
The funeral director and cemetery authority have been advised of the approval
Should you have any inquiries please contact the authorised officer [EHO] on [TELEPHONE] or (EMAIL ADDRESS)
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
EXHUMATION OF HUMAN REMAINS
PROCEDURES
PD2013_046 Issue date December-2013 14 of 14
APPENDIX 5
LETTERHEAD
SAMPLE LETTER TO CEMETERY AUTHORITY AND FUNERAL DIRECTORS
[NAME] [ADDRESS]
[DATE]
Dear [NAME]
EXHUMATION OF THE REMAINS OF THE LATE [NAME OF DECEASED]
Approval has been granted for the exhumation of the late [NAME OF DECEASED] from grave
vault crypt No Section [NAME OF PLACE OF INTERMENT OR
CEMETERY] in accordance with clause 71(1) (a) of the Public Health Regulation 2012 and
subject to compliance with the conditions specified in Schedule A Schedule B attached
A copy of the approval letter is attached for your information
Should you have any inquiries please contact [Authorised Officer) on [TELEPHONE] or email address
Yours sincerely
[NAME] Public Health Unit DirectorPublic Health Officer
Unclassified
Sydney Metro Exhumation Procedure v40 (final)
Unclassified
Addendum 2
NSW Heath Permit Application form
copy Sydney Metro 2017 Page 23 of 24
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
APPLICATION TO EXHUME REMAINS PUBLIC HEALTH REGULATION 2012 Clause 70(2)
In accordance with the requirements of Clause 70 (2) of the Public Health Regulation 2012 I helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Full name of applicant)
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip hereby (Address)
apply for permission to exhume the remains of the late helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip (Name of deceased)
from Grave Nohelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Section helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip being a single
interment within the helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellipCemetery for the purpose of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
I seek permission to exhume for the following reasons
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
The deceased (cross out which is not applicable)
was not known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012 or
was known to be infected with a prescribed infectious disease as defined in clause 53 of the Public Health Regulation 2012
I am entitled to make this application because I am (tick one)
1 [ ] The executor of the estate of the deceased or
2 [ ] The nearest surviving relative of the deceased or
3 [ ] If there is no such executor or relative available to make the application another the proper person to make the application for the reasons set out below
helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Full reasons for proper person to make application) Attached is
1 A certified copy of the death certificate of the deceased
2 A statutory declaration as to
My relationship to the deceased and
the wishes of the deceased regarding the disposal of the body (if known)
the reasons why the Director-General may consider me the proper person in all the circumstances to make the application (if applicable)
3 The application fee of $helliphelliphelliphelliphelliphelliphellip
Signature helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip Date helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
(Applicant)
The exhumation is to be supervised in strict accordance with the attached Plan of Management
by helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
employed with helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip(Funeral DirectorCemetery)
in the capacity of helliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip
Form C70
Unclassified
copy Sydney Metro 2017 Unclassified Page 24 of 24
ExMP v30 (final)
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
bttp wwwshd nsw gay auQQpulat onhealthPubtic Healthhtml
NSW
Public Health Unit ll iI I
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 57 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise gaseous and particulate pollutant emissions from construction activities as far as feasible and reasonable Identify and control potential dust and air pollutant sources
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
General Site related dust identifiable fumes odours and vapours will not infringe beyond site boundaries where practical
Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the Site specific controls required for air quality and dust management including - Correct use of PPE - Use of monitoring equipment - Methods to control dust
Project Manager
Greenhouse Gases
Regular maintenance of plant and equipment for optimum performance will be undertaken to keep emissions to a minimum and increase plant productivity
Vehicles and equipment must be fitted with appropriate emission control equipment and routinely maintained Plant should be switched off when not in use wherever practicable
All plant equipment and vehicles are to be regularly monitored and maintained and records kept of maintenance Engine tampering to increase power output is prohibited
Air emissions from plant vehicles and equipment should be visually monitored throughout construction
Comply with National Greenhouse Emission Reporting Scheme (NGERS) reporting requirements
Project Manager
Dark Smoke
All internal combustion engines will be regularly serviced to ensure optimum operation and minimise the volume of visible smoke emitted Any Plant or light vehicles emitting unreasonable smoke (concentrations higher than normal operation) will cease operation and be serviced by a trained and qualified technician
Materials on site will not be burned intentionally without consulting and obtaining the authorisation of the relevant Local Shire Fire Authority and Client The burning of any material on site should be a last option after alternative methods have been considered
All
Dust Monitoring
The following dust monitoring methods will be applied on the Site
Obtaining weather reports from the Bureau of Meteorology (BOM) website Visual inspection
Project Engineer
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 58 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 6 - Air Quality amp Dust Management Sub Plan Responsibility
Dust Control
Dust control methods to be applied on the site to keep dust generated within the site boundaries as reasonably practicable will be
- Wind fencing around the site or between the site and local residences - Application of waterdust suppressant via water carts - Hydro mulching to stabilise soils - Physical application of ground cover - Cessation of works in adverse weather conditions - Restricted speed limits on site - Reschedule dust generating activities to avoid adverse weather conditions - Communicate dust risk and mitigation measures to staff prior to commencing work
All
Fumes Odours and Vapours
The Site will endeavour to keep the generation of emission of unreasonable levels of fumes odours and vapours to a minimum Refer to the Waste Management Sub Plan and Hydrocarbon and Chemical Environmental Management Sub Plan which detail storage and handling controls that minimise fumes odours and vapours
All
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for dust mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 59 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Minimise unreasonable noise and vibration impacts on residents and businesses Avoid structural damage to buildings or heritage items as a result of construction vibration Undertake active community consultation Reduce visual impact of construction to surrounding community Maintain positive cooperative relationships with schools childcare centres local residents and building owners
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Mitigation Measures
Community
The nearest noise and vibration sensitive receivers will be notified of future works and expected levels of noise and vibration well in advance of the works occurring Notifications will be in accordance with the Community Communications Strategy
Information will be provided to the affected community before and during construction through media such as letterbox drops meetings or individual contact A website will also be established for the project to provide information
A toll-free 24hour project hotline will be provided for enquiries and complaints during the works
Sydney Metro and Georgiou Project Manager
Training and Competency
As part of the Site Induction workers will be informed of the site specific management required
for noise and vibration including
- Sensitive receivers - Hours of works - Correct use of plant and equipment - Monitoring requirements
Standard hours of construction
Approved standard hours of construction are Monday to Friday
7 am to 6 pm Saturday 8 am to 1 pm No work on Sundays or public holidays
Project Manager
Out of Hours works Any out of hourrsquos works will require a noise assessment and approval by Sydney Metro through the out of hourrsquos application (Appendix 7A)
Project Engineer Environmental Site Representative
Plant Equipment amp Vehicles
All operators of plant will comply with requirements of the Construction Traffic Management Plan in relation to parking and laydown access and egress to site haulage routes and general site traffic movements
Plant will be fitted with appropriate noise emissionvibration control equipment Plant will be fitted with adequate seat suspension
Plant Department
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 60 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7- Noise Vibration and Light spill Management Sub Plan Responsibility
Plant should be switched off when not in use wherever practicable Tasks using equipment that causes vibration to hands will be rotated at intervals to reduce
exposure Consideration may be given to the use of anti-vibration PPE All plant equipment and vehicles are to be regularly monitored and maintained and records kept
of maintenance Any abnormalities in expected noise or vibration emissions will be recorded in the plantrsquos log
book and reported to the plant department Prioritise the use of hydraulic concrete shears jaw crushers coring and wire sawing in lieu of
rockbreakers for demolition of structures Use of smaller capacity rockbreakers or lower vibration generating rockbreakers Consider methods of isolating the vibration sensitive structure from the vibration intensive work
area by severing the vibration transmission path using non-vibration intensive means such a sawing
Lighting of construction areas (if required) would be orientated to minimise glare and light spill impacts on adjacent receivers
Monitoring
Continuous vibration monitoring will be undertaken whenever vibration generating plant will be working close to or within the recommended minimum working distances
When conducting vibration monitoring within or near the minimum working distances a warning system will be implemented including one or both of an audible andor visual warning alarm andor SMS andor email alerts to site staff
Attended noise monitoring will occur at the nearest noise sensitive receiver when - Requested by Sydney Metro - When noise levels are predicted to exceed the NML by more than 10dBA - When out of hours works continue past midnight - When noise complaints are received
Noise monitoring will determine if the predictions in the noise assessment were accurate
Project Engineer Environmental Site Representative
Environmental Inspections amp Monitoring
Daily (Visual) and weekly (documented)
General observation for noise and vibration mitigation measures onsite Weekly inspections using Georgiou Beakon inspection form
All staff
Reporting HSEQ Monthly Management Meeting Monthly Environmental Performance Report
Project Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 61 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 7A ndash Sydney Metro Out of Hours Application form
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 1 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Out of hours work application form
This form is to be used for formal review and approval of out of hours (OOH) work as it may affect Residential and non-residential receivers This form can be used in accordance with the SM-17-00005396 City amp Southwest out of hours work protocol Each OOH application and all applicable appendices must be submitted to Sydney Metro as one PDF file at least 15 business days prior to the commencement of the proposed OOH work
1 OOH Application
Sydney Metro Project
Eg City amp Southwest Greater West West etc
Contract
Contractor
Application Title
Eg lsquoSmith St service relocation worksrsquo
Application Number
Eg 1 2 3 etc
Application Date
Original submission date (resubmission date in parentheses if applicable)
Relevant Planning Approval
Environment Protection Licence (EPL)
If subject to an EPL state title and number
2 Proposed OOH Work Details
Description of works including
Work methodologies
List of plantequipment to be used (worst case scenario)
Location Map (andor Environmental Control Map) attached as Appendix 1 indicating location of works plantequipment locations and receivers (including distance to nearest receiver for noisiest plantequipment)
Traffic Management Plan andor Traffic Control Plan if applicable as Appendix 2
Timing of works
Including proposed datestimes works are planned to be undertaken outside standard hours
Worst-case number of consecutive occasions affecting the same receiver
Refer to Section 4 for definition of lsquooccasionrsquo
Justification
Demonstrate how the proposed OOH work has been scheduled in accordance with the OOH work period prioritisation list Program acceleration is generally not accepted as a justification
Unless specified otherwise in project-specific documentation the prioritisation of work time periods is as follows
Standard Hours 7am to 6pm weekdays and 8am to 1pm Saturdays (note that Standard Hours for works subject to the City amp Southwest Sydenham to Bankstown planning approval also include 1pm to 6pm Saturdays)
Daytime OOH 1pm to 6pm Saturdays and 8am to 6pm Sundays and Public Holidays
Evening OOH 6pm to 9pm every day
Night Time OOH 9pm to 7am weekday mornings and 9pm to 8am weekend and Public Holiday mornings
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Assessed Noise and Vibration Impacts and Standard Mitigation Measures
Are the proposed works consistent with a prepared Construction Noise amp Vibration Impact Statement (CNVIS) (YN)
If lsquoNrsquo skip this section and move to Section 4
State the title of the CNVIS and attach the section(s) describing the noise and vibration impacts of the proposed works as Appendix 3
Quantitatively summarise the worst-case predicted noise and vibration impacts specific to the proposed OOH work for each OOH period on the nearest receivers and compare these against the respective management levels
For Night Time OOH Period works include a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Worst-case predicted noise impact summary
Worst-case predicted vibration impact summary
Potential sleep disturbance summary (for night time OOH periods only)
Using Table 4 and Table 5 indicate in Table 6
Which Additional Mitigation Measures (AMMs) are applicable for consideration
Which of those applicable for consideration are planned to be implemented
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered respite alternative accommodation etc)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
4 Non-Assessed Noise and Vibration Impacts
Skip this section if Section 3 has been completed in full
A quantitative noise assessment for OOH work is to be carried out in accordance with the Interim Construction Noise Guideline (DECC 2009) This section allows applicants to address these requirements through the following steps
1) Establishing Rating Background Levels (RBLs) and Noise Management Levels (NMLs)
2) Predicting the anticipated noise levels using a quantitative noise assessment
a Works that are not likely to generate high noise impacts for a significant duration may use a preliminary quantitative noise assessment (facilitated within this form) This ensures that all applications as a minimum include a preliminary quantitative noise assessment in accordance with the Interim Construction Noise Guideline (ICNG)
b Works that are likely to generate high noise impacts for a significant duration may require a detailed quantitative noise assessment (eg Construction Noise and Vibration Impact Statement) to be undertaken
c Works that are likely to generate ground-borne or structure-borne vibration andor noise require specialist advice and assessment
3) Comparing predicted noise levels against RBLsNMLs and applying standard mitigation measures as appropriate (ie implementing lsquoall feasible and reasonablersquo mitigation measures in accordance with the ICNG)
4) Considering additional mitigation measures when predicted noise levels exceed RBLsNMLs
The need for a detailed quantitative noise and vibration assessment will be considered by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable) collectively when the predicted noise levels are anticipated to
Exceed an RBL at a residential receiver or an NML at a non-residential receiver by more than 10dBA AND
Affect the same receiver on 10 or more consecutive occasions An occasion is anytime works are carried out
o Between 6pm on a weekday and the start of standard hours the next day OR
o Between 1pm on a Saturday and 8am on a Sunday (or between 6pm on a Saturday and 8am on a Sunday for works subject to the Sydenham to Bankstown planning approval) OR
o Between 8am on a Sunday or public holiday and the start of standard hours the next day
A detailed quantitative noise and vibration assessment should generally include
Derivation of RBLs for residential receivers andor derivation of NMLs for non-residential receivers based on noise monitoring at representative locations and local sensitivities
Detailed noise predictions for daytime evening and night time OOH periods (as applicable) in accordance with Section 45 of the ICNG (including an outline of timing duration and predicted noise levels for each OOH period)
For Night Time OOH Period works a review of potential sleep disturbance impacts in accordance with Section 43 of the ICNG
Detailed predictions of vibration levels for sensitive receivers
Please complete the following Steps 1 to 4
Step 1
RBLsNMLs
If RBLs for residential receivers or NMLs for non-residential receivers have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment or Construction Noise and Vibration Impact Statement for other work activities) enter into Table 3 and attach the supporting evidence as Appendix 3
If no RBLsNMLs have been established use Table 1 to estimate and enter into Table 3
Step 2
Predicted Anticipated Noise Levels
If predicted anticipated noise levels have already been established (eg in an Environmental Impact Statement Review of Environmental Factors detailed quantitative noise assessment) enter the predicted anticipated noise levels into Table 3 and attach the supporting evidence as Appendix 3
If predicted anticipated noise levels have not already been established use Table 2 to estimate anticipated noise aspects for the noisiest plantequipment and enter into Table 3 In Table 3 use these values to calculate the anticipated predicted noise levels
Step 3
Exceedances and Mitigation Measures
Compare the anticipated predicted noise levels to the applicable RBLsNMLs calculate the exceedances and enter into Table 3 In Section 5 provide a description of the standard mitigation measures that are planned to be implemented in order to mitigate the noise impacts (and vibration impacts if relevant) as much as lsquofeasible and reasonablersquo in accordance with the ICNG
Step 4
Consideration of Additional Mitigation Measures
Use Table 4 and the exceedances in Table 3 to determine the applicable Additional Mitigation Measures for consideration Use
Table 6 to indicate which of these measures are applicable for consideration which will be implemented and provide justificationdetails accordingly
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
5 Standard Mitigation Measures
Outline the standard noise mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Outline the standard vibration mitigation measures that will be implemented during the proposed OOH work
Ie Implementation of all lsquofeasible and reasonablersquo mitigation measures in accordance with the ICNG)
Table 1 Noise RBLs and NMLs
Skip this section RBLs and NMLs have already been established in other documentation
Sensitive Receiver Category Estimated RBLs (dBA)
Residential Daytime OOH Evening OOH Night Time OOH
Urban (eg city hubs near busy roads near industrial activity) 55 50 45
Suburban 45 40 35
Quiet rural or isolated 40 35 30
Non-Residential ICNG NMLs (dBA)
Industrial facilities 75 (only applicable when in use)
Offices or retail 70 (only applicable when in use)
Health and educational facilities 55 (only applicable when in use)
Table 2 Predicted Noise Level Aspects
Skip this section if predicted noise levels have already been established in other documentation
Noise Aspect Select the most applicable value for each noise aspect below and enter into Table 3 dBA
1 PlantEquipment Noise Level at 10m
Including non-continuous use reduction (-5dBA) and annoying activity penalty (+5dBA) for as per ICNG (refer to ICNG Appendix B for predicted noise level data)
Underline indicates vibratory generating plantequipment
Impact sheet piling rig 100
Hand-held tamper excavator with hammer rock-breaker drivenvibratory piling concrete saw diamond saw air track drill large dozer hand-held rail grinder
95
Jackhammer rock crusher angle grinder pneumatic hammer medium dozer tracked loader impact wrench
90
Mainline tamper ballast regulator dynamic track stabiliser vibratory roller mainline rail grinder ballast train (pourfill ballast) chainsaw tub grinderlarge mulcher scraper grader super-suckervacuum truck large backhoewheeled front-end loader bored piling pavement profiler fixed crane tracked excavator
85
Small bulldozer small excavator tower crane truck-mounted crane forklift bobcat skid-steer front-end loader road trucktruck and dog dump truck concrete truckpumpmixer compressor non-vibratorylarge pad foot roller whacker packercompactor water cart pavement laying machine asphalt truck and sprayer line marking truck standard penetration testing welder pin puller
80
Concrete vibrator cherry-picker scissor liftelevated work platformFranna crane small backhoe front end loader fence post driver electric drill rig hand held rattle gun generator (dieselpetrol) spreader
75
Lighting tower medium-rigid trucksemi-trailer welding equipment small front end loader 70
Light vehicle hand-tools (no impact) small cement mixer attenuated generator (inside housing)
65
2 Multiple Plant More than one of the noisiest plant being used simultaneously at roughly the same location +5
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
3 Local Screening
Existing screening between site and receiver (buildings cuttings canopies etc) - 5
Temporary screening to be implemented near work site - 10
Acoustic shed or enclosure - 25
4 Distance Attenuation
lt 10 metres 0
10 to 20 metres - 5
20 to 35 metres - 10
35 to 60 metres - 15
60 to 100 metres - 20
100 to 180 metres - 25
180 to 350 metres - 30
350 to 1000 metres - 40
Table 3 Predicted Noise Levels and Exceedances of RBLs andor NMLs (dBA)
Skip this section if Section 3 has been completed in full
Period
(only complete as applicable for each period)
Noisiest PlantEquipm
ent
(state the noisiest
plantequipment to be used during each applicable
OOH period)
Receiver Type
(state lsquoResrsquo or lsquoNon-Resrsquo as applicable for
closest receiver to noisiest
plantequipment)
Enter the most applicable values from Table 2 then add to determine
the Predicted Noise Level
Pre
dic
ted
No
ise L
evel
(1 +
2 +
3 +
4)
RB
L (
for
Res)
NM
L (
for
Non-R
es)
Exceedance
(Predicted Noise Level minus RBL for Res or NML for
Non-Res) 1
Pla
nt
Eq
uip
me
nt
No
ise L
evel
2
Mu
ltip
le
Pla
nt
Eq
uip
me
nt
3
Lo
cal
Scre
en
ing
4
Dis
tan
ce
Att
en
ua
tio
n
Daytime OOH
Evening OOH
Night Time OOH
Refer to OOH period timings under Section 2 of this form
Table 4 Additional Mitigation Measures (AMM) requiring Consideration for Implementation
OOH Period
AMMs that must be considered for implementation
(apply the exceedances from Table 3 to the two OOH period categories below as applicable)
lt= 10 dBA Exceedance
10 to lt= 20 dBA Exceedance
20 to lt= 30 dBA Exceedance
gt 30 dBA Exceedance
Daytime OOH Period ndash LB M LB M IB LB PC RO SN
Evening and Night Time OOH Periods
ndash M LB M IB LB PC SN RO M IB LB PC SN RO AA
AA is only applicable to Night Time OOH periods
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 5 List of Additional Mitigation Measures (AMM)
AMM Abbrev
AMM AMM Descriptions and Guidance
LB
Letterbox-drop
(generic to the project)
A newsletter is generally produced and distributed to the local community via letterbox-drop and the project mailing list These newsletters provide an overview of current and upcoming works across the project and other topics of interest The objective is to engage inform and provide project-specific messages The geographic extent of letterbox-drops is generally centred on the immediate surrounding community within 200 metres from the works site
For works that are subject to the Sydenham to Bankstown planning approval these will include an indicative schedule of likely OOH work for at least the upcoming two month period
M Monitoring
Where it has been identified that specific construction activities are likely to exceed the relevant Rating Background Levels (RBL) andor Noise Management Levels (NMLs) monitoring may be conducted at the affected receiver(s) or a nominated representative location (typically the nearest receiver where more than one receiver have been identified) Monitoring can be in the form of either unattended logging or operator attended surveys The purpose of monitoring is to inform the relevant personnel when the RBLNML has been exceeded so that additional management measures may be implemented
IB Individual Briefings
Individual briefings are used to inform stakeholders about the impacts of high noise activities and mitigation measures that will be implemented Communications representatives would visit identified stakeholders at least 48 hours ahead of potentially disturbing construction activities Individual briefings provide affected stakeholders with personalised contact and tailored advice with the opportunity to comment on the project
PC Phone calls
(andor emails)
Phone calls andor emails (with specific notifications attached) detailing relevant information would be made to identifiedaffected stakeholders within seven days of proposed work The objective of the phone calls andor emails is to support letterbox-drop and specific notifications Phone calls andor emails provide affected stakeholders with personalised contact and tailored advice with the opportunity to provide comments on the proposed work and specific needs
SN
Specific Notifications
(specific to the OOH work)
Specific notifications are letterbox-dropped to identified stakeholders no later than 7 days prior to out of hour construction activities commencing that are likely to exceed the RBLsNMLs Specific notifications may be produced by Sydney Trains or by Sydney Metro (or on behalf of Sydney Metro by a contractor as approved by Sydney Metro)
- Sydney Trains specific notifications cover all works being undertaken by various parties (including Sydney Metro) during designated rail possession periods These specific notifications are delivered 14 days prior to works commencing and are delivered to all properties located within 250m of the proposed works
- Sydney Metro specific notifications focus on proposed Sydney Metro works being undertaken outside of designated rail possession periods and are only produced in the absence of any Sydney Trains notifications covering the proposed works These notifications are delivered 7 days prior to works commencing and are delivered to all properties located within 100m of day works and within 200m of night works
All notifications are emailed to all registered stakeholders on site-specific email distribution lists
For works that are subject to the Sydenham to Bankstown planning approval these will include indicative information on the type of OOH work location duration expected noise characteristics expected noise level and likely mitigation and management measures
RO Respite Offer
The purpose of a project specific respite offer is to provide residents subjected to lengthy periods of noise andor vibration impacts respite during OOH periods Respite offers are offers made to affected receivers to provide a period of either no or limited noise impacts This can be in the form of stopping or limiting works onsite or offering affected receivers dinnermovie vouchers The first priority is to implement a period of no or limited noise impacts If this cannot be achieved dinnermovie vouchers may be offered on a case-by-case basis
AA Alternative
Accommodation (residential only)
Alternative accommodation options may be provided for residents living in close proximity to construction works that are likely to incur unreasonably high impacts during night time OOH periods Alternative accommodation will be considered on a case-by-case basis
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Table 6 Consideration of Additional Mitigation Measures (AMM)
Additional Mitigation Measures
Applicable for Consideration
YN
(refer to Table 4)
To be Implemented
YN
JustificationDetails
For AMMs that are applicable for consideration but not being implemented justify why the AMM is not being implemented
For AMMs that are being implemented provide details on how the AMM is being implemented (eg which receivers being offered RO AA etc)
LB
M
IB
PC
SN
RO
AA
For OOH work that is subject to the Sydenham to Bankstown approval and RO is required for consideration include in the lsquoJustificationCommentsrsquo column how community consultation influenced the decision to implement or not implement RO in accordance with Condition E23 If RO is being implemented include how community consultation influenced the manner in which RO is being implemented
6 Consideration Against Relevant Vibration Criteria
Using Table 2 indicate whether any vibratory plantequipment is planned to be used for the proposed works (YN)
If lsquoNrsquo skip this section and move to Section 7
lsquoPeoplersquo Criterion
Are the proposed works anticipated to have any perceptible sleep disturbance impacts (YN)
lsquoStructuresrsquo Criterion
Are the proposed works anticipated to generate greater than 75mms vibration impacts on surrounding structures (generally within 25 metres of works) (YN)
lsquoSensitive Equipmentrsquo Criterion
Are the proposed works anticipated to impact sensitive equipment located in surrounding non-residential receivers (YN)
If lsquoYrsquo is answered to ANY of the above criteria AND the impacts affect the same receiver for more than one consecutive occasion (refer to Section 4 for lsquooccasionrsquo definition) the need to prepare a detailed quantitative assessment will be considered collectively by Sydney Metro the contractor and the Acoustic AdvisorEnvironmental Representative (if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
7 City amp Southwest Construction Noise amp Vibration Strategy Addendum Mitigation Measures
If the proposed OOH work is part of the City amp Southwest project identify any mitigation measures to be implemented that have arisen from the City amp Southwest Construction Noise amp Vibration Strategy Addendum
8 Cumulative Impacts
Document the relevant details of any other OOH work (Sydney Metro or otherwise) that will impact the same receivers as those being impacted by these proposed works either concurrently or within 3 days of the start or end of these proposed works
If other works have been identified in the row above how have the proposed works been coordinated to ensure appropriate respite is provided
9 Community Consultation
What community consultation has been undertaken already
What community consultation is planned to be undertaken
If drafted already attach applicable Community Notification as Appendix 4
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
10 Contractorrsquos Signature
Contractorrsquos Identification of Risk Level
If subject to the Chatswood to Sydenham (C2S) or Sydenham to Bankstown (S2B) planning approval and not subject to an EPL provide Contractorrsquos Identification of Risk Level (refer to the City amp Southwest OOH Works StrategyProtocol for guidance)
Circle LOW or HIGH
Contractorrsquos Signature
Name
Title
Contact Number
Date
11 Contractorrsquos Contact Details
Contractor Personnel Name Mobile
Manager Environment
Manager Communications
Contractorrsquos Representative
Contractorrsquos 24hr contact person
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 10 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
C2SS2B Planning Approval Determination Page
Step 1 ndash Endorsement from Sydney Metro Director Public
Communications or Contractorrsquos Communications Manager
Step 2 ndash Risk IdentificationEndorsement from the AA under the C2S Planning Approval or from the
ER under the S2B Planning Approval
Step 3 ndash If works are under Sydney Trains EPL approval from Sydney Metro Director of Planning Environment and Sustainability
If works are not under an EPL approval from either the ER or the Secretary of the NSW Department of Planning amp Environment
Risk Level NA
If not subject to an EPL circle Risk Level as LOW or HIGH
If works are HIGH Risk Level and after 9pm Sydney Metro submits application to the Secretary of the
NSW Department of Planning amp Environment for approval
NA
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Role
Date
Comments
(including AAER Risk Level comments if applicable)
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 11 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Generic Determination Page (ie not subject to C2S or S2B planning approvals)
Step 1 ndash Sydney Metro Director of
Project Communications
Step 2 ndash Acoustic Advisor
(may be optional depending on planning approval or contract requirements)
Step 3 ndash Environmental Representative
(may be optional depending on planning approval or contract requirements)
Step 4 ndashSydney Metro Director of Planning Environment amp Sustainability
(only required if not approved already)
Action Endorsement Circle Endorsement or Approval Circle Endorsement or Approval Approval
Signature
Approved Road Occupancy LicenceRoad Opening Permit (if applicable) must be sighted prior to endorsement
Name
Date
Comments
Conditions
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 12 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 1 Location Map (andor Environmental Control Map)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 13 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 2 Traffic Management Plan andor Traffic Control Plan
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 14 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 3 Supporting Evidence for Noise amp Vibration Impacts (eg Construction Noise amp Vibration Impact Statement noise assessment etc)
(if applicable)
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 15 of 15
SM-17-00000115 CEMP Appendix 7A - OOHW application
Appendix 4 Community Notification
(if applicable and already drafted)
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 62 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Objectives amp Targets
Refer to the Site Objectives amp Targets (section 57 of this CEMP) Any site contamination will be effectively managed to limit the potential risk to human health and the environment Spoil will be managed to avoid contamination of land or water Prioritise reuse of contaminated spoil into the project rather than offsite reuse or disposal
Project Manager
Performance Criteria
100 Compliance with Client amp legal requirements 100 achievement with Site Objectives amp targets 100 achievement of relevant Sydney Metro CEMF objectives
Project Manager
Planning and assessment
Planning
The Golders Douglas Partners contamination assessment report (June 2020) considered investigation results and data from previous relevant Sydney Metro West (SMW) investigations in the general area The physical characteristics of the soil on site as determined by the above report is described as ldquofill material described as containing evidence of anthropogenic materials including ash gravels terracotta tile fragments bricks and glass In addition to this sandstone bedrock was regularly encounteredsuspected to be present (eg drilling method refusal) during the pavement investigation This evidence implies that there is a wide variety of soil types and materials across the Site associated with natural and historical anthropogenic related activities The findings included elevated concentrations of heavy metals (copper nickel zinc) encountered at one location on the Site and several within close proximity to the Site However the exceedances were considered to pose a low risk to ecological receptors given that the majority of the Site is covered in asphalt hardstand with very low potential for exposure to subsurface soils Elevated concentrations of BaP were encountered in several boreholes within close proximity to the Site Once again the risks to ecological receptors from these were considered low due to the presence of asphalt hardstand at the Site Asbestos was identified at one borehole SMW_BH415 at a depth of 05 m The laboratory reported that chrysotile was detected below the reporting limit of 01 gkg The report considered due to the location access nature of the ACM (bonded) that there is a low risk of exposure to potential receptors Should the soil not be able to be reused on site further sampling assessment and waste classification must occur for any soil that is to be disposed offsite in accordance with the Sydney Metro Waste Classification Procedure (Appendix 1A)
Project Manager HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 63 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
Unexpected finds of contamination onsite
In the event that contamination is identified on site Appendix 8A will be followed for soil contamination excluding Asbestos material For unexpected Asbestos Finds Appendix 8B will be followed
Supervisors All workers
Assessment
If any potential contamination is discovered during construction the soil will be excavated and transported to the stockpile area for assessment which may include sampling by a suitably qualified environmental consultant
The assessment must consider whether the material is suitable to return to site for reuse with consideration to the final land use and pathways and receptors for the contaminants
Laboratory testing associated with the assessment will be prioritised to 24 hour turnaround to mitigate any delay where required
The assessment detailing the type extent and management options for the contaminated soil must be provided to Sydney Metro before proceeding to either reuse or dispose of material
For unexpected Asbestos finds the controls listed in the section below must be followed before any excavation and transport to stockpile or offsite
Project Manager Supervisor Environmental scientist
Asbestos management measures
Access Restrictions
Signs and barriers will be erected to warn of the danger and to prevent unauthorised people entering areas where asbestos contaminated fill material is being excavated handled
The location and extent of any access control areas will be agreed in discussion between the Project Manager Project Engineer HSE Advisor and the Environmental Coordinator and will be established in accordance with NOHSC2002 (2005) Code of Practice for the Safe Removal of Asbestos (2nd Ed) guidelines
Potential entry points to the asbestos work area should be signposted or labelled in accordance with AS 1319 (1994) Safety Signs for the Occupational Environment and NOHSC 2002 (2005b)
Earthworks Engineers Licenced removal contractor Supervisors
Asbestos Removal
For unexpected Asbestos finds the Certified Occupational Hygienist will conduct a risk assessment to demine Air monitoring requirements and any other PPE and management controls prior to removal (see air monitoring section)
All removal procedures for asbestos should be undertaken under the supervision of an appropriately licensed contractor which is either ASA or ASB depending on the material being removed The removal of material shall be monitored by a relevantly trained supervisor in accordance with the Code of Practice for the Safe Removal of Asbestos [NOHSC 2002 (2011)]
You must be licensed to remove asbestos except if removing 10 square metres or less of non-friable asbestos
Engineers Certified Occupational Hygienist Licenced removal contractor
Workcover notification Permit to Work
A permit to work authority will need to be issued to and signed by the contractor Workers engaged in the removal of asbestos on site will not be issued with a permit to work unless
Engineers Licenced removal contractor
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 64 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
they are employed by a company holding a removal licence issued by WorkCover NSW appropriate for the type of asbestos materials concerned
Workcover must be notified at least five days prior to commencement of asbestos removal work
Safe Work Method Statement and Asbestos Removal Plan
All notification and permit applications for removal of asbestos in soils must be accompanied by a site risk assessment (Asbestos Removal Plan) carried out by a competent or licensed person who determines If the asbestos is bonded or friable The extent of contamination A safe work procedure for the remediation of the site
Engineers Licenced removal contractor
Dust Control
In order to remove the asbestos safely we shall be using the ldquowet methodrdquo to carry out these works The wet method includes continuously keeping the soil with asbestos fragments watered so as to eliminate the asbestos dustfibres becoming airborne An exclusion zone of 10m (or whatrsquos appropriate ndash depending on limitations) will be isolated from the rest of the site using fencing or bunting Any personnel that do not have the correct PPE or relevant training will not be allowed in this area
Supervisors Earthworks Engineers
Clearance
Following the excavation and removal of asbestos contaminated material a licenced asbestos assessor will conduct inspections and sampling (where required) in the excavation to confirm that no asbestos remains A clearance report will be issued and works can recommence in the area
Licenced Asbestos Assessor
All potential contaminated finds
Training
A toolbox must occur for all worker for unexpected contamination finds procedure They will also be informed of the Site specific controls required for management of contamination in soil Site access restrictions Correct use of PPE Decontamination procedures Use of monitoring equipment Waste handling procedures Dust control measures and performance measures
all workers
Stockpile Contingency Measures
The following contingency measures will be put in place should stockpiling of potential contaminated soils be required All potential contaminated stockpiles will be separated by lot numbers and sign posted to
avoid any cross contamination Any temporary stockpiles of asbestos contaminated soil will be maintained under moist
conditions and remain covered at all times Sediment controls will be installed downslope of all contaminated soil stockpiles In order to confirm that all contaminated soil has been removed an Environmental
Consultant (ADE) will conduct a visual inspection or sampling of the material below the
Supervisors Earthworks Engineers
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 65 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
stockpile and provide a clearance certificate or the like as legislated The Environmental Consultant will advise of the validation criteria dependant on the contamination of the soil
Material tracking for contaminated finds assessed as suitable for onsite reuse
Where suspected contaminated material is identified the material will be tracked from the area in which the material was identified to its location in stockpile (lot number)
For all material assessed as suitable for reuse onsite the material will be tracked from its stockpile location to final destination for reuse onsite Survey will determine the m3 and the location of the final destination
All materials movements associated with unexpected contamination finds will be recorded on the materials tracking register
Supervisors Earthworks Engineers
Waste classification for materials assessed unsuitable for onsite reuse
Waste classifications are required for any excavated soil or fill material which is to be disposed off-site Soil or fill material to be taken off-site for disposal shall be assessed in accordance with the waste classification guidelines (NSW EPA 2014) Materials excavated from the site should be tracked from lsquocradle to graversquo in order to provide detailed and accurate information about the location and quantity of all materials from the time of their excavation until their disposal For any truck or bin leaving the site the following information would be recorded origin of material material type waste classification report approximate volume truck andor bin registration number Receiving licenced facility For all soils known or having the potential to contain asbestos the following applies The POEO Act defines lsquoasbestos wastersquo as any waste that contains asbestos including
fragments or fibres It is understood that as a result the NSW EPA considers asbestos contaminated soil to be an asbestos waste In addition the Protection of the Environment Operations (Waste) Regulation 2014 provides certain requirements for the transportation of asbestos It is understood that the NSW EPA requires any management of soil containing asbestos waste on or off the site to be at least equal to controls set out by the Regulation
All asbestos contaminated soil or fill leaving site will be transported in a leak proof covered vehicle and disposed of at a licensed facility in accordance with waste classification guidelines (NSW EPA 2014)
Earthworks Engineers Licenced removal contractor ESR
Environmental Monitoring amp records
Air Monitoring
If asbestos removal work that requires a Class A licence that means it is friable then you must get the licensed asbestos assessor occupational Hygienist to undertake air monitoring of the asbestos removal area Monitoring for airborne asbestos in accordance with the Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres
Earthworks Engineers Licenced removal contractor Hygienist
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 66 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8 ndash Contaminated Land Management Sub Plan Responsibility
[NOHSC 3003(2005)] the analysis should be carried out by a NATA accredited laboratory during the removal operations Refer to Clause 50 and 51 for the WorkCover 2011 Safety Regulation for requirements
For other contaminated soil the occupational hygienist may determine that the risks associated with their disturbance and handling requires air monitoring
Record Keeping
The records associated with management of contaminated land that should be kept include Material tracking register including lots volume and type Asbestos Removal Plan (ARP) Asbestos Register Airborne Monitoring Reports Calibration certificates for air monitors Clearance Inspection Reports or Certificates Waste classification reports Laboratory sampling results Landfill disposal dockets
Earthworks Engineers ESR HampS Manager
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 67 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 8A ndash Unexpected Contamination finds procedure
1 Introduction
The following unexpected contaminated finds procedure will be adopted in the event that potential contamination
is discovered during construction Implementation of this procedure will ensure that contamination is managed in
such a way as to avoid harm to the environment workers community and comply with relevant legislation
2 Identification of Contamination
An unexpected find of contamination is likely to comprise of any soil characteristic which is not a typical soil
material identified in previous contamination assessment reports The Golders Douglas Partners contamination
assessment report (June 2020) section 102 makes note of indicators of contamination as
Significant staining
Odours from Soils
Oily sheen on water leaving soils
Anthropogenic waste materials other than those identified in the report (ie Ash Gravels Terracotta Tile
Bricks and Glass)
Where the soil characteristics are consistent with the reports and the above indicators are not present then no
further assessment is required for onsite reuse
Examples of these indicators are shown below
Photo 1 - Significant Staining or odorous soils
Discoloured soil (soil with non-natural colouring) Pungent smelling soils - petroleum compost
putrefied sulphurous septic sweet aromatic odours
Photo 2 ndash Oily Sheen on water
Rainbow sheen on water surfaces in soil
GC-HSE-PLA-437 Uncontrolled when saved or printed
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Photo 3 ndash Buried wastes
Buried oil drums chemical container
Photo 3 ndash Buried wastes
Buried demolition wastes (eg concrete tiles bricks asphalt timber metal
3 Potential risk areas of unexpected finds
The higher risk activities for encountering unexpected finds during construction activities are considered to be
excavation works that extend below road pavement layers and into general fill
Higher risk areas for encountering unexpected finds construction are considered to be
Areas of excavation that extend through general fill layers and into natural soils eg Stormwater trench
locations
Locations of excavation near previous Boreholes with identified contamination (see map below)
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4 Unexpected finds flow chart
If potentially contaminated soils are encountered the following steps must be followed
During excavationif visual indications of contamination are present such as significant stained soils
odorous soils sheen tarry or ashy material or unexpected anthropogenic material (other than what is
expected to be encountered on site) then
STOP EXCAVATION in the immediate affected area
Notify the Supervisor Environmental Site Rep and Client
Environmental consultant to conduct assessment on material to determine suitability for reuse onsite This
step may require sampling and lab analysis ndash undertake with quick 24hr turnaround
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No Yes
Sample test and classify in
accordance with Appendix
1A ndash Sydney Metro Waste
Classification procedure
Contact environmental consultant and hygienist and provide details of the find Depending on the nature and type
of the find they may be required to attend site before any further excavation disturbance
Excavate the material to the extent of the potential contamination in 200mm thick layers and in 500mm
horizontal increments (Do not exceed design excavation extents) and move to stockpile area (Where it will be
allocated a lot number and signposted to avoid any cross contamination) For Asbestos follow specific
requirements in the unexpected Asbestos Finds Procedure Cover the stockpile and install controls around the
stockpile
Offsite disposal at licenced
landfill facility Maintain all
waste tracking and disposal
records
No
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5 Materials Tracking
A Material tracking Register will be used to ensure information is collected for unexpected finds materials
identification and traceability This register records all unexpected finds materials The material is carefully
inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location and type of soil stored onsite
at the stockpile area The material class and stockpile number on the map will correspond with the information in
the register
6 Stockpile Management
The following contingency measures will be put in place should stockpiling of suspected contaminated soils be
required
All suspected contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Sediment controls will be installed downslope of all suspected contaminated soil stockpiles
7 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential contamination onsite as detailed in previous contamination assessment reports and this unexpected finds
procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works
Prior to commencement of each shift the Supervisor will inform all site personnel of any works involving
contaminated materials on site
8 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 8B ndash Unexpected Asbestos finds procedure
1 Introduction
The following Asbestos Management procedure will be adopted in the event that potential asbestos containing
material (ACM) or actual asbestos is uncovered during construction Implementation of this procedure will ensure
that asbestos is managed in such a way as to avoid harm to site personnel visitors and the community
2 Areas of known asbestos contamination
No asbestos was identified with the footprint of the proposed road construction works However there was one
Borehole (BH 415) from previous contamination assessments adjacent to the boundary that identified asbestos at
05m bgs The laboratory result was chrysotile detected below the reporting limit of 01 gkg (see location on map
below)
3 Identification of Asbestos
Asbestos has been used in the manufacturing of various products and these products can be found in either friable
or non-friable form All products are also known as asbestos-containing material Friable asbestos products are
generally quite loose and when dry can be crumbled into fine material or dust with light pressure such as
crushing with your hand
Non-friable asbestos products are made from a bonding compound (such as cement) mixed with a small proportion
(usually less than 15) of asbestos Non-friable asbestos products are solid rigid and non-friable and cannot be
crumbled pulverised or reduced to powder by hand pressure The asbestos fibres are tightly bound in the product
and are not normally released into the air When theyre in good condition non-friable asbestos products do not
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normally release any asbestos fibres into the air They are considered a very low risk for people who are in contact
with them as long as appropriate safety precautions are used when they are disturbed Non-friable asbestos
products that have been damaged or badly weathered may also become friable for example crushed asbestos
cement sheeting Examples of non-friable and friable asbestos are shown below
Photo 1 ndash example of non-friable asbestos in soil This is Asbestos cement sheeting that although broken it is solid rigid and cannot be crumbled or pulverised by hand pressure
Photo 2 ndash example of friable asbestos ndash this was a section of Asbestos cement sheeting that is weathered and crumbles under hand pressure
Photo 3 ndash example of non - friable asbestos ndash Asbestos cement water pipe in good condition
Photo 4 ndash example of friable asbestos ndash water pipe wrapped with friable woven ACM textile
4 Unexpected Asbestos ACM finds flow chart
In the event that a person on site identifies or disturbs asbestos ACM the unexpected asbestos management
procedure during Construction is summarised below
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Discovery of suspected asbestos containing materials
STOP EXCAVATION in the immediate affected area Demarcate and isolate area from workers
Notify the Supervisor
Suitable for onsite reuse
Provide client the results of assessment before proceeding to the next
step
Appropriate geotechnical assessment
confirms the material is suitable for
proposed final land use
Yes
Maintain tracking register for the
soil from cradle to grave include
test results surveyed volume and
final destination
No
Sample test and classify
in accordance with
Appendix 1A ndash Sydney
Metro Waste Classification
procedure
Yes
Friable Non Friable
Proceed with Licenced
Asbestos removal work in
accordance with section 6 -
11 Remove to stockpile for
reuse assessment by
Environmental Consultant
No
Greater than
10m2 of non-
friable asbestos
contamination
Less than 10m2 of
non-friable
asbestos
contamination
Proceed with non-
licenced asbestos
removal and
disposal in
accordance with
section 5
Trained and competent person to identify the asbestos
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5 Non Licence Asbestos removal work
Where small fragments of ACM or suspected ACM are found and provided that
the total number of fragments is lt 20 or
the total surface area of the fragmentpiece is lt 1 m2 or
the fragments are spread over an area of lt 10 m2 and
the fragments are non-friable
If the unexpected find meets the criteria above a trained and competent person will collect any fragments and
place it in a 200 mm polythene bag for later disposal at an appropriate waste facility A detailed visual inspection
of the area will be carried out by the Environmental consultant which will involve wet raking of the areas to a
depth of 10 cm for any further fragments If no further fragments are identified works can continue
If during the visual inspection the Environmental consultant determines that the criteria described above are
exceeded or if suspected asbestos ACM continues to be identified during excavation works andor if it is thought
that any uncovered material might be considered asbestos containing and friable works will cease and the
Environmental consultant will assess the situation and determine an appropriate course of action
6 Licenced Asbestos removal work
A licensed asbestos removalist will be required for removal works where there is friable asbestos or the
contaminated area is greater than 10 m2 There are two types of asbestos removal licences Class A and Class B
The type of licence required depends on the type and quantity of asbestos or ACM to be removed as outlined
below
Licence type What asbestos can be removed
Class A Can remove any amount or quantity of asbestos or ACM including any amount of friable asbestos or ACM any amount of asbestos-contaminated dust or debris (ACD) Any amount of non-friable asbestos or ACM
Class B Can remove
any amount of non-friable asbestos or ACM Note A Class B licence is required for removal of more than 10 m2
of non-friable asbestos or ACM but the licence holder can also remove up to 10 m2 of non-friable asbestos or ACM
ACD associated with the removal of non-friable asbestos or ACM Note A Class B licence is required for removal of ACD associated
with the removal of more than 10 msup2 of non-friable asbestos or ACM but the licence holder can also remove ACD associated with removal of up to 10msup2 of non-friable asbestos or ACM
No licence required Can remove
up to 10 m2 of non-friable asbestos or ACM ACD that is associated with the removal of less than 10 m2 of non-friable
asbestos or ACM Not associated with the removal of friable or non-friable asbestos
and is only a minor contamination
The licensed asbestos removalist will prepare an Asbestos Removal Control Plan prior to the removal of any
asbestos ACM The Asbestos Removal Control Plan documents the specific control measures to be implemented to
ensure site personnel and others are not at risk when asbestos removal work is being conducted It includes how
the asbestos removal will be carried out including temporary storage the method tools equipment and PPE to be
used and the asbestos ACM to be removed including the location type and condition of the asbestos ACM
The Client will be informed prior to excavation or removal of asbestos or ACM If the removal activity is to occur in
the vicinity of any occupied residence or business the project Community Advisor will notify the affected
residents or business owners
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7 Signage and demarcation
Georgiou will install warning signs and labels to clearly identify asbestos affected areas and where asbestos related
work is being carried out Flagging will be installed to delineate the asbestos related areas and restrict
unauthorised persons from entering the asbestos removal work Stockpiles will be covered and labelled Signage
and flagging will stay in place until all licensed asbestos removal work is complete and a clearance certificate is
provided
8 Notification
Prior to the commencement of licensed asbestos removal works notification to SafeWork NSW is required
SafeWork NSW requires a minimum of 5 daysrsquo notice prior to the removal of asbestos and the notification will be
made by the licensed asbestos removalist
9 Air Monitoring
All air monitoring requirements will be determined and conducted by a licensed asbestos assessor (LAA) The
location and layout of the air monitors will be detailed within the Asbestos Removal Control Plan
Air monitoring requirements will vary depending on the type of asbestos being removed the location and position
of the asbestos The following rules should be applied when determine if air monitoring is required (extract from
Safe Work Australia ndash Code of Practice on How to Safely Remove Asbestos (2016)
For friable asbestos removal ndash Air monitoring is mandatory for all friable asbestos removal This includes prior
to dismantling an enclosure and for the purposes of the clearance inspection
For more than 10 msup2 of non-friable asbestos removal ndash Air monitoring is not required but may be considered to
be carried out by a licensed asbestos assessor or competent person to ensure compliance with the duty to
eliminate or minimise exposure to airborne asbestos and to ensure the exposure standard is not exceeded
Public Location ndash Air monitoring should be considered where the asbestos removal work is being undertaken in
or next to a public location
Exposure air monitoring ndash Air monitoring should be carried out at other times to determine a workerrsquos exposure
to airborne asbestos if based on reasonable grounds there is uncertainty as to whether the exposure standard
may be exceeded and a risk assessment by a competent person indicates it is necessary Since most uses of
asbestos are prohibited exposure monitoring should not be required frequently
The results of air monitoring will be made available as soon as possible to all workers on site The asbestos
supervisor will be notified immediately if the fibre count exceeds the recommended level in the Exposure
Standards for Asbestos as set out in the National Code of Practice How to safely remove asbestos
10 Clearance
Following removal of asbestos ACM the licensed asbestos removalist will arrange for a clearance inspection of the
area to facilitate the issue of a clearance certificate and allow construction to recommence in the affected area
The clearance inspection is conducted by
an independent licensed asbestos assessor for work that was carried out by a Class A licensed asbestos
removalist
an independent competent person for asbestos work that is not required to be carried out by a Class A licensed
asbestos removalist
To be independent the licensed asbestos assessor must not be involved in the removal of asbestos for that specific
job and is not involved in a business or undertaking involved in the removal of the asbestos for that specific job
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A clearance certificate will be issued if the independent licensed asbestos assessor or competent person is satisfied
that the asbestos removal area and the immediate area are free from visible asbestos contamination Entry to the
area will be permitted following confirmation of certification
11 Decontamination
Decontamination of site personnel PPE and tools used in asbestos removal work will minimise exposure and spread
of asbestos outside of the removal area
Personal decontamination will occur every time a worker leaves the asbestos removal work area and involves
removal of all visible asbestos dustresidue from PPE and Respiratory Protective Equipment using an asbestos
vacuum cleaner and or wet wiping with a damp cloth Disposable PPE is considered asbestos waste and will be
disposed of at an appropriate waste facility Non-disposable protective clothing will be laundered in a suitable
laundering facility that is equipped to launder asbestos-contaminated clothing
Workers must be aware of personal hygiene and ensure that they carefully wash when leaving an asbestos removal
area paying particular attention to hands fingernails face and head
Tools will be dismantled (where appropriate) cleaned under controlled conditions and decontaminated prior to
removal from the area or disposed of at a suitable off site location
12 Stockpile Management
The following contingency measures will be put in place for any temporary stockpiling of asbestos contaminated
soils
All asbestos contaminated stockpiles will be separated by lot numbers and sign posted to avoid any cross
contamination
Any temporary stockpiles of asbestos contaminated soil will be maintained under moist conditions and remain
covered at all times
Sediment controls will be installed downslope of all contaminated soil stockpiles
In order to confirm that all contaminated soil has been removed validation sampling beneath stockpiles will
occur by an Environmental Consultant
13 Asbestos contaminated soil for reuse onsite
Stockpiled asbestos containing soils will be assessed for beneficial re-use with the Site (NEPC 2013) Any soils
identified to contain asbestos with concentrations of bonded ACM less than the NEPC (2013) Health Screening Level
(HSL)-D applicable for the future commercial industrial land use could be reused onsite providing the following
Placement in a designated location preferably beneath a road alignment or other suitably capped area (min
300 mm lsquocleanrsquo (ie ENMVENM soils) to eliminate any potential airborne exposure pathway
Occupational hygienist and asbestos removalists on-site supervising relocation and placement
Maintenance of an Site Asbestos Register to record the extent nature of the ACM materials retained or
identified on-site
Any other requirements by Sydney Metro such as adherence to the CEMP etc and or land conditions
A Long-term Environmental Management Plan to manage the presence of asbestos impacted materials remaining
on-site would be required if the proposed soils to be re-used are exceeding the HSL-D limits for non-friable or
friable asbestos
If stockpiled soils are identified to contain any detectable concentrations of Friable asbestos material is
recommended to be disposed off-site given its friable nature
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14 Waste disposal
Where the ACM is assessed as non-suitable for onsite reuse the licensed asbestos removalist will classify and dispose
of the ACM at a licensed asbestos waste disposal site in accordance with NSW EPA guidelines (including Waste
Classification Guidelines (EPA 2014)) and relevant industry codes of practice
Disposal of ACM will be to an approved asbestos waste facility listed on the NSW EPA website The transportation of
asbestos waste by trucks must comply with the following requirements
Transporter must have the appropriate EPA license to transport asbestos waste
Asbestos contaminated soils are wetted down
Any part of any vehicle in which a person transports asbestos waste is covered and leak proof during
transportation
Georgiou will notify the Client prior to removal of ACM from site and will provide details of the proposed method
and location of disposal Georgiou will maintain records of all asbestos ACM disposed off site the location of the
facility at which it was disposed and any receiptcertificate issued by the facilitydisposal authority
15 Materials Tracking
A Material tracking Register will be used to ensure information is collected for the movement of all asbestos
contaminated soils The material is carefully inspected ensuring the following information is recorded
Source identification
Contamination assessment results
Waste classification report ndash if unsuitable for onsite reuse
Volume of material (survey)
Destination identification (survey)
This register will track the movement of soils between excavation and final deposition this includes stockpiling
and testing and suitability classification will be recorded
In addition to this register a stockpile location map will be used to show the location of asbestos contaminated soil
stored onsite at the stockpile area The stockpile number on the map will correspond with the information in the
register
16 Training
All site personnel (including sub-contractors) will undertake an induction to ensure that they understand the
potential risks associated with asbestos management locations of asbestos as detailed in previous contamination
assessment reports and this unexpected finds procedure
A specific unexpected contamination finds toolbox will be conducted with all workers involved with excavation
works and include the unexpected asbestos finds procedure Prior to commencement of each shift the Supervisor
will inform all site personnel of any works involving contaminated materials on site
17 Review
This Plan will be reviewed in the following circumstances
Following a site inspection or work review that highlights an unexpected risk associated with the
implementation of this procedure
Following a change in legislation
Following a change in construction methods
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Appendix 9 ndash Sydney Metro Incident and non-compliance reporting procedure
Unclassified
Unclassified
Environmental Incident and Non-
compliance Reporting Procedure SM-17-00000096
Sydney Metro Integrated Management System (IMS)
Applicable to Sydney Metro
Document Owner Manager Environment
System Owner Executive Director Safety Sustainability amp Environment
Status FINAL
Version 51
Date of issue 18 February 2019
Review date 11 February 2020
copy Sydney Metro 2019
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 2 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table of contents 1 Purpose and scope 4
2 Introduction 4
3 Definitions 4
4 Accountabilities 5
5 Environmental Events 5
51 Worked Example ndash Classifying Environmental Events 7
511 Soil and Water Issue 7
512 Soil and Water Non-compliance 7
513 Soil and Water Incident 7
52 Notifiable Events 8
53 Event Types 8
6 Environmental Incident Classification and Management 10
61 Incident Classification 11
611 Class 3 Incidents 11
612 Class 2 Incidents 11
613 Class 1 Incidents 12
62 Incident Notification 12
621 Principalrsquos Representative (PR) 12
622 Environmental Lead (EL) 13
63 Incident Notification Reports 14
64 Incident Investigations 14
65 Environmental Incidents with Health and Safety Impacts 14
66 Reporting Pollution Incidents to Relevant Authorities 15
661 Maritime Related Incident Notification and Reporting 16
67 Environmental Compliance Register 16
7 Environmental Non-compliance 17
71 Non-compliance Rate 17
8 Corrective and Preventative Actions 18
81 Action Status 18
9 Related Documents and References 19
10 Superseded Documents 19
11 Document History 19
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 3 of 19
Environmental Incident and Non-compliance Reporting Procedure
Figures Figure 1 Environmental Event Classification Process 6 Figure 2 Environment Incident notification process for Class 1 and 2 Incidents 13
Tables Table 1 Examples of Notifiable Events 8 Table 2 Environmental Event Types and their descriptions 9 Table 3 Examples of Environmental Incidents 10 Table 4 Classification System for Environmental Incidents 11 Table 5 Contact details for Relevant Authorities 15
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 4 of 19
Environmental Incident and Non-compliance Reporting Procedure
1 Purpose and scope
This procedure documents the process to be used when classifying and reporting Environmental Events
This procedure applies to Sydney Metro and any contractor Sydney Metro engages to carry out works Principal Contractors must ensure their processes for managing Environmental Events is consistent with this document The requirement for consistency is documented in the Construction Environmental Management Framework (Section 33(f)) and shall be allocated as a contractual requirement to each delivery partner
2 Introduction
Sydney Metro is committed to minimising risks to the environment the rapid identification and rectification of breaches to Environmental Requirements and efficient and effective responses to Environmental Incidents that grows our ability to minimise harm and prevent future re-occurrences
This procedure defines an approach to classifying Environmental Issues Incidents and Non-compliances and establishes the immediate interim and long term actions that are taken in response to Environmental Events
3 Definitions
All terminology in this Procedure is taken to mean the generally accepted or dictionary definition with the following exceptions
Term Definition
Environment
means components of the earth including
a) land air and water and
b) any layer of the atmosphere and
c) any organic or inorganic matter and any living organism and
d) human-made or modified structures and areas and includes interacting natural ecosystems that include components referred to in (a)-(c)
Environmental Event
An occurrence that identifies actual or potential environmental impacts or non-compliances Events cans include conversations inspections incidents or failures of process
Environmental Harm Includes any direct or indirect alteration of the environment that has the effect of degrading the environment and without limiting the generality of the above includes any act or omission that results in pollution
Environmental Incident
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Environmental Issue An occurrence or set of circumstances where Environmental Harm or Non-compliance could occur if not rectified
Environmental Non-compliance
A breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 5 of 19
Environmental Incident and Non-compliance Reporting Procedure
Term Definition
Material Harm to the Environment
harm to the environment is material if
a) it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial or
b) it results in actual or potential loss or property damage of an amount or amounts in aggregate exceeding $10000 (or such other amount as is prescribed by the regulations) and
c) loss includes the reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent mitigate or make good harm to the environment
It does not matter that harm to the environment is caused only in the premises where the pollution incident occurs
Terms and jargon specific to this procedure are defined within the Sydney Metro Glossary
4 Accountabilities
The Executive Director Safety Sustainability amp Environment is accountable for this Procedure Accountability includes authorising the document monitoring its effectiveness and performing a formal document review
Direct Reports to the Chief Executive are accountable for ensuring the requirements of this document are implemented within their area of responsibility
The Direct Reports to the Chief Executive who are accountable for specific projectsprograms are accountable for ensuring associated contractors comply with the requirements of this document if specified in the relevant contracts
5 Environmental Events
Environmental surveillance data is relied upon to inform Sydney Metro of performance trends to provide assurance that legislative requirements are being met and indicate where surveillance activities should be directed In order to rely upon environmental data for this purpose there needs to be a high degree of consistency in the manner by which it is collected and interpreted Due to the need for consistency any incidentNon-compliance procedure produced by a delivery partner to Sydney Metro is required to be consistent with the requirements of this document
The concept of Environmental Events forms a common starting point for understanding what types of occurrences should be managed and reported as Incidents and what should be reported as Non-compliances or Issues When an Environmental Event occurs a series of questions can be asked to consistently determine what type of event it is Commonly Environmental Events lead to three different processes
1 Reporting of an Environmental Incident
2 Reporting of an Environmental Non-compliance or
3 Reporting of an Environmental Issue
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 6 of 19
Environmental Incident and Non-compliance Reporting Procedure
Incidents and Non-compliances are recorded using the Environmental Incident and Non-compliance Report Form (SM ES-FT-403) and Environmental Issues are recorded through environmental inspection reports using the Environmental Inspection Information amp Summary Form (SM ES-FT-406) These paper based records are subsequently entered into the Sydney Metro Compliance Register (Section 67) which is used to disseminate the data and facilities reporting internally and externally Note where a Principal Contractor has submitted alternative processes and these have been approved by Sydney Metro they may also be used
The figure below shows the process by which Environmental Events are classified (Figure 1)
Figure 1 Environmental Event Classification Process
Where Environmental Harm has been caused the event will always be classified as an Environmental Incident regardless of whether one or more Environmental Requirements have been breached Only when an event occurs without harm being caused to the environment will it be classified as a Non-compliance or Issue It should be noted that the Incident management process still captures any breaches of Environmental Requirements and these incidents contribute towards the calculation of the NC Rate (Section 71)
This flowchart above is intended to be a guide and there may be situations where it is unclear exactly how an Environmental Event should be classified In these situations a judgement call should be made in consultation with your Manager
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 7 of 19
Environmental Incident and Non-compliance Reporting Procedure
51 Worked Example ndash Classifying Environmental Events
This Section provides a fictitious example of Environmental Events which fall into each of the three different categories The situations outlined below are provided to explain how event classifications are made The background for these worked examples is as follows
Sydney Metro is carrying out works in a newly established site and substantial earthworks are occurring to construct piers for an elevated viaduct A nearby creek contains a variety of important fish species and the local community are known to use this creek for recreational fishing The Environmental Impact Statement identified the creek as being at risk of increased sedimentation from dirty water run-off and the Conditions of Approval include a requirement to have a Progressive Erosion and Sediment Control Plan in place This plan has been produced and indicates that sediment fences must be in place at specific locations to capture dirty water run-off Regular daily inspections of the sediment controls are carried out by the contractorrsquos Environment Manager and an Independent Environmental Representative has commenced a monthly inspection on this site at 7 am on Thursday morning
511 Soil and Water Issue
The Environmental Representative notices a sediment fence has been knocked over in one of the areas indicated as requiring fencing on the ERSED plan It appears to have occurred recently and there is no record of rainfall in the last few days During the course of the inspection all other ERSED controls appeared to be in good condition and erected in accordance with the requirements of the Blue Book In this example no harm has yet been caused and no environmental requirement has been breached so the event is classified as an Environmental Issue which is raised on the inspection report with an action to reinstall the fence
512 Soil and Water Non-compliance
Alternatively the Environmental Representative might have noticed many sediment fences had been knocked down and in some areas an absence of sediment fences where the plan indicates they are required Despite there being no rain in recent days the Environmental Representative concludes that the requirements of the plan are not being followed and have been breached The event is raised as non-compliance and actions are set in place to re-enforce the requirements of the ERSED plan for that sites workforce as well as the immediate reinstatement of controls
513 Soil and Water Incident
Finally in a third scenario the Environmental Representative notices many sediment fences are down and some are absent where required by the plan However significant rainfall has occurred in recent days and the Environmental Representative determines that it is likely dirty water has escaped through the area into the nearby creek potentially causing harm to the fish population This event is classified as an Incident by the inspector and immediate notification is undertaken Similar controls are implemented as described above
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 8 of 19
Environmental Incident and Non-compliance Reporting Procedure
52 Notifiable Events
There are a number of Acts and regulations that include a specific requirement to notify a Regulatory Authority When an Environmental Event triggers one of these notification requirements we then also refer to that event as a Notifiable Event (Table 1)
The Principal Contractorrsquos Environment Manager must determine whether an event is notifiable and may rely upon advice from Sydney Metro if it is provided
Table 1 Examples of Notifiable Events
Event type Legislation Trigger for Notification
Pollution Incident
1
POEO Act 1997 Part 57 Where Material Harm has occurred contact the EPA Pollution Line as soon as practicable POEO (General)
Regulation 2009 Section 101
Land contamination
Contaminated Land Management Act 1997
Section 60(1)
As soon as practicable after becoming aware of contamination that exceeds the relevant investigation levels in the National Environment Protection Measure where a person has or will be exposed to the contamination
Discovery of an Aboriginal relic
National Parks amp Wildlife Act 1974
Section 89A
Director General of EPA in writing within a reasonable time after becoming aware Note this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in the relevant Infrastructure Approval
Discover Aboriginal Remains
Commonwealth Aboriginal amp Torres Strait Islanders Heritage Protection Act 1984
Section 20 Commonwealth Minister of the Environment in writing as soon as practicable after becoming aware
Discovery of a relic
Heritage Act 1977 Section 146
Heritage Council in writing within a reasonable time after becoming aware
Note -this is not required for Projects approved under Part 52 of the Environmental Planning and Assessment Act (see section 115ZG) Notification and reporting is addressed in Infrastructure Approvals
53 Event Types
Each Environmental Event is assigned a secondary classification of an Event Type for the purpose of data analysis and general environmental management They are grouped by areas of environmental management so that targeted auditing training or awareness initiatives can be initiated in response to emergent trends Each Event Type is explained in Table 2
1 Further information on reporting pollution incidents to EPA is provided in Section 66 Environmental
IncidentNon-compliance Report
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2019 Unclassified Page 9 of 19
Environmental Incident and Non-compliance Reporting Procedure
Table 2 Environmental Event Types and their descriptions
Event Type
Applies To
Description Issue Incident
Non-compliance
Soil and Water bull bull bull
Covers the physical location chemical composition and ecology of soils and waterways Any event which changes these compositions is a Soil and Water event Within this event type all instances of contamination erosion and sedimentation of waterways is covered
Flora and Fauna bull bull bull Covers vegetation and vegetation communities as well as animals and animal habitat Any event where vegetation is felled or damaged animals are killed or injured or habitat is harmed or destroyed is covered
Waste and Spoil bull bull bull
Covers the management of Excavated Natural Material (ENM) and Virgin Excavated Natural Material (VENM) including on-site management and disposal and also the classification and management of Waste materials
Note that the transportation of spoil is covered under Traffic Transport and Access
Heritage bull bull bull Covers the management of known heritage artefacts or sites and the treatment of unexpected finds archaeological investigations and other impacts
Air Quality bull bull bull Covers the management of emissions of particulate matter odours and gasses used as air quality parameters from worksites
Noise and Vibration bull bull bull
Covers the management of airborne and ground borne noise and vibration and includes hold points on the commencement of any work where Out of Hours Works permits or Construction Noise Impact Statements are required
Community Stakeholder and Business
bull bull bull Covers the management of Community and Stakeholder requirements and includes complaint response procedure community management protocols and the maintenance of information on websites
Traffic Transport and Access bull bull bull
Covers the management of traffic inside and outside of sites including access points and parking requirements This event type also covers any requirements in relation to vehicles and vehicle maintenance or the transportation of waste and spoil
Spills and Leaks bull bull bull
Covers all instances where environmentally sensitive substances are held within a container which has the potential to leak or spill and covers pipes hoses fuel tanks storage tanks and plastic containers
Note Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Management Systems bull bull bull
Covers procedural or administrate processes that are common across all areas It specifically does not cover procedural or administrate processes which are unique to any of the other event types For example not completing a vegetation removal form prior to vegetation clearing is still a Flora and Fauna event
Note A good example of a Management Systems NC would be not reporting an Environmental Incident within required timeframes
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
6 Environmental Incident Classification and Management
Sydney Metro has defined an Environmental Incident as
An occurrence or set of circumstances as a consequence of which pollution (air water noise and land) or an adverse environmental impact has occurred or is likely to have occurred
Adverse environmental impact includes contamination harm to flora and fauna (either individual species or communities) damage to heritage items or adverse community impacts
Planning Approvals and Environment Protection Licences permit some environmental impacts and these are not intended to be captured as Environmental Incidents
Table 3 Examples of Environmental Incidents
Type Example Incident
Air Quality Odour that travels beyond the site boundary
Air Quality Dust exceeding reasonable levels without active management measures in place
Air Quality Operation or maintenance of plant in a manner that causes or has likely caused excessive air pollution
Soil and Water Discharge of water on or off site in a manner that causes or has likely caused water pollution without required approvals
Noise and Vibration Noise that travels beyond the site boundary as a result of poorly maintained plant or operation of plant in an inefficient manner
Noise and Vibration Failure to comply with the approved hours of work
Soil and Water
Where the chemical composition of soil or water has been detrimentally modified by a contaminant leading to potential or actual environmental harm For example rainfall causes a flow of water across a site that erodes soil and enters a waterway increasing the total suspended solids of that water body
Spills and Leaks
Where a substance has leaked from or spilt from a container that is designed to prevent that substance from escaping into the environment (including bunds fuels tanks chemical bottles and other containers)
Spills and Leaks specifically exclude anything in relation to the transport and deposition of sedimentation
Soil and Water Dispose of waste in a manner that harms or is likely to harm the environment
Flora and Fauna Harm or ldquopickrdquo a threatened species endangered population or endangered ecological community without required approvals
Flora and Fauna Damage to vegetation fauna or habitat including watercourses without required approvals
Heritage Damage disturbance destruction or works to heritage itemsrelics without required approvals
Heritage Damage disturbance or destruction of Aboriginal objects or places without required approvals
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
61 Incident Classification
Environmental Incidents are classified into one of three Classes that are based upon the consequence descriptors for environmental risks in the Sydney Metro Risk Matrix (refer to Sydney Metro Risk Management Standard) Each of these classifications trigger a variety of management actions andor legislative requirements depending on the severity of the consequence described where Class 3 represents minor consequences and Class 1 represents major consequences
This matrix is further sub-divided into consequence ratings ranging from C6 (low impact) to C1 (high impact) An incident transitions between a Class 3 to a Class 2 incident once material harm has been caused and transitions into a Class 1 incident once it is determined that the Environmental Harm caused in large-scale and cannot be remediated (Table 4)
Table 4 Classification System for Environmental Incidents
Class 3 Class 2 Class 1
C6 C5 C4 C3 C2 C1
No appreciable changes to
environment andor highly
localised event
Change from normal conditions
within environmental
regulatory limits and environmental effects are within site boundaries
Short-term andor well-contained environmental effects Minor
remedial actions probably required
Impacts external ecosystem and considerable
remediation is required
Long-term environmental impairment in
neighbouring or valued
ecosystems
Extensive remediation
required
Irreversible large-scale
environmental impact with loss of
valued ecosystems
611 Class 3 Incidents
These Incidents are events which cause Environmental Harm but do not cause Material Harm to the environment Normally Class 3 Incidents are not Notifiable Events and therefore a simple notification protocol is adopted whereby Sydney Metro must be notified within 48 hours verbally and in writing
In some cases it will be unclear whether Material Harm has been caused in the early stages of Incident Management If this is the case then the process for Class 2 Incidents is followed (see Section Class 2 Incidents) until it is clear that Material Harm has not been caused
A formal Incident Investigation report is not required for Class 3 Incidents however it is expected that the person responsible for completing the Incident Notification Report makes appropriate enquiries to determine the likely causal factors involved and assigns effective corrective actions
612 Class 2 Incidents
These Incidents are events which cause Material Harm to the environment and they always trigger notification of Regulatory Authorities These Incidents represent events that are far more serious than Class 3 Incidents and therefore strict communication protocols are required to ensure that effective and informed decisions are made (Figure 2)
The Environmental Lead contract Environment Manager and the Independent Environmental Representative must be notified verbally as soon as possible after the observer becomes aware of a Class 2 Incident
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Class 2 Incidents must be investigated and the investigation must produce an investigation report containing corrective or preventative actions This investigation report must be provided to Sydney Metro within 7 days of the event unless another timeframe is agreed with the EL
Despite any arrangements for the submission of investigation reports an Incident Notification Report must be provided with all available information and submitted to Sydney Metro within 48 hours It is not expected that initial Incident Notification Reports for Incidents under investigation initially include actions as these will be informed by the findings of the investigation The report should be updated with actions resulting from the investigation when available
613 Class 1 Incidents
Class 1 Environmental Incidents are managed in the same manner as Class 2 Incidents expect where a determination is made by the Chief Executive (or delegate) that a Crisis Management Team should be activated In this situation the Sydney Metro Crisis Management Implementation Plan is followed
62 Incident Notification
When and Environmental Event occurs which causes Environmental Harm in all cases both verbal and written communication of the incident must be carried out immediately and within 48 hours respectively For Class 1 and 2 Incidents the notification process shown in Figure 2 must be followed Written communication of Environmental Incidents is via an Incident Notification Report (Section 63)
This process includes specific roles and responsibilities within Sydney Metro and our delivery Partners who are required to take notification actions in response to Incidents
This notification process has been developed to ensure that crucial information about Incidents is captured early and communicated to specific individuals who can ensure the Environmental Impacts are minimised and efficient and effective responses to the event are implemented
In particular the Principals Representative and the Environmental Lead for Sydney Metro play a crucial role in the communication of Incidents within Sydney Metro and these roles are explained in more detail below
621 Principalrsquos Representative (PR)
Each works package establishes a contractual interface for communication between the contracted party and Sydney Metro Generally this interface is between the Principal Contractors Project Director and an appointed representative of Sydney Metro called the Principals Representative
All formal written communications must pass between these two individuals electronically using TeamBinder The Principals Representative holds certain responsibilities in the Incident management Process outlined in Figure 2
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
622 Environmental Lead (EL)
Where this procedure is applied to a works package an Environmental Lead (EL) will be selected for the relevant works package The Environmental Lead must possess environmental experience and competency in managing Incidents and be a representative of Sydney Metro for those works This representative holds specific responsibilities outlined in Figure 2
Figure 2 Environment Incident notification process for Class 1 and 2 Incidents
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Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
63 Incident Notification Reports
For all Incidents an Incident Notification Report must be completed and submitted to Sydney Metro within 48 hours These reports satisfy the requirement for written communication to Sydney Metro and are completed using the Environmental Incident and Non-compliance Notification Report (SM ES-FT-403) or a similar and consistent form approved by Sydney Metro
64 Incident Investigations
Environmental Incident Investigations must be carried out for all Class 1 and Class 2 Incidents Investigations may also be requested for any other Environmental Event at the discretion of Sydney Metro This discretion is likely to be exercised where incidents of a similar nature are occurring repetitively
When conducting an Environmental Incident investigation they must
Be led by a lead investigator who is suitably independent investigator capable of arriving at objective findings and is experienced in conducting environmental incident investigations
Consider the need for legal privilege during the investigation process in consultation with legal counsel
Be informed by all available information that is relevant to the investigation
Analyse the timeline of events which led up to and followed the occurrence of Environmental Harm including the immediate incident response
Be conducted in a manner that is consistent with recognised investigation techniques such as ICAMS
Gather and record evidence
Seek the input of key stakeholders and
Identify Preventative and Corrective actions and document these in the Incident Notification Report
65 Environmental Incidents with Health and Safety Impacts
It is possible that where an Event occurs that causes Environmental Harm harm is also caused to the health safety or wellbeing of people In these situations there will also be a Health and Safety Incident process undertaken which is separate to the process outlined in this document
While the definition of the Environment covers people under the POEO Act the management of impacts upon them are carried out using the Health and Safety Incident Management protocols This is because Health Safety and Wellbeing requirements are governed by a range of legislation other than the POEO Act and this procedure is not comprehensive in that regard Sydney Metro has well established processes to manage impacts on people without the need for the Environmental Incident Process to intervene
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
Furthermore where Environmental Events cause harm to both the lsquoenvironmentrsquo and people it is possible that the root causes for the respective impacts are different It is also possible that differences in the severity of the impacts trigger inconsistent notification requirements and investigation levels It is prudent to identify appropriate and effective corrective actions that reduce the risk of impacts to both people and the environment therefore separate Incident Management Processes are undertaken in these situations
For more detail on the management of Health and Safety Incidents please refer to the Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
66 Reporting Pollution Incidents to Relevant Authorities
If an Incident or Non-compliance is a Notifiable Event then a report must be provided to the relevant Regulatory Authority within the timeframe(s) specified by the relevant legislation Pollution Incidents which are causing or threatening Material Harm to the environment must be reported to each of the following authorities immediately after project personnel become aware of the Incident as required by Section 148 of the POEO Act 1997 The contact numbers for these authorities are listed in Table 5
Table 5 Contact details for Relevant Authorities
Type Example incident
EPA Environment Line 131 555
Local Authority Local Council (specific to area)
Ministry of Health Public Health Unit (refer to httpwwwhealthnswgovauPagesdefaultaspx to confirm local area contact details)
SafeWork NSW 131 050 or contactsafeworknswgovau
Fire and Rescue NSW 000
Relevant information required to be given to EPA when making a notification is specified in Section 150 of the POEO Act 1997 as follows
Time date nature duration and location of the incident
Location of the place where pollution is occurring or is likely to occur
Nature the estimated quantity or volume and the concentration of any pollutants involved
Circumstances in which the Incident occurred (including the cause of the Incident if known)
Action taken or proposed to be taken to deal with the Incident and any resulting pollution or threatened pollution and
Other information prescribed by the regulations
All relevant information known at the time of making the notification must be reported If the information required by (c) (d) or (e) above is not known at the time of initial notification but becomes known afterwards it must be reported to each authority immediately after it
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(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
becomes known Verbal notification must be followed by notification in writing within seven days of the date on which the Incident occurred
Pollution Incidents are not required to be reported if the Incident has already come to the attention of the EPA or the Incident involves only the emission of an odour
Failure to report a pollution Incident as required by the POEO Act 1997 is an offence
Where any work or activity is regulated by an Environment Protection License (EPL) notification of a pollution Incident to the EPA should be made by the licensee Thus where the contractor holds the EPL for the project notification to EPA shall be made by the contractor
For any work or activity that is not regulated by an EPL notification of pollution Incidents to EPA shall be made by Sydney Metro unless the contractor is instructed otherwise by Sydney Metro This includes pollution Incidents that occur as a result of pre-construction activities which may be undertaken prior to an EPL being required for a project Pre- construction activities are determined by the Planning Approval and may include for example geotechnical investigations or surveys
Where the Environmental Representative determines there to have been a significant off-site impact on people or the biophysical environment the program Director Sustainability Environment and Planning will notify the Secretary of the Department of Environment and Planning within 48 hours in accordance with Project Infrastructure Approval Conditions This notification will be followed by a full written report within seven days of the date on which the incident occurred
661 Maritime Related Incident Notification and Reporting
Marine Incidents involving vessels and personnel on board vessels must be reported to the Australian Maritime Safety Authority in accordance with the guidance published on their website at
Australian Maritime Safety Authority Incident Reporting and
Reporting obligations of owners and masters of domestic commercial vessels
67 Environmental Compliance Register
The Environmental Compliance Register is used to manage the information associated with reporting of Environmental Events This register is maintained by the Manager Environment and may be used by a variety of individuals to input data For access to the register or information on its use contact the Manager Environment
This register analyses the data it contains and produces environmental compliance statistics that are used to meet a range of reporting and environmental management requirements
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
7 Environmental Non-compliance
An Environmental Non-compliance is a breach of an Environmental Requirement originating from Planning Approvals Environment Protection Licenses lease agreements and other requirements documented in environmental management plans It is important to note that regardless of whether an event is classified as a Non-compliance or an Incident the process behind managing the event remains the same with the following exceptions
Non-compliances are not notifiable to Regulatory Authorities under the POEO Act
Non-compliances are reported to have occurred on the day the breach was raised as opposed to the date when the requirement was breached (this is to preserve historical reporting and analysis ndash see Section 71)
Non-compliances are not divided into severity classes (Section 52)
Non-compliances do not have the potential to trigger crisis or emergency management processes and
There is an informal notification process in the immediate timeframe following a Non-compliance being raised
When an Environmental Event occurs that causes Environmental Harm and also breaches one or more Environmental Requirements then an Incident Notification Report will be created which records what requirements were breached
If a Non-compliance is identified then it must be raised using the Environmental Incident and Non-compliance Report Form within 48 hours by the party responsible for the breach
71 Non-compliance Rate
A key environmental performance statistic used by Sydney Metro is the Non-compliance Rate This statistic provides a standardised way of comparing the performance of different projects or contractors The NC Rate is calculated using the following formula
= (119873119862119904 + 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119903119886119894119904119890119889 119894119899 119898119900119899119905ℎ) + (119874119901119890119899 119873119862119904 + 119874119901119890119899 119868119899119888119894119889119890119899119905119904 119908119894119905ℎ 119887119903119890119886119888ℎ119890119904 119891119903119900119898 119901119903119890119907119894119900119906119904 119898119900119899119905ℎ119904)
119879119900119905119886119897 119873119906119898119887119890119903 119900119891 119874119899119892119900119894119899119892 119877119890119902119906119894119903119890119898119890119899119905119904) 119883 100
Each month a count of the number of NCs raised and Incident raised where Environmental Requirements have also been breached is counted Added to this number is the number of these events which were raised in previous months that still held an Open status in the current reporting period Non-compliance and incident Events are considered Open if any of the associated Actions are Open The total is divided by the number of Environmental Requirements which are actively being complied with (Ongoing Requirements) and a multiplying factor of 100 is applied
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
8 Corrective and Preventative Actions
Whenever an Environmental Event is raised actions will be assigned to the event irrespective of whether it is an Issue Incident or Non-compliance These actions will generally be Corrective Actions which are implemented to eliminate the cause of the Incident Non-compliance or Issue and can be thought of as reactive measures in response to the Environmental Event
Preventative Actions may also be assigned to prevent the occurrence of an Incident Non-compliance or Issue and can be considered pro-active measures which may be recommended following a detailed investigation of the event
Actions must
Limit impacts as far as is reasonably practicable
eliminate risk where practicable
where is it not practicable to eliminate the risk follow the hierarchy of controls
address root causes and contributing factors and
be prioritised based on risk
The Executive Director Safety Sustainability amp Environment must ensure there are systems in place to
monitor corrective action status
escalate issues to the executive where progress on a corrective action is inadequate and
retain all corrective action responses for recording purposes
81 Action Status
Actions are allocated to a person who will take accountability for ensuring it is carried out within a timely manner and completed by the due date
Actions are either closed immediately if the Action has already been carried out and verified by Sydney Metro or are created with an open status The Action will remain in an open state until such a time as Sydney Metro verifies that the responsible person has completed the Action in a satisfactory manner Until all actions associated with an Incident Non-compliance or Issue are closed the original Environmental Event is considered to be open as well This is relevant when calculating the NC Rate as open Non-compliances and Incidents contribute toward the calculation of this statistic
Verification is determined by the Environmental Lead by sighting evidence of the Actions implementation
Unclassified
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
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Environmental Incident and Non-compliance Reporting Procedure
9 Related Documents and References
10 Superseded Documents
11 Document History
Related Documents and References
Environmental amp Sustainability Management Manual
Risk Management Standard
Health amp Safety Incident Reporting amp Investigation Standard (SM-17-00000040)
Crisis Management Implementation Plan
Environmental Incident and Non-compliance Notification Report
Environmental Inspection Information amp Summary
Sydney Metro Glossary
Superseded Documents
There are no documents superseded as a result of this document
Version Date of approval Notes
10 31 March 2015 New document
20 7 July 2016 IMS Review
30 7 April 2017 IMS Review
40 23 November 2018 IMS Review
50 11 February 2019 IMS Review
51 18 February 2019 Minor correction to formula
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 79 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 10 ndash Sydney Metro Environmental Inspection template
Sydney Metro ndash Integrated Management System (IMS)
(Uncontrolled when printed)
copy Sydney Metro 2016 CEMP Appendix 10 - Sydney Metro Inspection template Page 1 of 1
Environmental Inspection Report Template
Contract
Contractor Date
Inspection Number Time
Location
Weather
Attendees
Site Activities
Item No
Key Issues Action Party
Priority
(L M H)
Inspection by
Name Title Signature
Date
Copy to
- All attendees
-
-
-
GC-HSE-PLA-437 Uncontrolled when saved or printed
Always refer to GENIE for latest version
Page 80 of 80
12082020 Ver 30 Print Date 17-Nov-20
CEMP Bays Road Relocation Works
Appendix 11 ndash Georgiou Environmental Policy
COMPANY POLICY
Rob Monaci Chief Executive Officer Georgiou Group September 2020
ENVIRONMENTAL
Georgiou is committed to minimising where reasonably practicable its impact on the natural environment and social surroundings for the benefit of current and future generations while enhancing Georgioursquos environmental performance
In order to achieve this commitment Georgiou will
set environmental objectives and targets applicable to the aspects and potential impacts of projects and facilities
establish positive relationships with community and stakeholders
comply with all applicable environmental laws regulations statutory obligations and client environmental requirements
identify significant environmental aspects and develop effective and appropriate mitigation measures to minimise environmental impacts
provide measures to protect heritage biodiversity land and waterways
manage potential community impacts related to air quality noise and vibration
practice responsible resource use and waste management including the promotion of efficient use reuse and recycling of resources
implement and maintain Georgioursquos management system and practices to meet its business needs ASNZS ISO 14001 client and other obligations and
hold employees and subcontractors accountable for proactively meeting their environmental responsibilities
Achieving these commitments is fundamental to demonstrate a positive impact on the environment and communities associated with Georgioursquos activities and developments All employees and persons who work with Georgiou have a personal responsibility for implementing this Policy
SAFE
TY |
PRO
FIT
| RE
LATI
ON
SHIP
S |
PEO
PLE
| IN
NO
VAT
ION