Licensees under the Protection of the Environment Operations Act 1997 (POEO Act) are required to prepare a Pollution Incident Response Management Plan (PIRMP) for each licensed activity, in accordance with the requirements set out in Part 5.7A of the POEO Act and in Chapter 7 Part 3A of the Protection of the Environment Operations (General) Regulation 2009 (POEO(G) Regulation).
The objectives of these plans are to:
- ensure comprehensive and timely communication about a pollution incident to staff at the premises, the Environment Protection Authority (EPA), other relevant authorities specified in the Act (such as local councils, NSW Ministry of Health, WorkCover NSW, and Fire and Rescue NSW) and people outside the facility who may be affected by the impacts of the pollution incident;
- minimise and control the risk of a pollution incident at the facility by requiring identification of risks and the development of planned actions to minimise and manage those risks; and
- ensure that the plan is properly implemented by trained staff, identifying persons responsible for implementing it, and ensuring that the plan is regularly tested for accuracy, currency and suitability.
The Concise PIRMP contains relevant information that must be made available to the public, including the procedures for contacting the relevant authorities and procedures for communicating with the community in the event of a pollution incident for which there is a risk of ‘material harm to the environment’ within the meaning of section 147 of the POEO Act.
A pollution incident is required to be notified if there is a risk of ‘material harm to the environment’, which is defined in section 147 of the POEO Act as:
1. Harm to the environment is material if:
- It involves 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 $10,000 (or such other amount as is prescribed by the regulations), and
2. 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.
A 'pollution incident' includes a leak, spill or escape of a substance, or circumstances in which this is likely to occur.
Pollution Incident Notification
Immediate Notification of Incident to Relevant Authorities
In the event of any pollution incident site personnel must notify their supervisor immediately who will then contact the Emergency Response Co-ordinator.
The Emergency Response Co-ordinator reports all pollution incidents to the Relevant Authorities immediately* when a pollution incident has been identified as having or as likely to occur.
Regulatory authorities to be contacted include: See attached .pdf file.
*Immediately means promptly and without delay.
Information to be provided
The Emergency Call Log should be used to document a description of the incident. At the time of notification the Emergency Response Co-ordinator should provide the following information:
- the time, date, nature, duration and location of the incident;
- the location of the place where pollution is occurring or is likely to occur;
- the nature, the estimated quantity or volume and the concentration of any pollutants involved, if known;
- the circumstances in which the incident occurred (including the cause of the incident, if known),
- the action taken or proposed to be taken to deal with the incident and any resulting pollution or threatened pollution, if known; and
- other information prescribed by the regulations.
Lack of information should not prevent the Emergency Response Co-ordinator from making an immediate notification. As additional information becomes known, it must be notified immediately to each of the authorities listed in the table above.
Communicating with Neighbours & the Local Community
During an emergency situation it may be necessary to communicate the state/type of the emergency, the possible cause, its effects/consequences, likely duration and impact to potential stakeholders.
These early warning and updates will ensure the stakeholders have the information needed to minimise any risk of harm from the incident.
All information that is communicated to external stakeholders must be authorised by the Emergency Response Coordinator and/or the Chief Operating Officer. Decisions to notify neighbours and the local community will be made in consultation with regulatory authorities.
Stakeholders that may require notification include:
- Neighbours, local landowners and community representatives;
- Metgasco employees and family members;
- Insurers and lawyers.
Contact details for relevant stakeholders for each assets covered by the PIRMP are contained within the Metgasco Consultation Database.
Methods of Communication to the Community include:
- Personal visits;
- Letter box drops and newsletters;
- Emails to community representatives;
- Local radio announcements;
- Newspaper advertisements.
Site Emergency Contact Details (See .pdf file attached).
PIRMP Operational Flow Diagram (See .pdf file attached)
PIRMP Team Organizational Structure (see .pdf file attached)