1. 1. DEFINITION:
      Pollution incident means an incident or set of circumstances during or as a consequence of which there is or is likely to be a leak, spill or other escape or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise.
   2. NOTIFICATION:
      A pollution incident is required to be notified if there is a risk of ‘material harm to the environment’:
      
      1. harm to the environment is material if:
         
         1. it involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial, or
         2. 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.

Pollution incidents must be reported promptly to the EPA, NSW Health, Fire and Rescue NSW, Work Cover NSW and the local council.

1. AREAS OF POSSIBLE CONTAMINATION
   
   1. Hardstand Wash Down Area

      The area where boats are hauled out of the water and washed down is a bunded area serviced by drains which flow into the “First Flush” holding tank. Unless the tank is full and overflowing, there is no chance of the drains discharging into Sydney Harbour.

      The “First Flush” system is served by an automatic pump operated via a float switch mechanism. The pump raises the wash down water from the holding tank, through a filtration system and the then pumped via a sump pump into the sewer.

      The wash down of boats is conducted by the yard staff who have been briefed as to what procedures to action, should the “First Flush” system not operate and the drains in the wash down area fill with water. The drains can flood without wastewater discharging into Sydney Harbour.

      The procedure laid down is to cease operation immediately and rectify the fault. If the fault is a lengthy repair, engage a contractor to remove the waste water and thus eliminate any possibility of wastewater running into Sydney Harbour.

      The holding tank to the “First Flush” system can hold seven days of normal wash down waste water and the failure of any discharge pumps is noticed well before any water level in the drainage system becomes a problem.

   2. Hardstand Area

      The most likely pollution on the hardstand area is from paint or oil spill. Should such an accident occur it is likely to be a small amount (4-10 litres).

      A professionally supplied and maintained “Spill Kit” is located nearby.

   3. Chemical and Paint Storage Areas
      The paint and chemical store is bunded to prevent any spills entering the bunded hardstand area.

      A professionally supplied and maintained “Spill Kit” is located nearby.

   4. Diesel & Waste Oil Storage
      A Diesel Storage Tank and Waste Oil drums are contained in their individual bunded platforms. The bunded platforms are also within the “First Flush” bunded area.

      A professionally supplied and maintained “Spill Kit” is located beneath the steel stairs along the north wall of Building 11.

   5. Glue & Resin Storage
      A small quantity of glue and resins is stored in professionally supplied bunded cupboards.

      Should a spill occur it will be maintained within the bunded cupboard.

      Small quantities (1-2 litres) are utilised at times within Building 11 and accidental spills can be dealt with rags.

   6. Marina – Diesel Spill
      Refuelling of boats in the Marina is prohibited. However, should a diesel or oil spill occur, a professionally supplied and maintained “Spill Kit” is stored in the yard office. The Spill Kit contains a floating boom which can be stretched across the dock opening, preventing any contamination to be released into Sydney Harbour.
2. PRE-EMPTIVE ACTIONS TO BE TAKEN
   Pre-emptive actions to minimise or prevent any risk of harm to human health or the environment arising from the activities undertaken at the premises are described above. The first action is to surround any storm water grate to prevent any contamination from entering adjacent waterways.
3. INVENTORY OF POLLUTANTS
   See Schedule ‘A’
4. SAFETY EQUIPMENT
   Safety Equipment and Data is located in the Hardstand Storeroom beneath Building 11
5. CONTACT DETAILS
   See Schedule ‘B’
6. COMMUNICATIONS WITH NEIGHBOURS
   Management will maintain verbal communication will be maintained with neighbours.
7. MINIMISING HARM TO PERSONS ON SITE
   A muster location is established to the East of the Deckhouse Restaurant. Management will maintain verbal communication with those on site.
8. MAPS
   See Pollution Response Management Plan – Schedule ‘C’
9. ACTIONS TO BE TAKEN IMMEDIATELY AFTER AN INCIDENT
   Spill containment equipment will be activated.

   First Flush system shall be shut down until the spill is assessed.

   Management shall direct staff as to the appropriate clean-up procedures.

10. STAFF TRAINING
    Regular staff training will be undertaken on a six monthly basis or if staff is replaced.

    Yard management shall undertake ‘toolbox’ talks regarding containment and clean-up on a bi-monthly basis.

    Logs are to be maintained in the office regarding the training dates, etc.

11. MAKING PLANS AVAILABLE
    A copy of the Pollution Management Response Plan is maintained in the EPA Licence folder located above the yard managers desk.
12. TESTING PLANS
    A full simulation test of the plan will be undertaken every 12 months.
13. IMPLEMENTING PLANS
    A pollution incident management response shall be undertaken immediately a pollution incident which meets the requirements of the POEO Act occurs.

Woolwich Dock
March 2015