Your next step is to establish, implement, control and maintain operational controls to achieve your identified environmental performance objectives.

Operational controls are actions taken to mitigate risk of harm to an acceptable level which under the Act is so far as reasonably practicable. Options for controlling risk, described in Assessing and controlling risk: A guide for business (EPA publication 1695), may be placed in three categories:

• Elimination: the most effective control is to eliminate the hazard and any associated risk altogether.
• Substitution of the hazard / engineering controls: the second most effective controls reduce a risk by substituting the cause of the hazard with something safer or controlling the hazard with engineering controls. To be effective, these controls should operate independently of peoples’ actions.
  • Substituting the cause of hazard with a safer alternative takes priority over implementing controls.
  • Engineering controls are physical controls for a hazard. Examples include bunding and automatic shutdown systems for machinery.
• Administrative controls and use of personal protective equipment (PPE): The least effective controls rely on people doing the right thing or taking care at all times.
  • Administrative controls include training, procedure, policy, supervision or shift designs that lessen the threat of a hazard or at least help alert people to a hazard. Examples include induction processes, permitting systems and competency training.
  • Personal protective equipment (PPE) and spill kits, etc., should be used if individuals could be directly exposed to harmful pollution or waste.

Together, these elements create a ‘hierarchy’ of risk controls.

These controls can be used individually or in combination using the hierarchy of elimination, substitution, and administration. They can, for example, address air emissions across an entire site, surface water protection within an operating area, or a single activity such as acceptance of priority wastes for treatment.

The type and number of operational controls will depend on the nature of your activities, your risks and opportunities, environmental aspects, and compliance obligations. Remember, they are there for you to use as tools to manage your environmental performance. The better they reflect your company’s activities, the easier they will be to understand, the clearer the operating requirements and the more useful and effective they will be for you. Ideally, operational controls should be developed and maintained by suitably experienced persons (that may include consultants) and include contribution of information from employees and managers who work with those activities.

The level of detail provided in each operational control should reflect the complexity of the activities and potential severity of the environmental impact it is controlling. The following information has been aimed at a middle to large sized organisation with potential environmental impacts.

Operational control procedures

Operational control procedures provide a direct guide for implementing the controls to manage environmental aspects and meet your environmental performance objectives. Where possible, your procedures should be referenced in your risk register to provide a link to the risks being controlled through your procedures. Depending on your management systems and operational scale, these procedures can have the following structure:

• purpose;
• scope (description of aspect);
• definitions;
• responsibilities;
• procedure; and
• records.

Purpose

This section provides a brief, clear description of what the procedure is to be used for. For example; ‘to establish a process for controlling odour emissions from the rendering plant’.

 

Scope

This section describes the elements being managed by the procedure. This may be the environmental aspect involved or the environmental impacts that are being controlled. For example, ‘this procedure identifies management actions and performance standards to protect the quality of surface water discharged from the site’. Section 25(5)(b) of the Act requires you to provide information regarding your activities to ensure they can be used in a manner that complies with the GED.

 

 

Definitions

This section lists and provides the meaning of any specific terms relevant to the procedure. Depending on what the procedure is addressing, these may be terms such as: ‘environmental aspect’, ‘work instruction’, ‘odorous compound’, ‘pollution’, ‘engineering control’, ‘priority waste’.

 

Responsibilities

Personnel responsible for implementation of the various requirements of the procedure are identified in this section. You need to ensure that responsibility for each part of the procedure is allocated to a person, and that person is aware of the responsibility, has the training, resources and time to discharge that responsibility.

For example, ‘The Production Manager must ensure that this procedure is maintained, and all associated work instructions are allocated and implemented’, ‘the Site Supervisor must ensure that the product unloading area is inspected and maintained in accordance with this procedure’. Some personnel can be assigned multiple responsibilities. It is a good idea not to allocate all tasks to a single person and to ensure that there is a backup should the responsible person leave the company or is not able to conduct their allocated tasks.

 

Procedure

This is the most substantial section of the operational control procedure. It provides details of actions to control the elements of site activities or environmental impacts described in the procedure’s scope. The procedure can be supported by work instructions that provide detailed directions for performing a task or activity that avoids, reduces or controls risks of harm to human health or the environment.

 

This section of each operational control procedure should clearly specify how all stages of your risk management process are to be done. It needs to be comprehensive so that your personnel will know exactly what tasks they need to complete and how to do them. Just as importantly, if asked, you should present the procedure to EPA to demonstrate how you are meeting your GED obligations.

If a required task is complex, you can write environmental work instructions for that task. Your operational control procedure would then refer to that work instruction. You may list references to work instructions or background documents at the end of the procedure.

Depending on the nature of the risk being managed by the operational control procedure, you may need to include some, or all, of the items listed in this section. Each item listed here is accompanied by example text for a hypothetical bunded area and for a bag house as a guide.

• Describe the specific element/aspect of the activities being controlled.
  • Escape of product spilled in the oil loadout bay.
  • Discharge of process air from the dry mineral separation plant flue.
• Describe the process control used to minimise the risk.
  • The control is designed to capture and retain liquids that have been spilled in the oil loadout bay.
  • The dust content of air discharged from the dry mineral plant flue is controlled by filtration through cloth filters in the baghouse.
• Specify how the control equipment operates.
  • The bunded area is a backup structure that is designed to capture and retain liquids accidentally spilled in the oil loadout bay. Oil drums are not to be emptied into this area.
  • Exhaust air from within the dry mineral separation plant housing is extracted and passed through a bag filter before being discharged to air from the plant discharge flue.
• Specify plant operation requirements to avoid upset conditions.
  • The holding capacity of the bunded area is designed to hold the capacity of road transport tankers that use the loadout bay. It therefore must be kept sufficiently empty to maintain that capacity.
  • The air bag filter must treat all air discharged from the dry mineral separation plant flue sufficiently well to meet the EPA licence air discharge condition (or environmental performance indicator).
• Describe how the environment protection control is to be monitored.
  • The bunded area is to be visually inspected daily. The bunded area is to be cleaned annually using a pressure jet and closely inspected for cracks or other potential leakage points.
  • The bag filters are fitted with a differential pressure gauge linked to the Supervisory Control and Data Acquisition system (SCADA) . The system produces a visible and audible alarm if the pressure goes outside of set limits. The plant flue discharge air quality is sampled and tested annually. The filter system is shutdown annually and inspected for condition of the bag fabric and housing.
• List the environmental performance indicators. These operational limits should be measurable or clearly described.
  • As an ongoing requirement, the bund walls must be intact and the bunded area kept free of accumulated spills, stormwater, litter, or unauthorised materials (oil drums). The design capacity of the bunded area is to be maintained and any accumulated rainwater removed when it exceeds [your specified limit].
  • The plant SCADA system shows an alarm-free status, differential pressure gauge shows [NN bar], there are no visible particles in flue discharge, and solid particulate level in stack emission sample less than [NN mg/m3].
• Identify the location of monitoring points.
  • The bunded area around the oil loadout bay including the bunding itself, the submersible pump and pipework used to pump out the bund.
  • The control room SCADA system, differential pressure gauge at the end of the baghouse, and the baghouse dryer stack sampling port.
• Describe plant upset or failure indicators.
  • There is a failure of bund wall integrity (an emergency failure), visible cracking in a bund wall, or the bund does not retain liquid (leakage through the base). External indicators of failure can be that there is staining of the ground next to bunded area, overgrowth or death of vegetation down-slope of the bunded area, staining of surface water down-slope of the bunded area.
  • The SCADA triggers a visible and audible alarm, the differential pressure gauge shows abnormally high or low pressure, the filter fabric is torn or blinded, visible particles are seen in flue discharge air, there is a build-up of deposited dust underneath the plant flue.
• Describe how to respond to the upsets.
  • Stop work within the bunded area if there is a loss of capacity. Remove excess liquid waste in the bunding for disposal or treatment. Remove any litter from the bunded area. Repair any cracks or have the bund inspected by a suitably qualified engineer, and repair any defects.
  • Close down the dry mineral separation plant that discharges air to the bag house. Implement a maintenance cycle or inspect and conduct necessary repairs.
• Identify requirements for maintenance and testing of control equipment.
  • Every year pressure clean and inspect the bunded area for integrity and condition of fittings.
  • Test the SCADA alarm system weekly. Conduct an annual inspection of air filtration bags and repair or replace worn, blocked, or damaged bags. Calibrate the differential pressure gauge.
• Specify any reporting requirements.
  • Record your observations in the daily log in the folder kept in the control room next to the bunded area. Report any overflows immediately to the area supervisor. Report any signs of litter or accumulated materials to the area supervisor before the end of your shift. Record annual inspection results in the bunded area record sheet in the inspection folder. Take photos as part of the recording process. These records are to be copied weekly and stored in a secure place.
  • Maintain the SCADA records in a secure operating system. Store the air sampling and analysis report in a secure location. Record and retain the plant inspection and maintenance records in the asset management system.

Records

• Identify how actions taken as part of the operational control are to be recorded and the records securely retained.
  • Record the results of all bund inspections, cleaning and testing in a dedicated oil loadout area bunding inspection log. Once each page of the log is filled, transfer it to a secure location for future reference and review if required.
  • Record the results of all visual checks of SCADA alarm tests, air discharge quality tests, differential pressure gauge inspections, air filtration bag inspections and keep the records in a secure system. Record all upset conditions and remedial actions taken.