PL EV 01 Environmental Management Plan Rev.6 PDF

NEOEN Solar Farm Project
Environmental
Management Plan
Doc ID: PL-EV-01
Rev No.: 6
Rev Date: 09/03/2017
Prepared By:
Reviewed by:
David Glossop
Approved By:
Tony Wood
Snr Environment and
Marie Chuet
Sustainability Site Superintendent /
Coordinator OHS Manager Project Director
Id no.:PL-EV-01
Environmental Management Plan
TABLE OF CONTENTS
1 INTRODUCTION ................................................................................................................... 5
1.1 Purpose ........................................................................................................................ 5
1.2 Environmental Management System ............................................................................. 5
1.2.1 Environmental Management Plan (EMP) ..................................................................... 5
1.2.2 Management Sub-Plans ................................................................................................ 5
1.3 Document Responsibilities ............................................................................................ 6
1.4 Document Amendment and Distribution ........................................................................ 6
1.4.1 Revision Status .............................................................................................................. 6
2 PROJECT DESCRIPTION......................................................................................................... 7
2.1 Project Overview .......................................................................................................... 7
2.1.1 Working hours............................................................................................................... 7
3 DEFINITIONS........................................................................................................................ 7
4 ORGANISATION ................................................................................................................... 9
4.1 Project Organisational Chart ......................................................................................... 9
4.2 Responsibilities and Authorities................................................................................... 10
5 POLICIES............................................................................................................................ 10
6 BYCA OBJECTIVES, KPIS AND TARGETS ............................................................................... 10
6.1 Performance Measurement and Monitoring ................................................................ 13
6.1 Project Management Review ...................................................................................... 13
7 APPLICABLE REQUIREMENTS ............................................................................................. 14
7.1 Legal Requirements .................................................................................................... 14
7.2 Contractual Requirements ........................................................................................... 15
8 COMMUNICATION & CONSULTATION ................................................................................ 15
8.1 Internal Communications ............................................................................................ 15
8.1.1 Project Site Induction.................................................................................................. 16
8.1.2 Pre-Start Meetings ...................................................................................................... 16
8.1.3 Environmental Toolbox Meetings ............................................................................... 16
8.1.4 Project Notice Board ................................................................................................... 16
8.1.5 Environmental Alerts .................................................................................................. 17
8.1.6 Minimum Project Rules............................................................................................... 17
8.1.7 Works Coordination Meetings .................................................................................... 17
8.1.8 Unplanned Engagement ............................................................................................. 17
8.2 External Communication ............................................................................................. 18
8.2.1 Public Complaints........................................................................................................ 18
8.2.2 Liaison with Authorities and Emergency Services ...................................................... 18
8.2.3 Community.................................................................................................................. 18
9 COMPETENCE, TRAINING AND AWARENESS ....................................................................... 19
10 PROCESS CONTROL ............................................................................................................ 19
10.1 Risk Management ....................................................................................................... 19
10.1.1 Project Environmental Risk Assessment ..................................................................... 19
10.1.1.1 Review Frequencies .............................................................................................................. 20
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10.1.1.2 Subcontracted Work ............................................................................................................. 21

10.1.2 Task Observations ....................................................................................................... 21
10.2 Environment in Design ................................................................................................ 21
10.3 Reporting and Meetings.............................................................................................. 22
11 CONTRACTOR MANAGEMENT............................................................................................ 22
11.1 Environment in Procurement ....................................................................................... 22
11.2 Subcontractor Environmental Management Plan ......................................................... 23
12 EMERGENCY READINESS AND RESPONSES .......................................................................... 23
12.1 Hazard Reporting ........................................................................................................ 23
12.2 Emergency Preparedness ............................................................................................ 23
12.3 Accidents and Incidents ............................................................................................... 24
12.4 Incident Reporting and Records ................................................................................... 24
12.5 Incident Investigation ................................................................................................. 24
13 PROJECT SPECIFIC ENVIRONMENTAL OBJECTIVES ............................................................... 24
13.1 Project Specific Objectives, Factors and Impacts........................................................... 24
13.1.1 Terrestrial Flora and Fauna ......................................................................................... 25
13.1.1.1 Environmental Management Objectives .............................................................................. 25
13.1.1.2 Potential Environmental Impacts ......................................................................................... 25
13.1.2 Weed Management .................................................................................................... 26
13.1.3 Surface Water ............................................................................................................. 26
13.1.4 Soil ............................................................................................................................... 27
13.1.5 Air Quality ................................................................................................................... 27
13.1.6 Noise and Vibration .................................................................................................... 28
13.1.7 Visual Amenity ............................................................................................................ 28
13.1.8 Indigenous Heritage .................................................................................................... 29
13.1.9 Waste and Energy Management ................................................................................ 29
13.1.9.1 Objectives ............................................................................................................................. 29
13.1.10 Chemical Storage and Spill Response Management................................................... 30
13.1.11 Fire .............................................................................................................................. 31

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13.1.12 Ground Disturbance .................................................................................................... 31

14 INSPECTION AND TESTING ................................................................................................. 31
14.1 Site Inspections ........................................................................................................... 32
14.1.1 Environmental Inspections ......................................................................................... 32
14.1.1.1 Inspection Records ................................................................................................................ 33
14.2 Inspection of Plant/Equipment .................................................................................... 33
14.3 Environmental Monitoring .......................................................................................... 33
14.3.1 Noise and vibration monitoring .................................................................................. 33
14.3.2 Water quality monitoring ........................................................................................... 33
14.3.3 Air Quality Monitoring ................................................................................................ 33
14.4 Inspection, Measuring and Test Equipment.................................................................. 34
15 AUDITS.............................................................................................................................. 34
16 NON CONFORMANCE, CORRECTIVE ACTIONS AND PREVENTIVE ACTIONS ........................... 34
17 CONTROL OF RECORDS ...................................................................................................... 35
18 OPERATIONAL CONTROLS .................................................................................................. 35
18.1 Establishment/Commencement................................................................................... 35
18.2 Materials Control and Storage .................................................................................... 36
18.3 Plant and Equipment Control....................................................................................... 36
18.4 Hazardous Substances Management ........................................................................... 37
19 REVIEW CRITERIA .............................................................................................................. 37
Appendix 1 Parkes Overview and Environmental Constraints Map ..................................... 39
Appendix 2 Griffith Overview and Environmental Constraints Map ..................................... 40
Appendix 3 South Keswick Overview and Environmental Constraints Map .......................... 41
Appendix 4 Narromine Overview and Environmental Constraints Map ............................... 42
LIST OF TABLES
Table 1 - BYCA Project Objectives, KPIs and Targets ............................................................................. 10
Table 2 - Plant and Equipment Control ................................................................................................. 36

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1 INTRODUCTION
1.1 Purpose
The purpose of this Environmental Management Plan (EMP) is:
 To reduce the impact on the immediate and surrounding environment by minimising environmental
harm and preventing environmental incidents
 Systematically manage environmental risk
 Where practicable eliminate environmental risk, or if not practicable adequately control via
application of a hierarchy of risk control
 To comply with requirements of:
- the contract specifications
- Legislation prescribed by the relevant Regulatory Authorities
- BYCA Policy
1.2 Environmental Management System

The Project Environmental Management System shall comprise of: Policies
 Policies Manuals
 Environmental Manual (Corporate) Core
 Core Procedures Procedures
 Environmental Procedures Environmental
Procedures
 Environmental Management Plan (EMP)
Management Plans
 Environmental Management Sub-plans
 Forms Management Sub Plans
 Supporting Documentation
Forms
Supporting Documentation
As such, this EMP is aligned to, and mapped with relevant sections of the Environmental Manual and Core
Procedures.
1.2.1 Environmental Management Plan (EMP)

This EMP details environmental management measures, controls, resources and responsibilities required
during the Project to comply with all the requirements of relevant legislation, conditions of applicable
licences, approvals and permits.
Foreseeable aspects of the Project with potential to impact on the environment are addressed in detailed
sub-plans, procedures and the Project Environmental Risk Assessment; to mitigate potential environmental
impacts associated with the Project’s construction works.
1.2.2 Management Sub-Plans

The EMP consists of the main EMP framework (this document) and detailed Management sub-plans and
procedures that have been developed to mitigate potential environmental impacts associated with the
Project’s construction works.

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The Environmental sub-plans document environmental aspects, impacts, objectives and targets, specific
management guidelines, mitigation measures, safeguards, controls and roles responsible for implementing
these specific measures and controls. The following management sub-plans and procedures addressing the
key areas of environmental management for the Project are listed below:
 Flora and Fauna Management Plan;
 Weed Management Plan;
 Soil and Water Management Plan;
 Cultural Heritage Management Plan;
 Waste and Energy Management Plan;
 Fire Management Plan
1.3 Document Responsibilities

This Environmental Management Plan (EMP) must be in place and operational prior to commencement of
construction work.
The project dedicated Project/site Engineer in conjunction with the Project manager, will ensure that the
plan is monitored, reviewed, maintained and updated as necessary during the course of the project.
One hardcopy of the EMP and associated plans will be maintained by the Project/site Engineer (document
controlled revision) for the duration of the contract.
The Project/site Engineer will ensure that each subcontractor is provided with relevant parts of the Project
Environmental Risk Assessment for the preparation and planning of their works.
Where any change is made to this plan that has potential to impact on the health and safety of the
workforce, the environment or the work’s quality; the project dedicated Project/site Engineer, must ensure
details of this systemic change are effectively communicated to the site workforce and relevant
stakeholders.
1.4 Document Amendment and Distribution

Document amendments and distribution will be conducted as per detailed in the PL-CO-01 Project
Management Plan and the PL-QA-02 Records Management Plan.
New and amended documentation issued after the initial approval and distribution of this plan to controlled
copy holders shall be identified in the FS-QA-RG-06 Document Control Register. Revision details shall be
recorded in the Section 1.4.1 Revision Status of this plan.
All changes to documents shall be reviewed and approved by the same function that performed the original
review and approval and as per the cover of this plan, unless specifically designated otherwise.
1.4.1 Revision Status

Revision Revision Date Issued Date Nature of modification
0 21/11/2016 Contract Award revision
1 10/01/2017
2 17/01/2017
3 25/01/2017
4 06/02/2017
5 07/02/2017

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6 09/03/2017
2 PROJECT DESCRIPTION
2.1 Project Overview
Site specific information including project overview and environmental constraints are provided in the
following:
 Appendix 1 – Parkes
 Appendix 2 – Griffith
 Appendix 3 – South Keswick
 Appendix 4 – Narromine
The scope of works includes site preparation and early works, piling, system installation, grid connection,
and testing and commissioning of the solar farms. They are broken down to 4 key stages as follows:
Stage 1 – Early works consisting of piling tests, road construction and upgrades for site access, including
road widening and paving, and a basic right turn and basic left turn for truck entry and exit to each site.
 Basic Right Turn of intersection of Henry Parkes Way and Pat Meredith Drive
 Basic Left Turn of intersection of Henry Parkes Way and Pat Meredith Drive
 Upgrade of Pat Meredith Drive to site entry
Stage 2 – Civil works consisting of land clearing, levelling and earthworks, internal road construction,
drainage installation, laydown area preparation, fencing installation, site establishment, preparation of
delivery station and inverter station, and vegetation screening/landscaping.
Stage 3 – Mechanical works consisting of foundation piling (ramming and auguring), tracker installation,
module installation and delivery.
Stage 4 – Electrical works consisting of solar cabling of aerials and conduits, DC main cabling via direct burial,
MV cabling from inverter station to delivery station through direct buried, module connection, connection of
junction boxes-inverters-delivery station, connection to grid and finally testing and commissioning.
2.1.1 Working hours

The standard hours of operation are:
 7:00am to 6:00pm Monday to Friday
 8:00am to 1:00pm Saturday; and
 No works on Sundays and Public Holidays
The following works are permitted outside these standard hours for Parkes and Griffith:
 The delivery of plant, equipment and materials which is required outside these hours as requested
by police or other authorities for safety reasons; or
 Emergency work to avoid the loss of lives, property and/or to prevent environmental harm
3 DEFINITIONS
Actitudes BYCA initiative that aligns BYCA commitments to the environment and sustainable works, the
community, our customers and the health and safety of our employees
ALARP As Low as Reasonable Practicable (risk management objective)

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BYCA Bouygues Construction Australia Pty Ltd

Class 1 Causes or has the potential to cause pollution or degradation which has or may have long term
Environmental detrimental effects on the environment and/or community and will require extensive
incident remediation.
Class 2 Causes or has the potential to cause pollution or degradation which has persistent (greater than
Environmental three months) but reversible detrimental effects on the environment and/or community
incident
Class 3 Causes or has the potential to cause pollution or degradation which has short-term (less than one
Environmental month) and reversible detrimental effects on the environment and/or community
incident
Dangerous An unplanned incident event that had potential to cause injury or illness to any person, damage
Occurrence (DO) to property or the environment
EMP Environmental Management Plan
Hazard Any source of potential damage, harm or adverse health, safety or environmental effects on
someone or something
Hazardous Any material that, because of its quantity, concentration, or physical or chemical characteristics,
may pose a real hazard to human health or the environment. Hazardous materials may be
characterised by the following properties:
Flammable and Combustible Material ·
Toxic Material
Corrosive Material
Oxidizers
Aerosols
Compressed Gases
HS Health and Safety
Incident Work-related event or occurrence that exposes persons health and safety, the environment or
other objective to risk
OHS Occupational Health and Safety
QSE Quality Safety and Environmental
Notifiable A Notifiable Incident is defined as a pollution incident causing or threatening material harm to the
Incident environment. If an incident is a Notifiable Event then a report must be provided to the relevant
regulatory authority within the timeframe(s) specified by the relevant legislation
Risk Combination of the likelihood and the potential severity of an occurrence
Spill The inadvertent or accidental release of a Hazardous liquid with the potential to harm the
environment, outside of a bounded storage area, or area designed to capture spills
Worker A person is a worker if the person carries out work in any capacity for a person conducting a
business or undertaking, including work as:
(a) an employee; or
(b) a contractor or subcontractor; or
(c) an employee of a contractor or subcontractor; or
(d) an employee of a labour hire company who has been assigned to work in the person's
business or undertaking; or
(e) an outworker; or
(f) an apprentice or trainee or a student gaining experience
Workplace An activity where personnel, equipment and tools are combined to complete a specific task or
duty

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4 ORGANISATION
4.1 Project Organisational Chart

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4.2 Responsibilities and Authorities

Please refer to FS-CO-RR-03 BYCA Project Responsibilities & Authorities.
For Subcontracted work, subcontractor’s responsibilities shall be specified as part of their contract
agreement and on their Subcontractor Environmental Management Plan (when required).
5 POLICIES
Reference documents:
PO-EV-01 Environmental and Sustainability Policy
PO-CO-02 Risk Management Policy
PO-QA-01 Quality Policy
PO-HS-01 OHS Policy
PO-HR-23 Training and Development Policy
6 BYCA OBJECTIVES, KPIs AND TARGETS

Commitment to continuous improvement forms the foundation of the BYCA Management System.
This will be established through the collation, review and analysis of environmental data.
Table 1 - BYCA Project Objectives, KPIs and Targets
PROJECT OBJECTIVES, KPIs AND TARGETS
Objective Key Indicator Unit Target By Frequency
Report CO2 emissions

Report project CO2 Tonnes of CO2 HSE
(energy purchased, _ Monthly
emissions equivalent Coordinator
diesel fuel use etc.)
Ensure that project Notices issued by

ENVIRONMENT AND SUSTAINABLE CONSTRUCTION
activities conform with Environmental

No. of notices Nil Project Team _
legal and BYCA system Protection Authority to
requirements BYCA / Subcontractors
Ensure that project

activities conform with
legal and BYCA system
requirements Documented
Environmental
Ensure effective HSE
Inspection (FS-EV-AT- % 100% Weekly
communication of Coordinator
01 Environmental
matters that have Inspection Report)
potential to impact the
environment and the
community
Ensure that project No. of Environmental

Project
activities conform with Non Conformances
NCs issued Manager,
legal and BYCA system issued by Client, via <10 per CY _
annually HSE
requirements Internal or External
Coordinator
Audits
Ensure effective

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communication of
Project
matters that have Number of Manager,
potential to impact the documented Tool Box % 80% Monthly
environment and the Meetings (TBM) HSE
community Coordinator
Ensure risk
management is Workshops held to Project
aligned to planning of review Project manager,
% 80% Quarterly
high risk activities Environmental Risk HSE
Assessment Coordinator
80% NCs
Ensure Non
closed
Conformances and
Time to Close Non within
Complaints are closed % Project Team N/A
Conformances specified
within the specified
time
timeframe
frame
Ensure Non
Conformances and
Complaints are closed
within the specified 100% of
timeframe Close out of Public No. of complaints Project Team _
Ensure critical QSE Complaints Complains closed ≤ 2
requirements are Weeks
effectively
communicated to
Service Providers

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Ensure Non Percentage of

Conformances and "Significant" or high Project
Complaints are closed risks Subcontracts/ manager,
within the specified Supply Agreements Procurement
% 90% N/A
timeframe procured including a Manager,
CUSTOMERS AND PARTNERS FOR A SUSTAINABLE PROJECT
HSE Specification (FS- HSE

Ensure critical QSE
PC-08 HSE Contract Coordinator.
requirements are
Specifications)
effectively
communicated to
Percentage of
Service Providers Project
"Significant"
manager,
Ensure critical QSE Subcontracts/ Supply
Procurement
requirements are Agreements conducted % 90% N/A
Manager,
effectively with a Pre Contract
HSE
communicated to Meeting (FS-PC-09 Pre
Coordinator.
Service Providers Contract Interview)
Percentage of
"Significant" or high Project
risks Subcontracts/ manager,
Supply Agreements Procurement
% 90% N/A
procured including a Manager,
HSE Specification (FS- HSE
Ensure critical QSE PC-08 HSE Contract Coordinator.
requirements are Specifications)
effectively
communicated to
Percentage of
Service Providers Project
"Significant"
manager,
Subcontracts/ Supply
Procurement
Agreements conducted % 90% N/A
Manager,
with a Pre Contract
HSE
Meeting (FS-PC-09 Pre
Coordinator.
Contract Interview)

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PROJECT SPECIFIC OBJECTIVES AND KPIs
Frequenc
Objective Key indicator Unit Target By
y
Ensure that project Number of Notifiable

activities conform and Class 1 incidents Project Manager, Duration
with legal and BYCA No. 0 Project/site Engineer, of
system Superintendent project
PROJECT SPECIFIC
requirements
All plant and vehicles Project Manager,

Minimise impact of Duration
to have valid and Project/site Engineer,
weeds in % 100 of
signed BYCA weed Superintendent, HSE
construction project
hygiene form Coordinator
6.1 Performance Measurement and Monitoring

Global Environmental objectives are applied by BYCA and are established, implemented and
maintained at two levels:
 BYCA Corporate
 Sites (projects, subsidiaries)
During the mobilisation phase the BYCA Project manager will review and where required develop
additional targets and objectives relative to the contract and project specific risks. Project specific
KPIs will be developed in alignment with the Corporate Objectives and KPIs and based on the Project
Environmental Risk Assessment.
The Project manager is responsible to review performance on a regular basis with the project
dedicated Project/site Engineer, and may further modify targets and objects subsequent to
Management Review meetings.
Please refer to the PL-CO-01 Project Management Plan for further information.
6.1 Project Management Review

The Project manager shall convene a review at least once annually of the project Environmental
Management System. This review aims to assess the adequacy of the Environmental Management
System, project environmental performance, and develop a strategy for continuous improvement.

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7 APPLICABLE REQUIREMENTS
7.1 Legal Requirements
This EMP has been developed to comply with the relevant legislative and regulatory requirements,
Codes of Practice, Australian/Industry Standards, BYCA Manuals and Procedures and contract
requirements.
BYCA will ensure that relevant legislations, Codes of Practice and Standards relating to the project
are accessible to all persons via the BYCA file directory located at: P:\01 Corporate\73 00 QSE
The following environmental Acts, Regulations and Standards are applicable to this project:
NSW
 Environmental Planning and Assessment Act 1979
 Environmental Planning and Assessment Regulation 2000
 State Environmental Planning Policy (Infrastructure) 2007
 State Environmental Planning Policy (State and Regional Development) 2011
 State Environmental Planning Policy No. 55 ‐ Remediation of Land
 State Environmental Planning Policy No. 33 – Hazardous and Offensive
 Development
 State Environmental Planning Policy No. 44 – Koala Habitat Protection
 Protection of the Environment Operations Act 1997
 Roads Act 1993
 Native Vegetation Act 2003
 Water Management Act 2000
 Threatened Species Conservation Act 1995
 National Parks and Wildlife Act 1974
 Heritage Act 1977
Local Government
 Parkes Local Environmental Plan 2012
 Parkes Shire Council Development Control Plan 2013
 Griffith Local Environmental Plan 2014
 Narromine Local Environmental Plan 2011
 Narromine Development Control Plan 2012
 Orana Regional Environmental Plan No. 1 - Siding Springs (Deemed State Environmental
 Planning Policy)
 Dubbo Local Environmental Plan 2011
 Dubbo Development Control Plan 2013
Commonwealth
 Environment Protection and Biodiversity Conservation Act 1999
 Native Title Act 1993
 Renewable Energy (Electricity) Act 2000

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7.2 Contractual Requirements

BYCA have identified the most critical Environmental contractual requirements for the project, these
are:
 Submission and management of approvals through RMS and/or Council
 Comply with the relevant Council and Development Approval
 Produce a Construction, Operation, and Decommissioning Environmental Plan that must
include:
- Soil and Water Management Plan including a spill response plan
- Ground Cover Management Plan
- Weed Management Plan
- Traffic Management Plan
- Cultural Heritage Management Plan
- Vegetation Screening Management Plan
8 COMMUNICATION & CONSULTATION

8.1 Internal Communications
BYCA will implement the following methods for communicating and consulting environmental
information to the workforce:
 Site Induction
 Environmental Risk Assessment
 Toolbox Meetings
 Project Rules
 Occurrence reporting and investigations
 Training
 Pre-Start Meetings
 Project Notice Boards
 Electronic media including email and internet postings
 Environmental Alerts
 Scheduled meetings with environmental inclusive in agenda
 Posters/campaign material
 Unplanned engagement
 Work Coordination Meetings
The Project/site Engineer is responsible for the allocation of tasks associated with the distribution
and display of environmental information on the project e.g. maintenance of Site Environmental
Notice Boards.
Please refer to the PL-CO-01 Project Management Plan for accessing information details.

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8.1.1 Project Site Induction

Prior to commencement on site, all project personnel will undergo a site induction covering
awareness of quality, safety, environment issues and controls. The site inductions will specifically
include details of:
 The importance of all employees and subcontractors to conform with the environmental
policy and procedures and their roles in implementing the policy and procedures
 The significance of their work in relation to potential or actual impacts to the environment
 The importance of complying with procedures and policies for benefit to the environment
 Environmental risks identified as Extreme and High from the Environmental Risk Assessment
and their management measures
 Incident reporting requirements
 Environmental reporting requirements
 Emergency procedures
 Fire Management
 Sediment and Erosion Control
 Waste Management
All persons on site shall be inducted. It is a mandatory requirement that all persons who are not
accompanied on site by a BYCA staff member receive the full site induction. Acknowledgement of
the training will be obtained from participants by signature on a FS-CO-CT-09 Site Induction Record.
Please refer to PL-CO-01 Project Management Plan for further information.
8.1.2 Pre-Start Meetings

The Pre-Start Meeting (FS-CO-CT-01 Daily Pre-Start Meeting) is conducted by the Site Supervisor/
Superintendent prior to the commencement of work tasks/activities (either on a daily/pre-shift
basis). It serves as a forum to communicate significant environmental aspects/impacts and
requirements of the Project/site Engineer.
8.1.3 Environmental Toolbox Meetings

BYCA will discuss relevant environmental aspects during the Toolbox Meetings (FS-CO-CT-02 Toolbox
Meeting Record) to ensure all staff is aware of their responsibilities and any Extreme and High risks.
Meeting minutes are maintained as records of these meetings.
Environmental Toolbox meetings shall be conducted on a monthly basis.
8.1.4 Project Notice Board

The Project/site Engineer will ensure that a project notice board will be set up at each BYCA project.
The project notice board will display critical Environmental information.
The project notice board is used to communicate BYCA Environmental Policies and Procedures,
Emergency Procedures as well as the main environmental impacts and controls.

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8.1.5 Environmental Alerts

In response to a significant incident which has the potential to reoccur, BYCA is committed to
ensuring the incident learnings and any corrective action, is effectively communicated to all BYCA
sites as soon as practicable. BYCA will communicate this information via Safety Alerts where
practicable.
Environmental alerts will communicate to the workforce the prevention measures and controls to be
implemented to ensure that the environmental incident won’t reoccur.
The Environmental Alert will be allocated an ID number and filed.
8.1.6 Minimum Project Rules

The FS-CO-CT-03 Project Site Rules shall be prominently displayed on site at all times. As part of the
induction process, all persons on site shall be informed and be provided with a copy of the project
Site Rules.
Delivery personnel shall receive an induction and are requested to have this induction information
within the cabin of their truck while on site or request a copy prior to entering site.
The minimum site environmental rules to be communicated to workers include, but are not limited
to the following:
 Waste
 Noise and vibration
 Erosion and sediment control
 Hazardous substances
 Aquatic environment
 Biodiversity
 No go zones
 Threatened species and heritage
 Consumption
 Cleanliness and storage
 Community and media
8.1.7 Works Coordination Meetings

Work Coordination Meetings shall convene weekly and include QSE matters as part of their agenda.
Please refer to PL-CO-01 Project Management Plan.
8.1.8 Unplanned Engagement

The Managing Director, QSE Director, Project manager, Project Managers, OHS Manager,
Project/site Engineer, Quality Manager and Site Supervisors will verbally engage with the workforce
while they are on site. The purpose of the engagement will be to provide the workers with an
opportunity to raise any safety, environmental or quality issues they may have or to report hazards.

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Id no.:PL-HS-01
8.2 External Communication

8.2.1 Public Complaints
BYCA will respond to public complaints and emergencies including environmental issues and
incidents. All records of valid complaints causing environmental harm including actions taken to
mitigate complaints and response time to the complainant will be kept and routinely updated on the
FS-QA-RG-09 Project Complaints Register. The complaint will then be investigated and adequate
corrective/abatement actions implemented to mitigate the cause of the complaint and prevent
further environmental nuisance. Corrective actions will be recorded. Complaints will be treated as an
Incident where assessed applicable and the Incident process prescribed above adopted. Reviews and
audits of the project complaints register will be conducted to monitor the effectiveness of mitigation
measures and identify any trends in complaints.
The following details will be recorded for all valid complaints:
 Name, address and contact number for valid complainant
 Time and date of valid complaint
 Reasons for the complaint as stated by the valid complaint
 Investigations undertaken in response to the valid complaint
 Conclusions formed
 Actions taken to resolved the valid complaint
 Any abatement or management measures implemented to mitigate the cause of the valid
complaint
 Name and contact details of the person responsible for resolving the valid complaint
8.2.2 Liaison with Authorities and Emergency Services

At each construction work site, an emergency contact list must be established by the OHS Manager
and the Project/site Engineer as part of Emergency Management requirements and as per the PL-
CO-05 Emergency Management Plan.
The list will contain the contact names and 24-hour telephone contact numbers of all the applicable
authorities and emergency services.
Please refer to the PL-CO-01 Project Management Plan and the PL-CO-05 Emergency Management
Plan.
8.2.3 Community
The local community and relevant agencies will be informed and kept up to date with the operation
and environmental performance of the development through plannined community engagement
meetings as well as through websites set up to provide an overview of each project, FAQ’s, and a
community feedback form where queries or issues can be registered.
 http://dubbosolarhub.com.au/ (South Keswick and Narromine)
 http://parkessolarfarm.com.au
 http://griffithsolarfarm.com.au/

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9 COMPETENCE, TRAINING AND AWARENESS

Project personnel and visitors will receive suitable environmental training to ensure they are aware
of their responsibilities and are competent to carry out their work in an environmentally acceptable
manner. Environmental requirements will be explained to staff during the project Site Induction,
Environmental Notice Board and during Tool Box Talks as necessary.
Project staff (including subcontractors) will be provided with the following environmental
information during the induction and specific environmental training:
 Environmental policies
 Promoting awareness of site-specific environmental topics
 Reporting responsibilities for environmental incidents
 Contingency and emergency planning
 Information within the EMP and related sub plans, including significant project aspects,
impacts and controls
 Environmental objectives and targets for the job
 Regulatory requirements and consequent staff responsibilities
BYCA will manage the training of project personnel, site inductions (project inductions, visitor’s
induction and delivery driver’s inductions) and activity inductions as per the PL-CO-01 Project
Management Plan.
10 PROCESS CONTROL
10.1 Risk Management
BYCA is committed to managing risks by eliminating risk so far as is reasonably practicable, and if it is
not reasonably practicable to eliminate, controlling risks to a level which is As Low as Reasonable
Practicable (ALARP).
BYCA will manage environmental risk in accordance with the PR-CO-03 Risk Management Procedure.
Please refer to the Risk Management Procedure and the FS-CO-RM-01 Risk Level Matrix, for risk
acceptance criteria and hierarchy of controls.
Risks will be assessed at tender stage as well as on the design phase and recorded on the tender risk
register and design risk register accordingly. The Project manager will assign a risk owner for all
residual risk classified as “High” or “Extreme”, and ensure that any open “High” or “Extreme”
environmental risks are transferred onto the Project Environmental Risk Assessment and monitored
in accordance with this EMP and the PR-CO-03 Risk Management Procedure.
10.1.1 Project Environmental Risk Assessment

Environmental aspects and impacts are assessed at all stages of the project lifecycle. BYCA will
develop a preliminary Environmental Risk Assessment (FS-EV-RM-01 Project Environmental Risk
Assessment) for environmental aspects to identify and predict environmental and social impacts
specific to the constructions phase of the project and subsequently develop mitigation measures.
The project Environmental Risk Assessment will consider the following aspects:
 Traffic and pedestrians
 Community

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 Air quality including dust

 Heritage (Indigenous and Non-Indigenous)
 Soil and water
 Contaminated land (including Acid sulphate soils)
 Flora, fauna and weed control
 Waste including spoil
 Asbestos
 Sustainability
 Storage and use of hazardous materials
BYCA Projects are to use the current revision of the Project Environmental Risk Assessment to:
 Communicate risks to subcontractors during tender phase and Kick Off Meetings
 Communicate project risks to site workforce, through Site induction, Environmental Notice
Boards and Tool Box Talks
 Integrate environmental controls into construction methodology planning
 Develop Emergency Management Plans and determine project specific emergency response
requirements
The BYCA Project manager is responsible for the coordination of a Risk Workshop for the
development, and ongoing review of the Project Environmental Risk Assessment.
The Project/site Engineer is responsible to facilitate the Risk Workshops, and finalise the preparation
of the Project Environmental Risk Assessment.
The Project Environmental Risk Assessment shall be developed in the first 4 weeks of the
construction program. Irrespective of the contract type (i.e. Design and Construct, or Construct
Only) the Project manager is responsible for obtaining the FS-DE-RM-02 Design Risk Register from
the Designer and the FS-CO-RM-06 Tender & Project Risk Register from the Tender team.
Any design element that has an Environmental Residual Risk assessed as either, being Extreme or
High, is to be transferred onto the Project Environmental Risk Assessment, and further operational
controls are to be instituted to reduce the risk level (ALARP).
The Environmental Risk Workshop is to consist of a quorum of a minimum of 5 persons, and the
composition of the workshop should be made up of the following persons:
 Project manager
 Project/site Engineer
 Project and/or Site Engineer (for each work location)
 Site Superintendent
 Client Representative
10.1.1.1 Review Frequencies

The Project Environmental Risk Assessment is to be reviewed at quarterly intervals via Risk
Workshops, and may also be required to be reviewed:
 Subsequent to a serious incident
 Where there is a significant change in construction methodology or a legislative change that
may impact the environment considerably
Subsequent to completing each review, members of the Risk Workshop shall be signatories to the
current revision of the FS-EV-RM-01 Project Environmental Risk Assessment.

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The Project/site Engineer is responsible for communicating environmental updates to the Project
Environmental Risk Assessment to all stakeholders including subcontractors, commercial managers
and workers.
10.1.1.2 Subcontracted Work

When the work is subcontracted, subcontractors are responsible for considering environmental risks
on the development of their method of works.
As required, the Project/site Engineer or the BYCA Engineer responsible for procuring the
subcontractor will provide the subcontractor with a copy of the relevant Environmental Risk
Assessment prepared by BYCA.
Subcontractors working on environmental sensitive areas, shall prepare a site specific Environmental
Risk Assessment detailing the job steps and sequence, identifying foreseeable aspects and impacts,
assessing risk level and nominating control measures.
The Subcontractor’s Environmental Risk Assessment should be submitted to the relevant BYCA
Project Engineer (responsible for planning and coordinating the works) a minimum of 14 days prior
to the commencement date (as per Construction Program) or as per contract requirements. The
Project/site Engineer or delegate is to review the Subcontractor’s Environmental Risk Assessment.
The task can only commence subsequent to review and acceptance of the Environmental Risk
Assessment by the Project/site Engineer or delegate.
Environmental Risk Assessment should be re submitted by the subcontractors and re-reviewed by
BYCA:
 Subsequent to a serious incident
 Where there is a significant change in construction methodology
 Legislative change that modifies the project systems of work
10.1.2 Task Observations

Project managers are responsible to implement a schedule for undertaking Task Observations (Task
Observation Monitoring Program). The Task Observation Monitoring Program shall be developed by
the OHS Manager with the collaboration of the Project/site Engineer to provide adequate coverage
over all high risk tasks. BYCA project team representatives are responsible for implementing the FS-
CO-RM-05 Task Observation Program.
The Project Objectives and Key Performance Indicators section of this plan conveys the frequencies
for undertaking Task Observations.
The Task Monitoring Program is aimed to:
 Engage Sub Contract workers who participate in Task Observations
 Ensure environmental controls are in place and rules are being followed
 Identify potential for continuous improvement
 Ensure that trained and competent personnel are performing tasks
 Reinforce positive environmental behaviors and identify any At Risk behaviors
10.2 Environment in Design

Any design elements associated with the project will include an environmental review as part of the
design review. Environmental risks will be assessed in accordance with the BYCA Risk Matrix, the PR-
CO-03 Risk Management Procedure and the PR-DE-01 Design Control Procedure.

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The Project/site Engineer or delegate, when required, will attend the Design Risk Register
workshops, to ensure that environmental constraints and protocols have been addressed.
10.3 Reporting and Meetings

Reports and meetings are required to be conducted, prepared and submitted, as per BYCA Systems
Management and the contract requirements. This ensures project stakeholders are kept informed of
project progress, quality management, safety, risk, issues, financial and schedule performance.
11 CONTRACTOR MANAGEMENT
BYCA will ensure that environmental requirements are incorporated into systems used to procure
goods and services. Subcontractors must satisfy all the conditions detailed in this plan and its
associated sub plans and procedures.
Environmental responsibilities will form part of the Site Induction for all personnel working on-site.
Regular Tool Box Talks will be used to communicate detailed task specific responsibilities to
applicable personnel, including all subcontractors.
The performance of subcontractors in relation to their contractual requirements will be monitored
to ensure effective implementation and compliance of all requirements.
11.1 Environment in Procurement

All items purchased for the permanent works shall be subject to verification to ensure conformance
to contractual requirements. The Project/site Engineer shall liaise with procurement personnel to
ensure that purchasing documents such as purchase orders, subcontracts, requests for quotes/
tenders and other market request documentation contain specifications that are consistent with
achieving environmental objectives. The Project/site Engineer must ensure all subcontracts include
required environmental management contractual conditions as per the FS-PC-08 HSE Contract
Specifications. Please refer to PR-PC-01 Purchasing Procedure.
All subcontractors working on site will be evaluated for Environmental Management System
requirements and past performance.
All subcontractors shall include environmental considerations within their work methods and work
under the BYCA Environmental Management System. In addition, each subcontractor is required, as
part of their statutory and contractual obligations, to provide adequate information, instruction,
training and supervision to workers. The Project/site Engineer shall evaluate the required methods
of control for:
 Documentation, (e.g. specifications, drawings)
 Inspection and testing, (e.g. ITP’s/Checklists)
 Compliance with specifications
 Non-conforming items
 Inspection, measuring and test equipment
If the subcontractor/supplier has no existing environmental management system to satisfy the
above, the Project/site Engineer shall ensure that BYCA documentation will be made available for
their use.

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Subcontractors working in environmental sensitive areas of the project are required to submit a Site
Environmental Risk Assessment (refer to the Project Environmental Risk Assessment section of this
plan), and where required a Site EMP.
11.2 Subcontractor Environmental Management Plan

When required, subcontractors working in environmental sensitive areas will be required to submit
to BYCA a Site EMP, in the form approved by the Project/site Engineer for the project.
Each subcontractor’s EMP will be assessed by the responsible BYCA Project/site Engineer to ensure
that the subcontractor has in place the adequate systems to identify and control all the hazards
arising from their operations.
The performance and compliance of each subcontractor with their Site EMP will be monitored by
BYCA.
12 EMERGENCY READINESS AND RESPONSES

BYCA will ensure that systems are in place to effectively control an environmental emergency
situation whenever it arises on a BYCA site.
A Project Emergency Management Plan will be developed by the OHS Manager, in conjunction with
the Project/site Engineer, to address site specific emergency preparedness and responses. Please
refer to PR-CO-05 Emergency Management Procedure and PL-CO-02 Emergency Management Plan.
12.1 Hazard Reporting

All workers will be instructed that they must immediately report to their immediate Supervisor any
hazard likely to impact the environment or the community. With that in mind, all workers and
subcontractors involved are authorised to raise a FS-CO-RM-03 Hazard Report.
The Project/site Engineer shall record all reported hazards into the FS-QA-RG-02 Corrective &
Preventative Actions Register.
12.2 Emergency Preparedness

A site specific EMP (PL-CO-02 Emergency Management Plan) shall be developed for each BYCA
project and arrangements communicated to all persons via the Site Induction, Project Notice Board
and Toolbox Talk meetings. The aim of these methods of communication is to inform the planned
arrangements to all persons potentially affected by an emergency situation at a BYCA project.
The key to effective prevention of environmental incidents/non-compliances is monitoring,
surveillance and training. During construction activities, inspections and preventative actions will
include:
 Regular inspections of construction areas and the surrounding environment
 Identification of potential and actual environmental issues/non-compliances
 On-going environmental training
Environmental and safety information on hazardous materials e.g. Safety Data Sheets (SDS), will be
available at the site compound/designated chemical storage areas. Spill kits and other emergency
supplies (i.e. sand bags and silt fence equipment) will also be made available. The handling, storage
and use of hazardous materials (which includes both Hazardous Substances and Dangerous Goods)
shall be in accordance with the PR-HS-04 Hazardous Substances Procedure.

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Emergency Drills will be conducted to test the effectiveness of the emergency response systems.
Results of all emergency evacuation drills shall be recorded inclusive of any ongoing corrective
actions.
Following an emergency situation, a report will be completed by the Project/site Engineer
documenting the event (FS-EV-IM-01 Environmental Incident Report) and lessons learnt. Emergency
plans will then be modified to incorporate lessons learnt and staff will be trained on any changes to
the planned arrangements.
12.3 Accidents and Incidents

BYCA has an objective to eliminate environmental Class 1 and 2 incidents, and systematically reduce
the occurrence of any other incident that has potential to impact the environment or the
community. BYCA will follow the PR-CO-04 Incident Management Procedure for the reporting and
investigation of all incidents at BYCA sites.
All environmental incidents must be investigated by the Project/site Engineer or nominated delegate
as soon as possible after the event. When an environmental incident is part of an HS incident, the
investigation will include an OHS representative as part of the investigation team. The investigation
shall address the cause and/or impact of the incident.
12.4 Incident Reporting and Records

All actual or potential environmental incidents must be reported to a BYCA representative
immediately.
All personnel (including sub-contractors) are informed at Site Induction that they must report all
incidents, including any dangerous occurrence, as soon as practicable to the responsible BYCA
representative. Please refer to the PR-CO-04 Incident Management Procedure.
BYCA’s Project/site Engineer will ensure that any pollution incident that causes or threatens material
harm to the environment will be notified to the appropriate Regulatory Authority immediately. A
'pollution incident' includes a leak, spill or escape of a substance, or circumstances in which this is
likely to occur. Material harm includes on-site harm, as well as harm to the environment beyond the
premises where the pollution incident occurred.
12.5 Incident Investigation

Investigations are undertaken of all incidents and injuries (including Dangerous Occurrences) in
accordance with the PR-CO-04 Incident Management Procedure.
BYCA will investigate any environmental incident that has Class 1 or Class 2 incident potential,
including analysis of incident root cause and recommendations regarding corrective actions. All
investigations will be undertaken by a competent person who is conversant with the BYCA
investigations procedures.
13 PROJECT SPECIFIC ENVIRONMENTAL OBJECTIVES

13.1 Project Specific Objectives, Factors and Impacts
This EMP in conjunction with the respective Environmental sub plans, outline the management
strategies to control and mitigate environmental risks.
Each environmental factor is broken down into four components:

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 Objectives: outlines the objectives of environmental management that BYCA will achieve
during construction
 Potential Environmental Impact: outlines the potential environmental impact of the
proposed construction activities
 Management and contingency mitigation measures: BYCA will achieve its environmental
objectives through the identified management and mitigation measures. These measures
are defined on each Environmental Management sub plans to provide clear direction to
staff and contractors on how construction activities will be undertaken to limit
environmental disturbance and to manage and mitigate where avoidance is not practicable
 Monitoring: construction activities will have impacts on the environmental and BYCA will
monitor these impacts to ensure they are minimised and managed in accordance with both
the environmental commitments and relevant legislation. The Environmental Management
sub plans define the monitoring measures for the relevant impacts.
The Environmental Factors associated with this project are:
 Terrestrial flora and fauna
 Weed management
 Surface water
 Soil
 Visual amenity
 Indigenous heritage
 Waste and Energy management
 Chemical storage and spill response management
 Fire
Environmental constraints associated with each of the four sites are outlined in Appendix 1-4.
13.1.1 Terrestrial Flora and Fauna

13.1.1.1 Environmental Management Objectives
The terrestrial flora and fauna management objectives are as follows:
 Minimisation and management of impacts on flora and vegetation not required to be
cleared for construction works
 Minimisation and management of impacts to indigenous or otherwise protected fauna that
are located on-site, including the protection of remaining fauna habitats
 Minimise potential entrapment, sickness, stress, injury or death to fauna
 Minimisation of ground disturbance
 Promotion of the growth of local species and a stable vegetation community through
reducing access and maintenance of preserved areas
13.1.1.2 Potential Environmental Impacts

Potential environmental impacts to terrestrial flora and fauna include:
 Direct loss of native vegetation abundance and biodiversity due to the clearing of vegetation
within the construction area
 Direct and indirect loss of fauna abundance and biodiversity through habitat loss resulting
from vegetation clearance

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 Indirect impacts to flora due to alteration in hydrology and water quality of shallow
groundwater during project dewatering activities
 Direct impacts to vegetation and fauna habitat due to contamination risk associated with the
use of chemicals, and fuel spills from machine operations
 Noise disturbances to terrestrial fauna from project tools and machinery and vibration
impacts as a result of machinery operation and construction related to operational noise
 Direct impacts associated with excessive light (if night works are proposed)
 Smothering of vegetation foliage from dust mobilised through excavation and other soil
disturbances
 Introduction of plant and animal pests
 Introduction of soil pathogens
Refer to Environmental Sub-Plan PL-EV-02 for Management Measures
13.1.2 Weed Management

The environmental objectives with regard to weed management during construction are:
 Meet statutory obligations in relation to weed management
 Minimisation and management of impacts on existing vegetation community and natural
environment in and beyond the project area
 Promptly identify weed species and habitats and adopt specific weed control requirements
 No introduction of new weed species to previously non-infected areas
 No spread of weed species beyond those areas already infested

The key potential impacts arising from the introduction and spread of weeds in the project area are:
 Destruction of terrestrial and aquatic habitats through prevention of seedling recruitment
 Changes to abundance of indigenous fauna as a result of impacts on indigenous vegetation
and waterways
13.1.3 Surface Water

Surface water management objectives are as follows:
 Protection of the ecosystem surrounding the project area
 Emissions are to not adversely affect environmental values or the health, welfare and
amenity of people and land uses
 Statutory requirements will be implemented and acceptable agreed standards will be
montiored and maintained
 Minimisation and management of potential impacts to the quality of surface water
resources caused by the construction work
 Maximisation of the efficient use of water for the project
 Ensure the continued use of water resources

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 Control and minimise the volume of sediment, nutrients and pollutants being released off
site

Potential environmental impacts to surface water:
 Alteration in hydrology and hydrogeology of the environment of underlying aquifer(s),
estuaries, lakes and rivers; as a result of disturbance to groundwater-surface water
connectivity
 Impacts to water quality due to landfill contaminants and leachate seeping into the
groundwater and surface water bodies
 Indirect surface water contamination risks associated with construction activities adjacent to
a lake and river environment due to chemical and fuel spills, unmanaged stormwater flows
and run-off
13.1.4 Soil
The soil and erosion management objectives are:
 To reduce the potential for erosion and subsequent sedimentation
 Minimise sediment release to land and water
 Avoid unacceptable damage to native vegetation or wildlife habitats

Potential environmental impacts to soil are:
 Sediment runoff from newly exposed surfaces
 Sedimentation of waterways, wetlands, swamps and low lying areas
 Increased turbidity in creeks and associated waterways
 Disturbance to notable flora which is listed as Endangered
 Disturbance to notable flora regional ecosystems
 Disturbance to notable fauna species
 Sediment runoff/water pooling during heavy rainfall events
13.1.5 Air Quality

The air quality management objectives are:
 Protection of air quality
 Management of the ambient air in the vicinity of the construction works, noting the
protection of site workers will be addressed as part of a the Safety Management Plan (SMP)
 Use all reasonable and practicable measures to minimise airborne dust and greenhouse gas
emissions to minimise impacts on land, flora/fauna, water and air quality
 Track and report
 Minimise impacts on adjacent residents, land owners and community

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The potential impacts during construction to air quality include:
 An increase in particulate matter, carbon monoxide and nitrogen oxide emissions to the
environment due to the combustion of fuel and resulting exhaust emissions
 An increase in airborne dust to the environment due to:
- construction operations
- building material handling activities
- onsite vehicle movements on unsealed roads and
- clearing of flora and vegetation exposing dust
 Dust emissions may be generated as a result of earthwork activities, particularly during dry
and windy conditions. Excessive dust generation may be detrimental to human health, reduce
visual amenity as well as smother vegetation and impact fauna
13.1.6 Noise and Vibration

The environmental objectives with regards to noise and vibration management during the
construction phase are:
 Minimisation and management of noise generation from the project area
 Minimisation of the impact of noise emissions on environmental values and the health,
welfare and amenity of the population
 Compliance of noise emissions, both individually and cumulatively, with relevant statutory
requirements
 Incorporation of measures for minimising noise emissions during construction and operation
in design and procurement activities
 Undertake all reasonable and practicable measures during construction and operations to
minimise noise emissions

The potential noise and vibration impact of the Project during the construction phase is:
 Vehicle and machinery operation, including excavators, drilling equipment, pile drivers and
other equipment which may cause an increase in localised noise and vibration concerns to
neighbouring properties (residential, commercial and recreational), terrestrial and aquatic
fauna and heritage buildings/structures
13.1.7 Visual Amenity

The environmental objective with regard to the management of visual amenity during the
construction phase is to minimise and manage impacts to the visual amenity of the project.

The potential visual amenity impacts of the project during the construction phase are:

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 Aesthetics and visual amenity issues associated with the construction that could cause concern
to local residents in the area
 Some local residents and users of the public space and surrounding entertainment venues may
be concerned about clearing of flora and increased traffic volumes within the project area as
well as surrounding roads
 Transportation of mud from the site onto public roads
13.1.8 Indigenous Heritage

The environmental objectives with regard to the management of indigenous heritage during the
 Meet statutory obligations in relation to the management of indigenous heritage
 Implement where practicable the recommendations made by the indigenous groups of the
area in relation to indigenous heritage management
 Minimise and manage impacts to the indigenous heritage environment through responsible
heritage management
 Ensure changes to the biophysical environment do not adversely affect historical and
cultural associations and comply with relevant indigenous heritage legislation
 Ensure emissions do not adversely affect environmental values or the health, welfare and
amenity of people and land uses by meeting statutory requirements and acceptable
standards
 Create awareness of historical heritage and implement an effective communication protocol

The potential impacts of the project to indigenous heritage values during the construction phase are:
 Indirect contamination to indigenous heritage sites due to run-off, unintentional spills,
erosion of contaminated soil and dust
 Indirect contamination to indigenous heritage sites due to contamination of groundwater
and surface water flows as a result of clearing, spills, run-off and contamination
 Ground disturbance resulting in disturbance of known or unknown indigenous sites of
significance
 Impact on indigenous landscape and cultural value
13.1.9 Waste and Energy Management

13.1.9.1 Objectives
The environmental objectives with regard to waste and energy management during the construction
phase are:
 Minimise and manage the generation of waste from construction activities of the project by
reducing waste streams and recycling material where possible
 Dispose of waste in an environmentally acceptable manner and consistent with the
requirements of the relevant regulatory authority
 All waste contractors are to be certified
 Reduce energy consumption

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 Minimise visual impacts

 Minimise health risks to workers and the public
 Avoid contamination of soil and water
 Promote the principles and hierarchy of waste; reduce, reuse, recycle and dispose

Waste streams anticipated to be generated from construction activities can be:
 Waste soils
 Contaminated soils
 Wastewater
 Stormwater
 Sewerage waste
 Industrial wastes such as scrap metals
 Controlled wastes such as hydrocarbon waste and paint residues
 Domestic wastes
The potential impacts of the project associated with poor waste and energy management during the
 Potential soil, groundwater/surface contamination through waste or leachate spills or
leakage as a result of inappropriate storage and disposal
 Attraction of non-indigenous fauna and/or native animals through putrescible wastes
 Fire risk in waste storage areas
 The visual amenity impacted by litters
 Offensive odours from waste storage areas
 Excessive waste generation/inefficient use of resources
 Resource depletion
 Air emissions
13.1.10 Chemical Storage and Spill Response Management

The environmental objectives with regard to the chemical management during construction are:
 Ensure safe and responsible use of all chemicals in ways commensurate with their risk to the
environment
 The purchase, handling, storage and disposal of chemicals used on the project site are to be
managed appropriately to have negligible impact on the environment and so they do not
pose a threat to the health or safety of workers at the site
 Prevent uncontrolled releases of chemical substances into the environment
 Ensure that any spill or incident associated with chemicals is cleaned up quickly and
effectively to minimise the negative impact on the environment

The potential impacts of the project assoicated with poor chemical and spill response management
during the construction phase are:

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 Potential soil, groundwater/surface contamination through chemical/oil spills or leakage as a

result of inappropriate storage and use
 Fire risk at chemical/oil storage areas
 Offensive odours from chemical storage and use areas
 Toxic effects of chemicals on non-indigenous fauna and/or native animals through
inhalation, ingestion and skin contact
Refer to Sub-Plan PR-HS-04 for Management Measures
13.1.11 Fire
The environmental objectives with regard to the fire management during construction are:
 Minimise the risk of a fire originated on the project and the project vicinity
 Ensure measures are in place to appropriately response in the event of a fire
 Protect public and project personnel
 Minimise damage to, or loss of, private or public property or infrastructure
 Minimise damage to, or loss of, flora, fauna and ecosystem habitats

The potential impacts of the project assoicated with fire management during the construction phase
are:
 Increase to fire fuel loading from clearing and grubbing
 Disruption to vehicle use and parking
 Disturbance to notable flora species –
 Disturbance to notable flora regional ecosystems
 Removal/damage to fauna habitat
 Displacement/injury/fatality of fauna
13.1.12 Ground Disturbance

Ground disturbance and vegetation clearing shall be minimised at all times and conducted only in
accordance with an approved Ground Disturbance Permit (FS-HS-PM-05). A Ground Disturbance
Permit (GDP) must be in place prior to the commencement of any ground disturbing work related to
the project. The GDP shall ensure that any land disturbance takes place according to the conditions
of approval.
Any GDP breaches shall be reported as an incident through the PR-CO-04 Incident Management
Procedure.
14 INSPECTION AND TESTING

Inspection and testing shall be carried out using a number of methodologies and practices to ensure
that material, plant, equipment and work processes conform to required Environmental standards
and requirements. BYCA shall ensure that only competent/qualified persons carry out inspection and
testing.

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14.1 Site Inspections

All site inspections will be conducted following the PR-QA-03 Internal Audits and Inspections
Procedure.
The Project/site Engineer shall ensure that the required inspections and monitoring tasks are carried
out in accordance with the Project Environmental Risk Assessment, this EMP and associated sub
plans.
14.1.1 Environmental Inspections

BYCA will ensure that a procedure for planning and conducting site inspections and monitoring the
overall environmental performance of the site is in place so that hazards can be identified and
corrective actions implemented relative to risk level. This process also aims to ensure that workers,
inclusive of subcontractors where practicable, are engaged as part of the Environmental Inspection
Program. All site inspections will be conducted following the PR-QA-03 Internal Audits and
Inspections Procedure.
Environmental inspections will be conducted as per the Table 1 - BYCA Project Objectives and KPI’s of
this plan.
The Project Project/site Engineer is responsible for the development of an Environmental Inspection
Program. The Project manager is responsible to periodically review the status of the inspection
program, and to provide assurance regarding both the quantity and quality of inspections being
undertaken.
Project environmental inspections will be conducted on a weekly basis using the following forms:
 HSE Inspection (FS-CO-AT-01 HSE Inspection Checklist) and Task Observations (FS-CO-RM-04
Task Observation). These forms will be conducted as per the Table 1 - BYCA Project Objectives
and KPIs
 Environmental Inspection (FS-EV-AT-01 Environmental Inspection Report). This form is to be
conducted by the Project/site Engineer on a weekly basis. The following items and processes
will be monitored via this weekly checklist:
- Site security
- Environmental complaints
- General waste management
- Cleaning operations
- Hazardous / special waste
- Chemicals / oils / solvents / fuels
- Water pollution prevention
- Pollution response
- Dust/air pollution
- Light pollution
- Noise and vibration
- Permits / licences / consents
Any actions not undertaken from the preceding week will become priority actions on the following
week’s sheet.
Any environmental Corrective or Preventive Actions arising from these inspections shall be recorded
on the Corrective and Preventive Actions Register (FS-QA-RG-02). The Project/site Engineer is

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responsible to maintain the Environmental Corrective and Prevention Actions Register and ensure
the appropriate close out of any corrective/preventive action on a timely manner.
14.1.1.1 Inspection Records

Results of the Inspections shall be briefed to the Project manager, and where required, the project
team. Inspection Records shall be retained at a project level by the Project/site Engineer and be
reported via Environmental reporting system.
The Project/site Engineer is responsible for:
 Recording any identified hazards not immediately remedied into the FS-QA-RG-02 Corrective
& Preventative Actions Register
 Monitoring and reporting to the Project manager corrective action status
 Recording and reporting Positive Performance Indicators
14.2 Inspection of Plant/Equipment

The responsible BYCA Project and Site Engineers shall implement systems to ensure that procured
plant and equipment arrives on site in a safe and adequate condition.
Plant and Equipment inspections will be conducted as per the Project Safety Management Plan (PL-
HS-01 Safety Management Plan) to ensure that they comply with safety, service and maintenance
requirements.
Please refer to section 18.3 Plant and Equipment Control of this plan for further information.
14.3 Environmental Monitoring

Regular site inspections and monitoring shall be undertaken throughout the project to cover a
number of aspects, including the following key areas outlined below:
 Noise and vibration (as required)
 Water quality
 Air quality (as required)
14.3.1 Noise and vibration monitoring

All project activities which cause or have potential to cause noise and vibration impacts will be
monitored to ensure they are carried out in accordance with requirements in specific construction
noise and vibration impact assessments and the PL-EV-06 Noise and Vibration Management Plan.
Appropriate mitigation measures (where reasonable and feasible) will be implemented where
activities exceed or have the potential to exceed noise or vibration management levels.
14.3.2 Water quality monitoring

Surface water monitoring will determine water quality and any potential impacts, due to
construction activities, to any water body on the project or project vicinity. Any adverse
environmental impacts to surface water quality identified as a result of monitoring will be managed
according to the management and mitigation measures outlined in this EMP and the PL-EV-04 Soil
and Water Management Plan.
14.3.3 Air Quality Monitoring

The monitoring of dust levels shall be undertaken through regular visual inspections of the work
sites and activities by the Project/site Engineer or delegate.

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Id no.:PL-HS-01
Dust generating activities will be assessed during periods of windy conditions and ceased and
rescheduled where adequate control of dust generation cannot be achieved.
Visual observation of machinery conditions shall also be undertaken during site inspections in
addition to Daily Pre-Start Checks. Daily Pre-Start Checks are required to be undertaken by all plant
operators on construction plant, equipment, vehicles and machinery to ensure all equipment have
appropriate emission control devices, are in good working order and are being maintained correctly.
14.4 Inspection, Measuring and Test Equipment

Inspection, measuring and testing equipment used to monitor environmental factors will be
calibrated as per manufacturer’s recommendations and regulatory requirements. Inspection
Monitoring and Testing will be carried out in accordance with the PR-QA-02 Control of Inspection
Measuring & Testing Equipment Procedure and the PL-QA-01 Quality Management Plan.
Calibration and inspection reports/certificates will be recorded and filed as part of the project
Environmental Records.
A NATA registered laboratory will be used to conduct the compliance testing to the relevant
Australian/International Standards, when required.
Critical equipment subject to periodic inspection includes but is not limited to Atmospheric
Monitors, Noise Monitors, etc.
15 AUDITS
BYCA will conduct audits to ensure compliance with the BYCA Management System, legislative
requirements and Australian Standards.
Such audits will be conducted:
 Within the first 4 weeks of work, once the site has been established
 At intervals though out the life of the project consistent with the nature of the project, and
the level of risk
 At intervals no greater than 4 months
The Quality Manager will be responsible to develop and maintain the Project Audit Schedule (FS-QA-
RG-01 Audit Schedule Register) aligned with the BYCA Master Audit Schedule. The OHS Manager and
the Project/site Engineer will participate in the audit program and will be responsible for the
recoding and close out of any audit findings on their respective Non Conformances, Observation and
Improvement Opportunities Register.
Project Audit Schedule will be developed and reviewed to ensure coverage over the project scope
and high risks activities.
16 NON CONFORMANCE, CORRECTIVE ACTIONS AND

PREVENTIVE ACTIONS
BYCA will manage Non Conformances, Corrective and Preventive Actions as per the PR-QA-04 Non
Conformance, Corrective and Preventive Actions Procedure.
The Project/site Engineer shall maintain an Environmental Non Conformance Observations and
Improvement Opportunities Register (FS-QA-RG-05 Non Conformance (NC/NWN), Observation &

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Id no.:PL-HS-01
Opportunity Improvement (OI) Register) and an Environmental Corrective and Preventive Action
Register (FS-QA-RG-02 Corrective & Preventative Actions Register).
17 CONTROL OF RECORDS
At the project level, records of environmental compliance will be managed according to the PL-QA-
02 Records Management Plan.
A Record Filing Matrix will be established in accordance with the BYCA procedure PR-QA-01
Document Control and Record Management Procedure, taking into account local legislative
requirements. Records to be managed include:
 Training records
 Emergency evacuation records
 Project environmental risk assessment
 Incident reports and investigations
 Plant and equipment records
 Safety data sheets
 Hazardous substances register
 Monitoring records of hazardous substances use and storage
 Inspection, monitoring and testing records
 Details of personnel qualifications
 Internal review reports
 Minutes of Environmental meetings
 Design risk register
 Corrective action and preventive action reports
 Audit reports
 Non Conformance, Observation and Opportunity for Improvement Records
 Environmental Management System Review
 Induction records
 Monthly Environmental reports
Unless otherwise specified, Environmental records must be maintained for a minimum period of 7
years after completion of the project.
18 OPERATIONAL CONTROLS
18.1 Establishment/Commencement
Prior to commencement of the project the Project/site Engineer shall establish a program or
schedule to address the systematic implementation of the following environmental management
activities/tasks:
 Finalise the EMP and associated sub plans, forms and checklists
 Acquire licences, permits and approvals
 Develop Work Instructions
 Complete the Environmental Risk Assessment workshop at the beginning of the project and
progressive workshops throughout the project as required
 Establish a filing system for environmental records

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Id no.:PL-HS-01
 Define the environmental requirements for the contract

 Identify and detail environmental studies on potentially sensitive/threatened flora and fauna
known to exist in the area
 Define the environmental requirements for subcontractors and suppliers
 Establish a training program for environmental awareness and induction
 Establish communication with interested parties and site visits
 Establish the audit program
 Establish monitoring and testing regimes, and
 Establish environmental compliance and reporting mechanisms
The Project/site Engineer shall review the program/schedule each month to ensure that the
environmental management activities and tasks nominated in the program have been progressively
implemented.
18.2 Materials Control and Storage

BYCA will follow the below guidelines for materials control and storage:
 Incoming materials or items will be handled and stored in designated storage facilities or lay
down areas following receipt and inspection
 Designated storage and holding areas will be provided to prevent loss, damage or
deterioration of the items pending use or delivery. The method of storage and handling is
dependent on the types of materials and the protection required to prevent harm to the
environment
 For all chemicals that are stored on site, consideration will be given to the location and
method of storage, as well as the bunding capacity to ensure they comply with AS1940.
 Chemicals will not be stored in locations that present unnecessary risk such as close to
waterways or sensitive areas
 Bunding will be constructed of large enough capacity to hold 110% of the largest container
held in the storage area
 Location of containers and/or lay-down areas shall be defined on a site map prior to works
commencing
 A project staff member will be nominated by the Project Manager to handle stores receipt
and issue, and to document the transactions. Safety Data Sheets shall be maintained for
every chemical on site as per the safety management system requirements
18.3 Plant and Equipment Control

On arrival at site, all mobile plant and equipment will be checked at the moment of boarding to site
using the BYCA Plant Verification Checklists and FS-EV-AT-04 Weed Hygiene Form. Ongoing
inspections of plant will be documented in the manufacturer’s Daily Inspection Logs or Plant
Maintenance Log books and typically will include:
Table 2 - Plant and Equipment Control
Type Environmental Attribute Documents Required

to be checked
Plant - within specified noise level, - “Pre-start Checklist”,
(trucks, cranes, etc.) - engine covers secured, - Maintenance Log,
- no excessive vibration, - Checklist

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Id no.:PL-HS-01
- within specified air pollutant level,

- no fuel, oil, hydraulic fluid and coolant
leaks.
- clean or brushed down.
- Lids/covers secured, - Safety Data Sheet
Fuel, oil, chemical and - no leakage/spillage,
lubricant - marking/identification
Equipment (generators, - Within noise level (refer to ECP), - Checklist
pumps) - no excessive vibration
- clean or brushed down
The status of plant and equipment will be verified during site inspections and safety and
environmental audits.
All plant and equipment will be cleaned or brushed down prior to departure.
18.4 Hazardous Substances Management

BYCA will manage Hazardous substances in accordance with the PR-HS-04 Hazardous Substances
Procedure and the PL-HS-01 Safety Management Plan and will implement the following controls:
 All hazardous substances or dangerous goods procured for use on the project shall be
accompanied with:
- a Safety Data Sheet (SDS)
- a Risk Assessment generated by the Manufacturer/ Supplier
- adequate labelling
- spill kits shall be available in all areas where hydrocarbons and chemicals are stored or
used, where necessary, spill kits for water shall be provided
 All dangerous goods (DG) and hazardous substances shall be stored in a dedicated DG
storage container which is adequately ventilated, and has adequate bunting for the quantity
of DG and hazardous substances being stored
 DG shall be stored in accordance with the separation distances defined in AS/NZS 3833:2007
The Storage and Handling of Mixed Classes of Dangerous Goods
 Smoking is not permitted within 5 metres of dangerous goods storage containers
 DG storage containers shall be fitted with an external fire extinguisher which is suitably
mounted and sign marked. The fire extinguisher shall comply with AS2444 Portable Fire
Extinguishers and Fire Blankets, be 3.5 Kg minimum capacity and be Powder Type Class ABE
19 REVIEW CRITERIA
This document shall be reviewed as follows:
 As requested by Management Review
 When there is a change of method and/or technology that may affect the accuracy of this
document; or
 When there has been a significant event to which this document was relevant; or
 As a result of a non-conformance resulting from an audit

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Id no.:PL-HS-01

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Appendix 1 Parkes Overview and Environmental Constraints Map

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Id no.:PL-HS-01
Appendix 2 Griffith Overview and Environmental Constraints Map

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Id no.:PL-HS-01
Appendix 3 South Keswick Overview and Environmental Constraints Map

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Appendix 4 Narromine Overview and Environmental Constraints Map

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NEOEN Solar Farm Project

Rev Date: 09/03/2017

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10.1.1.2 Subcontracted Work ............................................................................................................. 21

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13.1.12 Ground Disturbance .................................................................................................... 31

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1.2 Environmental Management System

1.2.1 Environmental Management Plan (EMP)

1.2.2 Management Sub-Plans

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1.3 Document Responsibilities

1.4 Document Amendment and Distribution

1.4.1 Revision Status

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2.1.1 Working hours

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BYCA Bouygues Construction Australia Pty Ltd

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4.2 Responsibilities and Authorities

6 BYCA OBJECTIVES, KPIs AND TARGETS

PROJECT OBJECTIVES, KPIs AND TARGETS

Objective Key Indicator Unit Target By Frequency

Report CO2 emissions

Ensure that project Notices issued by

activities conform with Environmental

Ensure that project

Ensure that project No. of Environmental

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Ensure Non Percentage of

HSE Specification (FS- HSE

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PROJECT SPECIFIC OBJECTIVES AND KPIs

Ensure that project Number of Notifiable

All plant and vehicles Project Manager,

6.1 Performance Measurement and Monitoring

6.1 Project Management Review

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7.2 Contractual Requirements

8 COMMUNICATION & CONSULTATION

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8.1.1 Project Site Induction

8.1.2 Pre-Start Meetings

8.1.3 Environmental Toolbox Meetings

8.1.4 Project Notice Board

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8.1.5 Environmental Alerts

8.1.6 Minimum Project Rules

8.1.7 Works Coordination Meetings

8.1.8 Unplanned Engagement

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8.2 External Communication

8.2.2 Liaison with Authorities and Emergency Services

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9 COMPETENCE, TRAINING AND AWARENESS

10.1.1 Project Environmental Risk Assessment