Normanby Road Early Works Air Quality Delivery Work Plan
CRL-MTE-RME-LKA-PLN-800005
Revision: 001 Date: 21 February 2020
Page 1
| Normanby Road Early Works
Air Quality Delivery Work Plan
Document title CRL-MTE-RME-LKA-PLN-800005 This document is uncontrolled when printed. This document should be printed in colour
Revision Status Revision
Date
Version details
Prepared By
Approved By
Rev A00
25/11/19
Mana Whenua / CLG Review
Peter Stacey
Peter Roan
Rev A01
26/11/19
IPR and Auckland Council Review
Peter Stacey
Peter Roan
Rev 000
19/12/19
Final for submission
Peter Stacey
Peter Roan
Rev 001
21/02/20
Final
Peter Stacey
Peter Roan
Approval Status Name/Title
Signature
Date
Prepared by:
Peter Stacey Air Quality Specialist
19/12/2019
Reviewed by:
Jonathan Harland Air Quality Specialist
19/12/2019
Approved by:
Peter Roan Consenting Lead – Link Alliance
19/12/2019
Page 2
| Normanby Road Early Works
Air Quality Delivery Work Plan
Table of contents 1. Introduction ............................................................................................... 5 1.1
Overview of CRL Works in Mt Eden ................................................................................... 5
1.2
Purpose of the Air Quality DWP ........................................................................................ 6
1.3
Relevant Conditions .......................................................................................................... 6
1.4
DWP Review and updates ............................................................................................... 10
2. Normanby Road Early Works ....................................................................11 2.1
Overview of Works .......................................................................................................... 11
2.2
Construction Methodology.............................................................................................. 12
2.3
Discharges to Air ............................................................................................................. 12
2.4
Sensitive Locations .......................................................................................................... 12
2.5
Key Personnel.................................................................................................................. 13
3. Environmental setting ...............................................................................14 3.1
Locality ............................................................................................................................ 14
3.2
Meteorology.................................................................................................................... 14
3.3
Sensitive receptors .......................................................................................................... 16
4. Environmental Standards ..........................................................................17 4.1
Environmental Performance Standards........................................................................... 17
5. Monitoring Requirements .........................................................................18 5.1
Dust Monitoring .............................................................................................................. 18
5.2
Visual Inspection and Monitoring Methods .................................................................... 18
5.3
Instrumental Monitoring ................................................................................................. 19
5.3.1.
Dust ............................................................................................................................ 19
5.3.2.
Meteorological Monitoring.......................................................................................... 19
5.4
Odour Monitoring ........................................................................................................... 19
6. Operating Procedures ...............................................................................21 6.1
General Methods of Dust Control.................................................................................... 21
6.2
Dust Mitigation Measures ............................................................................................... 22
6.2.1. 6.3
Review of Dust Mitigation ............................................................................................... 23
6.3.1. 6.4 Page 3
Equipment Malfunction ............................................................................................... 23
Sources of Information ................................................................................................ 24
Control during Contaminated Material Handling ............................................................ 24
| Normanby Road Early Works
Air Quality Delivery Work Plan 6.5
Odour Mitigation Measures ............................................................................................ 24
6.6
Control of Vehicle Exhaust Emissions .............................................................................. 25
6.7
Dust contingency measures ............................................................................................. 25
7. Communication with Affected Parties ......................................................26 7.1
Complaints ...................................................................................................................... 26
8. Environmental Training .............................................................................27 8.1
Early Works Staff ............................................................................................................. 27
9. Record Keeping .........................................................................................28 9.1
Air Quality Diary .............................................................................................................. 28
Appendix A: Record of CLG, IRP and Auckland Council Comments .................29 A1. CLG Comments ..........................................................................................29 A2. IPR Comments ...........................................................................................29 A3. Auckland Council Comments.....................................................................29 Appendix B: Beaufort Scale .............................................................................31
Page 4
| Normanby Road Early Works
Air Quality Delivery Work Plan
1. Introduction The City Rail Link (CRL) project comprises the construction, operation and maintenance of a 3.4 km underground passenger railway, running between Britomart Station and the North Auckland Rail Line (NAL) in the vicinity of Mt Eden Station. The CRL also involves the construction of two new underground stations at Aotea and Karangahape and a redeveloped Mt Eden Station (refer to Figure 0-1) The design and construction of the CRL infrastructure between Aotea and Mt Eden Stations is being delivered by the Link Alliance. This Air Quality Delivery Work Plan (AQ DWP) has been prepared in relation to early works along and in the vicinity of Normanby Road, hereafter referred as the ‘Normanby Road early works.
Figure 0-1: CRL Route and Location
1.1 Overview of CRL Works in Mt Eden The CRL works in the Mt Eden area involve the construction of the southern section of the tunnel structures and the tie-in to the existing NAL, including the construction of the redeveloped Mt Eden Station. The Mt Eden Active Construction Zone (ACZ) and Construction Support Areas (CSA) for the NAL Mt Eden section are generally located between State Highway 1 (SH1) to the east and Dominion Road to the west. The works in this area include: • • • • • Page 5
Construction of an underground grade separation structure near Mt Eden Station; A new Mt Eden Station building incorporating passenger linkages; Modifications to the existing Mt Eden Station platforms; Road over rail bridges at Mt Eden Road, Normanby Road and Ruru Street with sections of road realignment; Grade separation structures and the east- and west-facing connections for the existing and new rail lines to pass-over and connect with each other;
| Normanby Road Early Works
Air Quality Delivery Work Plan • •
Pedestrian and cyclist bridge structures at Fenton Street and Porters Avenue; and New road linkages within the reinstated area post-construction.
Given the nature and scale of CRL works in Mt Eden, construction will be undertaken in a staged manner. This AQ DWP only relates to one component of the CRL Mt Eden works, the Normanby Road early works, as described in Section 2 below.
1.2 Purpose of the Air Quality DWP This AQ DWP has been prepared to identify the measures that will be implemented to mitigate and manage the potential adverse effects on air quality during the Normanby Road early works. The objective of the AQ DWP is to detail the best practicable options to avoid, remedy, or mitigate the adverse effects of discharges of dust, odour and hazardous air pollutants generated by construction activities for the early works. Amongst other things, this AQ DWP includes procedures for ensuring that construction and earthworks activities do not result in the following effects beyond the boundary of the early works area (Figure 2-1 in Section 2): • •
Offensive or objectionable dust or odours; or Hazardous air pollutants that cause, or are likely to cause, adverse effects on human health, environment or property.
The CRL designation 2500-6 (condition 59) requires the preparation of an AQ DWP, while condition 222 of discharge permit R/REG/2016/1899 requires the preparation of an Air Quality Management Plan (AQMP). These two separate requirements have been combined and are addressed in this single AQ DWP. This AQ DWP has been developed in consultation with the Mt Eden Community and Business Liaison Group (CLG) and has undergone Independent Peer Review (IPR) prior to submission to Auckland Council (as per designation conditions 7 and 11, and resource consent condition 19). A record of the consultation and review outcomes, including the Link Alliance’s response to matters raised, is included in Appendix A. This AQ DWP forms part of the Construction Environmental Management Plan (CEMP) for the Normanby Road early works.
1.3
Relevant Conditions
Table 1-1 identifies the designation and resource consent conditions relevant to this AQ DWP and where they are addressed in the document. Table 1-1: Air Quality conditions and location in the AQ DWP
Condition No.
Condition
Relevant section of DWP
CRL Designation Conditions 59.1
Page 6
An Air Quality DWP shall be prepared to avoid, remedy or mitigate the adverse effects on air quality during the construction of the City Rail Link or any part of it.
| Normanby Road Early Works
This document
Air Quality Delivery Work Plan
Condition No. 59.2
Condition
Relevant section of DWP
The objective of the Air Quality DWP is to detail the best practicable option to avoid dust and odour nuisance being caused by construction works and to remedy any such effects should they occur.
This document
To achieve the above objective the following shall be included in the Air Quality DWP and implemented as required:
59.3
(a) The procedures to be implemented for the continuous monitoring of Total Suspended Particulate (TSP) concentrations and meteorology including, but not limited to, the establishment of two monitoring sites (to the north and south of the site);
5.1
(b) Identification of the sensitive locations, and the specific methods for monitoring, including trigger limits to determine whether further action (such as implementation of the mitigation measures discussed below or other mitigation measures) is required;
2.4, 5
(c) Procedures for responding to malfunctions with construction machinery or works causing accidental dust discharges including, but not limited to, the requirement to remedy any malfunction within 24 hours;
6.2.1
(d) Procedures for monitoring weather conditions and the requirement that water spray is used on soil stockpiles, any nonpaved construction areas, and the wheels of trucks where dust may disperse beyond the site;
5.2, 5.3.2
(e) Procedures for establishing when the covering of trucks will be required;
5.2
(f) Procedures for determining when hard surfaced areas in construction yards and active construction areas should be cleaned including, but not limited to, the requirement that such areas be cleaned whenever dust generation occurs due to traffic on these surfaces;
5.2
(g) Procedures for responding to discharges of odour (including in the event of excavation of contaminated sites) including, but not limited to, the requirement to address discharge of objectionable odour by immediately ceasing the activity causing the discharge;
5.4
(h) Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including baghouses, pressure relief valves and high-level alarms to mitigate dust emissions;
N/A
(i) Procedures for, where practicable, limiting dust and odour nuisance and the methods for monitoring these procedures including Identification of contingency measures to address identified and verified adverse effects on sensitive receptors.
6.4, 6.5
Contingency measures may include options such as: (i) Cleaning of air filtration intakes; or (ii) Cleaning of other buildings and infrastructure; and
6.7
(j) Procedures for responding to any complaints received and the timeframes for response to complaints and reporting;
7.1
(k) Cross references to the specific sections in the Communication and Consultation Plan which detail how the communities in the vicinity of Page 7
6.7
| Normanby Road Early Works
7
Air Quality Delivery Work Plan
Condition No.
Condition
Relevant section of DWP
construction works are to be communicated with on the management of the adverse effects relating to air quality. Discharge Permit R/REG/2016/1899 Conditions 217
This resource consent shall expire 15 years after the consent commences unless it has been surrendered or been cancelled at an earlier date pursuant to the RMA.
Noted
218
The Consent Holder shall ensure that all processes on the Project work site shall be implemented, operated, maintained, supervised, monitored and controlled so that any emissions authorised by this consent are maintained at the minimum practicable level.
This Document
219
Unless provided for by Condition 220, there shall be no dust or odour beyond the boundary of the Project work site caused as a result of onsite processes which, in the opinion of Council, is noxious, offensive or objectionable.
This Document
220
Any noxious, offensive or objectionable dust or odour beyond the boundary of the Project work site caused as a result of construction and earthworks activities associated with the Project shall be mitigated as soon as practicable in accordance with the requirements of the certified Air Quality Management Plan as required by Condition 222.
This Document
221
The Consent Holder shall ensure that beyond the boundary of the Project worksite, there shall be no hazardous air pollutant caused as a result of construction and earthworks activities associated with the Project that causes, or is likely to cause, adverse effects on human health, environment or property.
This Document
222
The Consent Holder shall review the draft Air Quality Management Plan – Aotea Station to North Auckland Line dated May 2016 and submit to Council (Team Leader Central Monitoring) a final AQMP/s which is generally consistent with the draft AQMP provided in support of the application.
This Document
The final AQMP/s shall be prepared by a Senior Qualified Person, provided to the Council (Team Leader Central Monitoring) for certification at least 20 working days prior to the commencement of construction and shall include: a. a clear identification of the type and location of the controls proposed; 223
b. a detailed framework for the management, mitigation and monitoring of construction and earthworks activities associated with the Project;
6
c. a focus principally on the sources of dust discharges, and d. an assessment of the risk of discharges from each ACZ and the associated CSA.
224
Page 8
The final AQMP/s shall also provide detailed methods including, but not limited to, the following matters:
| Normanby Road Early Works
Air Quality Delivery Work Plan
Condition No.
Condition a. methods to ensure exposed surfaces remain dampened to minimise dust emissions (possible examples include a water spray system or other suitable system, water carts and other suppression methods);
6
b. ensuring a 20 km/hr vehicle speed limit within the ACZs and CSAs;
6.2
c. operation of wheel washes;
6.2
d. regular sweeping of public roads around the exit points of ACZs and CSAs and sealed vehicle accessways within these areas;
6.2
e. measures for supressing dust from any temporary stock piles (demonstrating how they are to be limited to no more than 24 mÂł of uncovered spoil at any one time in each ACZ); f. measures for the handling of cement associated with the forming of cement stabilised columns, including filter systems and high-level alarms where a silo is used;
225
Page 9
Relevant section of DWP
6.2 Not Applicable. This activity is not undertaken as part of the early works.
g. covering of loads of material being delivered and removed from the site;
6.2
h. instrument monitoring of dust concentrations (including identification of a monitoring methodology, monitoring network and appropriate alert thresholds) to ensure that any significant dust effects arising from the ACZs or CSAs are identified and remedied as soon as practicable throughout the Project;
5.3
i. the locations of instrument dust monitoring sites, including at least three re-locatable and/or fixed monitors to be associated with each of ACZs A, K and M, and the duration of this monitoring;
Not applicable, instrumental dust monitoring not required given the minor nature of the works.
j. measures for responding to continuous instrument dust monitoring trigger alarms, including contingency measures to reduce measured concentrations below the trigger thresholds and provisions for responding after standard operating hours;
Not applicable, instrumental dust monitoring not required given the minor nature of the works.
k. measures for undertaking meteorological observations and visual inspections of dust or other air discharges from the Project, to be completed at least on a daily basis, with all relevant information logged; and
5
l. information regarding complaint logging, investigation and response procedures, training and roles and responsibilities. The Team Leader Central Monitoring shall be requested to respond to the AQMP/s with any suggested changes within 10 working days from receipt of the AQMP; otherwise the AQMP may be considered by the Consent Holder to be certified by the Council.
7.1
Any change to the AQMP/ shall be submitted to the Council (Team Leader Central Monitoring) for certification. No activity reliant upon a change to the AQMP can be undertaken until the change has been certified. The Team Leader Central Monitoring shall be requested to respond to the proposed change within 10 working days from receipt of the
1.4
| Normanby Road Early Works
Air Quality Delivery Work Plan
Condition No.
Condition
Relevant section of DWP
change; otherwise the AQMP may be considered by the Consent Holder to be certified by the Council. 226
All works shall be undertaken in accordance with the certified AQMP/s.
Noted
227
Prior to the commencement of construction, and for the duration of excavation and construction associated with the Project which have the potential for significant dust emissions, the Consent Holder shall install, operate and maintain continuous dust monitoring undertaken using mobile instruments for the purposes of monitoring Total Suspended Particulates (TSP). The locations, durations and methods of TSP monitoring at each of ACZs A, K and M shall be in accordance with the details in the certified AQMP(s) required by Condition 222.
Not applicable, instrumental dust monitoring not required given the minor nature of the works.
228
1.4
The dust monitoring instruments shall be fitted with an alarm system that sends a warning to the responsible person identified by the AQMP/s when dust concentrations exceed alert levels specified by the certified AQMP/s. The Consent Holder shall ensure that the responsible person, or other nominated person, is available at all times to take immediate action to reduce dust emissions from the site.
Not applicable, instrumental dust monitoring not required given the minor nature of the works.
DWP Review and updates
This AQ DWP is a live document that will be reviewed as a result of a material change to the project, or to address unforeseen adverse air quality effects arising from construction, or unresolved complaints. Any material changes to this AQ DWP must be certified by Auckland Council prior to any on-site activity reliant upon the change commencing. Refer to Section 6.7 of the CEMP for further detail on the review and updating process.
Page 10
| Normanby Road Early Works
Air Quality Delivery Work Plan
2.
Normanby Road Early Works
2.1 Overview of Works The Normanby Road early works involve demolition of the building at 11 Water Street, establishment of a Construction Support Area for C5, construction of a temporary pedestrian bridge across the NAL and two retaining walls, and diversion of temporary and permanent utilities via a utility bridge (such as water, wastewater, stormwater, gas, electricity and communications) along and in the vicinity of Normanby Road. The early works are required in advance of the main construction works to provide adequate clearance between the CRL works and network utilities to enable construction of retaining walls, the Normanby Road grade separation bridge and the realigned Normanby Road / Boston Road / Nugent Street roundabout. The Normanby Road early works are planned to extend over eight months, between February 2020 and September 2020. Figure 2.1 shows the area of these works.
Figure 2-1: Extent of the Normanby Road early works area
Refer to the CEMP for a detailed description of the works.
Page 11
| Normanby Road Early Works
Air Quality Delivery Work Plan
2.2 Construction Methodology The Normanby Road early works will be divided into stages as described in the CEMP and the Construction Staging Plans in Appendix B of the CEMP.
2.3
Discharges to Air
The main potential discharge to air arising from the construction activities is particulate matter (dust). The following dust generating activities from the early works have been identified: • • • • • • • • • • •
Breaking up and excavating existing road surface concrete and asphalt; Concrete cutting; Excavation of trenches, and spoil removal; Demolition of 11 Water Street; Drilling holes for Piles Storage of excavated spoil and imported fill (up to 750 m³, if necessary); Movement of vehicles in the work areas; Backfilling of new wastewater and stormwater trenches Backfilling of the utility relocation trenches; Backfilling of retaining walls; and, Removal of trees.
In addition, there will also be discharges of combustion related air pollutants from mobile plant and diesel generators. These include oxides of nitrogen (nitric oxide (NO) and nitrogen dioxide (NO2)), carbon monoxide (CO) and volatile organic compounds (VOC). Asbestos-containing materials are present at 11 Water Street. However, these materials will be removed in compliance with appropriate regulations and industry standards prior to the commencement of demolition works. Therefore, asbestos fibres are not expected to be discharged to air as part of the demolition works.
2.4
Sensitive Locations
Due to the proximity of residents and businesses to the works, all locations within 100 m of the areas of the designation in which the early works will be undertaken are considered sensitive1 to the effects of dust that have the potential to result from the works.
1
The MfE has defined the sensitivity of different land uses in its Good Practice Guide for Assessing and Managing Odour in New Zealand. These definitions apply equally to the effects of dust, with both high density residential and commercial/retail areas considered to have high sensitivity. Page 12 | Normanby Road Early Works
Air Quality Delivery Work Plan
2.5
Key Personnel
The key personnel responsible for implementation of this AQ DWP are identified in Table 2-1. However, all site personnel are responsible for following the requirements of the AQ DWP. Refer to the CEMP for further detail on roles and responsibilities. Table 2-1: Key Personnel and Contact details
Role
Name
Project Manager – NAL Mt Eden Section
Glen Kirk
Construction Manager – NAL Mt Eden Section
Francois Pageron
Environmental and Sustainability Manager
Sarah Sutherland
Air Quality Specialist – Normanby Road Early Works
Peter Stacey
Link Alliance Communication and Engagement Manager
Rachel Blundell
Page 13
| Normanby Road Early Works
Air Quality Delivery Work Plan
3.
Environmental setting
This section of the AQ DWP describes the environment surrounding the early works site in terms of meteorological influences on the transport of air contaminants and sensitivity of adjacent activities to those discharges.
3.1 Locality The early works are being undertaken to the east of Mt Eden Station, in an urban environment adjacent to a range of commercial, residential and recreational activities. Due to the density of development and human occupation in surrounding areas, the sensitivity of the local environment to air pollution in general is relatively high.
3.2 Meteorology Figure 3-1 shows wind roses of wind speeds and directions measured at the Niwa weather station at the Auckland Museum of Transport and Technology (MOTAT), Western Springs over year-round, summer (December to February) and winter (June to August) periods. The weather station is located approximately 2.85 km to the west of the CRL Mt Eden site. Wind measurements at this station are considered to be generally representative of conditions in central Auckland. Although localised topographical features and adjacent buildings are likely to alter wind conditions, the wind direction frequency trends illustrated below are likely to be broadly similar to those experienced at the early works area. Based on the wind roses in Figure 3-1, winds are predominantly from the south, southwest and northeast. The nearest sensitive receptors are located to the southwest and therefore have the potential to be affected by dust when the wind is from the northeast. The amount of dust generated also largely depends on whether conditions are dry, and the wind speeds, with faster wind speeds increasing the effects of wind erosion and the distance that dust travels.
Page 14
| Normanby Road Early Works
Air Quality Delivery Work Plan All months, 2016-2019, Calms = 5.52%
Winter months, 2016-2019, Calms = 6.28%
Summer months, 2016-2019, Calms = 2.25%
Figure 3-1: Wind rose frequency analyses of wind speeds and directions at the Auckland MOTAT weather station for August 2016 to August 2019, year round, winter and summer months. Source: NIWA Cliflo database.
Page 15
| Normanby Road Early Works
Air Quality Delivery Work Plan Figure 3-2 shows that the expected drier months are during summer, when wind speeds also tend to be higher. Summer winds are dominated by north-easterly and south-westerly winds.
Figure 3-2: Percentage of wet days (rain exceeding 1 mm) over each month of the year at MOTAT. Source: NIWA Cliflo database.
3.3 Sensitive receptors Nearby activities that may be sensitive to dust and other air contaminants include: • • • • •
Page 16
Residential apartments, town houses and houses on Normanby Road, Boston Road, Nugent Street and Enfield Street; Life Central Church on Normanby Road; Bars and restaurants, particularly where premises include outdoor dining or entertainment areas, on Normanby Road; Retail, office and commercial premises; and Pedestrian access (to offices and other places of work) and parked vehicles along.
| Normanby Road Early Works
Air Quality Delivery Work Plan
4.
Environmental Standards
4.1 Environmental Performance Standards As required by the CRL designation and resource consent conditions, the intention of this AQ DWP is to ensure that construction air quality effects are kept to a practical minimum, recognising the sensitivity of the environment within which the works are being undertaken. Generally, the compliance measure used in construction processes is that dust and other air discharges do not result in “off-site� nuisance, where off-site in this case is defined as being outside of the CRL designation. Table 4-1 contains trigger levels for dust, dust deposition, odour and wind. Table 4-1: Environmental Trigger Levels for Air Discharges
Discharge
Trigger Level
Action
Dust Emissions
Dust is observed to be leaving the site.
Implement any required mitigation set out in Section 6.2
Dust Deposition
Evidence of dust on buildings or windows (a finger run down the glass leaves a clear line) Dirt on clean washing
Implement any required mitigation set out in Section 6.2
Odour
Presence of odour that is out of character with environment (e.g. smell of refuse in a residential area)
Implement any monitoring in Section 5.4 and mitigation set out in Section 6.5.
Wind
Wind speeds over 5.5 m/s (11 knots or Beaufort Scale 3) at 1.5 m above the ground.
Consider delaying activities that have the potential to generate dust during these wind conditions.
Page 17
| Normanby Road Early Works
Air Quality Delivery Work Plan
5.
Monitoring Requirements
5.1 Dust Monitoring The overall approach to dust control is primarily based on visual monitoring in combination with; good management of the construction areas; and a rapid response to any of the triggers outlined in Table 5-1 and/or to any complaints received. Good practice focusing on pre-emptive measures will aid in the avoidance of significant dust emissions, or if dust emissions occur, the subsequent mitigation or remediation of any adverse effects.
5.2 Visual Inspection and Monitoring Methods Visual monitoring of all construction areas will be undertaken on a daily basis, or more frequently if conditions change. This type of monitoring relates to the control measures described in Section 6.7 of this AQ DWP and will include pre-emptive measures to avoid dust emissions. Table 5-1 below describes the monitoring programme. Table 5-1: Visual Dust Monitoring Programme
Monitoring Activity
Frequency
Check weather forecasts for strong winds and rainfall to plan appropriate work schedule and dust management response.
Daily
Inspect construction exits and adjoining roads for the presence of dust deposition.
Twice daily
Observe weather conditions including wind and rain via observations and data outputs from weather stations.
Daily and as conditions change
Inspect all exposed surfaces for dampness.
Daily and as conditions change
Inspect stockpiles to ensure enclosure, covering, stabilisation or dampness. Ensure stockpile height is less than 3 m where possible or appropriate.
Daily and as conditions change
Inspect dust generating activities to ensure dust emissions are effectively controlled.
Daily and as new activities are commenced
Inspect watering systems (sprays and water carts) if used, to ensure equipment is maintained and functioning to effectively dampen exposed areas
Weekly
Monitor dust generating activities and water application rate (as required).
In winds over 5.5 m/s (11 knots or Beaufort Scale 3) at 1.5 m above the ground
Check for dust on local roads being used to access the site.
Daily
Inspect any wheel wash equipment to ensure effective operation.
Weekly
Page 18
| Normanby Road Early Works
Air Quality Delivery Work Plan
5.3 Instrumental Monitoring 5.3.1.
Dust
Given the relatively confined nature of the works and limited activities which can generate dust, together with the mitigation measures proposed which include visual monitoring, instrumental dust monitoring is not considered necessary for the Normanby Road early works.
5.3.2.
Meteorological Monitoring
Meteorological monitoring for the early works will be based on visual observations, with site engineers considering the weather conditions on a daily basis or as conditions change, and not undertaking activities in high wind conditions (winds with a speed greater than 5.5 m/s (11 knots or Beaufort Scale 3)) at 1.5 m above the ground, that might carry dust beyond the site boundary. The Beaufort Scale (Appendix B) will be used to determine wind speed.
5.4 Odour Monitoring Odour monitoring will be undertaken when it is considered likely that odorous material will be encountered (such as the excavation of contaminated materials). The decision to undertake monitoring will be made by the Environmental and Sustainability Manager. The frequency of monitoring will be dependent on the nature / scale of the source, location in relation to sensitive receptors, and meteorological conditions during exposure. Odour scouting will occur: • •
When potentially contaminated material is excavated and loaded onto construction vehicles; and/or When odour complaints have been received.
The Environmental and Sustainability Manager will ensure that at least one person in each work area is trained as an odour scout. This monitoring will involve the odour scout being downwind of the works and assessing odours on the intensity scale set out in Table 5-2. Where odours are identified as being “Distinct” and above, and the odour characteristic unpleasant, mitigation measures will be implemented (refer Section 6.5 of this AQ DWP). All observations shall be recorded in the daily Air Quality Diary (refer Section 9.1 of this AQ DWP). Table 5-2: Odour Intensity Scale
Intensity Scale
Criteria
0
No Odour
1
Very Weak
2
Weak
3
Distinct
4
Strong
5
Very Strong
6
Extremely Strong
Page 19
| Normanby Road Early Works
Air Quality Delivery Work Plan The odour scout will reassess the level of odour once the mitigation measures have been implemented. If the odours are still ‘Distinct’, further mitigation will be implemented, and / or the works halted until more conducive meteorological conditions are present, i.e. not blowing towards the sensitive receptor. If it is suspected that sources upwind of the works are responsible for any odour, then the odour scout will make appropriate observations and document this also.
Page 20
| Normanby Road Early Works
Air Quality Delivery Work Plan
6. Operating Procedures There are a range of routine measures that will be used on the site to manage and mitigate the effects of discharges of dust, odour or construction vehicle exhaust emissions. Additional mitigation may also be required in the event that: •
Monitoring indicates that abnormal discharges of dust are occurring;
•
Weather conditions are changing such that dust or odour discharges are more likely;
•
Complaints are received regarding discharges of dust, odour or construction vehicle exhaust emissions.
All processes on the early works site will be implemented, operated, maintained, supervised, monitored and controlled so that any emissions authorised by the resource consent are maintained at the minimum practicable level. If the available mitigation methods are unsuccessful in controlling discharges (i.e. dust and odour) that cause significant adverse effects on receptors beyond the early works boundary, then activities causing the discharge will be suspended until adequate mitigation can be put in place.
6.1 General Methods of Dust Control Dust control methods are generally associated with either reducing the potential for dust generation and transport associated with the activities described in Section 2 of this AQ DWP. General measures that will be employed during the early works to control dust from construction activities include:
Page 21
•
Controlling dust from any excavation by placing material directly into trucks where possible;
•
If material being excavated is very dry, using water sprays to increase surface moisture;
•
If materials are placed in temporary stockpiles, use water in dry windy conditions to control the dust potential or cover, if practicable, prior to removal off-site;
•
Controlling dust from exposed surfaces: Placing limits on vehicle speeds, where appropriate;
•
Limiting disturbance of soil or dusty materials: Reduction in vehicle movements and speeds and the use of lighter vehicles will also reduce disturbance and dust generation;
•
Maintenance of surface moisture content: Watering or wet suppression is used to dampen dry or dusty exposed areas;
•
Using water sprays to control concrete dust emissions associated with the demolition of 11 Water Street; and,
•
Removing excavated spoil from site on a regular basis.
| Normanby Road Early Works
Air Quality Delivery Work Plan
6.2 Dust Mitigation Measures The dust prevention methods recommended in Table 6-1 are methods that have been found to be effective for many sites across New Zealand. These methods can be used alone or in combination depending on the circumstances. Alternate methods may be employed after the effectiveness of those methods is demonstrated and this AQ DWP updated accordingly. The scale of dust prevention methods required in a particular area will be dependent on the degree of risk that the dust would cause adverse effects on the surrounding area. The dust control methods for the various degrees of risk are described below. The dust prevention methods outlined in Table 6-1 will be used, as applicable, in all areas of the early works. The list is not exhaustive and additional methods may be found to be effective. Table 6-1: Dust management measures
Source of Dust
Control
Personal responsible
Stockpiles
•
Limit the height of uncovered stockpiles to reduce wind entrainment. Stockpiles exceeding 3 m in height have a higher risk of discharging dust; Ensure that stockpiles do not exceed 24 m3 in size; Locate stockpiles in sheltered locations.; Maximise shelter from winds as far as practicable; Keep active stockpiles damp at all times.
Environmental and Sustainability Manager or delegated person
Limit the amount of exposed surfaces as much as possible; Keep exposed surfaces damp. Typical water requirements for most parts of New Zealand are up to 1 litre per square metre per hour; Cover surfaces with coarse materials where practicable); Stabilise cleared areas not required for construction, access or for parking if liable to cause excessive dust during windy conditions. Methods may include placing metal on surfaces.
Environmental and Sustainability Manager or delegated person
Regular removal of dust through washing or vacuum sweeping – the frequency determined by visual inspection; Clear all spillages on sealed surfaces as soon as practicable.
Environmental and Sustainability Manager or delegated person
Limit vehicle speeds to 20 km/h through the works areas; Limit load sizes to avoid spillages; Cover loads of fine materials; Minimise travel distances through appropriate site layout and design; Where necessary sweep public roads to remove any tracked dust.
Environmental and Sustainability Manager or delegated person
• • • • Unpaved Surfaces such as Roads and Yards
• •
• •
Sealed surfaces
•
• Vehicles
• • • • •
Page 22
| Normanby Road Early Works
Air Quality Delivery Work Plan
Source of Dust
Control
Personal responsible
Importation and Placement of Fill
•
Use water sprays as required during the placement and compaction of fill material to prevent dust generation;
Environmental and Sustainability Manager or delegated person
Miscellaneous
• •
Ensure sufficient water is available on site; Take account of daily weather forecast wind speed, wind direction and spoil conditions before commencing an operation that has a high wind potential; Install hoardings around construction areas sooner rather than later to assist by acting as wind breaks; Minimise the area of surfaces covered with fine materials.
Environmental and Sustainability Manager or delegated person
Use water as necessary to control dust from extraction and any cutting operations. As far as practical load excavated material directly into trucks.
Environmental and Sustainability Manager or delegated person
Use water sprays to control any concrete dust generated from building demolition. Minimise drop heights when loading material into trucks. Remove residual concrete dust from sealed surfaces after demolition.
Environmental and Sustainability Manager or delegated person
Use water as necessary to control dust from the placement of fill and bedding material as well as during compaction.
Environmental and Sustainability Manager or delegated person
• • Pavement Removal
• •
Building Demolition
• • •
Placement of Bedding Material
6.2.1.
•
Equipment Malfunction
If construction equipment fails and causes accidental dust discharges, it will be shut-down immediately and the fault repaired and tested prior to being allowed to continue operation. If equipment associated with dust control fails, the activities reliant on the equipment will be suspended until the fault can be repaired. The location, duration and time of any dust discharge caused by equipment failure will be recorded in the environmental dairy.
6.3 Review of Dust Mitigation When site operators are alerted to a potential off-site dust nuisance through any of the monitoring techniques described in Section 5 of this AQ DWP, or as a result of a complaint from a third party, the Construction Manager will immediately undertake a review of site activities to determine the source of the dust and implement such further mitigation as may be required in order to reduce the dust generation to acceptable levels. As appropriate the Construction Manager will notify the Environmental and Sustainability Manager.
Page 23
| Normanby Road Early Works
Air Quality Delivery Work Plan Once the additional mitigation has been implemented the Construction Manager will review the monitoring data to ensure that it has been effective.
6.3.1.
Sources of Information
The following link can be used to obtain local weather forecasting information. •
Met Service: http://www.metservice.com/towns-cities/auckland/auckland-central
6.4 Control during Contaminated Material Handling In accordance with the Contamination Delivery Work Plan (CDWP) (Appendix O of the Normanby Road early works CEMP), there is a risk of contaminated material being encountered during excavation due to the presence of uncontrolled fill and current/historical surrounding commercial/industrial land use activities. The CDWP sets out in detail how contaminated material will be dealt with during construction works and the procedures that will be followed. Set out below is further clarification on the specific mitigation measures that can be used to minimise the potential for any effects associated with discharges to air from contaminated material. As previously noted in Section 2.3, asbestos-containing materials identified in structures onsite will be removed prior to demolition. Any accidental discovery of asbestos-contaminated and/or asbestos-containing materials will be remediated as described in the CDWP. In general, it is considered that the dust generation, monitoring and control procedures described above are also suitable for use during the excavation, handling and transportation of any contaminated soils encountered during the early works. Because of the increased potential for effects associated with dust from contaminated material, it is assumed that there is an extreme dust risk associated with these works, and all appropriate mitigation measures will be implemented to minimise effects. Dependent on the location and the size of the excavation and nature of the contaminant this may include: •
Pre-wetting the area to eliminate the potential for dust generation, while taking care not to overwater and cause contaminated run-off;
•
Where practical, directly loading contaminated soils into trucks for transport to off-site disposal locations, and ensuring that all trucks are covered;
•
If stockpiling is necessary, ensuring they are damped or otherwise covered, particularly in dry windy weather conditions;
•
Carrying out ambient dust monitoring to assess the effectiveness of the control measures; and
•
Specific contaminant monitoring may be required depending on the outcome of any investigation required by the CDWP. The type of monitoring required shall be determined in consultation with the Contaminated Land Practitioner and the Air Quality Specialist.
6.5 Odour Mitigation Measures Discharges of odour are most likely to occur from any contaminated material encountered during the early works. There is also some potential for odour to occur when breaking into the existing sewer network, however these odours are unlikely to be significant, or occur for significant periods of time, as open ends of the wastewater connection will be capped. Odour emissions will be monitored by the odour scout during the excavation of such material and the following techniques utilised if necessary: Page 24
| Normanby Road Early Works
Air Quality Delivery Work Plan •
Limiting the time that the odorous material in the excavation is exposed;
•
Removing excavated odorous material from site as quickly as possible in covered trucks; and
•
The use of odour masking agents, chemical counteractants or digestive deodorant sprays.
If significant odour is detected and the odorous material cannot be removed quickly, and odour masking agents, chemical counteractants or digestive deodorant sprays are not immediately available, then the odorous material will be covered and work in that area suspended until suitable mitigation measures can be put in place. Section 5.4 of this AQ DWP sets out the odour monitoring procedure.
6.6 Control of Vehicle Exhaust Emissions The following key actions will be carried out to minimise emissions from vehicle exhausts: •
All construction machinery used on the site will be maintained in accordance with manufacturers’ requirements;
•
Where excessive exhaust smoke is identified from any construction vehicle that vehicle will be serviced as soon as is practicable and taken out of use until such maintenance has been completed; and
•
Unless warm-up or turbo maintenance procedures require it, construction vehicles will not be left idling while parked or unattended.
6.7 Dust contingency measures In the event that there is a significant dust emission that results in either complaints, the Link Alliance will implement contingency measures as follows, dependent on the nature of the complaint. These measures would be undertaken as a last resort if the source of the dust cannot be eliminated, in order to prevent build up. 1. Dust inside buildings or at a level which prevents windows being opened Following discussions with the building owner and/or occupiers, arrange to clean building ventilation system inlet filters if they are found to be significantly dirty as a consequence of construction activities. 2. Dust on the outside of buildings Arrange for the exterior of the building to be cleaned.
Page 25
| Normanby Road Early Works
Air Quality Delivery Work Plan
7.
Communication with Affected Parties
Communication and consultation with affected parties and the wider community in vicinity of the Normanby Road early works will be regular and ongoing. Methods to facilitate communication will be through the Mount Eden Community and Business Liaison Group, which will meet at least every three months during the construction of the early works, and through the methods discussed in the Communication and Consultation Plan (Appendix G of the CEMP). These measures include engagement tools such as publications, phone calls, use of the CRL website to provide updates, signage, and advertising material. One on one engagement may also be used for affected parties.
7.1 Complaints Although the measures described in this AQ DWP are aimed at avoiding complaints regarding discharges to air, complaints may be received from members of the public. It is important to ensure that any complaints are recorded and promptly investigated to identify and resolve the cause of the complaint. The requirements and procedures relating to complaints are detailed within the Communication and Consultation Plan.
Page 26
| Normanby Road Early Works
Air Quality Delivery Work Plan
8.
Environmental Training
8.1 Early Works Staff To achieve effective implementation of this AQ DWP and to ensure off site air quality impacts comply with designation and resource consent requirements, early works staff (contractors and subcontractors) will undergo general environmental awareness training and training about their responsibilities relating to the activities under this AQ DWP. Training requirements are described in full detail within the CEMP. Specific training requirements relating to this AQ DWP are outlined in Table 8-1. Table 8-1: Specific Training requirements in relation to AQ DWP
Training requirements
Frequency
Attendance
Introduction to the on-site monitoring equipment
As required & during new staff induction
All new staff members
Responding to complaints regarding dust and air quality concerns
As required & during new staff induction
Construction Manager, delegated staff member and duty managers
Page 27
| Normanby Road Early Works
Air Quality Delivery Work Plan
9.
Record Keeping
9.1 Air Quality Diary Construction activities can be affected by a number of different external and internal factors, such as weather conditions or equipment malfunction, which can contribute to an increase of dust emissions. Various control and mitigation measures are to be carried out on the site in order to prevent such effects and monitoring and inspection procedures will be used to assess the level of dust emissions both on the early works site and beyond its boundary. Recording relevant monitoring and inspection results, as well as the conditions of external and internal factors, can help to assess if control measures are being effective and to define appropriate corrective or preventive actions in case any undesirable effects are detected. The procedures for recording a daily Air Quality Diary are detailed below: •
The Construction Manager will fill out the daily diary each day and maintain the record on site.
•
The following information will be recorded in the daily diary: o
Any dust control equipment malfunctions and any remedial action(s) taken;
o
Results of the visual observations / inspections of dust emissions;
o
General weather conditions during the day (i.e., windy, calm, warm, rain, etc.);
o
The frequency of watercart and/or water sprinkling system use; and,
o
The date and signature of the person entering the information.
A copy of the daily Air Quality Diary will be kept in the early work project filing and document control system (refer to Section 6.6 of the CEMP).
Page 28
| Normanby Road Early Works
Air Quality Delivery Work Plan
Appendix A: Record of CLG, IRP and Auckland Council Comments A1. CLG Comments A CLG was held at 97 Mt Eden Rd on the 25 November 2019. Mitigation for dust measures were explained and the CLG appeared satisfied with the proposed dust mitigation measures as outlined in the DWP. No specific concerns were raised.
A2. IPR Comments The Normanby Road Early Works document has been reviewed and has been found to address the requirements of the designation conditions. The proposed procedures for management and monitoring of air quality effects have been well established in previous stages of this project. Section 4.1
Comment Section 4.1 states that Table 4.1 will contain trigger levels for odour, wind and dust deposition. There is in fact no trigger for “wind” in this table. This should be added.
Table 5.1
The overall approach to dust monitoring described in 5.1 is considered a good one and quite appropriate. However, it is noted that there are generally no trigger values outlined in Table 5.1, apart from a wind trigger value. Perhaps the text should read “…trigger values outlined in Table 4.1”.
Response Section updated to include “wind”
Section updated to include “…trigger values outlined in Table 4.1”
A3. Auckland Council Comments The Auckland Council reviewer considers that the draft AQ DWP generally complies with the Designation requirements. Notably, details of how dust effects are to be minimised are provided in a manner commensurate with the level of risk. Section
Comment
Response
4.1
Section 4.1 needs an update as it refers to instrumental dust monitoring trigger levels. Some mention of visual monitoring triggers for action here would be better – an extra line in Table 4-1 is needed detailing that visible dust leaving the works site is a trigger for action. Section 5.1 also refers to instrumental monitoring but needs to be updated so that visual evidence of dust emissions are watched for and reacted to if witnessed. Other CRL AQ DWPs may be
Section updated
Page 29
| Normanby Road Early Works
Air Quality Delivery Work Plan useful to pull this info from (see Aotea Utility Works 1-3 and Karangahape Road Other CRL AQ DWPs have utilised a daily Dust Risk Index Assessment, although it appears that the limited nature of works proposed for this portion has meant that this is not proposed here. In this situation, the reviewer is fine with this – common sense dust controls, monitoring and contingencies should sufficiently minimise dust from these initial enabling works.
Page 30
| Normanby Road Early Works
No response required
Air Quality Delivery Work Plan
Appendix B: Beaufort Scale Beaufort Force
Specification on Land
Speed Knots
km/h
m/s
Less than 1
Less than 1
Less than 1
Calm
Smoke rises vertically.
Very Light
Direction of wind shown by smoke drift but not by wind vanes
1–3
1–5
0.3 – 1.4
Light Breeze
Wind felt on face, leaves rustle, ordinary wind vane moved by wind.
4–6
6 – 11
1.67 – 3
Gentle Breeze
Leaves and small twigs in constant motion, wind extends light flag.
7 – 10
12 – 19
3.3 – 5.3
Moderate Breeze
Wind raises dust and loose paper, small branches move.
11 – 16
20 – 29
5.6 – 8
Fresh Breeze
Small trees in leaf start to sway, crested wavelets on inland waters.
17 – 21
30 – 39
8.3 – 10.8
6
Strong Breeze
Large branches in motion, whistling in telegraph wires, umbrellas used with difficulty.
22 – 27
40 – 50
11.1 – 13.9
7
Near Gale
Whole tress in motion, inconvenient to walk against wind
28 – 33
51 – 61
14.2 – 16.9
8
Gale
Twigs break from trees, difficult to walk.
34 – 40
62 – 74
17.2 – 20.6
41 – 47
75 – 87
20.8 – 24.2
48 – 55
88 – 101
24.4 – 28
0 1
2
3
4
5
Page 31
Description
Slight structural damage occurs, chimney pots and slates removed. Trees uprooted, considerable structural damage occurs.
9
Strong Gale
10
Storm
11
Violent Storm
Widespread damage.
56 – 63
102 – 117
28.3 – 32.5
12
Hurricane
Widespread damage.
> 64
> 119
> 33
| Normanby Road Early Works