Mt Eden Enabling Works Air Quality Delivery Work Plan
CRL-MTE-RME-LKA-PLN-800021
Revision: 000 Date: December 2019
Air Quality Delivery Work Plan
Mt Eden Enabling Works Air Quality Delivery Work Plan CRL-MTE-RME-LKA-PLN-800021
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Revision Status Revision
Date
Version details
Prepared By
Approved By
Rev A00
27/09/2019
Draft for Community Liaison Group and Mana Whenua
J Pene, R Butler
Peter Roan
Rev A01
20/11/2019
Draft for Auckland Council and Independent Peer Review
J Pene, R Butler
Peter Roan
Rev 000
04/12/2019
Final for Submission
J Pene, R Butler
Peter Roan
Approval Status Name/Title
Signature
Date
Prepared by:
Jason Pene Senior Environmental Engineer
04/12/2019
Reviewed by:
Richard Chilton Senior Air Quality Scientist
04/12/2019
Approved by:
Peter Roan Consenting Lead – Link Alliance
04/12/2019
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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....................................................................................................... 7
1.4
Sustainability .............................................................................................................. 10
1.5
DWP review and updates ............................................................................................ 10
1.6
DWP authors ............................................................................................................... 10
2. Project description ................................................................................. 12 2.1
Construction methodology .......................................................................................... 12
2.2
Discharges to air.......................................................................................................... 12
3. Environmental setting ............................................................................ 14 3.1
Site ............................................................................................................................. 14
3.2
Meteorology ............................................................................................................... 14
3.3
Sensitive receptors ...................................................................................................... 16
4. Environmental performance .................................................................. 18 5. Management procedures ....................................................................... 19 5.1
Dust Risk Assessment .................................................................................................. 19
5.2
Dust mitigation measures ............................................................................................ 19
5.2.1.
Operation of dust control equipment........................................................................... 24
5.2.2.
Equipment malfunction ................................................................................................ 24
5.3
Review of dust mitigation ............................................................................................ 24
5.3.1.
Sources of information.................................................................................................. 24
5.4
Odour control during contaminated material handling ................................................. 24
5.5
Control of vehicle exhaust emissions ........................................................................... 25
5.6
Dust contingency measures ......................................................................................... 25
6. Monitoring requirements....................................................................... 26 6.1
Dust monitoring .......................................................................................................... 26
6.2
Visual inspection and monitoring methods .................................................................. 26
6.3
Instrumental monitoring ............................................................................................. 27
6.3.1.
Dust monitoring ............................................................................................................ 27
6.3.2.
Dust trigger levels and alerts ........................................................................................ 28
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Air Quality Delivery Work Plan 6.3.3.
Meteorological monitoring ........................................................................................... 29
6.3.4.
Wind speed trigger dust alerts...................................................................................... 30
6.3.5.
Alternative management approach .............................................................................. 30
6.4
Monitoring data .......................................................................................................... 31
6.5
Monitoring equipment maintenance and calibration.................................................... 31
6.6
Odour monitoring ....................................................................................................... 31
7. Communication and complaints............................................................. 33 7.1
Project communications .............................................................................................. 33
7.2
Complaints .................................................................................................................. 33
7.2.1.
Receiving and recording complaints ............................................................................. 33
7.2.2.
Investigating complaints ............................................................................................... 33
8. Environmental training .......................................................................... 35 8.1
Project staff ................................................................................................................ 35
9. Record keeping ...................................................................................... 36 9.1
Air quality log.............................................................................................................. 36
10. Roles and responsibilities....................................................................... 37 Appendix A: ISCA Requirements .................................................................. 38 Appendix B: Staging Drawings ..................................................................... 39 Appendix C: Dust Risk Assessment Procedure .............................................. 40 Appendix D: Dust Risk Controls Sheet .......................................................... 42 Appendix E: Air Quality Log Sheet ................................................................ 43 Appendix F: Record of CLG, IPR and Auckland Council Comments ................ 44 F.1
CLG Comments ............................................................................................................ 44
F.2
Independent Peer Review Comments .......................................................................... 45
F.3
Auckland Council Comments ....................................................................................... 46
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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 involves the construction of two new underground stations at Aotea and Karangahape, and a redeveloped station at Mt Eden (refer to Figure 1-1). 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 the Mt Eden Enabling Works (“the Project�).
Figure 1-1: 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 Area (CSA) is generally located between Nikau Street to the north, State Highway 1 (SH1) to the east, Dominion Road to the west and the existing NAL to the south. The works in this area include: 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 for the existing and new rail lines to pass-over and connect with each other; Page 5 | Mt Eden Enabling 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 the first stage of these works, the Mt Eden Enabling Works, as described in Section 2 below. Following completion of the Mt Eden Enabling Works, works in this area will involve: Main construction works – these works will include: Tunnel Boring Machine (TBM) operations, structure construction and waterproofing/tanking for cut and cover tunnels, utilities installation, retaining wall for Ruru Street extension, construction of the rail line tieins including junctions and grade separation structures, realignment of the existing Western Line including platform reconstruction, grade separation of Normanby Road, pedestrian / cyclist bridges at Fenton and Porters, construction of the new station buildings. The Main Works will be undertaken from mid 2020 through to 2024. Public realm reinstatement – these works will involve establishing the final finishings and features that will comprise the completed Mt Eden Station and surrounds and will likely to be undertaken from 2021 to first quarter-2024.
1.2 Purpose of the Air Quality DWP This AQ DWP has been prepared to identify measures to mitigate and manage the potential adverse effects on air quality in the surrounding area during the Mt Eden Enabling Works. The objectives of the AQ DWP are: •
• • • • • •
To address requirements detailed in the CRL designation and relevant discharge permits for the Aotea to NAL (A2N) resource consent, which provides for the construction and ongoing operation, use and maintenance of the CRL route; Detail various sources of dust, odour and combustion air pollutants that may be created during the enabling works; Highlight specific sensitive locations; Identify dust and odour mitigation methods; Describe methods to minimise the discharge of combustion emissions from vehicles; Describe monitoring methods; and Set out methods for managing complaints regarding discharges into air and keeping compliance records.
This AQ DWP addresses the requirements of CRL designation condition 59 and A2N resource consent conditions 217 to 228 and will be implemented throughout the construction period. The CRL designation (condition 59) requires the preparation of an AQ DWP, while conditions 217 to 228 of the A2N resource consent require an Air Quality Management Plan (AQMP). These two separate document requirements have been combined and are addressed in this single AQ DWP. This AQ DWP has been prepared in consultation with the Mt Eden Community and Business Liaison Group (CLG) and reviewed by Independent Peer Review (IPR) prior to submission to Auckland Council (as per designation conditions 7 and 11, and condition 19 of the resource consent conditions). Page 6 | Mt Eden Enabling Works
Air Quality Delivery Work Plan This AQ DWP has been prepared by Link Alliance and forms part of the Construction Environmental Management Plan (CEMP) for the Project.
1.3 Relevant conditions Table 1-1 identifies the designation and resource consent conditions relevant to this DWP and where they are addressed in the document. Table 1-1: Relevant conditions and location in DWP
Condition No.
Condition
Relevant section of DWP
CRL Designation Conditions 59.1
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.
This document
59.2
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
59.3
To achieve the above objective the following shall be included in the Air Quality DWP and implemented as required: (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);
Section 6.3
(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;
Sections 3.3, 6
(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;
Section 6.5
(d) Procedures for monitoring weather conditions and the requirement that water spray is used on soil stockpiles, any non-paved construction areas, and the wheels of trucks where dust may disperse beyond the site;
Sections 5, 6.3.2,
(e) Procedures for establishing when the covering of trucks will be required;
Section 5
(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;
Section 5
(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;
Section 6.6
(h) Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including
Section 5
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Air Quality Delivery Work Plan Condition No.
Condition
Relevant section of DWP
baghouses, pressure relief valves and high level alarms to mitigate dust emissions; (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. Contingency measures may include options such as:
Section 5
i. Cleaning of air filtration intakes; or ii. Cleaning of other buildings and infrastructure; and (j) Procedures for responding to any complaints received and the timeframes for response to complaints and reporting;
Section 7.2
(k) Cross references to the specific sections in the Communication and Consultation Plan which detail how the communities in the vicinity of construction works are to be communicated with on the management of the adverse effects relating to air quality.
Section 7
Discharge permit (air – construction) R/REG/2016/1899 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 on-site 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
223
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:
Section 5
a. a clear identification of the type and location of the controls proposed;
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Air Quality Delivery Work Plan Condition No.
224
Condition
Relevant section of DWP
b. a detailed framework for the management, mitigation and monitoring of construction and earthworks activities associated with the Project;
Section 5
c. a focus principally on the sources of dust discharges, and
Section 5
d. an assessment of the risk of discharges from each ACZ and the associated CSA.
Section 5.1, Appendix C
The final AQMP/s shall also provide detailed methods including, but not limited to, the following matters:
Section 5
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); b. ensuring a 20 km/hr vehicle speed limit within the ACZs and CSAs;
Section 5.2
c. operation of wheel washes;
Section 5.2
d. regular sweeping of public roads around the exit points of ACZs and CSAs and sealed vehicle accessways within these areas;
Section 5.2
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);
Section 5.2
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;
Section 5.2
g. covering of loads of material being delivered and removed from the site;
Section 5.2
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;
Section 6.3
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;
Section 6.3
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;
Section 6.3
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
Section 6.3
l. information regarding complaint logging, investigation and response procedures, training and roles and responsibilities.
Section 7.2
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. Page 9 | Mt Eden Enabling Works
Air Quality Delivery Work Plan Condition No.
Condition
Relevant section of DWP
225
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.
N/A
The Team Leader Central Monitoring shall be requested to respond to the proposed change within 10 working days from receipt of the 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).
Section 6.3
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. 228
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.
Section 6.3
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.
1.4 Sustainability The Link Alliance is seeking an Infrastructure Sustainability Council of Australia (ISCA) Infrastructure Sustainability (IS) Rating. Further details can be found in the Project CEMP and Sustainability Rating Management Plan. Project sustainability requirements that relate directly to this AQ DWP are included in Appendix A. These requirements are imbedded within this AQ DWP to ensure that sustainability is a key focus and ‘the way we do things’. In some cases, the IS requirements and sustainability goals enhance the designation and consent requirements.
1.5 DWP review and updates This DWP is a live document that will be reviewed and updated at least annually, or as a result of a material change to the project, identification of increasing dust levels or potential for nuisance identified in monitoring required under this DWP, or to address unforeseen adverse contamination effects arising from construction, or unresolved complaints. Refer to Section 6.7 of the CEMP for further detail on the review and updating process.
1.6 DWP authors This AQ DWP has been prepared by a team of air quality specialists. Page 10 | Mt Eden Enabling Works
Air Quality Delivery Work Plan The AQ DWP has been authored by Jason Pene, a Senior Environmental Engineer and Principal of Tonkin & Taylor Ltd (T+T), with support from other T+T air quality specialists. Jason has over 18 years of experience in the assessment and management of air quality impacts, including management and monitoring of dust associated with linear infrastructure construction projects. The AQ DWP has been reviewed by Richard Chilton, a Senior Air Quality Specialist of T+T. Richard has 20 years of experience assessing and managing air quality impacts, and was the technical lead for the assessment of air discharges associated with the regional consenting process for the CRL project.
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Air Quality Delivery Work Plan
2.
Project description
In order to launch the TBM and commence construction of the CRL tie-ins to the NAL, a range of ‘enabling’ works are proposed, which are the subject of this AQ DWP. These enabling works are described in detail in the CEMP. In summary, the Mt Eden Enabling Works involve: • • •
•
• • • •
Continuation of the demolition and clearance of the Mt Eden CSA (these works are authorised under the Mt Eden Demolitions Outline Plan) Set up of a temporary site office, which is anticipated to be a 2-3 storey modular building (likely made up of containers) located in the western extent of the CSA. Piling and excavation associated with the preparation of the portal. This will involve the demolition of the redundant stormwater shaft located in the portal area; the installation of bored piles and associated works (ground anchors and shotcrete) to support the excavation face; and removal of spoil. Bulk excavation to form what will become the rail trenches/cut and cover tunnels, which will also provide a ramp for the TBM to be manoeuvred into position. The excavation will encounter basalt, which is to be blasted in order to expedite the works and minimise the amount of rock-breaking required. In places, softer ground conditions are anticipated to be encountered, which may require the use of sheet piles. Local mined tunnelling to facilitate the TBM launch. Construction of the additional Mt Eden Road bridge (north of the existing bridge), including temporary diversion of shallow utilities in this location. Construction of the Ruru Street bridge, including diversion of the Huia 2 watermain in this location. Temporary and permanent utility diversions (such as water, wastewater, stormwater, Vector overhead cables and ducting, gas and communications) along Fenton Street, Porters Avenue, Haultain Street and Wynyard Street to provide adequate clearance between the Huia 2 watermain and NAL, associated retaining walls, and the proposed Fenton Street pedestrian bridge.
Refer to the CEMP for a detailed description of the enabling works.
2.1 Construction methodology The Project will be divided into stages as described in the CEMP.
2.2 Discharges to air The main discharge to air from the construction activities outlined will be particulate matter (dust). Dust has the potential to cause nuisance or soil property if deposited in sufficient quantities in the environment. Fine dust particles and respirable crystalline silica (RCS) present in dust have the potential to affect respiratory heath while suspended in air. Dust from concrete crushing, breaking or handling is likely to have an increased RCS content. The following activities have the potential to result in discharges of particulate matter to air: •
Demolition activities (such as knocking down and breaking up of building material including plasterboard and blockwork, and cutting, breaking and crushing of concrete);
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Air Quality Delivery Work Plan • • • • • • • • •
Excavation, drilling and mining; Outdoor spoil handling/removal; Wind erosion of spoil and other stockpiled material; Basalt blasting; Basalt crushing; Mixing of bentonite powder to form bentonite slurry; Mixing of cement to form grout; Backfilling of excavations; and Movement of vehicles over unsealed surfaces (this includes trucks, loaders and excavators required for the tunnel excavation and spoil removal, and the delivery of construction materials such as concrete and steel).
Other minor discharges to air could include: • •
Combustion emissions from vehicles on site, which can affect respiratory health in the environment with sufficient exposure; and Odour from excavation or disturbance of contaminated soil (if encountered), which has the potential to cause nuisance.
The potential for discharge of asbestos dust is not considered in this AQ DWP. Procedures for managing asbestos dust during demolition works are specified in the Air Quality DWP for Mt Eden Demolition. Procedures for managing asbestos encountered during excavations are specified in the Contamination Delivery Work Plan (C DWP).
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Air Quality Delivery Work Plan
3.
Environmental setting
This section of the AQ DWP describes the environment surrounding the enabling works site in terms of meteorological influences on the transport of air contaminants and sensitivity of adjacent activities to those discharges.
3.1 Site The Mt Eden Enabling Works are being undertaken in the vicinity of the existing Mt Eden Station, which is an existing urban environment. The Project area is generally bounded by the NAL (south), Ngahura Street (west), Mt Eden Road (east) and Nikau Street (north), and is bisected by Shaddock Street. The area around the intersection of Porters Avenue / Haultain Street / Wynyard Road and along Fenton Street is also included in the Project area (“the Site�). Adjacent land uses comprise 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 likely to be generally representative of conditions over the Auckland isthmus as it is relatively free from nearby obstructions or eddies created by adjacent buildings. Although localised topographical features and adjacent buildings at the Mt Eden site are likely to alter wind conditions, the wind direction frequency trends illustrated below are likely to be broadly similar to those experienced at the Site. Based on the wind roses in Figure 3-1, winds are predominantly from the southwest and northeast, and therefore sensitive locations to the northeast and southwest of the site, respectively, are likely to be most frequently exposed to any off-site dust emissions from site activities. The amount of dust generated also largely depends on whether conditions are dry, and the wind speeds, with faster wind speeds increasing effect of wind erosion and the distance that the dust travels.
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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.
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 a south-westerly wind which will transport any emitted dust towards sensitive receptors to the northeast of site.
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Air Quality Delivery Work Plan
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 The Site is located in a mixed business zone adjacent to Mt Eden Station and features a range of adjacent activities, including activities sensitive to air pollution. Nearby activities that may be sensitive to dust and other air contaminants include: • • • • • • •
Residential apartments on Flower Street, Nikau Street, Fenton Street, Ngahura Street, Korari Street and Akiraho Street. Residential houses along Akiraho Street, Ruru Street and Sylvan Street. The Early Childcare Centre at the western end of Akiraho Street. Pedestrian access (to offices and other places of work) and parked vehicles along long roads. Bars and restaurants, particularly where premises include outdoor dining or entertainment areas. Retail, office and commercial premises. Cityside Baptist Church, Mt Eden Road.
The location of activities located within 100 m of the works area is shown in Figure 3-3.
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Air Quality Delivery Work Plan
Figure 3-3: Adjacent land use activities within 100 m of the site boundary. Page 17 | Mt Eden Enabling Works
Air Quality Delivery Work Plan
4.
Environmental performance
As required by the CRL designation conditions and the A2N resource consent conditions, the purpose 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. The key air quality compliance requirement for construction activities is that dust and other air discharges from the activities do not result in offensive or objectionable levels of dust or other contaminants beyond the site boundary. A range of air quality management and monitoring measures are specified in sections 5 and 6 to minimise the potential for adverse air quality effects and avoid the occurrence of offensive or objectionable dust or contaminants in the surrounding environment. These measures include monitoring trigger levels and response actions, which are intended to provide operational feedback to improve air quality management. The monitoring trigger levels are not intended as environmental performance standards in and of themselves.
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Air Quality Delivery Work Plan
5.
Management procedures
A range of routine measures will be used to manage and mitigate the effects of discharges of dust, odour or construction vehicle exhaust emissions during the Project. An adaptive approach to management of dust, including additional mitigation may 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 as determined using the Dust Risk Assessment; and / or
Complaints are received regarding discharges of dust, odour or construction vehicle exhaust emissions. If the available mitigation methods are unsuccessful in controlling discharges (i.e. dust and odour) that cause significant adverse effects on receptors beyond the Site boundary, the activities causing the discharge shall be suspended until adequate mitigation can be put in place.
•
5.1 Dust Risk Assessment To provide guidance to the Environmental and Sustainability Manager and area supervisors (refer Section 9 of this AQ DWP) on implementing dust mitigation, this Project will use a Dust Risk Assessment (DRA) approach. The DRA is described in Appendix C, and assigns a risk classification to each proposed activity with the potential to generate dust based on the scale of potential dust emissions and local environmental conditions (including sensitivity of adjacent activities and weather conditions). As the dust risk is dependent on local environmental conditions, the dust risk associated with activities should be re-calculated as conditions change. A “traffic light” indication of dust risk will be posted in each work area so that Project staff are aware of the dusk risk. The dust risk will be indicated as: • • •
Low risk (green). Moderate risk (orange). High or extreme risk (red).
5.2 Dust mitigation measures Dust management measures are specified for proposed enabling works activities in Table 5-1. Dust management measures may differ based on the dust risk of the activity calculated in accordance with the DRA in Appendix C. The control measures specified for the calculated dust risk level should be employed in addition to the measures for all preceding levels– e.g. a medium risk activity requires application of measures applicable to the corresponding low risk activity as well as measures specified for medium risk. Alternate methods may be employed after the effectiveness of those methods is demonstrated and this AQ DWP updated accordingly. The list of control methods is not exhaustive and additional methods may be found to be effective.
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Air Quality Delivery Work Plan Table 5-1: Dust management procedures.
Dust source
Dust risk level 1
Control measure(s)
Personal responsible
Stockpiles
Low
• Store stockpiled material containing a high content of fine material indoors or undercover where practicable. • Outdoor uncovered stockpiling of spoil is to be limited to a volume of no more than 24 m3 at any one time in an active construction zone (ACZ). This restriction does not apply outside ACZs, such as in construction support areas (CSAs). • Limit the height of any outdoor stockpiles to reduce wind entrainment (generally no greater than 3 m). • Orientate outdoor stockpiles to maximise wind sheltering as much as practicable. • Keep active stockpiles damp at all times or bunker or cover stockpiles of fine materials. • Dampen, cover or stabilise inactive stockpiles if they are producing visible dust emissions. • Stabilise stockpiles using various means depending on the length of inactivity (e.g. soil binders if inactive for 28 days). • Minimise drop heights and handling of stockpiled material to decrease potential for dust generation.
Environmental Sustainability Manager or delegated person
Medium
• Bunker or cover stockpiles of fine, dry materials if stockpile is existing for prolonged periods (greater than 1 month). • Maintain active stockpiles in damp condition with regular watering • Dampen inactive stockpiles if they are producing visible dust emissions • Utilise windbreak fences or temporary bunkers if they are producing visible dust.
Low
• • • • •
Vehicle movements (over sealed and unsealed surfaces)
Limit vehicle speeds to 20 km/h. Limit load sizes to avoid spillages. Cover loads of fine materials leaving or entering the site. Minimise on-site travel distances through appropriate site layout and design. Minimise mud and dust track out from unsealed areas to sealed areas by using wheel cleaning facilities at site exits to sealed roads.
Environmental Sustainability Manager or delegated person
1 Dust risk levels for each activity will be dependent on environmental conditions and are to be calculated in accordance with the procedure described in Appendix C. Page 20 | Mt Eden Enabling Works
Air Quality Delivery Work Plan Dust source
Dust risk level 1
Control measure(s)
Personal responsible
• Installation of wheel wash equipment (likely to be a hose). • Sealed access routes are to be cleaned with a vacuum sweeper truck on a weekly basis (at a minimum). • Any material identified to be tracked onto public roadways during regular inspections (or via notification from the public) is to cleaned with a vacuum sweeper truck.
Any outstanding demolition
Earth moving, mining and construction
Page 21 | Mt Eden Enabling Works
Medium
• If 1-hour average wind speeds are predicted in excess of 5 m/s, maintain unsealed surfaces in regular use in damp condition through surface watering (e.g. with water carts or fixed irrigation). • Where a suitable water supply is not available for surface watering, synthetic dust suppressants may be used as an alternative. The use of recycled oil-based suppressants is expressly prohibited.
High
• Maintain regularly used unsealed road surfaces in damp condition through surface watering in all wind conditions.
Low
• As required water sprays or fogging systems are used to dampen material to avoid dust generation.
Medium
• Only wet cutting of concrete should be undertaken. • Any breaking of concrete should be done under wet conditions (such as a water spray or fog directed at where the breaking is occurring).
High
• Dust from the removal of plaster board is controlled by wetting the plaster board as it is broken up. • Dust from knocking down and breaking up of blockwork or concrete, and from the removal of rubble will be controlled using water sprays or fogging systems directed onto the activity during dry and windy weather.
Low
• Limit the extent of excavation, mining and material handling activities in exposed areas carried out during dry and/or windy conditions as far as practicable. • Limit drop heights of material during handling, including from any conveyor transfer points. • Stabilise exposed areas not required for construction, access or parking, along with completed fill and spoil areas as soon as practicable.
Environmental Sustainability Manager or delegated person
Environmental Sustainability Manager or delegated person
Air Quality Delivery Work Plan Dust source
Dust risk level 1
Control measure(s)
Personal responsible
• Maintain dry surfaces of active earthworks and mining areas in damp condition. This should include pre-watering of active surfaces, prior to excavation and mining allowing enough time for moisture to penetrate the soil. • Remove excavated spoil from site on a regular basis. Medium and High
• Maintain surfaces of active earthworks areas in damp condition during dry weather. This should include pre-watering of earthworks surfaces, prior to excavation allowing enough time for moisture to penetrate the soil.
Loading and unloading of dry material
Medium
• Limit loading or unloading during windy conditions that cause dust to be emitted beyond the site boundary. • Cover loads of fine materials.
Environmental Sustainability Manager or delegated person
Blasting
Medium
• Blasting is to be carried out in accordance with dust management measures Blasting Management Plan • Topsoil and loose material overlying the rock shall be removed prior to blasting. • If the rock and adjacent material is dry, dampen with water where practicable.
Environmental Sustainability Manager or delegated person
High
• Use a fog canon on the area that is being blasted during the blast
Crushing (concrete and basalt)
Medium and High
• Only crushers fitted with water sprays or fogging systems are be used and those systems are to be operated at all times when crushing occurs. • Where practicable, the crusher plant is to be located to minimise the potential for wind to transport dust off-site (towards downwind off-site sensitive activities in particular).
Environmental Sustainability Manager or delegated person
Unpaved surfaces (including roads and yard areas)
Low
• Limit the amount of exposed surfaces as much as possible. • Use water sprays or watering trucks to dampen dry exposed surfaces. • 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 or other coarse material on surfaces.
Environmental Sustainability Manager or delegated person
Piling
Low and Medium
• All spoil to be placed in a pre-identified stockpile location and removed from site as soon as possible. • Any spilt material to be cleaned up immediately.
Environmental Sustainability Manager or delegated person
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Air Quality Delivery Work Plan Dust source
Dust risk level 1
Control measure(s)
Personal responsible
Cement silo
All dust risk levels
• Cement silos should be fitted and operated with a level alarm and pressure relief valves to ensure it is not over filled. • Cement silos should be fitted and operated with a filtration system as a dust management mechanism.
Environmental Sustainability Manager or delegated person
Rock drilling
Medium and High
• Drills used on rock or concrete in exposed areas should be fitted with dust suppression mechanisms where practicable.
Environmental Sustainability Manager or delegated person
Miscellaneous
All dust risk levels
• Ensure sufficient water is available for dust sprays on-site. • Taking account of daily of weather forecast wind speed and wind direction, and the condition of any excavated spoil (such as its dampness) before commencing an operation that has a high wind potential. • Installing wind fences where practicable and appropriate. Effectiveness is greatest where fencing is perpendicular to the prevailing northeast and southwest winds with porosity of about 50%. • Maintenance of surface moisture content: Watering or wet suppression is used to dampen dry or dusty exposed areas.
Environmental Sustainability Manager or delegated person
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5.2.1. Operation of dust control equipment Information will be sourced from the dust control equipment supplier on the following: •
Procedures for equipment inspection (including timeframes for regular inspections), maintenance, monitoring and recording, including baghouses, pressure relief valves, high level alarms and dust suppression mechanisms such as fog canons or sprays.
5.2.2. 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 (such as a baghouse) 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 Air Quality Log (log sheet template provided in Appendix E).
5.3 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 6 of this AQ DWP, or as a result of a complaint from a third party, the Site Supervisor will immediately undertake a review of site activities to determine the source of the dust and implement further mitigation measures as required in order to reduce the dust generation to acceptable levels. As appropriate the Site Supervisor will notify the Environmental and Sustainability Manager. In general, the additional mitigation will be those measures set out in Table 5.1. Once the additional mitigation has been implemented the Site Supervisor will review the monitoring data to ensure that it has been effective.
5.3.1. Sources of information The following are locations where information necessary for determining the Dust Risk Level and general dust control can be obtained: • • •
Site Specific monitoring web site where TSP and meteorological data can be accessed (to be established); and Met Service: http://www.metservice.com/towns-cities/auckland/auckland-central MetVUW North Island forecast charts: http://metvuw.co.nz/forecast/.
5.4 Odour control during contaminated material handling Odour may be emitted if contaminated soil is encountered during the excavation works, depending on the nature of the contamination. This section of the AQ DWP sets out the mitigation required by CRL designation condition 59.3(g) for minimising any potential for odour if contaminated material is encountered. Odour emissions will be monitored in accordance with Section 6.6 of this AQ DWP during the excavation of contaminated material and the following techniques considered if necessary: Page 24 | Mt Eden Enabling Works
• • •
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, the odorous material shall be covered with uncontaminated soil or other suitable material to suppress odour emissions, and work in that area suspended until suitable mitigation measures can be put in place.
5.5 Control of vehicle exhaust emissions The following key actions shall be carried out to minimise emissions from vehicle exhausts: • •
•
All construction machinery used on the site will be maintained at least 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.
5.6 Dust contingency measures In the event of significant long-term, unavoidable dust emissions, that results in verified complaints of dust inside buildings, the contractor will implement the following contingency measures, dependent on the nature of the complaint: •
Link Alliance will arrange for routine commercial cleaning of properties that are affected by adverse effects of dust.
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6.
Monitoring requirements 6.1 Dust monitoring
The overall approach to dust control for the Mt Eden Enabling Works is based on visual monitoring combined with targeted ambient dust monitoring; good management of the construction areas; and a rapid response to any of the triggers outlined in Sections 6.3.2 or 6.3.4, or complaints received. Good practice focusing on proactive measures will aid in avoiding significant dust emissions, however if dust emissions do occur, the monitoring will help to identify such occurrences and enable a prompt response.
6.2 Visual inspection and monitoring methods Visual monitoring of all construction areas will be undertaken by the Environmental and Sustainability Manager (or delegated person) on a daily basis, or more frequently if conditions change. This type of monitoring relates to the control measures described in Section 5 of this AQ DWP and will include proactive measures to avoid dust emissions. Table 6-1 below describes the visual dust monitoring activities to be undertaken during construction. Outcomes of visual inspections are to be recorded in the Air Quality Log (log sheet template provided in Appendix E). Table 6-1: Visual dust monitoring programme
Monitoring activity
Frequency
Check weather forecasts for strong winds and absence of rainfall to plan appropriate work schedule and dust management response.
Daily
Inspect land adjacent to the site, construction exits and adjoining roads for the presence of dust deposition and/or accumulation of dust material.
Twice daily
During repainting works at the apartment blocks at 10 Ruru Street inspect Nikau Street boundary for signs of visible dust emissions towards apartment blocks
Twice daily during repainting works at the apartment blocks at 10 Ruru Street
Observe weather conditions including wind and rain via observations and data outputs from weather stations.
Daily and as conditions change
Inspect all exposed un-stabilised surfaces for dampness and that the extent of those areas is being minimised.
Daily and as conditions change
Inspect stockpiles to ensure enclosure, covering, stabilisation or dampness. Ensure stockpiles are no greater than a combined 24 m3 and less than 3 m in height 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) to ensure equipment is maintained and functioning to effectively dampen exposed areas.
Weekly
Monitor dust generating activities and water application rate.
In winds over 5 m/s (1-hour average)
Check for dust on local roads being used to access the site.
Daily
Inspect any wheel wash equipment to ensure effective operation and that sediment laden water is not being tracked off site by vehicles.
Weekly
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Monitoring activity
Frequency
Monitoring that water sprays/fogs are being operated when crushing activities are being undertaken, and that control measures to minimise dust from drilling when setting charges are being implemented and effective.
When crushing activities are being undertaken.
6.3 Instrumental monitoring 6.3.1. Dust monitoring Continuous instrumental dust monitoring will be carried out at representative locations adjacent to sensitive areas when in the vicinity of dust generating activities. It is expected that at least two dust monitors are to be used to monitor dust from the Site. Condition 224 (i) of the A2N resource consent infers that three dust monitors are to be associated with the Mt Eden Active Construction Zone. However, a downwind and upwind monitor arrangement (with a single instrument in each direction) coupled with regular visual dust inspections in accordance with Section 6.2 provides an appropriate level of feedback information for the management of dust during the Mt Eden Enabling Works. The initial location of the monitors will be as follows: •
•
At the Mediaworks building at the corner of Nikau Street and Flower Street adjacent (to the north of) the proposed portal location. This site is intended to monitor particulate levels downwind of the ACZ in prevailing southwest winds. At the existing Mt Eden station platform adjacent (to the south of) the proposed concrete crusher location. This site is intended to monitor particulate levels between the crusher and adjacent residential and commercial activities on Akiraho Street.
The location of the monitors may need to be re-evaluated, and potentially moved, by the Environmental and Sustainability Manager (or delegated person) if the location of dust generating activities shift to continue to provide effective monitoring of particulate levels. As required by condition 227 of the A2N resource consent, ambient dust monitoring will commence prior to activities that have the potential for significant dust emissions. Dust monitoring have already been installed on-site as a consequence of the Mt Eden demolition works. Background concentrations of TSP have been established prior to commencement of the demolition works. This pre-construction monitoring will enable the trigger levels to be revised if they are too high (not reflective of dust impacts), or low (they are being frequently exceeded due to off-site dust emission sources). Particulate instrumental monitoring for the Project will include: • • • • •
Continuous instrumental monitoring of dust at the locations downwind and upwind of works locations; Calculation of 1-hour average concentrations from real-time monitoring data; Remote display of real-time particulate data (e.g. via the internet); Provision for alarms on 1-hour average concentrations measured above dust trigger levels (visual and/or via internet, email and mobile phone); Recording/logging of monitoring data; and
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•
Where practicable the monitors shall be located in accordance with AS/NZ 3580.1.1:2007 Method for Sampling and Analysis of Ambient Air – Guide to Siting Air Monitoring Equipment.
Dustprofiler particle counters manufactured by Aeroqual are to be installed to monitor dust at the above locations. Other options that meet the requirements of the CRL designation and resource consent conditions include: • •
Remote nephelometers; or Beta attenuation monitors.
6.3.2. Dust trigger levels and alerts Dust monitoring results are to be compared with trigger levels to indicate where dust levels may have the potential to cause adverse air quality effects and where modification to dust management measures may be required to avoid this outcome. In the first instance, trigger levels published by the Ministry for the Environment (MfE) 2 are adopted as operational dust trigger levels. In the event of monitoring results exceeding the trigger level, response actions are to be taken as outlined below. The trigger level values are described in Table 6-2. Table 6-2: Dust trigger levels
Discharge
Trigger Level
Dust monitoring*
• MfE recommended trigger values for TSP concentrations: − 200 µg/m3 (rolling 1-hour average)** OR • MfE recommended trigger values for PM10 concentrations: − 150 µg/m3 (rolling 1-hour average)**
• Evidence of dust on windows or cars (a finger run down the glass leaves a clear line) • Dirt on clean washing *The dust monitoring trigger levels should be updated to reflect the method of monitoring employed, if required (refer below). ** The MfE recommended trigger values do not relate specifically to rolling averages, which are specified in this case to provide instantaneous feedback on dust levels. Dust deposition
The dust monitoring trigger levels should be reviewed through regular (at least monthly) review of monitoring results. The regular review should include comparison with: • • • •
The trigger alerts specified in Table 6-2; A review criterion for TSP concentrations of 60 µg/m3 (24-hour average); Visual monitoring records; Dust complaints.
If review of monitoring results indicate the triggers specified in Table 6-2 have not provided suitable advance indication of potential adverse air quality effects, the triggers may require modification.
Ministry for the Environment. 2016. Good Practice Guide for Assessing and Managing Dust: Ministry for the Environment. Page 28 | Mt Eden Enabling Works 2
The monitoring equipment will be set up with text alerts to key personnel in the relevant work zone, when dust concentrations exceed the trigger values set out in Table 6-2. At a minimum this will include: • • • •
The Project Manager; The Environmental and Sustainability Manager; The Construction Manager; and Site Manager.
If Project personnel change, the Instrument Technician will be contacted to update the alerts. If a dust trigger alert is sent, one of the above staff members will immediately (within 30 minutes) respond and investigate the cause of the alert. This investigation will: • •
Determine if the alert is real and not caused by equipment malfunction; and Identify the source of dust and check to see that all of the required mitigation measures are being implemented.
If it is determined that construction activities are the cause of dust, and that mitigation measures outlined in Section 5 of this AQ DWP are not effective for controlling dust, the contractor will implement the dust contingency measure outlined in Section 5.6 of this AQ DWP. If these measures fail to effectively manage dust to acceptable levels, works shall be halted until it can be determined why dust emissions are occurring and what additional mitigation measures are required to control ambient dust to acceptable levels. The findings of the investigation will be recorded in the Air Quality Log (refer to Section 9.1 of this AQ DWP).
6.3.3. Meteorological monitoring Continuous instrumental monitoring of weather conditions at the site can provide useful information for dust management. A meteorological station that can continuously measure the following parameters is to be installed as part of the Mt Eden Enabling Works: • • • • •
Continuous instrumental monitoring of wind direction, wind speed, rainfall, and temperature; Recording of 1-minute and calculation of rolling 1-hourly averaged data; Provision for alarms on wind speed data measured above wind speed trigger levels (visual and/or via internet, email and mobile phone); Remote display of real-time meteorological data (e.g. via the internet); and Recording/logging of monitoring data.
Where practicable the monitors shall be located in accordance with AS 3580.14 -2011 Ambient Air – Guide for the Measurement of Horizontal Wind for Air Quality Applications. It will preferably be located to avoid adjacent buildings and other obstructions, where possible. In the absence of on-site weather monitoring data, information of current and preceding wind conditions may be obtained from: • • •
Weather observations from other CRL works areas (if available); Weather observations from other weather stations in Central Auckland (if available); Current wind observations are displayed by the Met Service at www.metservice.com.
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6.3.4. Wind speed trigger dust alerts The Trigger Levels proposed for wind speed measurements are detailed in Table 6-3. Table 6-3: Wind speed trigger levels
Discharge
Trigger Level
Wind speed
• Wind warning level: − 5 m/s (1-hour average) − 10 m/s (1-minute average occurring twice in 20 minute period)
In the event that wind speeds exceed the trigger values set out in this AQ DWP, text alerts will be sent to nominated Project personnel in the relevant work zone. As a minimum, the nominated personnel will include: • • • •
The Project Manager; The Environmental and Sustainability Manager; The Construction Manager; and The Site Manager.
If 1-hour average wind speeds exceed 5 m/s then visual monitoring of the work area will be undertaken to ensure that all appropriate mitigation outlined in this AQ DWP is being implemented and are effective.
6.3.5. Alternative management approach There is the potential that continuous instrumental measurement of particulate concentrations may be influenced by either background particulate emission sources (not associated with the Mt Eden Enabling Works, such as other construction activities, domestic home heating or motor vehicle emissions) or rainfall/high humidity conditions that can affect dust monitoring instruments. Previous experience at other CRL construction sites has shown that comparison of continuously measured ambient particulate concentrations with defined trigger levels may not always be indicative of adverse dust effects or a potential for dust nuisance experienced beyond the site boundary. If investigations of exceedance trigger levels establish that trigger events are not associated with onsite dust generation, an alternative dust risk assessment approach can be implemented. In that instance and if identified to be required by the Environmental and Sustainability Manager in consultation with the Auckland Council Monitoring, the following alternative approach will be taken: •
•
•
A response to individual dust trigger alerts in accordance with Section 6.3.2 will not be mandatory and instrumental dust monitoring results will instead be reviewed against the trigger levels specified in by the Environmental and Sustainability Manager (or delegated person) on a daily basis. Visual dust inspections are to continue in accordance with Section 6.2. If identified by the Environmental and Sustainability Manager as a result of a review of instrumental dust monitoring results, visual inspections may be required at an increased frequency. Dust risk is calculated each morning by site engineers in accordance with Section 5.1 and Appendix C and used to inform appropriate management procedures.
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6.4 Monitoring data All monitoring data from the dust monitors and the on-site meteorological station will be available to Project staff on-line, and electronically recorded for future reference.
6.5 Monitoring equipment maintenance and calibration The dust monitoring equipment and meteorological equipment will require periodic maintenance and calibration checks. These will be done at a frequency and as per manufacture specifications by either site personnel, who have received appropriate training, or an Instrument Technician. Unless the instrument recommends a higher frequency, at least quarterly maintenance and calibration will be carried out by a qualified Instrument Technician familiar with the equipment installed. In the event that there is an equipment malfunction, or the equipment needs to be relocated for some reason, then the Instrument Technician will attend to this.
6.6 Odour monitoring Odour monitoring (observations) will be undertaken when it is considered likely that odorous material may be encountered (such as contaminated soil materials) during excavations. The decision to undertake monitoring by a suitable experienced odour observer will be made by the Environmental and Sustainability Manager. The frequency of odour monitoring will be dependent on the nature/scale of the source, location in relation to sensitive receptors, and meteorological conditions during exposure. Odour observations will occur: • •
When potentially contaminated material is excavated and loaded onto trucks; and When odour complaints have been received.
The Environmental and Sustainability Manager will ensure that a trained odour scout is available to undertake odour observations as required. Monitoring will involve the odour observer being positioned downwind of the works and assessing odours on the intensity scale set out in Table 6-4. Where odours are identified as being “Distinct” and above, and the odour characteristic unpleasant, mitigation measures will be implemented. All observations will be recorded in the Air Quality Log (refer Section 9.1 of this AQ DWP). Table 6-4: Odour intensity scale
Intensity scale
Criteria
0
No odour
1
Very weak
2
Weak
3
Distinct
4
String
5
Very string
6
Extremely strong
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The odour observer 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, the odour observer shall make appropriate observations and document these also. As exposed odorants may potentially also present health risks, the procedures outlined in Section 7.1 of the Contamination DWP for unexpected discovery of contamination should also be followed.
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7.
Communication and complaints 7.1 Project communications
Section 7 of the Communication and Consultation Plan details how communities in the vicinity of the construction works will be communicated with in relation to the management of adverse effects relating to air quality. Communications will focus around informing communities of dust management and monitoring measures to be implemented during the Project and providing updates on these aspects as appropriate during the construction works.
7.2 Complaints Although the mitigation measures described in this AQ DWP are aimed at avoiding discharges to air, complaints may be received by 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 below.
7.2.1. Receiving and recording complaints A complaint may be received from a member of the public via the following: • • •
Direct call to the Project Hotline. Complaint received by Auckland Council which notifies the Link Alliance of the complaint. Written or email correspondence.
In all circumstances, correct and accurate information needs to be recorded by the person receiving the complaint in order to help investigate the cause of the complaint, and ensure appropriate mitigation has or will be undertaken. Any complaints received should be recorded in a complaints file, and an investigation undertaken as outlined in the CEMP and Project Communication and Consultation Plan. The following guide should be followed when a complaint is received: • • • • • • •
Record the details provided about the incident by the complainant. The name and contact details of the person(s) who raised the complaint (unless they elect not to provide this). Acknowledge receipt of the concern or complaint, and assure that an initial response shall be undertaken within 24 hours of receiving a complaint, and resolved as soon practicable. Known construction activities at the time and in the vicinity of the complainant during the concern or complaint period. Remedial actions undertaken (if any) and the outcome of these, including monitoring of the activity. Weather conditions at the time of the concern or complaint, including wind direction. Reporting of the investigation in the complaints file.
7.2.2. Investigating complaints The investigation of all complaints relating to air discharges will involve the following: •
Information about the incident as described by the complainant.
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• • • • •
Weather conditions at the time of the complaint, including wind direction and speed, and rainfall (if any). Reporting the findings and recommendations. Actions and time taken to close-out complaint. Communication with the complainant. Ensure reporting of the investigation is recorded in the complaints file.
An investigation of the complaint will require the Site Supervisor or delegated staff member to go around the whole site and make visual observations about activities occurring on site. This may also include going to the location where the complainant observed the impact. At all times during the complaints investigation, appropriate health and safety procedures must be followed.
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8.
Environmental training 8.1 Project staff
All Project staff (contractors and subcontractors) will undergo general environmental awareness training and training about their responsibilities relating to 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: AQ DWP specific training requirements
Training requirements
Frequency
Attendance
Introduction to the on-site monitoring equipment
As required and during new staff induction
Site Manager, Environmental and Sustainability Manager, delegated staff member and duty managers
Responding to continuous dust monitoring trigger alarm alerts
As required and during new staff induction
Site Manager, Environmental and Sustainability Manager, delegated staff member and duty managers
Responding to complaints regarding dust and air quality concerns
As required and during new staff induction
Site Manager, Environmental and Sustainability Manager, delegated staff member and duty managers
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9.
Record keeping 9.1 Air quality log
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 in dust emissions. Various control and mitigation measures will be carried out on-site to prevent such effects, and monitoring and inspection procedures will be used to assess the level of dust emissions both on the Project site and beyond its boundary. Recording relevant monitoring and inspection results, as well as the conditions of external and internal factors, can help 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 daily air quality inspections are detailed below: • •
The Construction Manager (or delegated person) will fill out an Air Quality Daily Log (refer Appendix E) form each day and maintain the record on site. The following information will be recorded: o Records of dust monitoring trigger events specified by this DWP, including identification of the monitor ID which registered the trigger event, the time and the averaging period of the TSP trigger event; o Any dust control equipment malfunctions and any remedial action(s) taken; o Results of the Visual 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.
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10. Roles and responsibilities The key management roles in relation to environmental management during construction are outlined in Section 4.1 of the CEMP. Specific roles relating to this AQ DWP are detailed in Table 10-1. Table 10-1: AQ DWP specific training requirements
Organisation
Role
Responsibilities
Link Alliance
Project Manager
Overall responsibility for site environmental management. Reviewing CEMP and sub-plans, including the AQ DWP.
Environmental and Sustainability Manager
Reporting on environmental performance. Inspection of works to assess compliance with the AQ DWP and sub-plans. Assess requirement for alternative dust management approach. Assess the requirement for odour monitoring.
Construction Manager
Report to AT any changes to construction techniques or natural environmental changes which require alterations to existing consents or new resource consents. Prepare, review and update CEMP, including the AQ DWP and other sub-plans. Update and maintain the environmental portion of the Project Risk Register. Maintain Daily Logs and Complaint Records. Training of all staff including subcontractors.
Consents and Compliance Teams
Approve the CEMP, including the AQ DWP and other sub-plans. Auditing to assess that compliance with the AQ DWP.
Auckland Council
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Appendix A: ISCA Requirements Table A-1 identifies the ISCA Credit Requirements relevant to this AQ DWP and where they are addressed in the document. Table A-1: ISCA requirements
Credit
Requirement
Relevant section
Other relevant information/comments
DIS-4 Level 1
Measures to minimise adverse impacts to local air quality identified and implemented
Table 5-1
Also refer to Project Erosion and Sediment Control Plan
DIS-4 Level 1
Monitoring of air emission and/or quality is undertaken at appropriate intervals
Section 6
DIS-4 Level 1
Monitoring of air emission and/or quality is undertaken in response to complaints
Section 7.2
DIS-4 Level 3
Monitoring and Modelling demonstrates no exceedances of air emission or air quality goals
Section 6
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Note dust trigger levels specified in section 6.3.2 are not intended as air quality goals. Also refer to Monitoring Results and Reports.
Appendix B: Staging Drawings Refer to Appendix B of the CEMP
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Appendix C: Dust Risk Assessment Procedure The risk of adverse off-site dust impacts and the level of dust mitigation and management processes required to minimise will vary depending on various factors including: • • •
Proximity of activity to sensitive locations in the surrounding environment; Weather conditions such as wind speed and whether the ground is dry; and The dust emission potential associated with the type of activity being undertaken.
The objective of this dust risk assessment (DRA) procedure is to provide guidance to the Environmental and Sustainability Manager, and site supervisors of the level of dust management procedures that should be implemented depending on what activity is being undertaken on site. The DRA procedure is based on those implemented by London Council and is outlined in Figure C-1 below 3,4.
Step 1
Calculate environmental Step 2 dust senstiivity from local Calculate dust risk for weather conditions and each activity to be proximity of sensitive undertaken (Table A-2). receptors (Table A-1).
Step 3 Ensure the appropriate level of dust management processes are implemented (section 5.2), and that the dust risk is displayed on-site.
Figure C-1 Graphical representation of process to determine dust risk
Calculating environmental dust sensitivity and dust transport potential The calculation of environmental dust sensitivity (and potential fort dust transport) requires identification of the following: 1. Identify location of nearest residential activity to the works activities to be undertaken and identify approximate separation distance for each works activity. 2. Review local weather forecast over works period for wind speeds (e.g. via https://www.metservice.com/towns-cities/auckland/auckland-central) and on-site meteorological data for rainfall in preceding 48 hours. With this information the environmental dust sensitivity rating can be calculated from Table C-1 below.
The Control of dust and Emissions During Construction and Demolition. Greater London authority, July 2014. Guidance on the assessment of dust from demolition and construction, Version 1.1, Institute of air Quality Management, February 2014. Page 40 | Mt Eden Enabling Works 3 4
Table C-1 Environmental dust sensitivity calculation
Receptor sensitivity
Environmental dust sensitivity
Residential receptor within 100 m of activity Residential receptor within 200 m OR other activities within 100 m of activity All other scenarios
Meteorological influences Predicted 1-hourly average wind speeds >5 m/s AND <1 mm of rain in the preceding 48 hours
Predicted 1-hourly average wind speeds >5 m/s OR <1 mm of rain in the preceding 48 hours
Predicted 1-hourly average wind speeds <5 m/s AND >1 mm of rain in the preceding 48 hours
High
Medium
Medium
Medium
Medium
Low
Low
Low
Negligible
Dust risk calculation The dust risk is subsequently derived from the dust emission potential of each prescribed activity associated with the works and the calculated environmental risk. Table C-2 Overall dust risk calculation
Activity*
Overall dust risk of activity
Calculated environmental dust sensitivity High
Medium
Low
Crushing
High
High
Medium
Blasting
High
High
Medium
Rock drilling
High
Medium
Medium
Earthworks and mining
High
Medium
Low
Vehicle movements over unpaved surfaces
High
Medium
Low
Demolition
High
Medium
Low
Cement silos
High
Medium
Low
Piling
Medium
Medium
Low
Outdoor stockpiling
Medium
Medium
Low
Ground stabilisation
Medium
Low
Low
Construction
Medium
Low
Low
Low
Negligible
Vehicle movements over Low paved surfaces * Each activity has a different dust emission potential
The calculated dust risk should be displayed on-site to ensure site staff implement the appropriate level of dust management procedures as specified in section 5.2. The dust management procedures for each activities’ risk level is described in Appendix D.
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Appendix D: Dust Risk Controls Sheet To be completed by the construction manager or others involved in the implementation of controls based on the requirements of section 5.2.
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Appendix E: Air Quality Log Sheet
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DAILY LOG FORM Date:___/___/_____ Mon Tue Wed Thu Fri Sat Sun
VISIBLE DUST EMISSIONS Source
Level*
Colour/Opacity
Time
Weather Cond.
Wind Speed / Wind Direction
(i.e. rain, windy, calm)
(e.g. “7 m/s / NE”)
_______________
____
___________
___:____
____________
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*Levels (extent) of visible dust emissions: (1) Minor visible emissions (<5m from source); (2) Moderate visible emissions (<30m from source); (3) Major visible emissions (>30m from source).
INVESTIGATION AND RESPONSE Date event was investigated:___/___/_____ Person responsible for investigation and response:________________________________ Possible cause(s):
Corrective actions:
Dust from wind erosion of exposed ground
Date:
Description:
Watercart not used properly
___/___/_____
___________________________________________
Exceedance of speed limit in unpaved surface
___/___/_____
___________________________________________
Materials not handled or stored properly
___/___/_____
___________________________________________
Loading/Unloading not carried out properly Other_________________________________________ ________________________________________________ ________________________________________________ ________________________________________________
Preventive actions: Date:
Description:
___/___/_____
___________________________________________
___/___/_____
___________________________________________
___/___/_____
___________________________________________
________________________________________________
VEHICLES AND MACHINERY – PRESTART CHECK Equipment identification
Excessive or prolonged visible emissions observed?
If yes, describe action taken (e.g., equipment repaired or removed from site within 24 hours):
___________________
________________________
_________________________________________________________
___________________
________________________
_________________________________________________________
___________________
________________________
_________________________________________________________
Person responsible for the above information: Name:______________________ Job Title:_________________________ Signature:______________________ Date:___/___/_____
Appendix F: Record of CLG, IPR and Auckland Council Comments F.1
CLG Comments
A Mt Eden CLG meeting was held on 8 October to discuss the Mt Eden Enabling Works and for the CLG to provide comments / feedback on the CEMP and sub-plans, including this AQ DWP. Comments from the CLG are recorded in Table F-1 below. Table F-1: Response to CLG feedback.
Comment ID
Feedback received from
Feedback comment
Response
CLG 01
Megan Ottley, 10 Ruru St
Apartments (three blocks) at 10 Ruru Street are scheduled to be re-painted in 2020 during the works
Further visual dust inspection requirements have been added to section 6.2 in the event the repainting of the apartment blocks occur
CLG-02
Richard Coombes, 3 Akiraho St
Movements of trucks will cause dust issues
Truck movements (over unsealed surfaces in particular) have the potential to generate dust. These emissions are to be managed in accordance Table 5 1 of the DWP.
CLG-02
Richard Coombes, 3 Akiraho St
Cars in the apartment block car park have already covered in a layer of dust. Will targeted monitoring be done off site?
Dust deposition reported at 3 Akiraho St could potentially have resulted from preceding demolition works (e.g. at the South Pacific Timber site) or from background sources (e.g. pollen). A dust monitor (measuring suspended dust concentrations) is recommended to be located on the south or southwest side of the Site (upwind of the works activities in prevailing southwest winds and downwind in northeast winds that are more common in summer months). A further monitor is recommended on the opposite side of the Site at Nikau Street.
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F.2
Independent Peer Review Comments
Comments received from the independent peer review (IPR) are recorded in Table F-2 below. Table F-2: Response to Independent Peer Review feedback.
Comment ID
Content
Feedback comment
Response
IPR 01
Section 6.3.1
It is noted that the method for particulate monitoring has not yet been determined. (Section 6.3.1) Three options are given. If particle counters are used, a dust trigger levels will need to be added to reflect the output of that instrument. That trigger value needs to be in Table 6.2 if there is any likelihood that this method is to be used. If particle counters are used, a dust trigger levels will need to be added to reflect the output of that instrument.
Particle counters have now been confirmed as the dust monitoring method to be employed. Units are subject to factory TSP calibration and the trigger levels in Table 6-2 remain unchanged on this basis. Requirements for review of dust monitoring results have been added to Section 6.3.2 including a potential for update of trigger levels.
IPR-02
Section 6.6
Section 6.6 relates to odour monitoring. The suggestion is that odour may be produced from the site if potentially contaminated material is excavated. The identification of nuisance odour described is considered appropriate. However, as the excavation of contaminated material is likely to be an unplanned event, it would be useful to see some process for the identification of the cause of the odour and some public health risk assessment of that odour. This may be detailed elsewhere, such as in a contamination plan for the project, and could be cross referenced in this document. However, this reviewer has not seen any contamination plan.
Reference to section 7.1 of Contamination DWP for unexpected discovery of contamination added to section 6.6.
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F.3
Auckland Council Comments
Comments received from the Auckland Council (AC) technical review are recorded in Table F-3 below. Table F-3: Response to Auckland Council technical review feedback.
Comment ID
Content
Feedback comment
Response
AC 01
Section 2.2
[Concrete crushing] May require mention of crystalline silica as a risk – see Mt Eden Demo AQ DWP.
Description of the potential effects of each emitted contaminant added to section 6.2, including reference to potential health effects of respirable crystalline silica.
AC-02
Section 2.3
[Asbestos removal] Was referenced in the Mt Eden Demo AQ DWP; okay to leave it there as most demolitions completed under that works package.
References in section 2.3 updated to Mt Eden Demo AQ DWP for demolition asbestos and to the Contamination DWP for excavation asbestos.
AC-03
Section 5.2, Table 5-1 (Stockpiles)
I agree with need for further discussion. On an effects basis, I have no issue with stockpiles as dust can be controlled by other measures than the 24 m³ maximum size threshold. However, on a consent compliance basis, it’s hard to get around this specific figure. I don’t believe that merely shifting the stockpiles to the CSA from the ACZ is a positive dust control measure.
Interpretation/application of outdoor stockpiling condition requirements are currently subject to discussions between the Link Alliance and Auckland Council. This DWP will be updated on the basis of the outcome of those discussions.
AC-04
Section 5.2, Table 5-1 (Vehicle movements over sealed and unsealed surfaces)
No mention of sweeping any sealed vehicle accessways. The exit needs to be sealed and cleaned regularly. Some further mention of avoiding tracking material onto the public road by cleaning (not just wheel washes).
Vacuum sweeping requirements for sealed accessways and public roads added to Table 5-1.
AC-05
Section 6.2, Table 6-1
Contingency measure for tracking on public roads required elsewhere in the DWP.
Section 5.2, Table 5-1 updated to include responses to identification of material tracked onto public roads
AC-06
Section 6.3.1
I’m not opposed to this reduction from 3 monitors, but it is hard to sign off as compliant with the A2N resource consent condition. I suggest either ‘general compliance’ is sought or a s127 of the RC sought (which could also resolve the 24 m³ stockpile limit).
The requirements relating to number of monitors are subject to similar discussions referred to in relation to comment AC-03 above. This DWP will be updated on the basis of the outcome of those discussions.
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Comment ID
Content
Feedback comment
Response
AC-07
Section 6.3.1
Text deleted in response to following comment (AC-08).
AC-08
Section 6.3.1
The prevailing wind directions appear incorrect here? SW with 2° NE (particularly in summer) – as stated in the controls table about wind fences. It’s a little surprising there isn’t yet more certainty on the instrumental monitoring – it would be easier to sign off on the AQ DWP if info of the monitor type and a map of indicative locations were included. Isn’t one already installed from the demo works?
AC-09
Section 6.3.2, Table 6-2
I agree with these 1-hr average trigger levels – high sensitivity environment under the GPG:Dust. Thoughts invited on also including 5-min and/or 24-hr average trigger values for TSP. Other CRL AQ DWPs have included the 24-hr trigger (60 µg/m³ as alert; 80 µg/m³ not to be exceeded). Whether formally included as a trigger or not, a 24-hr avg TSP value of >60 µg/m³ could indicate further dust controls are required, so some consideration of longer-term dust concentrations recorded should be made as part of the on-going Dust Risk Assessments.
Trigger levels based on 5 minute average particulate concentrations have not been included as they may be subject to short-term fluctuations that may not be reflective of a potential for dust nuisance. Use of rolling averages over longer averaging periods (e.g. 1 hour) would provide similarly rapid feedback on sustained dust levels that are more likely to cause dust nuisance. Table 6-2 has been updated to clarify that triggers apply to rolling 1-hour average concentrations. 24-hour average dust triggers would not provide for rapid response to increasing dust levels (even as a rolling average) and as a result have not been specified in Table 6-2. However, a 24-hour average review criterion may have use in illustrating trends in dust levels. Requirements for regular review of monitoring results are now specified in Section 6.3.2 including comparison with the suggested criterion for TSP concentrations of 60 µg/m3 as a 24-hour average.
AC-10
Section 6.3.3
Preference for 10 m weather mast deleted.
AC-11
Section 6.3.4
That [preference for a 10 m weather mast] would be ideal, but less robust met monitoring (i.e. monitor mounted to the dust instrument) would also be acceptable and still give useful info to supplement Met Service data. A 1-hr average [for the wind speed trigger] is quite coarse. GPG:Dust suggests trigger value of 10 m/s as a 1 min average – if exceeding twice in a 20 min period, then undertake mitigation measures.
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Section 6.3.1 has been updated to describe the initial monitoring locations and methods.
Additional short term wind trigger added to Table 6-3 to provide additional notification of strong gust speeds. Visual inspection trigger remain based on 1-hour averages to avoid repeated inspections on 20 minutes bases.
Comment ID
Content
AC-12
Section 6.3.4
AC-13
Section 6.3.5
AC-14
Section 9.1
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Feedback comment Not a big issue though; 5 m/s as a 1-hr average would be a reasonably windy day and visual assessments would likely have already concluded a high Dust Risk Index. Note this inspection is additional to the routine daily monitoring in Table 6-1 I’d prefer if this [use of the alternative dust management approach] was discussed with Council Monitoring Officer first (once false dust alerts identified as an issue). Suggest insert ‘identified to be required by the ESM in consultation with Council Monitoring Officer’ Only 1-hr average trigger values in the above.
Response
Corresponding inspection requirement exists in Table 6-1. Suggested modification adopted.
Reference to average concentrations removed.