Aurecon Revision A 28 September 2016 Draft for Aurecon review
Aurecon Revision B 3 October 2016 Draft for Aurecon review
Aurecon Revision C 4 October 2016 Draft for Aurecon review
Aurecon Revision 1 11 October 2016 Draft for AT review
Aurecon Revision 2 2 November 2016 Draft for AT review
Aurecon Revision 3 23 November 2016 Updated for Consent
Aurecon Revision 4 24 November 2016 Updated for AT review
Aurecon Revision 5 13 December 2016 Final for Consent
Aurecon Revision 6 10 August 2017 Updated with increased CSA at 28 Mt Eden Rd
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
Community
APPENDIX D Report
STORMWATER
List of Abbreviations
Acronym Meaning
AC Auckland Council
AT Auckland Transport
ADWP Air Quality Management Plan
CRL City Rail Link
CSA Construction support area
CSMP Contaminated soils management plan
NAL North Auckland Line
NZTM New Zealand Transverse Mercator (map projection)
RMA Resource Management Act 1991
TBM Tunnel Boring Machine
List of Units
Unit
°C
Meaning
Degrees Celsius
km Kilometre
km/hr Kilometre per hour
m Metre
m/s Metres per second
m² Square metre
m³ Cubic metre
1.0 INTRODUCTION
1.1 Overview
This Air Quality Delivery Work Plan1 (AQDWP) has been prepared to manage air quality during construction activities associated with the diversion of the Nikau Street Stormwater Main Realignment Project (the Project), which is an element of the City Rail Link (CRL) project.
This AQDWP manages the air quality for the Project for works both within and outside the designation.
The purpose of this AQDWP is to provide a framework for managing the air discharges, especially dust emissions, so that potential significant adverse effects beyond the construction site are avoided. This is to be primarily achieved by:
Identifying the sources of fugitive dust emissions associated with the construction activities
Describing controls and procedures to prevent fugitive dust emissions from each significant source.
Describing inspection and monitoring programs
Describing the training of personnel necessary for the AQDWP to be implemented
Describing the necessary record-keeping to verify and document ongoing compliance with the AQDWP
Establishing the roles and responsibilities of staff throughout the organisation in relation to the AQDWP
Dust emissions are considered to be the primary contaminant of concern discharged to air from the proposed works. Combustion emissions from the operation of vehicles, and any residual emissions from emission control equipment associated with the works are expected to give rise to air quality effects that are negligible. The Project is not expected to give rise to any offensive or objectionable odour effects as there are no known sources of odour associated with the three CSAs. As such, this AQDWP focuses on the management of dust emissions from the works as the effects of other emission sources are considered insignificant.
This AQDWP is an appendix of the Construction Environmental Management Plan (CEMP) which supports the outline plan and resource consent application to be lodged by Auckland Transport (AT) with Auckland Council (AC) for the proposed works.
Golder confirms that the content of this report has been written with reference to the detailed design drawings and the Construction Environmental Management Plan (Appendices B and D of the Assessment of Environmental Effects), prepared by Aurecon New Zealand Limited.
1.2 Air Quality Delivery Work Plan
The structure of the AQDWP is designed to provide a logical and practical framework for the management of air emissions from the Project construction and support sites. The AQDWP has the following key sections:
Section 2.0 provides a description of the project and site construction activities
Section 3.0 identifies the potential dust emissions sources and the structural and operational controls that are proposed to mitigate the risks associated with each source
Section 4.0 outlines a proposed dust monitoring programme.
Section 5.0 discusses complaints response and record keeping
Section 6.0 provides a program for training and awareness of staff.
Section 7.0 outlines the records that are required to be kept as part of compliance with this AQDWP.
Section 8.0 establishes the roles and responsibilities of staff.
Section 9.0 outlines the procedures for auditing and reviewing this AQDWP
The AQDWP has been prepared to satisfy CRL Designation condition 59 and also the requirements of the regional consents sought (as identified in the air quality assessment for the Project (Golder 2016)). For reference, the relevant sections of this AQDWP as they relate to the Designation Conditions are summarised in Table 1.
Table 1: CRL Designation Conditions for AQDWP.
Relevant CRL Designation Condition
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.
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.
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);
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;
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;
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;
e) Procedures for establishing when the covering of trucks will be required;
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;
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;
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;
Relevant section of AQDWP
Whole AQDWP
Whole AQDWP
Section 4 of the AQDWP
Section 2.3 and 4 of the AQDWP
Sections 5 and 8 of the AQDWP
Section 4 of the AQDWP
Table 3, Section 3.3 of the AQDWP
Table 3, Section 3.3 of the AQDWP
Section 5 of the AQDWP
Section 5 of the AQDWP
Relevant CRL Designation Condition
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:
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
1.3 Environmental Objective
Relevant section of AQDWP
Section 3 and 4 of the AQDWP
Section 6 of the AQDWP
The primary environmental objective is to carry out the construction activity in a manner which ensures there are no significant adverse air quality impacts on the environment at or in the vicinity of the sites associated with the diversion of the Nikau Street Stormwater Main. This objective will be achieved by ensuring that all site activities are contained within appropriate areas and site activities will not result in any discharges to air resulting in unacceptable levels of contaminants within the surrounding environment.
2.0 PROJECT DESCRIPTION
2.1 The Nikau Street Stormwater Main Realignment Project
The purpose of the Project is to enable the construction of the future CRL tunnels by realigning the Nikau Street Stormwater Main, which currently represents a critical CRL project constraint. The Project works involve the construction of a replacement stormwater main from the eastern end of Water Street, where it then passes beneath the CRL east of Mount Eden Road, it then continues west to connect into the existing main at the corner of Nikau Street and Ruru Street. The Project includes the construction of a central shaft at Mt Eden Road and retrieval shafts at Water Street and Nikau Street. The location and extent of works are shown in Appendix A
The realigned pipeline will be 1,950 mm (internal diameter) and is proposed to be constructed along a horizontally curved (R450 m) alignment which is required to reach the proposed shaft locations. The realigned pipeline and shaft locations have been positioned so they avoid the proposed rail tunnel alignment, basalt extents and existing properties (as far as is possible).
Two tunnel drives are proposed from the Mount Eden Road shaft Due to the depth of the upstream and downstream connection points and the requirement to pass beneath the proposed CRL alignment (approximately 15-20 m) pipe jacking is the proposed construction methodology. Pipe-jacking is a trenchless construction technique where a tunnel boring machine (TBM) with a pressurised slurry system excavates material/spoil. Pipes are then horizontally driven using a hydraulic ram from a series of vertical shafts. It is proposed to install shafts, along with associated construction support areas (CSAs), at the following locations:
A launch shaft adjacent to Mount Eden Road (approximately 12.5 m long, 9.5 m wide and 14.6 m deep), known as the “Mount Eden Road Shaft” is located between Mount Eden Road and the North Auckland Line (NAL). By constructing the launch shaft in this location, near the middle of the alignment, it allows the construction work to take place in two stages (Mount Eden Road to Nikau Street and Mount Eden Road to Water Street). The construction activities are to be supported by a construction support area of approximately 1,200 m² (plus an additional 350 m² for a temporary vehicle access ramp) surrounding the shaft.
A reception shaft at Water Street (approximately 8.5 m diameter and 16.7 m deep), known as the “Water Street Shaft” is located within an AT owned vacant site which is currently used as a carpark. The shaft is to be positioned between the end of Water Street and the existing NAL lines. It is proposed to be supported by a construction support area of approximately 1,500 m² surrounding the shaft.
A reception shaft at Nikau Street (varies from approximately 6.1 m to 10.9 m in diameter and 15.4 m deep) known as the “Nikau Street Shaft” is located within the footpath at the corner of Nikau Street and Ruru Street. It is proposed to be serviced by a construction support area of approximately 900 m² at 16-18 Ruru Street.
An additional CSA of 2,728 m2 will be located at 28 Mt Eden Road.
The shaft locations have been strategically selected to avoid clusters of utilities. However, it is expected that some utilities will not be able to be avoided and therefore will need to be protected or relocated before piling and shaft excavation. AT is currently engaging with relevant utility stakeholders as part of this work and it is anticipated that existing services will either be relocated or protected as part of the access shaft formation.
Table 2: Project earthworks and cut quantities.
Other ancillary works are required to enable the construction of the Project and include:
Relocation and protection of various minor utilities which clash with, or are in close proximity to, the shafts.
Temporary protection of the Huia No. 2 watermain adjacent to the Nikau Street shaft.
A section of mined tunnel of approximately 7 m will extend under Nikau Street to connect the realigned section of pipe from the Nikau Street shaft into the existing stormwater main at Ruru Street.
A mined connection to the existing pipe at Water Street.
The demolition of 26 Mount Eden Road to enable the construction of the Mount Eden shaft.
The demolition of 16-18 Ruru Street to enable the property to be used as a worksite and reduce disruption to the adjacent roads and properties. The Nikau Street shaft cannot be fully located within this property as a permanent manhole and riser is required by AC for maintenance access at this location.
The demolition of 28 Mount Eden Road to enable the use of the site as a construction support area. The floor slab and external impervious surfaces will remain in place. No excavation is proposed on this site.
Three new connections are required to connect the realigned Nikau Street Stormwater Main to the existing stormwater mains within Ruru Street at the corner of Nikau Street and Ruru Street.
In addition, three permanent access shafts are proposed within the reception and launch shafts during reinstatement at Water Street, Mount Eden Road and Nikau Street to accommodate access associated with the ongoing operation and maintenance of the realigned Nikau Street Stormwater Main.
Three new Gross Pollutant Traps (GPTs) on Boston Road (two) and Normanby Road (one). These works will require excavating pits of approximately 6 m wide, 6 m long and 7.9 m deep to install new 2.5 m wide GPTs and manholes (Figure 1)
The Project requires the earthworks cut and fill volumes as listed in Table 2. These are estimated in-situ earthworks volumes and do not take into account any bulking or wastage. Volumes are based on the current preliminary temporary works design and will be confirmed during detailed design.
Three new connections are required to connect the realigned Nikau Street Stormwater Main to the existing stormwater main within Ruru Street at the corner of Nikau Street and Ruru Street.
Three permanent access shafts are proposed within the reception and launch shafts during reinstatement at Water Street, Mount Eden Road and Nikau Street to accommodate access associated with the ongoing operation and maintenance of the realigned Nikau Street Stormwater Main.
The Nikau Street Stormwater Main diversion works are anticipated to take up to 13 months depending on the methodology chosen by the contractor. Works are expected to commence in April 2017.
2.2 Key Construction Phases and Considerations
A detailed construction methodology is outlined in the detailed design drawings and the CEMP (Appendix B and D of the Assessment of Environmental Effects) Key construction stages are summarised below:
1) Demolition of buildings at 26 Mt Eden Road and 16-18 Ruru Street.
2) Locate/Protect/Relocate minor conflicting services at Mt Eden Road.
3) Excavate and construct new Mount Eden Road launch shaft.
4) Locate and protect existing Water Street shaft (which serves the existing stormwater pipe – this shaft will not be used during construction).
5) Locate/Protect/Relocate other minor conflicting services at Water Street.
6) Excavate and construct new Water Street reception shaft.
7) Launch TBM from Mt Eden Road driving towards Water Street Shaft.
8) Put in place temporary traffic control measures at Nikau Street/Ruru Street.
9) Locate/Protect/Relocate other minor conflicting services at Nikau Street.
10) Excavate and construct new Nikau Street reception shaft.
11) Retrieve the TBM at Water Street reception shaft.
12) Launch TMB from Mount Eden Road driving towards Nikau Street Shaft.
13) Retrieve the pipe jacking machine at Nikau Street reception shaft.
14) Complete mined connection works to existing 1,950 mm dia. stormwater main at Water Street shaft and Nikau Street shaft.
15) Install GPTs.
16) Divert flow to new stormwater main.
17) Seal connections to existing stormwater main.
Figure 1: Gross pollutant trap locations.
2.3 Sensitive Locations
Off-site locations within approximately 100 m from the CSAs are considered sensitive to potential dust and odour impacts given the nature of the receiving environment. Examples of activities surrounding each of the three CSAs are as follows:
Water Street (overall assessment is moderate to high sensitivity):
The CSA is currently is an unpaved parking area primarily accessed at the southern end of Water Street.
It backs onto the rear of a small number of commercial and light industrial buildings along its northwestern boundary
It backs onto the railway lines to the southeast. Beyond the rail lines is a small retail complex including OfficeMax.
Mount Eden Road (overall assessment is high sensitivity):
Churches across the other side of Mt Eden Road (Promise Keepers – Life Church) to the northwest
Souvenir shop
Petrol Station
Firestone tyre centre
Bars and restaurants
Retail shops (e.g , kitchen supplies)
Residential apartments
Commercial offices
Press Print facility and rooftop apartment
Nikau Street (overall assessment is high sensitivity):
Residential apartment complex immediately across Ruru Street
Retail and motor repair workshop
South Pacific Timber off Shaddock Street
Dwelling at 31A Shaddock Street
3.0 DUST EMISSIONS SOURCES AND MITIGATION
3.1 Introduction
This section provides a description of the dust emission sources and mitigation measures for the proposed construction activities within the CSAs This is followed by a qualitative risk assessment for each key activity to identify the priority activities on the site that represent the highest risks in terms of creating an adverse dust effect beyond the boundary of the site. Finally, the emissions controls and procedures for each activity are described, as well as the person responsible for their implementation and management of dust control
Each of the potential risks is assessed in terms of the probability that they might occur (low, medium or high) and of the level of the consequence in case they do occur (low, medium or high). For instance, a potential risk with a low probability means that it is likely to occur only one to five times during the whole period of construction activities. A potential risk with a high probability means that it is likely to occur at least once per week during the period of construction activities. The consequence is independent of the probability and is related to effects on the environment (beyond the boundary of the CSA) of that risk when it does occur. A low level consequence means that any effects to the environment should be less than minor and no sensitive receptors would be affected. A high level consequence, on the other hand, means effects on the environment may be significant and that sensitive receptors are likely to be affected.
The risk level is assessed as low, medium or high based on the combination of the assessments of probability and consequence. The resulting risk level indicates the priority of that activity in terms of control measures and procedures for minimising dust emissions.
The risk assessment has been undertaken on the basis of the construction activities as described in the detailed design drawings and the Construction Environmental Management Plan (Appendices B and D of the Assessment of Environmental Effects), prepared by Aurecon New Zealand Limited.
Due to the relatively short duration of the Project, the risk assessment will need to be reviewed at critical milestones during the project, such as when there is a new or changed activity, changes to equipment or location of activities or when there is a change to legislative/consent/designation requirements. An annual review is not considered necessary in this instance
3.2 Overview of Sources
The main discharge into air arising from the proposed construction activities is particulate matter (dust). The following key activities have been identified in the Air Quality Assessment (Golder 2016a) as the potential sources of dust emissions from the proposed construction activities:
CSAs – due to unpaved surfaces, some storage of materials (up to 120 m³) and vehicles accessing and departing from the construction site.
Demolition of buildings at Nikau and Mt Eden Road
Shaft excavation and spoil removal.
Backfilling of the shafts.
Section 4 describes how the above key activities relate to the CSAs, as well as their risks in terms of the potential to result in adverse effects on sensitive activities Section 4 also details the associated mitigation measures that are to be used to control or suppress dust emissions from each activity. The operation of the TBM and the handling of the resulting spoil are not expected to be a significant source of dust.
3.3 Activities within Construction Support Areas
The risk assessment and the controls/procedures for mitigating dust emissions from the key activities within each of the CSAs are provided in Table 3 and will be generally the same for all three CSAs given the common nature of the activities
The stockpiling of spoil and other bulk materials on site can be sources of dust for most earthworks and construction activities if not carefully controlled. Where practical, materials will be excavated directly into trucks and removed offsite. No significant uncovered stockpiling of bulk materials amounts (i.e., greater than 120 m³) is proposed. Within Table 3 the probability that a risk of unmitigated dust emission occurring is denoted as ‘P’, the level of the consequence in case the risk does occur is denoted as ‘C’ and the overall risk assessment as ‘R’ . The control/procedure for each activity is intended to ensure that dust emissions are effectively controlled such that off-site effects are of an acceptable level.
In addition to the dust control/procedure noted below, consideration of dust management will form part of a daily toolbox meeting required by the overarching CEMP. The daily meeting is to include consideration of the weather forecast for that day and, where necessary, subsequent communication with immediate and potentially affected neighbours
Where it is verified that dust emissions from the Project have caused a significant impact on a neighbouring property, contingency response measures are to be determined and instigated, which may include the cleaning of air filtration intakes, or cleaning of buildings and infrastructure as necessary.
Table 3: Risk assessment and description of controls and procedures for dust sources within CSAs.
Person responsible
Building demolition at Mt Eden Road and Nikau Street sites
Storage of construction and waste materials up to 120 m³
Dust from demolition of buildings
M H
Prior to demolition (including removal of wall linings, cabling, pipework, joinery etc.), an asbestos survey is to be carried out of the two building to be demolished by an ‘appropriately experienced, qualified and certified contractor’ and if asbestos is present the demolition of the buildings shall be in accordance with recommendations from the contractor. However, it is expected that asbestos is unlikely to be present given the age of the two buildings.
Notwithstanding this, the use of water sprays shall be used to dampen the area of demolition during dry weather.
Dust from removal of plaster board is to be controlled by wetting the plaster board as it is broken up. Dust from the knocking down and breakup of blockwork and concrete and from the removal of rubble and placement of backfill will be controlled using water sprays directed onto the activity during dry weather.
Environment and Sustainability Manager (ESM) or delegated person
Dust emissions arising from the stored materials (e.g., excavated soil, engineering fill, drainage materials, and demolition debris) M M M
The proposed maximum storage volume is a relatively small amount of material and should not be an appreciable source of localised dust if simple control measures are taken. These may include spraying of water to keep the material damp or ensuring the stored material is covered, so that particles do not become suspended.
The stock piles shall also be kept to no more than 3 m above ground level to minimise wind exposure.
ESM or delegated person
ESM or delegated person
Activity/ Facility
Exit of vehicles from the site (Mount Eden Road)
Dust emissions from dried and re-suspended muddy material that is transported on the wheels of trucks and machinery exiting the CSAs and the site onto the adjoining roads.
Exit of vehicles from the site (Nikau Street and Water Street)
Dust emissions from dried and re-suspended muddy material that is transported on the wheels of trucks and machinery exiting the CSAs and the site onto the adjoining roads
Unpaved areas
Movement of vehicles
Unpaved areas may be present within the CSAs, especially following the demolition of existing buildings in those areas.
Dust emissions from the action of wheels and tracks associated with the movement of vehicles (trucks, loaders and excavators) during dry weather.
M M-H
Control/Procedure
All vehicles leaving the Mount Eden CSA will travel over a paved internal truck access route prior to accessing Mount Eden Road. When a build-up of muddy material is observed on wheels, these will be washed prior to the vehicle driving onto the paved truck access
A wet-vacuum sweeper truck will be used weekly to sweep the public road and site access way
Due to the small area of the CSAs for Nikau Street and Water Street and the small number of vehicle movements from those sites, a wheel wash is not considered necessary. However, a wet-vacuum sweeper truck will be used weekly to sweep the public roads around any exits from the site.
Potential dust from unpaved areas will be suppressed by routinely applying water or other dust suppression agent across areas that are frequently trafficked on dry days. During particularly dry conditions this may require reapplication of water over unpaved surfaces at a frequency of 30-minutes or less. In addition, windbreaks or hoarding fences will be installed the perimeter of the CSA to minimise wind speeds. Unconsolidated areas are to be compacted.
In addition to the watering measure described above, vehicle/machinery speeds will be limited to 15 km/hr. As the CSA are very confined areas, machinery is expected to be already travelling at very slowly and well within this speed limit.
Person responsible
ESM or delegated person
ESM or delegated person
ESM or delegated person
ESM or delegated person
Activity/ Facility
Paved areas
Excavation and spoil removal
Paved areas can result in dust emissions where a buildup of dusty material occurs over a period of time, allowing that material to be entrained by vehicles or by the wind.
Dust emissions due to wind erosion of the exposed surfaces within the shafts during dry weather and period of strong winds.
Removal of spoil and delivery of fill material
Dust emissions from uncovered loads on trucks.
Control/Procedure
Paved areas, particularly frequently trafficked areas, are to be cleaned on a weekly basis using a vacuum sweeper truck to remove the build-up on any dusty material.
Person responsible
The exposed surfaces of the shaft will be kept damp if necessary by spraying with water until such time that the shaft is sufficiently deep to be protected from the wind.
ESM or delegated person
Backfilling of the shafts
Contaminated soils
Dust emissions from the material being backfilled into the shaft
Contaminated dust and/or odour associated with planned or unexpected discovery of contaminated soils.
All trucks removing spoil and delivering fill to have loads covered.
If needed, water will be used for dampening exposed surfaces and/or the filling material during the backfilling operation. However, the surface area of each shaft and the amount of fill material is relatively small. This means there is limited potential for wind erosion of exposed surfaces
Construction may occur within reclamation fill or reworked materials, where contaminated soils may be encountered.
See the Contamination Delivery Work Plan (CDWP – Golder 2017).
ESM or delegated person
ESM or delegated person
ESM or delegated person
ESM or delegated person
Notes: P = Probability, C = Consequence, R = Risk assessment (Priority), L = Low, M = Medium, H = High ESM = Environment and Sustainability Manager
4.0
DUST MONITORING PROGRAMME
4.1 General Site Monitoring
The following general site monitoring will be undertaken:
Daily – The project Environment and Sustainability Manager (ESM) or delegated person will conduct twice daily inspections of all three CSAs (including all subcontractor activities), and any issues identified will be recorded and where necessary appropriate response measures actioned The daily monitoring will include wind conditions and visual inspections in order to check compliance with this AQDWP, and observations shall be recorded in a Daily Log (see Section 4.2 for further details).
Weekly – Formal site inspections are to be completed by the ESM CSA specific checklists will be developed to check compliance with this AQDWP.
Monthly – A representative from AT, and relevant Site Manager will undertake a monthly site visit with the project ESM, to confirm the work procedures containing environmental controls are being implemented in accordance with this AQDWP. A review of the current risk assessment table (Table 3) will be carried out by project ESM, updating it as required.
At the end of each month, the project ESM will submit a site inspection and environmental performance report to AT The report will include but not be limited to a summary of environmental issues that occurred and actions taken during the month to ensure compliance with this AQDWP. The report will include:
i) Completed CSA checklists
ii) Any details of any action item requests
iii) Complaints received
iv) Incidents that occurred
v) Investigations and corrective actions associated with complaint or incident investigations.
vi) Staff environmental inductions and awareness training.
4.2 Visual Inspections of Dust Emissions
This AQDWP outlines a number of controls and procedures that are to be carried out in order to ensure dust emissions are minimised from CSA sources. Visual inspections of the perimeter of all three CSAs will be performed on a twice daily basis during the construction activities and recorded.
The visual inspections will help to further ensure dust control measures are being effective. Records from daily visual inspections recorded in the Daily Logs can also be a useful tool for investigating and responding to complaints. The specific procedures for carrying out visual inspections are outlined below:
Visual inspections will be performed twice each day of operation by the ESM or delegated person around the whole perimeter of the three CSAs. The exits of the CSAs adjoining roads will also be inspected in order to verify that significant levels of mud and dusty material is not being carried by trucks and machinery onto public roads, and remedial action taken where necessary
If visible dust emissions are identified beyond the site boundary, the following details must be recorded in the Daily Log form:
the source of the visible dust emissions;
the level (extent) of the visible dust emissions:
1) minor visible emissions (< 5 m from source),
2) moderate visible emissions (5 to < 30 m from source),
3) major visible emissions (> 30 m from source),
a brief description of the colour and opacity of the visible dust emissions (e.g., dim brown, hazy grey, dense black, etc.); and
the time and general weather conditions (i.e., windy, calm, warm, etc.) at the moment the visible dust emissions were identified
If the assessed level of visible dust emissions is moderate or major, the duty or site manager for that CSA must be notified for further action, including ceasing on-site dust generating activities
When notified for further action, the duty or site manager will investigate the situation and take necessary measures to ensure dust levels do not give rise to offensive or objectionable dust impacts. Such actions will also be recorded in the Daily Log
4.3 Continuous Monitoring of Total Suspended Particulate
The small extent of the earthworks areas and low potential for dust emissions means that continuous monitoring of total suspended particulate is not considered to be necessary for manging dust effects associated with these works. Instead, monitoring of dust emissions from activities via regular visual inspections (as outlined in Section 4.2) will be carried out to ensure the emissions of dust are minimised from the Project.
It is considered that Condition 59.3 of the designation, which requires continuous monitoring of total suspended particulate, only applies to large scale earthworks associated with the construction of CRL (which has far greater potential dust effects), not small scale enabling works such as those proposed for the Project. Accordingly, the monitoring proposed in the AQDWP is considered to be commensurate with the scale of the works and fulfils the intent of Condition 59.3.
5.0 OTHER MINOR DISCHARGES TO AIR
Combustion emissions from the operation of vehicles, and any residual emissions from emission control equipment associated with the Project are expected to give rise to air quality effects that are negligible. However, all machinery and control equipment will be subjected to weekly checks for excessive and prolonged visible emissions and will be serviced in accordance with the supplier’s recommendations. Any malfunctioning machinery is to be repaired or removed from site within 24 hours
The Project is not expected to give rise to any offensive or objectionable odour effects as there are no known sources of odour associated with the three CSAs. Accordingly, odours effects are expected to be less than minor. If the Project results in unforeseen odour emissions or it becomes apparent that odour emissions may occur from an activity, then operations associated with that activity will cease and measures to address the discharge promptly investigated and implemented (including procedures for responding to discharges of odour and equipment inspection)
6.0 COMPLAINTS RESPONSE AND RECORDING
Although measures of this AQDWP are aimed at avoiding complaints regarding dust occurring (complaints regarding odour are not anticipated), in practice complaints may be made on occasions by members of the public.
It is important to ensure that any complaints that are received are recorded, promptly investigated to identify and resolve the cause of the complaint and appropriately responded to The requirements and procedures on how to accomplish this are detailed in the CEMP and the Project Communication and Consultation Plan (CCP)
7.0 ENVIRONMENTAL TRAINING
7.1 Project Staff
To achieve an effective AQDWP and to ensure off site air quality impacts comply with resource consent and the CRL designation condition requirements, all Project staff (contractors and subcontractors) will undergo general air quality awareness training and training about their responsibilities under the ADWP
As part of the site staff induction, matters relating to dust management will be provided to all staff and subcontractors prior to starting work on site Information will be provided on any procedural and/or structural controls employed on the CSAs to mitigate risk to air quality. Site engineers responsible for writing work plans and undertaking site specific safety and environmental risk assessments will also be given guidance on how to assess and plan for the environmental issues considered within the AQDWP
Air quality and other environmental issues will form a regular part of toolbox meetings (to be attended by contractor staff and subcontractors) to ensure all workers are aware of the key issues.
The training requirements outlined in Table 4 are aimed to ensure all staff will receive appropriate training to fully understand the risks of activities on the sites to the environment, particularly with regard to off-site dust impacts, and the requirements of this AQDWP. Regular review of training requirements will be undertaken to ensure all staff are appropriately trained.
Table 4: Training requirements
Training requirements Frequency Attendance
General site environmental management training and familiarly with the AQDWP
Responding to complaints regarding dust and air quality concerns
8.0 RECORD KEEPING
8.1
Overview
As required during new staff induction
As required during new staff induction
All new staff members
Site manager, delegated staff member and duty managers
The record keeping requirements of the AQDWP are outlined in Table 5 Details on the Daily Log are provided below
Table 5: Record keeping requirements
Records Responsibility Location
Daily Log and weekly/monthly environmental site inspections
Complaint records
Environmental incident reports
Environmental emergency reports
Annual environmental audit
Training records
Revisions to the AQDWP and relevant sub-plans
ESM CSA office
ESM and onsite personnel involved in the complaint response CSA office
ESM and onsite personnel involved in the environmental incident CSA office
ESM and onsite personnel involved in the environmental emergency ESM office
ESM
ESM
ESM
ESM office
ESM office
ESM office
8.2 Daily 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 are to be carried out on the site in order to prevent such effects Monitoring and inspection procedures will be used to assess the level of dust emissions both on the 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 Daily Log will provide a record of the relevant monitoring and inspection results
The site or duty manager for each CSA will fill out the Daily Log form twice each day and file it in a designated file in the CSA site office. A Daily Log form for each CSA is located in Appendix B of this AQDWP
The following information will be recorded in the Daily Log form:
i) Any dust control equipment malfunctions and any remedial action(s) taken
ii) Results of the visual inspections of dust emissions and wind conditions (see Section 4.2 for Visual Inspections procedures)
iii) General weather conditions during the day (i.e., windy, calm, warm, rain, etc.).
iv) The frequency of watercart and/or water sprinkling system use.
v) Complaints received and responses to complaints.
vi) The date, time and signature of the person entering the information
vii) The use of other mitigation measures, such as the use of chemical dust suppressants or covering of storage piles, and the reasons leading to their use.
9.0 ROLES AND RESPONSIBILITIES
9.1 Overview
Each person involved in the Project has equal responsibility to strive to avoid, remedy or mitigate adverse dust effects.
There are three key groups with responsibility for environmental management of the Project:
AT as the Project owner, holder of the resource consents and Requiring Authority responsible for the designation.
The Construction Contractor as the construction contractor undertaking the works.
AC as the consent authority who audits the works and monitors compliance with the designation conditions, the Construction Environmental Management Plan (CEMP) and Sub-Plans.
During the Project, an ESM will be appointed by the contractor as part of the Construction Team who will be involved throughout the contract period to give advice and to ensure that the AQDWP and other environmental sub-plans are implemented and maintained.
9.2 Specific Roles and Responsibilities
The key organisations, management roles and responsibilities in relation to air quality management during the construction associated with the Project are outlined in the CEMP. Those particularly relevant to air quality matters are outlined in Table 6
Compliance with the RMA and consent requirements.
Applications for new resource consents associated with changes to the activities proposed within the CSAs.
Review of contractor’s site specific environmental management plans and relevant sub-plans.
Overall responsibility for site environmental management.
Reviewing and reporting on environmental performance.
Inspection of works to assess compliance with the AQDWP, Sub-Plans and resource consent requirements.
Inspections, auditing and checking of environmental management practices and procedures
Report to AT any changes to construction techniques which require designation alterations and/or new resource consents.
Review and update of specific management plans and relevant sub-plans.
Maintain Daily Logs and Complaint Records.
Training of all staff including subcontractors.
Communicate with adjoining and potentially affected neighbours about significant events that could give rise to dust, and where relevant odour
Adherence to the AQDWP and Sub-Plans.
Adherence to resource consent requirements
Sub-contractors Construction Manager
Auckland Council Air Quality Consents Team
N/A
All Construction Team staff
Variation of specific management plans, and relevant sub-plans as required.
Reviewing and certifying the management plans
Auditing to assess compliance with the AQDWP
Auditing to assess compliance with resource consent requirements
Attend daily toolbox meetings as required
Be trained in dust and odour management
Responsible for reporting dust and odour incidents
Ensure dust and odour management procedures adhered to.
9.3 Contact Details
Contact details for those with key responsibilities in the implementation of this AQDWP are provided in the CEMP and CCP
10.0 ADWP AUDITING AND REVIEW
10.1
Introduction
This AQDWP may require review and amendment during the life of the Project to reflect changes to activities, risks, mitigation measures, responsibilities and management processes.
The ability to make changes to the AQDWP is an important aspect of continually improving the effectiveness of the AQDWP . A review process should also be undertaken once the detailed design and construction methods are finalised.
Auditing and review will be undertaken by the ESM Auditing and review will be used to provide an independent appraisal of the site’s performance in relation to the objectives of the AQDWP
The results of this review process will enable project staff, AT and AC to assess suitability, adequateness and effectiveness of site operations from an environmental perspective.
10.2
Auditing
AC may visit the site to undertake site inspections and assess compliance with the designation conditions. Site staff will be available to assist AC staff during these inspections and provide any information required. In particular, any information or records required to be available by any designation condition or resource consents held by AT will be kept on site and will be readily available upon request.
All documentation relating to this AQDWP shall be appropriately filed for auditing and review purposes.
10.3 Review
This AQDWP will be reviewed and updated when necessary to reflect changes in the construction methodologies, and throughout the course of the Project as required to reflect material changes associated with a new or changed activity, equipment or location of activities. The procedure for making changes to this AQDWP are given in the CEMP.
The AQDWP is subject to a review process with the Community Liaison Group (CLG) established for the Project and a suitably qualified independent peer reviewer. A summary of the outcomes of this review process is attached in Appendix C
11.0 LIMITATIONS
Your attention is drawn to the document, “Report Limitations”, Appendix D The statements presented in that document are intended to advise you of what your realistic expectations of this report should be, and to present you with recommendations on how to minimise the risks to which this report relates which are associated with this project. The document is not intended to exclude or otherwise limit the obligations necessarily imposed by law on Golder Associates (NZ) Limited, but rather to ensure that all parties who may rely on this report are aware of the responsibilities each assumes in so doing.
12.0 REFERENCES
Golder 2016a. Auckland City Rail Link – Nikau Street Stormwater Realignment Project: Air Quality Assessment. Report prepared by Golder Associates (NZ) Limited for Auckland Transport, October 2016
Golder 2017. Nikau Street Stormwater Realignment Project: Contamination Delivery Work Plan (CDWP). Report prepared by Golder Associates (NZ) Limited for Aurecon New Zealand Limited, August 2017
(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):
Dust from wind erosion of exposed ground
Watercart not used properly
Exceedance of speed limit in unpaved surface
Wheel wash not used correctly before exiting site
Materials not handled or stored properly
Loading/Unloading not carried out properly
Other_________________________________________
Corrective actions:
Date:
Description:
Preventive actions: Date:
Description:
Person responsible for the above information:
Source
DAILY LOG FORM – WATER STREET
VISIBLE DUST EMISSIONS
*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):
Dust from wind erosion of exposed ground
Watercart not used properly
Exceedance of speed limit in unpaved surface
Wheel wash not used correctly before exiting site
Materials not handled or stored properly
Loading/Unloading not carried out properly
Other_________________________________________
Corrective actions:
Date:
Description:
Preventive actions: Date:
Description:
Person responsible for the above information:
Source
DAILY LOG FORM – NIKAU STREET
VISIBLE DUST EMISSIONS
*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):
Dust from wind erosion of exposed ground
Watercart not used properly
Exceedance of speed limit in unpaved surface
Wheel wash not used correctly before exiting site
Materials not handled or stored properly
Loading/Unloading not carried out properly
Other_________________________________________
Corrective actions:
Date:
Description:
Preventive actions: Date:
Description:
Person responsible for the above information:
APPENDIX C
Community Liaison Group (CLG) Review Outcomes
COMMUNITY LIAISON GROUP (CLG) REVIEW OUTCOMES
Comments from the Community Liaison Group (CLG) regarding the Air Quality Delivery Work Plan are summarised below. Comment
1 14/11/16 9:10 pm Email M Main
Dealing with cleanliness of outside walls of building and cleaning, if necessary
Complaints regarding building cleaning are best dealt with as they arise Complaints will be dealt with as outlined in the CCP, attached as Appendix J of the CEMP. The mitigation measures and monitoring proposed in Sections 3 and 4 of the Air Quality Delivery Work Plan (AQDWP) will minimise any dust effects on buildings and detail contingency responses
INDEPENDENT PEER REVIEW (IPR) OUTCOMES
The following comments were received from Independent Peer Reviewer on the Air Quality Delivery Work Plan.
Peer Reviewer: Air Matters Limited – Carol McSweeney
Date: 12 December 2016
AQDWP Section
Section 4.3 and Appendix A
Section 2.2 and 4.2
Section 5.0 and Appendix A
Sections 4.1 and 4.2, Table 3
Comment
The document concludes that no continuous monitoring is required. The condition states that this is required. Some clarification needed as to the relevance of this condition to this site. Is there any statutory requirement for the conditions at this site?
Meteorology. Basic meteorology is suggested in the daily checks in Appendix A, however, there is no record of wind direction. This is required for any assessment of exceedances of dust trigger levels and of any complaints. Wind direction should be recorded in the daily log.
Section 4.2 suggests a trigger limit of moderate to major visible emissions. However, there is an error in this classification where moderate visible emissions should be 5 to <30 m from the source if the trigger level is to work.
Section 5 discusses minor discharges including emissions from the operation of vehicles and states there will be weekly checks of all machinery and control equipment. No detail of what will be checked for. Requires some parameters here.
As above, there is no assessment of wind direction which is required.
Section 4.2 indicates that there will be moderate or major dust before action is taken. In order to satisfy the intent of Condition 59.1(b) a trigger level should be established to implement the use of controls before moderate emissions occur.
Controls are well documented in Table 3 but the need to identify the requirement to increase controls (e.g. identification of a trigger value) needs to be quantified.
Table 3 The procedure in Table 3 requires covering of all loads of fine materials.
Table 3 What are the criteria for deciding that the wheel wash will be used? Table 3 states that “where necessary vehicles wheels will also be manually washed”. There should be some quantification here so that operators know the acceptable standard.
Table 3 Contaminated site response, document refers to the Contamination Delivery Work Plan. (This has not been seen by myself)
Resolution
Section 4.3 amended to explain why continuous dust monitoring not required for this particular project.
Appendix A amended to require the recording of wind direction.
Text amended in Section 4.2 to address comment.
Section 5.0 updated to add the parameter of weekly checks on excessive and prolonged visible emissions
This has been addressed in Section 4.3 and Appendix A.
The controls detailed in Table 3, where relevant, apply at all times and do not rely on a trigger level being exceeded.
Additional controls, including ceasing on-site dust generating activities are described in Section 4.2 as being required when a moderate trigger level is reached. Therefore, no changes are required to the report to address this comment
No action required – comment is simply stating that this measure is already included in the table.
Table 3 updated to make it clear that this relates to an observed build-up of muddy material on vehicle wheels.
No further action required.
AQDWP
Section
Sections 3.0 and 4.0
APPENDIX C
Peer Review Outcomes
Comment
This is well outlined in Table 3. However, there is no discussion of the procedure to address identified adverse effects of sensitive receptors.
The community liaison Group had a response from L Main (Appendix B) asking how issues of dust of buildings will be dealt with. This condition talks about contingency IF adverse effects are verified. This should be provided and cleaning of buildings may well be an appropriate response.
Section 6.0 Reference to Communication and Consultation Plan (CCP) that has not been seen by myself.
Section 3.1 Last paragraph, “risk assessment needs to be reviewed on an annual basis”. This seems inappropriate for a project that is planned to be 13 months long. It would be appropriate to identify when reviews should happen. Also quantify the regular intervals.
Section 3.2 Overview of Sources. This list should include the demolition of buildings at Nikau and Mt Eden Road (Covered in Table 3 but is important as a source so should be in 3.2 as well).
Table 3 Table 3 - potential unmitigated risk for asbestos. There is also a risk of discovery of asbestos in soil particularly in the areas of demolition. Historic asbestos is also a risk in soil in old parts of Auckland and should be added into Table 3.
Resolution
Additional text has been added prior to Table 3 to note the requirement of providing a contingency response (which may include cleaning of buildings) where dust from the CSA is verified as causing a significant effect on neighbours.
No further action required.
The short duration of the Project has been acknowledged and the text of the paragraph amended to address this comment and the requirement of an annual review removed.
Text added to Section 3.2 to address this.
This risk is addressed through the CSDWP.
APPENDIX D
Report Limitations
Report Limitations
This Report/Document has been provided by Golder Associates (NZ) Limited (“Golder”) subject to the following limitations:
i) This Report/Document has been prepared for the particular purpose outlined in Golder’s proposal and no responsibility is accepted for the use of this Report/Document, in whole or in part, in other contexts or for any other purpose.
ii) The scope and the period of Golder’s Services are as described in Golder’s proposal, and are subject to restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or circumstances that may exist at the site referenced in the Report/Document. If a service is not expressly indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any determination has been made by Golder in regards to it.
iii) Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Report/Document. Accordingly, if information in addition to that contained in this report is sought, additional studies and actions may be required.
iv) The passage of time affects the information and assessment provided in this Report/Document. Golder’s opinions are based upon information that existed at the time of the production of the Report/Document. The Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations.
v) Any assessments, designs and advice made in this Report/Document are based on the conditions indicated from published sources and the investigation described. No warranty is included, either express or implied, that the actual conditions will conform exactly to the assessments contained in this Report/Document.
vi) Where data supplied by the client or other external sources, including previous site investigation data, have been used, it has been assumed that the information is correct unless otherwise stated. No responsibility is accepted by Golder for incomplete or inaccurate data supplied by others.
vii) The Client acknowledges that Golder may have retained subconsultants affiliated with Golder to provide Services for the benefit of Golder. Golder will be fully responsible to the Client for the Services and work done by all of its subconsultants and subcontractors. The Client agrees that it will only assert claims against and seek to recover losses, damages or other liabilities from Golder and not Golder’s affiliated companies. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have any legal recourse, and waives any expense, loss, claim, demand, or cause of action, against Golder’s affiliated companies, and their employees, officers and directors.
viii) This Report/Document is provided for sole use by the Client and is confidential to it. No responsibility whatsoever for the contents of this Report/Document will be accepted to any person other than the Client. Any use which a third party makes of this Report/Document, or any reliance on or decisions to be made based on it, is the responsibility of such third parties. Golder accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this Report/Document.
