Case Study – EPA Site Improvement Notice on Dangerous Chemical Storage
How to assess and maintain controls to reduce environmental pollution risks at your commercial premises
Site Improvement Notice given by Environmental Protection Authority Victoria
How do you safely store over 5 million litres of expired hand sanitiser, one of the waste products of the Covid Pandemic? That’s the question one of our industrial clients in Melbourne had when they came to us for a plumbing consultation and rectifications after receiving an EPA (Environmental Protection Authority Victoria) Site Improvement Notice on their facility.
Our client had received a contract to store a gargantuan amount of expired hand sanitiser in large containers. The sanitiser, classed as dangerous goods, is comprised of 60% alcohol, meaning it is out of date 3 years from manufacturing date. The chemical is highly flammable and must therefore be stored appropriately.
Storing Expired Hand Sanitiser is a Nationwide, and Worldwide, Problem
In June 2023, Cleanaway received a fine for $18,492 by the EPA for accepting hand sanitiser without recording and reporting the waste. In this example, the EPA stated that ‘we have fined the company $18,492 for its records management failure. It’s a reminder to all businesses to track and record wastes in line with EPA publication 1827.2 Waste classification assessment protocol.”
Again in September 2023, Cleanaway received an EPA fine for transporting hand sanitiser without properly logging the movement of the chemicals. The $30,000 fine was due to the company again not recording the sanitiser as a reportable priority waste (RPW) on the EPA’s Waste Tracker System.
WA Today recently reported that the WA Health Department recently contracted Cleanaway to collect, transport and dispose of 130,000 bottles of expired sanitiser at a cost of $187,000. The NSW education department contracted Cleanaway to do the same a few months back at a cost of $536,000.
Achieving EPA Site Compliance for our Client
Our client was contracted to store 5 million litres of expired hand sanitiser. The sanitiser is currently housed in a 25,000m² newly built storage facility. The client received an EPA Site Improvement Notice requiring immediate rectification. They contacted McCarthy Plumbing Group for guidance as they were unsure of the process on how to achieve compliance.
In the initial stage of discussions on gaining EPA compliancy, we walk our clients through the process, variations and give examples of our history of EPA compliance rectification works. In this instance, the storage facility was being changed from a standard storage facility to a dangerous goods facility, given the contents of the containers (expired hand sanitiser including highly flammable ingredients such as ethanol).
As a part of the required facility upgrades in order for our client to accept 5 million litres of highly flammable chemicals, we needed to complete a site assessment to confirm the facility had been installed as per the builder drawings and was compliant. We needed to ensure there were no restrictions in access, depth and size of the existing pipes as this would pose risks and require additional safety processes and hazard prevention controls.
We obtained copies of the current ‘as built’ civil/stormwater drawings from the builder and thoroughly reviewed them. We also visually audited the site to confirm everything correlated as per the drawings.
Our main role in the rectification of changing the site from standard facility to dangerous goods facility was to ensure all stormwater points had isolation valves installed in the event of a spill, fire or other emergency. An isolation valve is a critical component in stormwater management. It allows for the rapid shutdown of the stormwater system in emergency situations, preventing potential environmental hazards and ensuring the safety of personnel and the facility. Stormwater isolation is crucial to prevent dangerous goods and contaminants from entering the stormwater drainage system during emergencies such as spills or leaks.
The two isolation valves used were selected based on our site audit and conditions. We conducted a Dial Before you Dig to get a site map of existing legal points of discharge (LPoD) from the site to cross reference with the civil/stormwater drawings. The emergency stormwater isolation valves were then installed using the following process:
- Prepare the base of the pit and apply concrete filler to create a smooth surface for valve to bond to.
- Install fasteners to the face of the pits in preparation for the valve installation.
- Organise franna crane to lower valves down into position.
- Secure valve to face of pit.
- Extend isolator shaft to ground.
- Provide signage and valve key to isolate in the event of emergency.
After installation, a custom 15 page standard operating procedure manual was created and site training occurred for select team members. The training ensured team members could isolate the stormwater drains using the valve in the case of an emergency.
The EPA carried out a site inspection, in which our installation was compliant, and our client achieved the required rectification for the Environmental Protection Authority (EPA) within three weeks of receiving a site improvement notice, ensuring no further breaches or fines.
I’ve been issued with an EPA Improvement notice, what do I do now?
McCarthy Plumbing Group will act as ‘first responders’ in assisting you with assessing and maintaining interim controls given to you by the EPA Authorised Officer. These controls may include capping of legal points of discharge to the stormwater outside of your boundary, installing isolation valves, educt and clean contaminated stormwater pits, assist in nominating an Environmental Consultant, installing bunding, clear stormwater pipes for assessment with a hydro-jet, assess stormwater collection using CCTV drain cameras, and give general plumbing and stormwater advice.
We can then assist your chosen Environmental Consultant to action the tasks in your site improvement notice and/or stormwater management plan including engineer control to stop trade wastewater/chemicals discharging beyond the boundary of the premises, design a stormwater management system (this can include preparation of groundworks/sealing, surface water controls, flow directions, drainage, sumps, pumps, valves, retention volumes, pipelines, legal point of discharge and attenuation systems).
If you have received an EPA site improvement notice, compliance notice or any other remedial notice and require assistance in navigating the requirements to achieve compliance, McCarthy Plumbing Group can assist in preventing further or potential water pollution occurring from your site by assessing and controlling risks to stormwater drains past your legal point of discharge.
We are situated in the Laverton North industrial area in close proximity to Kororoit Creek, Ryans Creek and Cherry Lake and are geographically central in location to assist businesses across Melbourne’s west and inner suburbs in ensuring stormwater management system compliancy. We are expert environmental protection plumbers working collaboratively with environmental consultant plumbing experts. To discuss your site improvement plan and stormwater management plan queries on 03 9931 0905.