lismore base hospital redevelopment stage 3c compliance audit · aq1238.01a compliance audit report...

Lismore Base Hospital Redevelopment Stage 3C Compliance Audit

Assessment of John Holland’s Environmental Management System Compliance Against the SSD 8963 Conditions of Consent

Audit Reference: AQ1238.01a

Audit Organisation: John Holland Pty Ltd

Auditors: Nilda Soto, Lead Auditor, AQUAS

Ana Maria Munoz, Auditor, AQUAS

Date of Audit: 27 November 2018

Draft Report Submitted: 20 December 2018

Final Report Submitted: 21 December 2018

Amendment, Distribution & Authorisation Record

AQ1238.01A COMPLIANCE AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 2 OF 30

Distribution list of electronic copies

Copy No. Revision No. Issued to

1.0 Final CBRE ‐ Mohaned El Gubbi

No reproduction of this document or any part thereof is permitted without prior written permission of AQUAS Pty Limited. This report has been prepared and reviewed in accordance with our Quality control system. This report has been prepared by: ANA MARIA MUNOZ Date: 21/12/2018 Management Systems Consultant This report was reviewed by: NILDA SOTO Date: 21/12/2018 Lead Environmental Auditor

© Copyright AQUAS Pty Ltd ABN: 40 050 539 010 All rights reserved. No material may be reproduced without prior permission. While we have tried to ensure the accuracy of the information in this publication, the Publisher accepts no responsibility or liability for any errors, omissions or resultant consequences including any loss or damage arising from reliance in information

in this publication. AQUAS Pty Ltd www.aquas.com.au


1. Executive Summary 4

2. Introduction 5

2.1 Background 5

2.2 Project Details 5

2.3 Audit Scope and Objective 5

2.4 Audit Date 5

2.5 Key Project Personnel 5

3. Audit Methodology 6

3.1 Opening Meeting 6

3.2 Audit Process 6

3.3 Audit Criteria 6

3.4 Closing Meeting 6

4. Compliance Status Summary 7

4.1 Overview 7

4.2 Non‐compliances 7

4.3 Not‐triggered 7

4.4 Opportunities for Improvement 9

4.5 Incidents 9

4.6 Complaints 10

Appendices

Appendix A. Audit Attendance Sheet 11

Appendix B. Independent Audit Declaration Form 12

Appendix C. Audit Checklist 13


1. Executive Summary

This report details the findings of the Ministers Conditions of Consent Compliance Audit for the construction works undertaken by John Holland at the Lismore Base Hospital Redevelopment Stage 3C.

Consent for Stage 3C construction and operation activities of four storey addition levels (7 to 10) was received on the 20th of September 2018 under the State Significant Infrastructure Approval (SSI) No. 8963.

Current works for Levels 7 to 10 include crane operations surveying, scaffolding, formwork, concrete pouring, steel post‐tensioning, structural framing and stormwater pipe works. John Holland is the nominated Principal Contractor for the project and is responsible for the management of environmental aspects associated with the works.

The audit was conducted by AQUAS on 27th November 2018 at Lismore Base Hospital, 60 Uralba Street, Lismore NSW. The audit scope included a compliance review against the Project Development Consent Conditions Part A, Part B and Part C. Part D and Part E were not part of this audit and they will be audited at the end the project. This is the first Compliance Audit undertaken for this project.

The audit confirmed that John Holland has addressed most of the compliance requirements of the Conditions of Consent for the current site activities. Administrative Controls (Part A) were in place except for the environmental performance reporting, summary of monitoring results, project progress, independent environmental audit report and construction compliance report, which are yet to be prepared and published in the website and were identified as not‐triggered findings.

The audit identified five not‐triggered against Part B ‐ Prior to Commencement of Construction. These include an External Walls and Cladding Certificate, Façade Building Material Statement, Access to information and the Compliance Reporting. Refer to Section 4.3 of this report.

The Community Communication Strategy, Construction Environmental Management Plan (CEMP) Traffic and Pedestrian Management Plan (TPMP), Noise and Vibration Management Plan (NVMP) and Waste Management Plan (WMP) were in place and they had been submitted to Department of Planning and relevant project stakeholders. Some opportunities for improvement were raised on two of those Plans to include details required by the Conditions of Consent. Refer to Section 4.4 of this report.

All the requirements from Part C ‐ of the Conditions of Consent ‘During Construction phase have been addressed by John Holland. Details of the audit compliance findings are described in the Section 4 of this report.

No environmental incidents have occurred so far and no complaints have been raised on the Stage 3C of the project.

This audit was undertaken in accordance with the Department of Planning and Environment’s Compliance Reporting Guidelines, June 2018.


2. Introduction

2.1 Background

CBRE has engaged AQUAS to undertake a compliance reporting audit during the delivery of Lismore Base Hospital (LBH) Stage 3C Redevelopment North Tower Extension Works project and verify compliance against the Development Consent Conditions SSD 8963. Stage 3C comprises the construction of an additional four floors to the North Tower (Levels 7 to 10), which will be fully integrated into the existing floors (Levels 3 to 6) of North Tower, constructed as part of Stage 3B of the LBH Redevelopment Project.

2.2 Project Details

Project Name Lismore Base Hospital (LBH) Stage 3C Redevelopment – North Tower Extension Works

Project Application Number SSD 8963.

Project Address 60 Uralba Street, Lismore NSW

Project Phase Construction

Project Activity Summary Current site works included crane operations surveying, scaffolding, formwork, concrete pouring, steel post‐tensioning, structural framing and stormwater pipe works.

2.3 Audit Scope and Objective

This audit was conducted to verify compliance of John Holland Environmental Management System for the construction activities against the requirements of the Development Consent Conditions SSD 8963 for the Lismore Base Hospital Stage 3C Redevelopment Project. This is the first compliance audit being undertaken by AQUAS during construction works.

2.4 Audit Date

The audit was conducted on 27th November 2018 at the Lismore Base Hospital Stage 3C site.

2.5 Key Project Personnel

Name Organisation Position

Brett Popham John Holland Project Manager

Michael Sawyer John Holland Safety Advisor / Environmental Representative

Will Roberts John Holland Senior Project Engineer

Mohaned El Gubbi CBRE Project Manager


3. Audit Methodology

3.1 Opening Meeting

An opening meeting was held with personnel from CBRE, John Holland and AQUAS as per the Audit Attendance Sheet (Refer to Appendix A) on 27th November 2018 at 8:35am.

Key items were discussed as follows:

Confirmation of the purpose and scope of the audit.

Overview of the Project and current status of the works.

Occurrence of Environmental incidents.

Overview of the audit process in accordance with the proposed Audit Program.

3.2 Audit Process

The audit commenced with a visitors’ site induction followed by a general site walk where status of construction works and relevant environmental controls in place could be observed.

The site walk was followed by review of compliance records and general discussions with John Holland staff for verification of compliance with the SSD 8963 requirements.

Name and position of persons interviewed:

Name Organisation Position

Brett Popham John Holland Project Manager

Michael Sawyer John Holland Safety Advisor / Environmental Representative

Will Roberts John Holland Senior Project Engineer

3.3 Audit Criteria

The following audit criteria/ratings were used for the rating of audit findings.

Audit Findings Rating

NC – Non‐Compliant

NT – Not triggered

OFI – Opportunity for Improvement

3.4 Closing Meeting

The closing meeting was held on 27th September 2018 at 2:45pm with representatives of CBRE, John Holland and AQUAS. General feedback and the findings of the audit were discussed during the closing meeting.

AQUAS auditors acknowledged the cooperation, openness and hospitality of John Holland staff during the conduct of this audit.


4. Compliance Status Summary

4.1 Overview

This audit assessed compliance of SSD 8963 Development Consent Conditions for the Lismore Base Hospital Redevelopment Project Stage 3C. The audit determined that John Holland has implemented measures in order to comply with these requirements.

The audit revealed the following non‐compliances, not‐triggered findings and opportunities for improvement with their rating category as follows:

Findings Rating Findings

Non‐Complaint 0

Not triggered 5

Opportunity for Improvement 3

4.2 Non‐compliances

There were zero non‐compliances raised during this audit.

4.3 Not‐triggered

The table below outlines the not‐triggered findings raised during the audit:

NT

No.

SSD 8963

Ref. No.

Description of the Requirement Details of the finding

NT‐01 A12 External Walls and Cladding – The external walls of all buildings including additions to existing buildings and structures that are part of the development must be constructed in accordance with the relevant requirement of the BCA.

The external walls of all buildings including additions to existing buildings still in design phase. Works have still not commenced.

NT‐02 A15

(iv), (v), (vi), (ix)

Access to information ‐ At least 48 hours before the commencement of construction until the completion of all works under this consent, or such other time as agreed by the Planning Secretary, the Applicant must:

a. Make the following information and documents (as they are obtained or approved) publicly available on its website:

iv. Regular reporting on the environmental performance of the development in accordance with the reporting arrangements in any plans or programs approved under the conditions of this consent;

v. A comprehensive summary of the monitoring results of the development, reported in a accordance with the specifications in any conditions of this consent, or any approved plans and programs;

(iv) Reporting on the environmental performance of the development has not yet been prepared as the project is only three months into construction.

(v) A comprehensive summary of the monitoring results of the development has not yet been prepared.

(vi) Summary of the current stage and progress of the development has not yet been prepared and published in the website.

(ix) Independent environmental audit reports of the development are yet to be published in the website as this is the first audit being undertaken for the project.


NT

No.

SSD 8963

Ref. No.

Description of the Requirement Details of the finding

vi. A summary of the current stage and progress of the development;

ix. Audit reports prepared as part of any independent environmental audit of the development and the Applicant’s response to the recommendations in any audit report;

b. Keep such information up to date, to the satisfaction of the Planning Secretary.

NT‐03 B3 External Walls and Cladding ‐ Prior to the commencement of construction, the Applicant must provide the Certifier with documented evidence that the products and systems proposed for use in the construction of external walls including finishes and claddings such as synthetic or aluminium composite panels comply with the requirement of the BCA

The Applicant must provide a copy of the documentation given to the Certifier to the Planning Secretary within seven days after the Certifier accepts it.

A Certificate with the products and systems proposed for use in the construction of external walls including finishes and cladding to comply with the relevant requirements of the BCA has not yet been provided to the Planning Secretary. This component still being designed and the Crown Certificate will be provided prior to the commencement of construction of the façade.

NT‐04 B4 Reflectivity ‐ The building materials used on the facades of the buildings must have a maximum normal specular reflectivity of visible light of 20 per cent and must be designed so as not to result in glare that causes any discomfort or threatens the safety of pedestrians or drivers. A statement demonstrating compliance with these requirements or where compliance cannot be met a report that demonstrates that the exceedance would not result in glare that causes any discomfort or threatens the safety of pedestrians or drivers must be submitted to the satisfaction of the Certifier prior to the commencement of construction

A statement demonstrating compliance with the building materials used on the façades including reflectivity requirements has not yet provided to the satisfaction of the Certifier as this component still being designed. Statement will be provided as part of the Crown Certificate prior commencement of construction of the façade.

NT‐05 B19 Compliance Reporting – No later than two weeks before the date notified for the commencement of construction, a Compliance Monitoring and Reporting Program prepared in accordance with the Compliance Reporting Post Approval Requirements (Department 2018) must be submitted to the Department and the Certifier.

Compliance Reports of the project must be carried out in accordance with the Compliance Reporting Post Approval Requirements (Department 2018).

The Applicant must make each Compliance Report publicly available 60 days after submitting it to the Department and notify the Department and the Certifier in writing at least seven days before this is done

A Construction Compliance Report has not yet been prepared and submitted to the Department of Planning as required. It was suggested to start collecting the necessary information for the six‐monthly compliance report.


4.4 Opportunities for Improvement

The table below outlines the opportunities for improvement raised during the audit:

OFI

No.

SSD 8963

Ref. No. Description of Requirement

Findings Comment/

Recommendation

OFI‐01 B13 The Applicant must not commence construction of the development until the CEMP is approved by the Certifier and a copy submitted to the Planning Secretary

CEMP Revision 7 was available in the Department of Planning website. However latest revision of the CEMP is Revision 10 dated 26/9/18.

It was recommended that the latest version of the CEMP (Rev.10) is uploaded in the Department of Planning website.

OFI‐02 B14 (f) The Construction Traffic and Pedestrian Management Sub Plan (CTPMP) as required by condition B12, must address, but not be limited to, the following matters:

(f) Include a program to monitor the effectiveness of these measures.

The monitoring processes and

a program to monitor the

effectiveness of the traffic and

pedestrian management

control measures is not

explicitly included in the

sighted Traffic Management

Plan (TMP) Rev. 6.

Traffic Management Plan to

include monitoring

processes and program to

monitor the effectiveness of

the traffic and pedestrian

management control

measures.

OFI‐03 B16 The Construction Waste Management Sub‐Plan (CWMP), must address, but not be limited to, the following matters where relevant:

a) detail the quantities of each waste type generated during construction and the proposed reuse, recycling and disposal locations;

b) removal of hazardous materials, particularly the method of containment and control of emission of fibres to the air, and disposal at an approved waste disposal facility in accordance with the requirements of the relevant legislation, codes, standards and guidelines, prior to the commencement of any building works.

Waste disposal facility has not been included in the Waste Management Plan as required by the Conditions of Consent. Also, the waste classification table indicates there is ‘Special Waste ‐ Asbestos Waste (potential for unanticipated discovery)’; it was noted that there is no asbestos in Stage 3C of the project.

Waste Management Plan Section 6.0 to be updated to include the waste disposal facility and delete reference to asbestos waste.

John Holland is required to action the identified opportunities for improvement to comply with the SSD 8963 Development Conditions of Consent and to enhance the Environmental performance during the progress of the Project.

4.5 Incidents

No environmental incidents have occurred so far for the Stage 3C of the project.


4.6 Complaints

No complaints have been received for Stage 3C of the project.

A Complaints Register is available where information about the complaints is recorded including resolution reached. One complaint for Out of Hours Noise was recorded, but this was for Stage 3B.


Appendix A. Audit Attendance Sheet


Appendix B. Independent Audit Declaration Form

Audit Compliance Codes: NC: No-Complaint; NT: Not triggered; OFI: Observation for Improvement AQ1238.01A COMPLIANCE AUDIT REPORT ‐ LBH STAGE 3C ‐ 20181221 FINAL PAGE 13 OF 30

Appendix C. Audit Checklist

Item No.

SSD 8963 Ref. No. Audit Compliance Criteria Audit Evidence Compliance

Rating

1.0 PART A – Administrative Conditions

1.1 A6 Evidence of consultation with relevant parties including details of the consultation undertaken, the outcome, matters resolved and unresolved, and the details of any disagreement remaining and how it was addressed.

Consultation with Lismore Hospital in order to develop the Traffic Control Plan (TCP) is being undertaken on a regular basis. Meetings with the local community and Council are conducted as required. Meetings were carried out for Stage 3B, no meetings so far for Stage 3C.

1.2 A7, A8, A9, C28

Revision of Strategies, Plans and Programs The strategies, plans and programs required under this consent must be prepared, combined, updated and staged (if applicable). Within three months of:

a. the submission of a compliance report under condition B19 and B19;

b. the submission of an incident report under condition C26; c. the submission of an Independent Audit under condition B20; d. the approval of any modification of the conditions of this

consent; or e. the Issue of a direction of the Planning Secretary under

condition A2 which requires a review, The strategies, plans and programs must be reviewed and approved and the Department and the Certifier must be notified in writing that a review is being carried out.

Sighted for Lismore Base Hospital North Tower Extension Level 7-10: - Approved Plans (NSW Government website) - Site Plan Proposed DA1000 Rev. 3 dated 20/09/2018 - GA Level 10 DA22010 Rev. DA 20/09/2018. - Crane Consent – SSD - Contract Program that includes North Tower, Lower Tower and Upper

Tower. - Construction Program.

Approval from Department of Planning was received on the 20/09/2018. Note: CEMP has been reviewed at least annually, this year (2018) 4 revisions have been made: one in May 2018 and three in September 2018. In general, review of the CEMP and associated documents is being done as necessary.

1.3 A10 Demolition Demolition work must comply with Australian Standard AS2601-2001 The demolition of structures (Standards Australia, 2001). The work plans required by AS 2801-2001 must be accompanied by a written statement from a suitably qualified person that the proposals contained in the work plan comply with the safety requirements of the standard.

This requirement is ‘Not Applicable’ as no demolition works are to be carried out for Stage 3C of the Lismore Base Hospital redevelopment.


Item No.


Rating

The work plans and the statement of compliance must be submitted to the Certifier before the commencement of works.

1.4 A11 Structural Adequacy All new buildings and structures, and any alterations or additions to existing buildings and structures, that are part of the development, must be constructed in accordance with the relevant requirements of the BCA.

Crown Building Work Certificate No. 18/124020-3 BCA classification – 5, 7a, 9a approved 5/10/2018 for SSD8963. Attachment 3 included the Design Certificate - Structural works prepared by Arcadis 16/06/2017 complying with BCA 2015 Parts B & C.

1.5 A12 External Walls and Cladding The external walls of all buildings including additions to existing buildings must comply with the relevant requirements of the BCA.

This requirement is currently at design phase and still under discussions with Health Infrastructure. Compliance with BCA requirements to be monitored in the next audit, identified as a non-triggered requirement.

NT-01

1.6 A13 Applicability of Guidelines References in the Conditions of this Consent to any guideline, protocol, AS or policy are to such guidelines, protocols, Standards or policies in the form they are in as at the date of this consent. However, consistent with the conditions of this consent and without altering any limits or criteria on this consent, the Planning Secretary, may, when issuing directions under this consent in respect of ongoing monitoring and management obligations, require compliance with an updated or revised version such a guideline, protocol, Standard or policy or a replacement of them.

No amendments or variations have been recorded from the Department of Planning so far. As an example a Design certificate for Structural was sighted, which makes reference to applicable AS e.g. 1170.1-2002.

1.7 A14 Monitoring and Environmental Audits Any condition of this consent that requires the carrying out of monitoring or an environmental audit, whether directly or by way of plan, strategy or program, is taken to be a condition requiring monitoring or an environmental audit under Division 9.4 of Part 9 of the EPA Act. This includes conditions in respect of incident notification, reporting and response, non-compliance notification, compliance reporting and independent auditing.

Independent Environmental Audits will be carried out every 6 months as indicated in the Audit Program sent from CBRE to Health Infrastructure. Also, John Holland has a HSEQ Internal Audits Schedule for 2018. Sighted HSE Risk 3 month look-ahead tool with audits for Nov 2018 to Jan 2019.


Item No.


Rating

1.8 A15 At least 48 hours before the commencement of construction until the completion of all works or such other time as agreed by the Planning Secretary, the Applicant must a. make the following information and documents (as they are

obtained or approved) publicly available on its website: i. the documents referred to In condition A2. of this consent; ii. all current statutory approvals for the development; iii. all approved strategies, plans and programs required under

the conditions of this consent; iv. regular reporting on the environmental performance of the

development in accordance with the reporting arrangements in any plans or programs approved under the conditions of this consent;

v. a comprehensive summary of the monitoring results of the development, reported in accordance with the specifications in any conditions of this consent, or any approved plans and programs;

vi. a summary of the current stage and progress of the development;

vii. contact details to enquire about the development or to make a complaint;

viii. a complaints register, updated monthly; ix. audit reports prepared as part of any independent

environmental audit of the development and the Applicant's response to the recommendations in any audit report;

x. any other matter required by the Planning Secretary; and b. keep such information up to date, to the satisfaction of the

Planning Secretary

a. Approved Plans are available at Department of Planning website.

i. Sighted examples for DA22007 and DA81001 ii. Notice of Decision SSD8963 signed 20/09/2018 iii. All approved plans, programs and strategies are in the DPE website iv. Not triggered. Environmental tracking is included in monthly reports

provided to CBRE. However formal environmental performance reporting will start after completion of this audit as the result of this audit will go in the website.

v. Not triggered – Summary of monitoring results is due to commence. vi. Not triggered - Project Description is included in the NSW Government

website. Summary of progress will start to be distributed every 3 months e.g. updates on the website.

vii. Lismore Hospital Redevelopment website has a “Contact Us” function. Also site signage has JH Project Manager and Site Manager Details.

viii. Complaints register is saved in the website – OK. ix. Not triggered - This is the first independent environmental audit. x. No other information has been requested.

NT-02

(iv, v, vi, ix)

2.0 PART B – Prior to Commencement of Construction

2.1 B1 The Contractor to notify the Department in writing of the dates of commencement of physical work and operation at least 48 hours before those dates. Also notify before commencement of each

Notification of commencement was sent to CBRE on the 3/10/2018 for the North Tower Extension (NTX) at Lismore base Hospital Stage 3C redevelopment Main Works. CBRE indicated that a letter was sent to Health Infrastructure (HI) notifying the commencement of the works.


Item No.


Rating

stage the date of commencement and development out be carried out in that stage.

2.2 B2 Certified Drawings Prior to the commencement of construction, the Applicant must submit to the satisfaction of the Certifier structural drawings prepared and signed by a suitably qualified practising Structural Engineer that demonstrates compliance with:

a. the relevant clauses of the BCA; and b. this development consent

Sighted Design Certificate - Structural 16/06/2017 signed. The certificate is for Lismore Base Hospital Stage 3B2, but includes North Tower Extension (Stage 3C). a. BCA 2015 Parts B & C included.

2.3 B3 External Walls and Cladding Provide the certifier with documented evidence that the products and systems proposed for use in the construction of the external walls including finishes and cladding comply with the requirements of the BCA. Copy of the documentation given to the Certifier to the Planning Secretary must be provided within 7 days after the Certifier accepts it.

This requirements has not finalised yet; currently CBRE is waiting for a decision to be made by Health Infrastructure. This requirement has been identified in the critical path. Copies of the documentation including products and systems for use in the construction of the external walls and cladding have not yet been prepared as this component still being designed.

NT-03

2.4 B4 Reflectivity, Outdoor lighting The building materials used on the facades must have a maximum normal specular reflectivity of visible light of 20 percent and designed so as not to result in glare. A statement demonstrating compliance with requirements to be submitted to the satisfaction of the Certifier prior commencing construction.

Design for reflectivity analysis was carried out on the 12/4/2018 for the whole building, however material for façade has not yet been approved by client. Currently there are 2 companies providing reflectivity requirements which comply with BCA requirements. Once a decision is made an update report will be produced. This requirement still being designed and so it is not-triggered. CBRE indicated that the relevant Crown Certificate for the façade will be obtained and submitted to DPE prior commencing construction of the façade.

NT-04

2.5 B5 Protection of Public Infrastructure Pre-Construction consultation and dilapidation reports Report submitted to the satisfaction of the Certifying Authority & copy to Council.

Sighted Stage 3B2 and North Tower Extension (3C) Dilapidation Report prepared by Peter Lucena E & Associates Pty Ltd on the 17/9/2018. Presented e-mail 27/09/2018 with Dilapidation Report and Video sent to Lismore City Council and CBRE.

2.6 B6, B7 Utilities and Services Pre-Construction of utility works approved by service providers.

Electricity, telecommunications and gas suppliers are in the critical path.


Item No.


Rating

Approval of service providers (electricity supply authority, telecommunications and gas carrier) prior to commencement of above ground work.

- Presented email 30/10/2018 with approval of request to expedite Application for a New Connection – NMI 40012949898 from essential energy (electrical supplier).

- Telstra - continue chasing as they haven’t received a response from them. - ELGAS letter sent 04/10/2018; LP Gas no formal letter received yet.

2.6 B8 A Community Communication Strategy must be prepared to provide mechanisms to facilitate communication between the Applicant, the relevant Council and the community (including adjoining affected landowners and businesses, and others), during the D&C of the development and for a min of 12 months following the completion of construction. The Community Communication Strategy must:

a. identify people to be consulted during the design and construction phases;

b. set out procedures and mechanisms for the regular distribution of accessible information about or relevant to the development;

c. provide for the formation of community-based forums, if required, that focus on key Env. Mgt. issues for the development;

d. set out procedures and mechanisms: i) through which the community can discuss or provide

feedback to the Applicant; ii) through which the Applicant will respond to enquiries or

feedback from the community; and iii) to resolve any issues and mediate any disputes that may

arise in relation to construction and operation of the development, including disputes regarding rectification or compensation.

The Community Communication Strategy must be submitted to the Planning Secretary for approval no later than two weeks before the commencement of any work. Work for the purposes of the development must not commence until the Community Communication Strategy has been approved

Community Communication Strategy SSD 17_8963 dated 07/09/2018 issued on the 13/09/18 was sighted. The project has signage outside construction site in case any person from the Hospital or local community has any enquiries. Site Manager and Project Manager phone numbers are included. Community Communication Strategy includes:

a. List of stakeholders who have been consulted during the redevelopment construction period e.g. Hospital executives, local businesses, Lismore City Council, CRRH, Rous Water, etc.

b. Communications mechanisms e.g. newsletters, website updates. Last newsletter was reviewed by HI.

c. Lismore Hospital leads meetings with HI/CBRE/Community and others. d. Letters were distributed to the community describing construction works.

Stakeholder Management Plan was sighted (LBH-PP-JH-Y-0011-03-SKMP-270718). Plan describes the communication tools with stakeholders:

- Meeting with community members – monthly or as requested. - Residents and business – letterbox drop and door knock, as required.

This Plan needs to be referenced in the CEMP. Presented letter from Department of Planning to Health Infrastructure dated 04/10/2018 approving the Community Communication Strategy for Lismore Base Hospital Redevelopment Stage 3C.


Item No.


Rating

by the Planning Secretary, or within another timeframe agreed with the Planning Secretary.

2.7 B9 The Applicant must ensure that all of its employees, contractors (and their sub-contractors) are made aware of, and are instructed to comply with, the conditions of this consent relevant to activities they carry out in respect of the development.

Site Induction presentation was presented including Environmental policy, Environmental key aspects and Environmental requirements from the SSD8963. Site Orientation Checklist was sighted for Electrician completed 26/11/18. Induction indicates project staff and contractors must comply with all project requirements and SSD conditions.

2.8 B10 Prior commencement of construction, all outdoor lighting within the site must comply with AS 1158.3.1.2005 and AS 4282-1997. Details to be submitted to the Certifier.

The AS 1158.3.1.2005 is not applicable for this project. An Electrical Design Certificate No. 29798-SYD-E dated 7/8/2017 was presented to comply with AS282:1997 for Lismore base Hospital Stage 3B2 (North Tower Extension)

2.9 B11 Access for People with Disabilities Compliance with requirements of the BCA to provide access and facilities for people with a disability. Certifier to ensure evidence from an appropriately qualified person is provided and the requirements are referenced o any certified plans.

Sighted Accessibility Compliance Statement (Construction Certificate) Stage 3C dated 26/11/2018 provided by McKenzie Group - Certifier. Certificate indicates that BCA clause D3.4 is an exemption.

2.10 B12 Construction Environmental Management Plan a. Prior to the commencement of construction works, a CEMP

must be prepared and include, but not be limited to, the following:

i) community consultation and complaints handling; ii) hours of work; iii) 24 hour contact details of site manager; iv) management of dust and odour to protect the amenity

of the neighbourhood; v) stormwater control and discharge; vi) measures to ensure that sediment and other materials

are not tracked onto the roadway by vehicles leaving the site;

CEMP for Lismore Base Hospital Stage 3C North Tower: LBH-PP-JH-Y-0004-09-CEMP dated 26/9/18 Rev.10 was sighted.

i. Section 7.4 indicates there will be external communication with Community Groups & Section 7.5.1 describes management of complaints.

ii. Section 5.1 iii. Section 5.2 includes site contact details iv. Dust and Air Quality Sub-plan version H dated 19/9/18 Section 6.0

defines the environmental control measures and safeguards. v. Water Quality Erosion and Sediment Control Sub-Plan Version H dated

19/9/18 Section 9.0 includes management of stormwater. vi. Water Quality Erosion and Sediment Control Sub-Plan Version H dated

19/9/18 Section 7.0 outlines sediment controls.


Item No.


Rating

vii) external lighting in compliance with AS4282:1997 Control of the Obtrusive Effects of Outdoor Lighting; and

viii) waste classification (for materials to be removed) and validation (for materials to remain) be undertaken to confirm the contamination status in these areas of the site.

Other Specific Management Plans: b. Construction Traffic and Pedestrian Management Sub-Plan c. Construction Noise and Vibration Management Sub-Plan d. Construction Waste Management Sub-Plan

vii. Included in Appendix 2 (Table 15) Outdoor lighting; however, this table needs to be updated to include all the Conditions of Consent for Stage 3C of the project.

viii. Waste Management Sub-Plan version I dated 26/9/18 section 6.0 indicates waste classification and disposal.

Sighted Plan and Sub-Plans for: b. Traffic Management Plan LBH-PP-JH-Y-0007-06-TMP Rev. 6 - 19/9/18 in place. c. Noise and Vibration Management Sub-Plan JH-ECP-ENV-004 CNVMP Rev. E 26/9/18 in place. d. Waste Management Sub-Plan JH-ECP-ENV-005 WM Rev. I - 26/9/18 in place.

2.11 B13 Prior to the commencement of construction works, a CEMP must be submitted for the approval of the Certifying Authority and a copy submitted to the Planning Secretary.

CEMP was submitted to CBRE. Sighted Building Certification for Crown Building Work, certificate No. 18/124020-3 from McKenzie Group which includes the CEMP Rev. 9 dated 19/09/2018 as part of the attachments No. 9. Certificate (which was required prior to works commencing) demonstrates review of CEMP. Also note that this formed part of the documentation issued to DPE for upload on the Lismore Hospital Redevelopment site as per the DPE condition. CEMP (Rev.7) available in the Department of Planning website, however latest revision of the CEMP is Rev. 10 dated 26/9/18. John Holland to upload the latest revision pf the CEMP.

OFI-01

2.12 B14 The Construction Traffic and Pedestrian Management Sub-Plan (CTPMP) as required by condition B.12 must address, but not be limited to, the following matters: a. be prepared by a suitably qualified and experienced person(s); b. be prepared in consultation with Council; c. detail measures to be implemented to ensure road safety and

network efficiency during construction considering general traffic, cyclists and pedestrians and bus services;

d. detail heavy vehicle routes, access and parking arrangements; e. include a Driver Code of Conduct to:

Traffic Management Plan for Lismore Base Hospital Stage 3C (LBH-PP-JH-Y-0007-06-TMP) Rev. 6 dated 19/9/18 was sighted. Plan included: a. TCP was prepared by Traffic Control Innovations (TCI) Consultant. b. Consultation and approval of TCP was sighted with Lismore City Council. Presented email approving TCP in Appendix 6 of the TCMP. c. Section 3.0 Vehicular Traffic Impacts d. Section 1.3 and 3.3 site access, section 4.2 parking e. Section 3.4 general construction deliveries included a driver code of conduct f. The following monitoring activities are undertaken:

- Joh Holland carries out internal audits one their company Global Mandatory Requirements (GMRs), there is one for is Traffic, Plant and People; sighted record on the 31/10/2018.


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i) minimise the Impacts of earthworks and construction on the local and regional road network;

ii) minimise conflicts with other road users; iii) minimise road traffic noise; and iv) ensure truck drivers use specified routes;

f. include a program to monitor the effectiveness of these measures;

g. if necessary, detail procedures for notifying residents and the community (including local schools),of any potential disruptions to routes.

- Daily sign-in register and daily checks were sighted dated 19/11/2018 signed by a Traffic Controller from TCI employee.

- Traffic Management inspections undertaken by John Holland, sighted completed one on the 9/10/2018; frequency of inspections: ‘as required’.

- Construction work site checklist is completed by CBRE and John Holland on fortnightly basis.

- The audit noted that the monitoring processes and a program to monitor the effectiveness of these measures is not explicitly included in the Traffic Management Plan.

g. Disruptions are notified via the newsletter and/or letter box to the residents and the Hospital. Sighted newsletter 3/4/18 for lower north tower and a newsletter for the installation of the crane. Also, there are some meetings carried out with representatives of the community. These meetings are led by Lismore Hospital and actions communicated to John Holland, as appropriate.

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2.13 B15 The Construction Noise and Vibration Management Sub-Plan (CNVMP) as required by condition B12,must address, but not be limited to, the following matters:

a. be prepared by a suitably qualified and experienced noise expert;

b. be prepared in consultation with Council and all noise sensitive receivers where noise levels exceed the construction noise management level in EPA's Interim Construction Noise Guideline (DECC, 2009);

c. describe procedures for achieving the noise management levels in EPA's Interim Construction Noise Guideline (DECC,2009);

d. describe the measures to be implemented to manage high noise generating works such as piling, in close proximity to sensitive receivers;

e. include strategies that have been developed with the community for managing high noise generating works;

f. describe the community consultation undertaken to develop the strategies in condition B15(e); and

Noise and Vibration Management Plan for Lismore Base Hospital Stage 3C JH-ECP-ENV-004 revision D dated 26/9/18 was sighted. a. Plan was prepared by Resonate Consultants. b. A Newsletter was distributed for the start of the North Tower Extension. Also,

Section 4.1 describes the process for consultation during construction c. Section 6.1.1 Noise management levels d. Section 6.1.2 highly noise affected e. Section 6.1.2 – restriction the hours of construction works. So far no ‘Out of

Hours’ works have been carried out for Sage 3C of the project. f. Section 4.0 – consultation during construction g. Section 4.2 indicates the complaint management procedure. This is further

described in the Stakeholder Management Plan. A Complaint Register is maintained in the NSW Government website (DPE) for Lismore Hospital Redevelopment. So far 1 complaint was received for Stage 3B (2) on the 3/7/2018 regarding an Out of Hours noise. None for Stage 3C.


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g. include a complaints management system that would be Implemented for the duration of the construction.

2.14 B16 The Construction Waste Management Sub-Plan (CWMP) as required by condition B12,must address, but not be limited to, the following matters where relevant:

a. detail the quantities of each waste type generated during construction and the proposed reuse, recycling and disposal locations;

b. removal of hazardous materials, particularly the method of containment and control of emission of fibres to the air, and disposal at an approved waste disposal facility in accordance with the requirements of the relevant legislation, codes, standards and guidelines, prior to the commencement of any building works.

Waste Management Plan for Lismore Base Hospital Stage 3C JH-ECP-ENV-005 revision I dated 26/9/18 was sighted. a. Section 6.0 includes waste type and estimated quantities. A table with

construction waste classification and transport/disposal method was sighted, however the waste disposal facility is not included. Also, this table indicates there is ‘Special waste - Asbestos Waste (potential for unanticipated discovery)’; however there are no asbestos in this stage of the project. Table should be updated.

Sighted report from Richmond Waste - October 2018 with quantities. b. Section 6.0 indicates that non-hazardous waste will be disposed of at

Northern Rivers Waste (Lismore NSW).

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2.15 B17 Operational Noise - Design of Mechanical Plant and Equipment Prior to commencement of construction, the Applicant must Incorporate the noise mitigation recommendations in the Lismore Hospital Stage 3C SEAR 9 Noise Impact Assessment, prepared by Acoustic Logic, dated 11/4/18, into the detailed design drawings. The Certifier must verify that all reasonable and feasible noise mitigation measures have been incorporated into the design to ensure the development will not exceed the recommended operational noise emission criteria.

SEA9 Noise Impact Assessment provided by Acoustic Logic dated 11/4/2018 Rev. 1. Note: Assessment to be included in the Completion of Crown Certificate.

2.16 B18 Mechanical ventilation Mechanical ventilation systems to be installed in accordance with BCA requirements and comply with AS 1668.2-2012 requirements and submitted to the Certifier.

Design Certificate - Mechanical for Lismore Base Hospital 3b@ - North Tower Extension sighted. Certificate was dated 22/10/2018 including compliance with AS/NZS 1668.1-2015, AS1668.2-2012.

2.17 B19 Compliance Reporting No later than two weeks before the date notified for the commencement of construction, a Compliance Monitoring and

A letter from CBRE dated 17/9/2018 was sent to Health Infrastructure indicating that a Consultant will be engaged to verify compliance monitoring and reporting to the Department.


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Reporting Program prepared in accordance with the Compliance Reporting Post Approval Requirements (Department 2018) must be submitted to the Department and the Certifier. Compliance Reports of the project must be carried out in accordance with the Compliance Reporting Post Approval Requirements (Department 2018). The Applicant must make each Compliance Report publicly available 60 days after submitting it to the Department and notify the Department and the Certifier in writing at least seven days before this is done.

A Construction Compliance Report for the Department of Planning, as per this Condition of Consent, has not yet been prepared. John Holland to start collecting the necessary information for the six-monthly compliance report.

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2.18 B20, B21, B22, B23

Independent Environmental Audit No later than 2 weeks before the date notified for the commencement of construction, an Independent Audit Program prepared in accordance with the Independent Audit Post Approval Requirements (Department 2018) must be submitted to the Department and the Certifier. Independent Audits of the development must be carried out in accordance with:

a. the Independent Audit Program submitted to the Department and the Certifier under condition 820 of this consent; and

b. the requirements for an Independent Audit Methodology and Independent Audit Report in the Independent Audit Post Approval Requirements (Department 2018).

In accordance with the specific requirements in the Independent Audit Post Approval. Requirements (Department 2018), the Applicant must:

a. review and respond to each Independent Audit Report prepared under condition B21(b) of this consent;

b. submit the response to the Department and the Certifier; and c. make each Independent Audit Report and response to it

publicly available within 60 days after submission to the Department and notify the Department and the Certifier in writing when this has been done.

This is the first independent environmental audit undertaken for this project stage - 3C North Tower Extension. An independent audit program was prepared by an external consultant (AQUAS) and sent to Department of Planning. Letter dated 27/9/2018. Audit program was sent 27/9/18 which indicates audits will be carried out every 6 months.


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Notwithstanding the requirements of the Independent Audit Post Approval Requirements (Department 2018), the Planning Secretary may approve a request for ongoing annual operational audits to be terminated, where it has been demonstrated to the Secretary's satisfaction that an audit has verified and confirmed operational compliance.

3.0 PART C – During Construction

3.1 C1 Approved Plans to be On-site A copy of the approved and certified plans, specifications and documents incorporating conditions of approval and certification must be kept on the Site at all times and must be ready available for perusal by any officer of the Department, Council or the Certifier.

John Holland Approved Plans for the Lismore Base Hospital Redevelopment Stage 3C are available in the Department of Planning website and NSW Government website. Also, sighted examples of site plans: Site Plan proposed DA1000 Rev. 3 dated 20/09/2018 and GA level 10 DA22010 Rev. DA 20/09/2018. Plans are kept in hard copies and electronic I the website.

3.2 C2 Site Notice. A site notice(s): a. must be prominently displayed at the boundaries of the site

for the purposes of informing the public of project details Including, but not limited to the details of the Builder, Certifier and Structural Engineer.

b. is to satisfy all but not be limited to, the following requirements:

i) minimum dimensions of the notice must measure 841mm x 594 mm (A1) with any text on the notice to be a minimum of 30-point type size;

ii) the notice is to be durable and weatherproof and is to be displayed throughout the works period;

iii) the approved hours of work, the name of the site/ project manager, the responsible managing company (if any),its address and 24-hour contact phone number for any inquiries, including construction/ noise complaint must be displayed on the site notice; and

Site Notice in place at Little Uralba Street. Signage included: Name of project, principal contractor, name and contact number of the site manager and project manager, after hours contact, site office address. Signage dimensions appear to be appropriate, is in good conditions and was mounted at eye level at the entry of the construction site.


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iv) the notice(s) is to be mounted at eye level on the perimeter hoardings/fencing and is to state that unauthorised entry to the site is not permitted.

3.3 C3 Operation of Construction Plant and Equipment All plant and equipment used on site, or to monitor the performance of the development must be:

a. maintained in a proper and efficient condition; and b. operated in a proper and efficient manner.

Tower Crane Plant hazard assessment was completed by subcontractor Lindores. A weekly log book is maintained sighted Tower Crane Daily/Weekly Safety & Service Log – 19/11/18-25/11/18 No. 69407023. Elevated Working Platform Log Book dated 29/11/18. John Holland reviewed/accepted Safe Work Method Statements

3.4 C4, C5, C6

Construction Hours Construction, including the delivery of materials to and from the site, may only be carried out between the following hours:

a. between 7am and 6pm, Mondays to Fridays inclusive; and b. between 8am and 1pm, Saturdays c. No work may be carried out on Sundays or public holidays.

Activities may be undertaken outside of the hours in Condition C4 if required:

a. by the Police or a public authority for the delivery of vehicles, plant or materials; or

b. in an emergency to avoid the loss of life, damage to property or to prevent environmental harm.

c. works are Inaudible at the nearest sensitive receivers. d. works are approved in advance in writing by the Planning

Secretary and sufficient justification is provided for the works. Notification of such activities must be given to affected residents before undertaking the activities or as soon as is practical afterwards. Rock breaking, rock hammering, sheet piling, pile driving and similar activities may only be carried out between the following hours:

a. 9am to 12pm, Monday to Friday;

Construction Hours are as per CEMP - Section 5.1 of the CEMP indicates the hours of work Mon-Fri 7am-6m, Sat 8am-1pm and no work on Sunday or public holidays. No ‘Out of Hours’ works have been carried out so far for Stage 3C. Not required so far. Section 5.1 of the CEMP includes the same hours of work for Rock breaking, rock hammering, etc. However this requirement is not applicable as these activities will not be carried out for Stage 3C.


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b. 2pm to 5pm Monday to Friday; and c. 9am to 12pm, Saturday.

3.5 C7 Implementation of Management Plan The Applicant must carry out the construction of the development in accordance with the most recent version of the approved CEMP.

Construction is being carried out in accordance with CEMP LBH-PP-JH-Y-0004-09-CEMP Rev.10 dated 26/9/18. It was recommended that the latest version of the Plan is uploaded into the Department of Planning website, as currently CEMP Rev.7 is the version available in the website.

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3.6 C8 Construction Traffic All construction vehicles (excluding worker vehicles) are to be contained wholly within the site, except if located in an approved on-street work zone, and vehicles must enter the site before stopping.

There is a loading/unloading area on Little Uralba St, also concrete trucks to access via the southern end of little Uralba St. Confirmed during the site walk.

3.7 C9 Road Occupancy Licence A Road Occupancy Licence must be obtained from the relevant road authority for any works that impact on traffic flows during construction activities.

This requirement is not applicable for this Project as they work is under the Lismore City Council – it is a council road. Approval from Lismore Council was sighted in email dated 21/3/18 in Appendix 6 of Traffic Management Plan (Rev. 6.0).

3.8 C10 SafeWork Requirements To protect the safety of work: personnel and the public, the work site must be adequately secured to prevent access by unauthorised personnel, and work must be conducted at all times in accordance with relevant SafeWork requirements.

PPE worn by workers sighted on construction site. Hospital security guards do patrols at night around the Hospital and construction site work area and site compounds. There is wire on top of the mesh.

3.9 C11 No Obstruction of Public Way The public way (outside of any approved construction works zone) must not be obstructed by any materials, vehicles, reuse, skips or the like, under any circumstances, unless there is prior written approval from the relevant authority. Non-compliance with this requirement will result In the Issue of a Notice by the relevant Authority to stop all works on site.

One street was closed for the construction site to take place. That is Little Uralba Street. No other public areas have been obstructed by the construction works. Traffic Control Plans are in place, when there is road closure or any obstruction will take place. Sighted TCP for Crane Set-up.


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3.10 C12 Construction Noise Limits The development must be constructed to achieve the construction noise management levels detailed in the Interim Construction Noise Guideline (DECC, 2009). All feasible and reasonable noise mitigation measures must be implemented and any activities that could exceed the construction noise management levels must be identified and managed in accordance with the management and mitigation measures identified in the approved CNVMP.

Project has not exceeded the required noise levels. Noise monitoring happens, as required. The Acoustic Logic Report includes a list of activities that will be carried out in the project Stage 3C and there is no need for a permanent noise monitoring device on site.

3.11 C13 The Applicant must ensure construction vehicles (including concrete agitator trucks) do not arrive at the site or surrounding residential precincts outside of the construction hours of work outlined under Condition C4.

Specific area for construction vehicles to park, bring materials and load with waste. Trucks are scheduled only during approved working hours.

3.12 C14 The Applicant must implement, where practicable and without compromising the safety of construction staff or members of the public, the use audible movement alarms of a type that would minimise noise Impacts on surrounding noise sensitive receivers.

No noise complaints for Stage 3C.

3.13 C15 Any noise generated during construction of the development must not be offensive noise within the meaning of the Protection of the Environment Operations Act 1997 or exceed approved noise limits for the site.

Project has not exceeded the required noise levels.

3.14 C16 Vibration Criteria Vibration caused by construction at any residence or structure outside the site must be limited to:

a. for structural damage, the latest version of DIN 4150--3 (1992-02) Structural Vibration Effects of vibration on structures (German Institute for Standardisation, 1999); and

b. for human exposure, the acceptable vibration values set out in the Environmental Noise Management Assessing Vibration: a technical guideline (DEC, 2006) (as may be updated or replaced from time to time)

No vibration monitors installed and no exceedance alerts received.


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3.15 C17, C18 Vibratory compactors must not be used closer than 30 metres from residential buildings unless vibration monitoring confirms compliance with the vibration criteria specified in condition C16. The limits in conditions C16 and C17 apply unless otherwise outlined in a CNVMP, approved as part of the CEMP required by condition 812 of this consent.

Vibratory compactors not used on site.

3.16 C19, C20 Dust Minimisation The Applicant must take all reasonable steps to minimise dust generated during all works authorised by this consent. During construction, the Applicant must ensure that:

a. exposed surfaces and stockpiles are suppressed by regular watering;

b. all trucks entering or leaving the site with loads have their loads covered;

c. trucks associated with the development do not track dirt onto the public road network;

d. public roads used by these trucks are kept clean; and e. land stabilisation works are carried out progressively on site

to minimise exposed surfaces

During the site walk dust was sighted on Level 8 and 9. John Holland did a clean-up (vacuum and wet-sweep) of the rubbish on scaffold, timbers left in set-downs, and concrete dust accumulated on the slab.

a. Complaint b. Confirmed c. If needed will clean the street d. Complaint e. All gravel. Streets are in good conditions

3.17 C21 Disposal of Seepage and Stormwater Not to be pumped to the street stormwater system unless approved

There is an underground basin connected to the stormwater system from Council. Basin measurements 97.2m3 – 4.5 x 12 x 1.8m. Environmental Representative undertakes monthly visual inspection of the basin to check any sediments. So far the water appear to be cleared. Presented Water supply and stormwater Notice to Applicant of Determination of Application dates 5/11/18.


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3.18 C22, C23 Waste Storage and Processing Waste must be secured and maintained within designated waste storage areas at all times and must not leave the site onto neighbouring public or private properties. All waste generated during construction must be assess, classified and managed in accordance with the Waste Classification Guidelines Part 1: Classifying Waste (EPA,2014).

There is a designated waste storage area and a Richmond Waste Bin in place on the ground floor. Also, each floor has a waste bin allocated. Waste report received from Richmond Waste. Sighted report for October 2018 indicating the amounts and type of waste.

3.19 C24 The body of any vehicle or trailer used to transport waste or excavation spoil must be covered before leaving the premises to prevent any spillage or escape of any dust, waste of spoil. Mud, splatter, dust and other material likely to fall from or be cast off the wheels, underside or body of any vehicle, trailer or motorised plant leaving the site must be removed before leaving the premises.

Waste/spoil is covered before leaving the site.

3.20 C25 The Applicant must ensure that concrete waste and rinse water are not disposed of on the site and are prevented from entering any natural of artificial watercourse.

During site walk good practices were observed.

3.21 C26 Incident Notification, Reporting and Response The Department must be notified in writing ID [email protected] immediately after the Applicant becomes aware of an incident The notification must identify the development (Including the development application number and the name of the development if it has one), and set out the location and nature of the Incident. Subsequent notification must be given and reports submitted in accordance with the requirements set out in Appendix 1.

Section 7.5.2 of CEMP has details for incidents management and there is also an Incident procedure JH-MPR-SQE-010 in place. No environmental incidents have been reported so far for this project.

3.22 Appx. 1 Subsequent notification must be given and reports submitted in accordance with the requirements set out in Appendix 1. Notification of an incident must: a. identify the development an application number

No environmental incidents have been reported so far for this project. However, Appendix 1 has not been included in the Obligation Register.


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b. provide details of the incident (date, time, location, a brief description of what occurred and why it is classified as an incident)

c. identify how the incident was detected d. identify when the applicant became aware of the incident e. identify and actual or potential non-compliance with condition

of consent f. describe what immediate steps were taken in relation to the

incident g. identify further actions that will be taken in relation to the

incident; and h. identify a project contact for further communication regarding

the incident

3.23 Appx. 1 Within 30 days of the date on which the incident occurred or agreed by the Planning Secretary, applicant to provide a detail report on the incident addressing all requirements below, and such further reports as may be requested. Incident report must include: a. a summary of the incident b. outcomes of an incident investigation, including identification of

the cause of the incident c. details of the corrective and preventive actions that have been,

or will be, implemented to address the incident and prevent reoccurrence

d. details of any communication with other stakeholders regarding the incident

No incident has occurred onsite

3.24 C27 The Department must be notified in writing to [email protected] within seven days after the Applicant becomes aware of any non-compliance. The Certifier must also notify the Department in writing to [email protected] within seven days after they identify any non-compliance. The notification must identify the development and the application number for it, set out the condition of consent that the development is non-compliant with, the way in which it does not comply and the

No non-compliances or corrective actions have been raised for this project so far. Zero EPA breaches.


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reasons for the non-compliance (if known) and what actions have been, or will be, undertaken to address the non-compliance.

3.25 C29 Revision of Strategies, Plans and Programs If necessary to either improve the environmental performance of the development, cater for a modification or comply with a direction, the strategies, plans and programs required under this consent must be revised, to the satisfaction of the Certifier. Where revisions are required, the revised document must be submitted to the Certifier for approval within 6wks.

CEMP has been reviewed at least annually, this year 4 revisions have been made: one in May and 3 in September 2018. In general review of the CEMP and associated documents is done as necessary.

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