Consequence Likehood Risk Rating Consequence Likehood Risk Rating
1
Tyre sheredding process and mobie
plant operation Noise pollution Noise Damage Minor Possible 8
Medium
Environmental and Occupational Noise Assessment conducted in 2013 (document held by HSEQ team). No evidence of
environmental noise pollution or vibration concerns as a result of Tyrecycle activities
Minor Very Unlikely 3
Low
Releaeses to water Surface water contamination Significant Possible 13
Medium Significant Very Unlikely 6
Low
Releases to land Soil Contamination Significant Possible 13
Medium Significant Very Unlikely 6
Low
Releases to water Surface water contamination Significant Possible 13
Medium Significant Very Unlikely 6
Low
Releases to land Land contamination Minor Possible 8
Medium Minor Unlikely 5
Low
4 Washing trucks Releases to Water Surface water contamination
Minor Possible
8 Medium
All trucks are taken off site to a suitably equipped facility for
cleaning Minor Very Unlikely 3
Low Generation of
waste Land contamination Major Likely 21
High Major Very Unlikely 10
Medium
Contamination of
stormwater Stormwater contamination Extensive Likely 24
Extreme Extensive Very Unlikely 15
High
Polluted ambient smoke, gases, heavy metals, Volatile Organic Compounds (VOC) and Polycyclic Aromatic Hydrocarbons (PAH’s)
Air contamination Extensive Likely 24
Extreme Extensive Very Unlikely 15
High
Releases to Water Uncontained Releases with
Potential Impact to Humans, Significant Possible 13
Medium Significant Very Unlikely 6
Low
Releases to land Fauna or Flora Significant Possible 13
Medium Significant Unlikely 6
Low
Surface water contamination Significant Posibble 13
Medium Significant Very Unlikely 6
Low
Spills and leaks Significant Possible 13
Medium Significant Very Unlikely 6
Low Emission to air Air pollution (smog, acid rain,
dust, visual impairment) Minor Possible 8
Medium Minor Unlikely 5
Low
Releases to land Land contamination Minor Unlikely 5
Low Minor Very Unlikely 3
Low 8
Dust generation in yard and by product of existing crumbing
process.
A speed limit of 8 kph is imposed to minimise the dust raised by truck and plant movements around the yard. Dust particle concentrations have been assessed to comply with the relevant air quality requirements. Shred is not inherently dusty and is unlikely to have any impact on dust emissins from the site.
6 Storage of tyre shred (TDF)
Shred is stored on a dedicated area of hardstand in the yard to ensure product quality for customers and to comply with licence requirements. Shred is loaded from storage area directly into shipping containers. Any product that leaves the area is routinely picked up/raked up. The storm water captured from yard run off channels inyo th drainage system which is contained with a valve.
7 Acid Battery Generation of
waste
Stored on bunds, undercover until plastic wrapped and collected by contractor. Limits placed on stacking to max 2 batteries high.
Spill kit and eye wash facility available if a spill or leak does occur.
Regular weekly collections to minimise stock at all times. Training to ensure staff adhere to procedure. Audits and inspections for monitoring and review.
3 Storage & handling of oils, grease, coolants, paints, Process water
Oils, grease & coolants stored inside the maintenance shed on undercover bunds. Spill kits stocked & located nearby in the event of a leak or spill. Correct disposal of waste as required. Information and education. Routine inspections, observations & audits conducted as per IPI table to monitor and verify. Flammable products stored in flameproof, bunded cabinet.
5
Tyre fire & associated potential Releases of smoke, oil, toxic gas,
contaminated fire wash water
< Fire prevention: Pre-employment arson checks; site security;
cctv; ignition sources assessed & managed; hot work permit system; site induction; emergency preparedness drills; worker training; temperature gun; cleaning schedule; housekeeping observations; waste storage observations; chemical storage observations; internal & external audits.
< Fuel loads: Pile dimensions; stock management plan; pile flood markers.
< Fire spread: Pile & boundary separation; mobile plant; tyre pit walls.
< Fire suppression: Adequate & effective hydrants; hose reels;
water tanks; sprinklers; extinguishers; spark detection & foam suppression; emergency service access.
< Water containment: Site kerb & bund in place as per hydraulic modelling; interceptor pits; storage volume of drainage system pipes and pits; storm water discharge isolation valve; waste sucker truck agreement.
2 Collection and storage of used drained oil filters for customer
Oil filters are pre-drained by the customer prior to collection to reduce residual volume. Oil filters are stored in containers that are stored on undercover bunds. Spill kits are available and employees are trained to use them. Regular collections are arranged to ensure that minimum levels are kept on site at all times.
Induction training modules (employees and contractors); Collection SWMS; Collection Truck Training Module; Truck audits.
Activity Aspect Impact
PRE - CONTROL RISK
Management measures POST - CONTROL RISK
Negligible or no environmental damage
< No community complaints
< No corrective actions required
< No breach of regulation or consent
Minor environmental damage
< Impact confined to site
< Action/control required
< Warning letter from Authority
< An isolated community complaint
Significant Environmental Damage
< Contained off-site environmental damage (e.g.: spill on road)
< Local media interest
< Repeat community complaints
< Regulatory enforcement action (e.g.: fine, notice, order)
Major environmental damage
< Uncontained off-site environmental damage (e.g.: polluted water)
< Regional media interest
< Multiple community complaints (5+ p/a)
< Notification to authority required
< Civil prosecution Extensive environmental
damage
< Long-term environmental damage
< National media interest
< Criminal prosecution
Very Unlikely This consequence has never been known to ocurr ot it is extremely unlikely that is could ever occur
Unlikely Could occur but considered unlikely or doubtful
Possible Could happen or know it to happen
Likely Could easily happen/likely
Almost Certain Could occur often/very likely
Consequences of an environmental event
Determine the likehoos or probability of the unwanted event
WA
NOISE
The sources of possible nuisance noise at this site include the shredding process, the Tyrecycle and contractor trucks, the mobile plant and small hand operated tools such as drills, grinders and welding equipment.
The levels of noise generated at the site are significant enough to require hearing protection to be worn for people in close proximity to certain parts of the plant and therefore controls are in place, but the levels are not a risk of concern for noise levels being emitted off the property. An Occupational Noise Assessment was conducted in 2019 and contains further details. This aspect is assessment every 5 years.
CHEMICALS
Procedures for appropriate storage and handling and monitoring processes are in place for possible pollutants or contaminants used on site that may turn into prescribed industrial wastes if spilt or are no longer fit for purpose (ie. they turn into a waste).
There are small quantities of LPG bottles at this site for use in the mobile plant. These are secured, labelled and managed to ensure the risk of environmental harm is minimal.
There are minor quantities of flammable liquids stored on site, such as paints and thinners. These are located in flammable liquid cabinets or on identified bunds within the workshop or shed. They are labelled and have safety data sheets and spill kits readily available to enable the recovery of spilt material. Safe storage information regarding segregation and compatibility with other products is displayed. The risk of environmental harm from flammable liquids is low.
There are other substances such as oils, coolants and grease that are used in the maintenance of the plant and trucks that are classified as neither hazardous substances nor dangerous goods. These are all stored in minor quantities, on bunds, have accompanying safety data sheets and spill kits and are handled accordingly to ensure a low environmental risk.
There is a minor store of diesel on the O’Connor site, used for re-fuelling. This IBC is stored on a bund, inside a shed, undercover, adjacent to a spill kit, and contained within the whole of site kerb/bund system.
Minor quantities of used car batteries and drained oil filters are temporarily stored undercover at the O’Connor site until they are collected and further recycled. The batteries are stored and handled in accordance with the requirements for Class 8 dangerous goods. Bunds, spill kits, safe operating procedures and personal protective equipment are available and used as required, in conjunction with other safety and environmental processes.
AIR QUALITY
The activities at this site do not generate or contribute to the existing sources of odour in the local area. The tyre recycling process does not involve the addition of chemicals or the generation of significant energy which could alter the state of the rubber. As such, other than vehicle traffic and minor quantities of fuels used to power the fixed and mobile plant, no sources of offensive odour have been identified.
This aspect is monitored through routine inspections.
The ground surface at this site is primarily sealed in the yard with areas of hardstand around the fixed plant, the weighbridge and the driveway. The risk of the local community being adversely affected by dust generated on site to the level of disrupting normal activities, is low due to management of site and proximity to sensitive receptors. This aspect is monitored through routine inspections.
WATER
Surface Water: Surface water on this site is captured through the storm water drainage system. The site drains are designed to maintain capture of liquids due to the previous site owner (Caltex) sealing the drainage channels. In the unlikely event that localised waste containment measures have failed and traces of prescribed industrial waste are in contained in surface water, this water passes through an isolation valve prior to site discharge to ensure environmental compliance. No surface water complaints to this date have been received from the local community.
Process Water: There is water used within the tyre recycling process as a method of cooling down the plant and the products and therefore reducing the risk of ignition or combustion. This water is collected and reused back through the plant. The indoor shredding plant is contained within a concrete bund.
Truck Wash Water: Tyrecycle operate a small fleet of heavy rigid cage trucks for the purpose of tyre collection. To mitigate the possibility of contaminants entering the storm/surface/ground water system, these trucks are washed by a contractor who captures and takes away all wash water.
Fire Wash Water: The risk of fire is addressed comprehensively throughout the integrated HSEQ Management System with a significant focus on prevention and preparation. In the unlikely event of a fire event occurring, the environmental aspect is the potential release of fire water that may be contaminated with the elements of tyres that have been burnt. Any contaminated fire water contained on site would also be removed as quickly as possible by using a licensed waste water removal contractor, as per the standing agreement in place.
Other control measures are also available such as separation techniques of single burning tyres and removing oxygen by smothering with dirt in the event of discovering a single tyre on fire. This would result in the avoidance of using water at all and therefore in producing contaminated water.
WASTE
As a recycler, our business model is such that the disposal of waste is the least preferred option in the waste hierarchy. To achieve this, most of what is considered as waste to others, is considered as feed stock to us. This site adheres to a Stock Management Plan (below) for the allocation of tyres and shred as these are considered our primary stock. In addition to the whole of site kerb/bunding containment system, these items are locally managed. Wastes generated from our processes have been considered in the site Aspect and Impact Register. This identifies control measures and any specific monitoring requirements that have been put in place based on the level of risk identified. This includes the containment under normal operating conditions; and the contingency plans that will occur in the event of an environmental incident.
In Western Australia, whole tyres and any tyre pieces are considered to be a controlled waste. Tyres are stored at this site in limited size piles and with separation distances between piles and the boundary fences to ensure that access is provided for emergency services and to limit any potential fire events to one section, not the entire site. Tyres outside are maintained in 60m2 x 3.7m piles and groups of 4 tyre piles are separated by 18m. Tyres inside are maintained in 30m2 x 3.7m piles and groups of 4 tyre piles are separated by 3m. Shred piles are 20m x 5m x 3m.
