Monitoring

Once environmental performance objectives and indicators, and risk control performance objectives have been set, it is important to routinely check whether your controls are performing to your established standards and meeting your targets.

The necessary data or observations to demonstrate this will be collected through implementation of an environmental monitoring program that specifies the frequency, location and type of checks required.

Operational controls and environmental monitoring

The type of monitoring you conduct depends on the specific risks posed by your activity. It may include:

• groundwater, surface water or stormwater sampling
• stack testing
• continuous emissions monitoring (CEM)
• dust monitoring
• odour checks
• noise, leachate or landfill gas monitoring
• any other type of monitoring such as event-based or periodic (daily, weekly, etc.)
• continuous real-time monitoring linked to a SCADA system (for example, water level or discharge monitoring).

Other data gathered as part of your routine checks may include:

• maintenance records
• consultant reports, site inspections, walk-throughs or other regular checks
• incident records and near misses
• complaints, community reports or any other type of feedback from affected communities and stakeholders
• assessment of pollution incidents
• benchmarking of performance during the development licence phase
• correspondence with external parties, for example, WorkSafe, EPA, local council.

You (or your consultants) should analyse the data and results from your monitoring program to identify any trends, patterns, noncompliance and areas for improvement. The quality of your data should also be checked to ensure they are representative of your activities. Your quality control checks might include:

• instrument calibration
• instrument maintenance and performance checks
• competence of personnel conducting the monitoring
• consistency of results obtained by different operators
• investigation of outlier results
• changes to equipment at the monitoring point.

EPA expects your monitoring activities to be linked to your risk control performance objectives and be relevant to your environmental performance objectives. Details of your monitoring program must be included in your RMMP.

Refer to Appendix C for an example of a monitoring plan and how it can be linked to performance objectives.

Trigger action response

As part of your monitoring (particularly where you are monitoring any segment of the environment as defined in the Environment Reference Standard), your RMMP should include specific actions for when pre-defined conditions (‘triggers’) are met. This includes actions to:

• compare environmental monitoring data with guideline value or objective
• immediately respond when a trigger is exceeded
• escalate measures to manage the situation that has been triggered.

Depending on risk and complexity, it may be appropriate that triggers are established using a tiered approach to allow staged levels of response, for example:

• Tier 1 (green, alert trigger) for early indication of potential impact or an emerging issue
• Tier 2 (amber, action trigger) for indication of potential impact or moderate risk
• Tier 3 (red, impact trigger) for realised impact or unacceptable risk.

For simple monitoring procedures, a tiered approach may not be necessary.

Your RMMP should clearly illustrate your trigger action response in a summary table that is easy for EPA to find and review. This may be attached as an appendix to your RMMP or provided as listed references so that EPA may access it.

Further detail about trigger action responses and additional examples of how this information can be presented is provided in Appendix D.