147623010 014 R Rev0 Nutrient EMP - Orica

29 September 2014

Orica Kooragang Island Environmental Management Plan - Nutrient

REP

OR

T

Report Number. 147623010-014-Rev0

Distribution:

Orica - 1 Copy Golder - 1 File Copy

Submitted to:Sherree Woodroffe Environment and Community Manager Kooragang Island Orica Australia Pty Ltd

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29 September 2014 Report No. 147623010-014-Rev0 i

Table of Contents

1.0 INTRODUCTION ........................................................................................................................................................ 3

1.1 Background .................................................................................................................................................. 3

1.2 EMP Objectives ............................................................................................................................................ 3

2.0 SITE SETTING ........................................................................................................................................................... 4

2.1 Site Description............................................................................................................................................. 4

2.2 Land Use ...................................................................................................................................................... 4

3.0 NUTRIENT CONTAMINATION .................................................................................................................................. 5

3.1 Sources of Contamination ............................................................................................................................ 5

3.2 Remediation/Prevention of Contamination ................................................................................................... 5

3.3 Identification of Contamination ..................................................................................................................... 5

3.3.1 Soil .......................................................................................................................................................... 5

3.3.1.1 Applicable Concentration Screening Criteria ....................................................................................... 6

3.3.2 Groundwater ........................................................................................................................................... 6

3.3.2.1 On-site ................................................................................................................................................. 6

3.3.2.2 Off-site ................................................................................................................................................. 6

3.3.2.3 Applicable Concentration Screening Criteria ....................................................................................... 6

3.3.3 Secondary Contaminant .......................................................................................................................... 6

3.4 Extent of Soil and Groundwater Contamination ............................................................................................ 7

4.0 MANAGEMENT OF INTRUSIVE WORKS ................................................................................................................ 8

4.1 Introduction ................................................................................................................................................... 8

4.2 Potential Exposure Pathways ....................................................................................................................... 8

4.3 Intrusive Excavations .................................................................................................................................... 8

4.3.1 Earthworks .............................................................................................................................................. 9

4.3.2 Disposal of Excess Spoil ......................................................................................................................... 9

4.4 Handling and Disposal of Groundwater ........................................................................................................ 9

4.5 Below Ground Infrastructure ....................................................................................................................... 10

5.0 CONTINGENCY ....................................................................................................................................................... 11

6.0 EMP IMPLEMENTATION ........................................................................................................................................ 12

6.1 Responsibility of Implementation of the EMP ............................................................................................. 12

6.1.1 Orica’s Responsibilities ......................................................................................................................... 12

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29 September 2014 Report No. 147623010-014-Rev0 ii

6.1.2 Stakeholders Responsibility .................................................................................................................. 12

6.2 Document Control ....................................................................................................................................... 12

6.3 Stakeholders to Undertake Own Investigations .......................................................................................... 12

7.0 REFERENCES ......................................................................................................................................................... 14

8.0 LIMITATIONS .......................................................................................................................................................... 15

TABLES

Table 1: Emergency Contact Details. ................................................................................................................................ 11

Table 2: Orica Contact Details (Stakeholder) .................................................................................................................... 12

APPENDICES

APPENDIX A Figures

APPENDIX B Limitations

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29 September 2014 Report No. 147623010-014-Rev0 3

1.0 INTRODUCTION Golder Associates Pty Ltd (Golder) was commissioned by Orica Australia Pty Ltd (Orica) to develop an Environmental Management Plan (EMP) and provide a framework to minimise risks to either human health or the environment from potentially nutrient (ammonia, nitrate and nitrite) affected soil and groundwater (the “contamination”).

The EMP is applicable to the entire Orica Kooragang Island Facility located at 15 Greenleaf Road, Kooragang Island, New South Wales (NSW) (the ‘site’) and adjacent lands not owned by Orica (Figure 1, Appendix A) and addresses issues relating to Orica related nutrient contamination only.

The scope of the EMP does not include the operation and management of the Orica facility or adjacent land. Given the historical and current site activities (Section 1.1), it is anticipated that well-established procedures (e.g. emergency response plan and safe work statements) are available at the site to prevent potential risks to human health/safety and the environment associated with nutrient production or handling. It is also anticipated that the Orica work force at the site are familiar with the risks associated with ammonia, nitrate and ammonium nitrate. However, the same level of understanding may not be present for the work force on adjacent land.

This EMP does not address related chemicals of concern that may be present at adjacent lands not owned by Orica.

1.1 Background The site commenced production of ammonium nitrate for the purpose of fertiliser manufacture in 1969 and is currently owned by Orica for manufacturing of ammonia, nitric acid and ammonium nitrate.

Contamination identified on the site is being addressed under the Contaminated Land Management Act (1997) in association with the NSW Environment Protection Authority (EPA). Recently, a Management Order (MO) (Number 20131408, dated 29 April 2014, herein referred as “MO”) was issued to the site, in which an EMP is required to be developed such that the risks presented by nutrient contamination to off-site receptors can be addressed.

To meet Orica’s obligations under the MO, this EMP has been prepared based on the current understanding of the nature and extent of nutrient contamination at on- and off-site areas. Noting that the extent of the nutrient contamination has not yet been fully assessed, the EMP should be revised (as appropriate) with the progression of the contamination delineation and groundwater monitoring programs required under the MO.

1.2 EMP Objectives The objectives of the EMP are to:

Meet Orica’s obligations under the MO;

Provide information on the nature and extent of identified contamination;

Identify the need for procedures to minimise exposure of workers to the contamination during intrusive works in the affected area;

Identify the need for the excavation of spoil and the extraction of groundwater to be minimised, and the requirement for spoil and groundwater to be reinstated or managed/disposed of appropriately;

Provide contact details for use in the event of any off-site environmental incident arising from nutrient contamination; and

Detail the framework for document control of the EMP.

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2.0 SITE SETTING

2.1 Site Description Kooragang Island was originally a series of smaller islands which formed part of the Hunter River Delta. The southern portion of Kooragang Island was subsequently reclaimed1 in the late 1950s and early 1960s from the original landform of a series of tidal mud flats using dredged sand from the Hunter River.

The Orica site is located on the southern end of Kooragang Island, near the confluence of the Northern and Southern Arms of the Hunter River. The adjacent lands potentially affected by the nutrient impacted soils and groundwater include:

To the west: Heron Road and Port of Newcastle (PoN) facilities including Kooragang Berths No.2 and No.3. The two berths are used for port-related bulk goods handling activities.

To the northwest: Hydro Aluminium owned facility. The land was used for storage of bulk materials used in the aluminium smelting industry and has now been closed.

To the north: Incitec Pivot Limited (IPL) site, which is operated as a fertiliser storage and distribution facility.

To the east: Greenleaf Road and followed by a grassed foreshore area. This land is managed by PoN.

To the south: A warehouse followed by Heron Road and the Walsh Point Reserve. The warehouse is operated by Patricks and used for the storage of bulk goods including fertilisers.

Locations of the site and the adjacent land are presented in Figure 1 within Appendix A.

2.2 Land Use Kooragang Island is currently used for industrial purposes. Based on the Zoning ‘Special Activities’ under the Major Development State Environmental Planning Policy (Major Projects) Amendment Three Ports (2009), the existing industrial land uses and the industrial ports facility, it is considered likely that Kooragang Island, including the portion of land covered by this EMP, will continue to be used for industrial purposes for the foreseeable future.

1 Based on review of available historical aerial photographs.

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3.0 NUTRIENT CONTAMINATION

3.1 Sources of Contamination The site commenced production of ammonium nitrate in 1969 and currently operates with one ammonia plant, three nitric acid plants and two ammonium nitrate plants. It is considered that the nutrient contamination at the site has resulted from historical waste disposal practices, spillages and leaks associated with the production, storage and/or use of nitrogen based compounds.

In addition to the on-site contamination, investigations to date have found elevated nutrient concentrations in soil and/or groundwater within the facilities to the west (associated with the migration of on-site groundwater).

3.2 Remediation/Prevention of Contamination Activities have been undertaken to prevent contaminations at the site. These activities included:

Elimination of the discharge of ammonia storage tank scrubber effluent to the environment (discharge of scrubber effluent to the subsurface was ceased in February 2005);

Bunding of ammonium nitrate storage tanks, sealing of areas where ammonium nitrate could be deposited and collection of stormwater to the recovery systems or effluent;

Cessation of the use of the former “Borrow Pit” (a general disposal ground for waste materials) in 2000 and relining the nitrate effluent pond in 2009;

Improvements to the integrity of the effluent system and in-ground process lines associated with the ammonia plant and nitric acid plants; and

Additional source control works required within the Environment Protection Licence (EPL, No.828) issued for the site.

3.3 Identification of Contamination A series of investigations have been undertaken since 1998. The investigations included assessment of soil and/or groundwater collected from beneath, around and/or down-gradient of (potential) nutrient sources (e.g. ammonia storage tank scrubber discharge area) and general site areas. The assessments have identified that there are areas on the Orica Kooragang Island site that have elevated levels of nutrient (ammonia, nitrite and nitrate) in both soil and groundwater. There have also been elevated levels of nutrient identified offsite to the west of the ammonia storage tank scrubber discharge area.

Indicative areas affected by nutrient contamination (based on groundwater data) are detailed in Figure 2, within Appendix A.

As a result of nutrient contamination at the Orica Kooragang Island site there is potential to encounter nutrient in soil and groundwater at land downgradient of the site. Further delineation of nutrient contamination both on and offsite is required by the MO.

3.3.1 Soil Only limited (and aged) data on nutrient concentrations in soil are available at onsite locations. There is no current data available on nutrient concentrations in soil offsite.

The onsite soil sample analysis identified that:

The reported nitrite concentrations were low;

The reported ammonia concentrations in soils above the saturated zones were lower than 500 milligram per kilogram (mg/kg), whilst the highest ammonia concentration reported in soils within the saturated zones was 2500 mg/kg; and

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The reported nitrate concentrations in soils above the saturated zones were lower than 1200 mg/kg, whilst the highest nitrate concentration reported in soils within the saturated zones was 1600 mg/kg.

3.3.1.1 Applicable Concentration Screening Criteria There is currently no human-health or ecological based assessment criteria applicable within Australia for screening of ammonia, nitrate or nitrite concentration in soil.

3.3.2 Groundwater Groundwater data collected since 2010 have showed elevated nutrient concentrations in on-site and off-site groundwater and are summarised below.

3.3.2.1 On-site Targeted groundwater monitoring to assess nutrient concentrations at key locations onsite has been undertaken. In addition, there has been limited monitoring undertaken at general locations onsite. The onsite groundwater data indicated that:

Nitrite concentrations in groundwater were low (<5 milligram/litre (mg/L)) in shallow and deeper groundwater;

Ammonia and nitrate concentrations in shallow groundwater ranged from 0.01 to 4,000 mg/L and from 3 to 5000 mg/L, respectively;

Ammonia and nitrate concentrations in deeper groundwater ranged from 20 to 10,000 mg/L and from <0.01 to 9,000 mg/L, respectively;

Deeper groundwater generally had higher ammonia and nitrate concentrations than shallower groundwater; and

The highest ammonia and nitrate concentrations were generally reported in the southern portion of the site.

3.3.2.2 Off-site Off-site nutrient data for groundwater are limited to the facilities to the west of the Orica site. The reported ammonia and nitrate concentrations within port facilities to the west of the site varied from 15 to 120 mg/L and from 1 to 40 mg/L, respectively.

3.3.2.3 Applicable Concentration Screening Criteria There are currently no human-health based assessment criteria2 applicable within Australia for screening of ammonia, nitrate or nitrite concentration in groundwater.

The Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC & ARMCANZ, 2000) provides criterion for screening of ammonia concentration in groundwater for protection of 95% species in marine water in slightly disturbed ecosystems (0.91 mg/L). The ammonia concentrations reported in on-site and off-site groundwater samples generally exceeded this criterion.

3.3.3 Secondary Contaminant As a result of nutrient contamination from aqueous ammonia, ammonium nitrate or nitric acid there is potential for high or low pH to be encountered in the soil and groundwater either on or offsite, and as such, pH has been incorporated in the EMP.

2 Australian Drinking Water Guidelines (AHMRC, 2004) have trigger values for nutrients, but not considered appropriate within the EMP as the groundwater at the site or adjacent area is not used for drinking purpose.

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3.4 Extent of Soil and Groundwater Contamination A program of works is being undertaken by Orica to assess the extent of nutrient contamination both on and offsite. The EMP will be updated as required, when the results of these programs have been assessed

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4.0 MANAGEMENT OF INTRUSIVE WORKS

4.1 Introduction This section describes the process that should be considered prior to undertaking intrusive works.

As the nutrient concentrations have not been fully assessed, when performing intrusive works on- or off-site, it should be assumed that there is potential for encountering contaminated soil and/or groundwater. The presence of chemicals of concern (nutrient and pH) will need to be considered to enable appropriate management plans to be developed and implemented such that potential exposure of personnel and the potential for the release of soil or groundwater to the environment can be minimised.

Depending on the scale of the proposed intrusive works, consideration should be given to undertaking appropriate testing of soil and/or groundwater prior to the commencement of works. This will allow modification of the proposed intrusive works to be considered, development of appropriate health, safety and environmental controls and/or preparation for the management/disposal of soil and/or groundwater.

4.2 Potential Exposure Pathways Workers involved in disturbing soil or groundwater, if contaminated, could be exposed to the chemicals of concern (nutrient and pH) by:

Ingestion of soil or groundwater through poor hygiene practices (i.e. eating or drinking during work activities, not washing hands before eating, etc.);

Direct contact through the skin (i.e. by handling the soil or groundwater without the appropriate personal protective equipment (PPE));

Inhalation of dust generated from the soil (either during excavation, or subsequent storage or handling); and

Inhalation of aerosols from groundwater spray, such as irrigation of extracted groundwater.

Planning and review of intrusive works involving exposure and/or disturbance of soil or groundwater, and implementation of appropriate health and safety measures, will minimise the potential for worker contact with nutrient contaminated materials through the above listed exposure pathways.

4.3 Intrusive Excavations Prior to exposing and/or disturbing soils and/or groundwater by intrusive excavation works, the following activities should be carried out and implemented:

If not on the Orica facility, notify Orica to discuss the scope of works to be undertaken, how spoil and/or water is to be managed and the likelihood of generating excess spoil or water;

Assess proposed works to ensure that measures are considered and implemented to minimise the requirement to expose and/or excavate potentially contaminated materials;

Ensure contractors/workers are aware of the potential for contaminated materials to be encountered;

Preparation of a specific health and safety plan for the proposed activities/works to minimise potential exposure, including procedures, the provision of PPE, site services etc;

Consideration of equipment used to minimise potential exposure, both in terms of minimising the disturbance of potentially contaminated soil or groundwater as well as minimising potential exposure to workers;

Preparation of a specific environmental protection plan including soil and water management protocols;

Preparation of a methodology for managing excavated soil and extracted groundwater; and

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Contingency planning (Section 5.0) to include encountering significantly higher or unexpected concentrations of nutrient.

4.3.1 Earthworks During excavation works, care should be taken to separate the soil materials that are suspected to be contaminated from potentially uncontaminated soils that are deemed to be appropriate for reuse. It is expected that soils excavated from above groundwater levels will generally have low nutrient concentrations and are likely to be suitable for reuse, unless unrelated contamination has occurred. In addition, care should be taken (and considered as part of the handling procedures associated with intrusive works) to minimise any dust generation.

Excess spoil generated from intrusive works that cannot be appropriately reinstated within the original excavation area or are considered unsuitable for reuse, should be assessed for off-site disposal (as described in Section 4.3.2). The responsibility for the assessment and disposal of such material remains with the site owner.

4.3.2 Disposal of Excess Spoil Spoil that is not returned to the original excavation, or is suspected of being contaminated, must be appropriately managed.

This may entail assessment and classification prior to off-site disposal to a licensed landfill facility. If material is to be disposed to landfill, the assessment and classification and subsequent disposal must be in accordance with the applicable NSW Department of Environment, Climate Change and Water (DECCW, now EPA) waste regulations and the “Waste Classification Guidelines. Part 1: Classifying Waste” (DECCW, December 2009). This may involve analytical testing for compounds other than nutrient, and discussion with the Waste Management Section of the NSW EPA and/or licenced landfill facility operators to ensure the waste is disposed appropriately.

Provisions for temporary storage of the excess spoil in an environmentally responsible manner prior to disposal must be undertaken. This should include measures such as:

Placement of material away from drainage lines, watercourses or stormwater drains;

Construction of sediment retention features around stockpiled materials;

Covering of stockpiled materials; and

Dust suppression.

4.4 Handling and Disposal of Groundwater In general, based on the geology, if excavation works are required to be undertaken at depths below the groundwater table then it is possible that dewatering will be required. However, because of the requirement to dewater, associated shoring and approval processes, the general engineering approaches adopted for works would aim to avoid or minimise the requirement for dewatering, regardless of the presence of contamination. With the presence of nutrient contaminated groundwater, it is highly recommended that engineering approaches for proposed works should minimise or avoid the requirement to dewater wherever possible.

If groundwater is required to be extracted, the groundwater should be stored and managed in appropriate temporary storage facilities to allow the water to be assessed and classified prior to disposal. Extracted groundwater may require treatment and disposal via a trade waste agreement and/or disposal to a licenced facility. It is noted that this would be required irrespective of the presence of nutrients.

Dependent on the assessment of the water quality, the water may be able to be reused beneficially on-site. Although extraction of groundwater specifically for beneficial use is unlikely given the hydrogeological setting and general water quality (e.g. elevated total dissolved solids), and no previous precedence of groundwater

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extraction for beneficial use, consideration and/or assessment should be given to minimise potential exposure pathways.

It is noted that dewatering activities and any planned irrigation or reuse, regardless of the presence or not of contamination, may require regulatory approval.

4.5 Below Ground Infrastructure Planning and design of developments with below ground infrastructure should consider potential effects on groundwater flow which may change the migration of nutrient in groundwater within the area where infrastructure to be installed. For example, infrastructure below the groundwater table may act as preferential pathways along which nutrient contamination may be able to migrate. Each specific proposed development with infrastructure below the groundwater table should be considered with respect to the most current groundwater flow conditions available upon specific request from Orica.

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5.0 CONTINGENCY In the event of any off-site environmental incident arising from nutrient contamination within the potentially affected area, relevant field personnel should make effort to contact Orica (and/or emergency authorities when required under Part 5.7 of the Protection of the Environment Operations Act 1997) for advice.

Table 1: Emergency Contact Details.

Name / Title Organisation Telephone

Environment and Community Manager

Orica Australia Pty Ltd 4908 9300

Environment Lead Orica Australia Pty Ltd 4908 9300

Environment Line Environment Protection Authority 131 555

Port-wide Emergency Reporting Line

Port of Newcastle 4929 3890

WorkCover^ 131 050

Fire and Rescue NSW^ 000 or 1300 729 579

Newcastle City Council^ 4974 2000

Hunter New England Local Health District^

4924 6477

Note: ^ Notification of these agencies is only required in the event that notification in accordance with Part 5.7 of the Protection of the Environment Operations Act 1997

Personnel should also be made aware of their duty to notify pollution incidents under Part 5.7 of the Protection of the Environment Operations Act 1997.

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6.0 EMP IMPLEMENTATION

6.1 Responsibility of Implementation of the EMP 6.1.1 Orica’s Responsibilities Orica will be responsible for providing this EMP and associated information to all affected Stakeholders. On Orica’s land, Orica is responsible for implementing the requirements of the EMP.

Orica will also assist Stakeholders to implement the requirements of the EMP on their land, to the extent practicable. This may include the provision of information required to assist with planning of proposed development or intrusive works, to the extent that the development/activity will affect the contamination.

Orica will also periodically update Stakeholders on:

Changes to the status of the contamination present beneath Stakeholders land; and

Changes to the EMP.

6.1.2 Stakeholders Responsibility Individual Stakeholders are responsible for the implementation of the EMP on their own sites. The Stakeholders are also responsible for informing Orica of any development or activity where that development or activity has the potential to affect or be affected by the contamination as explained in this EMP.

Contact details for Orica are provided in Table 2 below.

Table 2: Orica Contact Details (Stakeholder)

Name / Title Organisation Telephone

Environment and Community Manager Orica Australia Pty Ltd 4908 9300

Environment Lead Orica Australia Pty Ltd 4908 9300

6.2 Document Control The EMP will be a Controlled Document and management of the document will be undertaken within the Orica Kooragang Island document management system. The document management system is an electronic system that provides an individual document number for the document, has revision management and has a process for reminders to review the document.

The EMP will be updated as required periodically based on the understanding of the contamination at that time. It is envisaged that the EMP will be revised (as appropriate) with the progression of the contamination delineation and groundwater monitoring programs required under the MO.

All Stakeholders will be advised on a two yearly basis, in the form of a letter, of the following:

The requirement for the Stakeholder to implement the EMP;

Changes to the EMP (this may include reissuing a revision of the EMP as appropriate);

Changes to the contamination from either monitoring or investigation works undertaken; or

Remedial/management activities undertaken.

6.3 Stakeholders to Undertake Own Investigations The information in this document is provided for general information only and it may or may not be applicable to a particular set of circumstances. Orica makes no warranty or representation about:

The accuracy or completeness of any information in this document;

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The nature or extent of contamination; and

The appropriateness of any proposed activity or development or any procedures or recommendations in this document.

Stakeholders should not rely on this document and should undertake their own investigations and obtain their own independent advice.

Information in this document is based on the current state of knowledge of the contamination and the regulatory environment as at the date of this document. Orica accepts no responsibility for changes over time.

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7.0 REFERENCES ANZECC & ARMCANZ (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality.

DECCW (December 2009) Waste Classification Guidelines. Part 1: Classifying Waste.

www.legislation.nsw.gov.au/mapindex?type=epi&year=2005&no=194#3PT. Major Development State Environmental Planning Policy (Major Projects) Amendment Three Ports (2009). Accessed on 20 September 2014.

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8.0 LIMITATIONS This document is subject to the limitations stated in Appendix B.

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29 September 2014 Report No. 147623010-014-Rev0

Report Signature Page

GOLDER ASSOCIATES PTY LTD

Ke Ye Andrew Holloway Environmental Scientist Principal Environmental Scientist

KY/AH/ky

A.B.N. 64 006 107 857

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

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APPENDIX A Figures

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ORICA KOORAGANG ISLAND

SITE LOCATION

SCALE (at A4)Coordinate System: GDA 1994 MGA Zone 56

NOTESSite boundary is approximate.

COPYRIGHT

FIGURE 1STOCKTON

HAMILTONNEWCASTLE

KOORAGANG

1:12,500

0 100 200 300 40050 metres

File Location:

147623010

KY

24/09/2014FA

LEGEND

Orica Kooragang Island FacilityIncitec Pivot LimitedHydro AluminiumPort of NewcastleToll Holdings (Lease)

PROJECT:

CHECKED:

DATE:DRAWN:

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Aerial Photography Copyright - Service LayerCredits: © 2014 DigitalGlobe © 2014 GeoEyeEarthstar Geographics SIO © 2014 MicrosoftCorporation © AND © 2014 MapData Sciences PtyLtd, PSMABase map data copyright MapInfo Australia Pty Ltd

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EMP - NUTRIENTORICA KOORAGANG ISLAND

INDICATIVE AREAS AFFECTED BY NUTRIENTS

SCALE (at A3)Coordinate System: GDA 1994 MGA Zone 56

NOTESBuilding footprint (CAD_MGA56.DWG) provided by client.

COPYRIGHT1. Aerial Photography Copyright NearMap Pty Ltd. Image dated 2013.07.05 and sourced on 2013.07.17. Image intended for indicative purposes only. More information can be found here: http://www.nearmap.com/2. Base map data copyright MapInfo Australia Pty Ltd

FIGURE 2

WICKHAM

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MARYVILLE PORT HUNTERTIGHES HILL

HUNTER RIVER

1:4,0000 50 100 150 20025 metres

File Location:

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KY

26/09/2014FA

LEGENDOrica Kooragang Island FacilityIndicative Areas Affected by Nutrients (based on available groundwater data)Downgradient Areas for Implementation ofthe EMP (no groundwater data available)

PROJECT:

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APPENDIX B Limitations

LIMITATIONS

This Document has been provided by Golder Associates Pty Ltd (“Golder”) subject to the following limitations: This Document has been prepared for the particular purpose outlined in Golder’s proposal and no responsibility is accepted for the use of this Document, in whole or in part, in other contexts or for any other purpose. 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 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. 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 Document. Accordingly, additional studies and actions may be required. In addition, it is recognised that the passage of time affects the information and assessment provided in this Document. Golder’s opinions are based upon information that existed at the time of the production of the Document. It is understood that 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. Any assessments made in this 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 Document. 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. Golder may have retained subconsultants affiliated with Golder to provide Services for the benefit of Golder. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have any direct legal recourse to, and waives any claim, demand, or cause of action against, Golder’s affiliated companies, and their employees, officers and directors. This Document is provided for sole use by the Client and is confidential to it and its professional advisers. No responsibility whatsoever for the contents of this Document will be accepted to any person other than the Client. Any use which a third party makes of this 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 Document.

GOLDER ASSOCIATES PTY LTD GAP Form No. LEG 04 RL 1

Golder Associates Pty Ltd

124 Pacific Highway

St. Leonards, New South Wales 2065

Australia

T: +61 2 9478 3900

147623010 014 R Rev0 Nutrient EMP - Orica

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