Management of Contamination in the Proposed Development...

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;.

ENSR AECOM

Prepared for:

Sydney Harbour Foreshore Authority

PO Box N408Grosvenor PlaceSydney NSW 1220

Management of Contamination in theProposed Development of Callan Park

HLA-Envirosciences Pty Limited (HLA ENSR)

25 October 2007

Document No.: S4095301_RPTCalianPark_250ct07

II Me,ged, ",lin ENS>':

In 2007

ENSR l\

DISTRIBUTION

Management of Contamination in the Proposed Development of Callan Park

Callan Park, Rozelle, NSW

25 October 2007

Copies Recipient Copies Recipient

1 ecopy MrT Kennedy 1 HLA ENSR library1 unbound SHFAhard copy PO Box N40B

Grosvenor PlaceSydney NSW 1220

This document was prepared for the sole use of Sydney Harbour Foreshore Authority and the regulatory agenciesthat are directly involved in this project, the only intend,ed beneficiaries of our work. No other party should rely on theinformation contained herein Without the prior written consent of HLA-Envirosciences Pty Limited (HLA ENSR) andSydney Harbour Foreshore Authority.

By

HLA"Envirosciences Pty Limited (HLA ENSR)

ABN: 34060 204 702

Level 5, 828 Pacific Highway Gordon NSW 2072

PO Box 726 Pymble NSW 2073

Senior Principal

Technical Peer Reviewer: Date:

NSW/ Sydney Operations Manager

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CONTENTS

1.0 INTRODUCTION 1

1.1 Background 1

1.2 Contamination matters required to be addressed at the Master Plan stage .. 1

1.3 Reports referred to 2

2.0 PROPOSED DEVELOPMENT OF THE SITE 3

2.1 Potential development of the Site 3

2.2 Environmental criteria applicable to the development.. 3

2.2.1 Protection of human health 3

2.2.2 Protection of the environment 4

3.0 ASSESSMENT OF CONTAMINATION ON THE SiTE 5

3.1 Stage 1 assessment. 5

3.1.1 Objective 5

3.1.2 Scope of work 5

3.1.3 Potentially contaminating activities on the Site 5

3.1.4 Potential constraints posed by contamination 5

3.2 Stage 2 assessment 8.

3.2.1 Objectives 8

3.2.2 Scope of work 8

3.2.3 Suitability of sampling locations 9

3.2.4 Suitability of field methods 10

3.2.5 Suitability of chemicals of potential concern 10

3.2.6 Suitability of laboratory methods 12

3.3 Results of investigation 12

3.3.1 Development Areas 12

3.3.2 Non-Development Areas 12

4.0 EES REPORT 15

4.1 Purpose of the EES report 15

4.2 Objective 15

4.3 Key environmental issues 15

4.4 Remedial options for fill materials 16

5.0 CONCLUSION 19

5.1 Preliminary investigation 19

5.2 Requirement for additional assessment 19

5.2.1 Environmental assessment.. 19

5.2.2 Hazardous materials survey : 19

5.3 Management of contamination issues 20

5.3.1 Fill materials 20

5.3.2 Groundwater 20

5.3.3 Underground storage tanks 20

5.3.4 Buildings 20

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5.4 Management of the Site 21

Appendices

Appendix A : Figures from Coffey Report

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1.0 Introduction

1.1 Background

HLA ENSR was engaged by the Sydney Harbour Foreshore Authority ("SHFA") to provide advicereiating to the management of contamination of soil and groundwater at the Callan Park Hospital site(the "Site"), situated at Rozelle. The advice was required as part of the master planning process that isbeing undertaken as part of the development proposal in accordance with the Callan Park Act (SpecialProvisions) 2002.

The advice is based on reports relating to the assessment of contamination on the Site reported byCoffey Geosciences Pty Ltd ("Coffey") in 2000 and 2002 on behalf of the NSW Health Department aspart of the preparation of a Master Plan for the redevelopment proposed for the Site at that time.Subsequently, in 2002 Environmental & Earth Sciences ("EES") assessed the significance ofcontamination identified on the Site by review of the Coffey reports for Landcom, who at that time wereconsidering developing the Site.

In June 2007. the Minister for Planning, Sydney Harbour Foreshore Authority and the University ofSydney entered into a non-binding Memorandum of Understanding that "...seeks to exploreopportunities to grant a 99 year lease to the University of Sydney to develop a coherent campusenvironment ...for use for higher education purposes".

It is understood that the proposed Master Plan applies to the whole of the Site, which is described tohave an area of 61 ha within the area generally bounded by Glover Street, Balmain Road, ManningStreet and Iron Cove, as shown in Figure 1 (Appendix A).

The Master Plan will comply with the requirements of State Environmental Planning Policy No. 56(SEPP 56) "Sydney Harbour Foreshores and Tributaries" that requires, amongst other things, anexplanation of and a proposal for "remediation of the site". In the context of SEPP 56, "remediation"relates to the processes of identification of nature and extent of contamination on the Site andsubsequent remedial works that are undertaken to ensure protection of (i) the health of users of the siteand (ii) the environment.

In 2002, the author of this report (Dr Bill Ryall), then employed by Contamination Management PtyLimited, provided advice to Leichhardt Council relating to the management of contamination at the Siteas identified in the Master Plan prepared at that time. The proposed Master Plan principles allow fordifferent development options for the Site. Proposed options will have significant impacts for themanagement of the contamination at the Site and although extent of contamination remains to bequantified, it is considered that contamination issues can be addressed during the development of theSite.

1.2 Contamination matters required to be addressed at the Master Planstage

For the purposes of master planning, contamination issues that have potential to significantly impact onthe proposed development are required to be identified and their impact assessed. These issues relateto contamination that (i) could prevent the redevelopment being undertaken andlor (ii) could result inmajor impact on the redevelopment program in terms of necessary remedial works giving rise to:

• Unacceptable environmental impacts resulting, for example, if significant remediationwas required adjacent to sensitive waterways or if large volumes of volatilecompounds were required to be remediated;

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• Unacceptable social impacts resulting, for example, from excessive generation ofnoise, dust, vibration, vehicle movements and excavation of large quantities ofasbestos containing materials and the like; and

• Time and cost escalations caused by the identification of unexpected majorcontamination.

However, at the master planning stage, it is not required that contamination be quantified according toguidelines endorsed by NSW EPA (part of the Department of Environment and Climate Change(DECC)). Detailed environmental assessment and quantification of contamination are generallyundertaken at a later time, commonly prior to seeking specific development consent or as a condition ofa specific development consent.

1.3 Reports referred to

In preparing this advice, the following reports provided by SHFA have been referred to:

• "Rozelle Hospital, Stage 1 Preliminary Geotechnical and Contamination Study.Issues Paper on Geotechnical & Environmental Constraints" by Coffey dated 30August 2000;

• "Rozelle Hospital, Preliminary Contamination Assessment," by Coffey dated 14March 2002; and

• "Review of contamination and geotechnical conditions at Rozelle hospital site" byEES dated 29 August 2002.

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2.0 Proposed development of the Site

2.1 p'otential development of the Site

Coffey considered the environmental condition of the Site in terms of:

• "Development Areas". which comprised the land in the south-western part of the Siteused by non-government organisations and the NSW Ambulance Service and whichhas frontages to Balmain Road. Wharf Road and Glover Street and which wereproposed at that time to be developed for residential use; and

• "Non-Development Area", which comprised the remainder of the Site (excluding theCollege of Arts), which was proposed for development for public open space use.

It is understood that the development considered by Coffey is no longer proposed and that the final usesfor the Site have not been concluded. However, for the purpose of this advice, the following has beenassumed:

• Similar activities as are currently undertaken will continue to be undertaken on theCollege of Arts precinct;

• The Development Areas will continue to be used for purposes similar to the current;and

• The Non-Development Area will continue to be used as playing fields and for openspace purposes.

It is understood that some 47 ha of the Site would be devoted to open space uses and that thedevelopment may also include land to be used for residential purposes for staff or students, but that thisuse for this purpose or the locations have not been confirmed.

2.2 Environmental criteria applicable to the development

2.2.1 Protection of human health

With respect to the protection of health of occupiers and users of land, NSW DEC (2006) Guidelines forthe NSW Site Auditor Scheme (2"d Edition) endorses health-based investigation levels (HILs) for anumber of land use scenarios for commonly encountered chemicals of potential concern. If the HILs areexceeded, additional investigation is required to be undertaken to determine if an unacceptable risk isposed to the health of occupiers or users. If the risk is considered to be unacceptable, remediation ormanagement of the contamination is required.

It is noted that the assessment undertaken by Coffey in 2002 referred results of chemical testing of soilto HIL A levels, which apply to the most sensitive use of land for (i) residential purposes where occupiershave access to the soil and consume home-grown vegetables and fruit and (ii) for use of land for childday-care centres, preschools and primary schools. These criteria were for the previous Master Plan andare much more sensitive than are required for the uses of the Site proposed in the current Master Plan.The consequence of this is that Coffey identified "contamination" which need not be addressed for theuses of the Site currently proposed. For example, Coffey identified contamination in the DevelopmentAreas that would not be suitable for land used for residential purposes, as proposed at the time, but thatwould now be acceptable for the current proposed of the land by non-government organisations or bythe University.

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With respect to the current Master Ptan, the relevant environmental criteria for parts of the Site are asfollows:

• College of Arts and the Development Area - reference to HIL F levels is appropriate.These levels for most chemicals of potential concern are five times less sensitivethan the HIL A levels;

• Playing fields and open space purposes - reference to HIL E levels is appropriate.These levels for most chemicals of potential concern are two times less sensitivethan the HIL A levels; and

• Parts of the Site that may be developed for accommodation purposes - reference toHIL D levels may be appropriate if occupiers have minimal access to the soil. Theselevels for most chemicals of potential concern are four times less sensitive than theHIL A levels.

Environmental criteria for petroleum hydrocarbons have been set by NSW EPA at 65 mg/kg for lightpetroleum hydrocarbons and 1000 mg/kg for medium and heavy petroleum hydrocarbons, although it isnoted that NSW DEC (2006) Guidelines for the NSW Site Auditor Scheme (2"" Edition) endorses muchhigher levels for medium and heavy petroleum hydrocarbons if speciation into aromatic and aliphaticfractions is reported by the laboratory.

2.2.2 Protection of the environment

With respect to the protection of the environment, NSW EPA (2006) Guidelines for the NSW Site AuditorScheme (2"" Edition) endorses guidelines to protect the healthy growth of plants, termedphytotoxicological investigation levels.

With respect to protection of groundwater and receiving waters, NSW EPA has endorsed so-called"trigger levels" listed in ANZECC/ARMCANZ (2000) Australian and New Zealand Guidelines for Freshand Marine Water Quality.

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3.0 Assessment of contamination on the Site

3.1 Stage 1 assessment

3.1.1 Objective

The objective of the Stage 1 assessment undertaken by Coffey was stated "...to prepare an issuespaper identifying primary constraints imposed by site geotechnical and potential contaminationconditions".

3.1.2 Scope of work

The following scope of work was undertaken by Coffey to achieve the objective:

• a review of existing information relating to the Site;

• a limited inspection of the Site;

• a review of historical aerial photographs to observe the development of the Site andthe surrounding area over the last 50 to 60 years;

• interviews with personnel who had long association with the Site;

• a review of records, if any, held by Leichhardt Council relating to contamination at theSite;

• assessment of potential risks that could present constraint to development of theSite;

• preparation of an issues papers discussing potential risks and their potential impacts;and

• recommendation of a scope of work for a second stage of investigation tocharacterise the risks identified.

3.1.3 Potentially contaminating activities on the Site

The Site was confirmed to have a complex history of industrial uses that extended over a period of some150 years. In addition to its principal use as a hospital, ancillary activities carried out on the Site includedoperation of boilers, vanous types of workshops, storage of dangerous goods such as fuel andpesticides, bowling greens, a golf course and disposal of waste into landfills on the Site. At least onepart of the Site was identified as having been a quarry that was at some later time filled with wastematerials and which could be classified as a landfill.

Coffey summarised the results of the investigation in Table 2 of their report and referred to the mostsignificant potential contamination identified on the Hospital site as "Primary potential contaminationconstraints", which are discussed below.

3.1.4 Potential constraints posed by contamination

Uncontrolled filling

Uncontrolled filling was identified in "major" areas in four parts of the Site, as identified on Coffey'sFigure 2 (in Appendix A). However, as discussed below, fill materials were identified on all parts of theSite investigated by Coffey and had been placed over the natural soil and bedrock to form the presentlevels across the Site.

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Potential contaminants likely to be present in the fill materials were identified as heavy metals (arsenic,cadmium, chromium, copper, lead, mercury, nickel and zinc), petroleum hydrocarbons, polycyclicaromatic hydrocarbons (PAHs), organochlorine pesticides (OCPs), polychlorinated biphenyls (PCBs),cyanide and asbestos.

Coffey noted that the risk of contamination being present in the filled areas was "high" and that ..... if thefilled areas are contaminated, substantial soil remediation would be required".

Boiler ash distribution

Coffey identified distribution of boiler ash in gardens and lawns across the Site as a potential majorconstraint to development of the Site and identified the risk of contamination from this material as "high".Potential contaminants in the ash were stated to be heavy metals, petroleum hydrocarbons and PAHs,the latter commonly being the most serious because of the presence of carcinogenic tar-like compoundsthat arise from the incomplete combustion of coal used to fire boilers.

With respect to ash, Coffey noted that ..... remediation of contaminated soil in affected areas" would berequired.

Other contamination issues

Other potential contamination sources were identified by Coffey, but these were concluded to presentlesser potential constraints to redevelopment of the Site compared with those listed above. The mostsignificant of the other contamination issues identified by Coffey are discussed below.

Underground fuel tanks

Coffey noted that four underground fuel storage tanks were identified on the Site and that the risk ofcontamination caused by leakage of fuel was considered to be "high".

Coffey also noted the possibility that undiscovered underground tanks might be present on the Site. Thepresence of undiscovered tanks is always a high possibility on industrial sites that have operated for along period of time when records and personnel familiar with operation of the site are no longeravailable.

Heavy metals and asbestos around buildings

Coffey noted that lead from paint peeling from buildings, zinc leaching from galvanised ironsheds/buildings/roofs and asbestos from weathering of asbestos cement building materials presented a"medium to high" risk of contamination on the Site, but that the contamination derived from thesesources would be localised around buildings and would not present a significant constraint todevelopment.

However, the materials, and in particular asbestos fibres from weathering of roofs, gutters anddownpipes can enter stormwater and natural drainage lines and can be distributed far from the sourcebuilding/s. As discussed below, it is likely that asbestos would have been used for other purposes on theSite and a more comprehensive program to assess the presence of this material on the Site will berequired to be undertaken. In addition, documentation of any asbestos removal programs and the fate ofthe asbestos materials are required to be documented as early as possible in the investigation of theenvironmental condition of the Site.

Weed and insect control

Coffey noted that there was a "medium" risk of contamination from applications of chemicals to bowlinggreens, golf course greens, lawns and gardens, the nursery and the south-east corner .of the Site, which

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was formerly cultivated (Figure 2). The chemicals of potential concern in these areas were listed asheavy metals, OCPs and herbicides.

Coffey concluded that contamination from the application and storage of pesticides and herbicides waslikely to be localised and that any contamination from these activities were not likely to present asignificant constraint to redevelopment of the Site. Whilst this conclusion may be valid, if wastepesticides or pesticide containers were disposed in the major filled parts of the Site, contamination ofgroundwater may have resulted. As discussed below, the assessment of groundwater quality andremediation of groundwater that is identified to be contaminated is a significant matter that is required tobe assessed.

Remainder of the site

Coffey also considered the "Remainder of the site", I.e. the bulk of the Site not addressed by the specificactivities listed above, had a "low to high" risk of contamination from unspecified chemicals of potentialconcern "due to the age of the site, the possibility of other potentially contaminating activities havingoccurred on the site cannot be ruled auf'. Coffey concluded that the presence of contamination fromthese unidentified sources was "not likely to present a significant constraint to redevelopment of thesite".

Opinion on potential contaminants

It is considered that Coffey's Stage 1 investigation identified most of the likely contamination issues thatcould impact on the development of the Site. However, it is considered that two important issues thathave potential to impact significantly on the redevelopment of the Site, being the presence of asbestosand the potential for groundwater contamination, were not addressed in appropriate detail, as discussedbelow.

Asbestos

Coffey's reports identified asbestos as a substance of concern on the Site as a weathering product fromasbestos cement roofs and other asbestos cement building materials, however, on other hospital siteswithin the Sydney region, it has been found that asbestos containing materials were commonly disposedin filled areas on these sites. The removal of asbestos from filling during development of these hospitalsites and other former industrial sites has presented major environmental and commercial issues duringdevelopment of these sites.

On such hospital sites within the Sydney region, asbestos has been identified as:

• bonded asbestos materials, which were commonly used as roofing and wallmaterials ("fibro"), pipes (gutters, down pipes and sub-surface pipes), floor tiles("Iino") and in electrical equipment (eg. power distribution boards); and

• friable asbestos, which was commonly used as lagging for insulating boilers, servicepipes and ducts. In addition, this substance was used as spray-on insulation withinbuildings.

The use of asbestos and asbestos containing materials on the Site and any programs in which asbestoscontaining materials were removed from buildings on the Site are required to be documented thoroughlyat the development application stage. It is also critical that that the fate of the asbestos waste bedocumented. Given the practices on other hospital sites, there is a high probability that these materialscould have been disposed on the Site, particularly since a number of areas of major filling have beenidentified.

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The presence of asbestos fibres in fill materials presents a major cost and time constraint in remediatingfilling containing this material because of the emotive nature of the community and other land usersresponse to asbestos and the hazardous nature of the fibres that may be liberated during buildingdemolition and earthworks programs.

However, the Coffey reports did not identify significant quantities of asbestos in fill materials intersectedin bores across the Site and no asbestos was identified in the ten samples of the fill materials from theDevelopment Area analysed by Coffey. Consequently, asbestos in fill materials may not present asignificant issue at the Site, however, this cannot be stated with any certainty at this time.

Groundwater contamination

It is highly likely that the several major filled areas on the Site could have impacted the quality ofgroundwater discharging into Iron Cove. The remediation of contaminated groundwater may present amajor constraint to development of these areas.

In addition, because the Site falls towards Iron Cove, contamination of groundwater discharging into IronCove could be a result of the presence of contaminants in fill materials in parts of the Hospital siteremote from Iron Cove. The requirement to remediate groundwater, therefore, may impact developmentof any contaminated partls of the Site that may be contributing contamination to groundwater. For thesereasons, it is considered that an appropriate level of investigation of the quality of groundwater shouldhave been undertaken by Coffey.

It is noted that Coffey recommended that investigation of groundwater contamination be undertaken inthe short term in a subsequent investigation on the Lower Glover Street Oval, but it is considered thatthe quality of groundwater in the filled areas adjacent to Iron Cove should have been subject to at least apreliminary assessment by Coffey. It is considered that this assessment can be undertaken at an earlystage during the development of the Site.

3.2 Stage 2 assessment

3.2.1 Objectives

The objectives of the second stage of assessment undertaken by Coffey were stated to:

• Further assess the primary constraints posed by contamination conditions within theDevelopment Areas by undertaking limited soil sampling and testing; and

• Make a preliminary assessment of the nature of contamination in the NonDevelopment Area by undertaking limited soil sampling and testing.

Opinion relating to objectives

It is considered that the scope of the Stage 2 assessment was inadequate given the number and natureof the potentially contaminating activities identified in the Stage 1 assessment and given theuncertainties that related to use of the site, particularly the disposal of waste, the disposal of ashcontaining carcinogenic PAHs, the probable use of asbestos and the high probability of groundwaterbeing contaminated.

3.2.2 Scope of work

Coffey undertook the following scope of work:

• Collection of samples of fill materials and soil from locations across the Site;

• Chemical analysis in a commercial laboratory for chemicals of potential concern; and

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• Assessment of the results of the field observations and chemical analyses.

Opinion relating to scope of work

It is considered that the scope of work for the second stage of assessment should have been expandedto assess the impact of asbestos and the quality of groundwater in the filled areas at the northernboundary of the site, adjacent to Iron Cove. As noted above, it was known from the Stage 1 investigationthat major filled areas were present in these areas (Figure 2, Appendix A) and that the filling had beenuncontrolled and was sourced from both on-site and off-site locations.

3.2.3 Suitability of sampling locations

The number of sampling locations adopted by Coffey to achieve the objective of determiningcontamination conditions in the four Development Area was as follows:

• Glover/Church Street Precinct (approximately 2 ha in area) - 2 bores and 1 handauger locations.

• Broughton Hall Precinct (approximately 1 ha in area) - 1 bore within the precinct and2 bores on the precinct boundary.

• Balmain Road Precinct (approximately 4 ha in area) - 1 bore and 1 hand augerlocations.

• Manning Street Precinct (approximately 1 ha in area) - no sampling locations.

Opinion relating to locations tested

Development Area

It is considered that the number of sampling locations was inadequate to allow the environmentalcondition of the Development Area to be assessed. It is obvious that it is not possible to arrive at anyreliable conclusions relating to contamination for the Manning Street Precinct where no samples werecollected.

In addition, the locations adopted in the investigation were not suitable for detecting the presence ofcontamination that could reasonably be expected to have been derived from many of the potentiallycontaminating activities reported in the Stage 1 investigation. Although it is recognised that the objectiveof the assessment was not to characterise the environmental condition of the Development Area inaccordance with guidelines endorsed by NSW EPA, it is obvious that the closer any assessment comesto meeting the EPA's guidelines, the more confidence can be placed on the drawing of technically viableand environmentally justifiable conclusions in regard to the suitability of the Site for a specific use.

The NSW EPA (1995) Sampling Design Guidelines state that the minimum number of samplinglocations required to detect a contamination "hot spot" on a site of 1 ha in area is 21 locations; on a siteof 2 ha in area is 30 locations; and on a site of 4 ha in area is 50 locations. Although these numbers ofsamples would not be required at the master planning stage, comparison of the number of samplinglocations adopted by Coffey with the minimum number stated in the NSW EPA guidelines indicates thatthe number of sampling locations adopted to date is not capable of yielding adequate information of thenature and extent of contamination for the previous master plan.

Non-Development Area

The rationale for adoption of the sample locations in the Non-Development Area was not adequatelyjustified and although it was clear why some locations were adopted (eg. adjacent to underground fuelstorage tanks), most locations were not justified.

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3.2.4 Suitability of field methods

Coffey's report did not present appropriate detail to allow an independent assessment of the reliability ofthe field quality control procedures, sample collection, handling, documentation and the field screeningmethod used to detect the presence of volatile organic compounds (VQCs). However, informationpresented in various parts of the report indicated that the field methods were probably suitable for thepurpose of the assessment, except where bores had been used in parts of the Site where major fillinghad taken place to depths ranging to 11 m below the present ground level.

It is strongly preferred to collect samples of heterogeneous fill materials using an excavator, butgenerally this method is suitable only to depths of less than 6 m. Samples collected from the excavatorbucket allow the nature of the fill materials to be assessed far better than samples collected from smalldiameter bores using a standard penetration testing (SPT) sampler. which was employed by Coffey forthe investigation. In collecting samples from depths exceeding that possible with an excavator, samplesare commonly collected using a large-diameter drilling using a casing advancing system.

It is considered that the sample collection methods employed for the assessment were not appropriateto allow the detection of asbestos at depth in heterogeneous fill materials.

3.2.5 Suitability of chemicals of potential concern

The chemicals of potential concern adopted were adequate for the purpose of the assessment.However, the number of samples actually analysed for these chemicals was inadequate, as discussedbelow.

Development Areas

The number of samples analysed from the Development Areas was as follows:

• Glover/Church Street Precinct (approximately 2 ha in area) - 3 samples analysed forheavy metals petroleum hydrocarbons, BTEX compounds (benzene, toluene,ethylbenzene, xylenes) and PAHs.

• Broughton Hall Precinct (approximately 1 ha in area) - 1 sample analysed for allchemicals of potential concern and 2 samples analysed for heavy metals, petroleumhydrocarbons and PAHs.

• Balmain Road Precinct (approximately 4 ha in area) - 1 sample analysed for allchemicals of potential concern, except BTEX compounds and 1 sample analysed forheavy metals, petroleum hydrocarbons and PAHs.

• Manning Street Precinct (approximately 1 ha in area) - no samples analysed.

It is considered that the number of samples analysed from the four Development Areas was inadequateto allow even a preliminary understanding of the presence of contamination in these areas and wasincapable of indicating the likely lateral or vertical distribution of contamination.

Again, it is considered that it is not possible to arrive at any conclusions relating to constraints presentedby contamination for the Manning Street Precinct where sampling was not conducted.

Given that the fill materials were described by Coffey as "heterogeneous" and "the constituents of the fillmaterial varied between boreholes", it is considered that a large number of samples would be requiredto establish the environmental condition of these materials.

Coffey also stated that "Groundwater inflow was observed in a number of boreholes in and adjacent tothe Potential Development Areas mostly just above the sandstone bedrock, suggesting that water is

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ponding and/or seeping over the sandstone bedrock". The implication of this statement is thatstormwater is able to infiltrate through the fill materials and has potential to mobilise contaminants.

Ultimately, it is considered that contaminated groundwater would migrate to Iron Cove and it was for thisreason that the quality of seepage groundwater and permanent groundwater adjacent to Iron Coveshould have been assessed as part of the investigation.

Non-Development Areas

The two principal areas of concern identified on the Site by Coffey were the major filled areas and theapplication of ash to gardens and lawns across the Site.

The major filled areas and the number of sample locations were as follows:

• Lower Glover Street Oval - 3 bores, with 3 samples analysed.

• Area between Lower Glover Street Oval and Repatriation Oval - no bores.

• Repatriation Oval- 1 bore, with 1 sample analysed.

• Area between Repatriation Oval and Callan Point - 1 bore, with 1 sample analysed.

• Area between Repatriation Oval and North Crescent - no bores.

• Area between North Crescent and Electricity Sub-station - 2 bores, with 2 samplesanalysed.

Opinion on adeguacy of sampling

It is considered that the number of samples analysed from the major filled areas was inadequate to alloweven a preliminary understanding of the presence of contamination in these areas and was incapable ofindicating the lateral or vertical distribution of contamination. Consequently, it was not possible to obtainan understanding of the nature and extent of potential remedial works in these areas.

It is considered that a comprehensive sampling and analysis plan should have been adopted for themajor filled areas, at least some of which were identified to have been used for disposal of hospitalwaste and waste from other unknown sources.

Other potential contaminating activities identified in the Stage 1 investigation were not assessed by theStage 2 investigation. These include application of pesticides and herbicides on bowling and golfgreens, contamination from paint and asbestos adjacent to buildings, contamination around dangerousgoods and chemical stores, electrical transformers and workshops, and application of pesticides aroundand beneath buildings. It is agreed that many of these matters would be of localised extent and can bedealt with at a later stage of site investigation, but it is considered that these matters should have beenaddressed by an appropriate level of investigation at the master planning stage to demonstrate theoverall environmental condition across the Site.

It is also considered that issues identified in the Stage 1 investigation that have an emotive impactshould have been addressed by investigation at the master planning stage. For example, the Stage 1investigation described "a poisonous chemicals storage shed is located next to the Gardeners shed.This is predominantly used to store herbicide and protective equipment waste that was used by staff tocollect asbestos". Because the nature, origin, quantity and use/s of the "poisonous chemicals" and"protective equipment waste" were not identified, it is considered, given the description of the contents ofthe shed, that an appropriate level of Investigation should have been completed in this area in the Stage2 investigation at the master planning stage.

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Similarly, the Stage 1 investigation identified that "hospital rubbish" was disposed on the Site and thatthere was uncertainty whether "clinical waste" was disposed on the Site. It is considered that thediscovery of clinical waste, if present, during the development of the Site would have a serious socialand possibly health impacts and that this matter should have been addressed by an appropriate level ofinvestigation.

3.2.6 Suitability of laboratory methods

The laboratory analytical methods employed by the NATA registered commercial laboratory, AustralianLaboratory Services (ALS), were in accordance with the requirements of NSW EPA (1997) and weresatisfactory to achieve the objectives of the assessment.

It is noted, however, that a second NATA registered laboratory was not employed to analyse splitduplicate samples and that this was not in accordance with requirements of NSW EPA (1997).Consequently, it is not possible to independently verify the accuracy and precision of all of the resultsreported by ALS. However, a lower level of reliability is acceptable for the purposes of the preliminaryinvestigation.

3.3 Results of investigation

3.3.1 Development Areas

Fill materials were identified on each of the three Developmeht Areas on which samples were collected.Coffey stated the fill materials generally ranged in thickness from less than 0.5 to 2 m, but that the fill onthe Broughton Hall Precinct was up to 5.6 m in thickness.

To characterise the environmental condition of fill materials requires that samples of each fill typeidentified in the bore be tested for the chemicals of potential concern. For example, the log for bore BH9in the Broughton Hall Precinct identified six fill types to be present, but only two of the fill types weretested. The log also noted that the presence of asbestos containing materials was tested for only in onenear surface sample (0 to 0.5 m) so it is unknown whether asbestos is present within the bulk of the fillmaterial.

Even though the results reported were inadequate to allow for the assessment of the nature and extentof contamination in the four Potential Development Areas, contamination by copper and PAHs wasidentified on the Broughton Hall Precinct.

It was noted from inspection of the bore and hand auger logs in Coffey's report that many samplesappeared to have been collected from across the boundary of the fill materials and underlying naturalsoil. If the underlying natural soil was uncontaminated, as would be expected on the Hospital site,results of analyses of the samples collected would underestimate the levels of contamination in thesesamples.

In addition, hand auger HA16 on the Balmain Road Precinct terminated in fill materials, so that thevertical extent of fill material in this location was not determined. This was unfortunate, as this was oneof only two locations tested in this large precinct that was proposed for residential development.

It is considered that the samples analysed were not adequate to identify potential constraints or risksthat may be associated with contamination on the Development Areas.

3,3.2 Non-Development Areas

At the few locations where samples were collected and analysed from the major filled areas, significantcontamination by arsenic, copper, lead, mercury, zinc, petroleum hydrocarbons and PAHs wasidentified. In the major filled areas, asbestos was tested for in only three samples.

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It is considered that the high levels of petroleum hydrocarbons and heavy metals and elevated levels ofPAHs identified at the groundwater table in fill materials in the Lower Glover Street Oval indicate thehigh probability of remediation being required in this area. The contamination in this area was present atsome 9 m below the present ground level and, if excavation is required, this would present a significantconstraint to development of this part of the Site.

Given the proximity of the major filled areas to Iron Cove it is very probable that groundwater within thefilled areas would be contaminated and would be migrating to Iron Cove. If the groundwater iscontaminated, remediation and/or management would be required. Remediation of groundwater is asignificant issue, particularly if the source contamination is located in proximity to Iron Cove.

It is considered that the remediation of the major filled areas could represent a significant constraint toredevelopment of the Site and should have been addressed in more detail by Coffey. However, as theLower Glover Street and Repatriation Ovals are located remote from the developed areas of the Site, itis considered that remedial or management works that may be required could be undertakenindependently of development works on the remainder of the Site.

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4.0 EES report

4.1 Purpose of the EES report

The EES report was prepared for Landcom as part of the program of due diligence being undertaken", "prior to the purchase of this significant site",

It is envisaged that Landcom would have considered development of the Site to have included a largeproportion of residential land use,

4.2 Objective

With respect to the environmentai condition of the Site, the EES report was undertaken principally to:

• provide a review of the Coffey reports;

• assess the risk associated with contamination identified at the Site;

• assess whether additionai investigation was required; and

• provide an estimate of costs associated with remediation and removal of asbestoscontaining materiais,

EES did not undertake sampiing or analysis of any samples from the Site,

4.3 Key environmental issues

The EES report identified key environmental issues to undertake:

• engagement of a site auditor accredited by NSW EPA to "",review the data that hasbeen collected to date and establish with certainty the scope of further works" ,"

• "",a more detailed site contamination assessment";

• a program of groundwater monitoring that "",wili be critical in establishing thelikelihood of contamination movement from the site (especially from the Lower GloverStreet and repatriation Parks) and possible impacts on environmental receptors(such as Sydney Harbour aquatic ecosystems)";

• a site-specific human health and environmental risk assessment (HERA) after"sufficient contaminant characterisation has been undertaken" to provide risk-basedcriteria for potential remedial works;

• an audit of hazardous materials in buildings that are proposed to be demolished orrenovated; and

• remedial works that "",will be required at the site", but the scope of the works wouldbe "" ,based on a number of factors, most importantly the risk assessment and therequirements of the site auditor"; and

• preparation of an Environmentai Management Plan (EMP) that "",will be required sothat the site is managed after the land has been transferred and during the site

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, .

development in a manner that will not cause an adverse impact on human health orthe environment".

With respect to the remedial works envisaged by EES, the following were considered to be required:

• removal of the underground storage tanks and any associated contaminated soil;

• removal of contaminated soil that is "...unacceptable for the purpose of the proposedsite usage";

• "In some areas capping and containment of contaminated soil may be required";

• "Remediation of groundwater may also be required if unacceptable levels ofcontaminants are detected".

4.4 Remedial options for fill materials

The EES report considered "The details in the environmental assessments that have been undertakento date to is insufficient to allow fixed estimates to be made regarding the scope or costs of necessaryremediation or site management", the following remedial options were considered "...could address theidentified (and predicted) contamination issues":

• Option A - "Complete removal of all contaminated soil";

• Option B - "Removal and replacement of the top 500 mm of cover, coupled with ahuman health and ecological risk assessment";

• Option C - "Undertake a human health and ecological risk assessment with (ifrequired) selective hot spot removal".

The EES report provided a screening of the remedial options by consideration of general responseactions, the remediation technology and considered the advantages and disadvantages relating to eachoption, but did not reach a conclusion as to the preferred option due to the preliminary nature of theenvironmental assessment undertaken to date.

Cost estimates were provided for the three remedial options, as follows:

• Option A - $56 million

• Option B - $19 million;

• Option C - $6 million.

However, the cost estimates were heavily qualified, principally due to the inadequate assessment of theenvironmental condition of the Site.

The EES reports did not address remediation or management of groundwater.

Opinion relating to remedial options and cost estimates

It is considered that Options A and B are unsuitable for implementation at the Site and would not berequired to address contamination of the nature identified by Coffey or that would be expected to bepresent at the Site and that the results of the limited assessment undertaken by Coffey do not indicatethat such excessive measures would be required.

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With respect to Option C, the greatest cost was for disposal of soil from below proposed buildingfootprints in the Development Area where "Only IPCU building has recorded soils considered to beunacceptable for the proposed land use". At the time of the EES report, this part of the Site was beingproposed for residential land use and results of chemical analyses were compared to HIL A levels,however, it is now considered that the use would be for purposes the same as or similar to the existingand that less stringent HIL F criteria would apply. In the vicinity of the IPCU building no contaminationwas identified in surface soils and impact by PAHs at a depth of approximately 5 m below the groundsurface was less than HIL F levels relating to land used for commercial or industrial purposes. Inaddition, even if this part of the Site was used for residential purposes, the identified contamination isless than the HIL D levels that would apply.

Consequently, it is considered that the majority of the $5.4 million cost estimate for remediation Option Cwould not be required.

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5.0 Conclusion

5.1 Preliminary investigation

The preliminary investigations undertaken by Coffey confirmed that the Site is characterised by acomplex history of use for industrial purposes dating back over some 150 years. It can be confidentlystated that during the operation of the Site, measures to protect the environment according to standardsacceptabie today would not have been employed and that contamination of soil and groundwater on theSite would be expected.

A notable characteristic of the Site is the widespread presence of fill materials, which include waste fromthe hospital and other materials from unknown sources. Severai parts of the Site contain large areas ofdeep filling (landfills), with waste materials identified to depths up to 11 m below the present groundlevels. The fill materials, although not adequately characterised to date, contain contamination by heavymetals, petroleum hydrocarbons and PAHs and in addition given the unidentified sources of the fillmaterials, it is considered likely that other types of contamination are also present.

The Coffey investigations documented a number of uncertainties relating to the uses of specific parts ofthe Site, including the disposal of waste materials. Although the major waste disposal sites haveprobably been identified by Coffey, there is a high probability of other disposal sites being presentelsewhere on the Site.

It is clear that the preliminary investigations undertaken by Coffey were not of adequate scope to haveidentified all contamination that may be present at the Site. Nevertheless, the results identifiedcontaminated fill materials to be present at a number of locations across the Site, as expected on a sitethat has been used as a hospital for a long time.

5.2 Requirement for additional assessment

5.2.1 Environmental assessment

It is considered that additional assessment of the environmental condition of fill materials andgroundwater is required to be undertaken across the Site, but it is considered that this can beaccomplished in a staged manner during the early stages of development of specific parts of the Site.

Assessment of the environment condition of groundwater within the filled parts of the Site, andparticularly in the major filled areas of the Lower Glover Street and Repatriation Ovals, should beundertaken on a Site-wide basis during the earliest stage of development on the Site.

5.2.2 Hazardous materials survey

A survey of hazardous materials within buildings across the Site is required to be undertaken and it isconsidered that this can be undertaken in a staged manner during the early stages of development ofspecific parts of the Site.

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5.3 Management of contamination issues

5.3.1 Fill materials

Whilst it is considered that significant contamination "hot spots" may be best addressed by excavationand disposal to a iandfill licensed by NSW EPA to receive the appropriate class of waste, themaintenance of the Site under the control of one entity allows for appropriate relocation of impacted soilsfrom one part of the Site to another, as development requires, and for their management subject to theterms of a long-term Environmental Management Plan.

The use of the part of the Site referred to by Coffey as the Development Area for community purposes,which are less sensitive than the residential use proposed in the former Master Plan, will result in muchless remediation, if any, being required in this part of the Site. If residential use for part of the Site wasrequired it is considered that this could be undertaken by removal of any impacted materials to lesssensitive parts of the Site or they could potentially remain in place at depth, subject to the terms of along-term Environmental Management Plan which would manage exposure to the impacted materials.

The remote locations of the areas of principal environmental concern on the Site, the landfilled areas ofthe Lower Glover Street and Repatriation Ovals, results in these areas being able to be addressedindependently of the other parts of the Site. The assessment undertaken to date by Coffey indicated theOvals in their current condition are suitable for use as playing fields, additional investigation, particularlyrelated to the quality of groundwater but also of the nature of the fill materials, is required to beundertaken at the earliest opportunity during development of the Site. For continued use as playingfields, it is considered that only maintenance of the surface cover is required, and that any contaminationidentified at depth within the fill materials would be managed subject to the terms of a long-termEnvironmental Management Plan to protect the health of users of the playing fields.

5.3.2 Groundwater

It is considered that there is a high probability that groundwater, particularly in the north-western partwithin major fill areas, will be identified to be contaminated. Whilst the contaminants that couldreasonably be expected to be present in the groundwater would not pose a risk of harm to users of theSite, if the contamination is identified to be significant and to be migrating from the Site to Iron Cove,measures would be required to be implemented to prevent the migration.

Measures that could be implemented include installation of a cut-off wall and collection and treatment ordisposal of contaminated water and/or identification and excavation of significant contamination "hotspots" that give rise to contamination of groundwater. It is not considered that excavation and disposal ofthe bulk of the fill materials to an off-site landfill would be required.

It is considered that the additional investigation and installation of remedial or management measures atthe Ovals could be undertaken independently of development elsewhere on the Site.

5.3.3 Underground storage tanks

The contents of the four underground fuel storage tanks on the Site should be identified during theearliest stage of development on the Site. If the tanks are identified to have not been decommissioned inaccordance with the requirements of WorkCover NSW, the tanks, associated fittings and anycontaminated soil should be removed at the earliest time practicable to minimise the potential for ongoing contamination of soil and potential contamination of groundwater.

5.3.4 Buildings

Asbestos materials, heavy metal-based paints, PCBs and the like identified in buildings across the Sitethat could give rise to contamination of the soil or to pose an unacceptable risk to occupiers or users,should be removed from the Site.

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5.4 Management of the Site

It is considered that the control of the Site by one entity, such as the University of Sydney, would allow along-term Environmental Management Plan to be implemented successfully to manage contaminationissues across the Site and that contamination at depth that does not significantly contaminategroundwater could safely remain in place.

In addition, given the large size of the Site, its control under one entity allows impacted materials to bemoved from one part of the Site to another for safe management subject to the terms of a long-termEnvironmental Management Plan.

In summary, notwithstanding the contamination issues identified during the preliminary assessment andthe presence of contamination that could reasonably be expected to be present on the Site, it isconsidered that issues relating to contaminated fill materials and groundwater could be addressedsatisfactorily in a staged manner during any development of the Site in accordance with this MasterPlan.

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Appendix A: Figures from Coffey Report

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